Unknown, 596 F.3d 25. · Go Syfert
Unknown, 596 F.3d 25. Cases Citing This Book View Copy Cite
“failure to comply with the anti-ferret rule permits the court to 'disregard any statement of fact not supported by a specific citation to record material properly considered on summary judgment”
209 citation events (209 in the last 25 years) across 20 distinct courts.
Strongest positive: CRANDALL v. ORONO POLICE DEPARTMENT (med, 2025-04-29)
Treatment trajectory · 2010 → 2026 · click a year to view as-of
2010 2018 2026
Top citers, strongest first. 50 distinct citers.
discussed Cited as authority (verbatim quote) CRANDALL v. ORONO POLICE DEPARTMENT
D. Me. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
the analysis of when and under what conditions diabetes is considered a disability for ada purposes is a matter of degree
examined Cited as authority (verbatim quote) Fournier v. Commonwealth of Massachusetts (5×) also: Cited "see", Cited "see, e.g."
D. Mass. · 2020 · signal: see also · quote attribution · 3 verbatim quotes · confidence high
i was unaware of at any point , and i wasn't involved in making the decision to move her. that was a decision by .
discussed Cited as authority (verbatim quote) Polanco v. UPS Freight Services, Inc. (2×) also: Cited "see"
D.P.R. · 2016 · signal: see · quote attribution · 1 verbatim quote · confidence high
failure to comply with the anti-ferret rule permits the court to 'disregard any statement of fact not supported by a specific citation to record material properly considered on summary judgment
discussed Cited as authority (rule) O'Horo v. Boston Medical Center Corporation
1st Cir. · 2025 · confidence medium
LP, 856 F.3d 119, 138 (1st Cir. 2017) (one day between protected conduct and alleged retaliatory action insufficient to establish pretext); Alvarado, 687 F.3d 463 -64 (same, but one week); Carreras v. Sajo, García & Partners, 596 F.3d 25, 38 (1st Cir. 2010) (same, but four days).
discussed Cited as authority (rule) Quintana-Dieppa v. Department of the Army
1st Cir. · 2025 · confidence medium
Simply put, although very close "temporal proximity may suffice for a prima facie case of retaliation," it "does not satisfy [Quintana's] ultimate burden to establish that the true explanation" for her reassignment "was retaliation for engaging in protected conduct rather than poor performance." Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 38 (1st Cir. 2010) (affirming summary judgment and explaining that temporal proximity of four days did not suffice to show pretext)(citation omitted); see Echevarria v. AstraZeneca Pharm.
discussed Cited as authority (rule) Cora v. Amgen Manufacturing, Limited
D.P.R. · 2025 · confidence medium
To establish a claim of retaliation pursuant to the ADA, Cora must eventually show “(1) that he engaged in protected conduct, (2) that he suffered an adverse employment action, and (3) that there was a causal connection between the protected conduct and the adverse employment action.” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 35 (1st Cir. 2010) (citing Soileau, 105 F.3d at 16 ).
discussed Cited as authority (rule) Stratton v. Bentley University
1st Cir. · 2024 · confidence medium
We treat a district court's application of its local rules with deference, Carreras v. Sajo, García & Partners, 596 F.3d 25, 31 (1st Cir. 2010), and we have warned litigants to ignore those rules "at their peril." López-Hernández v. Terumo P.R.
discussed Cited as authority (rule) Sheridan v. Centerra Group, LLC (2×)
1st Cir. · 2024 · confidence medium
To survive summary judgment on his retaliation claim, Rios "must establish a genuine issue of material fact as to whether he . . . was retaliated-against within the meaning of the ADA." Carreras v. Sajo, García & Partners, 596 F.3d 25, 32 (1st Cir. 2010).
discussed Cited as authority (rule) Board of Trustees of the IUOE Local 4 Pension Fund v. Alongi
D. Mass. · 2024 · confidence medium
Sensing v. Outback Steakhouse of Fla., LLC, 575 F.3d 145, 153 (1st Cir. 2009) (“The guidelines represent the MCAD’s interpretation of [Chapter] 151B, and are entitled to substantial deference, even though they do not carry the force of law.”). 11 “The analysis of when and under what conditions diabetes is considered a disability for ADA purposes is a matter of degree.” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 34 (1st Cir. 2010).
discussed Cited as authority (rule) Lieber v. Marquis Management, LLC
D.N.H. · 2023 · confidence medium
“The employer’s burden is ‘one of production, not persuasion.’” Carreras v. Sajo, García & Partners, 596 F.3d 25, 36 (1st Cir. 2010) (quoting Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 142 (2000)).
discussed Cited as authority (rule) Daniel P. Lieber v. P Marquis Management, LLC, et al
D.N.H. · 2023 · confidence medium
“The employer’s burden is ‘one of production, not persuasion.’” Carreras v. Sajo, García & Partners, 596 F.3d 25, 36 (1st Cir. 2010) (quoting Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 142 (2000)).
cited Cited as authority (rule) Rae v. Woburn Public Schools
D. Mass. · 2023 · confidence medium
Elizabeth B. v. Esposito, 675 F.3d 26, 41 (1st Cir. 2012) (citing Carreras v. Sajo, García & Partners, 596 F.3d 25, 35 (1st Cir. 2010); Reinhardt v. Albuquerque Pub.
discussed Cited as authority (rule) Equal Employment Opportunity Commission v. Citizens Bank, N.A.
D.R.I. · 2023 · confidence medium
Rather, the Court “must determine the existence of a disability on a case-by-case basis. . . . [It] must assess the effect of [the employee’s] alleged impairment on his life, rather than relying on his diagnoses alone, in order to determine whether he is disabled within the meaning of the ADA.” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 33 (1st Cir. 2010) (internal quotation mark and citation omitted).
discussed Cited as authority (rule) Falmouth School Department v. Mr. and Mrs. Doe
1st Cir. · 2022 · signal: cf. · confidence medium
Cf. Carreras v. Sajo, García & Partners, 596 F.3d 25, 38 (1st Cir. 2010) (noting that, in the employment context, "suspicions raised by temporal proximity 'can be authoritatively dispelled . . . by an employer's convincing account of the legitimate reasons for the firing'" (ellipses in original) (quoting Holloway v. Thompson Island Outward Bound Educ.
discussed Cited as authority (rule) Sheridan v. Centerra Group LLC (2×)
D.P.R. · 2022 · confidence medium
Carreras v. Sajo, García & Partners, 596 F.3d 25, 35 (1st Cir. 2010).
discussed Cited as authority (rule) Kuc v. Smith & Nephew, Inc.
D. Mass. · 2022 · confidence medium
(ECF No. 43-7). legitimate reasons such that a factfinder could infer that the employer did not act for the asserted non-discriminatory reasons.” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 37 (1st Cir. 2010) (quotations marks and emphasis omitted).
discussed Cited as authority (rule) Leah Wallace, Plaintiff v. New Hampshire Ball Bearings, Inc., Defendant (2×) also: Cited "see"
D.N.H. · 2022 · confidence medium
“Once a plaintiff makes out a prima facie case of retaliation, the burden shifts to the employer to articulate a legitimate, nondiscriminatory reason for its employment decision.” Carreras, 596 F.3d at 36 (quotations and citations omitted).
discussed Cited as authority (rule) Wallace v. New Hampshire Ball Bearings, Inc. (2×) also: Cited "see"
D.N.H. · 2022 · confidence medium
“Once a plaintiff makes out a prima facie case of retaliation, the burden shifts to the employer to articulate a legitimate, nondiscriminatory reason for its employment decision.” Carreras, 596 F.3d at 36 (quotations and citations omitted).
discussed Cited as authority (rule) Brown v. US Department of Veterans Affairs, Secretary
D.N.H. · 2021 · confidence medium
LP, 856 F.3d 119, 138 (1st Cir. 2017) (alterations omitted) (quoting Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 38 (1st Cir. 2010)); see Sanchez- Rodriguez v. AT & T Mobility P.R., Inc., 673 F.3d 1, 15 (1st Cir. 2012) (affirming grant of summary judgment on retaliation claim where plaintiff’s only evidence of pretext was temporal proximity between protected conduct and adverse employment action); Mariani-Colon, 511 F.3d at 224 (same); Calero-Cerezo v. U.S. Dep’t of Just., 355 F.3d 6, 25-26 (1st Cir. 2004) (same); Hodgens, 144 F.3d at 170-71 (same); see also Holloway v. Thompson Isla…
discussed Cited as authority (rule) Deana Brown v. Denis McDonough, Secretary, U.S. Department of Veterans Affairs
D.N.H. · 2021 · confidence medium
LP, 856 F.3d 119, 138 (1st Cir. 2017) (alterations omitted) (quoting Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 38 (1st Cir. 2010)); see Sanchez- Rodriguez v. AT & T Mobility P.R., Inc., 673 F.3d 1, 15 (1st Cir. 2012) (affirming grant of summary judgment on retaliation claim where plaintiff’s only evidence of pretext was temporal proximity between protected conduct and adverse employment action); Mariani-Colon, 511 F.3d at 224 (same); Calero-Cerezo v. U.S. Dep’t of Just., 355 F.3d 6, 25-26 (1st Cir. 2004) (same); Hodgens, 144 F.3d at 170-71 (same); see also Holloway v. Thompson Isla…
discussed Cited as authority (rule) Snell v. Neville (2×) also: Cited "see"
1st Cir. · 2021 · confidence medium
While it is correct that temporal proximity between a protected action (such as filing grievances) and the adverse action (terminating Snell's use of the Terminal) can, at times, demonstrate causation, see Esposito, 675 F.3d at 42 (quoting Carreras v. Sajo, García & Partners, 596 F.3d 25, 38 (1st Cir. 2010)), the proximity fails to do so in this instance.
cited Cited as authority (rule) Lazarre v. Turco
D. Mass. · 2020 · confidence medium
Carreras v. Sajo Garcia & Partners, 596 F.3d 25, 35 (1st Cir. 2010).
discussed Cited as authority (rule) Abbey Cayman Asset Company v. The Estate of Nitza Milagros Marrero Robles
D.P.R. · 2020 · confidence medium
As such, Rule 56 “prevents parties from improperly shift[ing] the burden of organizing 24 1 the evidence presented in a given case to the district court.” Carreras v. Sajo, Garcia & Partners, 2 596 F.3d 25, 31 (1st Cir. 2010)(citing Mariani-Colón, 511 F.3d at 219 ) (internal quotation 3 marks omitted).
discussed Cited as authority (rule) Lima v. Middlesex Sheriff's Office (2×)
D. Mass. · 2020 · confidence medium
“Once a plaintiff makes out a prima facie case of retaliation, ‘the burden shifts to the employer to articulate a legitimate, nondiscriminatory reason for its employment decision.’” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 36 (1st Cir. 2010), quoting Wright, 352 F.3d at 478 (citation and quotation marks omitted).
discussed Cited as authority (rule) Smith v. Holder
E.D. Mo. · 2020 · confidence medium
See Griffin v. United Parcel Serv., Inc., 661 F.3d 216, 223 (5th Cir. 2011) (finding that the analysis of when and under what conditions diabetes is considered a disability is a matter of degree); Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 33-35 (1st Cir. 2010) (finding that the existence of a disability is fact- intensive and individualized and in this case, the plaintiff’s diabetes did not qualify as a disability because it did not substantially limit a major life activity); Lawson v. CSX Transp., Inc., 245 F.3d 916, 923-26 (7th Cir. 2001) (finding the plaintiff’s insulin-dependen…
cited Cited as authority (rule) MCLEAN v. DELHAIZE AMERICA DISTRIBUTION LLC
D. Me. · 2019 · confidence medium
Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 37 (1st Cir. 2010) (internal citations and quotations omitted).
discussed Cited as authority (rule) BAILEY v. DAL GLOBAL SERVICES LLC
D. Me. · 2019 · confidence medium
Likewise, to successfully allege a claim of retaliation under the MHRA, Bailey must meet the criteria for an ADA claim: “(1) that he engaged in protected conduct, (2) that he suffered an adverse employment action, and (3) that there was a causal connection between the protected conduct and the adverse employment action.” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 35 (1st Cir. 2010); see also Soileau v. Guilford of Maine, Inc., 928 F. Supp. 37, 45 (D.
discussed Cited as authority (rule) Brader v. Biogen Inc.
D. Mass. · 2019 · confidence medium
“Once a plaintiff makes out a prima facie case of retaliation, ‘the burden shifts to the employer to articulate a legitimate, nondiscriminatory reason for its employment decision.’” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 36 (1st Cir., 2010) (quoting Wright v. CompUSA, Inc., 352 F.3d 472, 478 (1st Cir. 2003)).
discussed Cited as authority (rule) Barlatier v. Local Motion, Inc.
D. Mass. · 2018 · confidence medium
“To be substantially limiting, an impairment must cause a person to be ‘unable to perform a major life activity that an average person in the general population can perform,’ or to be significantly restricted in the performance of a particular major life activity as compared to an average person in the general population.” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 33 (1st Cir. 2010) (quoting 29 C.F.R. § 1630.2 (j)(1)).
discussed Cited as authority (rule) Hagenah v. Berkshire County ARC, Inc.
D. Mass. · 2018 · confidence medium
Elizabeth B., 675 F.3d at 42 ("[C]lose temporal proximity between protected conduct and an adverse action sometimes 'may suffice for a prima facie case of retaliation.'") (quoting Carreras v. Sajo, García & Partners, 596 F.3d 25, 38 (1st Cir. 2010)).
discussed Cited as authority (rule) Gazco-Hernandez v. Neffenger
usdistct · 2018 · confidence medium
"An employee can establish pretext 'by showing weaknesses, implausibilities, inconsistencies, incoherencies, or contradictions in the employer's proffered legitimate reasons such that a factfinder could infer that the employer did not act for the asserted non-discriminatory reasons.' " Carreras , 596 F.3d at 37 (emphasis in original) (citing Santiago-Ramos , 217 F.3d at 56 ).
discussed Cited as authority (rule) Pérez v. Oriental Bank & Trust
usdistct · 2018 · confidence medium
"An employee can establish pretext 'by showing weaknesses, implausibilities, inconsistencies, incoherencies, or contradictions in the employer's proffered legitimate reasons such that a factfinder could infer that the employer did not act for the asserted non-discriminatory reasons.' " Carreras , 596 F.3d at 37 (emphasis in original) (citing Santiago-Ramos , 217 F.3d 46 , 56 (1st Cir. 2000) ).
discussed Cited as authority (rule) Caez-Fermaint v. State Ins. Fund Corp.
usdistct · 2017 · confidence medium
"An employee can establish pretext 'by showing weaknesses, implausibilities, inconsistencies, incoherencies, or contradictions in the employer's proffered legitimate reasons such that a factfinder could infer that the employer did not act for the asserted non-discriminatory reasons.' " Carreras , 596 F.3d at 37 (emphasis in original) (citing Santiago-Ramos v. Centennial P.R.
examined Cited as authority (rule) Borges v. El Conquistador Partnership (3×) also: Cited "see"
D.P.R. · 2017 · confidence medium
“It prevents parties from ‘improperly shifting] the burden of organizing the evidence presented in a given case to the district court.’ ” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 31 (1st Cir. 2010) (citing Mariani-Colón v. Dep’t of Homeland Sec., 511 F.3d 216, 219 (1st Cir. 2007)).
examined Cited as authority (rule) Delgado-Echevarria v. AstraZeneca Pharmaceuticals LP (4×)
1st Cir. · 2017 · confidence medium
Delgado “bears the ultimate burden to create a plausible inference that the employer had a retaliatory motive.” Carreras v. Sajo, García & Partners, 596 F.3d 25, 36 (1st Cir. 2010).
discussed Cited as authority (rule) Ortiz-Martínez v. Fresenius Health Partners, PR, LLC
1st Cir. · 2017 · confidence medium
Carreras v. Sajo, García & Partners, 596 F.3d 25, 32 (1st Cir. 2010) (citing Cabán Hernández v. Philip Morris USA, Inc., 486 F.3d 1, 8 (1st Cir. 2007)).
discussed Cited as authority (rule) Padro Octaviani v. GlaxoSmithKline Consumer Healthcare
D.P.R. · 2017 · confidence medium
“We ‘draw all reasonable inferences in the light most favorable to the nonmovant.’ We will not, however, ‘draw unreasonable inferences or credit bald assertions, empty conclusions, [or] rank conjecture.’” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 32 (1st Cir. 2010) (emphasis in original) (citing Gabán Hernandez v. Philip Morris USA, Inc., 486 F.3d 1, 8 (1st Cir. 2007)); see also Smith v. Jenkins, 732 F.3d 51, 76 (1st Cir. 2013) (reiterating Shafmaster v. United States, 707 F.3d 130, 135 (1st Cir. 2013)).
discussed Cited as authority (rule) Vazquez-Robles v. Commoloco, Inc.
D.P.R. · 2016 · confidence medium
A plaintiff may rely on “very close temporal proximity between the protected action by the employee and the adverse employment action by the employer [to] give rise to an inference of causation.” Valle-Arce, 651 F.3d at 199 ; see Sanchez-Rodriguez v. AT & T Mobility P.R., Inc., 673 F.3d 1, 16 (1st Cir.2012) (holding that span of three months between filing EEOC complaint and being disciplined was “close enough to suggest causation”); Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 38 (1st Cir. 2010) (holding that span of four days between requesting reasonable accommodation and being…
cited Cited as authority (rule) Maldonado-Cátala v. Municipality of Naranjito
D.P.R. · 2015 · confidence medium
Facts that do not directly qualify or refute those proffered by the movant must be submitted in a separate section, Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 32 (1st Cir.2010) (citing D.P.R.
discussed Cited as authority (rule) Flovac, Inc. v. Airvac, Inc.
D.P.R. · 2015 · confidence medium
Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 31 (1st Cir.2010); see also Nieves v. Univ. of P.R., 7 F.3d 270, 280 (1st Cir.1993) (“[A] party may not generate a trial-worthy dis pute at summary judgment merely by presenting unsubstantiated allegations in its memoranda”)- At any rate, this proffer explains neither why nor how vacuum sewer systems are more suitable in these areas; and even assuming that it did, it sheds no light on what these areas share in common- that would exclude the other kinds of sewer systems.
discussed Cited as authority (rule) Parker v. Accellent
D.N.H. · 2014 · confidence medium
To make out a claim of retaliation under the ADA, “a plaintiff must show (1) that he engaged in protected conduct, (2) that he suffered an adverse employment action, and (3) that there was a causal connection between the protected conduct and the adverse employment action.” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 35 (1st Cir. 2010); see also Madeja, 149 N.H. at 379 (applying New Hampshire law).
cited Cited as authority (rule) Williams v. Robert F. Kennedy Children's Action Corp.
D. Mass. · 2014 · confidence medium
Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 32 (1st Cir.2010).
examined Cited as authority (rule) Akerson v. Pritzker (3×) also: Cited "see, e.g."
D. Mass. · 2013 · confidence medium
Disability under the Rehabilitation Act may be established under the “actual disability prong” through a showing of a physical or mental impairment which substantially limits one or more major life activities. 42 U.S.C. § 12102 (1); Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 33 (1st Cir.2010).
discussed Cited as authority (rule) Gonzalez v. Sears Holding Co.
D.P.R. · 2013 · confidence medium
Carreras v. Sajo, García & Partners, 596 F.3d 25, 33 (1st Cir.2010) (“To be substantially limiting, an impairment must cause a person to be ‘unable to perform a major life activity as compared to an average person in the general population.’ 29 C.F.R. § 1630.2 (j)(l)”).
discussed Cited as authority (rule) Floyd v. Office of Representative Sheila Jackson Lee
D.D.C. · 2013 · confidence medium
The First Circuit now says that “[i]t is well established that ‘requesting an accommodation, without filing a formal charge or engaging in other specific behaviors listed in § 12203(a), is ... behavior protected from an employer’s retaliation.’ ” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 35-36 (1st Cir.2010) (quoting Wright v. CompUSA Inc., 352 F.3d 472, 477-78 (1st Cir.2003)).
discussed Cited as authority (rule) Kelley v. Correctional Medical Services, Inc.
1st Cir. · 2013 · confidence medium
To survive summary judgment on a retaliation claim, the plaintiff “must establish a genuine issue of material fact as to whether [s]he ... was retaliated-against within the meaning of the ADA.” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 32 (1st Cir.2010) (citing Fed.R.Civ.P. 56(c)). 12 We review the district court’s grant of summary judgment de novo.
discussed Cited as authority (rule) Goonan v. Federal Reserve Bank
S.D.N.Y. · 2013 · confidence medium
“It is well established that ‘requesting an accommodation ... [is] behavior protected from an employer’s retaliation.” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 35-36 (1st Cir. 2010) (quoting Wrigh t v. CompUSA, Inc., 352 F.3d 472, 477-78 (1st Cir. 2003)).
discussed Cited as authority (rule) Ahmed v. Napolitano
D. Mass. · 2012 · confidence medium
It is true that “[a]n employee can establish pretext ‘by showing weaknesses, implausibilities, inconsistencies, incoherencies, or contradictions in the employer’s proffered legitimate reasons such that a factfinder could infer that the employer did not act for the asserted non-discriminatory reasons.’ ” Carreras v. Sajo, Garcia & Partners, 596 F.3d 25, 37 (1st Cir. 2010) (quoting Santiago-Ramos v. Centennial P.R.
cited Cited as authority (rule) Hall v. Mid-State Machine Products
D. Me. · 2012 · confidence medium
The problem with these arguments is that “[t]he evidence was consistent on the essential point.” Carreras v. Sajo, 596 F.3d 25, 37 (1st Cir.2010).
cited Cited as authority (rule) Jones v. Walgreen Co.
1st Cir. · 2012 · confidence medium
See Colón-Fontánez v. Municipality of San Juan, 660 F.3d 17, 36 (1st Cir.2011); Carreras v. Sajo, García & Partners, 596 F.3d 25, 35-36 (1st Cir.2010).
LIPEZ, Circuit Judge.

In this workplace discrimination and retaliation suit, the district court ruled that plaintiff, Erick Carreras, failed to comply with Puerto Rico’s anti-ferret rule, D.P.R.R. 56(c). On this basis, it deemed as admitted portions of defendant Sajo, García & Partners’ (“SGP”) statement of uncontested facts and granted summary judgment to defendant. Carreras argues on appeal that the district court improperly invoked Local Rule 56 and erred in rejecting his claims under the Americans with Disabilities Act of 1990, 42 U.S.C. §§ 12101-12213 (“ADA”), and various Puerto Rico anti-discrimination laws. We disagree and affirm.

I.

We begin with a recitation of the basic facts underlying the dispute, derived from the facts explicitly admitted by Carreras. SGP, a marketing agency, hired Carreras as an Art Director in December 2003. Carreras’ responsibilities included preparing the creative art for products being marketed by SGP. In August 2004, Carrer[*30] as and Sajo Ruiz, an SGP partner, exchanged heated emails about Carreras’ alleged failure to complete work on time. [1] Carreras has type II diabetes, which he controls by taking insulin every morning and evening. At the commencement of his employment with SGP, Carreras filled out a form on which he indicated that he had diabetes and was dependent on insulin.

On October 21, 2004, Carreras emailed Ruiz informing him that he had worked late that evening and had been prevented from taking his insulin shot. Ruiz replied the next morning asking Carreras to clarify what had prevented him from taking his medicine and stating that there should be no obstacle to Carreras taking his treatment. In response, Carreras stated that he was prevented from administering his medicine because he had to stay late at the office. [2] SGP terminated Carreras’ employment on October 25, 2004.

Carreras filed suit against SGP alleging that he had experienced discrimination based on his disability and retaliation for requesting a reasonable accommodation in violation of the ADA. 42 U.S.C. §§ 12101-12213. After discovery was complete, SGP moved for summary judgment and filed a separate Statement of Uncontested Facts in support of its motion. In response, Carreras submitted a document styled as “Plaintiffs Response and Objections to Defendant’s Proposed Statement of Uncontested Facts.” The district court found that statement to be defective under Puerto Rico Local Rule 56 because it failed to admit, qualify or deny certain facts proposed by SGP, it did not contain a separate section for the new facts it sought to introduce, and it did not contain appropriate citation to the record to support denied facts.

In accordance with the anti-ferret rule, the district court disregarded those portions of Carreras’ opposition it found defective and deemed as admitted many of SGP’s properly supported facts. See D.P.R.R. 56(e). With its recitation of the facts in its written opinion, the district court made clear the facts it deemed admitted. The court focused primarily on those facts pertaining to the effect, or lack thereof, of Carreras’ diabetes on his work and daily life. In a footnote, the court explained that “the reason for [Carreras’] dismissal is in dispute. However, because it is immaterial for the resolution of this case, we will eschew any discussion in this regard.” Hence, the court’s recitation of “Uncontested Facts” in its opinion, where it sets forth the effect of its deeming analysis on the summary judgment record, does not focus on the retaliation claim.

After making its deeming determination, the district court granted summary judgment to SGP based on Carreras’ failure to create a genuine issue of material fact as to whether he is disabled within the meaning of the ADA. The court noted, however, that even if Carreras qualified as disabled, his arguments that SGP failed to accommodate his disability must fail because Carreras had neither requested nor been denied accommodation. For the same reason, the district court rejected Carreras’ claim that he was retaliated against for making a request for reasonable accommodation.

[*31] Carreras appeals, contending that his statement complied with the local rule and that the district court erred in granting summary judgment based on its deeming order.

II.

Carreras argues that the district court improperly applied Local Rule 56(c), the District of Puerto Rico’s anti-ferret rule. The rule states, in relevant part:

A party opposing a motion for summary judgment shall submit with its opposition a separate, short, and concise statement of material facts. The opposing statement shall admit, deny or qualify the facts by reference to each numbered paragraph of the moving party’s statement of material facts and unless a fact is admitted, shall support each denial or qualification by a record citation as required by this rule. The opposing statement may contain in a separate section additional facts, set forth in separate numbered paragraphs and supported by a record citation as required by subsection (e) of this rule.

D.P.R.R. 56(c). Subsection (e) of the rule states that citations must be “to the specific page or paragraph of identified record material supporting the assertion.” D.P.R.R. 56(e). Failure to comply with the anti-ferret rule permits the court to “disregard any statement of fact not supported by a specific citation to record material properly considered on summary judgment.” D.P.R.R. 56(e). We review the district court’s application of a local rule for abuse of discretion. See Sánchez-Figueroa v. Banco Popular de Puerto Rico, 527 F.3d 209, 213 (1st Cir.2008). While a district court may choose not to invoke the rule in response to every violation, we have consistently upheld the enforcement of the rule, and we treat the district court’s decision to apply it with deference. See CMI Capital Market Inv. v. González-Toro, 520 F.3d 58, 62-63 (1st Cir.2008); Mariani-Colón v. Dep’t of Homeland Sec., 511 F.3d 216, 219 (1st Cir.2007); Cabán Hernández v. Philip Morris USA, Inc., 486 F.3d 1, 7 (1st Cir. 2007). The rule is intended “to relieve the district court of any responsibility to ferret through the record to discern whether any material fact is genuinely in dispute.” CMI Capital Market, 520 F.3d at 62. It prevents parties from “improperly shifting] the burden of organizing the evidence presented in a given case to the district court.” Mariani-Colón, 511 F.3d at 219. As such, the rule is important to the functioning of the district court.

Here, Carreras did submit a response to SGP’s Statement of Uncontested Facts. Although he argues that his response properly accepted or denied every fact with appropriate citation, Carreras properly denied only certain of SGP’s facts. Accordingly, the district court stated that it would “partially disregard” Carreras’ opposing statement of uncontested facts. [3] The record shows that in many instances Carreras’ response manifestly ignores the express requirements of the anti-ferret rule. Most blatantly, in at least two in[*32] stances, Carreras’ opposition fails to “accept, qualify or deny” the fact listed by his opponent. Instead, it explains discursively why Carreras believes the fact to be irrelevant. Furthermore, Carreras’ opposition frequently fails to support denied facts with appropriate citation to the record.

Finally, Carreras’ response includes argumentation asserting numerous additional facts. Those facts are often unsupported by record citations, they are not numbered, and they are not “contain[ed] in a separate section.” Carreras’ argument that the rule does not require additional facts to be adduced in a separate section is unavailing. The plain language of the rule specifically requires that additional facts be put forward in a “separate section.” D.P.R.R. 56(c). In light of these substantial failings, the district court acted well within its discretion when it deemed as admitted a portion of SGP’s properly supported facts.

III.

To survive summary judgment on his discrimination and retaliation claims, Carreras must establish a genuine issue of material fact as to whether he experienced disability discrimination or was retaliated-against within the meaning of the ADA. Fed.R.Civ.P. 56(c). [4] Our review of the district court’s grant of summary judgment is de novo. Cabán-Hernández, 486 F.3d at 8. We “draw all reasonable inferences in the light most favorable to the nonmovant.” Id. We will not, however, “draw unreasonable inferences or credit bald assertions, empty conclusions, [or] rank conjecture.” Id. (emphasis in original).

A. Disability Discrimination under the ADA

The district court found that Carreras failed to establish a prima facie ease of discrimination under the ADA because he could not establish that he is disabled within the meaning of the statute. Under the ADA, a disability is defined as: (a) a physical or mental impairment which substantially limits one or more of an individual’s major life activities; (b) a record of such impairment; or (c) being regarded as having such an impairment. 42 U.S.C. § 12102(1). [5] We have employed a three-part test to determine whether an individual qualifies as disabled under the first definition, which is at issue here. First, does the plaintiff suffer a mental or physical impairment? Second, does the life activity limited by the impairment qualify as “major”? And finally, does the impairment, in fact, substantially limit that major life activity? See Calero-Cerezo, 355 F.3d at 20. The burden is on the plaintiff to establish these three elements. Id. Carr-eras contends that he is disabled because his diabetes is a physical impairment that substantially limits his ability to eat and see, two major life activities.

[*33] We must determine the existence of a disability “on a case-by-case basis.” Albertson’s, Inc. v. Kirkingburg, 527 U.S. 555, 566, 119 S.Ct. 2162, 144 L.Ed.2d 518 (1999). Thus, we must assess the effect of Carreras’ alleged impairment on his life, rather than relying on his diagnoses alone, in order to determine whether he is disabled within the meaning of the ADA. Id. We agree with Carreras that insulin-dependent diabetes is a physical impairment. See, e.g., Rohr v. Salt River Project Agric. Improvements and Power Dist., 555 F.3d 850, 858 (9th Cir.2009) (“Diabetes is a ‘physical impairment’ because it affects the digestive, hemic and endocrine systems.... ”). It is similarly beyond dispute that eating and seeing qualify as “major life activities.” See, e.g., Gillen v. Fallon Ambulance Serv., Inc., 283 F.3d 11, 21 (1st Cir.2002) (major life activities include “functions such as caring for oneself, ... seeing”); Calero-Cerezo, 355 F.3d at 21 (recognizing eating as a major life activity for purposes of the ADA).

We cannot agree, however, that on the record before us there is any genuine issue of material fact as to whether Carreras’ diabetes “substantially limited” his ability to eat or to see. “The ADA does not define ‘substantially limits,’ but ‘substantially’ suggests ‘considerable’ or ‘specified to a large degree.’ ” Sutton v. United Air Lines, Inc., 527 U.S. 471, 491, 119 S.Ct. 2139, 144 L.Ed.2d 450 (1999), superseded by statute on other grounds, ADA Amendments Act of 2008, Pub.L. No. 110-325, 172 Stat. 3553 (2008). To be substantially limiting, an impairment must cause a person to be “unable to perform a major life activity that an average person in the general population can perform,” or to be significantly restricted in the performance of a particular major life activity as compared to an average person in the general population. 29 C.F.R. § 1630.2(j)(l); see also Carroll v. Xerox Corp., 294 F.3d 231, 239 (1st Cir.2002). [6] In assessing in this case the degree of limitation occasioned by a physical impairment, we also take into consideration “the effectiveness, side effects and burdens of a plaintiffs mitigating measures,” in this case Carreras’ twice-daily insulin shots. Rohr, 555 F.3d at 859 (citing Sutton, 527 U.S. at 482-84, 119 S.Ct. 2139). [7] Our inquiry is “fact-intensive and individualized.” Sepulveda v. Glickman, 167 F.Supp.2d 186, 191 (D.P.R.2001); Sutton, 527 U.S. at 483, 119 S.Ct. 2139.

[*34] 1. Carreras’ claim that his diabetes substantially limits his vision

The facts of record fail to create a genuine issue of material fact as to whether Carreras’ vision is substantially limited by his diabetes. Carreras asserts that high blood sugar levels cause his vision to blur, constituting a substantial limitation under the ADA. He does not contest, however, that his latest blurred vision episode occurred a year before he was deposed in this case. Nor does he set forth facts that would explain how such infrequent episodes of blurred vision cause him to be significantly restricted in his ability to see. “To qualify as disabling, a limitation ... must be permanent or long term, and considerable compared to the [seeing] most people do in their daily lives.” Fredricksen v. United Parcel Serv., Co., 581 F.3d 516, 522 (7th Cir.2009) (citation and quotation marks omitted).

The facts show that Carreras’ ability to see does not differ in a significant way from the ability to see of the general population. Cf. Albertson’s, Inc., v. Kirkingburg, 527 U.S. 555, 565-67, 119 S.Ct. 2162, 144 L.Ed.2d 518 (1999) (finding that monocular individuals must “prove a disability by offering evidence that the extent of the limitation in terms of their own experience, as in loss of depth perception and visual field, is substantial”); Kelly v. Drexel Univ., 94 F.3d 102, 106, 108 (3d Cir.1996) (finding plaintiffs limp and inability to walk more than a mile or jog did not “substantially limit him in the relevant major life activity, walking”). It is undisputed that Carreras drives his son to school and himself to work every morning, drives home again in the evening, reads as part of his current employment, and performs other routine daily activities that presumably would not be possible if his vision were substantially impaired. See Scheerer v. Potter, 443 F.3d 916, 920 (7th Cir.2006) (finding diabetic with “intermittent episodes of significant neuropathy” not substantially limited in his ability to walk because “he nonetheless was generally able to walk and stand during the pertinent time period”). As described in the record, Carreras’ diabetes does not limit his sight to a degree that would differentiate him from the rest of the population.

2. Carreras’ claim that his diabetes substantially limits his eating

Carreras has also failed to raise a genuine issue of material fact as to whether his diabetes substantially limits his life activity of eating. It is undisputed that Carreras’ diabetes requires certain adjustments to his diet. He avoids refined flours, drinks juice that is not artificially sweetened, and eats six meals a day. Proof that a medical condition “requires medication, a fixed meal schedule, [and] timely snack breaks,” without more, does not amount to a “substantial limitation” under the ADA. Sepulveda, 167 F.Supp.2d at 191 (quotation marks omitted).

The analysis of when and under what conditions diabetes is considered a disability for ADA purposes “is a matter of degree.” Id. at 190. We recognize that living with diabetes may result in a complex calculus balancing food intake, activity level, and the amount of insulin administered. An individual living with diabetes may or may not experience a substantial limitation in his or her ability to eat as contrasted with the rest of the population. See, e.g., Lawson v. CSX Transp., Inc., 245 F.3d 916, 924 (7th Cir.2001) (describing substantial limitation on eating entailed by “perpetual, multi-faceted and demanding treatment regime” for plaintiffs diabetes (quotation marks omitted)); Rohr, 555 F.3d at 859 (finding genuine issue of material fact as to whether plaintiff had a substantial impairment in eating where he[*35] described controlling his disease through a combination of diet and insulin as “being on a chemical rollercoaster” (quotation marks omitted)). Many diabetics follow a “severely restrictive, and highly demanding” regimen to control their disease from which any deviation could result in a trip to the emergency room. See Fraser v. Goodale, 342 F.3d 1032, 1041 (9th Cir. 2003).

The record indicates, however, that Carreras is at the far end of the spectrum from those plaintiffs who “cannot put a morsel of food” into their mouths “without carefully assessing whether it will tip [their] blood sugar[ ]” levels. Id. 8 He does not dispute that his twice daily insulin shots successfully control his diabetes. Cf. Lawson, 245 F.3d at 924 (finding jury question as to whether diabetic could meet the substantial limitation threshold because “even when taking insulin, [plaintiffs] ‘ability to regulate his blood sugar and metabolize food is difficult, erratic, and substantially limited’ ”). Indeed, the facts are that, by taking two insulin shots each day and eating fairly often, Carreras succeeds in preventing his diabetes from substantially limiting any of his major life activities. Compare Sutton, 527 U.S. at 488-89, 119 S.Ct. 2139 (the wearing of corrective lenses to neutralize the effects of myopia negated substantial impairment of vision caused by plaintiffs disability) with Lawson, 245 F.3d at 925-26 (the need to coordinate “multifaceted factors” and to maintain “constant vigilance” over plaintiffs insulin regimen, coupled with the grave effects of noncompliance, distinguished plaintiffs case from Sutton).

3. Summary

In summary, Carreras adduces no evidence that his diabetes causes more than minor limitations on his eating and seeing. See Rohr, 555 F.3d at 860 (“If daily insulin injections alone more or less stabilized [plaintiffs] blood sugar levels, such that any limitation imposed on his diet would be minor, then [his] major life activity of eating might not be substantially limited.”). We therefore agree with the district court that Carreras has not raised a genuine issue of material fact as to whether he is disabled under the ADA.

B. Retaliation under the ADA [9]

The retaliation provision in the ADA states that “[n]o person shall discriminate against any individual because such individual has opposed any act or practice made unlawful by this chapter.” 42 U.S.C. § 12203(a). In order to establish a claim of retaliation under the ADA, a plaintiff must show (1) that he engaged in protected conduct, (2) that he suffered an adverse employment action, and (3) that there was a causal connection between the protected conduct and the adverse employment action. Soileau v. Guilford of Maine, Inc., 105 F.3d 12, 16 (1st Cir.1997). [10] It is well established that “requesting an accommodation, without filing a formal charge or engaging in other specific behaviors listed in § 12203(a), is nonetheless behavior protected from an[*36] employer’s retaliation.” Wright v. CompUSA Inc., 352 F.3d 472, 477-78 (1st Cir. 2003). Even if he fails to bring a successful disability claim under the ADA, a plaintiff may nonetheless assert a claim for retaliation. Soileau, 105 F.3d at 16.

Once a plaintiff makes out a prima facie case of retaliation, “the burden shifts to the employer to articulate a legitimate, nondiscriminatory reason for its employment decision.” Wright, 352 F.3d at 478 (citation and quotation marks omitted); see also McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-804, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973) (establishing burden-shifting framework for Title VII cases). The employer’s burden is “one of production, not persuasion.” Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 142, 120 S.Ct. 2097, 147 L.Ed.2d 105 (2000). If the employer produces a legitimate reason for its decision, “the burden under McDonnell Douglas shifts back to the plaintiff to show that the motive was discriminatory [or retaliatory].” Sabinson v. Trs. of Dartmouth Coll., 542 F.3d 1, 4 (1st Cir.2008) (citing Reeves, 530 U.S. at 142-43, 120 S.Ct. 2097); see also Kersey v. Wash. Metro. Area Transit Auth., 586 F.3d 13, 17 (D.C.Cir.2009). Thus, the plaintiff bears the ultimate burden to create a plausible inference that the employer had a retaliatory motive. Benoit v. Technical Mfg. Corp., 331 F.3d 166, 174 (1st Cir.2003).

Carreras argues that his email to Ruiz and three other SGP supervisors sent on October 21, 2004, in which he informed them that he had to work late and had been prevented from taking his insulin shot, constituted a request for a reasonable accommodation under the ADA. [11] He contends that his firing on October 25, 2004 was a direct result of that request for accommodation. He asserts that he is entitled to an inference of causal connection between the two events because his termination occurred in such close temporal proximity to his engaging in protected conduct.

The district court found that Carreras had not requested an accommodation within the meaning of the ADA and granted summary judgment for SGP on the claim of retaliation. We affirm that judgment, albeit on different grounds. See Estades-Negroni v. Assocs. Corp. of North Am., 377 F.3d 58, 62 (1st Cir.2004) (“We may affirm ... on any grounds supported by the record.”).

For convenience we assume, without deciding, that Carreras has made his prima facie case. As noted, once an employee has made a prima facie showing of retaliation, the burden shifts to the employer to produce evidence that there was a legitimate, non-retaliatory motive for the adverse employment action. Wright, 352 F.3d at 478. SGP has met its burden. SGP claims that Carreras’ deficient performance and insubordination prompted the SGP partners to terminate his employment. In support of its claim, SGP introduced the email from Ruiz to Carreras. That email, written in all capital letters and dated August 25, 2004, reads, in relevant part:

IT IS VERY FRUSTRATING TO NOT BE ABLE TO COUNT ON YOUR PRESENCE WHEN I MOST NEED YOU. I CERTAINLY UNDERSTAND THE UNEXPECTED, BUT IT ALWAYS HAPPENS THAT WHEN I[*37] HAVE A MEETING WITH A CLIENT, I AM MISSING THE UNFINISHED MATERIAL; AND THE RESPONSIBLE PERSON HAS A PERSONAL ISSUE TO SOLVE. [12]

IN THE FUTURE, CALL ME DIRECTLY AT THE CELL PHONE OR AT MY HOME, AND I’LL COME AND FINISH THE ART EVEN IF I HAVE TO WORK ALL NIGHT.

This documentary evidence showing Ruiz’s dissatisfaction with Carreras meets SGP’s burden of producing evidence that demonstrates its legitimate, non-retaliatory reason for firing Carreras.

In the face of such evidence, Carr-eras bears the ultimate burden of establishing that SGP’s stated reason for his dismissal is a pretext for retaliation. Santiago-Ramos v. Centennial P.R. Wireless Corp., 217 F.3d 46, 54 (1st Cir.2000). Carreras attempts to meet this burden by pointing to what he characterizes as inconsistencies in statements given by SGP managers about the reason he was fired, when the decision to fire him was made, and why there was a delay between the making of that decision and the firing. Specifically, Carreras cites deposition testimony showing that two of three members of SGP’s management recalled that the decision to terminate Carreras was made in early-to-mid October, while another thought it was made at the end of September. Further, Carreras cites deposition testimony showing that one of those managers thought there was some delay between the decision and Carreras’ firing because Carreras might improve his performance in that time, a second thought it was in order to hire a replacement, and a third thought the delay involved the need to complete legal paperwork. Finally, in its Joint Initial Scheduling Conference Memorandum, SGP said the reason for Carreras’ firing was that his “output was not timely and up to the quality standards that defendant requested for him.” By contrast, Carreras argues, Ruiz stated in his deposition that Carreras did good work, but that he was fired because of “coworker complaints and because he was not getting his job done in time.” [13]

An employee can establish pretext “by showing weaknesses, implausibilities, inconsistencies, incoherencies, or contradictions in the employer’s proffered legitimate reasons such that a factfinder could infer that the employer did not act for the asserted non-discriminatory reasons.” Id. at 56 (quotation marks and citation omitted) (emphasis added). The minor inconsistencies cited by Carreras, however, do not undermine SGP’s contention that his work performance was unsatisfactory. The slight differences in SGP’s accounts of the timing of the decision or the reason for the short delay before its implementation do not permit a reasonable factfinder to infer that SGP did not fire Carreras because of his poor work performance. The evidence was consistent on the essential point, i.e., that Carreras’ work was untimely and therefore unsatisfactory. Our laws are designed to ensure against discrimination and retaliation, not “inaccuracy by an employer.” Rivas Rosado v. Radio Shack, Inc., 312 F.3d 532, 535 (1st Cir.2002). Moreover, the dissatisfaction with Carreras was expressed in writing two months[*38] before he complained about having to work late and was fired. This is not a case in which the employer’s “nondiscriminatory reasons were after-the-fact justifications, provided subsequent to the beginning of legal action.” Santiago-Ramos, 217 F.3d at 56.

In the final analysis, the only evidence in the summary judgment record supporting Carreras’ retaliation claim is the temporal proximity between his October 21, 2004 email to Ruiz and his firing on October 25, 2004. Such temporal proximity may suffice for a prima facie case of retaliation. It does not satisfy Carreras’ ultimate burden to establish that the true explanation for his firing was retaliation for engaging in protected conduct rather than poor performance. See Holloway, 275 Fed.Appx at 27 (suspicions raised by temporal proximity “can be authoritatively dispelled ... by an employer’s convincing account of the legitimate reasons for the firing”); see also Soileau, 105 F.3d at 16-17 (rejecting claim of retaliation based solely on temporal proximity). We affirm the entry of summary judgment for SGP on Carreras’ retaliation claim under the ADA. [14]

Affirmed.

1

. Although Carreras characterizes Ruiz's email as a tantrum, he does not deny that it was sent and that he replied.

2

. SGP's personnel manual listed working hours as 9 a.m. to 6 p.m., but expressly stated that working hours are irregular in the advertising industry and that all employees must be available when necessary during and/or after normal hours. The only storage requirement for Carreras' insulin was refrigeration. SGP had a refrigerator available to employees at its offices.

3

. Carreras argues that, despite its assertion to the contrary, the district court rejected his entire response to SGP's Statement of Uncontested Facts. We disagree. In its recitation of the facts, set forth in a portion of the opinion entitled "Uncontested Facts," the district court made clear which facts it considered to be uncontested with citations to the record signifying that certain of those facts were derived from SGP's Statement of Uncontested Facts. As noted, the court's focus in this recitation was on Carreras’ workplace discrimination claim, not his retaliation claim. The district court was under no obligation to go beyond the relevant facts, as it saw them, in order to catalogue the sufficiency of Carreras' opposition to every one of SGP's proposed facts.

4

. "A 'genuine' issue is one that could be resolved in favor of either party, and a 'material fact' is one that has the potential of affecting the outcome of the case.” Calero-Cerezo v. U.S. Dep’t of Justice, 355 F.3d 6, 19 (1st Cir.2004).

5

. Although Carreras states on appeal that he was regarded as having an impairment, he did not assert this argument below and we deem it to be waived. Even if Carreras had not waived this argument below, it would fail here because his brief contains no support for the claim. As we have explained on many occasions, " '[i]ssues adverted to in a perfunctory manner, unaccompanied by some effort at developed argumentation, are deemed waived.' ” United States v. Rivera Calderon, 578 F.3d 78, 94 n. 4 (1st Cir.2009) (quoting United States v. Zannino, 895 F.2d 1, 17 (1st Cir.1990)).

6

. In considering whether a litigant’s physical impairment is substantially limiting for purposes of the ADA, the inquiry is not confined to limitations that might occur in the workplace. Toyota Motor Mfg., Kentucky, Inc. v. Williams, 534 U.S. 184, 200-01, 122 S.Ct. 681, 151 L.Ed.2d 615 (2002), superseded by statute on other grounds, ADA Amendments Act of 2008, Pub.L. No. 110-325, 172 Stat. 3553 (2008). Rather, courts must focus on whether a major life activity is substantially impaired in the course of a litigant's daily life. Id. at 200-02.

7

. Carreras has made no argument about the effect of the ADA Amendments Act of 2008 on his claim. See Pub.L. No. 110-325, § 2(a)(4)-(6), 122 Stat. 3553 (2008). Regardless, that law is not retroactive where, as here, the disputed activity occurred before its passage and Congress expressed no clear intent to make the statute retroactive. We have recently suggested as much, see Thornton v. United Parcel Serv., Inc., 587 F.3d 27, 34 n. 3 (1st Cir.2009), and all circuits to consider the issue to date have so held. See Becerril v. Pima County Assessor’s Office, 587 F.3d 1162, 1164 (9th Cir.2009) (per curiam); Fredericksen v. United Parcel Serv., 581 F.3d 516, 521 n. 1 (7th Cir.2009); Lytes v. DC Water & Sewer Auth., 572 F.3d 936, 940 (D.C.Cir.2009); Milholland v. Summer County Bd. of Educ., 569 F.3d 562 (6th Cir.2009); E.E.O.C. v. Agro Distribution, LLC, 555 F.3d 462, 469 n. 8 (5th Cir.2009).

8

. Carreras' complaint states that failure to take his insulin causes headaches and an undefined “loss of control of his condition.”

9

. We note that the district court did not circumscribe the summary judgment record with a deeming order that applies to the retaliation claim.

10

.In Soileau, we explained that because of the relatedness of the two statutes, "guidance on the proper analysis of [an] ADA retaliation claim is found in Title VII cases.” 105 F.3d at 16. We therefore refer to cases interpreting Title VII’s retaliation provision as well as those specifically addressing the ADA in conducting our analysis of Carreras' retaliation claim.

11

. Carreras attempts to argue, in the alternative, that his email somehow constituted opposition to his employer’s "interference] with the treatment for his diabetes,” and that such opposition is protected conduct under the ADA. This claim is undeveloped and therefore waived. Even if it were not, our analysis of the retaliation claim would be the same.

12

. From Carreras’ response to this email, which is also in the record, we deduce that the "personal issue” to which Ruiz refers was Carreras’ failure to come to work on time because he did not have his glasses.

13

. Carreras also cites the lack of "written evidence” of any deficiencies in his performance during the months preceding his firing. In making this argument, Carreras overlooks the August 2004 email from Ruiz.

14

. We also affirm the district court’s dismissal without prejudice of Carreras’ claims arising under Puerto Rico law. See Penobscot Indian Nation v. Key Bank of Maine, 112 F.3d 538, 564 (1st Cir.1997) ("[T]he decision to retain or disclaim jurisdiction over the remaining state law claims at issue in this case lies in the broad discretion of the district court.”)