costs that was entered in favor of the defendant the case involves an african american woman who was a six year employee of the j t d c juvenile temporary detention center as the quarters where the center was under the consent decree and was operated pursuant to a court order by girl dunlap she had a requisite educational background including people there were given those position who are not african american in fact we did not have the educational and work experience that she did so she attempted to do that the problems occurred during her secure employment when she miss crothers head a automobile accident where she was injured and both of her hands did as a result she filed a workout she was unable to work for a period of time and then in june of two thousand  she came upon a riot by juvenile detainees at the facility and during her attempt to contact for a back up in assistance she was rushed by the detainees pinned to a desk by one of them and was brutalized she sustained injuries as a result of this attack and she reported it to her supervisor and she was sent to the emergency room at the hospital for treatment the injuries aggravated the preexisting injury that she had to her hands as a result of the car accident her hand of swelled up and she was unable to function in her job she was off from work pursuant to doctor's notice  could not breathe fainted she had to be taken to a hospital and treated at the hospital and this was because she was forced by the employer into that situation which they knew that she should she was restricted by doctor's orders from being put into with the juvenile detainees because of the anxiety disorder that she was diagnosed with her workman's comp claim was contested she was told to go on disability and go to the pension board and there was a refusal to deal with her situation in a matter that we argue in our brief she should have been and could have been accommodated and with those restrictions and she was certainly qualified and able to perform the positions th were available other dandy contact with the joint i'll paint he's as i said she was an employee prior to being diagnosed with anxiety disorder she had a good work history up until these series of incidents and injuries and there were reasonable accommodations that could have and should have been made to take into account her disability plaintiff also brought claims for sex and race discrimination in addition to plea well this is kind of fact specific your honor because she was brutalized by the juvenile detainees during this riot incident that she was she found herself in a metal lot so that has not only cause or physical but also psychological injuries that were diagnosed and treated by both counseling and medication and confirmed in fact by three separate doctors who doesn't add that fact that the  thirty could be a major life it gives include quote performing manual tasks seeing hearing standing speaking breathing learning reading concentrating thinking communicating and working with one c she was working gathering statistics for various supervisors and the board and she had to report to the federal court in relation to her consent decree and she worked as a hearing officer on disciplinary manners  other employees who were alleged to have violated rules and procedures you know absentee issues violence towards detainee issues or inappropriate behavior on the job that type of situation w no typically these war alleged violations of the personnel code or policies or procedures of the county of cook as they related to the  implementation of their duties at work or they would involve violation of the provisions of the consent decree itself but they did not involve detainees being present to during the the disciplinary hearings typically that would involve union representation perhaps an attorney if the employee had one it would be that type of situation but  americans with disability act as amended in two thousand and eight provided that the primary purpose was to make it easier for people with disabilities to obtain protection under the a b a and it was not you know the question of whether an individual meets the definition of disability on the disk partition not be should not the man extensive analysis because the courts have previously been looking at more of a disability analysis rather than looking at the discrimination allegation basically the plaintiff relies solely on her own deposition testimony i'm not contending the depositional plaintiff alone can't a stablish or can't can't defeat a motion for summary judgment but one presumes that it's only when those facts are colorable true that it can defeat the most that is maybe in the in her testimony but it's certainly not justified by the records that we have with regard to the major life activities your honor it's clear first of all it's important note that in their response to the motion for summary judgment ms cr based on that the court determined that that is not a major life function synthetic schools have to the job that she was working at appeal in the brief she suggested that she was quoted from working in any job that might have contact with children however i forgot to mention  but in at the time that she supposedly was put in work with any children she was a clerk at a part time worker at the lady footlocker where lady footlocker go and so necessarily she would come into contact with juveniles and that what i don't know into contact with public is clearly refuted by the record and by her own testimony also you're honest with regard to their constant claims that somehow their job g t c that didn't job involve contact with children the record doesn't support that either we  individuals that couldn't work with kids but that's not because of disability it's because they had committed some act that caused them to be fired if it involved contact with children and so when a court ordered them to return to work early on like put them  record children not because of a disability not because of a physical or mental condition but rather because he didn't trust and those are the only two people in the record in her motion in the response to a motion for summary judgment miss caruthers identifies of a document that was produced by the for the county board that identifies the various work centers in d c and claims that this shows that in fact there are jobs without children contect but there's nothing in there that actually says these jobs don't tell children how to just identifies the various work areas description in march of two thousand and ten she came back in march doesn't townsite in march two thousand and ten she signed a job description which included the up responsibility of being a hearing officer she told bill kern her supervisor that if actually she wasn't  hearing officer but she still signed the form it wasn't until current forced her to perform the responsibility of a hearing officer that she suddenly produce the note from a doctor he's not even a doctor he's a health health specialist and that no just simply sa given past circumstances she shouldn't be working with children at this time this pressure mentioned three doctors i'm aware of dr monarchy and this health profession i'm not aware of another doctor in the record who has said that she can't work which own but be that as it may it's clear that her limitation was job specific and so the inability of her to do to work with children j t c means that she is not otherwise qualified there's no accommodation that we can make that would enable her to perform her job her job involves hearing children's  there is another clerk it's likely bananas and she does principally data entry but the reason that she princely does it big data entry is because she was better at it than it was brothers was but it still doesn't preclude the chance that at some point in the future she may also become a hearing officer the job requires flexibility that's why it's hearing officer at ministry of assistant because when you need more hearing officers you need the ability of all six of them to work a five in the work that's what kurt was trying to do that's why he required her to go to the the training and to begin hearing off service hearing officer again you're right that we can talk much more initially about the gender discrimination or the sex discrimination but it's clear that there's a failure proof in that regard the there is no was someone who was excess had excess of absenteeism and was fired but there was a lot of return in fact mr mosley was sick he took a leave of absence when he got better he came back to work there was nothing to show that there was any gender discrimination or sex discrimination she didn't like and then says she necessarily is or telly and against bill kern and brenda walsh to people that were in pop that were supervisors to miss caruthers both testify that they weren't even aware of the e e o c claims so they couldn't have been the butt for cause can hear there are disagreements and disputed facts here between the parties even as to some of the essential things counsel said to the court that does he doesn't know of the three doctors they are dr campbell dr miller and dr amen kosky who is a cook county medical evaluated who also found this carruthers to be diagnosed with an anxiety disorder and should you know agree that she should not be for a period of time the place is being used as a patronage dumping ground the jap last a few cations meant nothing in the budget they were ignored ho sale monies were being wasted stolen children were being abused so there's a long history administrative positions that did not have a contact with the residence for example in the partners for payroll business finance executive secretaries numerous other positions where a catholic with the detainees was not required the employer had a duty to try to accommodate it and part of that was to consult with the employee does that to determine the precise job related limitations imposed by the disability and the provider the overcome those within reasonable accommodation there was no attempt to to do that with miss crothers in fact every obstacle was placed in front of her at every step of the way with respect to the disability the workman's compensation that this is the medical are all kinds of obstacles that were placed before her to make sure that she is not able to return to her usual position when she applied for other jobs you know she was selected for either of the two positions that she did apply for as we have stated in our reply brief you know the the disability here is clearly documented by three separate physicians it is a recognize disability on their da da their war reasonable accommodations that the employer could have made if they wanted to but you know because of the if you will oversight by the federal court and mr d violated her constitutional rights and therefore we are asking our honor to take into consideration both our grief and the reply very and take a look at the arguments as well as the cases we believe that the trial court should be