Department of Justice FOR IMMEDIATE RELEASE CR WEDNESDAY, JUNE 25, 1997 (202) 616-2765 TDD (202) 514-1888 JUSTICE DEPARTMENT REACHES AGREEMENT WITH TENNESSEE CITY TO SETTLE PARAMEDIC'S DISCRIMINATION CHARGE WASHINGTON, D.C. -- The metropolitan government of Nashville and Davidson County will change its hiring policies after it allegedly discriminated against a partially deaf paramedic by denying him a job solely based on his disability, under an agreement with the Justice Department. The agreement, filed today in U.S. District Court in Nashville, was reached under the 1990 Americans with Disabilities Act (ADA). It resolves allegations that the Metro Fire Department denied Nashville resident Jeffrey Ola, who is deaf in one ear, a position as a paramedic based on a policy which categorically excluded individuals with certain medical conditions, regardless of their abilities to perform job functions. "Public servants should be hired based on their qualifications, not on stereotypes," said Isabelle Katz Pinzler, Acting Assistant Attorney General for Civil Rights. "Any other policy keeps qualified, talented people out of jobs they deserve." Ola had been working for several years as an EMT-paramedic in nearby Sumner County, where he had performed successfully and (MORE) 01-07329 - 2 - experienced no problems due to his hearing. However, according to a complaint lodged with the Equal Employment Opportunity Commission (EEOC), in early 1994, his application for a similar position with the Metro Fire Department was refused without regard for his experience or abilities. The refusal was based on a policy which barred the any consideration of individuals with hearing disabilities for EMT positions. After making a finding of discriminatin, the EEOC referred the matter to the Justice Department who then entered into negotiations with the metropolitan government. Under the agreement, the city will: * hire Mr. Ola as an EMT-paramedic beginning today; * establish a policy which will ensure that individuals are evaluated based on their abilities without applying categorical standards based on medical conditions; and, * pay Mr. Ola approximately $54,000 in back pay and compensatory damages. The agreement must be approved by the court. Title I of the ADA requires that employers individually assess each job applicant to determine that person's current ability to perform a job function. Under the law, medical exams may be imposed by employers only after the applicant has been given a job offer, and any determinations based on medical exams must be job- related and consistent with business necessity. Those interested in finding out more about the law can access (MORE) 01-07330 - 3 - the Department's ADA Home page on the World Wide Web at http://www.usdoj.gov/crt/ada/adahom1.htm or call the ADA Information line at (800) 514-0301 (voice) or (800) 514-0383 (TDD). ### 97-264 01-07331 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) ) THE METROPOLITAN GOVERNMENT OF ) NASHVILLE AND DAVIDSON COUNTY, ) CIVIL ACTION NO. TENNESSEE, acting by and through ) the Metropolitan Fire Department, ) Emergency Ambulance Service, ) ) Defendant. ) ) ) JOINT MOTION FOR ENTRY OF CONSENT DECREE The United States has simultaneously filed a complaint against the Metropolitan Government of Nashville and Davidson County, Tennessee, and the Metropolitan Fire Department, collectively the "Defendant", alleging, inter alia, that the Defendant discriminated against Mr. Jeffrey Ola on the basis of disability by failing or refusing to hire him as an emergency medical technician-paramedic in January 1994, in violation of Title I of the Americans with Disabilities Act of 1990. The Defendant denies any and all allegations advanced by the United States. After negotiations, the United States and the Defendant have reached an agreement which resolves these claims. Counsel for the Defendant has agreed to the terms of the attached Consent Decree, and this Motion. The United States and the Defendant hereby jointly move for entry of the Consent Decree. 01-07332 JOHN M. ROBERTS ISABELLE KATZ PINZLER United States Attorney Acting Assistant Attorney General By: JOHN L. WODATCH ROBERT WATSOM Section Chief Assistant Umited States Attorney RENEE M. WOHLENHAUS Acting Deputy Section Chief (Signature) ROBERT MATHER BEBE NOVICH Trial Attorneys Disability Rights Section Civil Rights Division Department of Justice 1425 New York Avenue, N.W. Washington, D.C. 20005 Telephone: 202-307-2236 Attorneys for Plaintiff -2- 01-07333 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE UNITED STATES OF AMERICA, ) Plaintiff, ) v. ) THE METROPOLITAN GOVERNMENT OF ) NASHVILLE AND DAVIDSON COUNTY, ) CIVIL ACTION NO. TENNESSEE, acting by and through ) the Metropolitan Fire Department, ) Emergency Ambulance Service, ) Defendant. ) ) ) COMPLAINT Plaintiff, United States of America, alleges: 1. This action is brought on behalf of the United States pursuant to Section 107(a) of the Americans with Disabilities Act of 1990 ("ADA"), 42 U.S.C. S 12117(a), which incorporates by reference Section 706 of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. S 2000e-5. 2. This Court has jurisdiction of this action under 42 U.S.C. S 2000e-5(f) and 28 U.S.C. S 1345. 3. The Defendant Metropolitan Government of Nashville and Davidson County, Tennessee ("Metro") is a body corporate and politic created under the laws of the State of Tennessee. 4. Pursuant to 28 U.S.C. S 1391, venue is proper in this District, as the Defendant Metro is located in the Middle District 01-07334 of Tennessee. 5. Metro operates the Metropolitan Fire Department and Emergency Ambulance Service ("Fire Department") which employs, among other personnel, paramedics and emergency medical technicians ("EMTs"). 6. Metro is a person within the meaning of Section 101(7) of the ADA, 42 U.S.C. S 12111(7), and Section 701 of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. S 2000e(a). 7. Metro is an employer within the meaning of Section 101(5) of the ADA, 42 U.S.C. S 1211(5) and a covered entity within the meaning of Section 101(2) of the ADA, 42 U.S.C. S 12111(2). 8. Jeffery Ola has a profound hearing loss in his right ear. He is an individual with a disability within the meaning of 42 U.S.C. S 12102. 9. Jeffery Ola has worked as a paramedic for over five years, has been employed as a paramedic in two separate Tennessee counties, and has served as an EMT instructor. He holds a paramedic license from the State of Tennessee. 10. On or about September 20, 1993, Mr. Ola applied for a paramedic position with the Metropolitan Fire Department, Emergency Ambulance Service. 11. After a written examination and an oral examination/interview, Mr. Ola was offered a position as a paramedic, conditioned on the results of a polygraph test, drug screening test, and physical examination. He accepted this offer. 12. Following the physical examination which revealed Mr. - 2 - 01-07335 Ola's hearing impairment, and without any further assessment of Mr. Ola's ability to perform the essential functions of a paramedic, the Metro refused to hire Mr. Ola for the paramedic position. 13. Mr. Ola was qualified and able to perform the essential functions of the paramedic position for which he applied, with or without reasonable accommodations for his disability. 14. The conduct of Defendant in refusing to hire Mr. Ola constitutes discrimination on the basis of disability in violation of Title I of the ADA, 42 U.S.C. S 12112(a). 15. As a result of Defendant's discriminatory conduct, Mr. Ola has incurred lost wages and benefits and has suffered inconvenience, frustration, humiliation, and emotional distress. 16. Mr. Ola filed a timely charge (Charge No. 253-94-0476) with the Equal Employment Opportunity Commission ("EEOC"), in which he alleged that he had been discriminated against in employment on the basis of his disability by the Defendant Metro based on his disability. Pursuant to Section 706 of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. S 2000e-5, incorporated by reference in Section 107(a) of the ADA, 42 U.S.C. S 12117(a), the EEOC investigated the charge, found reasonable cause to believe that the allegations of discrimination on the basis of disability were true, attempted unsuccessfully to conciliate, and subsequently referred the matter to the Department of Justice. 17. All required conditions precedent to the filing of this suit have been performed or have occurred. - 3 - 01-07336 PRAYER FOR RELIEF WHEREFORE, the United States prays that the Court: (a) Enjoin Defendant from failing or refusing to (i) provide sufficient remedial relief to make whole the charging party, Jeffrey A. Ola, for the individual loss he has suffered as a result of the discrimination against him as alleged in this Complaint, including the offer of a position as a paramedic with retroactive seniority, payment of back pay with interest, pension and related benefits; and (ii) take other appropriate nondiscriminatory measures to overcome the effects of discrimination; and (b) Award compensatory damages to Jeffrey A. Ola as would fully compensate Mr. Ola for injuries caused by the Defendant's discriminatory conduct, pursuant to and within the statutory limitations of Section 102 of the Civil Rights Act of 1991, 42 U.S.C. S 1981(a); and - 4 - 01-07337 (c) Award such other additional relief as justice may require. JANET RENO Attorney General By: (Signature) JOHN M. ROBERTS ISABELLE KATZ PINZLER United States Attorney Acting Assistant Attorney Middle District of Tennessee General Civil Rights Division By: (Signature) ROBERT C. WATSON JOHN WODATCH, Chief Assistant United States Disability Rights Section Attorney Civil Rights Division (Signature) RENE WOHLENHAUS ROBERT MATHER BEBE NOVICH Attorneys Disability Rights Section Civil Rights Division U.S. Department of Justice P.O. Box 66738 Washington, D.C. 20035-6738 (202) 307-2236 - 5 - 01-07338 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) ) THE METROPOLITAN GOVERNMENT OF ) NASHVILLE AND DAVIDSON COUNTY, ) CIVIL ACTION NO. TENNESSEE, acting by and through ) the Metropolitan Fire Department, ) Emergency Ambulance Service, ) ) ) Defendant. ) ) ) ROBERT J. MATHER BEBE NOVICH Attorneys for Plaintiff Civil Rights Division U.S. Department of Justice P.O. Box 66738 Washington D.C. 20035-6738 (202) 307-2236 (202) 616-2313 WM. MICHAEL SAFELY Attorney for Defendant Department of Law Metropolitan Government of Nashville and Davidson County 204 Metro Courthouse Nashville, Tennessee 37201 (615) 862-6341 CONSENT DECREE This action was brought by the United States against the Metropolitan Government of Nashville and Davidson County to enforce the provisions of Title I of the Americans with Disabilities Act of 1990 ("ADA"), 42 U.S.C. Section Section 12111-12117. In 01-07339 its complaint, the United States alleges, inter alia, that the Metropolitan Government of Nashville and Davidson County (hereinafter collectively "Defendant") discriminated against Mr. Ola on the basis of disability by failing or refusing to hire him as an emergency medical technician-paramedic in January 1994, despite Mr. Ola's successful completion of all components of the selection process and despite the fact that Mr. Ola was certified by the State of Tennessee as an EMT-P and capable of performing the essential functions of the position. At that time, he had been working part-time in the position of paramedic in Sumner County, Tennessee, for over a year and in Hickman County, Tennessee, for more than five years. This Consent Decree resolves all issues raised by the complaint. The parties, desiring that this action be settled by appropriate Consent Decree and without the burden of protracted litigation, agree to the jurisdiction of the Court over the parties and the subject matter of this action. The parties hereby waive, for the purpose of this Consent Decree only, a hearing and findings of fact and conclusions of law on all issues, and further agree to the entry of this Consent Decree as final and binding among themselves as to the issues raised in the complaint. -2- 01-07340 It is therefore ORDERED, ADJUDGED AND DECREED as follows: A. PROSPECTIVE RELIEF 1. The Defendant, by and through its officials, agents, employees and all persons in active concert or participation with the Defendant, is enjoined from refusing to hire applicants on the basis of disability in violation of Title I of the ADA. Defendant shall evaluate, on an individualized basis, every applicant's ability to perform the essential functions of the job, including considering his/her current physical abilities to perform the essential functions of the job with or without an accommodation. Defendant shall also perform such an individualized assessment if it makes a job offer to an applicant contingent upon passing a medical examination of his/her physical condition. 2. In making any employment decision (including making a conditional job offer), the Defendant shall not utilize any personnel standards, including but not limited to medical/physical standards (e.g., standards issued by the National Fire Protection Association) that require automatic, absolute, or categorical exclusions or other limitations of applicants or employees based on those applicants' or employees' physical conditions. All hiring decisions shall be based on an individualized assessment, as described in paragraphs three (3) and four (4) below. -3- 01-07341 3. Before rejecting an applicant on the basis that he/she poses a direct threat to the health or safety of himself/herself or others, the Defendant shall perform an individualized assessment within the meaning of 29 C.F.R. S 1630(r). This individualized assessment shall include a consideration of all relevant factors including the duration of the risk, the nature and severity of the potential harm, the likelihood that the potential harm will occur, and the imminence of the potential harm. In evaluating those factors, the Defendant will consider all relevant information, including, but not limited to, information specified in 29 C.F.R S 1630(r) and the interpretive guidance to that section: for example, input from the applicant, the experience of the applicant within previous similar positions, and the opinions of medical doctors, and other professionals or associates of the applicant who have expertise in the medical condition involved and/or direct knowledge of the applicant. 4. Before rejecting an applicant on the basis that he/she poses a direct threat, the Defendant shall advise the applicant of the reasons for the proposed rejection, including each essential function of the job which Defendant believes the applicant cannot perform and all of the reasons why Defendant believes the applicant cannot perform those functions, and invite him/her to provide, within a reasonable time, additional information in regard to his/her ability to perform the job, with or without an accommodation, including but not limited to -4- 01-07342 information from other physicians and information about his/her current and recent physical capabilities as described in paragraph three (3). The Defendant shall evaluate this information in good faith to determine whether the applicant can perform the essential functions of the position with or without reasonable accommodation. 5. The Defendant shall provide ADA training to all Fire Department personnel who participate in making hiring, firing, promotion, and personnel decisions, and to medical personnel hired to evaluate applicants. Such training shall include at least the provisions of paragraphs two (2) through four (4). Within five (5) business days after the training has been completed, the Defendant shall provide to the Plaintiff written certification that it has conducted such training. 6. Within sixty (60) days of entry of this Consent Decree, the Defendant shall review and where necessary modify its application, selection, promotion, evaluation, and termination procedures and standards to ensure that such procedures and standards comply with Title I of the ADA. This review shall include modifications to ensure compliance with paragraphs two (2) through four (4). 7. The Defendant shall post notices (in the form of Appendix A) in conspicuous places at the Metro Courthouse, at the fire headquarters, and at all fire stations and substations. The notices shall remain posted for six (6) months from the date of entry of this Consent Decree. -5- 01-07343 8. The Defendant, by and through its officials, agents, employees and all persons in active concert or participation with the Defendant, is enjoined from retaliating against Mr. Ola or any other person because that person has opposed policies or practices he or she believes to discriminate on the basis of disability, has filed an EEOC charge, or because of that person's participation in or cooperation with the initiation, investigation, litigation or administration of the charge on which the complaint in this case is predicated or this Consent Decree. B. INDIVIDUAL REMEDIAL RELIEF 9. The Defendant shall offer Mr. Ola a monetary awary of $49,296.74 in back pay for the period up to June 25, 1997, and additional back pay for the period thereafter in such event that hiring occurs after that date. 10. The Defendant shall offer Mr. Ola a monetary award of $4,999.00 in compensatory damages, for any claims arising out of or related to the instant action. The Defendant will not require Mr. Ola to accept instatement to an EMT-P position to be entitled to this monetary award, or the monetary award provided for in paragraph nine (9) of this Consent Decree. 11. The Defendant shall offer Jeffrey A. Ola employment as an EMT-P in the Metropolitan Fire Department's Emergency Services Division. The Defendant shall not condition this offer on the completion of any probationary period, training, test, or -6- 01-07344 attendance at any fire academy. Should Mr. Ola accept the offer of instatement, his seniority date as an EMT-P will be February 1, 1994, for all purposes for which seniority is computed or considered, including but not limited to pay step increases, promotions, vacations, assignments and pension. If Mr. Ola accepts this offer of instatement to an EMT-P position, the Defendant shall separately pay the full contribution, including the employee's contribution, to the Metropolitan Fire Retirement System sufficient to place Mr. Ola for pension purposes in the position of an employee with a seniority date for retirement purposes of February 1, 1994. 12. Should Mr. Ola accept the offer of instatement to an EMT-P position, the Defendant shall credit Mr. Ola with the full vacation leave, sick leave, personal leave and any other leave, and any other accumulated benefits, that Mr. Ola would have received or been credited with had he been hired on February 1, 1994. 13. In order to accept any of the relief to be offered by the Defendant under this Consent Decree, Mr. Ola must complete a Release and Election of Remedies form (Appendix C). Within ten (10) days of the Defendant's receipt of Mr. Ola's executed Release and Election of Remedies form, the Defendant shall pay to Mr. Ola the monetary award described in paragraphs nine (9) and ten (10) of this Consent Decree. In addition, should Mr. Ola accept the position of EMT-P, the Defendant shall hire Mr. Ola and begin paying his salary within ten (10) days of the -7- 01-07345 Defendant's receipt of Mr. Ola's executed Release and Election of Remedies form. C. IMPLEMENTATION 14. The Defendant agrees to notify Mr. Ola of the terms of this Consent Decree within three (3) days of its entry by mailing to him, by certified mail, return receipt requested, a copy of the letter in the form set forth in Appendix B and enclosing a copy of the Consent Decree and a copy of the Release and Election of Remedies form attached as Appendix C. The letter identified as Appendix B shall advise Mr. Ola that to accept the relief offered, he must return the executed Appendix C Release and Election of Remedies form to the Defendant within thirty (30) days of his receipt of the Appendix B letter unless he shows good cause for his failure to do so. 15. This Consent Decree shall terminate three (3) years from the date of its entry. Prior to its termination any party may move, for good cause shown, to extend the duration of the Consent Decree. D. RECORDS 16. Within sixty (60) calendar days after entry of this Consent Decree, the Defendant shall provide counsel for the United States a report showing the disposition of individual relief for Mr. Ola pursuant to this Consent Decree and copies of all the documents contained in Mr. Ola's personnel file. Within fourteen (14) calendar days of the completion of the examination -8- 01-07346 and modification of procedures described in paragraph six (6), the Defendant shall forward to the Plaintiff copies of all selection procedures and policies related to the hiring of emergency medical technicians-paramedics in the Metropolitan Fire Department. In addition, the Defendant shall make available for inspection and copying, within fourteen (14) calendar days after receipt of a request by the Plaintiff, through its counsel, all documents used for the Defendant's compliance with an implementation of this Consent Decree. It is so ORDERED, this day of , 1997. HON. UNITED STATES DISTRICT JUDGE Agreed and Consented to: (Signature) CHIEF NORMAN DOZIER Director of Fire Metropolitan Fire Department (Signature) (Signature) WM. MICHAEL SAFELY ROBERT J. MATHER Attorney for Defendant BEBE NOVICH Department of Law Attorneys for Metropolitan Government Plaintiff of Nashville and Davidson Civil Rights Division County U. S. Department of Justice 204 Metro Courthouse P. O. Box 66738 Nashville, Tennessee 37201 Washington, D.C. 20035-6738 (615) 862-6341 (202) 307-2236 (202) 616-2313 -9- 01-07347 APPENDIX A NOTICE TO EMPLOYEES Title I of the Americans with Disabilities Act (ADA) prohibits employment discrimination on the basis of disability. The ADA makes it unlawful to discriminate against a qualified individual with a disability because of the disability of such individual in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training, and other terms, conditions and privileges of employment. The Equal Employment Opportunity-Commission ("EEOC") is the federal agency primarily responsible for investigating individual charges of discrimination under Title I of the ADA. Any individual who believes that he or she has been discriminated against in violation of the ADA, or who desires more information on the ADA or other employment discrimination statutes can contact the EEOC at the following address and phone number: Equal Employment Opportunity Commission Nashville District Office 50 Vintage Way Suite 202 Nashville, Tennessee 37228-9940 Phone No. (615) 736-5820 FAX No. (615) 736-2107 TDD No. (615) 736-5870 The Metropolitan Government of Nashville and Davidson Government, supports and will comply with the ADA in all respects. Date Signature Title 01-07348 APPENDIX B NOTICE LETTER United States v. The Metropolitan Government of Nashville and Davidson Government, Tennessee, Case No. 97-CV- - (M.D. Tenn.) (Hon. ) [Date] Jeffrey A. Ola 622 Beech Street Centerville, Tennessee 37033 Dear Mr. Ola: A Consent Decree has been entered settling a complaint of employment discrimination filed by the United States against the Metropolitan Government of Nashville and Davidson Government, Tennessee ("the Defendant") in the case United States v. The Metropolitan Government of Nashville and Davidson Government, Tennessee, Case No. 97-CV- - (M.D. Tenn) (Hon. ). Under the terms of the Consent Decree entered on [date], we are offering you a monetary award and instatement to the position of emergency medical technician-paramedic with the Metropolitan Fire Department with a seniority date as an emergency medical technician-paramedic of February 1, 1994. We enclose a copy of the Consent Decree. Please review it carefully. As a monetary award, we are offering you $54,295.74. You may obtain the monetary award by completing and returning the enclosed Release and Election of Remedies form to the following address: Wm. Michael Safely Department of Law Metropolitan Government of Nashville and Davidson County 204 Metro Courthouse Nashville, Tennessee 37201 You must sign and notarize the Release and Election of Remedies Form before you return it. We offer the monetary award to you on the following condition: if you accept it, we will require you to release the Defendant from all employment discrimination claims you may have against it on the basis of your disability arising out of this case and EEOC Charge No. 253-94-0476. -1- 01-07349 If you accept the monetary award, the Defendant will send you a check for the monetary award within ten days of the Defendant's receipt of your Release and Election of Remedies Form. IF YOU FAIL TO SUBMIT THE RELEASE, AS DIRECTED IN THIS LETTER, WITHIN THIRTY (30) DAYS FROM YOUR RECEIPT OF THIS LETTER, YOU WILL FORFEIT YOUR RIGHTS TO ANY MONETARY AWARD UNDER THIS CONSENT DECREE, UNLESS YOU CAN SHOW GOOD CAUSE FOR YOUR FAILURE TO DO SO WITHIN A REASONABLE TIME THEREAFTER. If you have any questions concerning this settlement, you may contact Robert Mather or Bebe Novich, the attorneys for the United States Department of Justice at (202) 307-2236 or 616-2313. Sincerely, Wm. Michael Safely, Esquire Attorney The Metropolitan Government Enclosures -2- 01-07350 APPENDIX C RELEASE AND ELECTION OF REMEDIES FORM United States v. The Metropolitan Government of Nashville and Davidson Government, Tennessee, Case No. 97-CV- - (M.D. Tenn) (Hon. ) STATE OF TENNESSEE COUNTY OF DAVIDSON For and in consideration of the payment of a monetary award and/or instatement to the position of emergency medical technician-paramedic with a seniority date of February 1, 1994, made by The Metropolitan Government of Nashville and Davidson Government (hereinafter "the Defendant") pursuant to the provisions of the Consent Decree entered by the Honorable [ , United States District Judge, on [date] in United States v. The Metropolitan Government of Nashville and Davidson Government, Tennessee, Case No. 97-CV- - (M.D. Tenn) (Hon. ), I, Jeffrey A. Ola, hereby release and forever discharge the Metropolitan Government, its current and past and future officials, employees and agents, of and from any legal and equitable claims arising out of United States v. The Metropolitan Government of Nashville and Davidson Government, Tennessee, Case No. 97-CV- - (M.D. Tenn) (Hon. ), and any and all claims arising out of EEOC Charge 253-94-0476. This Release constitutes the entire agreement between myself and the Metropolitan Government without exception or exclusion. I acknowledge that the Metropolitan Government has made a copy of the Consent Decree in this action available to me. I HAVE READ THIS RELEASE AND UNDERSTAND THE CONTENTS THEREOF AND I EXECUTE THIS RELEASE OF MY OWN FREE ACT AND DEED. Signed this day of , 1997. Jeffrey A. Ola Social Security Number Other Identification Sworn and subscribed to before me this day of , 1997. NOTARY PUBLIC My commission expires: 01-07351 ELECTION OF REMEDIES Please complete by checking the appropriate response to each following: A. Monetary Award I hereby accept the monetary award of $54,295.74 contained in the Consent Decree in the case of United States v. The Metropolitan Government of Nashville and Davidson County, Case No. 97-CV- - (M.D. Tenn) (Hon. ) B. Job Offer Award I hereby accept the offer of instatement to the position of emergency medical technician- paramedic with the Metropolitan Fire Department contained in the Consent Decree in United States v. The Metropolitan Government of Nashville and Davidson County, Case No. 97- CV- - (M.D. Tenn) (Hon. ). I decline the job offer award. Date: Signature Social Security No. TO RECEIVE EITHER AWARD, YOU MUST ALSO COMPLETE AND RETURN THE ENCLOSED RELEASE FORM. FAILURE TO RETURN BOTH THIS FORM AND THE RELEASE FORM WITHIN THIRTY (30) DAYS WILL RESULT IN FORFEITURE OF THE AWARDS UNLESS YOU SHOW GOOD CAUSE FOR YOUR FAILURE TO TIMELY RESPOND. RETURN THE COMPLETED FORMS TO: WM. MICHAEL SAFELY Attorney for Defendant Department of Law Metropolitan Government of Nashville and Davidson County 204 Metro Courthouse Nashville, Tennessee 37201 (615) 862-6341 01-07352