Reply-To: "Lee Kent"
From: "Lee Kent"
To:
Subject: Complaint Initial
Date: Wed, 28 Aug 2002 13:43:35 -0400
MIME-Version: 1.0
Content-Type: multipart/alternative;
boundary="----=_NextPart_000_54EE_01C3422F.51673400"
X-Priority: 3
X-MSMail-Priority: Normal
X-Mailer: Microsoft Outlook Express 6.00.2600.0000
Disposition-Notification-To: "Lee Kent"
X-MIMEOLE: Produced By Microsoft MimeOLE V6.00.2800.1165

This is a multi-part message in MIME format.

------=_NextPart_000_54EE_01C3422F.51673400
Content-Type: text/plain;
charset="iso-8859-1"
Content-Transfer-Encoding: quoted-printable

Mr. Sanders,

Per our telephone conversation of last week I am providing you with the =
following information in advance of its transmittal to you in U.S. mail. =
I have the initial intake form as you provided it to Patricia Thompson =
for my use and I will be submitting it to you in the mail transmittal. =
Below are the following:

1: The letter of introduction
2: The Form 5 synopsis and summary of the charges of discrimination
3: The letter I provided to Patricia Thompson in support of her case =
before the EEOC.

If there is anything else I need to include with this filing please so =
inform and thank you for your kindness and attention.

Lee Kent Hempfling
53 Muirfield Parkway
Charleston SC 29414
843-327-1996
leekent@comcast.net

=20

Billy C. Sanders, Program Manager

United States Equal Employment Opportunity Commission

Charlotte District Office

129 W. Trade Street

Suite 400

Charlotte NC 28202

=20

August 30, 2002

=20

Mr. Sanders;

=20

Enclosed with this letter are the complaint, the initial intake form, =
contents of Form 5, document manifest, implied employment contract =
examination, supporting documents of non-email nature, supporting email =
documents, copy of the FBI complaint, copy of the FCC complaint, copy of =
the letter sent to the owner of the former employer and copy of my =
statement to the EEOC regarding discrimination issues related to the =
filing of Patricia Thompson.

=20

I respectfully submit these documents as a formal complaint filed =
against my former employer: L.M. Communications Inc. and its =
subsidiaries, L.M. Communications of South Carolina Inc. and L.M. =
Communications of South Carolina II Inc. and request an investigation =
and the pressing of charges for violating my rights under Title VII of =
the Civil Rights Act of 1964, as amended.

=20

I seek redress of grievances for the violations of law perpetrated =
including those outlined in the FBI and FCC complaints attached as =
retaliation actions taken against me and such relief maximum as =
permitted by law to make me whole and whereas the discrimination was =
intentional: such compensatory and punitive damages as may be acquired =
as the maximum permitted by law including actual monetary losses, future =
monetary losses, and for mental anguish and inconvenience.=20

=20

Since it is outlined and proven within these documents that the employer =
acted with malice and reckless indifference I further seek such punitive =
damages to the maximum permitted by law.

=20

I further seek that the employer be required to post notices to all =
employees addressing the violations of each specific charge and advising =
them of their rights under the laws EEOC enforces and their right to be =
free from retaliation.

=20

I further seek the employer be required to take corrective or preventive =
actions to cure the source of the identified discrimination and minimize =
the chance of its recurrence, as well as discontinue the specific =
discriminatory practices involved in the case.

=20

I further seek specifically the elimination of any perceived non-compete =
condition and return of all monies provided to the employer in repayment =
of a forced moving loan.

Submitted via U.S. Mail August 30, 2002-08-28

=20

=20

Sincerely

=20

=20

___________________________

=20

Lee Kent Hempfling

53 Muirfield Parkway

Charleston S.C. 29414

843-327-1996

leekent@comcast.net

=20

=
-------------------------------------------------------------------------=
--------------------------------------------



FORM 5 (Test 10/94)

=20

Chare of Discrimination:

=20

[x] FEPA

[x] EEOC

=20

Name: Lee Kent Hempfling

Home Phone: 843-327-1996

Street Address: 53 Muirfield Parkway, Charleston S.C. 29414

DOB: 09/09/52

=20

Employer: L.M. Communications Inc.

# Employees: 15+

Phone: 843-769-4799

Street Address: 59 Windemere Blvd. Charleston S.C. 29407

=20

Cause of Discrimination Based On:

[x] Age=20

[x] Religion=20

[x] Retaliation

=20

Dates of Discrimination: Inclusive from 2/1/2002 to 7/25/2002

=20

The Particulars Are:

=20

I: I was subjected to discriminatory terms and conditions of =
employment, harassed, denied employment, subjected to a hostile =
religious and retaliatory work environment, denied employment and =
discharged from my full time position because of retaliation for my =
attempt to offer equal employment ability in hiring of minorities, =
complaining about the refusal of management to consider minorities for =
full time positions and objecting to and requesting management's =
intervention to stop harassment directed at me in the workplace and out =
of the workplace which "contributed to the hostile environment" =
experienced at work in violation of Title VII of the Civil Rights Act of =
1964, as amended.

=20

A: Retaliatory Intimidation I was subjected to =
included:

1: Threatening emails while =
employed.

2: Threatening email after =
discharge.

3: Threatening anti-Semitic =
terrorist photo sent in email.

4: Refusal to permit the carrying =
out of my job responsibilities.

5: Blame for lost commercial =
revenue.

6: Sabotage of work performed.

7: Public humiliation and character =
assassination.

8: Humiliation to staff by =
management.

9: Attempts to trick me into =
violating corporate policy.

10: Sabotage of transmitter power to =
damage performance.

11: Sabotage of station audio =
processing to damage performance.

12: Sabotage of program elements for =
my morning show.

13: I AND my wife were ordered not to access any phone number in the =
Lexington KY area code.

14: Refusal to permit work tools. (Supplied after I was discharged.)

15: Called a liar repeatedly.

16: Insulted continuously behind my back.

17: Ignoring every instance reported by me of alleged illegal activity.

18: Receipt of edited audio music file obviously claiming responsibility =
for my discharge.

19: Equipment was damaged.

20: Notices of unsafe working conditions were ignored.

21: Music scheduling software was tampered with.

22: Attack continued after employment.

23: Penalized for wanting to improve the midday show by reducing the =
show to part time if I wanted to replace the current staff member.

24: Rumors and innuendos.

25: Threatened with legal action.

26: Refusal to repair equipment.

27: Replacing equipment with inferior parts.

28: Hatred for 'black' music.

29: Branded a 'complainer'.

30: Intimidation of new employee before starting date.

31: Software was deleted from production equipment.

32: Given a broken 'boom box' to suffice for an aircheck machine.

33: Retaliation for stopping 'Plugola' on the air.

34: Continual reference to changing format.

35: Phone call from engineer yelling about a memo I was told to write =
asking for his help in changing microphones.

36: Show prep stolen from my desk.

37: Equipment in my desk was damaged.

38: Given a non-working phone for my desk.

39: Ethics questioned.

40: Interruptions on the 'hotline' while doing my show.

41: Tampering with the station's Legal ID

42: Given worst computer in the building for my desk.

43: Degradation of my wife for having spoken to Lynn Martin.

=20

=20

=20

II: The reason I was given for discharge was "poor performance =
of the station" however the Arbitron ratings results for the period in =
question showed "significant gains" according to Mindy Spar, =
entertainment writer for the Charleston Post & Courier. I tried =
repeatedly to hire a minority person full time but was forced out of my =
employment for doing so.

=20

III: I believe I have been discriminated against because of my =
religion, Jewish, and in retaliation for complaining about =
discrimination in violation of Title VII of the Civil Rights Act of =
1964, as amended.

=20

IV: At-Will employment does not apply as an implied contract was =
in force.

=20

V: Furthermore, the company discriminates against Blacks as a =
class relative to hiring, job assignments, wages, promotions, transfers, =
discipline and discharge and discriminates against those who object to =
such actions and discriminates against those who attempt to correct such =
actions.

=20

-------------------------------------------------------------------------=
----------------------------



Equal Employment Opportunity Commission

=20

August 27, 2002

=20

I, Lee Kent (Lee Kent) Hempfling, former Program Director of WCOO-FM a =
radio station owned by L.M. Communications II Of South Carolina Inc. and =
operated by L.M. Communications Inc. of Lexington KY. , located at 59 =
Windemere Charleston S.C. 29407 do hereby submit the following statement =
on behalf of and in support of the alleged EEO violations as submitted =
by Patricia Thompson, a Black, former part time radio announcer with =
same ... as follows:

=20

When I arrived at WCOO to begin my duties as program director I searched =
for documentation regarding current employees to determine the pay =
scales and terms whereby new employees would be hired in relation to =
existing employees.

=20

The only records I could find were copies located in my department and =
consisted of a few disciplinary records on past and present employees =
and two statements providing wage information. I could only assume that =
current part time employees were being treated equally.

=20

I asked General Manager Charlie Cohn what the rate was for part time =
employment in programming as both records on file indicated a vast =
discrepancy with one person receiving over $9.00 an hour and another =
receiving a monthly salary in order to keep him below his required =
disability earnings limit even though he was paid for outside work by =
writing the checks to his girlfriend instead of him (Wayne Morath).

=20

There were no pay records in the programming files for Patricia =
Thompson.=20

=20

Cohn's response was between $7.00 and $7.50 per hour after he inquired =
whom it was I was planning to hire. At that time it was Jessica Mickey =
to work Sunday mornings. This was before Ms. Thompson left the station.

=20

I again asked Cohn the same question when I hired Dwight (Landon) Lane =
for part time on Saturdays with the same response. This was after Ms. =
Thompson left the station.

=20

I was appalled to find out at a later date that Patricia Thompson had =
been with the station longer than any other part time employee and had =
been receiving far less in hourly rate.

=20

During the initial stages of my taking over the programming of WCOO I =
evaluated each employee's on air work performance and determined that =
Patricia Thompson was the most qualified current employee for promotion =
to full time status. This was based on my listening to her show and to =
tapes of her show provided by Ms. Thompson as the station did not have =
an air check machine so she taped her show on her own machine.

=20

After approximately 30 days of evaluation I approached Cohn informing =
him that I had decided for the best interest of the station's ratings =
potential to replace Linda (Logan) Grumbein in "middays" on air and to =
replace Wayne Morath (Skip St. John ) in the afternoon position and =
would be seeking the best qualified candidates through public =
advertisement in trade journals and on line trade publications.=20

=20

At that time I informed Cohn that I was thinking of Patricia Thompson as =
the midday replacement. His response was an emphatic 'no' with the =
reason given that he 'had issues with Trish'. He offered no further =
explanation at that time.

=20

I placed an equal opportunity ad on AllAccess.Com, and =
TVAndRadioJobs.Com for the afternoon position as a blind box because of =
the concern that both current parties would be disgruntled if they knew =
they were being replaced.=20

=20

Only Mike (Allen) Almond, then program director of WYBB (the sister =
station), Cohn and myself knew of the ads being placed.

=20

Shortly after the placement I listened to both Grumbein and Morath's air =
shifts and wrote an aircheck critique and letter to both separately =
indicating the problems they had on the air and the problems I had with =
their execution of the format.

=20

Both Grumbein and Morath approach Cohn about the critiques and wrote =
complaint letters about me to Cohn threatening legal action for having =
dared tell them how they were to perform their jobs.

=20

It was then that I looked deeper into what personnel records I had =
access to and noticed that Grumbein had been hired as full time status =
the day after I left for Charleston from Phoenix, Arizona. Such hiring =
was without equal employment opportunity as no public notice was made of =
the opening and no person within the station or outside of the station =
was given the ability to compete for the position.

=20

When I arrived I had been treated to a good deal of gossip about fellow =
employees from both Grumbein and Morath and Leslie Twigger (Office =
Manager) with Grumbein specifically referring to Patricia Thompson in =
derogatory terms and telling me to watch out for her.

=20

After careful consideration of the employees in the department I found =
the truth to be the opposite. Grumbein was the one to watch out for. =
Patricia Thompson was a professional and did not fit in with the =
unprofessional bickering and backbiting going on inside the department =
from Grumbein.=20

=20

Over the course of my employment I repeatedly approached Cohn about the =
midday position (afternoons were filled by hiring John Majhor of Sante =
Fe, New Mexico and severing the employment of Morath ) and each time I =
reiterated my strong belief that not only was Patricia Thompson the most =
qualified person in the building for the position but the station did =
not have a single full time black employee in programming. (Denise =
Moseley was the only other black employee and she was the receptionist). =
I strongly believed the station required an ethnic presence for proper =
presentation of the format and it appeared to me that the station did =
not care to do so.

=20

When Patricia Thompson resigned from the station she broke down and =
cried when she informed me of her decision. I told her I was planning to =
train her more as I had intended to move her into full time. She did not =
know at that time that I had been trying to do that without success.

=20

Ms. Thompson wrote a letter to L.M. Communications owner Lynn Martin in =
which she described the hostile environment she had suffered under while =
working in his station and told him of many other goings on all of which =
I was aware of but was unable to do anything about as I could not remove =
the two persons mostly responsible for the environment problems =
(Grumbein and engineer Bruce Musso who had begun a threatening email =
campaign directed at me and had been intimidating the staff I had hired =
ever since I had insisted to Cohn that the station have a black full =
time staff employee) and I could not do anything about Cohn's obvious =
distaste for involving Ms. Thompson in any station position.

=20

I was aware of a letter written by Ms. Thompson prior to my arrival =
where she brought up the problem of her not being given fair treatment =
for full time status and promotion and even though I do not remember her =
mentioning race in that letter it was my first reaction in reading it =
knowing the mannerisms and facial expressions used by Cohn when speaking =
of any minority person.

=20

In fact Cohn blamed the lack of sales for WCOO on the station not having =
a black salesman when it was obvious to me that color had nothing to do =
with sales. Cohn repeatedly tried to talk me into getting rid of the =
'black' format and to change the station to an all 80's format. =
Considering his close relationship with Musso and Musso's continuous =
attacks on me and those who worked for me I was convinced the problem =
was similar to Musso's racial bigotry, flying the confederate flag on =
his truck and carrying a gun in it as well.

=20

Shortly after her letter to Martin; Cohn and Almond approached me to =
inform me that they had offered a full time position in traffic to Ms. =
Thompson. It was not necessary for them to tell me that as I knew better =
from word inside the station and from Almond talking away from Cohn =
earlier in the search process for a midday replacement. I knew they were =
lying and trying to make up a cover story and they were trying to =
include me in it.

=20

Management was instructed by Martin, the owner, not to have contact with =
Ms. Thompson while any potential legal issues were outstanding yet =
knowing this, Cohn ordered me to call her to see what she wanted while =
at the same time insisting he would never hire her. I refused to =
disregard the owner's orders. I told Martin I considered that act to be =
a set up.

=20

Also shortly after that letter Cohn ordered me to train Denise Moseley =
as a part time air staff member. When I tried to coach her he refused to =
allow her to be coached unless it was on her own time. That move was =
simply to put a black person on the air, qualified or not and the =
refusal to permit coaching during paid working hours amounted to Cohn's =
insisting Moseley learn the job without the benefit of instruction =
thereby guaranteeing she would not learn. Cohn interrupted a training =
session and yelled at Moseley that she was not to do that on company =
time.

=20

Weeks went by when finally Consultant Don Hallett approached me at the =
station on an in station visit with Martin and told me it had been =
decided to replace Grumbein and that if I wanted "Trish" I should get a =
demo of hers and send it to him. I was then supposed to remove Grumbein, =
advertise properly for the position and include Ms. Thompson's demo as =
an applicant and if I still felt Ms. Thompson was the most qualified for =
the position that it would pay mid 20's and would be a full time =
position.=20

=20

Cohn rejected the instruction and refused to permit Grumbein's =
replacement with Ms. Thompson or Grumbein's discharge. I strongly =
believe the reason to be that Ms. Thompson had complained about unequal =
treatment in the past and Cohn refused to deal with that.

=20

When I later learned that Ms. Thompson was working for a lot longer and =
at a much lower pay scale than her white counterparts I was appalled =
that such behavior had been permitted and apparently condoned by the =
ownership.

=20

The EEOC is welcome to any material I have on file relating to WCOO and =
L.M. Communications (in all three of its incarnations) and they are =
offered in support of the correction of wrongs perpetrated upon Ms. =
Patricia Thompson and all other minority persons who have or may have =
worked for that company.

=20

I was fired on July 23 2002 which occurred the second day of the week =
following my airing of a parody commercial on WCOO that I wrote and =
produced using one of my character voices that spoke of the confederate =
flag as being a display of treason. I am convinced it was a major part =
in my discharge.

=20

A replacement morning personality was hired after I left without =
advertisement, without equal employment ability for any other race, =
creed, sex or national origin to compete for said position and the =
person was hired part time at what I believe to be $8.50 per hour.

=20

Hallett on behalf of Martin had asked me repeatedly if I intended to =
remain with the station until retirement. The answer was repeatedly, =
yes.=20

=20

I took the position based upon Martin's initial statement to me in the =
employment interview that he desired to have me stay until retirement =
even though the money offered was less than the initial discussions.=20

=20

I thought I could make a difference inside that station by standing up =
for what was right and at nearly 50 years of age an offer of 'stay until =
retirement' was a valuable asset in taking a position.

=20

I repeatedly, both orally and in writing requested a full time black =
employee in programming. The issue was repeatedly ignored.

=20

Sincerely

=20

=20

_____________________

=20

Lee Kent Hempfling

53 Muirfield Parkway

Charleston SC 29414

843-327-1996

leekent@comcast.net




------=_NextPart_000_54EE_01C3422F.51673400
Content-Type: text/html;
charset="iso-8859-1"
Content-Transfer-Encoding: quoted-printable



charset=3Diso-8859-1">




Mr. Sanders,

 

Per our telephone conversation of last week I am =
providing=20
you with the following information in advance of its transmittal to you =
in U.S.=20
mail. I have the initial intake form as you provided it to Patricia =
Thompson for=20
my use and I will be submitting it to you in the mail transmittal. Below =
are the=20
following:

 

1: The letter of introduction

2: The Form 5 synopsis and summary of the =
charges of=20
discrimination

3: The letter I provided to Patricia Thompson in =
support=20
of her case before the EEOC.

 

If there is anything else I need to include with =
this=20
filing please so inform and thank you for your kindness and=20
attention.

 

Lee Kent Hempfling

53 Muirfield Parkway

Charleston SC 29414

843-327-1996

href=3D"mailto:leekent@comcast.net">leekent@comcast.net

 


 prefix =3D o=20
ns =3D "urn:schemas-microsoft-com:office:office" />


.5in">Billy C.=20
Sanders, Program Manager


United States Equal =
Employment=20
Opportunity Commission


Charlotte District =
Office


129 W. Trade =
Street


Suite 400


Charlotte NC =
28202


 


August 30, 2002


 


Mr. Sanders;


 


Enclosed with this =
letter are the=20
complaint, the initial intake form, contents of Form 5, document =
manifest,=20
implied employment contract examination, supporting documents of =
non-email=20
nature, supporting email documents, copy of the FBI complaint, copy of =
the FCC=20
complaint, copy of the letter sent to the owner of the former employer =
and copy=20
of my statement to the EEOC regarding discrimination issues related to =
the=20
filing of Patricia Thompson.


 


I respectfully submit =
these=20
documents as a formal complaint filed against my former employer: L.M.=20
Communications Inc. and its subsidiaries, L.M. Communications of South =
Carolina=20
Inc. and L.M. Communications of South Carolina II Inc. and request an=20
investigation and the pressing of charges for violating my rights under =
Title=20
VII of the Civil Rights Act of 1964, as amended.


 


I seek redress of =
grievances for=20
the violations of law perpetrated including those outlined in the FBI =
and FCC=20
complaints attached as retaliation actions taken against me and such =
relief=20
maximum as permitted by law to make me whole and whereas the =
discrimination was=20
intentional: such EN">compensatory and=20
punitive damages as may be acquired as the maximum permitted by law =
including=20
actual monetary losses, future monetary losses, and for mental anguish =
and=20
inconvenience.


style=3D"mso-ansi-language: EN"> 


style=3D"mso-ansi-language: EN">Since it is outlined and proven within =
these=20
documents that the employer acted with malice and reckless indifference =
I=20
further seek such punitive damages to the maximum permitted by=20
law.


style=3D"mso-ansi-language: EN"> 


style=3D"mso-ansi-language: EN">I further seek that the employer be =
required to=20
post notices to all employees addressing the violations of each specific =
charge=20
and advising them of their rights under the laws EEOC enforces and their =
right=20
to be free from retaliation.


style=3D"mso-ansi-language: EN"> 


style=3D"mso-ansi-language: EN">I further seek the employer be required =
to take=20
corrective or preventive actions to cure the source of the identified=20
discrimination and minimize the chance of its recurrence, as well as =
discontinue=20
the specific discriminatory practices involved in the=20
case.


style=3D"mso-ansi-language: EN"> 


style=3D"mso-ansi-language: EN">I further seek specifically the =
elimination of any=20
perceived non-compete condition and return of all monies provided to the =

employer in repayment of a forced moving loan.


style=3D"mso-ansi-language: EN">Submitted via U.S. Mail August 30,=20
2002-08-28


style=3D"mso-ansi-language: EN"> 


style=3D"mso-ansi-language: EN"> 


style=3D"mso-ansi-language: EN">Sincerely


style=3D"mso-ansi-language: EN"> 


style=3D"mso-ansi-language: EN"> 


style=3D"mso-ansi-language: =
EN">___________________________


 


Lee Kent =
Hempfling


53 Muirfield =
Parkway


Charleston S.C. =
29414


843-327-1996


href=3D"mailto:leekent@comcast.net">leekent@comcast.net


 


 face=3DArial>------------------------------------------------------------=
---------------------------------------------------------


face=3DArial> 


justify">face=3D"Times New Roman">FORM 5 (Test 10/94)


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">Chare of Discrimination:


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">[x] FEPA


justify">face=3D"Times New Roman">[x] EEOC


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">Name: style=3D"mso-tab-count: =
2">           &nbs=
p;=20
 Lee Kent=20
Hempfling


justify">face=3D"Times New Roman">Home Phone:style=3D"mso-tab-count: 1">    =
843-327-1996


justify">face=3D"Times New Roman">Street Address: 53 Muirfield Parkway, =
Charleston S.C.=20
29414


justify">face=3D"Times New Roman">DOB: 09/09/52


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">Employer:style=3D"mso-tab-count: =
1">        =20
L.M. Communications Inc.


justify">face=3D"Times New Roman"># Employees:yes">  =20
15+


justify">face=3D"Times New Roman">Phone:style=3D"mso-tab-count: =
2">           &nbs=
p; =20
843-769-4799


justify">face=3D"Times New Roman">Street Address: 59 Windemere Blvd. Charleston =
S.C.=20
29407


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">Cause of Discrimination Based On:


justify">face=3D"Times New Roman">[x] Age


justify">face=3D"Times New Roman">[x] Religion


justify">face=3D"Times New Roman">[x] Retaliation


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">Dates of Discrimination:style=3D"mso-spacerun: yes">  Inclusive from 2/1/2002 to=20
7/25/2002


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">The Particulars Are:


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">I: style=3D"mso-tab-count: =
1">        =20
I was subjected to discriminatory terms and conditions of =
employment,=20
harassed, denied employment, subjected to a hostile religious and =
retaliatory=20
work environment, denied employment and discharged from my full time =
position=20
because of retaliation for my attempt to offer equal employment ability =
in=20
hiring of minorities, complaining about the refusal of management to =
consider=20
minorities for full time positions and objecting to and requesting =
management=92s=20
intervention to stop harassment directed at me in the workplace and out =
of the=20
workplace which =93contributed to the hostile environment=94 experienced =
at work in=20
violation of Title VII of the Civil Rights Act of 1964, as =
amended.


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
1">           =20
style=3D"mso-tab-count: =
1">           =20
A: Retaliatory Intimidation I was subjected to =
included:


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
1: Threatening emails while employed.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
2: Threatening email after discharge.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
3: Threatening anti-Semitic terrorist photo sent in =
email.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
4: Refusal to permit the carrying out of my job=20
responsibilities.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
5: Blame for lost commercial revenue.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
6: Sabotage of work performed.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
7: Public humiliation and character assassination.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
8: Humiliation to staff by management.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
9: Attempts to trick me into violating corporate =
policy.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
10: Sabotage of transmitter power to damage =
performance.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
11: Sabotage of station audio processing to damage=20
performance.


justify">face=3D"Times New Roman">style=3D"mso-tab-count: =
2">           &nbs=
p;           =20
style=3D"mso-tab-count: =
1">           =20
12: Sabotage of program elements for my morning show.


justify">face=3D"Times New Roman">13: I AND my wife were ordered not to access =
any phone=20
number in the Lexington KY area code.


justify">face=3D"Times New Roman">14: Refusal to permit work tools. (Supplied =
after I was=20
discharged.)


justify">face=3D"Times New Roman">15: Called a liar repeatedly.


justify">face=3D"Times New Roman">16: Insulted continuously behind my =
back.


justify">face=3D"Times New Roman">17: Ignoring every instance reported by me of =
alleged=20
illegal activity.


justify">face=3D"Times New Roman">18: Receipt of edited audio music file =
obviously claiming=20
responsibility for my discharge.


justify">face=3D"Times New Roman">19: =20
Equipment was damaged.


justify">face=3D"Times New Roman">20: Notices of unsafe working conditions were=20
ignored.


justify">face=3D"Times New Roman">21: Music scheduling software was tampered=20
with.


justify">face=3D"Times New Roman">22: Attack continued after =
employment.


justify">face=3D"Times New Roman">23: Penalized for wanting to improve the midday =
show by=20
reducing the show to part time if I wanted to replace the current staff=20
member.


justify">face=3D"Times New Roman">24: Rumors and innuendos.


justify">face=3D"Times New Roman">25: Threatened with legal action.


justify">face=3D"Times New Roman">26: Refusal to repair equipment.


justify">face=3D"Times New Roman">27: Replacing equipment with inferior =
parts.


justify">face=3D"Times New Roman">28: Hatred for =91black=92 music.


justify">face=3D"Times New Roman">29: Branded a =91complainer=92.


justify">face=3D"Times New Roman">30: Intimidation of new employee before =
starting=20
date.


justify">face=3D"Times New Roman">31: Software was deleted from production=20
equipment.


justify">face=3D"Times New Roman">32: Given a broken =91boom box=92 to suffice =
for an aircheck=20
machine.


justify">face=3D"Times New Roman">33: Retaliation for stopping =91Plugola=92 on =
the=20
air.


justify">face=3D"Times New Roman">34: Continual reference to changing =
format.


justify">face=3D"Times New Roman">35: Phone call from engineer yelling about a =
memo I was=20
told to write asking for his help in changing microphones.


justify">face=3D"Times New Roman">36: Show prep stolen from my desk.


justify">face=3D"Times New Roman">37: Equipment in my desk was =
damaged.


justify">face=3D"Times New Roman">38: Given a non-working phone for my =
desk.


justify">face=3D"Times New Roman">39: Ethics questioned.


justify">face=3D"Times New Roman">40: Interruptions on the =91hotline=92 while =
doing my=20
show.


justify">face=3D"Times New Roman">41: Tampering with the station=92s Legal =
ID


justify">face=3D"Times New Roman">42: Given worst computer in the building for my =

desk.


justify">face=3D"Times New Roman">43: Degradation of my wife for having spoken to =
Lynn=20
Martin.


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">II: style=3D"mso-tab-count: 1">        =
The=20
reason I was given for discharge was =93poor performance of the =
station=94 however=20
the Arbitron ratings results for the period in question showed =
=93significant=20
gains=94 according to Mindy Spar, entertainment writer for the =
Charleston Post=20
& Courier. I tried repeatedly to hire a minority person full time =
but was=20
forced out of my employment for doing so.


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">III:style=3D"mso-tab-count: 1">        =
I=20
believe I have been discriminated against because of my religion, =
Jewish, and in=20
retaliation for complaining about discrimination in violation of Title =
VII of=20
the Civil Rights Act of 1964, as amended.


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">IV:style=3D"mso-tab-count: 1">       =
At-Will=20
employment does not apply as an implied contract was in =
force.


justify">face=3D"Times New Roman"> 


justify">face=3D"Times New Roman">V:style=3D"mso-tab-count: =
1">        Furthermore,=20
the company discriminates against Blacks as a class relative to hiring, =
job=20
assignments, wages, promotions, transfers, discipline and discharge and=20
discriminates against those who object to such actions and discriminates =
against=20
those who attempt to correct such actions.


justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in =
0pt">---------------------------------------------------------------=
--------------------------------------


0pt"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Equal Employment Opportunity =
Commission


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">August 27, 2002


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I, Lee Kent (Lee Kent) Hempfling, former =
Program Director=20
of WCOO-FM a radio station owned by L.M. Communications II Of South =
Carolina=20
Inc. and operated by L.M. Communications Inc. of Lexington KY. , located =
at 59=20
Windemere Charleston S.C. 29407 do hereby submit the following statement =
on=20
behalf of and in support of the alleged EEO violations as submitted by =
Patricia=20
Thompson, a Black, former part time radio announcer with same ... as=20
follows:


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">When I arrived at WCOO to begin my duties as =
program=20
director I searched for documentation regarding current employees to =
determine=20
the pay scales and terms whereby new employees would be hired in =
relation to=20
existing employees.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">The only records I could find were copies =
located in my=20
department and consisted of a few disciplinary records on past and =
present=20
employees and two statements providing wage information. I could only =
assume=20
that current part time employees were being treated equally.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I asked General Manager Charlie Cohn what the =
rate was=20
for part time employment in programming as both records on file =
indicated a vast=20
discrepancy with one person receiving over $9.00 an hour and another =
receiving a=20
monthly salary in order to keep him below his required disability =
earnings limit=20
even though he was paid for outside work by writing the checks to his =
girlfriend=20
instead of him (Wayne Morath).


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">There were no pay records in the programming =
files for=20
Patricia Thompson.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Cohn=92s response was between $7.00 and $7.50 =
per hour=20
after he inquired whom it was I was planning to hire. At that time it =
was=20
Jessica Mickey to work Sunday mornings. This was before Ms. Thompson =
left the=20
station.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I again asked Cohn the same question when I =
hired Dwight=20
(Landon) Lane for part time on Saturdays with the same response. This =
was after=20
Ms. Thompson left the station.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I was appalled to find out at a later date that =
Patricia=20
Thompson had been with the station longer than any other part time =
employee and=20
had been receiving far less in hourly rate.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">During the initial stages of my taking over the =

programming of WCOO I evaluated each employee=92s on air work =
performance and=20
determined that Patricia Thompson was the most qualified current =
employee for=20
promotion to full time status. This was based on my listening to her =
show and to=20
tapes of her show provided by Ms. Thompson as the station did not have =
an air=20
check machine so she taped her show on her own machine.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">After approximately 30 days of evaluation I =
approached=20
Cohn informing him that I had decided for the best interest of the =
station=92s=20
ratings potential to replace Linda (Logan) Grumbein in =93middays=94 on =
air and to=20
replace Wayne Morath (Skip St. John ) in the afternoon position and =
would be=20
seeking the best qualified candidates through public advertisement in =
trade=20
journals and on line trade publications.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">At that time I informed Cohn that I was =
thinking of=20
Patricia Thompson as the midday replacement. His response was an =
emphatic =91no=92=20
with the reason given that he =91had issues with Trish=92. He offered no =
further=20
explanation at that time.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I placed an equal opportunity ad on =
AllAccess.Com, and=20
TVAndRadioJobs.Com for the afternoon position as a blind box because of =
the=20
concern that both current parties would be disgruntled if they knew they =
were=20
being replaced.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Only Mike (Allen) Almond, then program director =
of WYBB=20
(the sister station), Cohn and myself knew of the ads being =
placed.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Shortly after the placement I listened to both =
Grumbein=20
and Morath=92s air shifts and wrote an aircheck critique and letter to =
both=20
separately indicating the problems they had on the air and the problems =
I had=20
with their execution of the format.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Both Grumbein and Morath approach Cohn about =
the=20
critiques and wrote complaint letters about me to Cohn threatening legal =
action=20
for having dared tell them how they were to perform their =
jobs.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">It was then that I looked deeper into what =
personnel=20
records I had access to and noticed that Grumbein had been hired as full =
time=20
status the day after I left for Charleston from Phoenix, Arizona. Such =
hiring=20
was without equal employment opportunity as no public notice was made of =
the=20
opening and no person within the station or outside of the station was =
given the=20
ability to compete for the position.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">When I arrived I had been treated to a good =
deal of=20
gossip about fellow employees from both Grumbein and Morathstyle=3D"mso-spacerun: yes">  and Leslie Twigger (Office =
Manager) with=20
Grumbein specifically referring to Patricia Thompson in derogatory terms =
and=20
telling me to watch out for her.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">After careful consideration of the employees in =
the=20
department I found the truth to be the opposite. Grumbein was the one to =
watch=20
out for. Patricia Thompson was a professional and did not fit in with =
the=20
unprofessional bickering and backbiting going on inside the department =
from=20
Grumbein.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Over the course of my employment I repeatedly =
approached=20
Cohn about the midday position (afternoons were filled by hiring John =
Majhor of=20
Sante Fe, New Mexico and severing the employment of Morath ) and each =
time I=20
reiterated my strong belief that not only was Patricia Thompson the most =

qualified person in the building for the position but the station did =
not have a=20
single full time black employee in programming. (Denise Moseley was the =
only=20
other black employee and she was the receptionist). I strongly believed =
the=20
station required an ethnic presence for proper presentation of the =
format and it=20
appeared to me that the station did not care to do so.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">When Patricia Thompson resigned from the =
station she=20
broke down and cried when she informed me of her decision. I told her I =
was=20
planning to train her more as I had intended to move her into full time. =
She did=20
not know at that time that I had been trying to do that without=20
success.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Ms. Thompson wrote a letter to L.M. =
Communications owner=20
Lynn Martin in which she described the hostile environment she had =
suffered=20
under while working in his station and told him of many other goings on =
all of=20
which I was aware of but was unable to do anything about as I could not =
remove=20
the two persons mostly responsible for the environment problems =
(Grumbein and=20
engineer Bruce Musso who had begun a threatening email campaign directed =
at me=20
and had been intimidating the staff I had hired ever since I had =
insisted to=20
Cohn that the station have a black full time staff employee) and I could =
not do=20
anything about Cohn=92s obvious distaste for involving Ms. Thompson in =
any station=20
position.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I was aware of a letter written by Ms. Thompson =
prior to=20
my arrival where she brought up the problem of her not being given fair=20
treatment for full time status and promotion and even though I do not =
remember=20
her mentioning race in that letter it was my first reaction in reading =
it=20
knowing the mannerisms and facial expressions used by Cohn when speaking =
of any=20
minority person.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">In fact Cohn blamed the lack of sales for WCOO =
on the=20
station not having a black salesman when it was obvious to me that color =
had=20
nothing to do with sales. Cohn repeatedly tried to talk me into getting =
rid of=20
the =91black=92 format and to change the station to an all 80=92s =
format. Considering=20
his close relationship with Musso and Musso=92s continuous attacks on me =
and those=20
who worked for me I was convinced the problem was similar to Musso=92s =
racial=20
bigotry, flying the confederate flag on his truck and carrying a gun in =
it as=20
well.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Shortly after her letter to Martin; Cohn and =
Almond=20
approached me to inform me that they had offered a full time position in =
traffic=20
to Ms. Thompson. It was not necessary for them to tell me that as I knew =
better=20
from word inside the station and from Almond talking away from Cohn =
earlier in=20
the search process for a midday replacement. I knew they were lying and =
trying=20
to make up a cover story and they were trying to include me in =
it.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Management was instructed by Martin, the owner, =
not to=20
have contact with Ms. Thompson while any potential legal issues were =
outstanding=20
yet knowing this, Cohn ordered me to call her to see what she wanted =
while at=20
the same time insisting he would never hire her. I refused to disregard =
the=20
owner=92s orders. I told Martin I considered that act to be a set =
up.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Also shortly after that letter Cohn ordered me =
to train=20
Denise Moseley as a part time air staff member. When I tried to coach =
her he=20
refused to allow her to be coached unless it was on her own time. That =
move was=20
simply to put a black person on the air, qualified or not and the =
refusal to=20
permit coaching during paid working hours amounted to Cohn=92s insisting =
Moseley=20
learn the job without the benefit of instruction thereby guaranteeing =
she would=20
not learn. Cohn interrupted a training session and yelled at Moseley =
that she=20
was not to do that on company time.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Weeks went by when finally Consultant Don =
Hallett=20
approached me at the station on an in station visit with Martin and told =
me it=20
had been decided to replace Grumbein and that if I wanted =93Trish=94 I =
should get a=20
demo of hers and send it to him. I was then supposed to remove Grumbein, =

advertise properly for the position and include Ms. Thompson=92s demo as =
an=20
applicant and if I still felt Ms. Thompson was the most qualified for =
the=20
position that it would pay mid 20=92s and would be a full time position. =


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Cohn rejected the instruction and refused to =
permit=20
Grumbein=92s replacement with Ms. Thompson or Grumbein=92s discharge. I =
strongly=20
believe the reason to be that Ms. Thompson had complained about unequal=20
treatment in the past and Cohn refused to deal with that.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">When I later learned that Ms. Thompson was =
working for a=20
lot longer and at a much lower pay scale than her white counterparts I =
was=20
appalled that such behavior had been permitted and apparently condoned =
by the=20
ownership.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">The EEOC is welcome to any material I have on =
file=20
relating to WCOO and L.M. Communications (in all three of its =
incarnations) and=20
they are offered in support of the correction of wrongs perpetrated upon =
Ms.=20
Patricia Thompson and all other minority persons who have or may have =
worked for=20
that company.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I was fired on July 23 2002 which occurred the =
second day=20
of the week following my airing of a parody commercial on WCOO that I =
wrote and=20
produced using one of my character voices that spoke of the confederate =
flag as=20
being a display of treason. I am convinced it was a major part in my=20
discharge.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">A replacement morning personality was hired =
after I left=20
without advertisement, without equal employment ability for any other =
race,=20
creed, sex or national origin to compete for said position and the =
person was=20
hired part time at what I believe to be $8.50 per hour.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Hallett on behalf of Martin had asked me =
repeatedly if I=20
intended to remain with the station until retirement. The answer was =
repeatedly,=20
yes.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I took the position based upon Martin=92s =
initial statement=20
to me in the employment interview that he desired to have me stay until=20
retirement even though the money offered was less than the initial =
discussions.=20


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I thought I could make a difference inside that =
station=20
by standing up for what was right and at nearly 50 years of age an offer =
of=20
=91stay until retirement=92 was a valuable asset in taking a =
position.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">I repeatedly, both orally and in writing =
requested a full=20
time black employee in programming. The issue was repeatedly =
ignored.


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Sincerely


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">_____________________


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman"> 


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Lee Kent Hempfling


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">53 Muirfield Parkway


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">Charleston SC 29414


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">843-327-1996


style=3D"MARGIN: 0in 0in 0pt; LINE-HEIGHT: 150%; TEXT-ALIGN: =
justify">face=3D"Times New Roman">leekent@comcast.net


style=3D"MARGIN: 0in 0in =
0pt"> 



------=_NextPart_000_54EE_01C3422F.51673400--