Notice (2021-06-24)

Summary

Defendant's Exhibit List filed November 1, 2021 as Document 31 in Together Employees v. Mass General Brigham, Incorporated, Civil Action No. 1:21-cv-11686, in the U.S. District Court for the District of Massachusetts. The list describes 52 exhibits. The first exhibits are MGB communications and policies on the COVID-19 vaccine requirement for employees, including a June 24, 2021 communication and a September 8, 2021 updated HR vaccination policy, along with an Annals of Internal Medicine article and a joint statement supporting vaccine mandates for health care workers. The remaining exhibits are the exemption request forms submitted by the individual plaintiffs and MGB emails requesting more information or stating that the requests had been denied. The list ends with a certificate of service signed by Katherine A. Perrelli.

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         Case 1:21-cv-11686-FDS Document 31 Filed 11/01/21 Page 1 of 5




                         UNITED STATES DISTRICT COURT
                       FOR THE DISTRICT OF MASSACHUSETTS

                                    )
TOGETHER EMPLOYEES, by Individual   )
Representatives, ROBERTA LANCIONE,  )
JOYCE MILLER, MARIA DIFRONZO,       )
MICHAEL SACCOCCIO, ELIZABETH BIGGER,)
NATASHA DICICCO, NICHOLAS ARNO and  )
RUBEN ALMEIDA,                      )                 Civil Action No. 1:21-cv-11686
                    Plaintiffs,     )
v.                                  )
                                    )
MASS GENERAL BRIGHAM, INCORPORATED. )
               Defendant.           )
                                    )
                                    )
                                    )

                                 Defendant’s Exhibit List

Exhibit 1.    June 24, 2021 MGB Communication COVID-19 Vaccine Requirement for
              Employees

Exhibit 2.    August 10, 2021 MGB Communication A Message from Anne Klibanski, MD

Exhibit 3.    September 29, 2021 MGB Communication Advanced Notice: Employees will be
              vaccine compliant with first dose of Moderna or Pfizer by October 15

Exhibit 4.    September 8, 2021 Updated MGB HR COVID 19 Vaccination Policy

Exhibit 5.    The Case for Mandating COVID-19 Vaccines for Health Care Workers, Annals of
              Internal Medicine

Exhibit 6.    Joint Statement in Support of COVID-19 Vaccine Mandates for All Workers in
              Health and Long-Term Care

Exhibit 7.    COVID Vaccine Medical Exemption Request Form 2021

Exhibit 8.    October 22, 2021 Vaccine Policy

Exhibit 9.    August 11, 2021 Maria DiFronzo Medical Exemption Request

Exhibit 10.   August 24, 2021 MGB email to Maria DiFrozono that her request for medical
              exemption from the vaccination requirement had been denied

Exhibit 11.   September 2, 2021 Roberta Lancione Medical Exemption Request
         Case 1:21-cv-11686-FDS Document 31 Filed 11/01/21 Page 2 of 5




Exhibit 12.   September 9, 2021 MGB email to Roberta Lancione that her request for medical
              exemption from the vaccination requirement had been denied

Exhibit 13.   August 17, 2021 Joyce Miller Medical Exemption Request

Exhibit 14.   September 9, 2021 MGB email to Joyce Miller that her request for medical
              exemption from the vaccination requirement had been denied

Exhibit 15.   August 19, 2021 Michael Saccoccio Medical Exemption Request

Exhibit 16.   September 9, 2021 MGB email to Michael Saccoccio that his request for medical
              exemption from the vaccination requirement had been denied

Exhibit 17.   September 13, 2021 Michael Saccoccio email supplementing his Medical
              Exemption Request

Exhibit 18.   September 17, 2021 Michael Saccoccio med letter further supplementing his
              Medical Exemption Request

Exhibit 19.   September 24, 2021 MGB email to Michael Saccoccio confirming that his request
              for medical exemption from the vaccination requirement had been denied

Exhibit 20.   Flu and COVID-19 Religious Exemption Form 2021

Exhibit 21.   September 1, 2021 Ruben Almeida Religious Exemption Request

Exhibit 22.   September 10, 2021 MGB email requesting additional information from Ruben
              Almeida

Exhibit 23.   September 12 2021 Ruben Almeida email response to MGB’s request for
              additional information

Exhibit 24.   September 23, 2021 MGB email notification to Ruben Almeida that his request
              for a religious exemption from the vaccination requirement had been denied

Exhibit 25.   August 24, 2021 Nicholas Arno Religious Exemption Request

Exhibit 26.   September 4, 2021 MGB email requesting additional information from Nicholas
              Arno

Exhibit 27.   September 7, 2021 Nicholas Arno email response to MGB’s request for additional
              information

Exhibit 28.   September 14, 2021 MGB email notification to Nicholas Arno that his request for
              a religious exemption from the vaccination requirement had been denied

Exhibit 29.   September 3, 2021, Elizabeth Bigger Religious Exemption Request




                                             2
         Case 1:21-cv-11686-FDS Document 31 Filed 11/01/21 Page 3 of 5




Exhibit 30.   September 10, 2021 MGB email requesting additional information from Elizabeth
              Bigger

Exhibit 31.   September 13, 2021 Elizabeth Bigger email response to MGB’s request for
              additional information

Exhibit 32.   September 14, 2021 MGB email notification to Elizabeth Bigger that her request
              for a religious exemption from the vaccination requirement had been denied

Exhibit 33.   September 2, 2021 Natasha DiCicco Religious Exemption Form

Exhibit 34.   September 10, 2021 MGB email requesting additional information from Natasha
              DiCicco

Exhibit 35.   September 10, 2021 Natasha DiCicco email response to MGB’s request for
              additional information

Exhibit 36.   September 14, 2021 MGB email notification to Natasha DiCicco that her request
              for a religious exemption from the vaccination requirement had been denied

Exhibit 37.   September 1, 2021 Maria DiFronzo Religious Exemption Form

Exhibit 38.   September 10, 2021 MGB email requesting additional information from Maria
              DiFronzo

Exhibit 39.   September 13, 2021 Maria DiFronzo email response to MGB’s request for
              additional information

Exhibit 40.   September 14, 2021 MGB email notification to Maria DiFronzo that her request
              for a religious exemption from the vaccination requirement had been denied

Exhibit 41.   September 3, 2021, Roberta Lancione Religious Exemption Form

Exhibit 42.   September 9, 2021 MGB email requesting additional information from Roberta
              Lancione

Exhibit 43.   September 12, 2021 Roberta Lancione email response to MGB’s request for
              additional information

Exhibit 44.   September 16, 2021 MGB email notification to Roberta Lancione that her request
              for a religious exemption from the vaccination requirement had been denied

Exhibit 45.   August 20, 2021 Joyce Miller Religious Exemption Form

Exhibit 46.   September 4, 2021 MGB email requesting additional information from Joyce
              Miller

Exhibit 47.   September 7, 2021 Joyce Miller email response to MGB’s request for additional
              information


                                             3
         Case 1:21-cv-11686-FDS Document 31 Filed 11/01/21 Page 4 of 5




Exhibit 48.   September 14, 2021 MGB email notification to Joyce Miller that her request for a
              religious exemption from the vaccination requirement had been denied

Exhibit 49.   August 22, 2021 Michael Saccoccio Religious Exemption Form

Exhibit 50.   September 2, 2021 MGB email requesting additional information from Michael
              Saccoccio

Exhibit 51.   September 7, 2021 Michael Saccoccio email response to MGB’s request for
              additional information

Exhibit 52.   September 11, 2021 MGB email notification to Michael Saccoccio that his
              request for a religious exemption from the vaccination requirement had been
              denied




                                              4
          Case 1:21-cv-11686-FDS Document 31 Filed 11/01/21 Page 5 of 5




                                 CERTIFICATE OF SERVICE

        I hereby certify that on November 1, 2021, a copy of the foregoing document was filed
electronically through the Court’s electronic filing system (“ECF system”) and that counsel for
Plaintiffs is a registered user of the ECF system. Notice of this filing will be sent by operation of
the Court’s ECF system to all parties indicated on the electronic filing receipt. Parties may
access this filing through the Court’s ECF system.

                                              /s/ Katherine A. Perrelli
                                              Katherine A. Perrelli


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