[brief] 62.  Admitted that Defendant [...] was never served with the purported letter of reprimand that Defendants produced in discovery.  Denied that Defendants have set forth a true, accurate, or credible rationale for why Defendant [...] was never served with the purported letter of discipline insofar as Defendants claim: "the reprimand was never served on him because during that time many members of the department were dealing with covid and the Director had to prioritize his actions."  63.  Admitted that Defendants maintained said antidiscrimination policy in writing.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  64.  Admitted that Defendants maintained said antidiscrimination policy in writing.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  65.  Admitted that Defendants maintained said antidiscrimination policy in writing.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  66.  Admitted that employees of the Defendant are trained on their written antidiscrimination policy.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  67.  Admitted that employees of the Defendant are trained on their written antidiscrimination policy.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  68.  Admitted that Defendants maintained said antidiscrimination policy in writing.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  69.  Admitted that Defendants maintained said antidiscrimination policy in writing.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  February 21, 2023  70.  Admitted that employees of the Defendant are trained on their written antidiscrimination policy.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  71.  Admitted that employees of the Defendant are trained on their written antidiscrimination policy.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  72.  Admitted that Defendants maintained said antidiscrimination policy in writing.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  73.  Admitted that Defendants maintained said antidiscrimination policy in writing.  Denied that upper management level personnel maintained workplace policies in practice or provided a culture of leadership which effectuated and enforced same.  PLAINTIFF'S STATEMENT OF MATERIAL OF FACTS