Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 1 of 35 PageID: 202
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`GEORGE SAQA
`
`Civil Action No. 2:23-03994-SDW-JBC
`
`Plaintiff
`
`vs.
`
` FIRST AMENDED COMPLAINT
`
` Jury Trial Demanded
`
`FACTORY MUTUAL INSURANCE
`COMPANY D/B/A FM GLOBAL
`
`Defendant
`
`________________________________________
`
`PLAINTIFF, George Saqa, residing at 185 West High St., Bound Brook, NJ 08805, by way of
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`First Amended Complaint against the above-named Defendant, says as follows:
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`THE PARTIES, VENUE, AND JURISDICTION
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`1. Plaintiff, George Saqa, (hereinafter “Saqa” or “Plaintiff” was an employee of Defendant
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`Factory Mutual Insurance Company D/B/A FM Global, who was hired on December 3,
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`2001, and worked for said Defendant until the time of his termination on January 4, 2022.
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`His most recent job title was Jurisdiction Consultant II, and his job responsibilities were
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`to inspect boilers at various facilities of Defendant’s insureds. He does not identify as a
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`member of any particular organized religious, but has maintained sincerely held religious
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`beliefs against all forms of immunization and vaccination, as well as abortion and human
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`~ 1 ~
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`

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`genetic modification, generally, which are integral to his comprehensive belief system
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`concerning deep and imponderable matters of right and wrong, good and evil, and life,
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`death and the afterlife. He prays for the guidance and blessing of God with respect to all
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`decisions concerning the care for the body He gave him, and which must be returned to
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`God upon his death without deviation from the design in which God intended for it, as he
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`believes that God created him in His perfect image, and that his body is a Temple of the
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`Holy Spirit. Observance of his faith therefore demands that he must maintain the sanctity
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`of his body against the desecration, invasion and/or alteration thereof, which includes
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`being compelled to undergo any unwanted medical procedure or receive any vaccine,
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`injection or immunization which would introduce substances or insert items into his body
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`that he believes to be unholy, or otherwise would alter it or any part thereof from God’s
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`intended design. He believes that life is sacred, begins at conception, that God did not
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`make any mistakes when He created any life on Earth, and that humanity substituting its
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`own judgment for God’s on matters of God’s Creation is blasphemy
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`2. Plaintiff therefore maintains a faith-based objection to the use of all vaccines and/or
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`immunizations, generally (which he has not received since turning the age of 18 in
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`observance of said religious beliefs), as well as the use of aborted fetal cell lines,
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`genetically modified and/or artificially preserved or “immortalized” human cell lines,
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`adenoviral vector technology, mRNA genetic modification or “gene therapy” technology,
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`and spike protein technology, as well as the use of animal and/or insect genetic material
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`to be injected into the human bloodstream, regardless of whether same are actual
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`ingredients or components in vaccine products themselves or were merely used in their
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`research, development and/or confirmatory lab testing, as anathema to his beliefs in the
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`
`
`~ 2 ~
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`

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`holiness and perfection of God’s Creation and divine providence, and considers using any
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`product produced with those elements, methods and functionality to be a sin. 1
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`3. Defendant Factory Mutual Insurance Company D/B/A FM Global, (Hereinafter “FM” or
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`“Defendant”) with a place of business located at 300 Kimball Dr., Parsippany-Troy Hills,
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`NJ 07054, is and is a business entity which holds itself out to the public as an issuer of
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`commercial property insurance. It is responsible for Plaintiff’s damages herein.
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`4. Venue and jurisdiction is proper in the United States District Court, District of New
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`Jersey pursuant to Federal Question Jurisdiction, as well as the location of all parties
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`within the State of New Jersey.
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`
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`
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`ALLEGATIONS OF FACT
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`5. In September of 2021, Defendant Factory Mutual Insurance Company D/B/A FM Global
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`announced to its employees that they would be required to partake in the use of a
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`COVID-19 vaccine product and provide proof of same by November 15, 2021 as a
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`continued condition of employment. It instructed its employees that they may request a
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`religious and/or medical accommodation from said requirement. Plaintiff requested same
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`on or about November 12, 2021. Plaintiff initially communicated to Defendant’s Human
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`Resources department via email that he cannot partake in the use of a vaccine whose
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`creation and development was supported by human genetic modification technology as
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`same contravened his sincerely-held religious beliefs. A copy of same is attached hereto
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`as Exhibit “A.”
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`1 Plaintiff cites to the Bible verses and religious texts 1 Corinthians 3:16-17, 1 Corinthians 6:19-20, Genesis 1:24 and
`1:28, Exodus 15:26 and 20:13, Leviticus 5:2, Numbers 6:24-26, Deuteronomy 32:39, Psalm 139:13-16, Jeremiah
`1:4-5, Psalm 103:3-5, Psalm 127:3-5, Matthew 6:24, Luke 16:13, Proverbs 6:16-19, John 3:16, Romans 14:5 and
`14:12, Psalm 22:10, Psalm 106:37-38 and Revelation 18:23, as well as the Catechism of the Catholic Church #1782
`and #1800 as representative of his underlying religious beliefs relevant to this action that conflicted with his
`former employer’s vaccine mandate. Teachings and elements of Christianity are incorporated into Plaintiff’s
`religious observance and identity.
`
`
`
`~ 3 ~
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`

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`6. Thereafter, on November 17, 2021, Julie J. Libutti, Defendant’s Manager of Human
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`Resources Business Partners sent Defendant an email enclosing a document which
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`belittled, questioned and “gaslighted” Plaintiff’s stated religious beliefs, claiming that
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`various major organized religions “all approved” of COVID-19 vaccination, and
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`informing him that if he “would nonetheless still like to move forward” with his request,
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`he would need to complete a questionnaire seeking additional information from him,
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`which Plaintiff understood to be Defendant informing him that his religious beliefs as
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`stated were unworthy of Defendant’s respect or understanding, and an attempt to
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`intimidate and/or dissuade him from proceeding with his accommodation request. On
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`information and belief, other employers in the State of New Jersey often accepted
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`statements similar to Plaintiff’s initial statement without further inquiry and granted their
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`employees the requested vaccine exemptions immediately, if they mandated COVID-19
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`vaccines at all, and did not subject their employees to this form of inquisition which
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`appears designed to harvest information upon which Defendant could rely upon to deny a
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`religious accommodation request. Plaintiff responded to this questionnaire. Copies of this
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`documentation are attached hereto as Exhibit “B.”
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`7. Thereafter, on December 6, 2021, Plaintiff received the enclosed document from Ms.
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`Libutti on behalf of Defendant attached hereto as Exhibit “C” indicating that Defendant
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`denied his religious exemption request, stating that he has “not shown a satisfactory basis
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`for an accommodation on religious grounds.” This document communicated the
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`ultimatum that Plaintiff partake in the use of a product forbidden by his faith by
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`December 13, 2021 or else his position will be terminated effective January 4, 2022.
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`~ 4 ~
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`

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`8. Thereafter, Plaintiff retained the undersigned counsel to communicate with Defendants
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`concerning the improper denial of his religious accommodation request. The undersigned
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`prepared the enclosed statement with Plaintiff’s participation which was signed by
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`Plaintiff and submitted to Defendants on December 9, 2021. Same provided extensive
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`additional details concerning Plaintiff’s faith-based objection to the use of COVID-19
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`vaccine products as well as all other vaccines and immunizations, and cited to specific
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`Christian religious texts faith which outlined his religious beliefs regarding same in order
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`to furnish Defendant with additional information, and as to how said beliefs were
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`consistently applied by Plaintiff in his life. The statement further explained Plaintiff’s
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`reasons as to why he felt that FM’s denial of his accommodation request was improper in
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`contravention to applicable law, and requested that same now be accommodated, and the
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`information contained therein was true and accurate at all times relevant to this action,
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`and did not reflect any recent change in religious beliefs since the time Plaintiff made his
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`initial request. Everything Plaintiff stated herein was his sincerely held religious beliefs at
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`all relevant times. Plaintiff, however, simply did not understand what information he was
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`supposed to convey in the first instance, having not been in this position before. Plaintiff
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`further was not attempting to obtain a “secular benefit” for mere “personal preferences,”
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`he was simply asking for a reasonable accommodation from having to choose between
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`the free exercise of his religious observance and his career. A true copy of this statement
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`is attached hereto as Exhibit “D.”
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`9. Instead of discharging its obligations under law to engage in a good faith “interactive
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`process” with Plaintiff following submission of his religious accommodation request,
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`Defendant instead subjected him to an overly oppressive and intrusive inquisition
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`
`
`~ 5 ~
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`

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`following which it denied same, wherein it harvested sensitive personal information from
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`him without any intention of giving said information any proper respect or consideration.
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`Despite being informed on numerous occasions by Plaintiff and his counsel that Plaintiff
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`honestly and reasonably believed it had violated the law, Defendant instead retaliated by
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`repeatedly telling Plaintiff that his religious beliefs were either fabricated, insincere, or
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`otherwise unworthy of their respect and/or acceptance, bullying him into violating his
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`religious beliefs under threat of losing his income, and ultimately, terminated Plaintiff’s
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`employment effective January 4, 2022.
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`10. On information and belief, at or around the time Defendant denied Plaintiff’s religious
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`accommodation request and thereafter terminated his employment, the “Omicron” variant
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`strain of COVID-19 was the predominant variant strain of COVID-19 present in the
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`United States and New Jersey, essentially replacing all previously prevalent variant
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`strains of the virus.
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`11. On information and belief, information was publicly available to Defendant at that time
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`indicating that the existing COVID-19 vaccine products then available to the public did
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`not actually prevent transmission or infection of the Omicron variant, or COVID-19 in
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`general.
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`12. In fact, on January 10, 2022, Albert Bourla, the CEO of Pfizer, the manufacturer of the
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`only COVID-19 vaccine product to have received full FDA approval at the time, openly
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`admitted in an interview with Yahoo Finance2 that two doses of its (then) current
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`COVID-19 vaccine provided “very little protection, if any” against the Omicron strain.
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`13. Upon information and belief, Defendant treated Plaintiff differently from other
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`individuals who requested accommodations from its COVID-19 vaccination requirements
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`2 Available at https://youtu.be/lhMbKyDq9_w
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`
`
`~ 6 ~
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`

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`(perhaps because Plaintiff did not consider himself as being an adherent of any particular
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`organized religion, though that is not a requirement for applicable statutory protection),
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`and it permitted others who worked for it to continue to do so unvaccinated for COVID-
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`19, whether those employees were given religious exemptions, medical exemptions, or
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`otherwise, despite its allegations to Plaintiff regarding “undue hardship.”
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`14. On information and belief, other companies that provided similar services to Defendant
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`in the State of New Jersey routinely granted religious accommodations from COVID-19
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`vaccine requirements (if they imposed them at all) to their employees at all times relevant
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`to this action.
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`15. Upon information and belief, Defendant could have accommodated Plaintiff’s sincerely
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`held religious beliefs which prohibited him from partaking in the use of a vaccine or
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`immunization without substantial increased burden(s) and/or cost(s) in relation to the
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`conduct of its particular business3, especially in light of the fact that the COVID-19
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`vaccine products available to the public at the time did not actually prevent transmission
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`or infection of COVID-19, but it refused to do so. Up until the time Plaintiff’s
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`employment was terminated, on information and belief, he was able to perform all
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`functions of his employment without issue based on his vaccination status.
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`16. On information and belief, Defendant had since rescinded its employee COVID-19
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`vaccination mandate after Plaintiff’s termination, and same is no longer in force or effect
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`at this time. Despite it having done so, and having the opportunity to both mitigate
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`Plaintiff’s financial damages and ameliorate its acts of discrimination by offering
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`Plaintiff reinstatement to his former position, Defendant has refused to do so.
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`3 See Groff v. DeJoy (No. 22-174, June 29, 2023).
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`
`
`~ 7 ~
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`

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`17. On March 3, 2022, Plaintiff filed a Charge of Discrimination with the U.S. Equal
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`Employment Opportunity Commission, alleging he was discriminated against on the
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`basis of his age and religion. On September 23, 2022, the EEOC issued a Notice of Right
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`to Sue to Plaintiff. True copies of both documents are attached hereto as Exhibit “E”
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`18. As a result of Defendant’s actions, Plaintiff has suffered the loss of his position which he
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`spent 20 years of his career, has suffered marginalization on the basis of his sincerely-
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`held religious beliefs, was subjected to a hostile work environment on the basis of his
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`religious beliefs, and has suffered both economic and non-economic damages.
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`COUNT ONE – VIOLATION OF THE NEW JERSEY LAW AGAINST
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`DISCRIMINATION N.J.S.A. 10:5-1 Et. Seq.
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`19. Plaintiff repeats and re-alleges all previous allegations of this First Amended Complaint
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`as if fully set forth herein.
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`20. The actions of Defendants and their staff as described above, inter alia, in failing to
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`consider Plaintiff’s religious accommodation request in good faith and in accordance
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`with law via the absence of a required “interactive process,” their attempts to “single-
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`out” Plaintiff and treat him differently than other employees who requested religious
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`accommodations, their denial of Plaintiff’s requested religious accommodation despite
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`the fact that Plaintiff had a sincerely held religious belief against the job requirement at
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`issue which Defendant refused to recognize and the absence of any “undue hardship”
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`within the meaning of the Supreme Court’s Groff decision to justify the denial thereof,
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`their repeated attempts to marginalize and/or gaslight Plaintiff’s professed religious
`
`~ 8 ~
`
`

`

`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 9 of 35 PageID: 210
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`beliefs in which they communicated their utter lack of respect for same, their continuous
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`bombardment of Plaintiff with demands that he partake in the use of a product they knew
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`to be forbidden by his faith under threat of the loss of his career, as well as their
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`messaging that he did not have “sincere” religious beliefs worthy of acknowledgment or
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`respect, and their retaliation against Plaintiff for having requested a religious
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`accommodation, leading up to and including the termination of his employment,
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`constitute violations of the New Jersey Law Against Discrimination (“LAD”), N.J.S.A.
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`10:5-1 et seq. under theories of “failure to accommodate,” “disparate treatment,” “quid
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`pro quo,”4 “hostile work environment,” and “retaliation.”
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`21. As a direct and proximate result of the above-described actions of the Defendants,
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`Plaintiff has been damaged and his civil rights under law have been violated.
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`WHEREFORE Plaintiff demands judgment against Defendant for compensatory and punitive
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`damages in an amount to be determined at time of trial, and as otherwise provided by law,
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`together with an award of counsel fees and economic, non-economic, punitive and/or
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`exemplary damages as may be applicable pursuant to the applicable Federal and State
`
`statutes upon which Plaintiff’s claims are based, pre-judgment interest accruing to the date of
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`entry of judgment, costs of suit, and such other relief the Court deems equitable and just.
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`4 Quid pro quo discrimination may arise in the contest of a disparate treatment of failure to accommodate claim
`when an employee is “required or coerced to abandon, alter or adopt a religious practice as a condition of
`employment.” Here, Defendant attempted to pressure plaintiff into abandoning or otherwise acting
`inconsistently with his sincerely held religious beliefs by partaking in the use of a vaccine product which was
`prohibited by his sincerely held religious beliefs in order to maintain his employment, and terminated said
`employment when he refused to do so. See Questions and Answers: Religious Discrimination in the Workplace,
`EEOC Guidance dated 7-22-2008, available at: https://www.eeoc.gov/laws/guidance/questions-and-answers-
`religious-discrimination-workplace
`
`~ 9 ~
`
`

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`COUNT TWO – VIOLATION OF TITLE VII OF THE CIVIL RIGHTS ACT OF 1964
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`22. Plaintiff repeats and re-alleges all previous allegations of this First Amended Complaint
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`as if fully set forth herein.
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`23. The above-described actions of Defendant, inter alia, constitute unlawful employment
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`discrimination against Plaintiff based upon his sincerely held religious beliefs, and
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`Defendant’s failure to engage in a proper “interactive process” with Plaintiff when it
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`either knew or should have known that it imposed employment-related requirements
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`upon him that violated said beliefs, and despite Plaintiff’s numerous good faith efforts to
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`attempt to provide additional information for Defendant’s consideration concerning his
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`religious beliefs, even with the assistance of counsel, it refused to consider same, and
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`instead terminated his employment in contravention to 42 U.S.C. § 2000e et seq, in
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`violation of Plaintiff’s civil rights, under the legal theories of “failure to accommodate,”
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`“disparate treatment,” “hostile work environment” and “retaliation” based upon
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`Plaintiff’s sincerely held religious beliefs.
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`24. Plaintiff has complied with the requirements of law to obtain a Notice of Right to Sue
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`from the EEOC in order to assert a private cause of action under this Act, and the instant
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`action was commenced within the applicable time period to do so.
`
`~ 10 ~
`
`

`

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`25. As a direct and proximate result of the above-described actions of the Defendant, Plaintiff
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`has been damaged.
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`WHEREFORE Plaintiff demands judgment against Defendant for compensatory and punitive
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`damages in an amount to be determined at time of trial, and as otherwise provided by law,
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`together with an award of counsel fees and economic, non-economic, punitive and/or
`
`exemplary damages as may be applicable pursuant to the applicable Federal and State
`
`statutes upon which Plaintiff’s claims are based, pre-judgment interest accruing to the date of
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`entry of judgment, costs of suit, and such other relief the Court deems equitable and just.
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`COUNT THREE– WRONGFUL TERMINATION AT COMMON LAW (CONTRACT
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`& TORT)
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`26. Plaintiff repeats and re-alleges all allegations of this First Amended Complaint as if fully
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`set forth herein.
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`27. Defendant’s termination of Plaintiff’s employment and associated denial of various
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`financial benefits he was due to receive had he not been wrongfully terminated (including,
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`but not limited to potential severance pay it would have offered other employees laid off after
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`20+ years of service to the company), was wrongful at common law and constitutes a breach
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`of an implied contract of good faith and fair dealing implicit in all contracts, including the
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`implied provision that an employer will not discharge an employee in contravention to a clear
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`mandate of public policy (including, but not limited to: violating his sincerely held religious
`
`~ 11 ~
`
`

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`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 12 of 35 PageID: 213
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`beliefs which are protected by law, especially when all applicable State and Federal mandates
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`protected religious exemptions).
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`28. As a direct and proximate result of the above-described actions of the Defendants,
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`Plaintiff has been damaged.
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`WHEREFORE Plaintiff demands judgment against Defendant for compensatory and punitive
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`damages in an amount to be determined at time of trial, and as otherwise provided by law,
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`together with an award of counsel fees and economic, non-economic, punitive and/or
`
`exemplary damages as may be applicable pursuant to the applicable Federal and State
`
`statutes upon which Plaintiff’s claims are based, pre-judgment interest accruing to the date of
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`entry of judgment, costs of suit, and such other relief the Court deems equitable and just.
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`COUNT FOUR – UNJUST ENRICHMENT
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`29. Plaintiff repeats and re-alleges all allegations of this First Amended Complaint as if fully
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`set forth herein.
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`30. Defendant’s conduct in terminating Plaintiff rather than compensating him appropriately
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`for the work he performed during his 20+ years of service to the Company in a manner
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`commensurate with that of other employees performing the same or similar work
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`(including, but not limited to Defendant's denial of severance pay to Plaintiff) as Plaintiff
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`as described above has caused Defendants to become unjustly enriched, and said profits
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`must be disgorged as a matter of law and equity.
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`31. As a direct and proximate result of same, Plaintiff have been damaged.
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`~ 12 ~
`
`

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`WHEREFORE Plaintiff demands judgment against Defendant for compensatory and punitive
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`damages in an amount to be determined at time of trial, and as otherwise provided by law,
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`together with an award of counsel fees and economic, non-economic, punitive and/or
`
`exemplary damages as may be applicable pursuant to the applicable Federal and State
`
`statutes upon which Plaintiff’s claims are based, pre-judgment interest accruing to the date of
`
`entry of judgment, costs of suit, and such other relief the Court deems equitable and just.
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`COUNT FIVE – TORTIOUS INTERFERENCE WITH PROSPECTIVE ECONOMIC
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`ADVANTAGE
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`32. Plaintiff repeats and re-allege all allegations of this First Amended Complaint as if
`fully set forth herein.
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`33. Defendant’s conduct described in this Complaint interfered with Plaintiff’s prospective
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`economic advantage intentionally and with malice by wrongfully depriving his income,
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`compensation and/or benefits that he reasonably expected to earn, with the timing of his
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`termination being immediately before he was due to receive same, the interference
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`caused the loss of the expected advantage, and the injury caused economic damage to
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`Plaintiff.
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`34. As a direct and proximate result of same, Plaintiff has been damaged.
`
`~ 13 ~
`
`

`

`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 14 of 35 PageID: 215
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`WHEREFORE Plaintiff demands judgment against Defendant for compensatory and punitive
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`damages in an amount to be determined at time of trial, and as otherwise provided by law,
`
`together with an award of counsel fees and economic, non-economic, punitive and/or
`
`exemplary damages as may be applicable pursuant to the applicable Federal and State
`
`statutes upon which Plaintiff’s claims are based, pre-judgment interest accruing to the date of
`
`entry of judgment, costs of suit, and such other relief the Court deems equitable and just.
`
`Date: April 4, 2024
`
`Respectfully submitted,
`
`/s/ Daryl Kipnis (SBN 023812006)
`daryl@kipnislawoffices.com
`KIPNIS LAW OFFICES
`125 Half Mile Road, Suite 200
`Red Bank, NJ 07701
`Telephone: (732) 595-5298
`Fax: (732) 412-7925
`Attorney for Plaintiff
`
`DEMAND FOR TRIAL BY JURY
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`Plaintiff hereby demands trial by jury on all issues so triable pursuant to FRCP 38
`
`Date: April 4, 2024
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`Respectfully submitted,
`
`/s/ Daryl Kipnis (SBN 023812006)
`daryl@kipnislawoffices.com
`KIPNIS LAW OFFICES
`125 Half Mile Road, Suite 200
`Red Bank, NJ 07701
`Telephone: (732) 595-5298
`Fax: (732) 412-7925
`Attorney for Plaintiff
`
`~ 14 ~
`
`

`

`Case 2:23-c
`
`Saqa, George
`
`
`
`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 15 of 35 PageID: 216
`
`
`
`From:
`Sent:
`To:
`Subject:
`
`Attachments:
`
`Hello Julie--Happy Friday,
`
`Saga, George
`Friday, November 12, 2021 2:34 PM
`Libutti, Julie
`Request ForReligious Exemption/Accommodation Related to FM Global's COVID-19
`Vaccination Policy
`FM Global Employee Request for Medical Exemption-Accommodation.pdf
`
`Please see my attached request for a religious exemption/accommodation regarding FM's COVID-19 vaccination
`policy. Thanks and have a great weekend.
`
`Regards,
`
`George Saga
`
`FREE Resources
`
`a[=
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`iqa@
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`it may contain information
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`e
`This
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`nature or subject to legalprivilege.
`It mayalso include information developedto reducethe possibility of
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`FM Global undertakes no duty to any party by providing such information. Disclosure
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`EXHIBIT "A"
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`EXHIBIT "A"
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`

`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 16 of 35 PageID: 217
`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 16 of 35 PagelD: 217
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`FM! al
`
`REQUEST FOR MEDICAL OR RELIGIOUS EXEMPTION/ACCOMMODATIONRELATED TO FM GLOBAL’s COVID-19
`VACCINATION POLICY
`
`GENERAL INFORMATION AND INSTRUCTIONS FOR COMPLETING THIS FORM
`
`To complete a request for a medical exemption/accommodation from Factory Mutual Insurance Company
`{FM Global or Company) under
`the Americans with Disabilities Act
`(ADA) or
`a
`religious
`exemption/accommodation under Title VI! of the Civil Rights Act of 1964 (Title Vil) related to FM Global’s
`COVID-19 Vaccination Policy, please complete this form and return it to your HR Business Partner within
`five (5) calendar days of receipt from the Company.This information will be used by Human Resources
`to engagein an interactive process to determine eligibility for, and identify possible, accommodations.
`
`If an employee declines to complete the enclosed form and any associated documentation, it may impact
`the Company’s ability to adequately understand the employee’s request or effectively engage in the
`interactive process to determineeligibility for reasonable accommodation under the ADAor Title Vil and
`identify possible accommodations.
`
`Page 1 of 4
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`

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`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 17 of 35 PageID: 218
`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 17 of 35 PagelD: 218
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`Fue|
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`REQUEST FOR MEDICAL OR RELIGIOUS EXEMPTION/ACCOMMODATIONRELATED TO FM GLoBat’s COVID-19
`VACCINATION POLICY
`
`Part 1-—To Be Completed by Employee
`
`Name: ___GeorgeSaga__
`
`
`
`Position/Title:___Jurisdictional Specialist Date of Request: 142i24
`
`
`
`Type of accommodation requested [check all that apply):
`
`Qualifying Medical Condition?
`
`X__
`
`Sincerely Held Religious Belief
`
`Length of time the accommodation is needed:
`
`For the entire duration that FM Globai deems necessary.
`
`In lieu of receiving a
`Describe the job-related and/or workplace accommodations you are requesting:
`COVID-19 vaccination, | request the reasonable accommodation of allowing me to perform weekly COVID-19
`
`hands often, and continue to follow social distancing guidelines to retain my current position as a Jurisdictional
`Specialist.
`
`For qualifying medical conditions only, please attach the Health Care Provider Form for Medical Exemption
`completed by your treating physician.”
`
`For sincerely held religious belief only, please briefly describe the religious principle, practice, tenet, or belief
`supporting your request and why this principle, practice, tenet, or belief confiicts with or predudes you from
`receiving a COVID-19 vaccination.
`
`(am notifying you that | am experiencing a conflict between my sincerely held religious beliefs and receiving the COVIO-19 vaccine.
`God created me with a naturally robust immune system, and | will not alter His design. Itis a sin against my God-given conscience to
`allow unwanted intrusions into my body that would interfere with His perfect creation.
`
`| am notaffiliated with any
`There is no specific tenet that | can quote to you since my personalreligious beliefs are my own.
`particular mainstream religion.
`| arm a spiritual being created by God the way He intended. Being coerced to inject the COVID-19
`vaccine into my body would alter my biological anatomy at a cellular level, thereby negating God's creation. This activity would be in
`extreme conflict with my sincerely held religious beliefs.
`
`religion, or religious scholars.
`
`Please note that these are my sincerely held religious beliefs. The law does not recognize the need for employers to consult ”
`religious scholars” or examine "church doctrine” regarding the vaccine. A religious exemption request is made by each individual,
`based on each individual's sincerely heid religious, ethical and/or moral beliefs, not the tenets or beliefs of a church, doctrine,
`
`1A qualifying medical condition is one that is based on standard criteria for medical exemptions recommendedby the Centers for Disease
`Control (CDC) and Prevention or Advisory Committees on Immunization Practices (ACIP) or physical conditions or medical circumstances
`such that the COVID-19 vaccine is not considered safe.
`2 The Company may request additional information and/or documentation from you about your qualifying medical condition to assist the
`Company in (i} determining your eligibility for a reasonable accommodation,and {ii) identifying the most appropriate accommodation.
`
`Page 2 of 4
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`

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`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 18 of 35 PageID: 219
`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 18 of 35 PagelD: 219
`Ey eee
`
`
`REQUEST FOR MEDICAL OR RELIGIOUS EXEMPTION/ACCOMMODATION RELATED TO FM GLOBAL’s COVID-19
`VACCINATION POLICY
`
`Employee Attestation
`
`| certify that this form and the information | am submitting in support of my request for an accommodation is
`truthful, complete, and accurate to the best of my knowledge. | understand that any intentional misrepresentation
`contained in this request may result in the denial of my request and in disciplinary action up to and including
`termination of employment. | also understand that my request for an accommodation may not be grantedif it is
`not reasonable,if it poses a direct threat to the health and/or safety of others in the workplace and/or to me,or if
`it creates an undue hardship on the Company. If this is a request based onasincerely held religious belief, | further
`certify that
`the foregoing description supporting my request for a religious exemption from the COVID-19
`vaccination is true, correct, and based upon sincerely held religious beliefs, observances, or practices.
`
`Employeesignature: Ske uge £gn
`Print Name: George Sa7A
`
`Date:
`
`Il;[I
`
`/lafat
`
`Page 3 of 4
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`

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`Case 2:23-cv-03994-SDW-JBC Document 18 Filed 04/04/24 Page 19 of 35 PageID: 220
`
`Saqa, George
`Thursday, November 25, 2021 1:03 PN
`Libutti, Julie
`
`
`
`RE: Request For Religious Exemption/Accommodation Related to FM Global's
`COVID-19 Vaccination Policy
`Attachments: Religious Exemption Request Additional Information Letter -