DISCOVERY IS MY FRIEND

Discovery Will Prove

 

  1. Failure to Provide Required Safety Mats

Discovery will prove hershey knew mats were required.

  Hershey had mats available.

  Hershey chose not to provide them.

   Their own doctor linked my injury to    prolonged standing without mats.

   2. Failure to Provide Reasonable Disability Accommodation

Discovery will prove I notified them of neuropathy.

 Supervisors documented my limitations.

They had multiple low-impact positions available.

Hershey chose not to accommodate my disability.

3. Refusal to File an Injury Report Discovery will prove:

I showed the wound.

Managers documented seeing it.

The company had a legal duty to file.

Hershey chose not to file an injury report.

Lee Timmons chose to reclassify the injury as a neuropathy issue, not work-related.

Discovery will show their own doctor documented the injury was caused by 12 hours on concrete without required rubber mats.

4. Denial of Medical Treatment Discovery will prove:

I requested medical assistance multiple times.

HR and safety staff documented my requests.

Medical treatment was available and required.

Hershey chose not to provide any medical treatment as the injury worsened.

 

5. Targeted Assignment to the Only Station Without Mats Discovery will prove:

My line had 15+ workers available to rotate.

4 out or 5 stations had mats.

I was repeatedly assigned to the 1 unpadded station. A 1 man station that rotated every 3 hours. 4 rotations 4 people

Hershey chose to rotate me into the one position without mats repeatdly.

It was the easiest job on the line and others wanted it, yet Lee repeatedly assigned me to that one unprotected position and did not allow me to trade out.

6. Time-Theft Pay Scheme

Discovery will prove:

Workers were required to clock in before donning and sanitizing, and clock out before changing back into street wear.

Managers enforced this rule under threat of discipline.

Minutes were taken from every shift across the line.

Discovery will provide a list of employees who were victimized by this practice daily.

Hershey chose not to follow wage‑law requirements designed to protect workers.

 

7. Contradictions Inside Their Own Medical Documentation Discovery will prove:

Hershey moved me from production to a forklift to help relieve pressure on my foot — only to place me on a stand‑up forklift, which increased strain and worsened the injury.

 

8. Stand-Up Forklift Assignment While Injured Discovery will prove:. Stand-Up Forklift Assignment While Injured Discovery will prove:

They knew I had foot trauma.

They documented my limitations.

Stand‑up forklifts put direct pressure on the injured area.

9. Contradictions Inside Their Own Medical Documentation Discovery will prove:

Their own doctor wrote that my injury was caused by prolonged standing on concrete without mats — a direct acknowledgment of unsafe working conditions.

The OSHA reporting section in the same packet marks the injury as not work-related.

These two statements cannot both be true, yet Hershey submitted them together as if they were.

This isn’t a clerical error — it’s a corporate contradiction that hides responsibility while admitting the cause.

Hershey chose not to correct, clarify, or reconcile this conflict, even though they had full access to the doctor’s findings.

The only reason I even received this copy 158 days after the exam is because I went in and picked it up myself — not because Hershey provided it.

This contradiction will become a centerpiece of discovery, because it exposes both the unsafe conditions and the attempt to deny them.

10. Witnesses and Additional Victim Testimony will be provided by disvovery.

Multiple coworkers witnessed my injury, the worsening condition, the unfair assignments, and the retaliation.

Discovery will provide the full list of these witnesses.

It will also reveal the name of a coworker who fell down the stairs carrying heavy totes, required surgery, and returned to work ready to do his job.

Instead of paying him the same rate as others performing identical work, Hershey chose to underpay him — effectively forcing him to quit.

Discovery will provide his name and confirm his story, adding another example of how Hershey treats injured workers.

 

11. Pattern of Retaliation and Unsafe Culture Discovery will prove:

Hershey’s responses to injuries follow a predictable pattern: deny, minimize, reclassify, and push the worker out.

Training records, safety audits, and internal emails will show this culture existed long before my case.

Discovery will reveal whether similar injuries were brushed aside, misclassified, or ignored.

This could establish a broader pattern that supports every claim made in The Hershey Thing.

 

12. Exposure of OSHA Reporting Failures Discovery will prove:

Hershey’s handling of my injury — especially the contradiction between the doctor’s statement and the OSHA classification — may expose broader OSHA-reporting violations.

Emails, safety logs, and internal communications will reveal who marked my injury “not work-related” and why.

Discovery will show whether similar injuries were misclassified to avoid reporting requirements.

This may expose a pattern of conduct that violates federal safety laws.

 

13. Pattern of Retaliation and Unsafe Culture Discovery will prove:

Hershey’s responses to injuries follow a predictable pattern: deny, minimize, reclassify, and push the worker out.

Training records, safety audits, and internal emails will show this culture existed long before my case.

Discovery will reveal whether similar injuries were brushed aside, misclassified, or ignored.

This could establishe a broader pattern that supports every claim made in The Hershey Thing.

14. Exposure of OSHA Reporting Failures Discovery will prove:

Hershey’s handling of my injury — especially the contradiction between the doctor’s statement and the OSHA classification — may expose broader OSHA‑reporting violations.

Emails, safety logs, and internal communications will reveal who marked my injury “not work‑related” and why.

Discovery will show whether similar injuries were misclassified to avoid reporting requirements.

This may expose a pattern of conduct that violates federal safety laws.

 

15. Exposure Through Cross‑Comparison of Employee Injuries Discovery will prove:

Other workers’ injury records show the same pattern: denial, reclassification, non‑reporting.

When these cases are viewed together, the pattern becomes undeniable.

Discovery will confirm if this was or wasn’t an isolated mistake — it was how Hershey handled injured workers.