William J. Broedel and Joan C. Broedel - Page 3




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          disability.  The complaint alleged that during 1992 and 1993,               
          SUNY had repeatedly harassed and discriminated against Mr.                  
          Broedel and pressured him to retire.  The complaint alleged                 
          injuries of “financial loss, pain and mental anguish.”2  The                
          complaint was later crossfiled with the Equal Employment                    
          Opportunity Commission (EEOC).                                              
               A hearing was scheduled for December 14, 1993, before                  
          William Babiskin (Mr. Babiskin), an impartial arbitrator,                   
          regarding the notices of discipline issued to Mr. Broedel.  On              
          the day of the hearing, Mr. Broedel, Richard Lesniak3 (Mr.                  
          Lesniak), and Robert Patterson4 (Mr. Patterson) met with Richard            
          Hasselbach (Mr. Hasselbach), the attorney representing SUNY’s               
          interests, and Anthony Panebianco (Mr. Panebianco), the Director            
          of Human Resources for SUNY and authorizing official with respect           
          to any settlement amount SUNY would pay, to discuss the                     
          possibility of a settlement.  The parties agreed that Mr. Broedel           
          would retire immediately in exchange for an amount equal to one             
          and one-half times Mr. Broedel’s annual salary.  The parties then           
          met with Mr. Babiskin, and the terms of the settlement agreement            
          were written out by him and incorporated into a consent award.              



               2The complaint alleged that harassment by SUNY caused Mr.              
          Broedel to be hospitalized for stress and high blood pressure.              
               3Richard Lesniak was Mr. Broedel’s union steward.                      
               4Robert Patterson was a union representative.                          





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