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Statement of Claims

Count I – Failure to Provide Required Safety Equipment
Defendant failed to provide mandated rubber safety mats despite written policy and training materials requiring their use.

Count II – Failure to Provide Reasonable Accommodation (ADA Violations)
Defendant was informed of Plaintiff’s neuropathy and related limitations and refused to provide reasonable accommodations as required under disability law.

Count III – Failure to File a Mandatory Injury Report
Defendant declined to document an on-the-job injury after Plaintiff reported and visibly exhibited wounds, in violation of workplace reporting standards.

Count IV – Denial of Medical Treatment / Failure to Render Aid
Defendant failed to provide basic medical attention or first aid after being notified of an active workplace injury.

Count V – Assignment to Unsafe Work Conditions
Defendant knowingly required Plaintiff to work at the only station without safety mats while numerous alternative employees were available, creating foreseeable risk of injury.

Count VI – Unpaid Required Work (Wage and Hour Violations)
Defendant required employees to don and doff protective gear off the clock, resulting in uncompensated work time and systematic underpayment.

Count VII – Retaliation for Reporting Safety Concerns
After Plaintiff raised safety and accommodation issues, Defendant engaged in retaliatory conduct contrary to federal and state protections.

Count VIII – Wrongful Termination Following Workplace Injury
Plaintiff was terminated after sustaining injuries caused by Defendant’s assignments and after reporting safety violations.

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