TIMELINE FOR DISABILITY AND DISCRIMINATION CASE
This is the timeline for my disability and discrimination case against the Persona Kidney Care.
| DATE/TIME | SOURCE | FACTS |
| 01/012020 | PERSONAKidney Care Teammate Policies | This document provides a summary of the Defendant’s policies. |
| 29/04/2020 | Start Date and Location Email | On this Email, I informed the Defendant that I had sent a notice of resignation to my former employer. The Defendant acknowledged my Email and promised to send the Offer letter. |
| 13/05/2020 | Completion of Background Process | On this Email Communication to the Defendant, I informed the Defendant that I had completed all background processes. On the same day, the Defendant informed me that I had been approved to join the DaVita Kidney Care. |
| 05/06/2020 | Offer letter from DaVita Kidney Care | The Defendant sent me this letter confirming my offer of a full-time employment as a Social Worker (MSW) II. The Defendant set my compensation at $67,000, subject to relevant deductions. Notably, the employment was at-will. |
| 12/06/2020 | New Hire: Flustered | The Defendant responded to my concerns sent earlier pertaining to the decision of the Defendant to transfer me to the Mt. Rainer site, which is a hostile environment. |
| 15/06/2020 | Grievance and Request for Accommodation | In this letter, I expressed my concerns regarding the Defendant’s decision to change my secondary work location from Glenarden. The said change increased my workload. I also informed the Defendant that I suffered from anxiety and depression. Accordingly, I specifically requested for a transition plan, an advanced notice of any upcoming work changes, improved communication, improved transparency, and improved access to equipment. |
| 20/07/2020 | Attorney’s Letter to the Defendant | In this letter, my former attorney sent the Defendant a letter demanding the Defendant to accommodate me for my disability. |
| 07/01/2020 | Notice of Challenges after transfer | In this correspondence, I informed Defendant of the challenges I faced pursuant to the transfer of my work-location. |
| 10/07/2020 | Denial of Accommodation | The Defendant sent me correspondence informing me that they are unable to ensure accommodation to me pursuant to my Grievance and Request for Accommodation. |
| 03/09/2020 | Letter showing details of Team meeting | In this letter, I outlined the activities of the team meeting held on September 3, 2020. |
| 15/09/2020 | Limited Access to the Defendant’s applications | This letter concerned my lack of full access to needed clinical applications (Falcon) to complete my full duties. |
| 24/09/2020 | EEOC- Maryland Commission on Human Rights | Here, I filed a charge of discrimination against the Defendant. In the said Complaint, I raised concerns how the Defendant transferred me to another location, terminated my training abruptly, and discontinued my contact with patients. |
| 8/10/2020 | Letter on Meeting Conflicts | In this letter, the Defendant’s Communications Director discussed meeting conflicts with me. |
| 22/10/2020 | Letter from Mental Health Provider | In this letter, my mental health provider notified the Defendant of my progress while under their care. |
| 11/11/2020 | Meeting time Conflicts | In this letter, I expressed my concerns over meeting time. |
| 13/11/2020 | Medical Letter on the changing of meeting times | In this letter, I expressed concerns over the FA’s decision to change and/or extend meeting times. |
| 18/11/2020 | Correspondence showing the challenges I faced at the Defendant’s facility | In this letter, I expressed my concerns to the Divisional Social Workers that I was overwhelmed by my challenges at the Defendant’s facility. |
| 18/11/2020 | Request for a Laptop | In this letter, I requested the Defendant to provide me a laptop because I was having a problem with my computer. |
| 20/11/2020 | Request for Transfer | In this letter, I requested the Defendant to transfer me to another location based on challenges I was facing with my teammates. |
| 30/11/2020 | Learning Plan Updates | In this correspondence, the Defendant placed me on a learning plan. |
| 13/01/2021 | Denial of Request for Transfer | In this letter, the Defendant denied to grant me my request for transfer. |
| 14/01/2021 | Correspondence showing high case load | In this correspondence, the Divisional Social Worker supported my need for extra time due to high caseload. |
| 04/02/2021 | Dr. Parris’s letter recommending further accommodation for me. | In this letter, Dr. Parris had requested the Defendant to accommodate me by limiting my time in the lobby, and patients’ area to 30 min a day. |
| 09/02/2021 | Updated Accommodation Request | In this letter, I requested further accommodation from the Defendant pursuant to the letter from Dr. Parris. |
| 09/02/2021 | Correspondence to the Divisional Social Workers showing my challenges with facility manager | In this letter, I expressed my concern over the challenges I was facing at the Defendant’s facility. |
| 19/02/2021 | Corrective Action | In this correspondence, the Defendant cited alleged instances of my violation of the Defendant’s policies. |
| 03/03/2021 | Defendant’s denial of my Request for further accommodation | In this letter, the Defendant denied to grant my request for further accommodation, which was recommended by Dr. Parris. Based on this communication the Defendant’s HR and management met with me on March 5, 2021. They then decided to follow-up with my physician with documents requesting for more information. |
| 2021 | EEOC- Maryland Commission on Human Rights | I filed another charge of discrimination against the Defendant. In the Complaint, I alleged that the Defendant had discriminated upon me based on my disability in retaliation for my engagement in a protected activity. I alleged that the Defendant had denied my request to limit the time I spent on the screening process to 30min. |
| 06/03/2021 | List of Therapy Sessions | This document shows the number of therapy sessions I attended and the expenses incurred thereat. |
| 09/03/2021 | My response to my Request for Review | In this letter, I sought a review of the Defendant’s Facility Manager’s corrective action memo. |
| 16/03/2021 | Follow up request | In this letter, I sent the Defendant additional information regarding my accommodation request. |
| 30/03/2021 | Defendant’s follow-up request | In this letter, the Defendant wrote Dr. Parris requesting for further information to show why I was entitled to accommodation. |
| 05/04.2021 | Second Denial of Accommodation | In this letter, the Defendant sent me a notice of Denial of my accommodation request(s) made on February 4, 2021. |
| 07/04/2021 | Second Letter to the Defendant’s H.R. expressing concerns about the ringer device on my door. | In this letter to the HR, I expressed my concerns about a ringer device that was placed on my door, which the Defendant alleged was for communication. The ringer device is a distraction to me, considering the busy nature of the clinic. |
| Photo of ringer device | This photo shows the ringer device on my door. | |
| 23/04/2021 | Finding of Investigation | The Defendant informed me that they had completed investigations on my complaint for discrimination and retaliation, and that they had not found any proof of retaliation or discrimination. |
| 14/09/2021 | Request for a Laptop | In this letter, I requested for a laptop to facilitate the home program. |
| 15/11/2021 | Evaluation Request | This correspondence shows communication regarding my delayed evaluation. |
| Other Supporting Documents | This collection contains documents that I relied on in making my write-up |
At Legal writing experts, we would be happy to assist in preparing any legal document you need. We are international lawyers and attorneys with significant experience in legal drafting, Commercial-Corporate practice and consulting. In the last few years, we have successfully undertaken similar assignments for clients from different jurisdictions. If given this opportunity, we will be able to prepare the legal document within the shortest time possible.