Declaration of Tyler Adams — Adams v. Mass General Brigham, Inc. (D. Mass.)
- Date
- 2025-03-18
Summary
Document 285-1, filed March 18, 2025 in Adams, et al. v. Mass General Brigham, Inc., Civil Action No. 1:21-11686-FDS, in the U.S. District Court for the District of Massachusetts, is Exhibit B, the declaration of plaintiff Tyler Marie Adams. The pro se declaration is offered in support of the pro se plaintiffs' motion to deconsolidate cases and their second amended complaint. It recounts the declarant's employment with Mass General Brigham from March of 2018, a remote position begun on October 21, 2020, and the denial of her COVID-19 vaccine medical exemption requests on August 30, 2021 and September 16, 2021. The declaration states she was terminated on November 10, 2021 for failing to comply with the vaccine mandate. It also describes her concerns about communication with her former counsel, Attorney Ryan McLane, and about settlement negotiations and discovery materials.
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
Case 1:21-cv-11686-FDS Document 285-1 Filed 03/18/25 Page 1 of 6
EXHIBIT
B
DECLARATION OF
TYLER ADAMS
Case 1:21-cv-11686-FDS Document 285-1 Filed 03/18/25 Page 2 of 6
Page 1 of 5
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
____________________________________
)
TYLER ADAMS, ROSEANN )
MCNAMARA, MICHELLE ORFANOS, )
DR. SARAH SHULMAN, AND JAMIE )
STEVERMAN, )
Plaintiffs, )
) Civil Action No. 1:21-11686-FDS
v. )
)
MASS GENERAL BRIGHAM, INC. and )
Defendant. )
____________________________________)
DECLARATION OF TYLER MARIE ADAMS
In support of their “PRO SE PLAINTIFFS’ MOTION TO DECONSOLIDATE CASES AND
SEPARATE FROM THE REPRESENTED PLAINTIFFS” and “PRO SE PLAINTIFFS’
2ndAMENDED COMPLAINT AND MEMORANDUM OF LAW IN SUPPORT” against
MASSGENERAL BRIGHAM, INC. (“the defendant”), Tyler Marie Adams submits this affidavit
as testimony in this case.
I, Tyler Adams, hereby declare under penalty of perjury that the following facts are true to
the best of my knowledge, belief, and recollection:
Personal Information:
1. I am over the age of eighteen and am a citizen of the United States of America and of
the State of South Carolina.
Employment History with Mass General Brigham (MGB):
2. I began employment with Mass General Brigham at North Shore Physicians Group in Rowley,
MA, in March of 2018.


Case 1:21-cv-11686-FDS Document 285-1 Filed 03/18/25 Page 3 of 6
Page 2 of 5
3. On or about November , 2018 I received my first promotion.
4. Between 2018 and 2021, I received four salary increases for my performance.
5. I was chosen by leadership to participate in a Rapid Process Improvement workshop in March
of 2019.
6. I received a certificate for recognition of my valuable contributions, as well as over a dozen
"Made Someone’s Day" certificates for my excellent commitment to service between 2018 and
2020.
7.On June 16, 2020, I provided Office Manager Maryellen Percival a letter from my primary care
provider confirming an allergic reaction to medical-grade surgical masks.
8. On August 25, 2020, I emailed my manager, Maryellen Percival, and MGB Occupational
Health a letter from my dermatologist, Kim Comeau PA-C, which included test results verifying
my severe allergy to compounds found in surgical masks and N95 masks. The letter stated that I
should avoid all N95 and surgical masks due to this severe allergy.
9. On or about October 5, 2020, I was provided a PAPR apparatus by Occupational Health due to
my allergic reaction to masks.
10. On October 7, 2020, I sent an email to Human Resources (HR) Sandra Rossetti and others
detailing the challenges of wearing the PAPR.
11. On or about October 8, 2020, I had a meeting with my manager, Maryellen Percival, and HR,
Sandra Rossetti, to discuss alternatives to the PAPR, including the use of a CAPR, a remote
position, or applying for FMLA.
12. On or about October 12, 2020, I was provided a CAPR to use, which was unsuccessful.


Case 1:21-cv-11686-FDS Document 285-1 Filed 03/18/25 Page 4 of 6
Page 3 of 5
13. On October 21, 2020, I was granted and began a full-time remote position as a New Patient
Intake Clinical Navigator.
Mortgage Loan and Knowledge of COVID Vaccine Mandates:
14. In late February 2021, I applied for a mortgage loan to purchase property. There
was a question on one of the forms submitted to MGB HR in March 2021 asking
about the probability of continued employment (whether the employer planned on
terminating the applicant within the next year or two). During review of depositions I
received on December 23, 2024, defense counsel's agents testified that MGB knew
by late 2020 that COVID-19 vaccine mandates were coming in 2021.
15. On April 5, 2021, I closed on the property I had applied for in February 2021.
COVID-19 Vaccine Exemption Process:
16. On August 23, 2021, I submitted my medical exemption form for the COVID-19
vaccine, stating that I am allergic to MiraLAX (the brand name for PEG). This is a CDC
contraindication to the COVID vaccine.
17. On August 30, 2021, I received an email from the medical exemption committee
denying my request, despite my status as a full-time work-from-home employee
(100% off-site). The denial stated, “The medical information you provided does not
demonstrate sufficient medical reasons or contraindication to support an exemption.”
18. On September 2, 2021, I sent Occupational Health a letter from my primary care
physician, Dr. Guy Navarra, verifying my medical exemption due to a history of
multiple severe allergies, including an allergy to MiraLAX (PEG), Cipro, and a history
of thrombophilia.


Case 1:21-cv-11686-FDS Document 285-1 Filed 03/18/25 Page 5 of 6
Page 4 of 5
19. On September 16, 2021, I received a second email from the medical exemption
committee again denying my request, despite MGB having three letters from my
doctors confirming my medical history and allergic reactions. The committee
recommended that I consult an MGB allergist.
20. On or about early September 2021, HR began emailing employees daily,
instructing them to receive the COVID-19 vaccination by October 15, 2021, or face
termination from employment.
21. On October 4, 2021, I communicated with HR business partner Sandy Rosetti regarding my
exemption denial, to which I was only informed that my medical exemption had been denied
after being reviewed by MBG “clinical experts”, despite the medical advice and decision made
by my primary care physician and my employment status being fully remote. I was advised that
if I did not comply, my employment would end regardless of the facts I presented.
Termination and Unemployment Benefits:
22. On November 10, 2021, I was terminated from my position for “failing to comply with the
COVID-19 vaccine mandate”
23. On November 10, 2021, I applied for unemployment compensation, which I received until
May 23, 2022. I began a part-time job as a massage therapist in June 2022.
Pursuit of Legal Action and Concerns About Representation:
24. On October 5, 2021, I retained Attorney Ryan McLane for legal representation, joining a
large group of plaintiffs suing MGB for discrimination related to the COVID-19 vaccine
exemption process.


Case 1:21-cv-11686-FDS Document 285-1 Filed 03/18/25 Page 6 of 6
Page 5 of 5
25. Throughout the case, communication with Attorney McLane was primarily through his
assistant and Zoom calls, which did not allow questions from plaintiffs. On one occasion,
Attorney McLane became belligerent when questioned about the handling of case funds.
26. On or about August 2024, I was told that the case was on hold due to final negotiations for a
settlement. Despite my repeated inquiries regarding the settlement's fairness, Attorney McLane
indicated that MGB would only accept a settlement with at least 80 plaintiffs.
27. On or about October 2024, I attempted to obtain discovery materials from Attorney McLane
but was told to get them from the defendant. When I contacted the Court, I was instructed to get
the materials from Attorney McLane or file a subpoena.
28. On or about December 2024, I discovered instances of disparate treatment, including the
reversal of vaccine exemption denials for other employees, including the assistant to Dr
Hashimoto. During this time, I also discovered that another employee was granted a vaccine
exemption due to an allergy which again was not afforded to me despite my diagnosis being
exactly the same.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this 17 day of March, 2025.
/s/ Tyler Adams
TYLER ADAMS (Pro se)
Declarant


File and source
- File
- gov.uscourts.mad.238919.285.1.pdf
- Size
- 180,496 bytes
- SHA-256
- 76fc3fd913ff238b560135279a241cb0c289e4b0353246cdc5880347fd50ac98
- Original
- archive.org