| 1 |
“Cox provided Mr. Coates with extensive accommodations.” |
Azariah Workman, HR, Supervisor, Compliance Team |
Direct systems evidence (Workday/HR logs);
Third-party corroboration;
Internal communications
|
42 U.S.C. § 12112(b)(5)(A) |
Produce all records of “extensive” accommodations or sworn affidavit. If not, statement should be stricken and adverse inference applied. |
| 2 |
“Mr. Coates refused to return to work.” |
Azariah Workman, Supervisor, HR, Legal Counsel |
Direct systems evidence (STD claim records, HR logs);
Third-party corroboration;
Internal communications
|
29 C.F.R. § 825.311(c) |
Produce documentation of refusal or sworn affidavit. If not, statement should be stricken and adverse inference applied. |
| 3 |
“Cox was unaware of any disability claim or need for accommodation prior to disciplinary action.” |
Azariah Workman, HR, Supervisor, Payroll |
Direct systems evidence (notification logs, HRIS entries);
Third-party corroboration;
Internal communications
|
42 U.S.C. § 12112(b)(5)(A) |
Produce proof of lack of notice or sworn affidavit. If not, statement should be stricken and adverse inference applied. |
| 4 |
“No medical documentation was ever provided to support Mr. Coates’ absences.” |
HR, Azariah Workman, Benefits Team |
Direct systems evidence (uploaded docs, HRIS, claim files);
Third-party corroboration;
Internal communications
|
29 C.F.R. § 825.302(c) |
Produce documentation or sworn affidavit. If not, statement should be stricken and adverse inference applied. |
| 5 |
“Absences in June were unexcused and subject to corrective action.” |
Azariah Workman, Supervisor, HR |
Direct systems evidence (approved leave logs, STD claim data);
Third-party corroboration;
Payroll records
|
29 C.F.R. § 825.220(c) |
Produce evidence of unexcused absence or sworn affidavit. If not, statement should be stricken and adverse inference applied. |
| 6 |
“Cox fully cooperated with all disability claims and requests.” |
HR, Azariah Workman, Compliance, Benefits Team |
Direct systems evidence (response logs, claim files);
Third-party corroboration;
Internal communications
|
29 C.F.R. § 1630.2(o)(3) |
Produce documentation of cooperation or sworn affidavit. If not, statement should be stricken and adverse inference applied. |
| 7 |
“No documentation was ever provided to Cox.” |
HR, Azariah Workman, Benefits Team, Supervisor |
Direct systems evidence (uploaded files, claim records);
Third-party corroboration;
Internal communications
|
42 U.S.C. § 12112(b)(5)(A) |
Produce documentation or sworn affidavit. If not, statement should be stricken and adverse inference applied. |
| 8 |
“Return-to-work date was not communicated.” |
Supervisor, HR, Azariah Workman |
Direct systems evidence (claim closure, RTW notices);
Third-party corroboration;
Internal communications
|
29 C.F.R. § 1630.2(o)(3) |
Produce evidence of lack of notice or sworn affidavit. If not, statement should be stricken and adverse inference applied. |