EMPLOYER DISCRIMINATION; EVIDENCE OF UNLAWFUL MOTIVATION; NEXUS – Departure from Past Practices or Procedures

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Employer did not depart from past practice when it required employee to give 24 hours advance notice of request for time off to conduct union business, whether such leave was covered by the contract or not, but did depart from practice when it disciplined another employee for failure to provide 48 hours notice, where current policy and practice required only 24-hour notice. Evidence established that parties had a longstanding past practice of requiring 24-hour notice. Contract provisions did not alter past practice requiring notice.