Employment Case Evidence Matrix

Scope and warning#

This page principally organizes cross-referenced claim material, but its evidence-access and discovery-clock sections now cite distinct procedure provisions directly. No legal proposition is cleared merely because another Roadmap refers to it. Working manuscripts exist for Roadmaps 027, 027.1, 028 and 029; their existence does not establish independent verification. Cross-document consistency and final legal review remain outstanding.

Worksheet-number provenance warning (non-public candidate). This earlier corpus uses serials 100–124 for employment-specific worksheets. The October 11 unified index reassigns at least some of those numbers to different subjects: it labels 104 an ADA/FEHA accommodation chronology rather than the older personnel-file/source worksheet, 107 a damages ledger rather than the older protected-activity witness topic, and 113 a Government Claims Act worksheet rather than the old agency exhibit index. These topic examples establish a concrete collision; a full mapping cannot be certified without the two manuscript bodies. Do not generate links from bare worksheet numbers below until each intended title + slug + body is reconciled. Keep valid law citations and stable decimal Roadmap supplements separate from bare-serial collisions.

How to read the matrix#

Each claim has four rows: elements (what must be shown, from the element tables); defenses (what will be argued, from the playbook); evidence (the categories that bear on both, with the records key); worksheets (where the facts are collected). The evidence row is the heart of the page. It is written so that a worker can go through it with a highlighter and mark what is in hand, what has been requested, and what only counsel can get.

The matrix#

Wrongful termination in violation of public policy — Roadmaps 010, 011

Elements. Employment; termination or constructive discharge; a public policy that is constitutional or statutory, public, fundamental and well established; the violation as a substantial motivating reason; harm (legacy claim-element table; supplement link held).

Defenses. No employment relationship; no termination (resignation); no qualifying policy; legitimate reason; same decision; limitations (two years, Code Civ. Proc. § 335.1); arbitration; bankruptcy (133).

Evidence. Offer letter, hiring notice, wage statements (H/R); the separation letter and its stated reason (H); the chronology of the protected conduct and the termination (H); the decisionmakers and their knowledge (D — communications; depositions); the position's history after termination (D); reasons stated in any lawfully received position statement (A, conditional) and in the employer's own records (D); any EDD document requires a separate statutory-access and admissibility determination; the personnel file (R, then D for the audit trail); comparators (D, under Williams); the statute or constitutional provision that supplies the policy (public).

Legacy working tools (serial destinations held). Case chronology; entity identification; decisionmaker/knowledge record; adverse-action/decision-reason evidence; protected-activity witness log.

FEHA disability discrimination — Roadmap 013; ADA — Roadmap 012

Elements. Covered employer (five / fifteen employees); employee; disability (FEHA "limits"; ADA "substantially limits"; regarded as); qualified; adverse action; substantial motivating reason (FEHA) or but-for (ADA); harm; exhaustion (CRD / EEOC) (legacy claim-element table; supplement link held).

Defenses. Wrong employer; employee count; contractor; no disability; not qualified; legitimate reason; same decision; limitations and exhaustion defects; the federal caps (133; Roadmap 037).

Evidence. Employee count (D — interrogatory; the employer's own filings); the entity records (H/R; D for agreements); the worker's medical documentation of limitation (H — the worker's own; disclosed with counsel); the employer's knowledge (H — the request and its transmission; D — the recipient's communications); the essential functions (H — job description; D — the employer's); performance records (R, then D with audit trail); the adverse action and reason (H; A; D); the charge or complaint and the right-to-sue notice (H).

Legacy working tools (serial destinations held). Case chronology; entity identification; decisionmaker/knowledge record; accommodation evidence; decision/reason evidence; agency correspondence and exhibit index.

Failure to accommodate; failure to engage in the interactive process — Roadmaps 014, 015

Elements. As above, plus: employer knowledge of the disability; a reasonable accommodation that was available; failure to provide it; for the interactive process, request or known need, the worker's willingness, and the employer's failure to engage in good faith (legacy claim-element table; supplement link held).

Defenses and remedies. No notice of a disability-related need; no effective accommodation available; undue hardship (the covered entity must prove the applicable statutory defense); disputed responsibility for a documented breakdown in the interactive process. Do not describe 42 U.S.C. § 1981a(a)(3) as a blanket defense to an ADA liability finding. Where its elements are demonstrated, the federal provision restricts the compensatory/punitive damages awarded under § 1981a for a covered accommodation practice; it does not by its own terms extinguish separately authorized equitable relief or every other cause of action (defense playbook 133; Roadmap 037).

Evidence. Preserve the request and its exact language, date, delivery medium and intended and actual recipient (H); acknowledgments, routing and employer understanding (H; D); each interactive-process communication, in both directions, including response gaps (H; D); functional restrictions rather than surplus diagnostic material (H, privately segregated); each effective alternative discussed, the available position/job task and its date (H; D); the particular offered or refused option (H; D); contemporaneous hardship analysis, if any (D); the controlling policy version (H; D); and properly narrowed comparator accommodations (D, under Williams). For a federal § 1981a(a)(3) good-faith assertion, separately obtain dated records of actual consultation, alternative exploration and implementation attempts; a generic policy statement is not itself proof of those efforts.

Legacy working tools (serial destinations held). Case chronology; accommodation/interactive-process evidence; decision/reason evidence.

Request-specific FEHA retaliation must not be merged into the accommodation merits claim. California Government Code § 12940(m)(2) independently forbids retaliation or discrimination for requesting accommodation under subdivision (m), regardless of whether it was granted, and says this protection is in addition to subdivision (h). Section 12940(n) separately imposes the timely, good-faith interactive-process requirement in the circumstances it defines. For each potentially applicable theory, preserve the actual words of the request, recipient, receipt evidence, employer response, alleged adverse act, responsible actor and chronology. An employer may dispute that the communication requested disability-related accommodation, that the respondent was a covered actor, that the actor knew of the request, or that the action was retaliatory; the mere existence of an accommodation request does not resolve those issues. The statute was checked against a public 2025 Code reproduction on October 12, 2026; the official 2026 chapter text and later treatment remain a release gate. Source: https://california.public.law/codes/government_code_section_12940 (external site) (subds. (h), (m)(1)–(2), (n)).

ADA good-faith remedy check is fact-specific and narrower than FEHA. Under 42 U.S.C. § 1981a(a)(3), the covered entity must show a good-faith consultative effort to identify and provide an equally effective reasonable accommodation without undue hardship. Its explicit limitation applies to damages awarded under § 1981a, not all remedies, and it should not be silently imported into the California FEHA analysis. Read § 1981a(a)(2), (a)(3), (b)(2) and the separate relief provisions together; verify the cause of action and forum before quantifying any damages. The 2024 U.S. Code text was reviewed directly from the Government Publishing Office; later federal enactments have not been separately citator-cleared. Source: https://www.govinfo.gov/content/pkg/USCODE-2024-title42/html/USCODE-2024-title42-chap21-subchapI-sec1981a.htm (external site).

Return to work; fitness for duty; direct threat — Roadmaps 016, 017, 018

Elements and defenses. The clearance and the employer's response; the lawfulness of the medical inquiry or examination (job-related and consistent with business necessity); the direct-threat defense's individualized-assessment requirement, which the employer must prove (legacy claim-element table link held; defense playbook 133).

Evidence. The clearance and its restrictions (H); the date provided and the response (H); the fitness-for-duty referral, the examiner's engagement letter and the questions put to the examiner (D; the medical content subject to protective order); the employer's safety rationale as first written (D); the position's status — held, filled, eliminated (D); the policy on return to work and its application to others (D); the EEOC's guidance on inquiries and examinations (public; Roadmap 017).

Legacy working tools (serial destinations held). Case chronology; accommodation/interactive-process evidence; decision/reason evidence.

Retaliation — FEHA, ADA, § 1102.5, § 1278.5, § 2056, § 6310, after reporting to a regulator — Roadmaps 019–023

Elements. Protected activity, covered actor/facility/employer, knowledge, qualifying adverse action, causation and harm must be analyzed separately for each statute rather than combined into a single generalized retaliation test. Labor Code § 1102.5 uses § 1102.6's contributing-factor/clear-and-convincing sequence; Health & Safety Code § 1278.5 has its own health-facility scope and conditional 120-day evidentiary presumption for healthcare workers; Business & Professions Code § 2056 specifically concerns a physician's advocacy for medically appropriate care. FEHA and ADA use their own distinct protected-activity and causation rules (see claim-specific Roadmaps and the unresolved 096.3 supplement reference).

Defenses. No protected activity; no legally sufficient notice/knowledge; no actionable adverse act or causation; legitimate independent reason (with the claim-specific, not automatic, burden of proof); no covered health facility or responsible actor under § 1278.5; physician-advocacy requirements not satisfied under § 2056; limitations or other statutory exceptions. Section 1102.6's clear-and-convincing same-decision burden applies only when that statute governs, not to all claims listed here (133).

Evidence. The report, complaint or request, with date, recipient and transmission record (H); the acknowledgment or file number of any external report (H); the recipient's forwarding and the decisionmakers' knowledge (D); the timing (legacy adverse-action chronology worksheet, former 100; canonical numeric link held); the adverse action and its stated reason (H; A if lawfully provided; D); differences between stated reasons across dated sources (H; A if available; R; D), without presuming every agency document is obtainable or admissible; the facility's licensing status (public); the employer's own policy requiring reports of the kind made (H; D); comparators who did not report (D).

Legacy working tools (serial destinations held). Case chronology; decisionmaker/knowledge record; adverse-action/decision-reason evidence; protected-activity witness log; clinical-practice evidence.

Already-known information can still be protected whistleblowing. In People ex rel. Garcia-Brower v. Kolla's, Inc. (2023) 14 Cal.5th 719, the California Supreme Court held that an employee's report of a legal violation to an employer or agency can constitute a disclosure under Labor Code § 1102.5(b) even if the recipient already knew of the violation. Thus an opposing claim that the supervisor was already aware is not, standing alone, a valid novelty-of-disclosure bar. The claim still requires the particular protected report, its legal-violation content and reasonable-belief predicate under the statute, the actor's relevant knowledge, an adverse action and causation under the applicable elements and § 1102.6 burden framework. Preserve the original text/audio/transmission evidence, the speaker's role, audience, and whether the report described suspected noncompliance with a statute or regulation; label generalized disagreement about staffing or clinical preference as unresolved, not automatically qualifying. The controlling historical holding was reviewed in the published-opinion reproduction; no independent current-case citator or full statutory-history review was completed. Source: https://law.justia.com/cases/california/supreme-court/2023/s269456.html (external site).

Three distinct knowledge questions: (i) Who received the report or accommodation request, and when? (ii) Who knew enough about it to affect the challenged decision, and when? (iii) What documents objectively show the original decision reason was formulated, recommended and approved? Prior institutional awareness of the underlying problem is not interchangeable with awareness that the particular worker made a protected report. A respondent can concede that a complaint occurred yet dispute the decisionmaker's knowledge, timing, qualifying content or causal contribution. Keep favorable and adverse correspondence, automatic-routing records, timestamped decision drafts and recipient declarations in separate matrix cells rather than collapsing them into a single inference.

Healthcare whistleblowing requires a facility-and-claimant coverage gate. Section 1278.5(b) protects specified complaints, reports and participation relating to care, services or conditions at a qualifying health facility. Subdivision (i) incorporates the health-facility chapter; § 1250(j) includes defined correctional treatment centers, but a correctional housing facility's outpatient clinic is not automatically a licensed § 1250(j) correctional treatment center. Subdivision (j) excludes enumerated incarcerated patients from § 1278.5 coverage; that exclusion must not be misdescribed as eliminating all protections for clinicians working in detention. For a worker's rebuttable presumption under § 1278.5(d), confirm that responsible facility or operating-entity personnel knew of the protected acts and that the discriminatory action occurred within 120 days of the worker's filed grievance or complaint; § 1278.5(e) expressly calls this a presumption affecting the burden of producing evidence, not a conclusive finding or a replacement for merits analysis. Ryan v. County of Los Angeles (2025), B320677, held that public entities operating covered health facilities can come within the statute; it reversed a demurrer on that issue, not a final determination that the doctor prevailed. Slone v. El Centro Regional Medical Center (2024) 106 Cal.App.5th 1160 illustrates the need to test the employer's nonretaliatory narrative, material effect and evidence of actual causation. Neither case decides whether any particular county jail health-services arrangement qualifies. Verify venue, actual facility license/status, reporting content, notice, actor, remedy and subsequent case history before asserting this claim.

Physician-advocacy provision is distinct. Business & Professions Code § 2056 protects defined medically appropriate patient-care advocacy and addresses adverse action principally for that advocacy while preserving lawful peer review and utilization review. It does not convert any policy disagreement or professional frustration into protected advocacy. Preserve the actual patient-safety subject without patient identifiers, the communication's purpose and recipient, the decision's stated basis, peer-review setting and contemporaneous alternatives before taking a position under § 2056. Sources: H&S §§ 1250, 1278.5; B&P § 2056; Ryan and Slone (reviewed at the holding/statutory-text level only; no 2026 citator certification).

Leave — FMLA, CFRA, pregnancy disability and related leave — Roadmaps 024, 025

Elements. Coverage and eligibility; qualifying reason; notice; interference (denial; failure to reinstate) or retaliation; remedies including liquidated damages absent good faith (legacy claim-element table; supplement link held).

Defenses. Ineligible; not a serious health condition; no notice; leave exhausted; the employee would have been terminated regardless; good faith (133).

Evidence. The eligibility facts (R — payroll records for hours; H — hire date); the leave request and the employer's designation notice (H); the certification and any recertification request (H); the return date and the reinstatement response (H); the position's status (D); the employer's leave policy and its application to others (H; D); the CRD's and the Department of Labor's guidance (public).

Legacy working tools (serial destinations held). Case chronology; personnel/source-record request log; accommodation/interactive-process evidence.

Wages, final pay, wage statements, PAGA — Roadmaps 026, 026.1

Elements. Employment; wages earned and unpaid by period and amount; willful failure to pay final wages; knowing and intentional wage-statement violations with injury; for PAGA, aggrieved-employee status and the LWDA notice (legacy claim-element table; supplement link held).

Defenses. Not wages; paid; good-faith dispute (8 C.C.R. § 13520); contested employee-versus-independent-contractor status with the applicable occupation, statutory-exemption and relationship-specific classification test (the Borello test applies to certain qualifying licensed physicians under California's AB 5 provisions; neither a license nor a 1099 alone resolves employment status); limitations and applicable PAGA transition/cure rules; arbitration; debtor-specific bankruptcy treatment of prepetition claims (133).

Evidence. Wage statements (H); payroll records (R under § 226; D); timecards/underlying time records (R for employee inspection only if the applicable IWC wage order or another governing rule authorizes it; D where lawful and needed; do not read § 226 alone as an unconditional right to obtain copies of every raw timecard); a compensation, bonus or commission plan (H; R under § 432 only for instruments the employee actually signed; D for other relevant versions); the hiring notice (H); the separation date and final-pay date (H); bank records of deposits (H); the entity on each document (legacy employer-identity worksheet, former 101; canonical numeric link held); the classification documents (W-2 / 1099; H); the employer's response to the Labor Commissioner (A).

Legacy working tools (serial destinations held). Case chronology; entity identification; personnel/source-record request log; mitigation/job-search ledger.

Benefits, retirement plans and ERISA; COBRA — Roadmaps 027, 027.1 (in queue)

Elements, at the level the register supports. An ERISA-governed plan (a threshold question never assumed); participant or beneficiary status; benefits due under the plan's terms; exhaustion of the plan's internal procedures; for COBRA, a qualifying event and the notice obligations (29 U.S.C. § 1132(a)(1)(B), (a)(3), (e)(1), AR-0961-F04; remaining claims, exceptions and legal pinpoints to be verified against the existing working Roadmaps before publication).

Defenses. Not an ERISA plan; not a participant; no benefit due; failure to exhaust; the plan's limitation period; preemption of state claims (not analyzed here).

Evidence. The plan document and summary plan description (R — by written request to the administrator under ERISA's disclosure provisions, not analyzed here; D); enrollment and benefit statements (H); the claim, the denial and the appeal (H); the COBRA election notice and its date (H); the plan's administrative record (D); the employer's and administrator's communications (D).

Legacy working tools (serial destinations held). Case chronology; personnel/source-record request log; mitigation/job-search ledger.

Contracts, offer letters, policies and oral promises — Roadmap 028 (in queue)

Elements, at the level the register supports. A contract, express or implied, limiting at-will termination or promising compensation (Labor Code § 2922's presumption, AR-010-S01; Foley, AR-010-C02; Guz, AR-010-C08); performance; breach; damages.

Defenses. At-will clause; integration clause; no implied contract (Guz); statute of frauds; limitations (two years oral; four years written); arbitration.

Evidence. The offer letter, agreement and acknowledgments (R under § 432; H); the handbook and its at-will and integration language (H; D); the course of dealing — evaluations, raises, assurances (H; D); the communications containing any oral promise and the witnesses to it (H; legacy communications/witness proof worksheet, former 103; canonical numeric link held); the employer's practice with others (D).

Legacy working tools (serial destinations held). Case chronology; communications/contract-promise witness proof; personnel/source-record request log.

Arbitration — Roadmap 029 (in queue)

Questions, at the level the register supports. Whether an agreement exists and was assented to; its scope; its enforceability under the unconscionability doctrine; the treatment of PAGA representative claims after Iskanian, Viking River and Adolph (AR-0261-C01–C03); the FAA's application (9 U.S.C. § 2, AR-S936, R1 pending).

Evidence. The signed agreement (R under § 432 — the single most important request; H); the circumstances of signing (H; legacy communications/witness proof worksheet, former 103; canonical numeric link held); the employer's arbitration policy and its versions (D); the agreement's terms on costs, discovery, forum and remedies (H).

Legacy working tools (serial destinations held). Case chronology; personnel/source-record request log.

Professional independence; corporate practice; credentialing and peer review — Roadmaps 030, 031, 032

Questions. Whether a non-physician controlled medical judgment (Bus. & Prof. Code §§ 2400, 2401, 2408; the Title 15 standards); whether the physician's advocacy was protected (§ 2056); whether an adverse action was a peer-review action under §§ 809 et seq. with its own procedures, or an employment action; the § 1157 limit on discovery of committee records (legacy claim-element table link held; Roadmaps 030–032).

Evidence. The protocols, utilization-review communications and directives, as the clinician lawfully possesses them (H; D) — described generically and never with patient identifiers (legacy clinical-practice records tool; numeric link held); the management services agreement and the professional corporation's governing documents, to the extent public or produced (public; D); the medical-staff bylaws and the credentialing file (H in part; D; P for committee proceedings); the employment agreement (H; R under § 432 if signed by the worker; otherwise consider proper discovery); the physician's advocacy communications (H).

Physician worker-status proof—not an employment-label shortcut. For a California-licensed physician providing professional or medical services to or by a health care entity, Labor Code § 2783(b), not the general professional-services category of § 2778, points to the Borello test instead of the default ABC test; the result remains fact-intensive. Record independently the right of control over schedules, patients, assignments and termination, provision of tools/facilities, distinct business and client activity, duration, payment design and the actual contracting entity. In a different evidentiary column, examine clinical-judgment control under B&P Code § 2400 and official Medical Board guidance; neither a possible CPOM violation nor the physician exception conclusively answers the FEHA/ADA employer-identity question. Compare source-level evidence supporting lawful professional autonomy as well as interference. Sources: https://codes.findlaw.com/ca/labor-code/lab-sect-2783/ (external site); https://www.ftb.ca.gov/file/business/industries/worker-classification-and-ab-5-faq.html (external site); https://www.mbc.ca.gov/Licensing/Physicians-and-Surgeons/Practice-Information/ (external site).

Legacy working tools (serial destinations held). Case chronology; protected-activity witness log; clinical-practice evidence.

Personnel files and records — Roadmap 033

Separate statutory rights and proof. Labor Code § 1198.5 covers covered personnel-performance/grievance records and, effective January 1, 2026, expressly includes employer-maintained education/training records and prescribed fields (§ 1198.5(a)(1)–(2)), without independently proving a record was ever maintained or requiring retroactive creation of a missing historical record; a written request, actual employer receipt, 30-calendar-day response framework with limited written extension, statutory exclusions and § 1198.5(n)–(o)'s specific pending personnel-matter lawsuit condition must be proved if that provision is invoked. Section 226 payroll-itemized-statement rights have their own request and timing rules. Section 432 concerns an instrument signed by the employee/applicant relating to obtaining or holding employment; it does not by itself demand every unsigned policy, peer-review file or all internal communications. A $750 access-penalty provision appears independently in § 1198.5(k) (covered personnel-record access) and § 226(f) (covered payroll-record access after the § 226(c) response period); these are different statutory predicates, not a pooled or presumed penalty. Section 432 provides a signed-instrument copy right but does not itself establish the same $750 penalty. The disputed scope, response and penalty must be analyzed individually, not inferred from one missing file (096.3 remains a supplement subject to separate cross-reference verification).

Evidence. Retain the exact request text and requested statutory category, signed employment instrument if relevant, proof of employer receipt, response and its date (H); compare lawful productions with existing records by record category and version (legacy personnel/source-record request tool; numeric link held). For education/training disputes, identify the maintained program record, provider, dates/duration, competencies and qualification or certification, without seeking unauthorized committee proceedings or another person's medical file. Preserve the employer's designation of a recipient, if any (H), and separately note whether litigation affecting § 1198.5(n) was already pending at receipt.

Worksheets. personnel/source-record request tool (older serial held), six-way records key (older serial held).

Workers' compensation exclusivity — Roadmap 037.1

Questions. Whether the injury is compensable and the civil claim is barred (Lab. Code §§ 3600, 3602); whether the claim is for discrimination or termination rather than for the injury (Moorpark); whether a § 132a claim lies before the WCAB (legacy claim-element table link held; defense playbook 133).

Evidence. The injury report and claim form (H); the worker's own workers'-compensation file (H for lawfully held documents; additional records subject to applicable agency access/privacy rules); the employer's response to the claim (A only if lawfully provided); the termination's relationship to the injury and the claim (legacy adverse-action chronology worksheet, former 100; canonical numeric link held); the return-to-work and modified-duty records (H; D).

Legacy working tools (serial destinations held). Case chronology; accommodation evidence; mitigation/job-search ledger.

Agency process and position statements — Roadmaps 034, 035, 036

Evidence. The charge or complaint, the acknowledgment and file number (H); the respondent position statement and nonconfidential attachments when the EEOC supplies them (A → H upon lawful receipt); the claimant's rebuttal and exhibits (H); agency requests or responses actually received (H); a determination or right-to-sue notice actually issued, with its receipt record (H); only those closed-file materials released after an authorized EEOC Section 83/FOIA or CRD records request (A → H if provided; redactions and use limits logged).

Charge-amendment matrix (private source control). For each EEOC/CRD version, record agency, exact named respondents, governing alleged act, first receipt/filing date, verification date, amendment date, service/notice date, related original material facts, and employer defense. Federal 29 C.F.R. § 1601.12(b) permits certain technical, clarifying and related-act amendments to relate back to original receipt, but not a blanket cure for omitted parties or unrelated discriminatory acts. The CRD amendment regulation, 2 CCR § 10022, contains older one-year-limit wording: cross-check the current three-year FEHA complaint-filing rule in Gov. Code § 12960(e)(5), the current department procedure and governing decisions before using that older wording in a limitations calculation. Evidence to preserve includes each actual charge PDF, amendments and agency correspondence—not assumptions about what an electronic portal silently changed. Sources: https://ecfr.io/Title-29/Section-1601.12 (external site); https://www.law.cornell.edu/regulations/california/2-CCR-10022 (external site); https://codes.findlaw.com/ca/government-code/gov-sect-12960/ (external site).

Worksheets. agency correspondence and exhibit index (older serial held).

Damages and mitigation — Roadmap 037

Evidence. Pre-termination compensation and benefits (H; R); post-termination earnings (H); the job-search record (H); the employer's mitigation evidence (D); the employee count for the federal caps (D); the decisionmaker's and approver's roles for the managing-agent question (D); treatment records the worker chooses to disclose (H).

Legacy working tools (serial destinations held). Decisionmaker/knowledge record; mitigation/job-search ledger.

Entity identity and bankruptcy — Roadmaps 004, 090, 091; legacy employer-identity/tax-record subjects (links withheld)

Evidence. Lawfully possessed employment documents identifying each entity and its role (H; statutory request only where applicable); public bankruptcy petition schedules and applicable court orders for the named debtor (public); official entity filings and historical names (public); intercompany agreements only through a lawful access/discovery route (D); properly noticed entity-designee testimony in a filed California action (D, Code Civ. Proc. § 2025.230); the worker's own tax/payroll records (H); and EDD wage information only to the extent disclosure is authorized (R for qualifying employee wage information; other submissions potentially restricted). In the October 9 master index, historical serials 094 and 095 identify employer-identity records and tax-record evidence; the October 11 unified index assigns 094 to California Board of Registered Nursing complaints and 095 to regulatory complaint versus civil lawsuit. These are distinct subject identities, not interchangeable page revisions. Retain both names in the private two-index provenance crosswalk; do not expose either as a resolved numeric link.

Legacy working tool (serial destination held). Entity identification and employer-control ledger.

A worked example: one document through the matrix#

Take a single wage statement from the month before a termination. In the entity row it is evidence of the name and address reported as employer under Labor Code § 226(a)(8), which must be tested against payroll, contracting, agency and control records rather than treated as conclusive proof of the legally responsible employer, and it is compared with the hiring notice, the offer letter and the public debtor list (legacy entity-identification tool; serial link held). In the wage row it records the employer-reported rate, hours, differential and deductions for that period; the statement alone neither verifies that the figures are correct nor establishes every element of a § 226 claim (Roadmap 026). In the damages row it supplies one contemporaneous pay input, which should be reconciled with actual deposits, applicable pay terms, benefits records and tax documents before any back-pay model is calculated (Roadmap 037; legacy mitigation/job-search ledger; old worksheet 112 number held). In the FEHA and ADA rows it can identify a candidate employer for further inquiry, but it does not establish applicable employee-count thresholds, the relevant entity aggregation rules, joint-employer status or statutory coverage. In the discovery row it is the exhibit put to the entity's designee under Code Civ. Proc. § 2025.230 with the question who issued it and why (Roadmap 038). In the position-statement row it is the document that answers an assertion that "a related entity" was the employer (Roadmap 036). It is numbered once in the legacy agency exhibit index (older worksheet 113—not the newer Government Claims Act worksheet) and cited by that exhibit identifier in every row. The same lawfully acquired document can support multiple elements and defenses without changing its source identifier, while retaining separate evidentiary-purpose and disclosure-permission decisions.

Now take the opposite kind of document: a purported screenshot of a scheduling system showing a position posted after a hypothetical termination, reportedly taken by someone who still has system access and forwarded without an established disclosure authorization. Even if its lawful provenance were established, the screenshot might indicate an advertisement or scheduling change, not by itself prove that the same position was filled or that a stated restructuring reason was false. In this hypothetical, a coworker obtained and disclosed internal-system material outside an established permission process; mark it X pending counsel review, do not solicit additional restricted material, and preserve only a lawful description of what was reported. Counsel can seek posting, hiring, staffing and system-audit records through appropriate production procedures (D), subject to proportionality and objections. Employer production may aid authentication but does not automatically prove motive.

Three evidence joins that require independent proof#

Accommodation chronology versus generalized medical assertions

Build a line for the first communicated work restriction or accommodation request, its recipient and receipt evidence; a separate line for each employer request for functional information; another for material supplied, clarifying questions, alternatives offered and decisions actually made. The request, the recipient's knowledge, the interactive exchanges, the functional limitation, and whether an effective option existed are distinct propositions. If the limitation or accommodation need is not obvious, the employer can seek reasonable documentation connected to that need; an unrestricted demand for complete medical history generally exceeds the EEOC's described scope. Conversely, a failure to provide legitimately requested sufficient documentation can matter to the defense. Do not treat a requested preferred accommodation as automatically required or an employer's assertion of insufficiency as automatically valid. Source: EEOC Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the ADA, questions 6–8, checked for these propositions on 2026-10-12. FEHA standards must be checked independently.

Federal and California accommodation triggers must be analyzed separately. EEOC healthcare-worker guidance describes an ADA accommodation request as an oral or written work-related change sought because of a medical condition, with no prescribed words. CRD's FEHA guidance also addresses an employer's duty to offer to initiate the interactive process when it otherwise becomes aware of a possible need—for example through a third party or observation. This distinction can affect the evidence matrix: capture request made, employer awareness from any source, who had that awareness, what functional barrier was understood, and what the employer did next in separate fields. Neither a diagnosis alone nor the simple fact of medical leave establishes that a particular decisionmaker was notified of a particular job adjustment need. Sources: EEOC, https://www.eeoc.gov/laws/guidance/health-care-workers-and-americans-disabilities-act (external site); CRD, https://calcivilrights.ca.gov/accommodation/ (external site) (agency guidance checked 2026-10-12). A claim-specific FEHA statutory/case-law review remains necessary.

Employer identity versus payroll-label identity

Keep separate fields for legal employing entity alleged, name on offer or contract, payroll issuing entity, entity whose EIN or SEIN appears, entity directing work, entity receiving accommodation communications, decisionmaker's principal, and entities named in bankruptcy. An EIN/SEIN, wage statement or successor's email domain may generate a useful lead but cannot on its own establish joint employment, alter ego, successor liability or falsification. Test each period separately, especially where corporate identity and bankruptcy status changed. Document the strongest innocent counterexplanation—authorized payroll processor, tax-account correction, asset transfer or agency reclassification—and identify what primary source would distinguish it from the claimant's inference.

Statutory FEHA W-2 signal is stronger than an EDD label but still rebuttable. Gov. Code § 12928 presumes that an entity identified on a federal W-2 is included within FEHA's employer definition, subject to rebuttal. Record W-2 box employer name/EIN, tax year, any W-2c, receipt/issuance date and employer explanation separately from W-2 wage amounts and from state SEIN or EDD amended wage-report entries. Record whether an entity actually hired, employed or directed the relevant act and what evidence could rebut statutory inclusion. Do not equate the W-2 presumption with automatically proving integrated-enterprise, joint-employer, successor or bankruptcy liability. Source: https://california.public.law/codes/government_code_section_12928 (external site) (nonofficial reproduction; 2026 official text and later judicial treatment pending).

Control and liability cannot be inferred from a payer alone. Federal EEOC guidance separates the integrated-enterprise inquiry (interrelated operations, common management, centralized labor relations, and common ownership/financial control) from joint-employer status (separate entities each controlling the worker). It treats successor liability as a further inquiry focused on relevant notice, continuity and relief from the predecessor. A payer can be distinct from the official who hired, received a request, directed clinical activities, decided discipline or approved termination. A county's oversight of contracted healthcare services, without more, is not synonymous with employer control; Vernon v. State of California (2004) 116 Cal.App.4th 114 cautions against equating ordinary government regulation with FEHA employment. Conversely, actual power over hiring, transfer, discipline or access to the position may matter even without issuing wages. Record date, named legal entity, specific act of control, direct evidence, contrary evidence, and legal theory for each entry.

Administrative naming is a separate gate. EEOC's published threshold manual generally directs that each joint employer be charged, while providing different discussions for integrated enterprises and successors; the actual charge, respondent service and applicable circuit/case-law exceptions require independent examination. An email address or SEIN correction establishes no charge amendment. Do not merge EEOC coverage, California FEHA employer status, and bankruptcy discharge into one test. Sources narrowly reviewed: https://www.eeoc.gov/laws/guidance/section-2-threshold-issues (external site) (§ 2-III B.1.a.iii, B.3.b; nonbinding agency guidance); https://law.justia.com/cases/california/court-of-appeal/2004/a101244.html (external site) (Vernon; subsequent treatment not citator-verified).

Adversarial identity challenge. The strongest respondent account may be that a W-2 reflects lawful payroll administration, a physician services agreement establishes independent-contractor factors under the correct state test, and clinical practice protocols are safety/contract oversight rather than unlawful lay clinical direction. Counter-test those positions using the statutory W-2 issuer presumption, contemporaneous control/decision records and professional-judgment directives—not merely branding, state tax numbers or a contract's conclusory labels. Each proposition requires independent coverage, admissibility, timing, and remedy analysis. Missing records are unresolved evidence, not an adverse inference without the required preservation and sanctions findings.

Legal-signal separation: do not let a single email prove four different elements

These rows are an evidence-quality screen only, not findings about a specific person or CFMG/Wellpath. Compare dates by source system and time zone. Protect employee medical details and withhold patient/juvenile records from public-facing versions.

Original agency record versus amended version

An original wage record and a subsequent amendment are two separate evidentiary objects. Record: source custodian, as-of date, submission date if established, first lawful receipt, specific fields changed, who authenticated each, and whether the agency record is employee-accessible, restricted or only described in correspondence. Use an unresolved value rather than asserting who initiated a change without a traceable filing history. Agency factual findings may face different admissibility limits from an employer-created payroll source; counsel must analyze them independently. A correction can be innocent, adverse, or inadequately explained; it is not automatic proof of retaliation.

Do not collapse four different clocks. Record independently (i) the underlying work/pay event date, (ii) the date a source employer or payroll processor generated or purportedly transmitted an entry, (iii) the agency's acceptance, revision or display date if actually documented, and (iv) the date the employee or other actor lawfully received or learned of each version. A screenshot's timestamp normally proves only the displayed state at capture; its metadata does not establish the original filing date or prove that the decisionmaker knew of a later correction. For each mismatch ask for the earliest contemporaneous source and the audit trail, not merely a retrospective explanation.

The legal burden must be tagged per claim. For California Labor Code § 1102.5 whistleblower retaliation governed by § 1102.6, Lawson v. PPG Architectural Finishes, Inc. (2022) 12 Cal.5th 703 holds that the employee establishes a contributing factor by a preponderance, after which the employer carries the clear-and-convincing same-decision burden. A separate McDonnell Douglas pretext requirement is not imposed on that claim. This framework must not be copied wholesale onto FEHA, ADA or every public-policy claim. Source checked as to this holding on 2026-10-12; later case history and application to the specific claim remain for counsel.

Reference hold. The older working corpus assigns distinct employment-evidence subjects to Roadmaps 094/095, whereas the later October 11 unified index assigns those numbers to nursing-board complaints and regulatory-versus-civil proceedings. Cross-references are therefore semantic pointers only until authoritative full text and the owner-approved canonical mapping can be compared.

Nonparty record request: separate process and permissions matrix#

A matrix row that says "D — obtainable by discovery" is only a candidate for lawful process, not proof that an employer, agency or healthcare custodian may release it. Where relevant information sits with a nonparty former employer or payroll custodian, distinguish California Code Civ. Proc. § 1985.6 employee-record notice and objections from a demand for records held by a party. Verify the statutory 10-day production notice and five-day pre-custodian-service notice, mailing extensions, authorized subject-only request exception in § 1985.6(k), and any affected employee's objection before assuming production. Where the recipient is a defined consumer-record custodian, assess § 1985.3. When a HIPAA-covered nonparty receives a medical-record request, the separate judicial-proceeding standard under 45 C.F.R. § 164.512(e) may require a narrowly framed court order or sufficient notice/protective-order assurances; a California subpoena form alone does not resolve that federal gate. Records of incarcerated or juvenile patients require other specialized restrictions beyond this employment matrix.

Private subpoena audit fields: (A) disputed element and minimally sufficient fact; (B) source custodian and legal entity; (C) record class and whether it concerns an employee, consumer, patient or juvenile; (D) statute/rule and any claim of exemption; (E) notice subject, notice date, form and proof; (F) custodian service and production dates; (G) mailing/service additions and objections; (H) court order, confidentiality/protective-order terms and allowable recipient; (I) scope narrowed or alternate non-patient source attempted; (J) actual lawful receipt, version hash and segregation location. If an objection, privilege or access restriction remains, the matrix records the unproduced lead; it does not direct a worker to obtain the material from another employee's account or the clinical system. This addition applies only to documentary process management, not a finding that any particular record exists. Sources: https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-1985-6/ (external site) ; https://selfhelp.courts.ca.gov/subpoena/give-notice (external site) ; https://california.public.law/codes/code_of_civil_procedure_section_1985.3 (external site) ; https://www.hhs.gov/hipaa/for-professionals/faq/may-a-covered-entity-not-party-to-legal-proceedings-disclose-information-by-court-order/index.html (external site) (text review limited; not a complete citator clearance).

A second clock ledger: discovery response and disclosure deadlines#

A claim deadline and a civil-discovery deadline belong in different columns. For each litigation event, retain the following nonpublic fields alongside its evidence row: (1) court and action filing date; (2) party and discovery device; (3) demand/service timestamp, service method and proof; (4) rule-trigger classification; (5) verified-response or supplemental-response service event, or no response; (6) counsel-calculated notice and compliance deadlines, written specific-date extensions and applicable service adjustments; (7) exact response, objections, privilege log, agreed production and actual production dates; (8) motion/order outcome and status. A 60-day § 2016.090 disclosure window in a covered action is reciprocal and demand-triggered, not an automatic entitlement on the date the case is filed. The nonrepresentation and action-category exemptions require separate checking. For an initial-disclosure event, also record verification method (declaration of party or authorized representative versus counsel signature); whether the ESI was copied or identified by category/location; the named parties and material provisions of any identified insurance/indemnity instrument; and any timely supplemental demand against its frequency limits. SB 66 (2025, ch. 50) removed the formerly scheduled 2027 repeal; do not silently apply the different older disclosure scheme. A 45-day § 2031.310(c) motion to compel further inspection response is not the same as a motion over no response (§ 2031.300) or an unfulfilled compliance undertaking (§ 2031.320). Similar further-response rules apply to interrogatories and requests for admission (§§ 2030.300(c), 2033.290(c)), but the admission no-response regime has separate consequences (§ 2033.280). A response row is not proof that its assertions are true and a claim of unavailable records is not proof of deliberate spoliation. The purpose is to prevent the otherwise strong evidentiary case from losing a procedural remedy through a miscalendared rule.

A practical adverse test is bilateral: if the respondent says an older platform is inaccessible, identify the system, alternative backups, retention policy, knowledgeable custodians, cost claims and what the law requires the opponent to show under § 2031.310(d)–(g); if the worker requests a broad archive, document why a narrower date/person/search-term scope or staged production may satisfy the contested element. Source texts reviewed in current code reproductions on October 12, 2026, not independently citator-validated. No private information belongs in the public corpus.

Building the matrix in practice#

The matrix is built in three passes. The first pass, before any filing, marks what is lawfully held (H), what may be requested by a specific non-litigation statutory route (R), and what may later become accessible through an agency proceeding (A, conditional). The worker assembles H records and sends justified R requests (Roadmap 033); agency filings, if warranted, are recorded separately with their own prerequisites and deadlines (Roadmaps 034–036). Filing a charge does not produce an automatic right to every position statement, attachment or investigative file. The pre-suit case file (Roadmap 009.1) is a live index of what has and has not actually been obtained, not a certification of completeness.

The second pass, with counsel after filing, targets the D category and the parallel time-sensitive disclosure ledger. Assess whether the case qualifies for California § 2016.090 reciprocal disclosures and whether to serve a demand, then distinguish no response, deficient verified response and noncompliance with an actual production promise. Each evidence row records what was demanded, the exact response and service date, what was produced, what was withheld under an asserted protection, and the source and outcome of the objection (Roadmap 038). The P category records the specific asserted privilege/privacy rule, not an automatic exclusion.

The third pass, before any dispositive motion or trial, reads the matrix by element and by defense: for each element, is there potentially admissible evidence in hand, from whom, authenticated how, and subject to which privilege or confidentiality restriction; for each defense, is there evidence that meets it. A row with an element and no currently identified proof requires investigation, law-specific burden analysis and counsel's judgment; it is not automatically a claim to drop. An unanswered defense can present serious dispositive-motion risk, but a defense must itself be legally available and factually supported. The matrix exists so that both are seen early.

Four independent gates before an exhibit is quoted or published#

EEOC's Section 83 disclosure procedures permit certain charge-file access after agency processing and require sanitization; the policy provides a restrictive transmittal notice for pre-suit disclosures. For third-party employee or patient information, a compliant subpoena, legitimate receipt, admissibility and permission to publish are four different determinations; the corresponding notice/objection or HIPAA documentation stays in the private ledger, not in a public exhibit. EDD distinguishes access to one's own records from a third party's request for confidential business/person records. Both access routes require a document-specific permissions check. Sources reviewed 2026-10-12: https://www.eeoc.gov/section-83-disclosure-information-charge-files (external site); https://edd.ca.gov/en/about_edd/third-party-requests/ (external site). The applicable court rules and any express restrictions govern actual use, not this generalized matrix.

Gaps the matrix exposes#

Certain gaps recur. The protected activity row often has the report but not the proof of the decisionmaker's knowledge; that proof is in the D category, and the pre-suit file should at least identify who was told and who was copied (legacy decisionmaker-knowledge evidence tool, former 102; canonical numeric link held). The pretext row often has the stated reason but not the comparators; comparators are D under Williams and the pre-suit file should at least record what the worker lawfully knows (legacy decision/reason evidence tool; serial link held). The damages row often has the pre-termination compensation but not the contemporaneous job-search record, which cannot be retrospectively recreated as a contemporaneous account; the worker should keep an accurately dated mitigation log (legacy worksheet 112, serial link held). The entity row often has a badge but not a complete sequence of wage statements; verify what is already lawfully held and whether a precisely scoped Labor Code request is available (Roadmap 033). And the arbitration row may be missing a signed agreement or evidence of assent. A targeted § 432 request can obtain copies of signed instruments within the statute's reach, but nonproduction does not establish that no agreement exists and a returned document does not, by itself, resolve validity, waiver, scope, governing law, or forum. Counsel should check other lawful sources and demand a reliable execution record rather than assume the request alone decides arbitrability.

The matrix and the agency stage#

The matrix is built for litigation but it is used first at the agency. At the agency stage, the matrix organizes documents actually submitted and received, including the worker's lawfully held records, independent statutory productions and any authorized respondent materials. The EEOC may supply the respondent's position statement and nonconfidential attachments for a charging-party response during investigation. CRD advises that it generally does not release open-case records; its investigative procedure must not be treated as interchangeable with the EEOC's. A formal rebuttal should answer specific factual assertions using dated exhibits while respecting the agency’s instructions and deadlines. For the EEOC, the charging-party position-statement Q&A contains a 20-day summary/30-day Question 2 inconsistency; its case-specific communication, transmission date and written extension confirmation therefore belong in the ledger. The respondent’s usual 30-day submission period is a different clock. The EEOC permits written, telephone or meeting responses; an oral response needs a dated memorialization and agency acknowledgment if available. Do not convert an evidentiary rebuttal into a presumed amended charge or a new right-to-sue event. A document naming a respondent or stating a reason for termination fixes what the respondent asserted, not necessarily the true employer or actual motive. Its admissibility in later litigation remains a separate inquiry, including authentication, attribution to a party or agent, other hearsay layers and possible privilege or statutory exclusion. Agency notices, requests, charge-file disclosures and any redactions are indexed only as actually received, with dates and restrictions. A request for an EEOC position statement while an investigation remains open must not be mislabeled a request for the complete post-processing charge file. For a closed charge, log whether access was sought by FOIA or Section 83, whether the proceedings truly ended despite any early right-to-sue notice, and whether a FOIA partial-denial appeal exists. EEOC’s charge-file FOIA Q&A describes a 90-calendar-day administrative appeal after the determination, while Section 83 has no equivalent administrative withholding appeal. Each route is separate from any litigation filing deadline and any permission to release the material publicly.

The matrix and settlement#

Settlement discussions, whether at mediation during the agency process or after suit, are conducted on the same matrix. Each side values the case by the rows: the strength of the evidence on each element, the strength of the answer to each defense, and the damages the records support. A complete lawful exhibit inventory, accurate chronology and supportable damages analysis can improve the parties' ability to evaluate settlement, but they do not predict leverage or settlement value. The matrix also disciplines the allocation of any settlement among wages, damages, penalties and fees (Roadmap 037), because each category corresponds to rows whose evidence supports it. Nothing in this section values any case; it describes how the matrix is used.

Reading the matrix across claims#

Three patterns recur. First, the same document serves many claims: the wage statement can document the entity named, pay terms and compliance issues under § 226 but does not conclusively resolve employer identity or establish a wage-statement violation by itself; the personnel file can document what the employer recorded and when, without alone proving that the reason was genuine or that an access statute was violated; a lawfully received position statement may fix a respondent's contemporaneous account of identity and reasons, with later evidentiary effect dependent on admissibility rules. The legacy agency exhibit index (old worksheet 113; serial link held) numbers each source exhibit once for that reason. Second, the evidence that meets a defense is usually the same evidence that proves an element viewed from the other side: evidence of decisionmaker knowledge addresses a prerequisite to causation but does not by itself prove retaliatory motive; a filled position may contradict some reorganization explanations depending on its duties and timing; and a dated job-search record may support mitigation while leaving reasonableness and loss contested. Third, the categories marked D are where cases are decided and where the pre-suit file is tested: a worker who arrives with a lawful H/R inventory and a chronology can identify precise discovery targets; unauthorized X-category acquisition creates avoidable privacy, discipline and litigation risks and should be referred to counsel rather than compounded by further circulation.

Elements of the claim#

Collected above by reference to the legacy claim-element tables (supplement link held). The matrix adds the source of the proof for each element, which the tables do not state, and that addition is its reason for existing: an element with a known source is a task; an element with no known source is a question for counsel before anything is filed.

Potentially relevant defendants#

By claim, as each Roadmap states; always by exact legal name (legacy employer-identity worksheet, former 101; canonical numeric link held). The matrix's entity row is the same for every claim because the question is the same for every claim, and the evidence that answers it — the wage statements, the hiring notice, the public debtor list, the agreements among affiliates, the entity designee's testimony — is gathered once and used throughout.

Administrative prerequisites#

By claim: CRD/EEOC complaint or charge procedures for FEHA and ADA; LWDA notice for applicable PAGA claims; benefit-plan administrative exhaustion generally for ERISA § 502(a)(1)(B) benefit claims (subject to recognized exceptions); and no general EEOC/CRD charge prerequisite for Labor Code § 1102.5, Tameny, ordinary private contract, most wage, FMLA or record-access claims. A public employer, union agreement, administrative scheme, particular statutory subsection, bankruptcy plan or arbitration agreement may create a separate prerequisite or forum issue. Do not infer a universal "none" from this matrix; confirm the claim-specific rule in the legacy filing/prerequisite supplement (numeric link held), then independently verify current law.

Limitation periods#

By claim, as each Roadmap states and the legacy deadlines supplement collects (numeric link held). None computed here. 2026 FEHA procedural check: Gov. Code § 12960(e)(5) generally provides three years to file the qualifying employment complaint with CRD, subject to statutory exceptions. Section 12960(f), amended by SB 477 effective January 1, 2026, separately addresses tolling for specified civil actions during CRD proceedings and disposition of timely agency appeals, provides for retroactivity, and states that it does not revive already-lapsed claims. Do not confuse an agency complaint filing period with a later civil-action period, or treat every respondent, claim or older civil action as automatically timely. Determine each act date, intake date, verified complaint date, closure notice date, timely appeal status, post-appeal closure notice and right-to-sue event from records; reconcile § 12965 and controlling interpretation before calculating. Source: https://law.justia.com/codes/california/code-gov/title-2/division-3/part-2-8/chapter-7/article-1/section-12960/ (external site) (2025 chaptered amendment effective 2026; official legislation page blocked).

Evidence and records to obtain#

The matrix.

Favorable and adverse facts#

By claim, as each Roadmap states. The matrix's contribution is the source column: a potentially important fact cannot justify unauthorized access, copying or disclosure of X-category material. Record the lawful discovery target without obtaining the restricted record; counsel must assess any already received material and admissibility separately.

Likely defenses#

By claim, from the playbook (133).

Causation#

By claim; the evidence of timing, knowledge and shifting reasons recurs in every row.

Damages and remedies#

Roadmap 037 and the legacy damages/remedies supplement (numeric link held).

Discovery#

Roadmap 038 explains the tools that obtain the D categories.

CFMG/Wellpath-specific relevance#

Why this may matter in a CFMG/Wellpath setting. The entity-identity row appears in every claim because, in a multi-entity organization operating under county contracts and with potentially relevant chapter 11 proceedings (Roadmaps 004, 090 and 091; legacy employer-identity topic numbered 094 is held and must not link to the newer nursing-board complaint page), allocation of employment authority can be decisive. The matrix states where the identity evidence lives — the worker's own records, the public dockets, the agreements obtainable only in discovery, the entity deposition — and nothing about what it shows for any worker.

Primary authorities#

The matrix relies principally on authorities addressed in its linked substantive Roadmaps. Procedural propositions separately checked on 2026-10-12 against current California code reproductions include CCP §§ 1985.6(b), (f), (k), 1985.3 (consumer-record definitions and notice), § 2016.090(a)–(d), §§ 2030.300(c), 2031.310(b)–(j), 2033.290(c) and 2033.280; separate medical-disclosure propositions were reviewed against official HHS guidance explaining 45 C.F.R. § 164.512(e), and the employee/consumer subpoena notice procedure was compared with California Courts' SUBP-025 instructions; sources: https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2016-090/ (external site) and https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2031-310/ (external site) (related text linked in Roadmap 038). Official legislative and subsequent-history review remains incomplete. Agency-access corrections reviewed on 2026-10-12 also rely on official EEOC position-statement instructions (https://www.eeoc.gov/employers/questions-and-answers-respondents-eeocs-position-statement-procedures (external site)), EEOC FOIA/Section 83 policy (https://www.eeoc.gov/foia/section-83-disclosure-information-charge-files (external site)), CRD's public-records guidance (https://calcivilrights.ca.gov/prarequests/ (external site)), and Cal. Unemp. Ins. Code § 1094/EDD disclosure guidance (https://edd.ca.gov/en/About_EDD/third-party-requests (external site)). These are issue-specific source checks, not verification of every legal claim in the matrix; current statutory text and subsequent history still require final editorial review.

Related roadmaps#

Employment Roadmaps 010–038 and entity Roadmap 004 are subject to their own source and version checks. The older bankruptcy Chapter 11 and stay/discharge drafts were historically numbered 090–091 but are absent from the October 11 unified index; those numbers are descriptive historical provenance, not validated canonical links. Legacy subject pointers 094 (employer identity), 095 (tax/evidence), 096.1–096.3 (supplemental tables) and the older 100–114 worksheet namespace likewise remain semantic references only, with no approved numerical links until original manuscript bodies and index mappings are compared. Current newer model and playbook indexes include 125–132 and 133.

Companion worksheet#

The matrix itself, printed, with the six-way records key marked by hand for each row; and the legacy agency exhibit index, not the later canonical Government Claims Act worksheet assigned serial 113, for numbering actual exhibits.

What this page cannot do#

It cannot apply any row to any facts, cannot obtain any record, and cannot substitute for the Roadmaps, the worksheets, or counsel. It shows where everything is and how it fits.