From the Joint Pre-Trial Memorandum in McQuade v. UMass Memorial Health Care, Inc. , the plaintiff's position:

In the summer of 2020, a position at UMass Memorial's Heart Vascular Interventional Lab commonly known as the Cath lab opened. Mr. McQuade and Andrews both applied for the Cath lab position. Ms. Andrews was awarded the Cath lab position. Once Mr. McQuade learned that Ms. Andrews was awarded the Cath lab position, he reached out to his union representatives for advice. Mr. McQuade's Massachusetts Nurses Association ("MNA") union representatives … both advised that Mr. McQuade should file a grievance because he had seniority over Andrews, and had the requisite experience to work in the Cath lab.

Ultimately, on September 11, 2020, Mr. McQuade was successful in his grievance and was

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