Even though Adams relies heavily on Bragdon, the government's brief never mentions the case. Instead, it relies on two cases from this circuit, Crandall v. Paralyzed Veterans of America, 146 F.3d 894 (D.C. Cir. 1998), and Department of State v. Coombs, 482 F.3d 577 (D.C. Cir. 2007). But neither of those cases stands for the proposition that an employer must know in what way the employee's impairment limits a major life activity in order to be held liable for disability discrimination.

“[I]n any action premised on failure to accommodate, the plaintiff typically bears the burden of providing notice of [his] disability and the limitations it imposes.” Faison v. Vance–Cooks , 896 F.Supp.2d 37, 57 (D.D.C.2012), citing Crandall v. Paralyzed Veterans of Am. , 146 F.3d 894, 897–98 (D.C.Cir.1998). Notice can be actual or constructive, but to satisfy the constructive notice requirement, the plaintiff's behavior must be “so obviously a manifestation ‘of an underlying disability that it would be reasonable to infer that [the defendant] actually knew of the disability.”

The employer's duty to engage in the interactive process is “trigger[ed]” by the employee's initial provision of notice of her disability and request for accommodation. Taylor v. Phoenixville Sch. Dist., 184 F.3d 296, 312–15 (3d Cir.1999). “[P]recise notice” of the employee's disability is unnecessary. Crandall v. Paralyzed Veterans of Am., 146 F.3d 894, 898 (D.C.Cir.1998) (finding notice insufficient to support failure-to-accommodate and discrete-act discrimination claims under Rehabilitation Act) (citation omitted). The employee need not apprise the employer of “specifics,” such as her impairment's name, diagnosis, or treatment. SeeTaylor, 184 F.3d at 314.

42 U.S.C. § 12112(b)(5)(A) (incorporated into the Rehabilitation Act by 29 U.S.C. § 791(g)). To prevail on a claim for denial of reasonable accommodation, Stewart had to produce sufficient evidence (a) that she was disabled for purposes of the Rehabilitation Act, 29 U.S.C. § 794; (b) that St. Elizabeths had notice of her disability, see Crandall v. Paralyzed Veterans of Am., 146 F.3d 894, 896-97 (D.C. Cir. 1998); and (c) that St. Elizabeths denied her request for a reasonable accommodation of her disability, see Mitchell v. Washingtonville Cent. Sch. Dist., 190 F.3d 1, 6 (2d Cir. 1999). Stewart challenges both St. Elizabeths' pre-October 2002 actions and its October 2002 actions.

see Taylor v. Rice, 451 F.3d 898, 905 (D.C. Cir. 2006) (stating that the Rehabilitation Act provides a private right of action against federal agencies for employment discrimination claims on the basis of a disability). To state a claim for relief under the Rehabilitation Act, the plaintiff must plead sufficient facts to establish that “(i) [she] suffered an adverse employment action (ii) because of [her] . . . disability.” Baloch v. Kempthorne, 550 F.3d 1191, 1196 (D.C. Cir. 2008). Additionally, the plaintiff must plead facts sufficient to show that her employer “must have acted with an awareness of the disability itself, and not merely an awareness of some deficiency in the employee's performance that might be a product of an unknown disability.” Crandall v. Paralyzed Veterans of Am., 146 F.3d 894, 897 (D.C. Cir. 1998). Finally, in making these assessments, the Court is mindful that “[c]laims and defenses under [the Rehabilitation Act and the ADA] are virtually identical[,]” Harrison v. Rubin, 174 F.3d 249, 253 (D.C. Cir. 1999), and “cases interpreting either are applicable and interchangeable[,]” Am. Council of the Blind v. Paulson, 525 F.3d 1256, 1260 n.2 (D.C. Cir. 2008) (internal quotation marks omitted).

There is a dearth of case law interpreting what it means to "receive federal financial assistance" under the Rehabilitation Act in situations where an employer receives federal grant assistance. In the most analogous case, the United States Court of Appeals for the District of Columbia Circuit, in Crandall v. Paralyzed Veterans of America, 146 F.3d 894, 896 (D.C. Cir. 1998), considered when an employer became bound by the anti-discrimination provisions of the Act. There, the term of Paralyzed Veterans' federal grant did not begin until September 11, 1992, according to the funding agency's letter approving the grant.

Nonetheless, the Court finds it appropriate to consider the defendant's argument that it lacked knowledge of the plaintiff's alleged disability. Whether an employer knew about an employee's disability is a "threshold question[ ]" with respect to the issue of disability discrimination vel non, Conn, 149 F.Supp.3d at 147, as "an employer cannot fire an employee because of a disability unless it knows of the disability," id. at 149 (emphasis added) (quoting Hedberg v. Ind. Bell Tel. Co., 47 F.3d 928, 932 (7th Cir. 1995) ); see also Crandall v. Paralyzed Veterans of Am., 146 F.3d 894, 898 (D.C. Cir. 1998) (in a Rehabilitation Act case, concluding that "[i]f [a plaintiff's] behavior is not so obviously [a] manifestation[ ] of an underlying disability that it would be reasonable to infer that an employer actually knew of the disability, and the employer has no other notice of the disability, there can be no actionable discrimination" (third and fourth alterations in original) (internal citation and quotation marks omitted) ); Hunt v. District of Columbia, 66 A.3d 987, 991 (D.C. 2013) (recognizing that "an employer's duty ... under the DCHRA[ ] [is] to make reasonable accommodation to the known physical or mental limitations of [a disabled] ... employee" (second omission and third alteration in original) (emphasis added) (internal quotation marks omitted) ). "To establish the employer's knowledge of [an employee's] disability, ‘notice ... need not be precise, but it must put the employer sufficiently on notice of the existence and nature of the disability.’ " Green v. Am. Univ., 647 F.Sup

See, e.g., Adams v. Rice, 531 F.3d 936, 950 (D.C. Cir. 2008) (rejecting government's argument that it could only be liable for disability discrimination if it knew how employee's impairment substantially limited a major life activity); E.E.O.C. v. Lee's Log Cabin, Inc., 546 F.3d 438, 441 (7th Cir. 2008) ("Even if the AIDS claim [was] properly before the court, the judge held, there was no evidence that Log Cabin knew Stewart suffered from AIDS."); Taylor v. Principal Fin. Grp., Inc., 93 F.3d 155 (5th Cir. 1996) ("The evidence does not show that Taylor ever told Matthews that he suffered a limitation as a result of his alleged impairment.") The "bedrock requirement" is "an adequate, prior alert to the defendant of the plaintiff's disabled status." Crandall v. Paralyzed Veterans of America, 146 F.3d 894, 898 (D.C. Cir. 1998). Although the claims in Adams and Crandall arose under the Rehabilitation Act, the analysis of disability discrimination claims under the Rehabilitation Act and the ADA are largely the same.

Though the Circuit has never decided the question directly, it has applied Ricks in cases involving statutes incorporated by the Accountability Act. See Crandall v. Paralyzed Veterans of Am., 146 F.3d 894, 896 (D.C.Cir.1998) (applying Ricks to claims brought under § 504 of the Rehabilitation Act of 1973); Currier v. Radio Free Europe/Radio Liberty, Inc., 159 F.3d 1363, 1366–67 (D.C.Cir.1998) (applying Ricks to claims brought under Title VII). The Court will therefore be guided by Ricks for assessing when the limitations period commenced in this case.

An employer cannot discriminate against an employee "because of" the employee's disability unless the employer has knowledge of the disability. Hedberg v. Indiana Bell Tel. Co., Inc., 47 F.3d 928, 931-32 (7th Cir. 1995); see also, e.g., Crandall v. Paralyzed Veterans of America, 146 F.3d 894, 896-97 (D.C. Cir. 1994) ("courts of appeals have overwhelmingly agreed that for this casual link to be shown the employer must have acted with an awareness of the disability itself, and not merely an awareness of some deficiency in the employee's performance that might be a product of an unknown disability") (collecting both Rehabilitation Act and ADA cases); Morisky v. Broward County, 80 F.3d 445, 447-49 (11th Cir. 1996) (citing Hedberg, rejecting the "contention that a plaintiff can sustain a prima facie case of handicap discrimination without proof that an employer had actual or constructive knowledge of an applicant's disability"); Hammon v. DHL Airways, Inc., 165 F.3d 441, 450 (6th Cir. 1999) (finding that where plaintiff failed to inform employer that he had a disability, plaintiff could not satisfy the prima facie requirements of ADA claim). So the Court's analysis focused not on whether Spurling was, in fact, disabled, or if she was qualified to perform the essential functions of her job once her na