05
Case File
The case file contains 12 documents — witness statements and exhibits. Work only from these materials and from what you develop in your interviews.
WITNESS STATEMENT · STATEMENT ADEYEMI
Witness Statement — Yusuf Adeyemi
Matter: Prairie State Logistics, Inc. v. Yusuf Adeyemi (Employment Arbitration) Witness ID: m11.wit.adeyemi Taken: February 10, 2026
My name is Yusuf Adeyemi. I am 41 years old and I live near Joliet. I started at Prairie State Logistics in March 2019 as a warehouse associate. I worked hard, learned the operation, and in 2022 they promoted me to second-shift operations supervisor. I ran a crew of about twenty-four people — inbound and outbound. For most of my time there my reviews were good. I got an "exceeds expectations" rating in 2023 and a spot bonus in 2024. In seven years, there was never a single write-up in my file. Not one.
Things changed last summer. The outbound targets kept going up, and there was no extra staffing to hit them. To get the trucks loaded, my crew kept working after the shift was supposed to end. The problem was the timekeeping system. Sometime in 2025 they switched to a setup that clocked everybody out automatically at their scheduled end time. So all the extra work my people were doing after that — twenty, thirty, forty minutes some nights — never got recorded, and they never got paid for it. I brought this up with Roland Pfeiffer, the site director, back in September. He told me to "make the numbers work." That stuck with me.
During peak season, October and November, there was another problem. The outbound bay got so crowded that pallets were staged right in front of the fire exits. I'd tell my leads to clear them, and they would, but the next night they'd be blocked again because there was nowhere else to put the freight. On November 5th I took a picture of the north exit blocked, because I couldn't believe it had gotten that bad.
On November 10th I finally put it all in writing. I emailed Bethany Croll in HR — the unpaid time and the blocked exits, both. She wrote back on the 12th saying she'd look into it. Then nothing happened. No follow-up, no meeting, nothing changed on the floor. So on November 18th I called a state hotline for wage and safety complaints and filed a report. I got a confirmation number back.
Three weeks later, on December 5th, Pfeiffer put me on a performance improvement plan. Outbound accuracy and "team coaching," he said. The numbers he pointed to were from October and November — the exact weeks we were short-staffed and running late every night. It was the first bad piece of paper in my whole file. Then on January 9th they fired me. The notice said it was the performance plan and also a "headcount reduction." Both. They offered me four weeks of severance if I signed a release giving up all my claims. I wouldn't sign it.
What bothers me most is the timing. I report the problems, and within weeks I'm suddenly a bad supervisor after seven clean years. A few weeks after that I'm gone. And then I hear they posted my shift's job again. I don't think that's a coincidence.
I want my job back if I can get it, or fair pay for what I lost — back pay and going forward. I want the unpaid wages for my crew made right. And I want a reference that doesn't end my career. This is a small world. The managers at these logistics sites all know each other, and I'm scared that if I get labeled the guy who made trouble, I won't work in this business again.
WITNESS STATEMENT · STATEMENT RUVALCABA
Witness Statement — Tomás Ruvalcaba
Matter: Prairie State Logistics, Inc. v. Yusuf Adeyemi (Employment Arbitration) Witness ID: m11.wit.ruvalcaba Taken: February 12, 2026
My name is Tomás Ruvalcaba. I'm 36. I drive a forklift and I'm a lead on the second shift at Prairie State Logistics, and I still work there. I've been on Yusuf's crew for about four years. I want to be careful here because I'm still employed, but I'm going to tell you what I actually saw.
Last fall we were slammed. The outbound numbers they wanted were higher than what we could do in the hours we had, so we stayed late — pretty much every night in October and November. I'd say twenty to forty minutes past when we were supposed to be done, depending on how the trucks were running. The thing is, the time clock cut us off at the scheduled end. It just clocked everybody out. So all that extra time we put in loading trucks, we didn't get paid for it. It was off the books. Guys grumbled about it in the break room but nobody wanted to be the one to make noise.
I heard Pfeiffer more than once tell Yusuf to keep the belt running after the shift was supposed to end. I remember one night in particular, we were maybe halfway through a trailer and the shift bell had already gone, and Pfeiffer came through and told Yusuf to keep it moving until it was loaded. That kind of thing happened a lot.
Yusuf was a good supervisor. He looked out for us. If anything, he was the one telling us to be safe and slow down when the floor got crazy. So when they wrote him up for "coaching" his team, that didn't match what I saw at all. He coached us plenty.
I also want to say — after Yusuf raised his concerns, there was a meeting where the supervisors told everybody not to "go outside the building" with problems, to bring things to management first. It felt like a message. People understood it.
I'm nervous about this. I've got a family and I need this job. But Yusuf got a raw deal, and the late nights without pay were real. I saw it every week.
WITNESS STATEMENT · STATEMENT NYARKO
Witness Statement — Ayana Nyarko
Matter: Prairie State Logistics, Inc. v. Yusuf Adeyemi (Employment Arbitration) Witness ID: m11.wit.nyarko Taken: February 18, 2026
My name is Ayana Nyarko. I'm an inbound clerk on the second shift at Prairie State Logistics. I've been at the site a little over two years and I worked near Yusuf Adeyemi's outbound area most nights.
I want to talk mainly about the fire exits, because that's what I saw most clearly. During peak season last fall — October into November — the outbound bay was packed. There was just more freight than places to stage it. Several nights I saw pallets sitting right in front of the north fire exit, blocking it. It wasn't a little in the way; it was fully in front of the door. I remember thinking that if something happened, people on that end of the floor would have a problem getting out.
Yusuf was on it. I heard him tell one of his leads to clear the exit more than once. They'd move the pallets, but the freight kept coming, so a day or two later it would be blocked again. It wasn't that nobody cared on his crew — it was that there was nowhere to put everything and the targets kept climbing.
The other thing I remember is a meeting after Yusuf raised his concerns. A couple of the supervisors got us together and basically said if we had problems we should bring them to management inside the building and not "go outside" with them. Nobody said Yusuf's name, but the timing made it pretty obvious what it was about. It made people uneasy about speaking up.
I liked working for Yusuf's crew. He was fair and he took safety seriously. When I heard they let him go for performance, it surprised me, because from what I saw he was one of the ones actually trying to do things right.
I'm telling the truth about what I saw with the exits and the meeting. I don't know anything about the paperwork side or the reasons they gave for firing him — that's not something I'd have been part of.
WITNESS STATEMENT · STATEMENT CROLL
Witness Statement — Bethany Croll (HR Business Partner)
Matter: Prairie State Logistics, Inc. v. Yusuf Adeyemi (Employment Arbitration) Witness ID: m11.wit.croll Taken: March 3, 2026 (statement summarized from interview; witness is employed by Respondent)
My name is Bethany Croll. I am the HR business partner assigned to the distribution center. I support the site on employee-relations matters, including complaints, performance documentation, and separations. I am providing this statement in my capacity as a Prairie State employee.
I received an email from Yusuf Adeyemi on November 10, 2025. In it he raised two concerns: that his crew was working past their clock-out without pay because of how the timekeeping was configured, and that fire exits in the outbound bay were being blocked by staged freight during peak season. I acknowledged his email on November 12 and told him I would look into it.
As part of handling the complaint, I forwarded Mr. Adeyemi's email to site operations so it could be reviewed by the operations leadership, which meant it went to Roland Pfeiffer, the director of operations, on November 12. That is our normal routing — the operational concerns he raised sat with operations to address. I understand there is a question in this case about who knew what and when, and I can only speak to the routing as it appears in my records.
On the timekeeping issue, I was told the system was operating as configured and that any off-schedule work should be logged through an exception process. On the fire-exit issue, I understood that operations was asked to keep the aisles and exits clear during the peak.
I was not the decision-maker on Mr. Adeyemi's performance improvement plan or his separation. Those were operations decisions, documented through the normal process. I processed the separation paperwork after the decision was made and communicated the severance offer that was extended in exchange for a release.
I don't have personal knowledge of any outside hotline complaint. My involvement was the internal email and the routing I've described.
CASE-FILE DOCUMENT · EMPLOYMENT AGREEMENT
Exhibit m11.exh.001 — Employment Agreement (Excerpt, with Arbitration Clause)
PRAIRIE STATE LOGISTICS, INC. — EMPLOYMENT AGREEMENT Employee: Yusuf Adeyemi Original execution: March 18, 2019 · Reaffirmed on promotion: June 1, 2022
The following are the provisions most relevant to this dispute. Non-material boilerplate (benefits enrollment, code-of-conduct acknowledgment, IT policy) is omitted.
1. At-Will Employment. Employment with Prairie State Logistics, Inc. ("the Company") is at will and may be ended by either party at any time, with or without cause, subject to the dispute-resolution provisions of Section 9.
4. Duties. Employee is employed as an Operations Supervisor and shall perform the duties assigned by site leadership, including supervision of assigned shift personnel and adherence to Company safety and timekeeping policies.
7. Timekeeping. Employee and Employee's direct reports shall record all working time in the Company timekeeping system in accordance with Company policy. Off-schedule work must be recorded through the exception process.
9. Dispute Resolution — Mandatory Arbitration. (a) The Company and Employee agree that any and all disputes, claims, or controversies arising out of or relating to Employee's employment or the termination of that employment — including claims of retaliation, wrongful discharge, and unpaid wages — shall be resolved exclusively by final and binding arbitration before a single neutral arbitrator. (b) The arbitration shall be administered by the designated arbitral forum under its employment rules and shall be governed by the law of the State of Illinois. (c) Class and collective waiver. Employee agrees to bring any covered claim only in Employee's individual capacity and not as a plaintiff or class member in any purported class or collective proceeding. (d) The Company shall pay the arbitrator's fees and the administrative fees of the arbitral forum. Each party shall otherwise bear its own attorneys' fees, except as a governing statute may provide. (e) This Section survives the termination of employment.
Acknowledgment. Employee acknowledges having read Section 9 and agrees to its terms.
Signature block: Yusuf Adeyemi (Employee), March 18, 2019; reaffirmed June 1, 2022. For the Company: Site HR, on the same dates.
[Case-file note: reproduced for the exercise; the full multi-page agreement and signature pages are in the matter file.]
CASE-FILE DOCUMENT · PERFORMANCE IMPROVEMENT PLAN
Exhibit m11.exh.002 — Performance Improvement Plan
PRAIRIE STATE LOGISTICS, INC. — PERFORMANCE IMPROVEMENT PLAN Employee: Yusuf Adeyemi · Position: Operations Supervisor, Second Shift Issued by: Roland Pfeiffer, Director of Operations Date issued: December 5, 2025 · Review period: 60 days
Purpose. This Performance Improvement Plan (PIP) is issued to address performance concerns and to set clear expectations and a timeline for improvement.
Areas of concern.
- Outbound accuracy. Second-shift outbound accuracy fell below the site target during October and November 2025. Mis-ships and pick errors on the shift exceeded the acceptable threshold in those months.
- Team coaching and adherence. Leadership has identified gaps in coaching shift personnel on process adherence and in ensuring staged freight does not obstruct aisles and marked exits.
Expectations for the review period.
- Bring second-shift outbound accuracy to or above the site target and sustain it.
- Document coaching sessions with shift leads on process adherence.
- Ensure aisles and marked exits remain clear at all times during the shift.
Consequences. Failure to meet the expectations above within the review period may result in further action up to and including termination of employment.
Employee comments. "I do not agree with this plan. The accuracy numbers cited are from the weeks we were running short-staffed and past scheduled end time to hit outbound targets. I raised the unpaid-time and blocked-exit issues in writing on November 10. — Y.A."
Signatures: Roland Pfeiffer (Director of Operations), Dec. 5, 2025. Yusuf Adeyemi (Employee — signed to acknowledge receipt, not agreement), Dec. 5, 2025.
[Case-file note: This is the first documented negative performance action in the employee's personnel file.]
CASE-FILE DOCUMENT · TERMINATION NOTICE
Exhibit m11.exh.003 — Termination / Separation Notice
PRAIRIE STATE LOGISTICS, INC. — NOTICE OF SEPARATION Employee: Yusuf Adeyemi · Position: Operations Supervisor, Second Shift Separation date: January 9, 2026 Prepared by: Site HR, at the direction of Operations
Reason for separation. Employee's separation is the result of (1) failure to meet the performance expectations set out in the Performance Improvement Plan issued December 5, 2025, and (2) a site headcount reduction eliminating certain supervisor positions.
Final pay. Final wages through the separation date, and any accrued unused paid time off, will be paid in accordance with Company policy and applicable law.
Separation offer. The Company offers Employee a severance payment equal to four (4) weeks of base pay, conditioned upon Employee's execution of a general release of all claims arising from employment. This offer is open for the review period stated in the enclosed release. [Case-file note: Employee did not sign the release.]
Company property and access. Employee must return all Company property and badge access on or before the separation date.
Benefits. Information regarding continuation of health coverage will be sent separately.
Acknowledged / delivered: Site HR, January 9, 2026.
[Case-file note: The notice states two independent grounds — a for-cause performance failure and a neutral reduction in force. The reduction-in-force memo is Exhibit m11.exh.008.]
CASE-FILE DOCUMENT · HR COMPLAINT EMAIL CHAIN
Exhibit m11.exh.004 — HR Complaint Email Chain (Adeyemi–Croll)
Reproduced from the parties' document exchange. HR's internal forward (below) was produced by the Company in the arbitration.
From: Yusuf Adeyemi To: Bethany Croll (HR Business Partner) Date: Monday, November 10, 2025, 11:42 PM Subject: Concerns — unpaid time after clock-out and blocked fire exits (2nd shift)
Bethany,
I need to raise two things in writing.
First, my crew has been working past our scheduled clock-out most nights to hit the outbound targets. Since the timekeeping change, the system clocks everyone out at scheduled end, so this extra time isn't being recorded or paid. Over the last several weeks this is a real amount of unpaid time across the shift. I raised it verbally with Roland in September and nothing changed.
Second, during peak the outbound bay has gotten so full that pallets are being staged in front of the fire exits, including the north exit. I have my leads clear them but they get blocked again because there's nowhere else to stage the freight. This is a safety problem and I want it documented.
Please let me know how the company wants to address both. Thank you.
— Yusuf
From: Bethany Croll To: Yusuf Adeyemi Date: Wednesday, November 12, 2025, 9:15 AM Subject: RE: Concerns — unpaid time after clock-out and blocked fire exits (2nd shift)
Yusuf — thank you for flagging these. I'll look into it and follow up. — Bethany
[Company-produced internal forward] From: Bethany Croll To: Roland Pfeiffer (Director of Operations) Date: Wednesday, November 12, 2025, 9:22 AM Subject: FW: Concerns — unpaid time after clock-out and blocked fire exits (2nd shift)
Roland — forwarding a complaint from Yusuf Adeyemi (below) on unpaid off-clock time and blocked exits on 2nd shift. These are operations items — can your team review and let me know how you want to handle? — B.
[Case-file note: There is no further written response to the employee in the produced record between November 12 and the December 5 PIP.]
CASE-FILE DOCUMENT · STATE HOTLINE CONFIRMATION
Exhibit m11.exh.005 — State Wage-and-Safety Hotline Confirmation
Reproduced from a screenshot the employee saved. Administrative confirmation only; the substance of the report is summarized.
STATE WAGE-AND-SAFETY COMPLAINT — SUBMISSION CONFIRMATION
Confirmation number: PS-WS-2025-11-004871 Date submitted: November 18, 2025, 8:03 PM Method: Online intake form (self-submitted)
Complainant contact on file: Y. Adeyemi (email and phone provided) Employer named: Prairie State Logistics, Inc. — distribution center, Will County
Nature of complaint (as entered by complainant):
- Employees required to work after automatic clock-out without pay for that time ("off-the-clock" work), second shift.
- Fire exits in the outbound bay blocked by staged freight during peak season.
What happens next (auto-generated): Your submission has been received and assigned the confirmation number above. An intake reviewer may contact you for additional information. Keep this confirmation number for your records.
[Case-file note: This confirmation reflects an external report made eight days after the internal HR email (Exhibit m11.exh.004) and seventeen days before the Performance Improvement Plan (Exhibit m11.exh.002). The Company asserts it did not receive notice of this external complaint until after the termination; the timing and routing are disputed.]
CASE-FILE DOCUMENT · FIRE EXIT PHOTO EXHIBIT
Exhibit m11.exh.006 — Photograph: Blocked North Fire Exit (Description)
The exhibit is a photograph taken on the employee's phone. It is described here for the exercise; the image file is in the matter file with its metadata.
Photograph metadata (as recorded by the device):
- Date/time taken: November 5, 2025, 10:47 PM
- Location tag: Prairie State Logistics distribution center, outbound bay (north end)
- Taken by: Yusuf Adeyemi
Description of the image: The photograph shows the north emergency exit of the outbound bay. A red "EXIT" sign is illuminated above a single push-bar door with a marked exit path on the floor. Directly in front of the door, three stacked pallets of shrink-wrapped cartons are staged, fully covering the marked path and reaching to within a few inches of the door. A yellow floor stripe and a wall-mounted sign reading "KEEP CLEAR — FIRE EXIT" are partially visible behind the pallets. A forklift is parked at the edge of the frame. The bay is otherwise densely packed with staged outbound freight.
Foundation notes (for the exercise): The photograph's date and time align with the peak-season period described in the witness statements (Exhibits/statements of Adeyemi, Ruvalcaba, and Nyarko) and precede the internal HR complaint of November 10, 2025.
[Case-file note: Additional photographs from other nights were referenced by witnesses but are not in the exchanged set; only the November 5 image is in evidence.]
CASE-FILE DOCUMENT · TIMEKEEPING RECORDS
Exhibit m11.exh.007 — Timekeeping / Punch Records Excerpt (Oct.–Nov. 2025)
Excerpt from the Company timekeeping export for the second shift, produced in the arbitration. Scheduled end of second shift is 11:00 PM. The system records an automatic clock-out at scheduled end. Names other than the parties are shown by initials.
| Date | Employee | Scheduled end | System clock-out | Notes |
|---|
| 2025-10-14 | T.R. (lead) | 11:00 PM | 11:00 PM (auto) | Trailer #4482 loaded 11:34 PM per dock log |
| 2025-10-14 | A.O. | 11:00 PM | 11:00 PM (auto) | On floor per badge until 11:28 PM |
| 2025-10-21 | T.R. (lead) | 11:00 PM | 11:00 PM (auto) | Dock log shows outbound activity to 11:41 PM |
| 2025-11-04 | Crew (12) | 11:00 PM | 11:00 PM (auto) | Outbound volume 118% of plan |
| 2025-11-05 | Crew (12) | 11:00 PM | 11:00 PM (auto) | Dock log: last trailer sealed 11:39 PM |
| 2025-11-11 | Crew (11) | 11:00 PM | 11:00 PM (auto) | Two exception entries filed; nine not |
Exception-process summary (same period): Of the shifts sampled above, exception entries to capture post-schedule work were filed on only a handful of occasions. Dock logs and badge-access records show floor and outbound activity continuing 20–40 minutes past the automatic clock-out on most sampled nights, without corresponding paid time.
[Case-file note: The mismatch between the automatic clock-out at 11:00 PM and the dock/badge activity after 11:00 PM is the documentary basis for the off-the-clock unpaid-time claim. The employee states he kept his own contemporaneous log of late nights; that log is referenced but was not produced with this exchange.]
CASE-FILE DOCUMENT · RIF MEMO
Exhibit m11.exh.008 — Reduction-in-Force Memo
PRAIRIE STATE LOGISTICS, INC. — INTERNAL MEMORANDUM (CONFIDENTIAL) Date: January 8, 2026 From: Roland Pfeiffer, Director of Operations To: Site HR Re: Second-quarter site staffing adjustment — supervisor positions
As part of the site's cost and staffing plan, we are eliminating two (2) supervisor positions effective this month:
- Second-shift Operations Supervisor — currently held by Y. Adeyemi.
- First-shift Receiving Supervisor — currently held by a supervisor who has provided notice of retirement effective this quarter.
The reduction reflects an operational decision to consolidate supervisory coverage across shifts. HR should process the separations in accordance with policy.
[Case-file note: This memo is dated one day before the January 9, 2026 separation. The separation notice (Exhibit m11.exh.003) cites both this reduction in force and the December 5 Performance Improvement Plan (Exhibit m11.exh.002). Within six weeks of the separation, the Company posted a "Shift Operations Lead — Second Shift" opening; whether that posting is the same role under a different title is disputed.]
06
Procedural & Factual History
Yusuf Adeyemi joined Prairie State Logistics in 2019 and became second-shift operations supervisor in 2022 with consistently strong reviews. In the summer and fall of 2025, his crew was routinely kept working past clock-out to hit outbound quotas, and a timekeeping change left that time unrecorded and unpaid; during the same peak season, staged pallets repeatedly blocked outbound-bay fire exits. On November 10, 2025, Adeyemi emailed a written complaint to HR business partner Bethany Croll about both problems; on November 18, 2025, having gotten no substantive response, he filed a complaint with a state wage-and-safety hotline. On December 5, 2025, the site's director of operations, Roland Pfeiffer, placed Adeyemi on a performance improvement plan — the first negative document in his file — citing October–November accuracy metrics. On January 9, 2026, the company terminated him, citing both the performance plan and a site headcount reduction memorialized in a reduction-in-force memo dated January 8, 2026; within six weeks it posted a second-shift operations-lead opening. Adeyemi refused a conditional severance release. Because his employment agreement contains a mandatory arbitration clause with a class waiver, the firm filed a demand for arbitration in February 2026. As of June 30, 2026, pre-hearing document exchange is ongoing and the hearing is anticipated later in the year.
Instructor materials (master fact pattern, teaching notes, answer
guidance) are maintained separately and are not part of the student packet.
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