4/26/2024 12:05 AM
`22CV42678
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`IN THE CIRCUIT COURT OF THE STATE OF OREGON
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`FOR THE COUNTY OF MULTNOMAH
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`ANDREW BANDSTRA,
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`Plaintiff,
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`v.
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`MULTNOMAH COUNTY,
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`Case No. 22CV42678
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`DECLARATION OF ANDREW POTTER
`IN SUPPORT OF DEFENDANT’S
`MOTION FOR SUMMARY JUDGMENT
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`Defendant.
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`I, Andrew Potter, under penalty of perjury, do declare and state as follows:
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`I have been employed with the Multnomah County Sheriff’s Office (MCSO) since
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`August 1999 and have always been in an IT supervisory role. My current position is IT Manager
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`2 in the Sheriff’s Business Services office.
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`3.
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`MCSO emails are stored on a County server. These emails are stored as soon as an
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`email is sent or received via a cloud archive service, therefore creating the email records close in
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`time to when they were created. Email correspondence is kept by MCSO in the regular course of
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`business and pursuant to a regular record-making policy. Each of the following Exhibits were
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`pulled from the cloud archive service and are true and correct copies of the email exchanges as
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`preserved in the normal course of business by MCSO.
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`4.
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`Attached as Exhibit 1 is an email from Deputy Andrew Bandstra to Matt Ingram
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`on November 17, 2021.
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`Page 1 – DECLARATION OF ANDREW POTTER IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY
`JUDGMENT
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`Multnomah County Attorney
`501 SE Hawthorne Blvd., Suite 500
`Portland, Oregon 97214
`(503) 988-3138 Fax (503) 988-3138
`Email: ashley.bannon.moore@multco.us
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`5.
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`Attached as Exhibit 2 is an email forwarded from Deputy Andrew Bandstra to an
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`external email address containing email correspondence between Deputy Andrew Bandstra and
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`Sergeant Thomas Jacobs December 7, 2021.
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`6.
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`Attached as Exhibit 3 is email correspondence between Melissa Regehr and
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`Deputy Andrew Bandstra on December 10, 2021 and December 11, 2021.
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`7.
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`Attached as Exhibit 4 is email correspondence involving Deputy Andrew Bandstra,
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`Rebecca Sanchez, Matt Ingram, Julia Pass and Jennifer Grogan on December 7, 2021 and
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`December 8, 2021.
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`Attached as Exhibit 5 is email correspondence involving Deputy Andrew Bandstra,
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`Rebecca Sanchez, and Matt Ingram on December 8, 2021.
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`9.
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`Attached as Exhibit 6 is email correspondence between Deputy Andrew Bandstra
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`and John Mullens on December 8, 2021.
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`10.
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`Attached as Exhibit 7 is email correspondence between Deputy Andrew Bandstra
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`and then-Sergeant Thomas Jacobs on December 7, 2021.
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`11.
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`The information in this declaration is true and correct to the best of my knowledge.
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`I HEREBY DECLARE THAT THE ABOVE STATEMENT IS TRUE TO THE
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`BEST OF MY KNOWLEDGE AND BELIEF, AND THAT I UNDERSTAND IT IS
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`MADE FOR USE AS EVIDENCE IN COURT AND IS SUBJECT TO PENALTY
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`FOR PERJURY.
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`DATED this 25th day of April, 2024.
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`____________________________________
`Andrew Potter
`IT Manager 2, CJIS Unit - MCSO Business Services
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`Page 2 – DECLARATION OF ANDREW POTTER IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY
`JUDGMENT
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`Multnomah County Attorney
`501 SE Hawthorne Blvd., Suite 500
`Portland, Oregon 97214
`(503) 988-3138 Fax (503) 988-3138
`Email: ashley.bannon.moore@multco.us
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`

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`CERTIFICATE OF SERVICE
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`I hereby certify that on April 25, 2024, I arranged to be served the foregoing
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`DECLARATION OF ANDY POTTER IN SUPPORT OF DEFENDANT’S MOTION FOR
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`SUMMARY JUDGMENT on:
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`Carl Post
`John Burgess
`Law Office of Daniel Snyder
`1000 SW Broadway, Suite 2400
`Portland, Oregon 97205
`Email: carlpost@lawofficeofdanielsnyder.com
`Email: johnburgess@lawofficeofdansnyder.com
` Of Attorneys for Plaintiff
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`by the following method or methods as indicated:
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`by mailing to said person(s) a true copy thereof, said copy placed in a sealed envelope,
`postage prepaid and addressed to said person(s) at the last known address for said person(s)
`as shown above, and deposited in the post office at Portland, Oregon, on the date set forth
`above.
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`by causing a true copy thereof to be hand delivered to said person(s) at the last known
`address for said person(s) as shown above, on the date set forth above.
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`by mailing via certified mail, return receipt requested, to said person(s) a true copy
`thereof, said copy placed in a sealed envelope, postage prepaid and addressed to said
`person(s) at the last known address for said person(s) as shown above, and deposited in the
`post office at Portland, Oregon, on the date set forth above.
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`by facsimile to said person(s) a true copy thereof at the facsimile number shown above,
`which is the last known facsimile number for said person(s) on the date set forth above. A
`copy of the confirmation report is attached hereto.
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`by File & Serve and emailing to said person(s) a true copy thereof at the email address
`shown above, which is the last known email address for said person(s) on the date set forth
`above.
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`/s/ Ashley Bannon Moore
`Ashley Bannon Moore, OSB No.
`Senior Assistant County Attorney
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`Page 2 – CERTIFICATE OF SERVICE
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`Multnomah County Attorney
`501 SE Hawthorne Blvd., Suite 500
`Portland, Oregon 97214
`(503) 988-3138 Fax (503) 988-3377
`Email: chris.gilmore@multco.us
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`

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`MC004282
`
`From:
`Sent:
`To:
`Subject:
`Attachments:
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`BANDSTRA Andrew
`Wednesday, November 17, 2021 10:12 PM PST
`INGRAM Matt P
`FW: ADA Process and Shields
`MCCDA COVID-19 Vaccine - MCCDA Counter 10-15-21MCCDA Counter.docx.pdf,
`Request_for_reasonable_accommodation.doc
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`This is what they sent me. Not sure why they sent me an accommodation form…
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`
`
`From: GROGAN Jennifer A
`Sent: Wednesday, November 17, 2021 3:15 PM
`To: BANDSTRA Andrew <andrew.bandstra@mcso.us>
`Cc: CRUMPTON Robert <robert.crumpton@mcso.us>; ALEXANDER Steven <steve.alexander@mcso.us>
`Subject: ADA Process and Shields
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`Hi Andy,
`As I mentioned in our conversation today, I am sending you this email to recap what we discussed. Rob
`is cc’d here as well and is aware of the direction being taken at this time. Since you are unvaccinated
`and are only medically approved to wear a shield, and not a mask, we cannot continue to have you
`working in your sworn capacity in the jail. As I also mentioned, below are some existing
`accommodations to be considered to allow you to continue in your sworn role in the jail. These options
`include the following:
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`Exhibit 1
`Page 1 of 7
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`

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`MC004283
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`1. Get vaccinated
`2. Wear an N95
`3. Transfer or demote to a non-sworn position
`4. Take a leave of absence
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`Because of the nature of your work and mask mandate, MCCDA has signed an agreement with the
`County on this topic, attached, which provides agreement with the direction the Sheriff’s Office has for
`the mask mandate and working in the jails. While the options listed above are very likely the only
`options for accommodation, I have also attached the accommodation request form that you may fill out
`and/or take to your health care provider for discussion on other options that may be considered for
`you. However, please understand that continuing to work unvaccinated in a shield will not be an
`approved accommodation, but we are open to consideration of any additional ideas you and/or your
`health care provider may have.
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` I
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` will be in touch in a couple of days to follow up on this and see if there are other options you may wish
`to offer for accommodation. Please let me know if you have additional questions and don’t hesitate to
`reach out.
`Thank you and take care,
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`
`Jennifer (she/her)
`MCSO HR
`503-793-5285
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`Exhibit 1
`Page 2 of 7
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`

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`MC004287
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`MULTNOMAH COUNTY
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`REQUEST FOR REASONABLE ACCOMMODATION
`PURPOSE: This form for Request for Reasonable Accommodation is designed to provide a means of
`reviewing potential accommodations for a covered individual. A request for an accommodation should
`be initiated by the employee. For the purpose of employment, a “qualified person with a disability” is
`a person who with or without reasonable accommodation, is able to perform the essential function of
`the position. Accommodations are determined on a case-by-case basis because the nature and extent of
`a disabling condition and the requirements of the job may vary. A reasonable accommodation is any
`change or adjustment to a job or work environment the permits a qualified applicant or employee with
`a disability to participate in the job application process, to perform the essential functions of a job, or
`to enjoy benefits and privileges of employment equal to those enjoyed by employees without
`disabilities.
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`GENERAL INFORMATION:
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`Submitting Request To:
`Request From:
`Position Title:
`Work Unit:
`Work Phone:
`E-mail Address:
`Supervisor’s Name:
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`Department:
`Work Location:
`Inter-office Address:
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`Supervisor’s Phone:
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`REQUEST FOR ACCOMMODATIONS:
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`1.
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`I am requesting access and/or accommodation because (please select one):
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`___(A) I am currently employed by the County and request a reasonable accommodation.
`Position Title:
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`___(B) I am applying for employment. The access and/or accommodation requested will allow
`me to participate in the examination.
`Examination Title (position):
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`2. Briefly describe the primary limitation(s) you are experiencing in performing your job.
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`Exhibit 1
`Page 3 of 7
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`

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`MC004288
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`3. What kind of access and/or accommodation are you requesting?
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`4. Describe how this accommodation will assist you to perform the essential functions of the job
`you have or for which you are applying.
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`5. Are you aware of any available resources to assist with your request? If known, include the
`names, addresses and telephone numbers of vendors and model number and approximate cost
`of any equipment requested.
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`Note: Under the ADA, when an individual qualifies for reasonable accommodation the employer
`is free to choose among effective accommodations and may choose one that is less expensive or
`easier to provide. A medical examination may be required to determine if any individual has a
`disability covered by the ADA and is entitled to an accommodation, and, if so, to help identify an
`effective accommodation.
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`Signature:______________________________ Date: ___________________________________
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`Printed Name:___________________________
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`Exhibit 1
`Page 4 of 7
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`

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`MC004284
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`Memorandum Of Agreement
`COVID-19 Vaccine
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`I. Parties to the Agreement
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`The parties to this Memorandum of Agreement (hereafter referred to as “MoA”) are Multnomah
`County, Oregon, (hereinafter referred to as “County”) the Multnomah County Corrections Deputy
`Association (hereafter referred to as “Union” or “MCCDA”).
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`II. Background
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`The County and Union have a mutual desire to keep our workforce, our clients and customers,
`and the entire community as safe and healthy as possible. The Governor of Oregon has
`ordered that all healthcare personnel and school staff in K-12 schools be fully vaccinated. She
`has set a deadline for both groups of October 18, 2021, or six weeks after the U.S. Food and
`Drug Administration grants full approval for one of the vaccines, whichever is later. The County
`intends to implement and meet this requirement by the deadline set by the Governor and apply
`it to all County employees.
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`The County and the Union agree the following post are covered by the Governor’s order:
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` MCDC: 4A Deputy, 4D Deputy, 4 Escort(s), Medical Clinic Deputy and the 3-5 Sergeant.
` MCIJ: D18 Deputy and the Medical Clinic Deputy
` Additional Posts: Any deputy assigned to a hospital post or medical transport post.
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`THEREFORE, the parties have reached the following Agreement:
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`III. Agreement
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`Employees are required to report their COVID-19 vaccination status for their initial doses
`A.
`from August 26, 2021 to September 10, 2021 and provide updates to vaccination status as
`needed if their status changes. Employees are required to receive and report any
`recommended boosters for the vaccine as directed by the County. Only Central and Department
`Human Resources Staff and managers with a need to know will be privy to this information. The
`County will provide regular updates to employees who have not submitted proof of vaccination
`regarding vaccination clinics and locations available in the Multnomah County area.
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`Employees, working posts covered by the Governor’s order (only employees who are in
`B.
`compliance with the order may work in such posts), that do not become fully vaccinated by
`October 18, 2021, for COVID-19, will be reassigned to another post that does not require being
`vaccinated.
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`Employees who are on a leave of absence and are unable to meet the County’s
`C.
`deadlines in this MOA, or have other extenuating circumstances, may provide their vaccine
`status by a later date determined by Department Human Resources after considering
`individual needs.
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`D.
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`An employee may apply for an exception/exemption from the vaccine due to
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`Exhibit 1
`Page 5 of 7
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`MC004285
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`County COVID-19 Memorandum of Agreement
`Page 2 of 4
`10/21/2021
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`medical/disability or sincerely held religious beliefs. Department Human Resources will assess
`exception/exemption requests and issue approvals or denials. An employee seeking an
`exception/exemption is encouraged to submit this request by September 10, 2021, or as soon
`as possible. If an exception/exemption is denied, and an employee has additional or clarifying
`information to provide, or they have had a change in circumstances, they may resubmit the
`exception/exemption request. By way of examples, and not an exclusive set of reasons for
`medical exception/exemption may include, potential allergic reactions to vaccination or having
`not completed an isolation period following a COVID-19 infection.
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`If an employee receives an exception/exemption from getting the vaccine, the County
`E.
`will engage in an interactive process to determine what reasonable accommodations may be
`offered, which may also depend upon whether an employee works with a contracted agency
`inside a facility that the County does not own. Depending upon the duties performed, an
`employee may be required to wear specific masks, engage in social distancing, undergo
`COVID-19 testing, be reassigned, and/or other reasonable accommodations consistent with
`OSHA safety requirements and the current guidance from public health officials. The cost of
`any accommodations including testing requirements shall be paid by the County, and if the
`County requires testing, the parties will meet and bargain over testing.
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`If an employee submits an exception/exemption request, but the exception/exemption
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`review process has not been completed, and no decision has been made by October 15, 2021,
`then the employee will be deemed provisionally approved until the exception/exemption process
`has been finalized. By way of an example, and not an exclusive reason for an
`exception/exemption review request not reaching completion by October 15, 2021, includes not
`having received a timely response from the employee’s health care provider.
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`Employees who have reported that they are partially vaccinated by October 13, 2021,
`G.
`meaning they have reported they have taken at least one vaccine dose, will have their layoff
`rescinded and be allowed to use their accrued sick leave (up to 40 hours), vacation,
`compensatory time, and holiday banks, or go on an unpaid leave of absence until they are fully
`vaccinated, unless they can be reassigned to a routine telework assignment until they are fully
`vaccinated. Leaves of absence will only be approved through November 30, 2021, unless the
`leave qualifies under FMLA/OFLA or an ADA leave of absence. If the employee has not
`reported that they are fully vaccinated by this date, a layoff notice will be issued that is effective
`on November 30, 2021. It is understood that employees are receiving more than fifteen days’
`notice of layoff for failure to comply with the County’s COVID-19 Vaccine mandate.
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`Employees who have submitted a medical or religious exception/exemption but are
`H.
`denied at any time after September 6, 2021, and are unable to complete vaccination by October
`18, 2021, will be allowed to use their accrued sick leave (up to 40 hours), vacation,
`compensatory time, and holiday banks, or go on an unpaid leave of absence, unless they can
`be reassigned to a routine telework assignment until they are fully vaccinated. Leaves of
`absence will only be approved through November 30, 2021, unless the leave qualifies under
`FMLA/OFLA or an ADA leave of absence. If the employee has not reported that they are fully
`vaccinated by this date, a layoff notice will be issued that is effective on November 30, 2021. It
`is understood that employees are receiving more than fifteen days’ notice of layoff for failure to
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`Exhibit 1
`Page 6 of 7
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`

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`MC004286
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`County COVID-19 Memorandum of Agreement
`Page 3 of 4
`10/21/2021
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`comply with the County’s COVID-19 Vaccine mandate.
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`Currently the vaccine is free to employees. If this changes and the employee
`I.
`receives any charge not covered by insurance, the County will reimburse the employee.
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`Employees may use county paid time to receive the vaccination and code the time as
`J.
`Administrative Leave. Employees must notify their supervisor in advance that they will be taking
`time off for a COVID-19 vaccination.
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`Employees will be granted an accrual bank equaling sixteen (16) hours of leave to use
`K.
`if an employee experiences a medical side effect from taking a COVID-19 vaccine, including
`a booster, that prevents the employee from performing their job duties. If an employee is on
`a schedule where they regularly work in excess of eight (8) hours per day, the employee will
`receive a leave bank equal to two (2) days of paid leave. This provision applies retroactively
`to August 27, 2021. Unused accruals will expire June 30, 2022.
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`Any dispute related to enforcement of terms of this agreement is subject to the
`L.
`grievance procedure as described in MCCDA’s CBA.
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`If the County enters into an agreement with another bargaining unit that is covered
`M.
`under the County’s vaccine mandate or provides unrepresented employees with conditions or
`compensation that is substantively better than what is contained in this Agreement, it shall also
`extend those terms to MCCDA represented employees.
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`AGREED to this date, October 21, 2021.
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`For the Union:
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`______________________________
`Matt Ingram, President
`MCCDA, President
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`For the County:
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` ______________________________
`Shelly Kent, Labor Relations Director
`Multnomah County
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`Exhibit 1
`Page 7 of 7
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`

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`MC005446
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`From:
`Sent:
`To:
`Subject:
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`BANDSTRA Andrew
`Thursday, December 9, 2021 3:20 PM PST
`hornets72@hotmail.com
`Fwd: Transfer video
`
`Begin forwarded message:
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`From: BANDSTRA Andrew <andrew.bandstra@mcso.us>
`Date: December 7, 2021 at 5:45:15 PM PST
`To: JACOBS Thomas <thomas.jacobs@mcso.us>
`Subject: Re: Transfer video
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`No they don’t cover it entirely. I was told by numerous deputies that info was passed on to
`you. I’m just passing on information and the county can do with it as they please.
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`On Dec 7, 2021, at 1:51 PM, JACOBS Thomas <thomas.jacobs@mcso.us> wrote:
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`The black squares cover the toilets so I am unsure what you are requesting. I haven't
`viewed someone using the toilet, don't the squares cover enough?
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`Sergeant Thomas Jacobs
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`MCDC West Operations Sergeant
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`1120 SW 3rd Ave
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`Portland, Oregon 97204
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`503-988-4089
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`Theodore Roosevelt
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`"To educate a man in mind and not in morals is to educate a menace to society".
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`-----Original Message-----
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`From: BANDSTRA Andrew
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`Sent: Tuesday, December 7, 2021 12:05 PM
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`To: JACOBS Thomas <thomas.jacobs@mcso.us>
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`Exhibit 2
`Page 1 of 2
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`

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`MC005447
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`Subject: Transfer video
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`Any plans on fixing the black squares on the cameras in transfer so you don’t see inmates
`using the bathroom?
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`Exhibit 2
`Page 2 of 2
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`MC005450
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`From:
`Sent:
`To:
`Subject:
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`Thanks!!!
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`BANDSTRA Andrew
`Saturday, December 11, 2021 3:03 PM PST
`REGEHR Melissa
`Re: info
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`On Dec 10, 2021, at 11:32 AM, REGEHR Melissa <melissa.regehr@mcso.us> wrote:
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`Ok so it was a Tuesday unknown of exact date...but it was the same day that the contractors
`put the monitors up in the transfer office. We had a female in either tank 5 or 7 and she was
`using the toilet. When she stood up to pull up her pants and underwear up her bare but cheeks
`were exposed to staff monitoring the cameras. I informed Sgt Jacobs of this concern within
`minutes of it occurring. He asked me how long ago it was, because he would need to review
`the tape to see what could be done. He reviewed it and then said oh my, we would have to
`cover the whole cell in a black box for us not to see that. I said I know. At this time I also
`informed him if male inmates did not stand right in front of the toilet to pee, we could
`possibly see their penis, especially if the inmate stands at the side of the toilet. The main
`concerns are with tanks 5-7.
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`sorry it took so long.
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`Regehr
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`Exhibit 3
`Page 1 of 1
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`

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`A_ Multnomah
`0 a County
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`MC000776
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`12/22/22, 10:54 AM
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`Multnomah County Mail - FW: Equal treatment
`
`Angie Alcorn <angie.alcorn@multco.us>
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`FW: Equal treatment
`1 message
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`-----Original Message-----
`From: PASS Julia D <julia.pass@mcso.us>
`Sent: Wednesday, December 8, 2021 7:54 AM
`To: SANCHEZ Rebecca E (she/her/ella) <rebecca.sanchez@mcso.us>; BANDSTRA Andrew
`<andrew.bandstra@mcso.us>
`Cc: INGRAM Matt P <matt.ingram@mcso.us>; GROGAN Jennifer A <jennifer.grogan@mcso.us>
`Subject: RE: Equal treatment
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`Thank you for letting us know, I'm cc'ing Jennifer to loop her in.
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`You will need to update your attestation in Workday to reflect this, and upload your vaccine card.
`If you'd rather not upload your vaccine card into Workday, you can send me a copy (front and back), and upload this
`email instead. Attached are instructions for completing your attestation if you need them, but let me know if you run into
`any issues.
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`If you are unable to complete the attestation from home, you can do it upon your return from leave.
`Thanks,
`
`Julia Pass, HR Analyst
`Phone: 503.407.6887
`Confidential Fax: 503.988.4321
`Pronouns: she/her (click here for more info)
`
`-----Original Message-----
`From: SANCHEZ Rebecca E (she/her/ella)
`Sent: Wednesday, December 8, 2021 7:50 AM
`To: BANDSTRA Andrew <andrew.bandstra@mcso.us>
`Cc: INGRAM Matt P <matt.ingram@mcso.us>; PASS Julia D <julia.pass@mcso.us>
`Subject: RE: Equal treatment
`
`Good morning Deputy Bandstra,
`
`Thank you for reaching out. All personnel and medical information is managed by MCSO HR. I have cc’d Julia Pass here
`for appropriate follow up with you. It’s my understanding, your Supervisor will also need notice of this update, if you
`haven’t already do so.
`
`Thank you,
`Rebecca
`
`Rebecca Sánchez
`Equity and Inclusion Manager
`Multnomah County Sheriff’s Office
`Cell: 503-729-6888
`I use she/her/ella pronouns why pronouns matter “The real experience of DEI looks less like buzzwords and more like
`constant cycles of iteration, action, and assessment to see if our work is having the impact we intend, and then doing it all
`over again to keep change coming.” – Lily Zheng
`
`https://mail.google.com/mail/u/0/?ik=00037fae0f&view=pt&search=all&permthid=thread-f%3A1752941314058671214%7Cmsg-f%3A17529413140586… 1/2
`
`ATTORNEY-CLIENT
`
`Exhibit 4
`Page 1 of 2
`
`

`

`MC000777
`
`12/22/22, 10:54 AM
`-----Original Message-----
`From: BANDSTRA Andrew
`Sent: Tuesday, December 7, 2021 5:59 PM
`To: SANCHEZ Rebecca E (she/her/ella) <rebecca.sanchez@mcso.us>
`Cc: INGRAM Matt P <matt.ingram@mcso.us>
`Subject: Equal treatment
`
`Multnomah County Mail - FW: Equal treatment
`
`I’m writing this email because I now identify as Vaccinated and would like to be afforded the privileges and opportunities
`as my Vaccinated coworkers.
`Thank you
`Deputy Bandstra
`
`Confidentiality: This e-mail transmission may contain confidential and/or privileged information. The information contained
`herein is intended for the addressee only. If you are not the addressee, please do not review, disclose, copy or distribute
`this transmission. If you have received this transmission in error, please contact the sender immediately.
`
`Vaccination Attestation - Create Request HR-REQ-07.pdf
`292K
`
`https://mail.google.com/mail/u/0/?ik=00037fae0f&view=pt&search=all&permthid=thread-f%3A1752941314058671214%7Cmsg-f%3A17529413140586… 2/2
`
`Exhibit 4
`Page 2 of 2
`
`

`

`MC004778
`
`From:
`Sent:
`To:
`Subject:
`
`
`INGRAM Matt P
`Wednesday, December 8, 2021 6:39 PM PST
`KAMMERER Kelly; CRUMPTON Robert; GREVSTAD Eric W; TIFFANY Matthew A
`Fwd: Equal treatment
`
`Sent from my iPhone
`
`Begin forwarded message:
`
`From: "SANCHEZ Rebecca E (she/her/ella)" <rebecca.sanchez@mcso.us>
`Date: December 8, 2021 at 12:42:18 PM PST
`To: BANDSTRA Andrew <andrew.bandstra@mcso.us>
`Cc: INGRAM Matt P <matt.ingram@mcso.us>
`Subject: RE: Equal treatment
`
`Good afternoon Deputy Bandstra,
`
`Thank you for your clarification and fo