Explain the arrangement and provide the records needed to establish the actual employment relationship and work.
Reconcile rather than conceal the difference
Do not change names in supporting documents to make them match. Identify why each entity appears and which facts each record can establish.
Internal documents created in the ordinary course: validation and commissioning reports, procedure revision histories, training matrices, project files and correspondence identifying the employee as the source of the knowledge. Counsel can assess whether suitable employer records, detailed manager statements and carefully redacted examples establish the knowledge without unnecessary client identifiers. Supplement the paper with training records, project assignments, technical evaluations, and comparisons showing special or advanced company knowledge; authorship by itself is not the standard. Start with evidence that existed before the petition: training records, restricted technical material, version histories, project assignments, and letters explaining why comparable employees cannot simply take over. Search internal wikis, ticket systems, and archived project folders before asking anyone to remember, because documents created at the time carry more weight than a summary written for the filing. Confirm which examples establish the necessary facts and coordinate with legal counsel on how to handle anything genuinely sensitive, without removing so much detail that the claim becomes unsupported. Ask the business to provide a plain-language comparison supported by its own records: release notes, process materials, training history, or examples of decisions the employee made.