To the reader,

     I am writing you an important message and I hope you will bear with
the message length as everything that has happened to me must be brought
to your attention.  Beginning a few years ago, I have suffered hardship at
my workplace because I am hearing impaired.  Particularly after I started
to complain to the Fair Employment and Housing Commission in Santa Ana, 
California and to the Equal Employment Opportunity Commission, I have been  
treated as a pariah.  Below is the letter from my attorney to Disney.  

<start>

THIS LETTER IS INTENDED FOR SETTLEMENT PURPOSES ONLY AND PURSUANT TO 
        EVIDENCE CODE #1152 IS NOT ADMISSABLE FOR ANY REASON

December 28, 1994

Dear Ed:

     We represent Richard Roehm with reference to his claims against the 
Disney Company.
     
     Mr. Roehm is deaf.  He has been an employee at Disneyland for over
thirteen years. since at least 1990, Mr. Roehm has been a constant victim of
blatant job discrimination and experienced directed and steady acts of 
retaliation by management for reporting Disney's discriminatory practices.
Further almost all of Mr. Roehm's requests for reasonable accommodation have
been met with either indifference or contempt.
     
     Mr. Roehm began with the Disney Company at Disneyland in the kitchen of
the Country Critters restaurant as a Culinary Host in 1981.  His duties 
consisted of cleaning the kitchen and doing basic food preparation.  By 1985,
Mr. Roehm was used as a Relief Receiver for two to three days per week in
addition to his responsibilities as a Culinary Host.
     
     When the Receiver needed help or was unavailable, Mr. Roehm filled in.
Both the Relief Receiver position and the Receiver position were at a higher
status and salary level than that of a Culinary Host.  At times, when the
Receiver position vacant, Mr. Roehm functioned as a Receiver, but was never
paid additionally for his services as a Receiver or a Relief Receiver.
     
     When Mr. Roehm functioned as a Relief Receiver, other individuals, 
usually two at a time, were designated as Back-up Receivers and worked under
Mr. Roehm's supervision assisting him and the Receiver when necessary.  For
approximately nine (9) years, as a Relief receiver, Mr. Roehm trained 
numerous Back-up Receivers.  Most recently, Mr Roehm was acting as Receiver
since that position has been open for three (3) months.  In that capacity Mr.
Roehm supervised the work of the Relief Receiver and the Back-up Receivers.
     
     Since 1983, Mr. Roehm had observed that it was standard practice to
promote the Relief Receiver to the position of Receiver when the Receiver job 
was vacated.  This occurred on numerous occaisons.  Yet, Mr. Roehm was not
promoted to the position.  In 1990 and again in 1992, the Back-up Receiver
directly under Mr. Roehm's supervision was promoted over him.  On the 
subsequent occaisons, in 1993 and 1994, neither Back-up Receivers wanted the
position. In those cases, in an unprecedented move, management decided to
advertize the Receiver position park-wide and fill it outside of mr. Roehm's
department with individuals wheo were clearly not qualified for the position
nor had any experience whatsoever.
     
     The circumstances below are illustrative.  In February, 1990, the 
Receiver position was vacated.  Mr Roehm was next in line.  However, the
Back-up Receiver under Mr. Roehm that he had trained and been supervising,
Michael Oskorus, was promoted to Receiver.
     
     In 1992 when Mr. Roehm was passed over for promotion, Mr. Oskorus
vacated the position and Tony Miller, the Back-up Receiver next in line that
Mr. Roehm had trained and was supervising was promoted to Receiver.
     
     Mr. Roehm was extremely distraught and began experiencing physical and
emotional repercussions as a result of Disney's discriminatory practices.
     
     In March of 1992, Mr. Roehm complained to the California Department of
Fair Employment and Housing (DFEH).  Subsequent to his DFEH complaint, he was
retaliated against via his 1992 annual evaluation.  After receiving successive
satisfactory employment evaluation ratings,  Mr. Roehm received a rating of
"Does Not Meet Disney Standards" on his June, 1992 and his September, 1993
evaluations.  Additionally his superiors became nonresponsive to his needs,
found fault with his work, and did not communicate with him in a timely
fashion regarding his work and work-related activities.
     
     In November, 1993, the receiver position was available again.  This time  
neither Back-up Receiver wanted the position.  In an unprecedented move, Joe
Lazzari, Mr. Roehm's supervisor told Mr. Roehm that the position was to be
advertized park-wide.  The individual that received the position was neither
trained nor had the requiste experience.
     
     In January, 1994, Mr. Roehm filed another DFEH complaint.  At his annual
evaluation, Mr. Roehm was given ratings of "Does Not Meet Disney Standards".
His superiors continued to chatise his work, berate him and were nonresponsive
to his work related needs.
     
     The Receiver position again became available in August, 1994.  Mr. Roehm
was told that the job was to be advertized park-wide again.  Mr. Roehm was
asked toofficially act as Receiver until the position was filled.  Mr. Roehm
acted as Receiver for approximately three (3) months performing the job
competently and successfully.  In November, 1994, Mr. Roehm was told he would
not be given the position. He was told that he was now being permanently
assigned to the kitchen.
     
     It is clear that Mr. Roehm could perform the job as a Receiver 
successfully and competently.  Not only had he been actually performing the
Receiver's job in the capacity of Relief Receiver and trained others who were
later given the job, but he was named Receiver temporarily when the position
was vacated in 1994.  However, he never received either the pay or the title
in this capacity and never received the permanent position.
     
     It should be noted that until Mr. Roehm reported that he was being
discriminated against on his job, his performance evaluations were
satisfactory in all categories.
     
     Further, despite management's later criticisms of Mr. Roehm's performance
(after he complained), Mr. Roehm continued to be an asset to the park.  He
installed a long-awaited FAX program on the computers, developed a 
computerized food inventory program that was vitally needed (and now much 
used) and won awards and commendations from other units for improving Park-
wide operations.  He continued acting as a Relief Receiver as he always had
and performed his job in a responsible and productive manner.
     
     Over the years, Mr. Roehm's job and the technology related to his 
position evolved such that he needed several accommodations in order to
efficiently do his job.  On numerous occaisons, Mr. Roehm made requests for
reasonable accommodation that would enable him to do his job as a deaf
employee and feel a part of the Department.  Rather than accommodate him, Mr.
Roehm was left to fend for himself.
     
     For example, almost immediately upon becomming a Relief Receiver, in 1985
it became clear to Mr. Roehm that it was neccesary for him to communicate with
other restaurants and food sites throughout the Park since the distribution of
food covered more sites and a wider area.  Mr. Roehm, like most deaf
individuals, cannot use the telephone.  It is neccesary for him to communicate
with others through a device called a telecommunications device for the deaf 
(TDD) which operates over the phone lines, similar to a teletypewriter.
     
     Unless the receiving individual also has a TDD, the deaf caller must 
call a relay operator who is hearing and serves as a translator.  The relay 
operator then places the call to the individual designated by the deaf caller
and serves to interpret both the TDD message that is sent by the deaf caller 
and the voice message back (to the deaf caller) sent by the hearing person
called.
     
     On numerous occasions Mr. Roehm requested that TDDs be installed at key
sites so that he could communicate with others directly.  At the very least,
Mr. Roehm requested that Disney furnish a TDD for him and an inside phone 
line so that he could call the relay operator who could eventually relay his
call or get a message to key sites.  Disney refused to accomodate either
request.
     
     Beginning aproximately 1988, Mr. Roehm began to lug his own, personal TDD
to work everyday and home every evening.  This was an extreme burden.  He had
to disconnect the device at home from his home phone line every morning in 
order to bring it to work.  Then when he was "beeped" on his pager in the
park, he had to go and retrieve his TDD from the Receiver office, find a pay
phone in the park that was available, have the correct change, find somewhere
to place the TDD, hook it up and make the phone call to the Deaf Relay Service
Operator who then called the site in the Park that had originally paged him. 
By then significicant time has elapsed and this impacted Mr. Roehm's ability
to complete requested tasks in a timely manner.
     
     On his own, in approximately 1991, Mr. Roehm discovered that the 
Disneyland Hotel actually had four TDDs for its deaf visitors.  He tried to
use the Hotel staff to relay his messages since an outside line was not 
required.  However, the Hotel staff considered Mr. Roehm's calls a burden and 
either hung up on him or interrupted his calls such that they were not 
completed.
     
     Mr. Roehm requested on numerous occaisons, beginning in approximately
1981, that a sign language interpreter be present at all staff meetings so
that he could follow the discussion.  However, there were dozens of 
important meetings and Disney only provided an interpreter on three occaisons.
At all other times he was told "something happened" to the interpreter.  Mr.
Roehm wascompletely left out of staff meetings and relegated to second-class
status.  He had to gather information from co-workers after the facts that was
often incomplete or inaccurate.  Further, due to the fact that he was unable
to participate in the discussions he was never able to ask questions, give 
in-put or vote on any decisions.
     
     Mr. Roehm's requests were met with contemptuous response.  On several
occaisons his supervisors rolled his eyes upwards coupled with an exasperated
expression.  This lack of reasonable accommodation alone, that of not 
providing interpreters at employment meetings, has been grounds for 
significant claims brought on by deaf individuals.
     
     As another example, on numerous occaisons, Mr. Roehm was accused of 
raising his voice, making threats or behaving angrily.  Deaf people, unable to
monitor their own voices (because they cannot hear themselves speak)
oftentimes speak loudly, gruffly and in uneven tones that may appear 
threatening to a hearing individual not used to deaf speech.  Upon explaining
this supervisors, Mr. Roehm was criticized further.
     
     Mr. Roehm's supervisors over the years were consistently insensitive as
well as unaccommodating to his deafness.  As an example, Mr. Roehm's latest
superior, Todd Collard, wrote Mr. Roehm an E-mail message telling him that he
was responsible for his own problems and that he sould keep quiet.
     
     In summary, The facts show that Disney refused to give Mr. Roehm a job
that he was already successfully performing simply because he is deaf.
     
     Further, Mr. Roehm was not provided interpreters for important meetings,
a TDD so that he could communicate with other stations or a beeper that was
adapted to accommodate his handicap despite numerous requests over 13 and a
half (13.5) year period.  These accommodation requests were all reasonable and
clearly would not have created an undue burden to the Disney Company.  They
were all low cost, convenient and appropriate accommodations for a deaf
employee.
    
    As a result of this continual denigration and humilation at work and 
accumulated years of Disney's lack of accommodation of Mr. Roehm's deafness,
Mr. Roehm suffered and is still suffering extreme emotional distress.  Mr.
Roehm's psychiatrist recommended that he go out on a disability leave last
month.  He is suffering from serious emotional problems as result of seeing
his career negated and his needs as a deaf person completely ignored. He
cannot eat or sleep normally, feels extremely anxious and nervous.  Mr. Roehm
is currently under the care of two physicians and takes several medication
daily.  His psychiatrist reports that he will require treatment for quite
some time.
     
     The Disney Company displayed astonishingly egregious and flagrant
discrimination against Mr. Roehm.  We are prepared to initate claims of
discrimination and retaliation against the Disney Company.  However, as a
precendent to litigation we have recommended to Mr. Roehm that we first
determine whether this matter can be resolved by negotiations.
     
     I look forward to hearing from you after you have had an opportunity to
look into the matter.


<end>

Thank you for taking the time to read and understand this very lenghthy
complaint.

Richard Roehm