Defendant’s Answer to Plaintiffs’ Corrected Amended Complaint

Summary

Answer of defendant Mass General Brigham Incorporated (MGB) to the plaintiffs' corrected amended complaint in Roberta Lancione, et al. v. Mass General Brigham Incorporated, Civil Action No. 1:21-cv-11686, (D. Mass.), filed 01/21/22 as Document 63. The employees allege MGB violated Title VII and the Americans with Disabilities Act by wrongfully denying religious and disability accommodations to its COVID-19 vaccination requirement; MGB denies the allegations. MGB admits that named plaintiffs sought religious and medical exemptions and says each request was reviewed and denied by its Religious Exemption Review Committee and clinical panels, and notes earlier denials of injunctive relief. It asserts affirmative defenses including legitimate non-discriminatory reasons and failure to mitigate; the answer is signed /s/ Lynn A. Kappelman of Seyfarth Shaw LLP.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

78101496v.7
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
ROBERTA LANCIONE, et al.,
Plaintiffs,
v.
MASS GENERAL BRIGHAM
INCORPORATED,
Defendant.
Civil Action No. 1:21-cv-11686
Date  Filed:  January 21, 2022
DEFENDANT’S ANSWER TO PLAINTIFFS’ CORRECTED AMENDED COMPLAINT
Defendant Mass General Brigham Incorporated (“MGB”), by and through its attorneys
Seyfarth Shaw LLP, hereby submits its Answer to Plaintiffs’ Corrected Amended Complaint (the
“Complaint”) as follows:
INTRODUCTION
COMPLAINT ¶1:
The issue in this case is defendant Mass General Brigham Incorporated’s violations of
Title VII and the Americans with Disabilities Act (“ADA”) in wrongfully denying religious and
disability accommodations to its employees.
ANSWER:
Paragraph 1 contains conclusions of law to which no response is required.  To the extent
a response is deemed required, MGB denies the allegations in Paragraph 1.
COMPLAINT ¶2:
Rather than adhering to federal law, the defendant instead created its own system-wide
“position” and “new process” as to the granting of religious and medical accommodations for a
newly imposed vaccination policy.
ANSWER:
Defendant denies the allegations in Paragraph 2.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 1 of 101

2
78101496v.7
COMPLAINT ¶3:
Defendant wrongly denied hundreds of its employees, many of whom fought on the front
lines saving lives and fighting the spread of COVID-19 from the beginning of the pandemic to
present, reasonable religious and disability accommodations that are protected by the
aforementioned federal laws.
ANSWER:
Defendant denies the allegations in Paragraph 3.
COMPLAINT ¶4:
All plaintiffs have submitted a “Charge of Discrimination form to the EEOC, with some
already having obtained a “Notice of Right to Sue,” stating that the EEOC will likely be unable
to complete administrative processing within 180 days.1
ANSWER:
Defendant lacks sufficient knowledge and information to respond to the allegations set
forth in Paragraph 4 of the Complaint and therefore denies the same.
COMPLAINT ¶5:
Plaintiffs brought this action prior to the remedy provided under 42 U.S.C. 2000-e-5(f)(2)
by motion for preliminary injunction and by a showing of irreparable harm, justifying the need to
seek immediate preliminary injunctive relief in advance of the EEOC’s completion of its
investigation or issuance of right to sue letters.2
ANSWER:
Paragraph 5 contains conclusions of law to which no response is required.  To the extent
a response is deemed required, MGB denies the allegations in Paragraph 5.  Further answering,
on November 4, 2021, this Court found that Plaintiffs did not establish entitlement to preliminary
injunction.   See Together Emps. v. Mass Gen. Brigham Inc., No. CV 21-11686-FDS, 2021 WL
5234394, at *21 (D. Mass. Nov. 10, 2021).  The First Circuit further denied Plaintiffs’ motion for
1 Since the initial filing, right to sue letters have been obtained and will be provided on or before the date ordered for
the production of initial disclosures.
2 The First Circuit has held that plaintiffs who show irreparable injury to justify injunctive relief prior to the remedy
provided under Title VII need not wait for the EEOC’s final review as outlined in 42 U.S.C. § 2000e–5(f)(2). Bailey
v. Delta Air Lines, Inc., 722 F.2d 942, 944 (1st Cir. 1983).
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 2 of 101

3
78101496v.7
an injunction pending appeal.  Together Emps. v. Mass Gen. Brigham Inc., 19 F.4th 1 (1st Cir.
2021).  Justice Stephen Breyer thereafter denied Plaintiffs’ emergency application for writ of
injunction pending appeal to the United States Supreme Court.  See Together Emps. v. Mass
Gen. Brigham Inc., No. 21A175, United States Supreme Court, Emergency Application to
Justice Breyer for Writ of Injunction Pending Appeal, Application denied November 29, 2021.
PARTIES
COMPLAINT ¶6:
Plaintiff Roberta Lancione is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing her
history of angio-edema from prior vaccination and her current treatment for Chronic
Lymphocytic Leukemia. Plaintiff Lancione was also denied a religious accommodation after
submitting a request to the defendant detailing her sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 6 except to admit that Ms. Lancione sought
both religious and medical exemptions from MGB’s COVID-19 vaccination requirement and
that Ms. Lancione’s requests were evaluated – and denied – by one or more trained individuals
on the Religious Exemption Review Committee and two clinical panels of medical experts.
Further answering, MGB states that Ms. Lancione submitted a request for medical exemption on
or about September 2, 2021 and a request for religious exemption on or about September 3,
2021.  MGB affirmatively states that  Ms. Lancione’s identified conditions were not included in
the CDC contraindications.
COMPLAINT ¶7:
Plaintiff Joyce Miller is an employee of defendant who was denied a disability
accommodation and a religious accommodation after submitting a request to the defendant
detailing her sincerely held religious beliefs and a signed form from her physician to support her
request for disability accommodations.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 3 of 101

4
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 7 except to admit that Ms. Miller sought
both religious and medical exemptions from MGB’s COVID-19 vaccination requirement and
that Ms. Miller’s requests were evaluated – and denied – by one or more trained individuals on
the Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Ms. Miller submitted a request for medical exemption on or about
August 17, 2021 and a request for religious exemption on or about August 20, 2021.  MGB
affirmatively states that Ms. Miller’s identified conditions were not included in the CDC
contraindications.
COMPLAINT ¶8:
Plaintiff Maria DiFronzo is an employee of defendant who was denied a disability
accommodation after submitting evidence that she is pregnant. Plaintiff DiFronzo was also
denied a religious accommodation after submitted a request to defendant detailing her sincerely
held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 8 except to admit that Ms. DiFronzo
sought both religious and medical exemptions from MGB’s COVID-19 vaccination requirement
and that Ms. DiFronzo’s requests were evaluated – and denied – by one or more trained
individuals on the Religious Exemption Review Committee and two clinical panels of medical
experts.  Further answering, MGB states that Ms. DiFronzo submitted a request for medical
exemption on or about August 11, 2021 and, following MGB’s denial of that request, she
submitted a request for religious exemption on or about September 1, 2021.  MGB affirmatively
states that Ms. DiFronzo’s medical exemption request form indicated that she was pregnant.
MGB further affirmatively states that during its medical request review process, the CDC
changed its guidance and announced an urgent health advisory to increase COVID-19
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 4 of 101

5
78101496v.7
vaccination among people who were pregnant and that pregnancy was not included among the
CDC contraindications.
COMPLAINT ¶9:
Plaintiff Michael Saccoccio is an employee of defendant who was denied a disability
accommodation after submitting three letters from two doctors detailing his inability to receive
the vaccine. Plaintiff Saccoccio was also denied a religious accommodation after submitting a
request to defendant detailing his sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 9 except to admit that Mr. Saccoccio
sought both religious and medical exemptions from MGB’s COVID-19 vaccination requirement
and that Mr. Saccoccio’s requests were evaluated – and denied – by one or more trained
individuals on the Religious Exemption Review Committee and two clinical panels of medical
experts.  Further answering, MGB states that Mr. Saccoccio submitted a request for medical
exemption on or about August 19, 2021 and a request for religious exemption on or about
August 22, 2021.  MGB  affirmatively states that Mr. Saccoccio’s identified conditions were not
included in the CDC contraindications. Finally, MGB affirmatively states that Mr. Saccoccio
submitted supplemental information following MGB’s denial of his request, and that MGB
considered that supplemental information and confirmed its denial of the request.
COMPLAINT ¶10:
Plaintiff, Caine Dufrene, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability as well as detailing his sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 10 except to admit that Mr. Dufrene sought
both religious and medical exemptions from MGB’s COVID-19 vaccination requirement and
that those requests were evaluated – and denied – by one or more trained individuals on the
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 5 of 101

6
78101496v.7
Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Mr. Dufrene submitted a request for medical exemption on or about
September 1, 2021 and a request for religious exemption on or about September 22, 2021.  MGB
affirmatively states that Mr. Dufrene’s identified conditions were not included in the CDC
contraindications.
COMPLAINT ¶11:
Plaintiff, Lori Fluery, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability as well as detailing her sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 11 except to admit that Ms. Fleury sought
both religious and medical exemptions from MGB’s COVID-19 vaccination requirement and
that those requests were evaluated – and denied – by one or more trained individuals on the
Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Ms. Fleury submitted a request for religious exemption on or about
August 15, 2021 and a request for medical exemption on or about October 5, 2021.  MGB
affirmatively states that Ms. Fleury’s s identified conditions were not included in the CDC
contraindications.
COMPLAINT ¶12:
Plaintiff, Kerry Haines, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability condition as well as detailing her sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 12 except to admit that Ms. Haines sought
both religious and medical exemptions from MGB’s COVID-19 vaccination requirement and
that those requests were evaluated – and denied – by one or more trained individuals on the
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 6 of 101

7
78101496v.7
Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Ms. Haines submitted a request for religious exemption on or about
September 1, 2021 and a request for medical exemption on or about September 13, 2021.  MGB
affirmatively states that Ms. Haines’s identified conditions were not included in the CDC
contraindications.
COMPLAINT ¶13:
Plaintiff, Scott Hooper, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability condition as well as detailing his sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 13 except to admit that Mr. Hooper sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that his request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.  Further answering, following a diligent review of its records, MGB states that there
is no documentation to support that Mr. Hooper submitted a medical exemption request related
to MGB’s vaccination requirement.
COMPLAINT ¶14:
Plaintiff, Susan Marconi, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability condition as well as detailing her sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 14 except to admit that Ms. Marconi
sought both religious and medical exemptions from MGB’s COVID-19 vaccination requirement
and that those requests were evaluated – and denied – by one or more trained individuals on the
Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Ms. Marconi submitted a request for religious exemption on or about
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 7 of 101

8
78101496v.7
September 1, 2021 and a request for medical exemption on or about September 2, 2021.  MGB
affirmatively states that Ms. Marconi’s identified conditions were not included in the CDC
contraindications.
COMPLAINT ¶15:
Plaintiff, Kelly Reynolds, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability condition as well as detailing her sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 15 except to admit that Ms. Reynolds
sought both religious and medical exemptions from MGB’s COVID-19 vaccination requirement
and that those requests were evaluated – and denied – by one or more trained individuals on the
Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Ms. Reynolds submitted a request for religious exemption on or
about September 2, 2021 and a request for medical exemption on or about September 20, 2021.
MGB  affirmatively states that Ms. Reynolds’s identified conditions were not included in the
CDC contraindications.
COMPLAINT ¶16:
Plaintiff, Christine Ritrovato, is an employee of defendant who was denied a disability
and religious accommodation after requesting both from defendant and submitting evidence of a
disability condition as well as detailing her sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 16 except to admit that Ms. Ritrovato
sought both religious and medical exemptions from MGB’s COVID-19 vaccination requirement
and that those requests were evaluated – and denied – by one or more trained individuals on the
Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Ms. Ritrovato submitted a request for medical exemption on or
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 8 of 101

9
78101496v.7
about August 18, 2021 and a request for religious exemption on or about September 1, 2021.
MGB affirmatively states that Ms. Ritrovato’s identified conditions were not included in the
CDC contraindications.
COMPLAINT ¶17:
Plaintiff, Sarah Wade, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability condition as well as detailing her sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 17 except to admit that Ms. Wade sought
both religious and medical exemptions from MGB’s COVID-19 vaccination requirement and
that those requests were evaluated – and denied – by one or more trained individuals on the
Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Ms. Wade submitted a request for religious exemption on or about
August 13, 2021 and a request for medical exemption on or about September 15, 2021.  MGB
affirmatively states that Ms. Wade’s identified conditions were not included in the CDC
contraindications.
COMPLAINT ¶18:
Plaintiff, James Wines, MD, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability condition as well as detailing his sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 18 except to admit that Dr. Wines sought
both religious and medical exemptions from MGB’s COVID-19 vaccination requirement and
that those requests were evaluated – and denied – by one or more trained individuals on the
Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Dr. Wines submitted a request for religious exemption on or about
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 9 of 101

10
78101496v.7
September 3, 2021 and a request for medical exemption on or about September 7, 2021.  MGB
affirmatively states that Dr. Wines’s identified conditions were not included in the CDC
contraindications.
COMPLAINT ¶19:
Plaintiff, Jill Driscoll, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability condition as well as detailing her sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 19 except to admit that Ms. Driscoll sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that her request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.  Further answering, following a diligent review of its records, MGB states that there
is no documentation to support that Ms. Driscoll submitted a medical exemption request related
to MGB’s vaccination requirement.
COMPLAINT ¶20:
Plaintiff, Marisa Williams, is an employee of defendant who was denied a disability and
religious accommodation after requesting both from defendant and submitting evidence of a
disability condition as well as detailing her sincerely held religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 20 except to admit that Ms. Williams
sought both religious and medical exemptions from MGB’s COVID-19 vaccination requirement
and that those requests were evaluated – and denied – by one or more trained individuals on the
Religious Exemption Review Committee and two clinical panels of medical experts.  Further
answering, MGB states that Ms. Williams submitted a request for religious exemption on or
about September 2, 2021 and a request for medical exemption on or about October 3, 2021.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 10 of 101

11
78101496v.7
MGB affirmatively states that Ms. Williams’s identified conditions were not included in the
CDC contraindications.
COMPLAINT ¶21:
Plaintiff, Tyler Adams, is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing her
disability condition for which defendant had already granted a her a reasonable accommodation
to their mask policy.
ANSWER:
Defendant denies the allegations in Paragraph 21 except to admit that Ms. Adams sought
a medical exemption from MGB’s COVID-19 vaccination requirement and that her request was
evaluated – and denied – by one or more trained individuals on two clinical panels of medical
experts.  MGB affirmatively states that Ms. Adams’s identified conditions were not included in
the CDC contraindications.  Answering further, Defendant states that it never granted Ms.
Adams an exemption from the mask policy, but that as part of an interactive process, MGB
provided her with a Powered Air Purifying Respirator to wear at work, and when Ms. Adams
expressed that she no longer wanted to wear that device, MGB offered – and Ms. Adams
accepted – a transfer into a remote role.
COMPLAINT ¶22:
Plaintiff, Melissa Candido, is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing her
disability contraindications.
ANSWER:
Defendant denies the allegations in Paragraph 22 except to admit that Ms. Candido
sought a medical exemption from MGB’s COVID-19 vaccination requirement and that her
request was evaluated – and denied – by one or more trained individuals on two clinical panels
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 11 of 101

12
78101496v.7
of medical experts.  MGB affirmatively states that Ms. Candido’s identified conditions were not
included in the CDC contraindications.
COMPLAINT ¶23:
Plaintiff, Lisa Cates, is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing her
disability contraindications.
ANSWER:
Defendant denies the allegations in Paragraph 23 except to admit that Ms. Cates sought a
medical exemption from MGB’s COVID-19 vaccination requirement and that her request was
evaluated – and denied – by one or more trained individuals on two clinical panels of medical
experts.  MGB affirmatively states that Ms. Cates’s identified conditions were not included in the
CDC contraindications.
COMPLAINT ¶24:
Plaintiff, Alan Doherty, is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing his
disability contraindications.
ANSWER:
Defendant denies the allegations in Paragraph 24 except to admit that Mr. Doherty sought
a medical exemption from MGB’s COVID-19 vaccination requirement and that his request was
evaluated – and denied – by one or more trained individuals on two clinical panels of medical
experts.  MGB affirmatively states that Mr. Doherty’s identified conditions were not included in
the CDC contraindications.
COMPLAINT ¶25:
Plaintiff, Jane Donegan, is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing her
disability contraindications.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 12 of 101

13
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 25 except to admit that Ms. Donegan
sought a medical exemption from MGB’s COVID-19 vaccination requirement and that her
request was evaluated – and denied – by one or more trained individuals on two clinical panels
of medical experts.  MGB affirmatively states that Ms. Donegan’s identified conditions were not
included in the CDC contraindications.
COMPLAINT ¶26:
Plaintiff, Kasie Pasquantonio, is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing her
disability contraindications.
ANSWER:
Defendant denies the allegations in Paragraph 26 except to admit that Ms. Pasquantonio
sought a medical exemption from MGB’s COVID-19 vaccination requirement and that her
request was evaluated – and denied – by one or more trained individuals on two clinical panels
of medical experts.   MGB affirmatively states that Ms. Pasquantonio’s identified conditions
were not included in the CDC contraindications.
COMPLAINT ¶27:
Plaintiff, Monalisa Pierre, is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing her
disability contraindications.
ANSWER:
Defendant denies the allegations in Paragraph 27 except to admit that Ms. Pierre sought a
medical exemption from MGB’s COVID-19 vaccination requirement and that her request was
evaluated – and denied – by one or more trained individuals on two clinical panels of medical
experts.  MGB affirmatively states that Ms. Pierre’s identified conditions were not included in
the CDC contraindications.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 13 of 101

14
78101496v.7
COMPLAINT ¶28:
Plaintiff, Melissa Pinnetti, is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing her
disability contraindications.
ANSWER:
Defendant denies the allegations in Paragraph 28.   Following a diligent review of its
records, MGB affirmatively states that there is no documentation to support that Ms. Pinnetti
submitted a medical exemption request related to MGB’s vaccination requirement.
COMPLAINT ¶29:
Plaintiff, Jennifer Tone, is an employee of defendant who was denied a disability
accommodation after submitting a request and documentation to the defendant detailing her
disability contraindications.
ANSWER:
Defendant denies the allegations in Paragraph 29 except to admit that Ms. Tone sought a
medical exemption from MGB’s COVID-19 vaccination requirement and that her request was
evaluated – and denied – by one or more trained individuals on two clinical panels of medical
experts.  MGB affirmatively states that Ms. Tone’s identified conditions were not included in the
CDC contraindications.
COMPLAINT ¶30:
Plaintiff Natasha DiCicco is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs to the defendant.
ANSWER:
Defendant denies the allegations in Paragraph 30 except to admit that Ms. DiCicco
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that her
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 14 of 101

15
78101496v.7
COMPLAINT ¶31:
Plaintiff, Nicholas Arno, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs to the defendant.
ANSWER:
Defendant denies the allegations in Paragraph 31 except to admit that Mr. Arno sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that his request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶32:
Plaintiff, Ruben Almeida, is an employee of defendant who had been given religious
accommodation by defendant in the past yet was denied a religious accommodation after sending
a request and detailing his sincerely held religious beliefs to the defendant.
ANSWER:
Defendant denies the allegations in Paragraph 32 except to admit that Mr. Almeida
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that his
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.  MGB further admits that Mr. Almeida sought a religious
exemption from MGB’s influenza vaccination requirement in 2018, 2019, and 2020 and that
those requests were granted.
COMPLAINT ¶33:
Plaintiff Mimi Adams, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs to defendant.
ANSWER:
Defendant denies the allegations in Paragraph 33 except to admit that Ms. Adams sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 15 of 101

16
78101496v.7
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶34:
Plaintiff, Alexandra Alexandrova, is an employee of defendant who had been given
religious accommodation by defendant in the past yet was denied a religious accommodation
after sending a request and detailing her sincerely held religious beliefs to defendant.
ANSWER:
Defendant denies the allegations in Paragraph 34 except to admit that Ms. Alexandrova
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.  MGB further admits that Ms. Alexandrova sought a religious
exemption from MGB’s influenza vaccination requirement in 2018, 2019, and 2020, and that
those requests were granted.
COMPLAINT ¶35:
Plaintiff, John Alfama, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs to defendant.
ANSWER:
Defendant denies the allegations in Paragraph 35 except to admit that Mr. Alfama sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶36:
Plaintiff, Nykiesha Allien, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 16 of 101

17
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 36 except to admit that Ms. Allien sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶37:
Plaintiff Charlotte Amedee is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 37 except to admit that Ms. Amedee
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶38:
Plaintiff, Tracy Anderson, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 38 except to admit that Ms. Anderson
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶39:
Plaintiff, Meredith Anderson, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 17 of 101

18
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 39 except to admit that Ms. Anderson
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶40:
Plaintiff, Alicia Attarian, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 40 except to admit that Ms. Attarian sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶41:
Plaintiff, Clarisse Bacolong, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 41 except to admit that Ms. Bacolong
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶42:
Plaintiff, Pamela Barone, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 18 of 101

19
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 42 except to admit that Ms. Barone sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶43:
Plaintiff, Stephen Barry, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 43 except to admit that Mr. Barry sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶44:
Plaintiff, Jennifer Beckwith, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 44 except to admit that Ms. Beckwith
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶45:
Plaintiff, Kathleen Beede, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 19 of 101

20
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 45 except to admit that Ms. Beede sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶46:
Plaintiff, Catherine Bernardone, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 46 except to admit that Ms. Bernadone
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶47:
Plaintiff, Linda Berube-Walker, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 47 except to admit that Ms. Berube-Walker
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶48:
Plaintiff, Kristie Boutin, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 20 of 101

21
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 48 except to admit that Ms. Boutin sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶49:
Plaintiff, Kelly Bianchi, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 49 except to admit that Ms. Bianchi sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶50:
Plaintiff, Brittini Bieker, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 50 except to admit that Ms. Bieker sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶51:
Plaintiff, Tiffany Bigham, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 21 of 101

22
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 51 except to admit that Ms. Bigham sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶52:
Plaintiff, Lora Blank, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 52 except to admit that Ms. Blank sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶53:
Plaintiff, Urszula Boryczka, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 53 except to admit that Ms. Boryczka
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶54:
Plaintiff, Josette Britton, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 22 of 101

23
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 54 except to admit that Ms. Britton sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶55:
Plaintiff, Kristen Brouillard, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 55 except to admit that Ms. Brouillard
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶56:
Plaintiff, Erin Brown, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 56 except to admit that Ms. Brown sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶57:
Plaintiff, Brenda Brown-Thawe, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 23 of 101

24
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 57 except to admit that Ms. Brown-Thawe
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶58:
Plaintiff, Christopher Burt, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 58 except to admit that Mr. Burt sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶59:
Plaintiff, Raquel Bustillo, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 59 except to admit that Ms. Bustillo sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶60:
Plaintiff, Denise Cadigan, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 24 of 101

25
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 60 except to admit that Ms. Cadigan
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶61:
Plaintiff, Maria Capozzi, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 61 except to admit that Ms. Capozzi sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶62:
Plaintiff, Gail Caracciolo, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 62 except to admit that Ms. Caracciolo
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶63:
Plaintiff, Mayra Cardona, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 25 of 101

26
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 63 except to admit that Ms. Cardona
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶64:
Plaintiff, Dwight Caufield, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 64 except to admit that Mr. Caufield
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶65:
Plaintiff, Elizabeth Chaisson, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 65 except to admit that Ms. Chaisson
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶66:
Plaintiff, Susan Chase, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 26 of 101

27
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 66 except to admit that Ms. Chase sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶67:
Plaintiff, Andrea Citrone, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 67 except to admit that Ms. Citrone sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶68:
Plaintiff, Alicia Clancy, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 68 except to admit that Ms. Clancy sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶69:
Plaintiff, Patricia Clark, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 27 of 101

28
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 69 except to admit that Ms. Clark sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶70:
Plaintiff, Courtney Concillo, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 70 except to admit that Ms. Concillo
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶71:
Plaintiff, Madeline Conley, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 71 except to admit that Ms. Conley sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶72:
Plaintiff, Laura Conway, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 28 of 101

29
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 72 except to admit that Ms. Conway
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶73:
Plaintiff, Courtney Coppola, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 73 except to admit that Ms. Coppola
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶74:
Plaintiff, Kelly Corona-Welch, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 74 except to admit that Ms. Corona-Welch
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶75:
Plaintiff, Daniel Correia, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 29 of 101

30
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 75 except to admit that Mr. Correia sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶76:
Plaintiff, Maria Coviello, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 76 except to admit that Ms. Coviello
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶77:
Plaintiff, Elisangela Cunha-Afonso, is an employee of defendant who was denied a
religious accommodation after requesting an accommodation and detailing her sincerely held
religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 77 except to admit that Ms. Cunha-Afonso
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶78:
Plaintiff, Taylor Curley, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 30 of 101

31
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 78 except to admit that Ms. Curley sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶79:
Plaintiff, Mark Dalimonte, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 79 except to admit that Mr. Dalimonte
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶80:
Plaintiff, Jill Daniels, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 80 except to admit that Ms. Daniels sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶81:
Plaintiff, Michele Deforge, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 31 of 101

32
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 81 except to admit that Ms. Deforge sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶82:
Plaintiff, Jean Marie Devine, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 82 except to admit that Ms. Devine sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶83:
Plaintiff, Dmitri Doncev, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 83 except to admit that Mr. Doncev sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶84:
Plaintiff, Joan Duffy, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 32 of 101

33
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 84 except to admit that Ms. Duffy sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶85:
Plaintiff, Jessika Dunn, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 85 except to admit that Ms. Dunn sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶86:
Plaintiff, Carlos Duran, MD, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 86 except to admit that Dr. Duran sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶87:
Plaintiff, Jennifer Duran, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 33 of 101

34
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 87 except to admit that Ms. Duran sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶88:
Plaintiff, Anika Ebanks, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 88 except to admit that Ms. Ebanks sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶89:
Plaintiff, Tansheka Edwards, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 89 except to admit that Ms. Edwards
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶90:
Plaintiff, Tom Emerson, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 34 of 101

35
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 90 except to admit that Mr. Emerson
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶91:
Plaintiff, Christopher Erickson, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 91 except to admit that Mr. Erickson
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶92:
Plaintiff, Sandra Federico, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 92 except to admit that Ms. Federico
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶93:
Plaintiff, Zinnia Feliciano, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 35 of 101

36
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 93 except to admit that Ms. Feliciano
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶94:
Plaintiff, Denise Flathers, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 94 except to admit that Ms. Flathers sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶95:
Plaintiff, Lisa Foley, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 95 except to admit that Ms. Foley sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶96:
Plaintiff, Kris Forde, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 36 of 101

37
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 96 except to admit that Ms. Forde sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶97:
Plaintiff, Jeanine Fotino, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 97 except to admit that Ms. Fotino sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶98:
Plaintiff, Ralph Frasca, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 98 except to admit that Mr. Frasca sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶99:
Plaintiff, Laina Frazier, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 37 of 101

38
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 99 except to admit that Ms. Frazier sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶100:
Plaintiff, Ruth Frenchwood, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 100 except to admit that Ms. Frenchwood
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶101:
Plaintiff, Lisa Freni, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 101 except to admit that Ms. Freni sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶102:
Plaintiff, Kathleen Fusco, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 38 of 101

39
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 102 except to admit that Ms. Fusco sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶103:
Plaintiff, Melissa Gable, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 103 except to admit that Ms. Gable sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶104:
Plaintiff, Maryna Garbitt, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 104 except to admit that Ms. Garbitt
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶105:
Plaintiff, Luisa Garcia, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 39 of 101

40
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 105 except to admit that Ms. Garcia sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶106:
Plaintiff, Kristen Gauthier, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 106 except to admit that Ms. Gauthier
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶107:
Plaintiff, Carmela Giso, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 107 except to admit that Ms. Giso sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶108:
Plaintiff, Elisabette Gomes, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 40 of 101

41
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 108 except to admit that Ms. Gomes
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶109:
Plaintiff, Jolene Gonsalves, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 109 except to admit that Ms. Gonsalves
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶110:
Plaintiff, Nelida Gonzalez, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 110 except to admit that Ms. Gonzalez
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶111:
Plaintiff, Sarah Graffam, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 41 of 101

42
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 111 except to admit that Ms. Graffam
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶112:
Plaintiff, David Granara, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 112 except to admit that Mr. Granara
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶113:
Plaintiff, Samantha Gross, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 113 except to admit that Ms. Gross sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶114:
Plaintiff, Martina Groves-Williams, is an employee of defendant who was denied a
religious accommodation after requesting an accommodation and detailing her sincerely held
religious beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 42 of 101

43
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 114 except to admit that Ms. Groves-
Williams sought a religious exemption from MGB’s COVID-19 vaccination requirement and
that the request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶115:
Plaintiff, Jamie Hadayia, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 115 except to admit that Ms. Hadayia
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶116:
Plaintiff, Adil Haiti, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 116 except to admit that Ms. Haiti sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶117:
Plaintiff, Ashley “Nikki” Hamel, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 43 of 101

44
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 117 except to admit that Ms. Hamel sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶118:
Plaintiff, Francesca Hirtle, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 118 except to admit that Ms. Hirtle sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶119:
Plaintiff, Marissa Hoffman, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 119 except to admit that Ms. Hoffman
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶120:
Plaintiff, W. Scott Hoge, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 44 of 101

45
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 120 except to admit that Mr. Hoge sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶121:
Plaintiff, Florence Holmes, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 121 except to admit that Ms. Holmes
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶122:
Plaintiff, Jeanmarie Holmes, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 122 except to admit that Ms. Holmes
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶123:
Plaintiff, Denise Homka, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 45 of 101

46
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 123 except to admit that Ms. Homka
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶124:
Plaintiff, Jennifer Howard, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 124 except to admit that Ms. Howard
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶125:
Plaintiff, Beverly Hupfer, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 125 except to admit that Ms. Hupfer
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶126:
Plaintiff, Martha Ithier, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 46 of 101

47
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 126 except to admit that Ms. Ithier sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶127:
Plaintiff, Steve Jean-Mary, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 127 except to admit that Mr. Jean-Mary
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶128:
Plaintiff, Jessica Joachim, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 128 except to admit that Ms. Joachim
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶129:
Plaintiff, Teresa Kanaiski, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 47 of 101

48
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 129 except to admit that Ms. Kanaiski
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶130:
Plaintiff, Jason Karanzas, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 130 except to admit that Mr. Karanzas
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶131:
Plaintiff, William Kasper, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 131 except to admit that Mr. Kasper sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶132:
Plaintiff, Konstantin Kerentsev, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 48 of 101

49
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 132 except to admit that Mr. Kerentsev
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶133:
Plaintiff, Lubjana Koli, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 133 except to admit that Ms. Koli sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶134:
Plaintiff, Julia Krafick, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 134 except to admit that Ms. Krafick
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶135:
Plaintiff, Andree Laflash, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 49 of 101

50
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 135 except to admit that Ms. Laflash
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶136:
Plaintiff, Marie Lafreniere, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 136 except to admit that Ms. Lafreniere
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶137:
Plaintiff, Joseph Lamontagne, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 137 except to admit that Mr. Lamontagne
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶138:
Plaintiff, Susan Leavitt, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 50 of 101

51
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 138 except to admit that Ms. Leavitt
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶139:
Plaintiff, Katherine Lemmertz, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 139 except to admit that Ms. Lemmertz
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶140:
Plaintiff, Ann Marie Lilly, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 140 except to admit that Ms. Lilly sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶141:
Plaintiff, Kim Litalien, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 51 of 101

52
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 141 except to admit that Ms. Litalien
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶142:
Plaintiff, Jillian Litto, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 142 except to admit that Ms. Litto sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶143:
Plaintiff, Michelle Logan, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 143 except to admit that Ms. Logan sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶144:
Plaintiff, Shannon Lundin, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 52 of 101

53
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 144 except to admit that Ms. Lundin
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶145:
Plaintiff, Christa Luongo, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 145 except to admit that Ms. Luongo
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶146:
Plaintiff, Leah Machado, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 146 except to admit that Ms. Machado
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶147:
Plaintiff, Angela MacLeod-Ruo, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 53 of 101

54
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 147 except to admit that Ms. MacLeod-
Ruo sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶148:
Plaintiff, Sarah Maloney, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 148 except to admit that Ms. Maloney
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶149:
Plaintiff, Amanda Marchionda, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 149 except to admit that Ms. Marchionda
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶150:
Plaintiff, Maria Margaris, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 54 of 101

55
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 150 except to admit that Ms. Margaris
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶151:
Plaintiff, Lorraine Martin, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 151 except to admit that Ms. Martin sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶152:
Plaintiff, Gina Mastro, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 152 except to admit that Ms. Mastro
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶153:
Plaintiff, Lisa Mastromatteo, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 55 of 101

56
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 153 except to admit that Ms. Mastromatteo
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶154:
Plaintiff, Barbara Matteson, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 154 except to admit that Ms. Matteson
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶155:
Plaintiff, Jessica McDonald, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 155 except to admit that Ms. McDonald
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶156:
Plaintiff, Devan McDonald, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 56 of 101

57
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 156 except to admit that Mr. McDonald
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶157:
Plaintiff, Janice McDonald, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 157 except to admit that Ms. McDonald
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶158:
Plaintiff, Nicholas McKay, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 158 except to admit that Mr. McKay
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶159:
Plaintiff, Roseann McNamara, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 57 of 101

58
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 159 except to admit that Ms. McNamara
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶160:
Plaintiff, Robin Meadows, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 160 except to admit that Ms. Meadows
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶161:
Plaintiff, Stefanie Michael, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 161 except to admit that Ms. Michael
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶162:
Plaintiff, Sara Miles, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 58 of 101

59
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 162 except to admit that Ms. Miles sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶163:
Plaintiff, Yuliya Mironovas, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 163 except to admit that Ms. Mironovas
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶164:
Plaintiff, Michelle Morena, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 164 except to admit that Ms. Morena
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶165:
Plaintiff, Raechel Morganto, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 59 of 101

60
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 165 except to admit that Ms. Morganto
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶166:
Plaintiff, Alice Morrison, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 166 except to admit that Ms. Morrison
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶167:
Plaintiff, Lori Munro, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 167 except to admit that Ms. Munro sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶168:
Plaintiff, Karen O’Connor, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 60 of 101

61
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 168.  Further answering, following a
diligent review of its records, MGB states that there is no documentation to support that Ms.
O’Connor submitted a religious exemption request related to MGB’s vaccination requirement.
COMPLAINT ¶169:
Plaintiff, Michelle Orfanos, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 169 except to admit that Ms. Orfanos
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶170:
Plaintiff, Lisa Orrall, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 170 except to admit that Ms. Orrall sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶171:
Plaintiff, Julia Pagiluca, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 61 of 101

62
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 171 except to admit that Ms. Pagiluca
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶172:
Plaintiff, Scott Palladino, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 172 except to admit that Mr. Palladino
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶173:
Plaintiff, Malinda Paulino, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 173 except to admit that Ms. Paulino
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶174:
Plaintiff, Teresa Penta, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 62 of 101

63
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 174 except to admit that Ms. Penta sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶175:
Plaintiff, Andrea Pittore-McManus, is an employee of defendant who was denied a
religious accommodation after requesting an accommodation and detailing her sincerely held
religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 175 except to admit that Ms. Pittore-
McManus sought a religious exemption from MGB’s COVID-19 vaccination requirement and
that the request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶176:
Plaintiff, Jhanel Potts, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 176 except to admit that Ms. Potts sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶177:
Plaintiff, Charles Riley, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 63 of 101

64
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 177 except to admit that Mr. Riley sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶178:
Plaintiff, Nicole Roberto, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 178 except to admit that Ms. Roberto
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶179:
Plaintiff, Gracinda Rochdi, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 179 except to admit that Mr. Rochdi
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶180:
Plaintiff, Jessica Rodriguez, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 64 of 101

65
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 180 except to admit that Ms. Rodriguez
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶181:
Plaintiff, Debra Rodriguez, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 181 except to admit that Ms. Rodriguez
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶182:
Plaintiff, Ericka Rollins, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 182 except to admit that Ms. Rollins
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶183:
Plaintiff, Felyn Rosario, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 65 of 101

66
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 183 except to admit that Ms. Rosario
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶184:
Plaintiff, Ann Rowand, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 184 except to admit that Ms. Rowand
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶185:
Plaintiff, Maria Rupnick, MD, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 185 except to admit that Dr. Rupnick
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶186:
Plaintiff, Laura Ryan, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 66 of 101

67
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 186 except to admit that Ms. Ryan sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶187:
Plaintiff, Elaine Samaris-Harrington, is an employee of defendant who was denied a
religious accommodation after requesting an accommodation and detailing her sincerely held
religious beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 187 except to admit that Ms. Samaris-
Harrington sought a religious exemption from MGB’s COVID-19 vaccination requirement and
that the request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶188:
Plaintiff Brenda Santiago is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 188 except to admit that Ms. Santiago
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶189:
Plaintiff, Sarah Shulman, MD, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 67 of 101

68
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 189 except to admit that Dr. Shulman
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶190:
Plaintiff, Elizabeth Silva, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 190 except to admit that Ms. Silva sought a
religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶191:
Plaintiff, Nikkia Simpson, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 191 except to admit that Ms. Simpson
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶192:
Plaintiff, Anne Smail, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 68 of 101

69
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 192 except to admit that Ms. Smail sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶193:
Plaintiff, Wendy Soumas, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 193 except to admit that Ms. Soumas
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶194:
Plaintiff, Danielle Stevens, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 194 except to admit that Ms. Stevens
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶195:
Plaintiff, Jamie Steverman, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 69 of 101

70
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 195 except to admit that Ms. Steverman
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶196:
Plaintiff, Michael Strong, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 196 except to admit that Mr. Strong sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶197:
Plaintiff, Joshua Sudbey, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 197 except to admit that Mr. Sudbey
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶198:
Plaintiff, Anna Sylvia, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 70 of 101

71
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 198 except to admit that Ms. Sylvia sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶199:
Plaintiff, Heather Szymczak, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 199 except to admit that Ms. Szymczak
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶200:
Plaintiff, Umberto Tatafiore, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 200 except to admit that Mr. Tatafiore
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶201:
Plaintiff, Anthony Taverna, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 71 of 101

72
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 201 except to admit that Mr. Taverna
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶202:
Plaintiff, Lisa Tobio, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 202 except to admit that Ms. Tobio sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶203:
Plaintiff, Kelly Todd, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 203 except to admit that Ms. Todd sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶204:
Plaintiff, Danielle Marie Tomasello, is an employee of defendant who was denied a
religious accommodation after requesting an accommodation and detailing her sincerely held
religious beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 72 of 101

73
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 204 except to admit that Ms. Tomasello
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶205:
Plaintiff, Ruth Tonico, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 205 except to admit that Ms. Tonico
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶206:
Plaintiff, Jane Torrance ,is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 206 except to admit that Ms. Torrance
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶207:
Plaintiff, Neldine Torres, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 73 of 101

74
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 207 except to admit that Ms. Torres sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶208:
Plaintiff, Nicole Towne, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 208 except to admit that Ms. Towne sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶209:
Plaintiff, Laura Tremblay, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 209 except to admit that Ms. Tremblay
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶210:
Plaintiff, Rosanna Ursino, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 74 of 101

75
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 210 except to admit that Ms. Ursino sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶211:
Plaintiff, Caroline Ventola, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 211 except to admit that Ms. Ventola
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶212:
Plaintiff, Lucia Ventura, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 212 except to admit that Ms. Ventura
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶213:
Plaintiff, Frivian Vicente, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 75 of 101

76
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 213 except to admit that Ms. Vicente
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶214:
Plaintiff, Patricia Vosikas, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 214 except to admit that Ms. Vosikas
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶215:
Plaintiff, Athina Vranishti, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 215 except to admit that Ms. Vranishti
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶216:
Plaintiff, Sheila Walsh, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 76 of 101

77
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 216 except to admit that Ms. Walsh sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶217:
Plaintiff, LeeAnn Whalley, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 217 except to admit that Ms. Whalley
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶218:
Plaintiff, Henrietta Williams, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 218 except to admit that Ms. Williams
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶219:
Plaintiff, Markian Zaiats, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 77 of 101

78
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 219 except to admit that Ms. Zaitas sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶220:
Plaintiff, Maritza Zuluaga, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 220 except to admit that Ms. Zuluaga
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶221:
Plaintiff, Kien Nguyen, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 221 except to admit that Mr. Nguyen
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶222:
Plaintiff, Esther Jones, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 78 of 101

79
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 222 except to admit that Ms. Jones sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶223:
Plaintiff, Patricia Parker, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 223 except to admit that Ms. Parker sought
a religious exemption from MGB’s COVID-19 vaccination requirement and that the request was
evaluated – and denied – by one or more trained individuals on the Religious Exemption Review
Committee.
COMPLAINT ¶224:
Plaintiff, Amilcar Cardoso, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 224 except to admit that Mr. Cardoso
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶225:
Plaintiff, Maria Crevello, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 79 of 101

80
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 225 except to admit that Ms. Crevello
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶226:
Plaintiff, Corinne Valstyn, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 226.  Further answering, following a
diligent review of its records, MGB states that there is no documentation to support that Ms.
Valstyn submitted a religious exemption request related to MGB’s vaccination requirement.
COMPLAINT ¶227:
Plaintiff, Francine Laforest, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing her sincerely held religious
beliefs.
ANSWER:
Defendant denies the allegations in Paragraph 227 except to admit that Ms. Laforest
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶228:
Plaintiff, Leandro Alcantara, is an employee of defendant who was denied a religious
accommodation after requesting an accommodation and detailing his sincerely held religious
beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 80 of 101

81
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 228 except to admit that Mr. Alcantara
sought a religious exemption from MGB’s COVID-19 vaccination requirement and that the
request was evaluated – and denied – by one or more trained individuals on the Religious
Exemption Review Committee.
COMPLAINT ¶229:
Defendant, Mass General Brigham Incorporated is a Massachusetts Corporation with a
principal address listed as 800 Boylston Street in Boston, Massachusetts. It has fourteen hospitals
and several other medical facilities throughout the Commonwealth of Massachusetts.
ANSWER:
Defendant admits the allegations in the first sentence Paragraph 229.  As to the second
sentence, Defendant admits that there are fourteen hospitals in its network and a number of
additional medically-related organizations.
JURISDICTION, VENUE AND STANDING
COMPLAINT ¶230:
Plaintiffs bring this action for disability discrimination under the Americans with
Disabilities Act (hereinafter “ADA”) and religious discrimination under Title VII of the Civil
Rights Act, with all claims arising within the context of plaintiffs’ employment by the defendant.
ANSWER:
Paragraph 230 contains conclusions of law to which no response is required.  To the
extent a response is deemed required, MGB denies the allegations in Paragraph 230.
COMPLAINT ¶231:
All plaintiffs are employees of the defendant in various hospitals and facilities and either
had their religious or disability accommodations wrongfully denied by the defendant.
ANSWER:
Defendant denies the allegations in Paragraph 231 and affirmatively states that the
Plaintiffs were not all employed by MGB.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 81 of 101

82
78101496v.7
COMPLAINT ¶232:
Plaintiffs are seeking declaratory and preliminary injunctive relief under 28 U.S.C. §
2201 and § 2202.
ANSWER:
Paragraph 232 contains conclusions of law to which no response is required.  Further
answering, on November 4, 2021, this Court found that Plaintiffs did not establish entitlement to
preliminary injunction.   See Together Emps., 2021 WL 5234394, at *21. The First Circuit
further denied Plaintiffs’ motion for an injunction pending appeal, Together Emps., 19 F.4th 1,
and Justice Stephen Breyer thereafter denied Plaintiffs’ emergency application for writ of
injunction pending appeal to the United States Supreme Court.  See Together Emps. No. 21A175,
United States Supreme Court, Emergency Application to Justice Breyer for Writ of Injunction
Pending Appeal, Application denied November 29, 2021.
FACTUAL BACKGROUND
COMPLAINT ¶233:
On June 24, 2021, defendant’s President and CEO, Ann Klibanski, announced that all
employees would be required to receive one of three COVID-19 vaccines. A true copy of the
announcement is included herewith as Exhibit A.
ANSWER:
The June 24, 2021 announcement speaks for itself and Defendant denies the allegations
in Paragraph 233 to the extent they are inconsistent with that announcement.
COMPLAINT ¶234:
The announcement initially stated that exemptions would be available for “medical and
religious reasons” and for “employees who are pregnant or who intend to become pregnant.”
ANSWER:
The June 24, 2021 announcement speaks for itself and Defendant denies the allegations
in Paragraph 234 to the extent they are inconsistent with that announcement.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 82 of 101

83
78101496v.7
COMPLAINT ¶235:
Defendant provided its employees with a “Covid Vaccine Medical Exemption Request
Form 2021” for those seeking medical accommodations, which allowed for a temporary
exemption for pregnancy stating, “According to the CDC and American College of Obstetrics
and Gynecology, the COVID-19 vaccination is safe and effective for pregnant women and to
protect the baby after it is born. However, pregnancy is a unique personal circumstance. We
encourage those pregnant to discuss this issue with their medical provider.” A true copy of the
Covid Vaccine Medical Exemption Request Form 2021 is included herewith as Exhibit B.
ANSWER:
The referenced medical exemption request form speaks for itself and Defendant denies
the allegations in Paragraph 235 to the extent they are inconsistent with that form.
COMPLAINT ¶236:
For any employees seeking religious exemptions to the new policy, defendant
purportedly established a committee to review the submitted religious exemptions.
ANSWER:
Defendant admits that it established a Religious Exemption Review Committee to review
requests for religious exemption from the vaccination requirement and otherwise denies the
allegations in Paragraph 236.
COMPLAINT ¶237:
The defendant’s required religious exemption form was an online form with several
check box questions and a small, one line text box with directions stating “In the space provided,
please (1) identify your sincerely held religious belief, practice or observance and (2) explain
why it prevents you from receiving a COVID-19 vaccine. Please note that you may be required
to provide additional information or supporting documentation to support your request for an
exemption.” A true copy of the exemption form is attached herewith as Exhibit C.
ANSWER:
Defendant states that the referenced religious exemption form speaks for itself and denies
the allegations in Paragraph 237 to the extent they are inconsistent with that form.  Answering
further, Defendant states that, on the form, MGB provided employees with a free text field to
respond to the two-prong prompt that Plaintiffs quote in Paragraph 237. MGB further
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 83 of 101

84
78101496v.7
affirmatively states that employees could choose how long of an explanation to write and that the
text box expanded as needed.
COMPLAINT ¶238:
The form contained no option to provide any supporting documentation, such as a
personal statement or a clergy letter.
ANSWER:
Defendant admits that the initial religious exemption request form did not include an
option to append supporting documentation.  Defendant affirmatively states that through its
interactive process, employees could submit any supporting documentation that they believed
was relevant to the Religious Exemption Review Committee by email – and those seeking
religious exemptions from the vaccination requirement routinely provided such supporting
documentation.
COMPLAINT ¶239:
Defendant then denied the plaintiffs’ requests prior to allowing them to provide
supporting documents for their accommodation requests.
ANSWER:
Defendant denies the allegations in Paragraph 239.
COMPLAINT ¶240:
These denials contained virtually no discussion, other than to state that plaintiffs failed to
state a sincerely held religious belief, or clearly misconstruing plaintiffs’ beliefs to fit a reason
for denial, followed by a link to where plaintiffs could get vaccinated.
ANSWER:
Defendant denies the allegations in Paragraph 240.
COMPLAINT ¶241:
Defendant’s offering of medical and religious exemptions was illusory and not based in
accordance with federal law, evidenced by (and not limited to) the following:
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 84 of 101

85
78101496v.7
a.
Defendant instructed its network physicians not to draft letters in support of
medical accommodations for their patients (Exhibit D);
b.
Defendant amended their medical accommodation form, removing the option for
a pregnancy accommodation after promising pregnant employees that they would
be granted accommodations (Exhibit E);
c.
Defendant would not disclose to its employees the individuals that comprised
defendant’s exemption committee, their qualifications, or what the review process
would entail3;
d.
Defendant refused to accommodate employees that it had accommodated in the
past, citing a “new process” that they had created (Exhibit F);
e.
Defendant sent out an email to unit supervisors (Exhibit G) stating that they
should encourage employees who had their religious accommodations denied to
instead get vaccinated;
f.
This same email provided talking points that supervisors were to use with their
subordinates, including assurances that their requests were “carefully reviewed by
a committee made up of individuals from across Mass General Brigham,” which
was “charged with reviewing requests and determining whether each request was
consistent with the system’s position around granting exceptions” (emphasis
added). Further, supervisors were to assure their subordinates that “each request
was evaluated based on all information provided, and because of that there is no
appeal process.”
g.
These instructions were given despite defendant deliberately withholding the
identity of those who sat on the committee and withholding “the system’s
position” for granting accommodations;
h.
Additionally, defendant deliberately failed to provide its employees with an
option to provide supporting information with their accommodation requests
before its anonymous committee “evaluated based on all information provided”
and denied the requests;
i.
Defendant would not allow for any appeals to denials of religious and disability
accommodations (Exhibit H), nor did defendant engage in any meaningful
interactive process with any of the plaintiffs; and
j.
Defendant granted many accommodations for employees with nearly identical
accommodation requests (Exhibit I) yet denied plaintiffs’ accommodation
requests with no explanation as to why.
3 On occasion, some members of the committee would respond using their names instead of the standard signature
“The MGB Vaccination Committee,” however the committee members, their qualifications, and the evaluation
criteria were never disclosed.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 85 of 101

86
78101496v.7
ANSWER:
Paragraph 241, including subparagraphs a-j, contains conclusions of law to which no
response is required.  As to the factual allegations contained in subparagraphs a-j, Defendant
denies the allegations except to state that the written communications referenced in
subparagraphs (a), (b), (e), and (f) speak for themselves, and Defendant denies the allegations in
those subparagraphs to the extent they are inconsistent with those written records – and to admit
that, as to subparagraph (c), for reasons including but not limited to protecting the employees
who comprised the Religious Exemption Review Committee and medical panels from
harassment, MGB did not identify the individual employees tasked with evaluating exemption
requests.
MASS GENERAL BRIGHAM’S DISABILITY DISCRIMINATION
COMPLAINT ¶242:
At least 29 Plaintiffs requested reasonable accommodations for disabilities under the
ADA.
ANSWER:
Defendant denies the allegations in Paragraph 242 except to admit that 25 Plaintiffs raise
allegations in this Corrected Amended Complaint related to requests for medical exemptions
from MGB’s COVID-19 vaccination requirement.
COMPLAINT ¶243:
Further, defendant did not engage in any meaningful interactive process with plaintiffs
who asserted their medical disabilities, which is a protected activity.
ANSWER:
Defendant denies the allegations in Paragraph 243.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 86 of 101

87
78101496v.7
COMPLAINT ¶244:
In lieu of an interactive process and in lieu of any reasonable accommodations, defendant
is [sic] placed unvaccinated plaintiffs on unpaid leave on October 20, 2021 and were terminated
on or about November 5, 2021.
ANSWER:
Defendant denies the allegations in Paragraph 244 except to admit that individuals who
did not comply with MGB’s vaccination requirement were placed on unpaid leave on or about
October 20, 2021 and were terminated on or about November 5, 2021.
MASS GENERAL BRIGHAM’S RELIGIOUS DISCRIMINATION
COMPLAINT ¶245:
To date, defendant has not stated what their “position on granting exceptions” is for
religious accommodations.
ANSWER:
Paragraph 245 is unintelligible.  To the extent a response is required, Defendant denies
the allegations in Paragraph 247.
COMPLAINT ¶246:
At least 204 Plaintiffs submitted a religious accommodation request.
ANSWER:
Defendant denies the allegations in Paragraph 246 except to admit that 214 Plaintiffs
raise allegations in this Corrected Amended Complaint related to requests for religious
exemptions from MGB’s COVID-19 vaccination requirement.
COMPLAINT ¶247:
These plaintiffs have sincerely held religious beliefs, rooted in Biblical Scripture and
received by them through prayer.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 87 of 101

88
78101496v.7
ANSWER:
Defendant lacks sufficient knowledge and information to respond to the allegations set
forth in Paragraph 247 and leaves Plaintiffs to their proof.
COMPLAINT ¶248:
Plaintiffs seek to make daily decisions, including those regarding vaccination and other
medical decisions, through prayer and by reading the Bible.
ANSWER:
Defendant lacks sufficient knowledge and information to respond to the allegations set
forth in Paragraph 248 and leaves Plaintiffs to their proof.
COMPLAINT ¶249:
These sincerely held and prayerfully developed religious beliefs preclude plaintiffs from
taking the COVID-19 vaccines.
ANSWER:
Defendant lacks sufficient knowledge and information to respond to the allegations set
forth in Paragraph 249 and leaves Plaintiffs to their proof.
COMPLAINT ¶250:
For plaintiffs to disobey sincerely held religious beliefs would violate their conscience.
See John 14:15 (NIV): “If you love me, keep my commands,” Acts 5:29 (KJV) “...We ought to
obey God rather than men.”
ANSWER:
Defendant lacks sufficient knowledge and information to respond to the allegations set
forth in Paragraph 250 and leaves Plaintiffs to their proof.
COMPLAINT ¶251:
All of the plaintiffs had their religious accommodation requests denied, without an
opportunity to appeal, and without any meaningful interactive process. (See ¶ 243 regarding
denial emails).
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 88 of 101

89
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 251 except to admit that, due to urgent
health and safety priorities, MGB determined it could not provide an appeal process for each
employee whose religious exemption request was denied.  Defendant affirmatively states that
where employees submitted additional communications after their requests were denied, one or
more individuals on the Religious Exemption Review Committee or the two clinical panels of
medical experts reviewed and considered those additional communications to the extent feasible.
COMPLAINT ¶252:
Plaintiffs submitted their request on an online exemption form that did not allow for
submission of supporting documents.
ANSWER:
Defendant admits that the initial religious exemption request form did not include an
option to append supporting documentation.  Defendant affirmatively states that through its
interactive process, employees could submit any supporting documentation that they believed
was relevant to the Religious Exemption Review Committee by email – and those seeking
religious exemptions from the vaccination requirement routinely provided such supporting
documentation.
COMPLAINT ¶253:
Not only were plaintiffs unable to submit supporting documents, but they were also not
informed as to who was reviewing their submissions. Thus, they had no way of providing
supporting documents through any other platform until they were denied.
ANSWER:
Defendant denies the allegations in Paragraph 253 except to admit that, for reasons
including but not limited to protecting the employees who comprised the Religious Exemption
Review Committee and medical panels from harassment, MGB did not identify the individual
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 89 of 101

90
78101496v.7
employees tasked with evaluating exemption requests.  Defendant affirmatively states that
through its interactive process, employees could submit any supporting documentation that they
believed was relevant to the Religious Exemption Review Committee by email.
COMPLAINT ¶254:
Plaintiffs were therefore reduced to an attempt at describing their personal religious
beliefs in a text box which visibly displayed, in the case of plaintiff DiCicco, a total of eight
words.
ANSWER:
Defendant denies the allegations in Paragraph 254.  MGB affirmatively states that it
provided employees with a free text field to respond to the two-prong prompt that Plaintiffs
quote in Paragraph 237 – and employees could choose how long of an explanation to write and
that the text box expanded as needed.
COMPLAINT ¶255:
Once these forms were submitted (by design, without the option to submit supporting
documents), defendant then denied plaintiffs requests for religious accommodations.
ANSWER:
Defendant denies the allegations in Paragraph 255.
COMPLAINT ¶256:
Defendant then emailed its department supervisors, instructing them to use talking points
with subordinates who had been denied religious exemptions, stating “each request was
evaluated based on all information provided, and because of that there is no appeal process.”
ANSWER:
Defendant states that the referenced email speaks for itself and denies the allegations in
Paragraph 256 to the extent they are inconsistent with the referenced email.
COMPLAINT ¶257:
In other words, defendant is simply paltering: It claims that it evaluated accommodation
requests based on “all the information provided,” which in itself is true, however, only because
defendant made it impossible for plaintiffs to provide supporting documents by not allowing for
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 90 of 101

91
78101496v.7
their submission on the exemption form and by not informing plaintiffs of who was reviewing
their request so that substantive information could be sent to those individuals.
ANSWER:
Defendant denies the allegations in Paragraph 257.
COMPLAINT ¶258:
Thus, plaintiffs’ accommodation requests (which defendant effectively reduced to what
plaintiffs could fit into a small, one line text box), were then swiftly denied, with the blame
placed on the plaintiffs, and the façade of a legitimate process being published to defendant’s
supervisors and employees.
ANSWER:
Defendant denies the allegations in Paragraph 258.
COMPLAINT ¶259:
Each plaintiff who sought a religious exemption was subject to the same procedure and
was not afforded an appeal or any meaningful interactive process.
ANSWER:
Defendant denies the allegations in Paragraph 259.
COMPLAINT ¶260:
Plaintiffs who failed to receive the vaccination were placed on unpaid leave on October
20, 2021 and were terminated on or about November 5, 2021.
ANSWER:
Defendant denies the allegations in Paragraph 260 except to admit that individuals who
did not comply with MGB’s vaccination requirement were placed on unpaid leave on or about
October 20, 2021 and were terminated on or about November 5, 2021.
COUNT I
(Disability Discrimination – Failure to Make Reasonable Accommodations)
COMPLAINT ¶261:
Plaintiffs repeat and reallege paragraphs 1-260 of this Complaint.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 91 of 101

92
78101496v.7
ANSWER:
Paragraph 261 consists of a statement of incorporation, to which no response is required.
To the extent that a response is required, Defendant incorporates its responses to the preceding
paragraphs.
COMPLAINT ¶262:
Plaintiffs who sought disability accommodations, all of whom are “qualified individuals”
under the definition of 42 U.S.C. 121114, requested reasonable accommodations for their specific
disabilities with respect to defendant’s vaccination policy in writing by submitting defendant’s
required exemption form.
ANSWER:
Paragraph 262 contains conclusions of law to which no response is required.  To the
extent a response is required, Defendant denies the allegations in Paragraph 262.
COMPLAINT ¶263:
Defendant has (and had) a duty as plaintiffs’ employer under 41 U.S.C. 12112(b)(5)(a) to
make “reasonable accommodations to the known physical or mental limitations of an otherwise
qualified individual with a disability.”
ANSWER:
Paragraph 263 contains conclusions of law to which no response is required.  To the
extent a response is required, Defendant denies the allegations in Paragraph 263.
COMPLAINT ¶264:
Defendant was and is “obligated to provide a reasonable accommodation (as long as it is
not unduly burdensome) where a protected employee has requested an accommodation, or the
employer otherwise knew that one was needed.” Murray v. Warren Pumps, LLC, 821 F.3d 77, 84
(1st Cir. 2016).
ANSWER:
Paragraph 264 contains conclusions of law to which no response is required.
4 Plaintiffs “with or without reasonable accommodation, can perform the essential functions of the employment
position that such individual holds or desires.” Id.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 92 of 101

93
78101496v.7
COMPLAINT ¶265:
Defendant failed to provide any reasonable accommodations upon reasonable requests by
plaintiffs.
ANSWER:
Defendant denies the allegations in Paragraph 265.
COMPLAINT ¶266:
Defendant failed to assert an undue hardship that would be caused by accommodating
plaintiffs’ disabilities.
ANSWER:
Defendant denies the allegations in Paragraph 266.
COMPLAINT ¶267:
Despite failing to assert an undue hardship, defendant in fact would not be “unduly
burdened” or face hardship in accommodating plaintiffs’ requests5, not only because it would not
financially or operationally burden defendant to accommodate plaintiffs (See Exhibit P), but
because defendant did accommodate some employees while others (including plaintiffs), it chose
not to, despite the accommodation requests being similar or nearly identical.
ANSWER:
Defendant denies the allegations in Paragraph 267.
COMPLAINT ¶268:
Defendant also failed to engage in any meaningful discussion, interactive process or
appeal with the plaintiffs who requested reasonable accommodations.
ANSWER:
Defendant denies the allegations in Paragraph 268.
5 Defendant’s most recent 990T form available via the IRS
(https://apps.irs.gov/pub/epostcard/cor/043230035_201909_990T_2020120117460444.pdf) shows that it has assets
of over six billion and as of August 10, 2021, defendant brought in revenues of $4.1 billion in the third quarter of
2021 alone: https://www.beckershospitalreview.com/finance/mass-general-brigham-posts-2-9b-gain-over-9-
months.html. Therefore, under § 12111’s definition of “undue hardship,” requiring significant difficulty or expense,
defendant cannot (and did not) assert that the accommodations would be unduly burdensome.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 93 of 101

94
78101496v.7
COMPLAINT ¶269:
All plaintiffs were and are ready, willing and able to abide by any reasonable
accommodations to defendant’s policy including those safety precautions already in effect.
ANSWER:
Defendant lacks sufficient information and information to respond to the allegations set
forth in Paragraph 269 as to what Plaintiffs were “ready, willing and able” to do and otherwise
denies the allegations in Paragraph 269.
COMPLAINT ¶270:
Plaintiffs are all facing adverse employment action, namely being placed on unpaid leave
and subsequently terminated, due to their inability to adhere to the defendant’s policy because of
their disabilities.
ANSWER:
Defendant denies the allegations in Paragraph 270.
COUNT II
(Religious Discrimination)
COMPLAINT ¶271:
Plaintiffs repeat and reallege paragraphs 1-270 of this Complaint.
ANSWER:
Paragraph 271 consists of a statement of incorporation, to which no response is required.
To the extent that a response is required, Defendant incorporates its responses to the preceding
paragraphs.
COMPLAINT ¶272:
Title VII prohibits “discriminat[ion] against any individual with respect to his
compensation, terms, conditions, or privileges of employment, because of such individual’s race,
color, religion, sex, or national origin.” Xiaoyan Tang v. Citizens Bank, N.A., 821 F.3d 206, 215
(1st Cir. 2016) quoting from 42 U.S.C. § 2000e–2(a)(1).
ANSWER:
Paragraph 272 contains conclusions of law to which no response is required.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 94 of 101

95
78101496v.7
COMPLAINT ¶273:
Defendant had a duty to “[o]ffer a reasonable accommodation to resolve a conflict
between an employee’s sincerely held religious belief and a condition of employment, unless
such an accommodation would create an undue hardship for the employer’s business.” Cloutier
v. Costco Wholesale Corp., 390 F.3d 126, 133 (1st Cir. 2004).
ANSWER:
Paragraph 273 contains conclusions of law to which no response is required.  To the
extent a response is required, Defendant denies the allegations in Paragraph 273.
COMPLAINT ¶274:
Once an employee demonstrates that their religious belief conflicts with an employment
condition, “the burden then shifts to the employer to show that it offered a reasonable
accommodation or, if it did not offer an accommodation, that doing so would have resulted in
undue hardship.” Id.
ANSWER:
Paragraph 274 contains conclusions of law to which no response is required.
COMPLAINT ¶275:
Plaintiffs requesting religious accommodations submitted a request for religious
accommodation to the defendant’s vaccination policy, informing defendant that its vaccination
policy was in conflict with their sincerely held religious beliefs.
ANSWER:
Defendant admits that some Plaintiffs submitted requests for religious exemption from
the vaccination requirement and otherwise denies the allegations in Paragraph 275.
COMPLAINT ¶276:
These requests were submitted via an online form, as required by defendant.
ANSWER:
Defendant admits that one element of the interactive process included an online form.
Defendant otherwise denies the allegations in Paragraph 276.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 95 of 101

96
78101496v.7
COMPLAINT ¶277:
Defendant neither offered to accommodate the plaintiffs nor showed that an
accommodation would have resulted in “undue hardship.”
ANSWER:
Defendant denies the allegations in paragraph 277.
COMPLAINT ¶278:
Despite failing to assert an undue hardship, defendant in fact would not be “unduly
burdened” or face hardship in accommodating plaintiffs’ requests, not only because it would not
financially or operationally burden defendant to accommodate plaintiffs, but because defendant
did accommodate some employees while others (including plaintiffs), it chose not to, despite the
accommodation requests being similar or nearly identical.
ANSWER:
Defendant denies the allegations in paragraph 278.
COMPLAINT ¶279:
Defendant also failed to engage in any meaningful discussion, interactive process or
appeal with the plaintiffs who requested reasonable accommodations.
ANSWER:
Defendant denies the allegations in paragraph 279.
COMPLAINT ¶280:
All plaintiffs were and are ready, willing and able to abide by any reasonable
accommodations to defendant’s policy including those safety precautions already in effect.
ANSWER:
Defendant lacks sufficient information and information to respond to the allegations set
forth in Paragraph 280 as to what Plaintiffs were “ready, willing and able” to do and otherwise
denies the allegations in Paragraph 280.
COMPLAINT ¶281:
Plaintiffs are all facing adverse employment action, namely being placed on unpaid leave
and subsequently terminated, due to their inability to adhere to the defendant’s policy because of
their religious beliefs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 96 of 101

97
78101496v.7
ANSWER:
Defendant denies the allegations in Paragraph 281.
PRAYER FOR RELIEF
COMPLAINT ¶282:
Declaration that defendant violated Title VII and the ADA by discriminating against
plaintiffs;
ANSWER:
Defendant denies that Plaintiffs are entitled to the relief sought, or to any relief.
COMPLAINT ¶283:
Enjoin defendant from taking adverse employment action against plaintiffs;
ANSWER:
Defendant denies that Plaintiffs are entitled to the relief sought, or to any relief.
COMPLAINT ¶284:
Enjoin defendant from enforcing its vaccination policy against plaintiffs until a verdict is
rendered by a jury;
ANSWER:
Defendant denies that Plaintiffs are entitled to the relief sought, or to any relief.
COMPLAINT ¶285:
Money damages;
ANSWER:
Defendant denies that Plaintiffs are entitled to the relief sought, or to any relief.
COMPLAINT ¶286:
Attorney fees and costs, plus any other relief this Court deems proper.
ANSWER:
Defendant denies that Plaintiffs are entitled to the relief sought, or to any relief.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 97 of 101

98
78101496v.7
AFFIRMATIVE DEFENSES
First Affirmative Defense
Plaintiffs fail to state a claim upon which relief can be granted.
Second Affirmative Defense
To the extent Plaintiffs’ claims are based on acts that occurred prior to any applicable
statute of limitations, Plaintiffs’ claims are time-barred, in whole or in part.
Third Affirmative Defense
To the extent Plaintiffs failed to exhaust their administrative remedies and/or failed to
comply with the procedural prerequisites prior to bringing some or all of their claims, the Court
lacks subject matter jurisdiction over such claims or such claims are otherwise barred.
Fourth Affirmative Defense
Granting Plaintiffs’ requests for exemption from the vaccination requirement would have
posed an undue hardship on Defendant.
Fifth Affirmative Defense
Plaintiffs who sought medical exemptions from the vaccination requirement were not
qualified individuals under the ADA because they posed a direct threat to the workplace and no
reasonable accommodation would eliminate that threat.
Sixth Affirmative Defense
Plaintiffs who sought medical exemptions from the vaccination requirement have not
shown that they were disabled under the law.
Seventh Affirmative Defense
MGB was not the employer of all of the Plaintiffs.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 98 of 101

99
78101496v.7
Eighth Affirmative Defense
To the extent Plaintiffs allege that any of Defendant’s employees acted in an improper or
illegal manner, such conduct, if it occurred, was outside the course and scope of their employment,
was not authorized, ratified, or condoned by Defendant, and was undertaken without the
knowledge or consent of Defendant.  Thus, Defendant is not liable for any such conduct, if it
occurred.
Ninth Affirmative Defense
Defendant has complied with all laws and regulations and otherwise satisfied its statutory
obligations toward Plaintiffs under Title VII and the ADA.
Tenth Affirmative Defense
Plaintiffs cannot establish a prima facie case of disability discrimination or religious
discrimination.
Eleventh Affirmative Defense
Plaintiffs’ claims are not actionable because the employment practices and/or decisions
challenged in the Complaint are justified by legitimate, non-discriminatory reasons.
Twelfth Affirmative Defense
Defendant avers that even if some impermissible motive were a factor in any employment
decision(s) concerning plaintiff, a claim that Defendant expressly denies, the same decision(s)
would have been reached for legitimate business reasons.
Thirteenth Affirmative Defense
Without conceding that Plaintiffs have suffered any damages as a result of the purportedly
wrongful acts of Defendant, Plaintiffs have failed to mitigate their damages.
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 99 of 101

100
78101496v.7
RESERVATION OF RIGHTS
Defendant reserves the right to raise additional defenses as may be discovered during the
course of these proceedings.  Defendant joins Plaintiffs in their request for a jury trial.
DATED:  January 21, 2022
Respectfully submitted,
DEFENDANT
MASS GENERAL BRIGHAM
INCORPORATED
By Its Attorneys,
/s/ Lynn A. Kappelman
Lynn A. Kappelman (BBO# 642017)
Katherine E. Perrelli (BBO# 549820)
Kristin McGurn (BBO# 559687)
Dawn Reddy Solowey (BBO# 567757)
SEYFARTH SHAW LLP
Seaport East
Two Seaport Lane, Suite 1200
Boston, MA 02210-2028
kperrelli@seyfarth.com
lkappelman@seyfarth.com
kmcgurn@seyfarth.com
dsolowey@seyfarth.com
TEL: (617) 946-4800
FAX: (617) 946-4801
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 100 of 101

101
78101496v.7
CERTIFICATE OF SERVICE
I, Lynn A. Kappelman, certify that on January 21, 2022, I caused a true and accurate
copy of the foregoing document to be filed and uploaded to the CM/ECF system.
/s/ Lynn A. Kappelman
Lynn A. Kappelman
Case 1:21-cv-11686-FDS   Document 63   Filed 01/21/22   Page 101 of 101

File and source

File

gov.uscourts.mad.238919.63.0.pdf

Size

273,167 bytes

SHA-256

d735e334f1fb7baeb91e8b1eda429e7f2f4d85398b6907bf191801e964fc6e05

Our copy

gov.uscourts.mad.238919.63.0.pdf

Original

archive.org