MEMORANDUM AND ORDER RE: MOTION TO DISMISS

WILLIAM B. SHUBB, UNITED STATES DISTRICT JUDGE

Plaintiff Betty Ravel filed this action against defendant Hewlett-Packard Enterprise, alleging that defendant discriminated against her on the basis of her disability in violation of the American with Disabilities Act (“ADA”) and the California Fair Employment and Housing Act (“FEHA”), (Notice of Removal Ex. A, First Am. Compl. (“FAC”) (Docket No. 1).) Before the court is defendant’s Motion to Dismiss plaintiffs Complaint. (Def.’s Mot. (Docket No, 4).)

I. Factual and Procedural Background

Plaintiff began working for defendant, a computer technology company, in 2010. (FAC ¶¶ 2, 12.) In March 2015, she was promoted to Sales Administration Manager, a position that involves managing teams of Executive Assistants “located all over the U.S. and internationally.” (Id. ¶¶ 15-16.) According to plaintiff, she would “manage[ ] her team on a virtual basis from her home office [in Folsom, CA], using Skype, e-mail and collaborative software,” “with occasional trips to the company’s [office] in Roseville, CA.” (Id.)

Plaintiff alleges that in May 2015, she “began experiencing shooting pains in her left leg.” (Id. ¶ 18.) Her doctor diagnosed her with sciatica and a herniated and two bulging spine discs. (Id. ¶ 19.) After the diagnosis, plaintiff “attempted" to work a few days in Roseville,” which she alleges is a one hour commute from her home. (Id. ¶22.) Plaintiff alleges that “[a]fter the third day of commuting to Roseville,” the pain in her left leg became “excruciating.” (Id.) As a result, she “resumed working at home.” (Id. ¶ 23.)

“In March 2016, plaintiff attempted to resume work on-site in Roseville, After three days, the severe pain returned—this time in both legs.” (Id. ¶ 28.) The one-hour commute to Roseville, according to plaintiff, was interfering with her acupuncturist’s “orders [to] ... alternate[ ] sitting, standing and lying down in ... 30-minute rotation^],” and thus “exacerbating] her herniated and bulging discs” and putting her at risk for “irreparable spinal damage.” (Id. ¶ 29.)

In April 2016, plaintiff requested that defendant allow her to work exclusively from home going forward. (See id. ¶ 30.) Defendant denied her request in July 2016 and told her that it could “accommodate [her medical] restrictions in the [Roseville] office.” (Id. ¶ 34.) Plaintiff then requested that defendant transfer her to its Folsom office, which she alleges “is only fifteen minutes from her home.” (Id. ¶ 37.) Defendant denied that request as well. (Id. ¶ 38.)

On July 22, 2016, plaintiff went on paid disability leave. (Id. ¶45.) She was paid 100% of her regular salary until September 2016, at which time her pay was reduced to 70%. (Id. ¶44.) Plaintiff alleges *1091that during the time she has been on leave, she has been “ready, willing and able to work from her home.” (Id. ¶ 45.)

Plaintiff filed this action in the California Superior Court on September 21, 2016. (Notice of Removal at 1.) She asserts the following causes of action against defendant: (1) disability discrimination in violation of the ADA, 42 U.S.C. §§ 12101 et seq., and FEHA, Cal. Gov. Code § 12940; (2) failure to engage in an interactive process in violation of the ADA, 42 U.S.C. § 12112(b)(5)(A), and . FEHA, Cal. Gov. Code § 12940(n); (3) failure to provide reasonable accommodation in violation of the ADA, 42 U.S.C. § 12112(b)(5)(A), and FEHA, Cal. Gov. Code § 12940(m); (4) failure to prevent discrimination and harassment in violation of FEHA, Cal. Gov. Code § 12940(k); (5) age discrimination in violation of FEHA, Cal. Gov. Code § 12940(a); and (6) intentional infliction of emotional distress. (FAC at 10-13.)

Defendant removed plaintiffs action to this court on November 1, 2016. (Notice of Removal.) Defendant now moves to dismiss plaintiffs Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). (Def.’s Mot.)

II. Legal Standard

On a motion to dismiss for failure to state a claim under Rule 12(b)(6), the court must accept the allegations in the pleadings as true and draw all reasonable inferences in favor of the plaintiff. See Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974), overruled on other grounds by Davis v. Scherer, 468 U.S. 183, 104 S.Ct. 3012, 82 L.Ed.2d 139 (1984); Cruz v. Beto, 405 U.S. 319, 322, 92 S.Ct. 1079, 31 L.Ed.2d 263 (1972). To survive a motion to dismiss, a plaintiff must plead “only enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007).

The “plausibility’ standard, “asks for more than a sheer possibility that a defendant has acted unlawfully,”- and where a plaintiff pleads facts that are “merely consistent with a defendant’s liability,” the facts “stop[] short of the line between possibility and plausibility.” Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009) (quoting Twombly, 550 U.S. at 557, 127 S.Ct. 1955).

“While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, a plaintiffs obligation to provide the ‘grounds’ of his ‘entitle[ment] to relief requires more than labels and conclusions.... ” Twombly, 550 U.S. at 555, 127 S.Ct. 1955 (citation omitted). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice,” and “the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions.” Iqbal, 556 U.S. at 678, 129 S.Ct. 1937.

III. Discussion

A. Disability Discrimination and Reasonable Accommodation

Plaintiffs first cause of action alleges that defendant discriminated against her on account of her disability. (FAC at 10.) Her third cause of action alleges that defendant failed to provide her a reasonable accommodation. (Id. at 12.) Each claim is brought under both the ADA and FEHA.

The ADA and FEHA each provide protections to disabled employees. See 42 U.S.C. § 12112(a); Cal.' Gov’t Code § 12940. While courts in this circuit have often analyzed claims brought under the ADA and FEHA together, see, e.g., Humphrey v. Mem’l Hosps. Ass’n, 239 F.3d 1128, 1140 (9th Cir. 2001) (“We analyze [plaintiffs] state and federal disability claims together.... ”), they have also not*1092ed that “in a number of instances!],] FEHA’s anti-discrimination provisions provide even greater protection to employees than does the ADA,” Diaz v. Fed. Express Corp., 373 F.Supp.2d 1034, 1053 (CD. Cal. 2005). Because FEHA provides greater protection than the ADA in some instances, “a judgment for a defendant as to an ADA claim will not necessarily lead to a similar judgment with respect to a FEHA claim.” Cripe v. City of San Jose, 261 F.3d 877, 895 (9th Cir. 2001).

A key issue raised in plaintiffs ADA and FEHA claims is whether defendant satisfied its obligation to provide her a lawful accommodation by placing her on paid disability leave, instead of allowing her to work from her home or at its Folsom office. Because the ADA and FEHA differ with respect to this question, the court will address plaintiffs disability discrimination and reasonable accommodation claims under the two legislations separately.

1. Disability Discrimination and Reasonable Accommodation Under the ADA

“The ADA prohibits an employer from discriminating against a qualified individual with a disability ‘because of the disability.’ ” Nunes v. Wal-Mart Stores, Inc., 164 F.3d 1243, 1246 (9th Cir. 1999) (quoting 42 U.S.C. § 12112(a)). To state a prima facie claim of disability discrimination under the ADA, plaintiff must allege facts that plausibly show: “(1) [she] is a disabled person within the meaning of the [ADA]; (2) [she] is a qualified individual with a disability; and (3) [she] suffered an adverse employment action because of [her] disability.” Hutton v. Elf Atochem N. Am., Inc., 273 F.3d 884, 891 (9th Cir. 2001).

With respect to the first prong, the ADA defines a “disabled person” as an individual who has “a physical or mental impairment that substantially limits one or more of the individual’s major life activities.” Coons v. Sec’y of U.S. Dep’t of Treasury, 383 F.3d 879, 884 (9th Cir. 2004). “An impairment covered under the ADA includes any physiological disorder,” id, and “major life activities” includes “standing,” “sitting,” and “lifting,” 29 C.F.R. § 1630.2. “Substantially limited” means that a person is “significantly restricted as to condition, manner or duration under which [she] can perform [the] particular major life activity as compared to ... [an] average person in the general population.” Coons, 383 F.3d at 885. “Temporary, non-chronic impairments of short duration, with little or no long term or permanent impact, are usually not disabilities.” Wilmarth v. City of Santa Rosa, 945 F.Supp. 1271, 1276 (N.D. Cal. 1996)

Defendant’s only challenge with respect to the first prong is that plaintiff cannot base her argument for “disabled person” status on mere “recommendations” from her physician alone. (Defi’s Mot. at 15.) That argument fails because plaintiff alleges that her acupuncturist’s advice that she not sit or stand for more than thirty minutes was in fact a “strict order[ ].” (FAC ¶ 29.)

Plaintiff alleges that her sciatica and disc condition prevent her from sitting or standing for more than thirty minutes, or lifting anything “more than ten pounds.” (See FAC ¶ 29.) While she indicates that her condition would improve over time “with proper treatment and care,” (id. ¶ 36), she also alleges that the effects of the condition and her need for accommodation are “permanent,” (id. ¶¶ 32, 36). Drawing reasonable infex-ences in plaintiffs favor, the court finds that these allegations are sufficient to plausibly suggest that plaintiff is a “disabled person” within the meaning of the ADA.

With respect to the second prong, the ADA defines “qualified individuals” as *1093those “with a disability who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds.” 42 U.S.C. § 12111(8). Plaintiff, who has been employed in her current position since March 2015, (FAC ¶ 15), alleges that since being diagnosed with back problems, she has been able to work from home without “miss[ing] a beat,” and that she is “ready, willing and able” to continue working if allowed to work from home or at defendant’s Folsom office, (FAC ¶¶ 27, 30, 37). Defendant did not dispute the “qualified” prong in its Motion. Thus, the court finds that plaintiff has plausibly alleged that she is a “qualified individual” under the ADA.

With respect to the third prong, defendant notes that the only adverse employment action plaintiff claims she was subject to was defendant’s decision to deny her request to work from home or at Folsom. (Def.’s Mot. at 11.) Defendant argues that its decision to deny her request does not constitute an adverse employment action because it offered her two “reasonable” alternatives to what she requested: (1) working at defendant’s Roseville office with leave to lie down in the conference room as needed, and (2) taking a paid leave of absence to recover from her back condition. (See id.; FAC ¶¶ 42, 45.)

Defendant correctly notes that under the ADA, “[a]n employer is not obligated to provide an employee the accommodation [she] requests or prefers, the employer need only provide some reasonable accommodation.” Zivkovic v. S. California Edison Co., 302 F.3d 1080, 1089 (9th Cir. 2002) (citing E.E.O.C. v. Yellow Freight Sys. Inc., 253 F.3d 943, 951 (7th Cir. 2001)). Defendant’s denial of plaintiffs requested accommodations, therefore, is not an “adverse employment action” within the meaning of the ADA if either of the alternatives it offered her is a “reasonable accommodation.”1

The ADA does not define the term “reasonable accommodation” with much precision. See 42 U.S.C. § 12111(9). The Equal Employment Opportunity Commission, however, has promulgated regulations that define “reasonable accommodation” to include “[m]odifications or adjustments to the work environment, or to the manner or circumstances under which the position held or desired is customarily performed, that enable an individual with a disability who is qualified to perform the essential functions of that position.” 29 C.F.R. § 1630.2(o)(l)(ii). The Ninth Circuit has similarly held that a “reasonable accommodation must be effective, in enabling the employee to perform the duties of [her] position.” Humphrey, 239 F.3d at 1137.

The first alternative offered by defendant—working at its Roseville office with permission to lie down in the conference room as needed—does not “enabl[e plaintiff] to perform the duties of [her] position” because it does not address plaintiffs alleged inability to commute to Roseville. (See FAC ¶¶ 29, 36 (noting that hour-long commute to Roseville was “ex-acerbatefing]” back condition).) Defendant argues that the ADA does not require employers to accommodate employees’ commutes because commutes are not considered part of their job duties. (See Def.’s Mot. at 10-11.) The Ninth Circuit has held, however, that an employer has an obligation “to accommodate an employ*1094ee’s limitations in getting to and from work” under the ADA.2 Livingston v. Fred Meyer Stores, Inc., 388 Fed.Appx. 738, 740 (9th Cir. 2010); see also Humphrey, 239 F.3d at 1135 (holding that employer had obligation to accommodate employee’s inability to get to work on time or at all due to obsessive compulsive disorder). In light of this holding and in light of plaintiffs alleged inability to commute to the Roseville office, defendant’s offer to have plaintiff continue working at the Roseville office does not constitute a reasonable accommodation. See Humphrey, 239 F.3d at 1137.

Defendant’s second alternative, however, has been recognized by the Ninth Circuit to be “reasonable.” In Humphrey, the Ninth Circuit held that a “leave of absence for medical treatment may be a reasonable accommodation under the ADA” where it would “permit [an employee], upon [her] return, to perform the essential functions of [her] job.” Humphrey, 239 F.3d at 1135-36. Leave need not be paid to be reasonable under the ADA. Nunes, 164 F.3d at 1247 (“Unpaid medical leave may be a reasonable accommodation under the ADA.”); Dark v. Curry Cty., 451 F.3d 1078, 1090 (9th Cir. 2006) (same).

Plaintiff alleges that she “has been on full disability [leave] as of July 22, 2016” and paid at least'70% of her monthly salary since then. (FAC ¶¶ 44-45.) She indicates that her back problems, while “permanent” and requiring “ongoing care,” (id. ¶¶ 32, 36), would improve over time as she remained on leave, (id. ¶ 36 (noting that plaintiff was making “progress” when not being forced to commute to Roseville)). In discussing the negative effects that plaintiffs Roseville commute was having on her back, plaintiffs acupuncturist ' recommended that plaintiff “work from home for a period of no less than 3 months” so that she could recover, (id. ¶ 36), which suggests that after that period, plaintiff would be able to resume working at Roseville. Because these allegations suggest that a disability leave would allow plaintiff to gain at least a partial recovery and, after a period of a few months, resume working at Roseville, the court finds that defendant’s offer of a paid medical leave constitutes a “reasonable accommodation” within the meaning of the ADA. See Humphrey, 239 F.3d at 1135-36; Nunes, 164 F.3d at 1247.

Because plaintiff’s Complaint indicates that defendant offered her two accommodations—one of which was “reasonable”—she has failed to state a claim that defendant’s denial of her preferred accommodations constitutes an “adverse employment action” within the meaning of the ADA. See Zivkovic, 302 F.3d at 1089.

To the extent plaintiff might argue that her disability leave, which involves a 30% pay cut, is nevertheless itself an “adverse employment action,” district courts in this circuit and several courts outside of this circuit have held that “a reasonable accommodation cannot be a materially adverse employment action.” West v. New Mexico *1095Taxation & Revenue Dep’t, 757 F.Supp.2d 1065, 1121 (D. N.M. 2010); see also Bultemeyer v. Fort Wayne Cmty. Sch., 100 F.3d 1281, 1283 (7th Cir. 1996) (“A reasonable accommodation ... should not be construed as an adverse employment action.”); Selenke v. Med. Imaging of Colorado, 248 F.3d 1249, 1265 (10th Cir. 2001) (where plaintiff alleges ADA discrimination and reasonable accommodation claims, the analyses for the two merge); Capote v. CSK Auto, Inc., No. 12-CV-02958 JST, 2014 WL 1614340, at *7 (N.D. Cal. Apr. 22, 2014) (same); Lafever v. Acosta, Inc., No. C10-01782 BZ, 2011 WL 1935888, at *4-5 (N.D. Cal. May 20, 2011) (same).

While the Ninth Circuit does not appear to have addressed the question, the court finds the reasoning of the above-cited cases to be instructive. Defendant already went beyond what is required under the ADA when it placed plaintiff on paid disability leave. See Nunes, 164 F.3d at 1247; Dark, 451 F.3d at 1090. Defendant’s provision of a “reasonable accommodation” in this case, while not the accommodation plaintiff wanted, should not be construed to be an “adverse employment action.”

Because plaintiff has failed to allege that defendant carried out an “adverse employment action” against her, she has failed to state a plausible claim of disability discrimination under the ADA. Some courts have held that plaintiffs may also establish disability discrimination “by presenting evidence of disparate treatment.” See, e.g., Hoffman v. Caterpillar, Inc., 256 F.3d 568, 572 (7th Cir. 2001). Plaintiff appears to raise a disparate impact argument in her Opposition, noting that “many other [Hewlett-Packard] employees ,.. are permitted to work from home.” (Pl.’s Opp’n at 5 (Docket No. 7).) Defendant correctly notes, however, that plaintiff did not allege in her Complaint that she was “treated differently than other similarly situated individuals.” (Def.’s Mot. at 17.)

Having determined that defendant’s offer of paid disability leave is a “reasonable accommodation” under the ADA, the court also finds that plaintiff has failed to state a plausible claim of failure to provide' reasonable accommodation under the ADA. Accordingly, the court will dismiss her first and third causes of action, to the extent they are brought under the ADA.

2. Disability Discrimination and Reasonable Accommodation Under FEHA

Plaintiff cites FEHA as a second statutory basis for her disability' discrimination and failure to provide reasonable accommodation claims. (See FAC at 10-11.) FEHA, similar to the ADA, prohibits employers from discriminating against employees “because of ... [a] physical disability [or] mental disability.” Cal. Gov. Code § 12940(a). “Because the FEHA provisions relating to disability discrimination are based on the ADA, decisions interpreting federal anti-discrimination laws are relevant in interpreting the FEHA’s similar provisions.” Humphrey, 239 F.3d at 1133 n.6. Indeed, courts have often “analyze[d] ... [FEHA] and federal disability claims together, relying on federal authority in the absence of contrary or differing state law.” Id.

FEHA, like the ADA, requires a plaintiff to plausibly allege the following in order to state a prima facie claim of disability discrimination: “(1) plaintiff suffers from a disability; (2) plaintiff is a qualified individual; and (3) plaintiff was subjected to an adverse employment action because of the disability.” Jensen v. Wells Fargo Bank, 85 Cal.App.4th 245, 254, 102 Cal.Rptr.2d 55 (2d Dist. 2000). The court is satisfied that its findings with respect to prongs (1) and (2) in the above ADA analysis resolve the same questions under FEHA. See Diaz, 373 F.Supp.2d at 1054 *1096(noting that “FEHA defines ‘disability’ more broadly than does the ADA”); Bates v. United Parcel Serv., Inc., 511 F.3d 974, 999 (9th Cir. 2007) (applying “qualified individual” analysis under ADA to same inquiry under FEHA). The court is also satisfied that its findings with respect to the reasonableness of the two accommodations defendant offered plaintiff in the above ADA analysis resolve the same questions under FEHA. See Nadaf-Rahrov v. Neiman Marcus Grp., Inc., 166 Cal.App.4th 952, 973, 83 Cal.Rptr.3d 190 (1st Dist. 2008) (noting that FEHA’s definition of “reasonable accommodation” “is virtually identical to the ADA’s statutory definition of the term”); Humphrey, 239 F.3d at 1133 (applying “reasonable accommodation” analysis under ADA to same inquiry under FEHA).

Unlike the ADA, however, FEHA does not provide employers complete autonomy in choosing which reasonable accommodation, when there are more than one, to offer an employee. Section 11068(c) of title 2 of the California Code of Regulations (“section 11068(c)”), which implements FEHA’s “reasonable accommodation” provision, states: “When an employee can work with a reasonable accommodation other than a leave of absence, an employer may not require that the employee take a leave of absence.” Cal. Code Regs. tit. 2, § 11068(c); see also Wallace v. Cty. of Stanislaus, 245 Cal.App.4th 109, 134, 199 Cal.Rptr.3d 462 (5th Dist. 2016) (applying section 11068(c) in FEHA case). Pursuant to this regulation, an employer’s decision to place an employee on leave when she is able to work with another reasonable accommodation “cannot be described as a lawful accommodation of a physical disability.” Wallace, 245 Cal.App.4th at 134, 199 Cal.Rptr.3d 462.

Here, defendant placed3 plaintiff on medical leave despite her asking to be allowed to work from home or at defendant’s Folsom office. (FAC ¶¶30, 37, 45.) If either accommodation requested by plaintiff is a “reasonable” within the meaning of FEHA, defendant will have failed to comply with section 11068(c).

Under FEHA, a “reasonable accommodation is a modification or adjustment to the work environment that enables the employee to perform the essential functions of the job ... she holds.” Canupp v. Children’s Receiving Home of Sacramento, 181 F.Supp.3d 767, 776 (E.D. Cal. 2016).

Based on the facts alleged in plaintiffs Complaint, either accommodation proposed by plaintiff—work from home or work at Folsom—appears to be “reasonable”: plaintiff alleges that when at home, she is able to work on her bed, “propped up with pillows, and conduct business with a laptop” without “missfing] a beat,” and if allowed to work at Folsom, she would be able to perform her job as usual so long as she could lie down in the conference room when she needs to. (See FAC ¶¶27, 37, 42.) Neither accommodation would appear to pose an undue burden to defendant, as plaintiffs position appears to involve work that is primarily done on a “virtual basis,” via “Skype, e-mail and collaborative software,” (id. ¶ 16; see also id. ¶ 25 (noting that plaintiffs manager “works from his home[,] near Chicago”)), and thus not dependent on where she works. Moreover, defendant has allegedly allowed Plaintiff to work from home on and off since 2011. (Id. ¶ 14).

*1097The court concludes that plaintiff has plausibly alleged that either of the accommodations she requested would constitute a “reasonable accommodation” under FEHA. Because defendant denied her both accommodations and left her with only one other “reasonable” alternative— going on medical leave—it has, under the facts alleged, failed to comply with section 11068(c). This failure is sufficient for the court to deny defendant’s Motion to dismiss plaintiffs third cause of action to the extent it is brought under FEHA.4 It is also sufficient for the court to deny defendant’s Motion to dismiss plaintiffs first cause of action to the extent it is brought under FEHA, as failure to comply with section 11068(c) constitutes “adverse employment action” when it leads to loss of income. See Wallace, 245 Cal.App.4th at 134-37, 199 Cal.Rptr.3d 462 (granting judgment for plaintiff on FEHA disability discrimination claim where adverse action alleged was placement on unpaid disability leave in violation of section 11068(c)).

B. Failure to Engage in an Interactive Process

Plaintiffs second cause of action alleges that defendant “failed to engage [in] a timely, good faith, interactive process with Plaintiff to determine effective reasonable accommodations for Plaintiffs ... disabilities.” (FAC ¶ 54.) The claim is brought under both the ADA and FEHA.

“Once an employer becomes aware of the need for accommodation, that employer has a mandatory obligation under the ADA [and FEHA] to engage in an interactive process with the employee to identify and implement appropriate reasonable accommodations.” Humphrey, 239 F.3d at 1137. “The interactive process requires communication and good-faith exploration of possible accommodations between employers and individual employees, and neither side can delay or obstruct the process.” Id. “Employers, who fail to engage in the interactive process in good faith, face liability for the remedies imposed by the statute if a reasonable accommodation would have been possible.” Id. at 1137-38.

Plaintiffs “interactive process” claim fails under the ADA because she has not alleged that defendant failed to provide her a reasonable accommodation under the ADA. See Rehling v. City of Chicago, 207 F.3d 1009, 1016 (7th Cir. 2000) (holding that there is no stand-alone claim for “failure to engage in an interactive process” under the ADA; plaintiff must also allege that defendant failed to provide a reasonable accommodation); Wilson v. Dollar Gen. Corp., 717 F.3d 337, 347 (4th Cir. 2013) (same); Lowe v. Indep. Sch. Dist. No. 1 of Logan Cty., 363 Fed.Appx. 548, 552 (10th Cir. 2010) (same).

To the extent she brings the same claim under FEHA, however, her claim is not dismissible on the same grounds because she has plausibly alleged that defendant failed to provide her a lawful accom*1098modation under FEHA. See Cal. Code Regs. tit. 2, § 11068(c).

Defendant nevertheless contends that it did not fail to satisfy its obligation to interact with plaintiff under FEHA because it responded to her requests to work from home or at Folsom with emails that stated along the lines of the following: “We have reviewed [your] work restrictions and have concluded that we can accommodate these restrictions in the [Roseville] office.” (Def.’s Mot. at 12 (quoting FAC ¶ 34); see also FAC ¶ 40 (“The note from your doctor does not identify any work restrictions because travel is not an essential function of your role and as a result, is not something the Company is required to accommodate.”).) Plaintiff contends that such responses are without “a modicum of explanation or interactive discussion,” and thus lacking in “good faith” and deficient under FEHA. (PL’s Opp’n at 8, 14 (Docket No. 7).)

It is for the trier of fact to determine whether defendant’s responses to plaintiff were sufficiently “interactive” under FEHA. The court will accordingly decline to dismiss plaintiffs second claim to the extent it is brought under FEHA. See Evergreen Partnering Grp., Inc. v. Pactiv Corp., 720 F.3d 33, 45 (1st Cir. 2013) (“It is not for the court to decide, at the pleading stage ... the meaning of documents that are subject to divergent reasonable intei--pretations.” (quoting Monsanto Co. v. Spray-Rite Serv. Corp., 465 U.S. 752, 766 n.11, 104 S.Ct. 1464, 79 L.Ed.2d 775 (1984))).

C. Failure to Prevent Discrimination and Harassment

Plaintiffs fourth cause of action alleges that defendant “failed to take all reasonable steps to prevent ... harassment, discrimination or retaliation” in violation of FEHA. (FAC at 12.) The statute she cites in support of that claim, section 12940(k) ■ of the California Government Code, provides that “[i]t is an unlawful employment practice ... [f]or an employer ... to fail to take all reasonable steps necessary ■ to prevent discrimination and harassment from occurring.” Cal. Gov’t Code § 12940(k). “Retaliation is included within the meaning of ‘discrimination’ for purposes of § 12940(k).” Rubadeau v. M.A. Mortenson Co., No. 1:13-CV-339 AWI JLT, 2013 WL 3356883, at *13 (E.D. Cal. July 3, 2013).

“A plaintiff seeking to recover on a failure to prevent discrimination claim under FEHA must show that (1) [she] was subjected to discrimination; (2) defendant failed to take all reasonable steps to prevent discrimination; and (3) this failure caused plaintiff to suffer injury, damage, loss or harm.” Achal v. Gate Gourmet, Inc., 114 F.Supp.3d 781, 804 (N.D. Cal. 2015), Courts have interpreted “a failure to prevent discrimination claim [to be] essentially derivative of a [FEHA] discrimination claim.” Id. (citing Trujillo v. N. Cty. Transit Dist., 63 Cal.App.4th 280, 289, 73 Cal.Rptr.2d 596 (4th Dist. 1998)); see also Rux v. Starbucks Corp., No. 2:05-CV-02299 MCE EFB, 2007 WL 1470134, at *9 (E.D. Cal. May 18, 2007) (denying defendant summary judgment on failure to prevent discrimination claim “[g]iven that” plaintiffs FEHA discrimination claim survived summary judgment); Juell v. Forest Pharm., Inc., 456 F.Supp.2d 1141, 1160 (E.D. Cal. 2006) (Damrell, J.) (same).

As discussed above, plaintiff has sufficiently alleged that defendant discriminated against her in violation of FEHA by placing her on disability leave instead of granting her a reasonable accommodation that would allow her to work. This alleged violation caused plaintiff economic loss by requiring her to take a 30% pay cut while on leave. Because plaintiffs FEHA disability discrimination claim survives defen*1099dant’s motion to dismiss, her failure to prevent discrimination claim survives the motion as well. See Achal, 114 F.Supp.3d at 804; Rux, 2007 WL 1470134, at *9; Juell, 456 F.Supp.2d at 1160.

D. Age Discrimination

Plaintiffs fifth cause of action alleges that defendant discriminated against her based on her age in violation of FEHA, Cal. Gov. Code § 12940(a). (FAC at 13.) “In order to make out a prima facie case of age discrimination under FEHA, a plaintiff must present evidence that the plaintiff (1) is over the age of 40; (2) suffered an adverse employment action; (3) was performing satisfactorily at the time of the adverse action; and (4) suffered the adverse action under circumstances that give rise to an inference of unlawful discrimination, i.e., evidence that the plaintiff was replaced by someone significantly younger than the plaintiff.” Sandell v. Taylor-Listug, Inc., 188 Cal.App.4th 297, 321, 115 Cal.Rptr.3d 453 (4th Dist. 2010).

Plaintiff, who is fifty-four, (see FAC ¶ 12), has not alleged facts giving rise to a plausible inference of age discrimination. Even assuming that plaintiffs being placed on disability leave with 70% pay qualifies as an “adverse employment action” for purposes of a FEHA age discrimination claim, there are no facts indicating that defendant’s decision to place her on leave was because of her age. Plaintiff does not allege that she has been replaced by a younger employee, that she overheard any negative comments about her age, or that age was ever a point of discussion at any time during her communications with defendant about an accommodation for her back problems. Plaintiffs counsel stated at oral argument that plaintiffs boss, who she alleges is allowed to work from home, is younger than plaintiff. That fact, however, is not alleged in the Complaint.

Plaintiff does allege that defendant’s CEO, Meg Whitman, issued a company-wide memo stating that the company should “amp[ ] up ... college hiring” and “return to a labor pyramid that really looks like a triangle where you have a lot of early career people” before she was placed on leave. (Id. ¶ 71.) At worst, the memo suggests that defendant may seek to hire more young applicants at the expense of older ones. Plaintiff is not a job applicant, and there is no suggestion in the memo, as alleged in plaintiffs Complaint, that defendant was seeking to get rid of current employees who are not young.

Because plaintiff has not alleged facts that plausibly suggest she was placed on disability leave because of age discrimination, she has failed to state a plausible claim of age discrimination under FEHA.

E. Intentional Infliction of Emotional Distress

Plaintiffs sixth and final cause of action alleges that defendant intentionally inflicted emotional distress upon her during the course of its interactions with her concerning her medical condition. (Id. at 13.) Under California law, “[a] cause of action for intentional infliction of emotional distress exists when there is (1) extreme and outrageous conduct by the defendant with the intention of causing, or reckless disregard of the probability of causing, emotional distress; (2) the plaintiffs suffering severe or extreme emotional distress; and (3) actual and proximate causation of the emotional distress by the defendant’s outrageous conduct.” Hughes v. Pair, 46 Cal.4th 1035, 1050, 95 Cal.Rptr.3d 636, 209 P.3d 963 (2009).

Plaintiff states, in her Opposition, that an email from one of her supervisors rejecting her request to work at Folsom was *1100particularly “brusque,” (Pl.’s Opp’n at 7), and that she was “shocked by [its] threatening tone,” (FAC ¶ 41). The email states, in relevant part:

The note from your doctor does not identify any work restrictions because travel is not an essential function of your role and as a result, is not something the Company is required to accommodate . Please be advised that you are expected to return to the office immediately. Failure to do so may result in disciplinary action.

(Id. ¶ 40.) This email, according to plaintiff, required her “to choose between 1) ignoring her treating doctor’s strict instructions and risking permanent damage to her back and spine by commuting to Roseville, or 2) incur[ing] ‘disciplinary action’ that could result in her getting fired from her job.” (Id. ¶ 41.) Plaintiff alleges that the email, “the refusal of [defendant] to engage in good faith dialogue,” defendant’s decision to place her on leave and cut her pay, and “uncertainty about her job” resulting from defendant’s conduct were all “substantial factor[s] in causing [her] severe emotional distress.” (Id. ¶ 77; Pl.’s Opp’n at 17.)

Again, it will be for the trier of fact to determine whether defendant’s treatment of plaintiff rose to the level of “extreme and outrageous” conduct. The court will accordingly decline to dismiss plaintiffs sixth claim at this time. See Evergreen, 720 F.3d at 45.

IT IS THEREFORE ORDERED that defendant’s Motion to Dismiss plaintiffs Complaint be, and the same hereby is, GRANTED IN PART and DENIED IN PART, as follows:

The following causes of action alleged by plaintiff are DISMISSED WITHOUT PREJUDICE: (1) disability discrimination in violation of the ADA, 42 U.S.C. §§ 12101 et seq.; (2) failure to engage in an interactive process in violation of the ADA, 42 U.S.C. § 12112(b)(5)(A); (3) failure to provide reasonable accommodation in violation of the ADA, 42 U.S.C. § 12112(b)(5)(A); and (4) age discrimination in violation of FEHA, Cal. Gov. Code § 12940(a).

Defendant’s Motion to dismiss the following causes of action is DENIED: (1) disability discrimination in violation of FEHA, Cal. Gov. Code § 12940; (2) failure to engage in an interactive process in violation of FEHA, Cal. Gov. Code § 12940(n); (3) failure to provide reasonable accommodation in violation of FEHA, Cal. Gov. Code § 12940(m); (4) failure to prevent discrimination and harassment in violation of FEHA, Cal. Gov. Code § 12940(k); and (5) intentional infliction of emotional distress.

Plaintiff has twenty days from the date this Order is signed to file an amended complaint, if she can do so consistent with this Order.

ORDER AND JUDGMENT*

WADE BRORBY, Senior Circuit Judge.

I. INTRODUCTION

Plaintiff Terrianne Lowe filed suit against her former employer, Independent School District No. 1 of Logan County, Oklahoma (“the District”), alleging that it failed to reasonably accommodate her post-polio condition, in violation of the Americans with Disabilities Act, 42 U.S.C. §§ 12101-12213 (“ADA”).1 The district *550court granted summary judgment in favor of the District, and Ms. Lowe appeals. This court has jurisdiction under 28 U.S.C. § 1291. We reverse.

II. BACKGROUND

Ms. Lowe had polio as a child and, as a result, has worn leg braces for most of her life and has had several knee replacements. She has been advised by her physician that she will have to be in a wheelchair at some point and that walking and standing for long periods will accelerate the deterioration of her leg muscles.

Ms. Lowe was certified to teach a variety of science courses for grades seven through twelve and had experience as a classroom teacher. Since the 1988-89 school year, Ms. Lowe had been employed by the District as a high school counselor. Because a counselor is a “teacher” under state law, Ms. Lowe was employed under a standard teacher’s contract with counseling duties added pursuant to a separate “extra duty” contract. Ms. Lowe’s counselor position was sedentary and required no accommodation for her disability.

In the fall of 2005, as a result of complaints from parents and-staff about Ms. Lowe’s performance as a counselor at Guthrie High School, Terry Simpson, the District Superintendent, determined that Ms. Lowe’s extra-duty contract as a counselor would not be renewed for the 2006-07 school year and that Ms. Lowe would, instead, be reassigned as a classroom teacher. Ms. Lowe was informed of this decision in March 2006 by Jan Chadwick, the principal of Guthrie High School. Ms. Lowe understood that her base salary as a teacher would not be affected by the reassignment but that she would lose the approximately $5700.00 in additional income she earned under the extra-duty contract as a counselor.

In May 2006, the temporary teaching contract of Mary Rhinehart expired and was not renewed by the District. Ms. Rhinehart had taught physical science at the high school in one of the smallest and most crowded classrooms that, as then configured, would not accommodate a walker or a wheelchair in the aisles between the lab tables. The physical science class, and all other science classes at the high school, were laboratory classes. The physical science class was the only opening for a science teacher at the high school for the 2006-07 school year.

Ms. Lowe, for reasons explained below, eventually came to understand that she would be reassigned to teach physical science in Ms. Rhinehart’s small, crowded classroom. In order to plan for that contingency, Ms. Lowe met with Lori Allen, head of the Guthrie High School science department, to share with Ms. Allen her concerns about the reassignment in light of her disability. Ms. Allen did not question the need for such a meeting because she had learned from a school board member that Ms. Rhinehart was not retained in order to open up a teaching slot for Ms. Lowe in Ms. Rhinehart’s former classroom. Together, Ms. Lowe and Ms. Allen compiled a list of accommodations they believed necessary in order for Ms. Lowe to teach physical science in the laboratory science classroom formerly used by Ms. Rhinehart. Before the end of the 2005-06 school year, Ms. Lowe presented the list of accommodations and a letter from her physician to principal Chadwick, her immediate supervisor, to Don Bowman, the District’s human resources director, and to Superintendent Simpson. Shortly thereafter, Ms. Chadwick was told by Don Bowman that no accommodation would be made and that Ms. Lowe should be as*551signed to a non-laboratory science class.2 Ms. Chadwick passed this information along to Ms. Lowe.

By August 2006, Ms. Lowe had heard nothing from the District regarding her request for accommodation, other than the message from Mr. Bowman, relayed by Ms. Chadwick, that no accommodation would be made. Two weeks before school was to begin, Mary Pratz, an advocacy specialist and representative with the Oklahoma Education Association, set up a meeting attended by Superintendent Simpson, Ms. Lowe, Michelle Redus, president of the Guthrie Association of Classroom Teachers, and herself. The purpose of the meeting was to discuss the accommodations Ms. Lowe believed she would need in order to teach physical science in Ms. Rhinehart’s former classroom. It is clear that, at the time of the August meeting, Ms. Lowe believed that such would be her assignment come the start of the new school year.

As we will discuss below, there is significant disagreement among those present at the August meeting as to what actually was said. One thing is clear: Ms. Lowe was dissatisfied with the result of the meeting and submitted her resignation two days later. She then filed charges with the EEOC and later retired from the District’s employ.

Ms. Lowe eventually sued the District claiming violation of the ADA with regard to the reassignment, and failure to accommodate regarding the new teaching position. The district court granted summary judgment to the District on both claims. The district court determined that Ms. Lowe failed to show pretext in the District’s proffered reason for her reassignment, a conclusion unchallenged on appeal. With regard to the failure-to-accommodate claim, the district court held that the claim failed because it was based only on Ms. Lowe’s speculation as to where she would be assigned when school finally began. The court further concluded that “[because plaintiff resigned before classes started, she cannot show that the defendant failed to accommodate her disability.” ApltApp. at 491. On appeal, Ms. Lowe argues that the district court erred in granting summary judgment to the District on her failure-to-accommodate claim, and that she was constructively discharged as a result of the District’s violation of the ADA.

III. DISCUSSION

“We review the district court’s grant of summary judgment de novo.” Smith v. Midland Brake, Inc., 180 F.3d 1154, 1159 (10th Cir.1999) (en banc). Summary judgment should be granted “if the pleadings, the discovery and disclosure materials on file, and any affidavits show that there is no genuine issue as to any material fact and that the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(c). We review the evidence in the light most favorable to Ms. Lowe as the non-movant. See Midland Brake, 180 F.3d at 1160.

In order “[t]o establish her claim under the ADA, [Ms. Lowe] must show: (1) she is a disabled person within the meaning of the ADA; (2) she is able to perform the essential job functions with or without reasonable accommodation; and (3) [defendant] discriminated against her because of her disability.” Albert v. Smith’s Food & Drug Ctrs., Inc., 356 F.3d 1242, 1249 (10th Cir.2004).

There is no dispute as to the first two requirements. The issue is whether the *552District discriminated against Ms. Lowe because of her disability. “The ADA defines the term ‘discriminate’ to include ‘not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless such covered entity can demonstrate that the accommodation would impose an undue hardship on the operation of the business of such covered entity .... ’ ” Midland Brake, 180 F.3d at 1161 (quoting 42 U.S.C. § 12112(b)(5)(A) (emphasis added)).

In Midland Brake “[w]e noted that the employer and employee must engage in an interactive process to determine what [accommodation] would be appropriate.” Albert, 356 F.3d at 1252 (citing Midland Brake, 180 F.3d at 1171). “The obligation to engage in an interactive process is inherent in the statutory obligation to offer a reasonable accommodation to an otherwise qualified disabled employee.” Midland Brake, 180 F.3d at 1172.

Once the District was in receipt of Ms. Lowe’s list of possible accommodations and the letter from her doctor regarding the reassignment, it was required to proceed “in a reasonably interactive manner” with Ms. Lowe to determine what reasonable accommodation might be made to the physical-science-teaching job in order for her to perform it successfully. See id. “The interactive process is typically an essential component of the process by which a reasonable accommodation can be determined,” and “includes good-faith communications between the employer and employee.” Id. “Neither party may create or destroy liability by causing a breakdown of the interactive process.” Albert, 356 F.3d at 1253. A question of fact as to whether an employer has failed to interact in good faith and thus failed to reasonably accommodate will preclude summary judgment for the employer. Id.

Defendant argues that “the interactive process is merely a means to achieve a reasonable accommodation rather than an independent substantive requirement.” Aplee. Br. at 10. While that is true, see Rehling v. City of Chicago, 207 F.3d 1009, 1015-16 (7th Cir.2000) (recognizing that the interactive process the ADA contemplates is not an end in itself), a plaintiff can prevail if she can “show that the result of the inadequate interactive process was the failure of the [employer] to fulfill its role in determining what specific actions must be taken ... in order to provide the qualified individual a reasonable accommodation,” id. at 1016 (quotation omitted). In other words, a plaintiff must show “that the employer’s failure to engage in an interactive process resulted in a failure to identify an appropriate accommodation for the qualified individual.” Id.

The first step in analyzing Ms. Lowe’s failure-to-accommodate claim is to determine whether her ultimate resignation was, as the district court concluded, based merely on her speculation as to where she would be reassigned. Contrary to the district court, we think that, given the information available to Ms. Lowe, she could have reasonably concluded that she would be assigned to teach a physical science class in a small and crowded classroom.

During litigation the District has maintained that, at the time she resigned, the location of Ms. Lowe’s new assignment was still undecided. That assertion, however, is contradicted by the District’s response to the EEOC inquiry where it stated that “Lowe was advised that for the 2006-2007 school year she would no longer have an extra duty assignment but would be assigned to teach a science class at Guthrie High School.” Aplt.App. at 426. *553Further, Ms. Lowe testified that she was told by Principal Chadwick and by Lori Allen, the head of the Guthrie High science department, that she would be teaching physical science in Ms. Rhinehart’s former classroom. Ms. Chadwick testified that she was of the opinion that Ms. Rhine-hart was not retained because the District needed the teaching slot for Ms. Lowe, and Michelle Redus, the head of the Guthrie Association of Classroom Teachers, learned from the head of the science department at the high school that Ms. Lowe would be teaching Ms. Rhinehart’s physical science class. The science-department head had been told by Sheryl Pierson, a School Board member, that Ms. Rhinehart was not retained because the Board was going to put Ms. Lowe in her teaching slot and in her classroom. Even Superintendent Simpson testified that he understood why people assumed that Ms. Lowe would be teaching a lab science class and went as far as testifying that he never told Ms. Lowe that she would not be assigned to Ms. Rhinehart’s old classroom.

Given all the evidence available to Ms. Lowe, much of it coming from defendant’s agents, we think the district court erred in concluding that Ms. Lowe’s view of the situation was based merely on her personal speculation. The fact that, even after the August meeting, Superintendent Simpson never informed Ms. Lowe that she would not have to teach in Ms. Rhine-hart’s classroom justified Ms. Lowe in her belief that she would not be able to resume duties as a classroom science teacher at Guthrie High School. Further, the District’s late-advanced theory that it could have placed Ms. Lowe in a junior high science class was never conveyed to her.

We turn now to the facts relative to the interactive process. See Albeit, 356 F.3d at 1253 (noting that the required case-by-case determination “relies on an examination of the factual background of the interactive process”). Early on, as mentioned above, Ms. Lowe learned from Principal Chadwick that no accommodation would be made. Ms. Chadwick had been told this by the District’s human resources director, Don Bowman, shortly after the District received the letter from Ms. Lowe’s doctor outlining necessary accommodations. After this indirect contact by Mr. Bowman, the District failed for at least four months to respond directly to Ms. Lowe’s suggestions for accommodation and only did so when prodded to act by Mary Pratz, an official from the Oklahoma Education Association.

When a meeting was finally convened at Ms. Pratz’s behest, even Superintendent Simpson admitted that he did not prepare for it, had not reviewed Ms. Lowe’s list of suggested accommodations, and did not know coming into the meeting that all science classes at the high school were lab classes. There is no dispute that Ms. Re-dus stated that the master schedule for the upcoming year at the high school indicated that Ms. Lowe would be teaching physical science, although there is also evidence that master schedules are sometimes changed at the last minute.

The pivotal issue is whether Ms. Lowe was told, at any time, that she would either be accommodated to teach the physical science class or that she would not have to teach a lab science class at all. The evidence on this point is contradictory. Ms. Lowe testified that Principal Chadwick told her early on that she would not be accommodated. Accounts of the August meeting, however, reveal a factual dispute on this point.

According to Ms. Lowe, Superintendent Simpson told her at the meeting that she would be teaching physical science without accommodation other than the assignment of a student to help her when she had to *554supervise a lab class. The consensus among those attending the meeting, other than Superintendent Simpson, was that no accommodation would be made. Mary Pratz, the. Oklahoma Education Association representative, thought Mr. Simpson had indicated that Ms. Lowe would not be teaching a lab science class so very little accommodation would be necessary.

Superintendent Simpson’s testimony, although more equivocal, contradicts Ms. Lowe’s version of events. He stated that at the August meeting, “I believe I indicated that there was a possibility she would not be in a lab science.” ApltApp. at 132. Mr. Simpson testified he explained at the meeting that, should Ms. Lowe need assistance, an aide would be provided if necessary, but that the aide would not be a student because district policy did not allow student aides to assist with instruction. Mr. Simpson testified that, at the time of the meeting, he had not decided where Ms. Lowe would be assigned, although that contradicts the District’s earlier representation to the EEOC and the testimony of a school board member that Mr. Simpson had told the Board he was reassigning Ms. Lowe to a science classroom. At the time of the August meeting, Mr. Simpson knew that teachers at the junior high level could be assigned to the high school and that Ms. Lowe could then be assigned to a non-lab science class in a junior high, but he did not tell Ms. Lowe that. He testified that he did tell Ms. Lowe that they would make whatever accommodation was necessary and reasonable.

Mr. Simpson also testified, however, that he did not respond to concerns that Ms. Lowe would be asked to teach in the Rhinehart classroom, nor did he promise to follow up on the issue. He did not tell Ms. Lowe she would not have to teach in Ms. Rhinehart’s classroom. This evidence raises a genuine issue of material fact as to whether the District complied with its obligation to reasonably accommodate Ms. Lowe, making summary judgment for the District on that issue inappropriate. .

In addition to concluding that Ms. Lowe’s failure-to-accommodate claim was too speculative, the district court held that “[bjecause plaintiff resigned before classes started, she cannot show that the defendant failed to accommodate her disability.” ApltApp. at 491. We think this is wrong for two reasons.

First, Ms. Lowe’s resignation did not preclude her failure-to-accommodate claim. In Albert, 356 F.3d 1242, the plaintiffs severe asthma prevented her from continuing her job as a cashier. She applied unsuccessfully for other jobs with the defendant and worked for three weeks in customer service. The defendant then told her there were no more hours for her in customer service, but she could have her old cashier job back if her physician would approve. When he would not, the plaintiff stopped working and filed for unemployment. The fact that plaintiff had stopped working for the defendant did not preclude her from pursuing her failure-to-accommodate claim. Indeed, this court held that because the material facts about the interactive process were in dispute, it was error to grant summary judgment to the defendant. Id. at 1253.

To the extent the District implies that, had Ms. Lowe not resigned, it would have continued to work with her toward a reasonable accommodation, we note that the existence of a dispute concerning the status of the interactive process raises a genuine issue of material fact as to whether the District failed in its duty to reasonably accommodate Ms. Lowe. See id.

Second, Ms. Lowe has raised a genuine issue of material fact on her con*555structive discharge claim.3 “Constructive discharge occurs when an employer unlawfully creates working conditions so intolerable that a reasonable person in the employee’s position would feel forced to resign.” Strickland v. United Parcel Serv., Inc., 555 F.3d 1224, 1228 (10th Cir. 2009) (quotation omitted). “The standard is objective: the employer’s subjective intent and the employee’s subjective views on the situation are irrelevant. Whether a constructive discharge occurred is a question of fact.” Id. (citation omitted). We conclude that a genuine issue of material fact exists as to whether a reasonable person, faced with a teaching assignment that will require much standing and moving about, and knowing that such activity will hasten her muscular degeneration and the need for a wheelchair, would have no other choice but to resign. See Sanchez v. Denver Pub. Schs., 164 F.3d 527, 534 (10th Cir.1998) (holding that the conditions of the job must be objectively intolerable and that the plaintiff must show that she had no other choice but to quit).

IV. CONCLUSION

The evidence produced by Ms. Lowe raises a genuine issue of material fact as to whether, by failing to engage in the interactive process in good faith, the District failed to identify an appropriate accommodation and thus violated the ADA. It also raises a genuine issue of material fact as to whether a reasonable person, under the circumstances, would have felt compelled to resign. We therefore REVERSE the district court’s entry of summary judgment and REMAND this case for further proceedings in accordance with this order and judgment.

O’BRIEN, J.,

concurring.

With the following observations, I join the Order and Judgment. In the spring of 2006 Lowe was on family leave, necessary because of a knee replacement. In March, 2006, shortly after she returned to work, Lowe was informed she would be reassigned from her counselor position to that of a classroom teacher, as she was certified to teach science. The news did not sit well with her because she preferred being a counselor and did not want to return to the classroom.1 In April she applied for a position with Guthrie Job Corps (GJC) citing the reason for wanting to leave her position with the school district as “retirement.” 2 She was offered full time employment, which she accepted on June 12, 2006. As of the date of the summary judgment motions she was still employed with GJC.

In the spring of 2006, the school district did not renew the teaching contract of Rhinehart, a high school science teacher. Lowe assumed she would be assigned to that position and so discussed the assumed change with the head of the high school science department. Later, but before the end of the school year, she notified the school district of her need for an ADA accommodation if she was going to be assigned to the Rhinehart classroom. She supported her request with a letter from her treating physician and she outlined *556(with the help of the head of the science department) a list of accommodations she felt were necessary for her to teach in Rhinehart’s classroom. See Appendix A. Through the school chain of command she was told no accommodations would be made as she would be assigned to a non-laboratory science class.

Lowe’s assumptions about where and what she would teach may have been reasonable (they were, after all, shared by other school supervisory employees, albeit those without decision-making authority), but two additional matters must be factored into the equation. First, Lowe knew, from school policy and personal experience, that teachers were often reassigned to any position they were qualified to teach based upon the needs of the school and such assignments were often made at the last minute in the fall before school starts. Second, she was told no accommodations would be made because she would be assigned to a non-laboratory class. Again, she assumed, perhaps reasonably, such assignment was impossible because all high school science classes were laboratoiy classes. But junior high science classes, which she was certified to teach, do not have labs and any renovations to those classrooms that might have been needed to accommodate Lowe’s disabilities wei'e minimal.

Nothing happened during most of the summer, but in early August the matter was revisited when a meeting was held to discuss accommodations Lowe might require in order to teach science.3 Lowe attended as did Superintendent Simpson, the ultimate decision-maker, and others. Lowe continued to express her preference to remain in the counselor position and her dismay at being forced back into the classroom. She wanted Simpson to revisit that decision. But the meeting also ad-di'essed her concerns about being able to effectively teach in a laboratory classroom unless her disabilities were accommodated. Simpson made clear that the major laboratory classroom renovation being pressed by Lowe, see Appendix A, would not be undertaken. As an alternative he suggested an aide might be hired to assist Lowe. Simpson claims he told Lowe she would not be required to teach a laboratory class. Lowe says no such representation was made. Pratz, a teacher advocate employed by the Oklahoma Education Association, was also at the meeting. Her recollection parallels Simpsons — “What my recollection is that Mr. Simpson’s response was, it will not be a lab science class, so it won’t need modifications.” (R. at 368.) Nevertheless, a factual dispute remains with respect to that material issue of fact. Undisputed, however, is a salient fact — Simpson never mentioned reassigning Lowe to the junior high.

It may be that Simpson had not reached a decision as to how, specifically, he would accommodate Lowe’s needs and wanted to keep his options open.4 On August 4, two days after the meeting and without re*557questing a definitive answer from Simpson as to what he would do in response to her concerns, Lowe sent her resignation letter, saying only, “Consider this my resignation. I am retiring.” The letter gave no notice she was resigning due to the School District’s failure to make reasonable accommodations, nor did she condition her resignation on such a failure.5 An employer is not liable for failing to assure an employee reasonable accommodations will be made. The statute imposes liability for “not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee ...” 42 U.S.C. § 12112(b)(5)(A) (emphasis added). Lowe’s resignation may have short-circuited the process by not giving the School District an adequate time to respond.6 We cannot know whether a reasonable accommodation would or would not have been forthcoming.

On the other hand, it could be that the junior high option was concocted, post hoc, as a convenient response to Lowe’s ADA complaint. If it was an option Simpson was actively considering at the time of the August meeting, it was not then communicated to Lowe or anyone else; perhaps with good reason, perhaps not. The record sheds no light.

The School District argues, correctly, I think, that the interactive process is merely a method of facilitating statutory goals. It is a recommendation, not a statutory requirement. White v. York Int’l Corp., 45 F.3d 357, 363 (10th Cir.1995). “The federal regulations implementing the ADA ‘envision an interactive process that requires participation by both parties.’ ” Templeton v. Neodata Servs., Inc., 162 F.3d 617, 619 (10th Cir.1998) (quoting Beck v. Univ. of Wis. Bd. of Regents, 75 F.3d 1130, 1135 (7th Cir.1996)) (emphasis added). While it may be an essential component to understand the employee’s needs, “a plaintiff cannot base a reasonable accommodation claim solely on the allegation that the em*558ployer failed to engage in an interactive process.” Rehling v. City of Chicago, 207 F.3d 1009, 1016 (7th Cir.2000) (“[T]he interactive process is a means and not an end in itself.”). Clearly an employer could, with impunity, ignore the interactive process so long as it reasonably accommodated employee needs.

This case comes down to whether the School District would have accommodated Lowe’s needs by reassignment to a non-laboratory classroom (as it could have done) had she not resigned in a huff.7 Since the record does not supply an answer to that question with reasonable certainty this case must be tried.

APPENDIX A

Orthopaedic [sic ] Specialists Incorporated

April 5, 2006

RE: Terrianne Lowe

TO WHOM IT MAY CONCERN:

Terrianne Lowe is a patient of mine who suffers from polio with postpolio syndrome extending back to 1952. She has also had multiple surgical procedures on both lower extremities for contractures and weakness, and recently has undergone bilateral knee replacement with ultimate revision of her right knee replacement. She has both proximal and distal weakness in her lower extremities.

Because of her muscle weakness and joint problems, this patient is unable to stand for any longer than ten minutes at a time and is unable to do any prolonged walking without orthotics and aids. She has a functional limitation which requires sedentary work only. She is unable to repetitively climb stairs; is unable to kneel, squat, or crawl.

Because of her significant functional limitations and disabilities, she will require appropriate accommodations at work to allow her to function within her limited capacity.

If I can provide any further information, please do not hesitate to let me know.

Sincerely,

/s/ Paul R. Miller, M.D.

(R. at 292.)

Laboratory Safety Modifications for Physical Disabilities

Classroom will need to be modified so teacher can be accessible to each table.

(Wider aisles to allow wheel chair/walker access)

Lab stations will need to be lowered. Chalkboards/whiteboards will need to be lowered so are accessible from a sitting position.

Overhead cart and screen will need to be modified to accommodate a sitting position.

*559Eyewash station will need to be added that is accessible.

Fume hood will need to be added that is accessible.

Safety Shower will need to be added that is accessible.

Fire extinguisher and fire blanket need to be lowered.

Chemical and flammable storage will need to be modified so it is accessible.

General lab equipment storage will need to be modified so it is accessible.

Teacher aide will be needed to gather lab equipment, transport chemicals, and monitor safety issues during labs.

(R. at 295.)

KANNE, Circuit Judge.

Joshua Bunn quit his job at a Dairy Queen franchise and sued the franchisee, his former employer, under the Americans with Disabilities Act. Bunn, who is vision-impaired, believed that the employer failed to accommodate his disability as required by law and that it subjected him to illegal disparate treatment when it reduced his scheduled hours during the winter months. The district court granted the employer’s motion for summary judgment on all claims, and Bunn appealed. After disposing of an initial procedural argument, we find that Bunn’s failure-to-accommodate claim falls short because the employer did reasonably accommodate Bunn’s disability. Next, we find that his disparate treatment claim fails because he has not introduced sufficient evidence to create a triable issue of material fact and because the undisputed facts show that the defendant is entitled to judgment as a matter of law. We affirm the judgment of the district court in all respects.

I. Background

Joshua Bunn is legally blind. He has no vision in one eye and greatly reduced vision in the other. On July 25, 2010, Bunn applied for employment with Khoury Enterprises (“Khoury”), a firm operating Dairy Queen franchises in the Indianapolis area. On September 27, 2010, Khoury hired Bunn for an hourly position. The parties dispute whether that position was formally classified as “full-time” or “part-time,” but for the purposes of this lawsuit that distinction is irrelevant.

Typically, hourly employees at Khoury’s Dairy Queen stores were required to rotate between various duty stations. These included preparing ice cream treats, preparing grilled food, working the cash register, maintaining the dining area, and more. Bunn’s first assignment was to the “Chill” department, in which Dairy Queen’s well-known ice cream treats were prepared. Bunn was unable to perform certain duties within the department without accommodation. The type on the ingredient labels was too small, and the monitors displaying orders to be filled were too high.

Store manager Larry Johnson took responsibility for finding a position better *680suited to Bunn’s needs. Eventually, he trained Bunn in the “Expo” department, in which employees were responsible for delivering food to dine-in customers and keeping the store and the dining area clean. Bunn was able to perform his duties in the Expo department with minimal accommodation, and Johnson decided to schedule Bunn exclusively in Expo. That meant Bunn’s position was different from the position held by most of his hourly peers, as they continued to rotate between departments while he stayed put. But it did not mean that Bunn was given fewer hours. From the time he was trained until the time he was suspended due to insubordinate conduct towards a supervisor, Bunn was scheduled full-time.

On November 17, 2010, night manager Norma Caballero asked Bunn to put his cell phone away while working (Bunn had been warned about using his phone during his shift on multiple occasions). Bunn refused, and Caballero reported that he gave her an “attitude” for the rest of the shift, including shoving a trash can at her when she asked him to take out the garbage. Caballero contacted Larry Johnson, and Bunn was suspended for ten days. Bunn signed a written suspension notice indicating that he understood why he was being disciplined.

Bunn’s hours decreased following the suspension. In December 2010, Bunn requested and received seven days off. Khoury’s restaurants were also closed for the holidays, and on occasion closed due to inclement weather. Bunn worked only 23.41 hours that month. In January 2011, after returning from vacation, Bunn worked just 12.33 hours. It is undisputed that, given the nature of a Dairy Queen franchise’s business, Khoury’s restaurants saw decreased demand during the cold weather months and adjusted many employee schedules accordingly. On February 1, 2011, Bunn submitted his resignation. He told Johnson that he felt he could work more hours with another employer; Johnson agreed.

After his resignation became effective, Bunn filed a timely charge of discrimination with the Equal Employment Opportunity Commission (“EEOC”). The EEOC declined to pursue the charge and issued a right-to-sue letter. Bunn brought this lawsuit alleging failure to accommodate his disability and disparate treatment, both in violation of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12112. The district court granted summary judgment in Khoury’s favor on all claims, finding that no material facts were genuinely disputed and that the undisputed facts entitled Khoury to a judgment as a matter of law. Bunn appeals, and we affirm.

II. ANALYSIS

There are three issues before us on appeal: (1) whether the district court erred by granting summary judgment before Bunn had a chance to respond to a late-filed affidavit submitted by the defendant; (2) whether the district court erred in granting summary judgment to the defendant on Bunn’s failure-to-accommodate claim; and (3) whether the district court erred by granting summary judgment to the defendant on Bunn’s disparate treatment claim. We affirm the district court’s treatment of this case in all respects.

A. Bunn’s Procedural Argument

Bunn begins by complaining about the briefing schedule. Khoury filed its motion and supporting brief for summary judgment on February 1, 2013. The Larry Johnson “affidavit” attached to those filings consisted of a signature page, and nothing else. Nonetheless, Khoury’s brief relied heavily on facts allegedly supplied by the missing body of that affidavit. *681Bunn twice filed for extensions of time to respond to Khoury’s motion for summary judgment, ultimately filing a response on March 20, 2013. Bunn was aware of the deficiency in Khoury’s filings at the time of his response; he noted it in his brief, but “speculated” that the absence of the affidavit made little difference. On April 30, 2013, the district court ordered Khoury to file the missing pages, and Khoury complied on May 6, 2013. On May 13, 2013, the district court granted Khoury’s motion for summary judgment. Bunn believes it was an error for the district court to fail to give him a separate, additional response period in which to file a brief addressing the completed Johnson affidavit. We disagree for two reasons.

The first reason is a legal one. Bunn’s argument, at its core, attacks the district court’s application of its own local rules. Local Rule 56.1(b) for the Southern District of Indiana affords a litigant 28 days to respond to a “summary judgment motion.” Bunn was given 28 days (and then some) in which to respond to Khoury’s motion. There is nothing in the plain language of the rule concerning an additional 28-day response period when one party is directed to correct a clerical error; the rule only applies to a response to a “motion,” not to a misfiled affidavit. The district court’s decision not to wait for a response therefore rested on its interpretation of an ambiguity, or of an area of no coverage, in the local rules. “[District courts have considerable discretion in interpreting and applying their own local rules.” Congregation of the Passion, Holy Cross Province v. Touche, Ross & Co., 854 F.2d 219, 223 (7th Cir.1988). We will intrude on that discretion only where we are “convinced” the district court made a mistake. Id. We cannot say we are “convinced” the district court made a mistake in this case when there is nothing at all in the rules to suggest that it did. What we can say is that the district court made a discretionary call concerning a matter not directly covered by the local or federal rules, as it was perfectly entitled to do.

The second reason we find Bunn’s procedural argument unpersuasive is a practical one. Bunn was not prejudiced in the slightest by Khoury’s failure to attach the complete Johnson affidavit to its motion for summary judgment. Every fact derived therefrom on which Khoury intended to rely was cited within its brief supporting the motion. Thus, even if Bunn could not look at the affidavit itself, he was aware of its contents and could have submitted contradictory evidence with his response, if he had any. He was also free to bring the matter to the district court’s attention at any time prior to his long-delayed submission of a response brief. But he did not,, and, in his response brief, Bunn himself averred that the missing affidavit made little difference. There is no legal or equitable reason for us to reverse on these grounds.

B. Failure to Accommodate

Bunn asks us to review the district court’s adverse grant of summary judgment on his failure to accommodate claim, a task which we undertake de novo. Swetlik v. Crawford, 738 F.3d 818, 826 (7th Cir.2013). Summary judgment is appropriate where the admissible evidence shows that there is no genuine dispute as to any material fact and that the moving party is entitled to judgment as a matter of law. Fed.R.Civ.P. 56(a); Lawson v. CSX Transp., Inc., 245 F.3d 916, 922 (7th Cir.2001). A “material fact” is one identified by the substantive law as affecting the outcome of the suit. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). A “genuine issue” exists with respect to any such ma*682terial fact, and summary judgment is therefore inappropriate, when “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Id. On the other hand, where the factual record taken as a whole could not lead a rational trier of fact to find for the non-moving party, there is nothing for a jury to do. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). In determining whether a genuine issue of material fact exists, we view the record in the light most favorable to the nonmoving party. Anderson, 477 U.S. at 255, 106 S.Ct. 2505.

Bunn brought his claim under the Americans with Disabilities Act. The ADA provides that a covered employer shall not “discriminate against a qualified individual on the basis of disability!.]” 42 U.S.C. § 12112(a). “Discrimination,” for the purposes of Section 12112(a), includes “not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee” unless the employer “can demonstrate that the accommodation would impose an undue hardship on the operation of the business.” 42 U.S.C. § 12112(b)(5)(A).

We have derived a three-part test from the statutory language. In order to establish a claim for failure to accommodate, a plaintiff must show that: (1) he is a qualified individual with a disability; (2) the employer was aware of her disability; and (3) the employer failed to reasonably accommodate the disability. EEOC v. Sears, Roebuck & Co., 417 F.3d 789, 797 (7th Cir.2005) (citing Hoffman v. Caterpillar, Inc., 256 F.3d 568, 572 (7th Cir.2001)). Khoury does not dispute that Bunn’s case satisfies the first two prongs. But the district court granted summary judgment to Khoury because Bunn’s case fails the third prong: Khoury did reasonably accommodate Bunn’s disability.

We agree with that conclusion. The term “reasonable accommodation,” in the context of this case, means “Modifications or adjustments to the work environment, or to the manner or circumstances under which the position held or desired is customarily performed, that enable [a qualified] individual with a disability ... to perform the essential functions of that position!.]” 29 C.F.R. § 1630.2(o )(l)(ii). Particular examples include “[m]aking existing facilities used by employees readily accessible to and usable by individuals with disabilities!,]” as well as “[j]ob restructuring; part-time or modified work schedules; reassignment to a vacant position; acquisition or modifications of equipment or devices; appropriate adjustment or modifications of examinations, training materials, or policies; the provision of qualified readers or interpreters; and other similar accommodations for individuals with disabilities.” 29 C.F.R. § 1630.2(o )(2)(i)-(ii). Of course, that list is not exhaustive. In the general sense, “an accommodation is any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities.” 29 C.F.R. pt. 1630 app. § 1630.2(o).

It is undisputed that, when it became clear that Bunn could not perform the rotating duties of a regular hourly employee, store manager Larry Johnson worked with him to determine which job functions he could perform and which he could not. Bunn was best able to perform the duties of an employee in the Expo department. Accordingly, instead of rotating Bunn through various departments, some of which were unsuitable for him, Johnson instructed Bunn’s immediate supervisors to schedule him exclusively in Expo. That *683“change ... in the way things [were] customarily done” enabled Bunn to enjoy equal employment opportunities, as evidenced by the undisputed fact that he was scheduled full-time in Expo from his hire date until his suspension. 29 C.F.R. pt. 1630 app. § 1630.2(o). It might also be called a “job restructuring,” or a “modified work schedule.” 29 C.F.R. § 1630.2(o )(2)(ii). In short, it was exactly the kind of accommodation envisioned by the regulations applicable to the ADA.

That is the end of our inquiry; the undisputed facts show that Khoury did what it was required to do by law. Bunn’s only argument to the contrary is that he asked for additional, or different, accommodations and was rebuffed. But even if we credit his version of events— which we are obligated to do at the summary judgment stage — that fact is not material. While the EEOC regulations accompanying the ADA do suggest that “it may be necessary for the [employer] to initiate an informal, interactive process with the [employee]” to determine an appropriate accommodation, 29 C.F.R. § 1630.2(o)(3) (emphasis added), there is no separate cause of action for a failure of that interactive process. In this area of the law, we are primarily concerned with the ends, not the means: “Because the interactive process is not an end in itself, it is not sufficient for [an employee] to show that [an employer] failed to engage in an interactive process or that it caused the interactive process to break down.” Rehling v. City of Chicago, 207 F.3d 1009, 1015-1016 (7th Cir.2000); see also Spurling v. C & M Fine Pack, Inc., 739 F.3d 1055, 1059 n. 1 (7th Cir.2014). Ultimately, Khoury did provide a reasonable accommodation to Bunn. Bunn’s apparent displeasure with the way in which Khoury decided on that accommodation, or with its failure to provide the exact accommodation he would have preferred, is irrelevant. Id. at 1016 (“The ADA seeks to ensure that qualified individuals are accommodated in the workplace, not to punish employers who, despite their failure to engage in an interactive process, have made reasonable accommodations.”). We affirm the district court’s grant of summary judgment on Bunn’s failure-to-accommodate claim.

C. Disparate Treatment

Finally, Bunn contests the district court’s adverse grant of summary judgment on his disparate treatment claim. Once again, we review de novo, mindful of the analytical rubric laid out for us by Rule 56. Dickerson v. Bd. of Trs. of Cmty. Coll. Dist. No. 522, 657 F.3d 595, 600 (7th Cir.2011). Once again, we affirm the judgment of the district court.

1. Direct Method

A plaintiff claiming disparate treatment in violation of the ADA can rely on two different methods of proof to survive a summary judgment motion. Bunn relies on both. The first is the “direct method,” in which a plaintiff must show that a genuine issue of material fact exists with respect to each of the three elements he will eventually be required to prove at trial: (1) that the plaintiff is disabled within the meaning of the ADA; (2) that the plaintiff is qualified to perform the essential functions of the job with or without accommodation; and (3) that the plaintiff has suffered an adverse employment action because of his disability. Timmons v. Gen. Motors Corp., 469 F.3d 1122, 1127 (7th Cir.2006).

Khoury concedes the first two prongs of the test, but contests the third. In theory, the third prong — tying an adverse employment action to a discriminatory animus— can be proved with either direct or eircum-*684stantial evidence. Dickerson, 657 F.3d at 601. But direct evidence, which might take the form of an admission of discriminatory intent by the relevant decisionmaker within the defendant employer’s ranks, is understandably rare in ADA eases. Most ADA plaintiffs therefore rely on circumstantial evidence, which might include:

(1) suspicious timing; (2) ambiguous statements or behavior towards other employees in the protected group; (3) evidence, statistical or otherwise, that similarly situated employees outside of the protected group systematically receive better treatment; and (4) evidence that the employer offered a pretextual reason for an adverse employment action.

Id. (citing Diaz v. Kraft Foods Global, Inc., 653 F.3d 582, 586-87 (7th Cir.2011); Burnell v. Gates Rubber Co., 647 F.3d 704, 708 (7th Cir.2011)).

Bunn, like most ADA plaintiffs, purports to rely on circumstantial evidence. But he presents none that is sufficient to create a genuine issue of fact. Even if we assume that Khoury subjected Bunn to an “adverse employment action” — an assumption which is not clearly supported by the evidence of record1 — he has suggested only three items which he believes will prove that such disparate treatment was due to his disability.

The first is his contention that he was disciplined for looking at his cell phone during his shift, while non-disabled employees were permitted to do so. There is no evidence in the record — not even in Bunn’s own affidavit — to support Bunn’s contention that non-disabled employees were not disciplined for similar conduct. Without any admissible evidence to support Bunn’s claim, we cannot say there is a genuine dispute.

The second is Bunn’s assertion that, when he asked Johnson if certain accommodations could be made to allow Bunn to work in departments other than Expo, Johnson rebuffed him, saying something like, “I will place you wherever I want,” without regard to sight restrictions. But it is undisputed that Johnson was the store manager, and that scheduling all of his employees — not just Bunn — wherever he wanted was a fundamental part of his job description. It is not evidence of discrimination when a manager tells an employee, “Leave the managing to me.” Furthermore, the undisputed evidence shows that Johnson in fact scheduled Bunn in a position which he could perform with minimal accommodation. Given that, it is hard to see how a rational jury could consider Johnson’s statement about scheduling discretion to be evidence of a discriminatory animus. Johnson’s comment does not create a triable issue.

The third is much like the second. Bunn claims that when he asked Johnson to schedule him for more hours, Johnson told Bunn he would schedule him for however many hours he saw fit. Again, this is simply a manager exercising control over an employee. There is no hint of disability discrimination in the content or the context of the quote. We are typically very cautious about relying on “stray remarks” as evidence of discriminatory animus even where the content is arguably discriminatory. See, e.g., Teruggi v. CIT Grp./Capital Fin., Inc., 709 F.3d 654, 661 (7th Cir.2013); Merillat v. Metal Spinners, Inc., *685470 F.3d 685, 694 (7th Cir.2006). There is even more reason to be cautious here, where the remarks in question do not single out the plaintiff based on his disability or any other individually distinguishing characteristic.

In short, Bunn has not produced sufficient evidence to create a triable issue of fact as to whether Khoury took an adverse employment action against him because of his disability. He therefore cannot rely on the direct method of proof to survive summary judgment.

2. Indirect Method

The second method of proof available to an ADA plaintiff hoping to survive summary judgment is the “indirect method,” originally developed in the Title VII context by McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973), and its multitudinous progeny. The indirect method of proof, which exists only to help plaintiffs survive summary judgment and falls away at the trial stage, follows a burden-shifting approach. First, the employee establishes a prima facie case by showing: (1) that he is disabled under the ADA; (2) that he was meeting his employer’s legitimate expectations; (3) that he suffered an adverse employment action; and (4) that similarly situated employees without a disability were treated more favorably. Lloyd v. Swifty Transp., Inc., 552 F.3d 594, 601 (7th Cir.2009). If the employee is able to establish a prima facie case, the burden shifts to the employer to produce a legitimate, non-discriminatory reason for the adverse employment action. Dickerson, 657 F.3d at 601 (citing Rooney v. Koch Air, LLC, 410 F.3d 376, 381 (7th Cir.2005)). The employer’s burden in that regard is one of production, not persuasion; the burden of persuasion remains with the employee throughout the process. South v. Ill. Envtl. Prot. Agency, 495 F.3d 747, 751-52 (7th Cir.2007). Finally, if a legitimate reason is produced, the employee must prove by a preponderance of the evidence that the employer’s stated reason is a lie. Dickerson, 657 F.3d at 601; Faas v. Sears, Roebuck & Co., 532 F.3d 633, 642 (7th Cir.2008) (“Pretext means a dishonest explanation, a lie rather than an oddity or an error.”) (internal quotation marks omitted).

Bunn fails the indirect method at every stage. First, Bunn has not made out a prima facie case of discrimination. The undisputed evidence shows that he did not meet his employer’s legitimate expectations. He missed an inordinate amount of work in his first several months on the job, and he shoved a trash can at the night manager, resulting in a suspension. He has also completely failed to identify, let alone discuss, a similarly situated non-disabled employee who was treated more favorably. That inquiry is too fact-intensive for us to rely on conjecture alone. See, e.g., Raymond v. Ameritech Corp., 442 F.3d 600, 610 (7th Cir.2006); Radue v. Kimberly-Clark Corp., 219 F.3d 612, 617-18 (7th Cir.2000) (an employee is similarly situated only where he is directly comparable in all material aspects, including performance, qualifications, and conduct). It is Bunn’s responsibility to identify a satisfactory comparator to the court, and he has not done so. When an employee cannot make out a prima facie case, that is the end of it; summary judgment is warranted.

Second, even if Bunn could establish a prima facie case, Khoury has met its burden of producing a legitimate reason for the reduction in Bunn’s scheduled hours — several reasons, in fact. Bunn’s hours were reduced during the winter months following his suspension because of weather closings, vacation days (which Bunn himself requested), and reduced de*686mand for Dairy Queen treats during the dead of winter. Bunn has not introduced a single shred of evidence suggesting that these explanations are lies, let alone evidence sufficient to meet the preponderance standard. Dickerson, 657 F.3d at 601. There is no genuine issue for trial.

In summary, we agree with the district court that Khoury is entitled to summary judgment on Bunn’s disparate treatment claim. Bunn has failed to create any triable issues of fact through either the direct or the indirect method of proof, and the undisputed facts entitle Khoury to judgment as a matter of law.

III. Conclusion

Bunn’s procedural argument asks us to wrest away from the district court its discretion to interpret and apply its own local rules. We decline to do so. His failure-to-accommodate claim fails because Khoury in fact provided a reasonable accommodation, and his disparate treatment claim fails because he has not produced sufficient evidence to create a triable issue of fact under any method of proof. We AFFIRM the judgment of the district court.