FILED
UNITED STATES DISTRICT COURT Q ] 2025
W^$TERN DISTRICT OF OKLAHOMA
JOAN KANE, CLERK
U.S. DIST. COURT WESTERN DIST. OKLA.
IN RE: EMPLOYMENT DISPUTE ) by .deputy
RESOLUTION PLAN FOR THE ) G.0.25-3
WESTERN DISTRICT OF OKLAHOMA )
I. Introduction
The Federal Judiciary is commirted to a workplace of respect, civility, fairness,
tolerance, and dignity, free of discrimination and harassment. These values are
essential to the Judiciary, which holds its Judges and Employees to the highest
standards. Ail Judges and Employees are expected to treat each other accordingly.
This Plan provides options for the reporting and resolution of allegations of wrongful
conduct (discrimination, sexual, racial, or other discriminatory harassment, abusive
conduct, and retaliation) in the workplace. Early action is the best way to maintain a
safe work environment. All Judges, Employing Offices, and Employees have a
responsibility to promote workplace civility, to prevent harassment or abusive conduct,
and to take appropriate action upon receipt of reliable information indicating a
likelihood of wrongful conduct under this Plan. See Code of Conduct for Judicial
Employees, Canon 3(C).
This Plan applies to all Judges, current and former Employees(including all law clerks;
chambers employees; paid and unpaid interns, externs, and other volunteers; federal
public defender employees; and probation and pretrial services employees), and
applicants for employment who have been interviewed. The following persons cannot
seek relief under this Plan: Judges, applicants for judicial appointment. Criminal
Justice Act panel attorneys and applicants, investigators and service providers,
community defender employees, volunteer mediators, and any other non-Employees
not specified above. See Appendix I for full definitions of Judges and Employees.
II. Wrongful Conduct
A. This Plan prohibits wrongful conduct that occurs during the period ofemployment
or the interview process (for an applicant). Wrongful conduct includes:
• discrimination;
• sexual, racial, and other discriminatory harassment;
• abusive conduct; and
• retaliation (including retaliation as described in the Whistleblower
Protection Provision in Guide to Judiciary Policy, Vol. 12. $ 220.10.20(01).
Wrongful conduct can be verbal, non-verbal, physical, or non-physical.
• Wrongful conduct also includes conduct that would violate the following
employment laws and policy, as applied to the Judiciary by Judicial
Conference policy:
• Title VII, Civil Rights Act of 1964;
• Age Discrimination in Employment Act of 1967;
• Americans with Disabilities Act of 1990 and the Rehabilitation Act of 1973;
• Family and Medical Leave Act of 1993;
• Uniformed Services Employment and Reemployment Rights Act of 1994;
• Whistleblower Protection Provision {Guide, Vol. 12, ^ 220.10.20fc)'):
• Worker Adjustment and Retraining Notification Act;
• Occupational Safety and Health Act; and
• The Employee Polygraph Protection Act of 1988.
See Guide, Vol. 12. Ch. 2.
B. Discrimination is an adverse employment action that materially affects the terms,
conditions, or privileges of employment(such as hiring, firing, failing to promote, or a
significant change in benefits)based on the following Protected Categories: race, color,
sex, gender, gender identity, pregnancy, sexual orientation, religion, national origin,
age (40 years and over)\ or disability.
C. Discriminatory harassment occurs when a workplace is permeated with
discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive
to alter the conditions of the employment and create an abusive working environment.
Discriminatory harassment includes sexual harassment.
Examples of conduct that may give rise to discriminatory harassment: racial slurs;
derogatory comments about a person's ethnicity, culture, or foreign accent; or jokes
about a person's age, disability, or sexual orientation.
Examples ofconduct that may give rise to sexual harassment: suggestive or obscene
notes, emails, text messages, or other types of communications; sexually degrading
comments; display of sexually suggestive objects or images; unwelcome or
inappropriate touching or physical contact; unwelcome sexual advances or
propositions; inappropriate remarks ofa sexual nature or about physical appearance; or
employment action affected by submission to, or rejection of, sexual advances.
^ The age discrimination provision does not apply to hiring, retirement, or separation of probation and pretrial
services officers under 5 U.S.C. chapters 83 and 84.
D. Abusive Conduct is a pattern of demonstrably egregious and hostile conduct not
based on a Protected Category that unreasonably interferes with an Employee's work
and creates an abusive working environment. Abusive conduct is threatening,
oppressive, or intimidating.
Abusive conduct does not include communications and actions reasonably related
management, including but not limited to: instruction, corrective to performance
criticism, and evaluation; performance improvement plans; duty assignments and
changes to duty assignments; office organization; progressive discipline; and adverse
action.
E. Retaliation is a materially adverse action taken against an Employee for
reporting wrongful conduct; for assisting in the defense of rights protected by this Plan;
or for opposing wrongflil conduct. Retaliation against a person who reveals or reports
wrongful conduct is itself wrongful conduct.
III. Reporting Wrongful Conduct
The Judiciary encourages early reporting and action on wrongful conduct. Employees
who experience, observe, or learn of reliable evidence of sexual, racial, or other
discriminatory harassment or abusive conduct are strongly encouraged to take
appropriate action,including reporting it to a supervisor, human resources professional,
Unit Executive, Employment Dispute Resolution ("EDR") Coordinator, Chief Judge,
Chief Circuit Judge, Circuit Director of Workplace Relations, or to the national Office
of Judicial Integrity. See Code of Conduct for Judicial Employees, Canon 3(C).
Employees are also encouraged to report wrongful conduct in the workplace by non-
Employees. Court and chambers' confidentiality requirements do not prevent any
Employee—including law clerks—from revealing or reporting wrongful conduct by
any person.
IV. Options for Resolution
The Judiciary's goal is to address wrongful conduct as soon as possible and to provide
multiple, flexible options for doing so. An Employee is always free to address a
conduct issue directly with the person who allegedly committed wrongful conduct or
to contact a colleague, supervisor, Unit Executive, Judge, Chief Judge, or other
individual to discuss or address the situation. This Plan provides the following
additional options, and Employees may choose the option(s) that best fit their needs
and comfort level.
A. Plan Options. This Plan provides three options to address wrongful conduct, as
explained in detail below:
1. Informal Advice
2. Assisted Resolution
3. Formal Complaint
B. General Rights. All options for resolution are intended to respect the privacy of
all involved to the greatest extent possible, and to protect the fairness and thoroughness
of the process by which allegations of wrongful conduct are initiated, investigated, and
ultimately resolved.
1. Confidentiality. All individuals involved in the processes under this
Plan must protect the confidentiality of the allegations of wrongful
conduct. Information will be shared only to the extent necessary and only
with those whose involvement is necessary to address the situation. An
assurance of confidentiality must yield when there is reliable information
of wrongful conduct that threatens the safety or security of any person or
that is serious or egregious such that it threatens the integrity of the
Judiciary.
Confidentiality obligations in the Code of Conduct for Judicial
Employees concerning use or disclosure of confidential information
received in the course of official duties do not prevent nor should they
discourage Employees from reporting or disclosing wrongful conduct,
including sexual, racial, or other forms of discriminatory harassment by
a Judge, supervisor, or other person.
Supervisors, Unit Executives, and Judges must take appropriate action
when they learn of reliable information of wrongful conduct, such as
sexual, racial, or other discriminatory harassment, which may include
informing the appropriate Chief Judge.
2. Impartiality. All investigations, hearings, and other processes under this
Plan must be conducted in a thorough, fair, and impartial manner. The
EDR Coordinator, the Circuit Director of Workplace Relations, and the
Presiding Judicial Officer must be impartial and may not act as an
advocate for either Party. The EDR Coordinator, Circuit Director of
Workplace Relations, or Presiding Judicial Officer must recuse if he or
she participated in, witnessed, or was otherwise involved with the conduct
or employment action giving rise to the claim. Recusal of these
individuals is also required if the matter creates an actual conflict or the
appearance of a conflict.
3. Right to representation. Both the Employee and the Employing Office
responsible for providing any remedy have the right to be represented by
an attorney or other person oftheir choice at their own expense. Another
Employee may assist the Employee or Employing Office if doing so will
not constitute a conflict of interest or unduly interfere with his or her
duties, as determined by the assisting Employee's appointing officer.
4. Interim Relief. An Employee, including a law clerk or other chambers
employee, who pursues any of the options under this Plan may request
transfer, an alternative work arrangement, or administrative leave if the
Employee alleges egregious conduct by a supervisor. Unit Executive, or
Judge that makes it untenable to continue working for that person. Any
such request must be made to the Unit Executive or Chief Judge, as
appropriate, to determine appropriate interim relief, if any, taking into
consideration the impact on the Employing Office.
5. Allegations Regarding a Judge. An Employee alleging that a Judge has
engaged in wrongful conduct may use any ofthe options for resolution as
set forth in Section C. An Employee may also file a complaint under the
Judicial Conduct and Disability Act, 28 U.S.C. §§ 351-364.
C. Specific Options
1. Informal Advice. An Employee may contact an EDR Coordinator,
Circuit Director of Workplace Relations, or the national Office ofJudicial
Integrity for confidential advice and guidance {see § IV.B.l) about a
range of topics including:
• the rights and protections afforded under this Plan, the Judicial
Conduct and Disability Act, and any other processes;
• ways to respond to wrongful conduct as it is happening; and/or
• options for addressing the conduct, such as informal resolution,
participating in Assisted Resolution, or pursuing a Formal
Complaint under this Plan, the Judicial Conduct and Disability
Act, or any other processes.
2, Assisted Resolution. Assisted Resolution is an interactive, flexible
process that may include:
• discussing the matter with the person whose behavior is of concern;
• conducting a preliminary investigation, including interviewing
persons alleged to have violated rights under this Plan and
witnesses to the conduct;
• engaging in voluntary mediation between the persons involved;
and/or
• resolving the matter by agreement.
a. To pursue this option, an Employee must contact an EDR Coordinator
or Circuit Director of Workplace Relations and complete a "Request
for Assisted Resolution"(Appendix 2). An Employee asserting any
claim of abusive conduct must first use Assisted Resolution before
filing a Formal Complaint. Filing a Request for Assisted Resolution
does not toll (extend) the time for filing a Formal Complaint under §
IV.C.3 unless one of the Parties requests, and the Chief Judge or
Presiding Judicial Officer grants, an extension oftime for good cause,
as permitted in § IV.C.3.a.
b. If the allegations concern the conduct of a Judge, the Chief Judge of
the appropriate Court must be notified and will be responsible for
coordinating any Assisted Resolution and/or taking any other action
required or appropriate under the circumstances. See, e.g., Rules for
Judicial-Conduct and Judicial-Disability Proceedings.
c. If the allegations concern the conduct of an Employee, the EDR
Coordinator or Circuit Director of Workplace Relations will
coordinate Assisted Resolution and must notify the appropriate Unit
Executive(s). The Unit Executive is responsible for assessing the
allegation(s) and taking appropriate steps to resolve the matter. If
the allegations concern the conduct of a Unit Executive, the EDR
Coordinator must notify the Chief Judge of the appropriate court,
who is responsible for assessing the allegation(s) and addressing the
matter as appropriate.
d. The Unit Executive or Chief Judge responsible for assessing the
allegations, as indicated in(b) and(c) above, may deny the Request
for Assisted Resolution at any time if he or she concludes it is
frivolous; it does not allege violations of the rights or protections in
this Plan; the alleged conduct arises out of the same facts and
circumstances, and was resolved by, a previous EDR Complaint or
other claim process or procedure; or on other appropriate grounds.
e. If Assisted Resolution is successful in resolving the matter, the
Parties will so acknowledge in writing.
f. The Parties by mutual assent, or the EDR Coordinator or Circuit
Director of Workplace Relations in his or her discretion, will
determine when to conclude the Assisted Resolution process. If
Assisted Resolution is not successful in resolving the matter, the
EDR Coordinator or Circuit Director of Workplace Relations will
advise the Employee of his or her rights to file a Formal Complaint
and/or pursue action under the Judicial Conduct and Disability Act,
if applicable, or any other processes.
3. Filing a Formal Complaint. An Employee may file a Formal Complaint
("Complaint") with any of the Court's EDR Coordinators to address a
claim of wrongful conduct.
a. To file a Complaint, an Employee must submit a "Formal
Complaint"(Appendix 3)to any of the Court's EDR Coordinators
within 180 days ofthe alleged wrongful conduct or within 180 days
of the time the Employee becomes aware or reasonably should
have become aware of such wrongful conduct. Use of the
Informal Advice or Assisted Resolution options does not toll
(extend) this 180-day deadline unless the Chief Judge of the
appropriate Court or the Presiding Judicial Officer grants an
extension of time for good cause.
b. An Employee asserting any claim of abusive conduct must first
use Assisted Resolution before filing a Formal Complaint.
c. The Employee filing the Complaint is called the Complainant.
The Party responding to the Complaint is the Employing Office
that is responsible for providing any appropriate remedy and is
called the Respondent. The Complaint is not filed against any
specific individual(s) but against the Employing Office.
d. Complaint Regarding a Judge. An Employee alleging that a
Judge has engaged in wrongful conduct may file a Complaint
under this Plan. The EDR Coordinator must immediately provide
a copy of the Complaint to the Chief Circuit Judge (or the next
most-senior active Circuit Judge, if the allegation is against the
Chief Circuit Judge), who will oversee the EDR Complaint
process. If a District, Magistrate, or Bankruptcy Judge is the
subject ofthe Complaint, the EDR Coordinator must also provide
a copy of the Complaint to the Chief District Judge (unless the
ChiefDistrict Judge is the subject ofthe Complaint,in which case
the Complaint will be given only to the Chief Circuit Judge).
If a Judge becomes the subject of both a Complaint under this Plan
and a complaint under the Judicial Conduct and Disability Act,the
Chief Circuit Judge will determine the appropriate procedure for
addressing both, which may include holding the EDR claim in
abeyance and determining how best to find any common issues of
fact, subject to all requirements of the Judicial Conduct and
Disability Act, the Rules for Judicial-Conduct and Judicial-
Disability Proceedings, and, as practicable, this EDR Plan.
Regardless of whether there is a formal complaint under the
Judicial Conduct and Disability Act, the Chief Circuit Judge
should consider the need for any necessary or appropriate interim
relief.
e. Formal Complaint Procedures and Procedural Rights
i. Appointment ofPresiding Judicial Officer. Upon receipt of
a Complaint, the EDR Coordinator will immediately send a copy
ofthe Complaint to the Chief Judge ofthe appropriate Court, who
will appoint a Presiding Judicial Officer. The Presiding Judicial
Officer will be a Judge in the Court or, when appropriate, a Judge
from another Court(with the consent ofthe respective ChiefJudge
of that Court).
ii. Presiding Judicial Officer. The Presiding Judicial Officer
oversees the Complaint proceeding. The Presiding Judicial
Officer will provide a copy of the Complaint to the head of the
Employing Office against which the Complaint has been filed
(Respondent), except when the Presiding Judicial Officer
determines for good cause that the circumstances dictate
otherwise. The Presiding Judicial Officer must provide the
individual alleged to have violated rights under this Plan notice
that a Complaint has beenfiled and the nature and substance ofthe
Complaint allegations.
The Presiding Judicial Officer will provide for appropriate
investigation and discovery, allow for settlement discussions,
determine any written submissions to be provided by the Parties,
determine if a hearing is needed, determine the time, date, and
place of the hearing, issue a written decision, and, if warranted,
order remedies.
iii. Disqualification and Replacement. Either Party may seek
disqualification of the EDR Coordinator or the Presiding Judicial
Officer by written request to the Chief Judge, explaining why the
individual should be disqualified.
If the Presiding Judicial Officer is disqualified, the Chief Judge
will designate another Judge to serve as Presiding Judicial Officer.
If the EDR Coordinator is disqualified, the Chief Judge will
appoint one ofthe alternate EDR Coordinators or, if available, an
EDR Coordinator from another Court (with the consent of the
respective Chief Judge of that Court).
iv. Response. The Respondent may file a Response to the
Complaint with the EDR Coordinator within 30 days of receiving
the Complaint. The EDR Coordinator must immediately send the
Response to the Presiding Judicial Officer and to the Complainant.
V. Investigation and Discovery. The Presiding Judicial
Officer will ensure that the allegations are thoroughly, impartially,
and fairly investigated, and may use outside trained investigators
if warranted. The investigation may include interviews with
persons alleged to have violated rights under this Plan and
witnesses, review of relevant records, and collecting documents
or other records. The Presiding Judicial Officer will provide for
such discovery to the Complainant and Respondent as is necessary
and appropriate. The Presiding Judicial Officer will also determine
what evidence and written arguments, if any, are necessary for a
fair and complete assessment ofthe allegations and response.
vi. Case preparation. The Complainant may use official time
to prepare his or her case, so long as it does not unduly interfere
with the performance of duties.
vii. Extensions of time. Any request for an extension of time
must be in writing. The Presiding Judicial Officer may extend any
ofthe deadlines set forth in this EDR Plan for good cause, except
for the deadline to issue a written decision, which may only be
extended by the Chief Judge.
viii. Established Precedent. In reaching a decision, the
Presiding Judicial Officer should be guided by judicial and
administrative decisions under relevant rules and statutes, as
appropriate. The Federal Rules of Evidence and any federal
procedural rules do not apply.
ix. Notice of Written Decision. The EDR Coordinator or
Presiding Judicial Officer will immediately send a copy of the
written decision to the Parties, the Chief Judge of the Court, and
to any individual alleged to have violated rights protected by this
Plan. The EDR Coordinator will inform the Parties of appeal
rights, procedures, and deadlines.
f. Resolution of Complaint Without a Hearing. After notifying
the Parties and giving them an opportunity to respond, the
Presiding Judicial Officer may resolve the matter without a
hearing.
i. The Presiding Judicial Officer may dismiss a Complaint
and issue a written decision at any time in the proceedings on the
grounds that: it is untimely filed, is frivolous, fails to state a claim,
or does not allege violations of the rights or protections in this
Plan; the alleged conduct arises out of the same facts and
circumstances, and was resolved by, a previous EDR Complaint
or other claim process or procedure; or on other appropriate
grounds.
ii. After completion of investigation and discovery, the
Presiding Judicial Officer may, on his or her own initiative or at
the request of either Party, issue a written decision ifthe Presiding
Judicial Officer determines that no relevant facts are in dispute
and that one ofthe Parties is entitled to a favorable decision on the
undisputed facts.
iii. The Parties may enter into an agreed written settlement if
approved in writing by the Presiding Judicial Officer and the Chief
Judge.
g. Resolution of Complaint With a Hearing. If the Complaint is
not resolved in its entirety by dismissal. Assisted Resolution, decision
without a hearing, or settlement, the Presiding Judicial Officer will order
a hearing on the merits ofthe Complaint.
i. Hearing. The hearing will be held no later than 60 days
after the filing of the Complaint unless the Presiding Judicial
Officer extends the deadline for good cause. The Presiding
Judicial Officer will determine the place and manner of the
hearing.
10
ii. Notice. The Presiding Judicial Officer must provide
reasonable notice of the hearing date, time, and place to the
Complainant, the Respondent, and any individual(s) alleged to
have violated the Complainant's rights.
iii. Right to Present Evidence. The Complainant and
Respondent have the right to present witnesses and documentary
evidence and to examine adverse witnesses.
iv. Record ofProceedings. A verbatim record of the hearing
must be made and will be the official record of the proceeding.
This may be a digital recording or a transcript.
V. Written Decision. The Presiding Judicial Officer will make
findings of fact and conclusions of law and issue a written
decision no later than 60 days after the conclusion ofthe hearing,
unless an extension for good cause is granted by the ChiefJudge.
h. Remedies. When the Presiding Judicial Officer finds that the
Complainant has established by a preponderance of the evidence (more
likely than not) that a substantive right protected by this Plan has been
violated, the Presiding Judicial Officer may direct the Employing Office
to provide remedies for the Complainant. The remedies are limited to
providing relief to the Complainant, should be tailored as closely as
possible to the specific violation(s)found, and take into consideration the
impact on the Employing Office. The ChiefJudge and Employing Office
(Respondent) must take appropriate action to carry out the remedies
ordered in the written decision, subject to any applicable policies or
procedures.
i. Allowable Remedies may include:
• placement of the Complainant in a position previously
denied;
• placement of the Complainant in a comparable
alternative position;
• reinstatement to a position from which the Complainant
was previously removed;
• prospective promotion of the Complainant;
• priority consideration of the Complainant for a future
promotion or position;
n
• back pay and associated benefits, when the statutory
criteria ofthe Back Pay Act are satisfied^;
• records modification and/or expungement;
• granting offamily and medical leave;
• any reasonable accommodation(s); and
• any other appropriate remedy to address the wrongful
conduct.^
ii. Unavailable Remedies. Other than under the Back Pay Act,
monetary damages are not available. The Presiding Judicial
Officer may award attorney's fees only if the statutory
requirements under the Back Pay Act are satisfied.
i. Review of Decision (Appeal). The Complainant and/or the
Respondent may appeal the decision to the judicial council of the circuit
by submitting in writing a Request for Review of Decision setting forth
the grounds for appeal within 30 days of the date of the decision under
procedures established by that judicial council(Appendix 4). The EDR
Coordinator will inform the Parties ofthe procedures for seeking review.
The decision will be reviewed based on the record created by the
Presiding Judicial Officer and will be affirmed ifsupported by substantial
evidence and the proper application of legal principles.
^ Remedies under the Back Pay Act, including attorney's fees, may be ordered only when the statutory criteria of
the Back Pay Act are satisfied, which include: (1) a finding of an unjustified or unwarranted personnel action;
(2)by an appropriate authority;(3) which resulted in the withdrawal or reduction of all orpart of the Employee's
pay, allowances, or differentials. An order of back pay is subject to review and approval by the Director of the
Administrative Office oftlie United States Courts. See 5 U.S.C. § 5596(b)(1) and Guide. Vol. 12. $ 690.
^ The issue in an EDR Complaint is whether the Employing Office is responsible for the alleged conduct; it is not
an action against any individual. The Presiding Judicial Officer lacks authority to impose disciplinary or similar
action against an individual. When there has been a finding of wrongful conduct in an EDR proceeding, an
appointing official, or official with delegated authority, should separately assess whether further action, in
accordance with any applicable policies and procedures, is necessary to correct and prevent wrongful conduct
and promote appropriate workplace behavior, such as:
requiring counseling or training;
ordering no contact with the Complainant;
reassigning or transferring an Employee;
reprimanding the Employee who engaged in wrongful conduct;
issuing a suspension, probation, or demotion of the Employee who engaged in wrongful conduct; and/or
terminating employment for the Employee who engaged in wrongful conduct.
12
V. Court and Employing Office Obligations
To ensure that Employees are aware of the options provided by this Plan, and that the Plan
is effectively implemented, Courts and Employing Offices must adhere to the following:
A. Adopt and Implement EDR Plan. In accordance with Judiciary policy,the District and
Bankruptcy Courts for the Westem District of Oldahoma have adopted and implemented the
Model EDR Plan enacted by the Judicial Conference ofthe United States with minor revisions,
and have submitted it to the Judicial Council ofthe Tenth Circuit for approval. A copy ofthis
EDR Plan and any subsequent modifications wiU also be filed with the Administrative Office of
the United States Courts
B. Record of Final Decisions; Publication Policy. At the conclusion ofEDRFormal
Complaint proceedings, a copy of the final EDR decision will be provided to the Tenth
Circuit Director of Workplace Relations. Final decisions made following Formal
Complaint proceedings under all EDR Plans within the Tenth Circuit will be made
available to the public free of charge upon written request addressed or emailed to the
Tenth Circuit Director of Workplace Relations. The EDR Presiding Judicial Officer's
decision shall be the "final decision" ifno timely Petition for Review ofthat EDR decision
is filed. If a timely Petition for Review of an EDR decision is filed, then the decision of
the Judicial Council(or its Employment Dispute Resolution Committee) on that Petition
for Review shall be the "final decision." The Tenth Circuit Director of Workplace
Relations shall ensure unifonn redaction of names and identifying information of all
parties, alleged violators, and other individuals involved as well as other sensitive
information that appears in a final decision before the final decision is released to the
public.
C. EDR Coordinators. The Chief Judge will designate both a primary EDR Coordinator
and at least one alternate EDR Coordinator for the Court. The Court may use an EDR
Coordinator from another Court, or may use the Circuit Director of Workplace Relations
as an alternate EDR Coordinator, if necessary, with the approval of the appropriate Chief
Judge. An Employee may choose the EDR Coordinator with whom he or she wishes to
seek Informal Advice, request Assisted Resolution, or file a Complaint under this EDR
Plan.
An EDR Coordinator must be an Employee who is not a Unit Executive. A Judge may not
be an EDR Coordinator. All EDR Coordinators must be trained and certified as set forth
in the EDR Interpretive Guide and Handbook.
D. Advising Employees of their Rights. The Courts and Employing Offices will:
1. prominently post on their internal and external main homepages a direct
link, labeled "Your Employee Rights and How to Report Wrongful
Conduct," to:
• the entire EDR Plan with all Appendices and relevant contact
13
information;
• the Judicial Conduct and Disability Act, the Rules for Judicial-Conduct
and Judicial-Disability Proceedings, and the Judicial Conduct and
Disability Complaint form; and
• contact infonnation for all of the Court's EDR Coordinators, Circuit
Director of Workplace Relations, and the national Office of Judicial
Integrity.
2. prominently display in the workplace:
• the posters set forth in Appendix 5; and
• an Anti-Discrimination and Harassment Notice that: (a) states that
discrimination or harassment based on race, color, sex, gender, gender
identity, pregnancy, sexual orientation, religion, national origin, age (40
years and over), or disability is prohibited; (b) explains that Employees
can report, resolve, and seek remedies for discrimination, harassment, or
other wrongful conduct under the EDR Plan by contacting any of the
Court's EDR Coordinators and/or the Circuit Director of Workplace
Relations, and/or the national Office of Judicial Integrity; (c) identifies
the names and contact information of all Court EDR Coordinators, the
Circuit Director of Workplace Relations, and the national Office of
Judicial Integrity; and (d) states where the EDR Plan can be located on
the Court's website.
3. ensure that each new Employee receive an electronic or paper copy of the
EDR Plan and acknowledge in writing that he or she has read the Plan; and
4. conduct training annually for all Judges and Employees, including chambers
staff, to ensure they are aware of the rights and obligations under the EDR
Plan and the options available for reporting wrongful conduct and seeking
relief.
E. Reporting. Courts and Employing Offices will provide annually, to the
Administrative Office of the United States Courts, data on: (1) the number and types of
alleged violations for which Assisted Resolution was requested, and for each matter,
whether it was resolved or was also the subject of a Complaint under this Plan or other
complaint;(2)the number and type of alleged violations for which Complaints under this
Plan were filed;(3)the resolution of each Complaint under this Plan (dismissed or settled
prior to a decision, or decided with or without a hearing); and(4)the rights under this Plan
that were found by decision to have been violated. Courts and Employing Offices should
also provide any information that may be helpful in identifying the conditions that may
have enabled wrongful conduct or prevented its discovery, and what precautionary or
curative steps should be undertaken to prevent its recurrence.
14
F. Appendices Attached:
1. Definitions
2. Request for Assisted Resolution
3. Formal Complaint Form
4. Request for Review of Decision Procedures and Sample Form
5. Posters
6. Tenth Circuit Policy to Certify EDR Plan Compliance
This Plan supersedes all prior Equal Employment Opportunity and Employment Dispute
Resolution Plans of the District and Bankruptcy Courts for the Western District
of Oklahoma and incorporates changes mandated by the Tenth Circuit Judicial Council
on October 7, 2024.
Approved for the United States District Court for ^e Western District of pklahoma:
'%(/
Date Timothy DeGiusti
Chief United States District Judge
Approved for the United States Bankruptcy Court for the Western District of Oklahoma:
Date Sarah Flail
Chief Bankruptcy Judge
15
DEFINITIONS
APPENDIX 1
Circuit Director of Workplace Relations: A circuit Employee who coordinates
workplace conduct issues and the implementation of all Court EDR Plans within the circuit.
The scope of duties may vary by circuit, but generally, a Circuit Director of Workplace
Relations may: provide Informal Advice and Assisted Resolution under any EDR Plan
within the circuit; assist in training the EDR Coordinators within the circuit; provide or
arrange for training throughout the circuit on workplace conduct, discrimination, and
sexual harassment; and collect and analyze statistical data and other information relevant
to workplace conduct matters.
Court: The Court(Courts ofAppeals,District Courts,Bankruptcy Courts, Court ofFederal
Claims and Court of International Trade, or of any Court created by an Act of Congressin
a territory that is invested with any jurisdiction of a District Court ofthe United States) in
which the Employing Office that would be responsible for ordering redress, correction, or
abatement of a violation of rights under this EDR Plan is located. In the case of disputes
involving employees ofthe federal public defender,"Court" refers to the appropriate Court
ofAppeals. In the case of disputes involving probation and pretrial services,"Court" refers
to the appropriate District Court.
EDR Coordinator: A Court Employee, other than a Judge or Unit Executive, designated
by the Chief Judge to coordinate all ofthe Options for Resolution provided for in this Plan.
The EDR Coordinator provides confidential advice and guidance (see § IV.B.l.) if an
Employee seeks Informal Advice; coordinates the Assisted Resolution process, including
any necessary investigation; accepts Complaints under this Plan for filing; and assists the
Presiding Judicial Officer in the Complaint proceeding, as directed. The EDR Coordinator
maintains and preserves all Court files pertaining to matters initiated and processed under
this EDR Plan. The EDR Coordinator assists the Court in meeting its obligations under this
Plan to train and advise employees of their rights under this Plan, and to post the Plan as
directed. Additional information on the EDR Coordinator's responsibilities may be found
in the EDR Interpretive Guide and Handbook.
Employee: All employees of a Court. This includes Unit Executives and their staffs;
judicial assistants and other chambers employees; law clerks; federal public defenders,
chief probation officers and chief pretrial services officers and their respective staffs; court
reporters appointed by a Court; and paid and unpaid interns, extems, and other volunteer
employees.
Employing Office/Respondent: The office of the Court, or Federal Public Defender
Office, that is responsible for providing any appropriate remedy. The Court is the
Employing Office of Judges and chambers employees.
Judge: A judge appointed under Article III ofthe Constitution, a United States bankruptcy
judge, a United States magistrate judge, a judge of the Court ofFederal Claims, a judge of
the Court of International Trade, or a judge of any Court created by Act of Congress in a
territory that is invested with any jurisdiction of a district court ofthe United States.
Office of Judicial Integrity: The office of the Administrative Office ofthe United States
Courts staffed to provide advice and guidance to Employees nationwide about workplace
conduct issues, including sexual, racial, and other discriminatory harassment, abusive
conduct and other wrongful conduct. Contact information for the Office of Judicial
Integrity can be found on JNet and on uscourts.gov.
Parties: The Employing Office and the Employee who has filed a request for Assisted
Resolution or a Formal Complaint.
Protected Category: Race, color, sex, gender, gender identity, pregnancy, sexual
orientation, religion, national origin, age(40 years and over),"^ or disability.
Unit Executive: Circuit executive, district court executive, clerk of court, chief probation
officer, chief pretrial services officer, federal public defender, bankruptcy administrator,
bankruptcy appellate panel clerk, senior staff attorney, chief preargument/conference
attorney/circuit mediator, or circuit librarian.
The age discrimination provision does not apply to hiring, retirement, or separation of probation and pretrial services
officers under 5 U.S.C. chapters 83 and 84.
Effective date: September 17, 2019
REQUEST FOR ASSISTED RESOLUTION
APPENDIX 2
*USE OF ASSISTED RESOLUTION DOES NOT EXTEND THE 180-DAY
DEADLINE TO FILE A FORMAL COMPLAINT UNLESS THE DEADLINE IS
EXTENDED UNDER EDR PLAN § IV.C.S.a'^
Submitted under the Procedures of the Western District of Oklahoma
Employment Dispute Resolution Plan
Court:
Full name of person submitting the form:
Your mailing address:
Your email address:
Your phone number(s):
Office in which you are employed or applied to:
Name and address of Employing Office from which you seek assistance {if the matter
involves ajudge or chambers employee, the Employing Office is the Court):
Your job title/job title applied for:
Date ofinterview (for interviewed applicants only):
Date(s) of alleged incident(s)for which you seek Assisted Resolution:
Summary of the actions or occurrences for which you seek Assisted Resolution (attach
additional pages as needed):
Names and contact information of any witnesses to the actions or occurrences for which
you seek Assisted Resolution:
Describe the assistance or corrective action you seek:
Alleged Wrongful Conduct for which you seek Assisted Resolution {check all that apply):
Discrimination based on {check all Harassment based on {check all that
that apply): apply)-.
■ Race ■ Race
■ Color ■ Color
■ Sex ■ Sex
■ Gender ■ Gender
■ Gender identity ■ Gender identity
■ Pregnancy ■ Pregnancy
■ Sexual orientation ■ Sexual orientation
■ Religion ■ Religion
■ National origin ■ National origin
■ Age ■ Age
■ Disability ■ Disability
Abusive Conduct Uniform Services Occupational Safety
Retaliation Employment and and Health
Whistleblower Reemployment Polygraph Protection
Protection Rights Other (describe)
Family and Medical Worker Adjustment
Leave and Retraining
Do you have an attorney or other person who represents you?
■ Yes
Please provide name, mailing address, email address, and phone number(s):
No
I acknowledge that this Request will be kept confidential to the extent possible, but
information may be shared to the extent necessary and with those whose involvement is
necessary to resolve this matter, as explained in the EDR Plan (see EDR Plan § IV.B.l).
Your signature
Date submitted
Request for Assisted Resolution reviewed by EDR Coordinator/Circuit Director of
Workplace Relations on
EDR Coordinator/Circuit Director of Workplace Relations name
EDR Coordinator/Circuit Director of Workplace Relations signature
Claim ID (OKWD-AR-YY-Sequential Number):
FORMAL COMPLAINT FORM
APPENDIX 3
Submitted under the Procedures of the Western District of Oklahoma
Employment Dispute Resolution Plan
Court:
Full name of person submitting the form (Complainant):
Your mailing address:
Your email address:
Your phone number(s):
Office in which you are employed or applied to:
Name and address of Employing Office from which you seek a remedy (if the matter
involves ajudge or chambers employee, the Employing Office is the Court):
Your job title/job title applied for:
Date of interview (for interviewed applicants only):
Date(s) of alleged incident(s)for which you seek a remedy:
Summary of the actions or occurrences giving rise to the Complaint (attach additional
pages as needed):
Describe the remedy or corrective action you seek {attach additional pages as needed)'.
Identify, and provide contact information for, any persons who were involved in this
matter, who were witnesses to the actions or occurrences, or who can provide relevant
information concerning the Complaint {attach additional pages as needed):
Identify the Wrongful Conduct that you believe occurred {check all that apply):
Discrimination based on {check all Harassment based on {check all that
that apply): apply):
■ Race ■ Race
■ Color ■ Color
■ Sex ■ Sex
■ Gender ■ Gender
■ Gender identity ■ Gender identity
■ Pregnancy ■ Pregnancy
■ Sexual orientation ■ Sexual orientation
■ Religion ■ Religion
■ National origin ■ National origin
■ Age ■ Age
■ Disability ■ Disability
■ Abusive Conduct
■ I have already sought Assisted Resolution for this Abusive Conduct claim. (You
must seek Assisted Resolution before filing a Formal Complaint for an Abusive
Conduct claim. EDR Plan,§§ IV.C.2(a) and IV.C.3(b).)
Provide date Request for Assisted Resolution submitted and concluded, and describe the
resolution, if any:
Retaliation Family and Medical Employment and
Whistleblower Leave Reemployment
Protection Uniform Services Rights
Worker Adjustment ■ Occupational Safety ■ Polygraph Protection
and Retraining and Health ■ Other (describe)
Do you have an attorney or other person who represents you?
■ Yes
Please provide name, mailing address, email address, and phone number(s);
No
■ I have attached copy(ies)of any documents that relate to my Complaint(such as emails,
notices of discipline or termination,job application, etc.)
I acknowledge that this Complaint will be kept confidential to the extent possible, but
information may be shared to the extent necessary and with those whose involvement is
necessary to resolve this matter, as explained in the EDR Plan (see EDR Plan § IV.B.1).
I affirm that the information provided in this Complaint is true and correct to the best of
my knowledge:
Complainant signature
Date submitted
Complaint reviewed by EDR Coordinator on
EDR Coordinator name
EDR Coordinator signature
Claim ID (OKWD-FC-YY-Sequential Number):
REQUEST FOR REVIEW OF DECISION(APPEAL)
APPENDIX 4
Submitted under the Procedures ofthe Tenth Circuit Court of Appeals Employment
Dispute Resolution Plan
Procedures for Review by
the Judicial Council of the Tenth Circuit
of Final Decisions and Summary Dismissals under the Employment Dispnte
Resolution Flans of the United States Courts of the Tenth Circuit
Approved by the Judicial Council ofthe Tenth Circuit
October 2, 2024
§1 Petition for Review
A. Notice of Procedures for Review
A party or individual aggrieved by a final decision or summary dismissal of a claim or complaint
filed under the Employment Dispute Resolution Plan("EDR Plan") of the United States Court of Appeals
for the Tenth Circuit or any of the District Courts or Bankruptcy Courts within the Tenth Circuit, may
petition for review of that decision under the following procedures established by the Judicial Council of
the Tenth Circuit(the "Judicial Council"). The EDR Coordinator for the employing court must inform all
persons served with notice of such final decision or summary dismissal of these procedures for seeking
review by the Judicial Council.
B. Timing and Form of Petition for Review
A petition for review must be sent to the Circuit Executive of the Tenth Circuit, by certified mail
or email, so long as the sender uses a Return Receipt to Confirm Delivery option and receives a Delivery
Confirmation notice in return, within 30 days of the date ofthe summaiy dismissal or final decision. Ifthe
thirtieth day falls on a Saturday, Sunday or court holiday, the deadline shall be extended to the next
following court business day. The petition must be in writing, and must be addressed to the Circuit
Executive, beginning "1 hereby petition the Judicial Council of the Tenth Circuit for review of the
{Presiding Judge's] order under the Employee Dispute Resolution Plan ofthe {name ofemploying court]."
Only one copy ofthe petition for review is required.
The petition must state the reasons why the petitioner believes that the Presiding Judge's
determinations were in error. The petition must be signed.
C. Receipt of Timely Petition in Proper Form; Record
Upon receipt ofa timely petition for review submitted in proper form under these rules,the Circuit
Executive will acknowledge receipt ofthe petition to all relevant parties, including the Presiding Judge and
the EDR Coordinator of the employing court. Upon receipt of such notice, the employing court will be
responsible for submitting the complete record of the EDR proceeding to the Circuit Executive, who must
then send the record to the Judicial Council for its consideration pursuant to Section 2, below. This record
must include copies of:
1. the complaint;
2. any memorandum, response, objections or other briefing submitted to the
Presiding Judge in connection with his or her consideration and disposition ofthe
claim or complaint;
3. any document, information or other record submitted to or received by the
Presiding judge in connection with his or her consideration and disposition ofthe
claim or complaint;
4. the Presiding Judge's order disposing ofthe claim or complaint;
5. the transcript of any hearing;
6. the petition for review; and
7. any other document that appears to be relevant and material to the petition.
§ 2 Consideration of Petition
A. Reviewing Judicial Officers
The petition for review will be reviewed by the entire Judicial Council, or the Chief Judge may
appoint a committee of the Judicial Council, which committee is empowered to act for and on behalf of
the Judicial Council in reviewing the petition.
B. Standard of Review
Any review will be conducted by the Judicial Council based on the record submitted under Section
1(C), above, and will be affirmed if the legal standards applied are consistent with judicial and
administrative decisions under the laws related to the rights protected by the employing court's EDR Plan
and decisions of the Judicial Council, the factual findings are supported by substantial evidence on the
record as a whole, and the discretionary decisions were not an abuse of discretion.
C. Action by Judicial Council
The Judicial Council may request written submissions or oral argument, and may affirm, reverse,
vacate or modify the decision under review. The decisions of the Judicial Council must be in writing
and shall be final and conclusive, and shall not be subject to any fiirther review or appeal. The decision
must not name the complainant or any individuals, and must be captioned as follows:
In the matter of a [Request for Counseling or Complaint] filed under the Employment
Dispute Resolution Plan of the[Name of Employing Court].
Judicial Council EDR Case No.[year-number]
The Circuit Executive must provide a copy ofthe final decision to all parties and to the Chief
Judge and EDR Coordinator of the employing court.
§ 3 Record of final decisions; Publication Policy.
All courts within the Tenth Circuit shall, at the conclusion of EDR Formal Complaint
proceedings, provide a copy ofthe final EDR decision to the Tenth Circuit Director of Workplace
Relations. Final decisions made following Formal Complaint proceedings under all EDR Plans
with the Tenth Circuit will be made available to the public free of charge upon written request
addressed or emailed to the Tenth Circuit Director of Workplace Relations. The EDR Presiding
Judicial Officer's decision shall be the "final decision" if no timely Petition for Review of that
EDR decision is filed. Ifa timely Petition for Review ofan EDR decision is filed, then the decision
of the Judicial Council (or its Employment Dispute Resolution Committee) on that Petition for
Review shall be the "final decision". The Tenth Circuit Director of Workplace Relations shall
ensure uniform redaction of names and identifying information ofall parties, alleged violators, and
other individuals involved as well as other sensitive information that appears in a final decision
before the final decision is released to the public.
POSTERS
APPENDIX 5
INFORMAL ADVICE
To request advice about a workplace concern,
contact your Employment Dispute Resolution
(EDR) coordinator, Circuit Director of Workplace
Relations, or the Office of Judicial Integrity.
They can provide you with advice and guidance ASSISTED RESOLUTION
on how to address the issue including: Contact an EDR Coordinator or Circuit
• Your rights under the EDR Plan Director of Workplace Relations to request
• Advice on handling discriminatory, Assisted Resolution. This interactive,
harassing, or abusive conduct flexible process may include:
• Discussions with the source of the
• Options for addressing the conduct
conduct
• Preliminary investigation, including
interviewing witnesses
• Resolving the matter by agreement
FORMAL COMPLAINT
Contact an EDR coordinator to file a formal complaint.
The Complaint must be filed within 180 days of the
alleged violation or the discovery of the violation.
This formal process includes:
• Appointment of Presiding Judicial Officer Contact Information:
• An investigation and/or hearing if appropriate Local EDR Coordinators
Melanie Jester – 405-609-5166
• Written decision
[email protected]
• Appeal rights Kelly Edwards – 405-609-5846
[email protected]
Kathleena Kruck – 405-609-5661
Confidentiality
[email protected]
All options for resolution are intended to respect
privacy of all involved to the greatest extent Circuit Director of Workplace Relations
possible, and to protect the fairness and Cleo Rauchway
thoroughness of the process by which allegations Phone 303-335-2690
of wrongful conduct are initiated, investigated, and Email
[email protected]
ultimately resolved.
National Office of Judicial Integrity
202-502-1603
[email protected]
Effective date: December 1, 2025
Employees of the Federal Judiciary are protected by the employment rights listed below, as described in Guide to
Judiciary Policy, Vol. 12, Ch. 2.
Employees have options for resolution, including Informal Advice, Assisted Resolution, and filing a Formal Complaint.
Formal Complaints must be filed within 180 days of when the Employee knew or should have known of the alleged violation.
More information, including a list of court EDR Coordinators, can be found on JNet.
Employees may confidentially report workplace discrimination, harassment, abusive behavior, or retaliation to an EDR
Coordinator, Circuit Director of Workplace Relations, or the Judicial Integrity Officer, Cleo J. Rauchway, at 202-502-1603.
Protection from Unlawful Family and Medical Leave Hazard-Free Workspaces
Discrimination Provides rights and protections for Requires employing offices to comply
Prohibits discrimination in personnel employees needing leave for with occupational safety and health
actions based on race, color, sex, specified family and medical reasons. standards, and provide workplaces
gender, gender identity, pregnancy, free of recognized hazards.
sexual orientation, religion, national
origin, age (40+), or disability.
Protection for Veterans and
Members of the Uniformed Polygraph Testing Prohibition
Services Restricts the use and the results of
Protection from Harassment Protects employees performing polygraph testing.
Prohibits sexual harassment, service in the uniformed services
discriminatory harassment, and from discrimination and provides
abusive conduct. certain benefits and reemployment
rights.
Protection for Exercising
Workplace Rights Notification of Office Closings
Prohibits intimidation, retaliation, or and Mass Layoffs
discrimination against employees Under certain circumstances,
who exercise their employment rights requires that employees be notified of
or report or oppose wrongful conduct, an office closing or of a mass layoff at
including whistleblower protection. least 60 days in advance of the event.
These rights are fully explained in Guide to Judiciary Policy, Vol. 12, Ch. 2.
Effective date: December 1, 2025
UNITED
The Employment Dispute Resplutipn
File a complaint with
an EDR coordinator
within 180 days of the
conduct (or discovery
of the conduct),
Gather ''-"l
Information
The Presiding Judicial
Officer decides what
Investigation and
discovery are needed
and if written
arguments are needed.
Hearing #/\t
The Presiding
Judicial Officer
determines if a
hearing is needed
DECISION
RIGHTS
An impartial investigation and/or hearing, ifappropriate.
Both parties may use a representative or attorney (at
own expense).
Both parties may present witnesses and examine
adverse witnesses.
A prompt written decision by a Presiding Judicial Officer.
Appeal.
Parties have the right to appeal to the circuit
judicial council within 30 days of a decision.
Effective date: September 17,2019
TENTH CIRCUIT JUDICIAL COUNCIL EDR COMPLIANCE POLICY
APPENDIX 6
TENTH CIRCUIT JUDICIAL COUNCIL POLICY
TO CERTIFY EDR PLAN COMPLIANCE.
A. Background
Chapter V(C)and(D)of the national Model EDR Plans as well as the Tenth Circuit's model
EDR Plans (for Courts and Federal Public Defender Organizations) contain numerous
requirements that must be followed by courts and employing offices, namely that each court and
FPDO:
• Have at least two EDR Coordinators, both of whom are trained and certified in
accordance with the EDR Interpretive Guide and Handbook;
• Prominently post on their internal and external website homepages the entire EDR Plan;
contact information for all of the Court's EDR Coordinators, Circuit Director of
Workplace Relations, and the national Office of Judicial Integrity; the Judicial Conduct
and Disability Act, the Rules for Judicial-Conduct and Judicial-Disability Proceedings,
and the Judicial Conduct and Disability Complaint form;
• Prominently post in court and employing office workplaces the EDR posters and a
specific anti-discrimination and anti-harassment notice, also with EDR contact
information;
• Ensure that all new employees receive a copy of the EDR Plan and acknowledge they
have read it; and
• Conduct annual EDR training for all judges and employees.
The Tenth Circuit Judicial Council has adopted the following policy that requires Courts and
FPDOs within the Circuit to annually certify to the Tenth Circuit Executive that they are in
compliance with their EDR Plan Chapter V requirements:
B. Adopted Compliance Policy
§ 1. Authority. Under the council's statutory authority provided in 28 U.S.C. § 332(d), the
Judicial Council ofthe Tenth Circuit hereby adopts the following policy.
§ 2. Scope. This policy applies to the Court of Appeals and its employing offices; the
bankruptcy appellate panel; district courts and bankruptcy courts, including probation and
pretrial services offices and any other internal employing offices; and the federal public defender
organizations(FPDOs)within the Tenth Circuit.
§ 3. Compliance with EDR Court and Employing Office Obligations. Within thirty
days of the end of each fiscal year, the Tenth Circuit Director of Workplace Relations
(DWR), acting on behalf of the Judicial Council and the Circuit Executive's Office,
will request all Tenth Circuit courts and FPDOs to certify that it and all of their
employing offices are in full compliance with the obligations in (and as more fully
described in) the EDR Plan to:
• Designate a primary EDR Coordinator and alternate EDR Coordinator, each of
whom has been trained and certified as required;
• Prominently post a direct link on their internal and external main homepages to
the entire EDR Plan; the Judicial Conduct and Disability Act, the Rules for
Judicial-Conduct and Judicial-Disability Proceedings, and the Judicial Conduct
and Disability Complaint form; and contact information for all of the court's
EDR Coordinators, Circuit Director of Workplace Relations, and the national
Office of Judicial Integrity;
• Display in their workplaces the EDR posters attached to the EDR Plan and the
requisite Anti-Discrimination and Harassment Notice;
• Ensure that all employees have received a copy of their EDR Plan and have
acknowledged that they read it;
• Conduct training annually for all judges, including chambers staff; and
employees; and
• Provide the requisite annual EDR data to the Administrative Office ofthe United States
Courts.
§ 4. EDR Complaint Record-Keeping. The Tenth Circuit Director of Workplace Relations
shall be designated as an alternate EDR Coordinator in all of the courts and FPDOs. If an
employee submits an EDR Formal Complaint to a local EDR Coordinator other than the Tenth
Circuit Director of Workplace Relations, that local EDR Coordinator must provide to the Tenth
Circuit Director of Workplace Relations, within five business days of submission, a copy of the
EDR Formal Complaint; the designation of the Presiding Judicial Officer; the Respondent's
Response; and the written final decision ofthe designated Presiding Judicial Officer. At the
conclusion of EDR Formal Complaint proceedings a copy of all other papers, files, and reports
related to the EDR Complaint shall be filed with the Tenth Circuit Director of Workplace
Relations.
§ 5. Attachment of This Policy to EDR Plans. A copy of this Policy shall be attached as an
additional Appendix to all Tenth Circuit Court and FPDO EDR Plans.
