Response | Filed: July 31, 2026
| Entered: July 31, 2026
Hendrix v. Life Care Centers of America, Inc.
Civil Rights: Jobs | Kansas
Memorandum in Opposition to Motion
MEMORANDUM IN OPPOSITION by Plaintiff Faybria V. Hendrix re 46 MOTION for Summary Judgment (Attachments: # 1 Exhibit A - Askren Offer Letter and Termination Personnel Action Form, # 2 Exhibit B - P's Termination Personnel Action Form, June 26, 2024, # 3 Exhibit C - Email from Katie Rush, June 7, 2024, # 4 Exhibit D - Email and Attachment, June 7, 2024, # 5 Exhibit E - Reasonable Suspicion Checklist for Drug and Alcohol Screening, # 6 Exhibit F - Drug and Alcohol Policy, # 7 Exhibit G - Email Chain, Nieset to facility management, April 17, 2024, # 8 Exhibit H - P's Email to LCCA corporate, May 14, 2024, # 9 Exhibit I - Payroll records, January 2024 through June 2024, # 10 Exhibit J - EthicsPoint Case File, # 11 Exhibit K - Compliance In-Take File (intake form, EthicsPoint case record, and referral email, # 12 Exhibit L - Associate Handbook for Field Associates (excerpts), # 13 Exhibit M - Defendant's Responses to Plaintiff's First Request for Admission, # 14 Exhibit N - Defendant's Amended Rule 26(a)(1) Initial Disclosures served March 30, 2026, # 15 Exhibit O - Summary of Overtime Hours and Compensation (Fed. R. Evid. 1006), # 16 Exhibit P - Email from Mary Jones to LCCA Corporate, June 11, 2024, # 17 Exhibit Q - Defendant's Answers to Plaintiff's First Set of Interrogatories, # 18 Exhibit R - Defendant's Responses to Plaintiff's First Request for Production, # 19 Exhibit S - Letter from Darian D. Doser to Kenneth N. Caldwell, April 21, 2026, # 20 Exhibit T - Onboarding Policy Acknowledgement Form signed by Plaintiff, September 9, 2014)(Caldwell, Kenneth)