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to the employer unilaterally establishes without the benefit of collective disabled See Barnett, 196 RM at 990-91 (concluding ADA reassignment provision does not 1998). employer to make exception require employer's established seniority policy to favor negotiations. employee); see also Foreman v. Babcock Wilcox Co., 117 F.3d 800, 810 (Sth Cir. 1997) (agreeing in dicta). Webmdcom Protonix 219. 141 F.3d 667 (7th Cir. that
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