Proskauer Whistleblower Defense

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ALJ Applies Villanueva Factors, Finds Overseas Employee’s Whistleblower Claim “Territorial”

By Lloyd B. Chinn, Daniel Saperstein, Daniel Ornstein and Cecile Martin on Posted in DOL Decisions
In Dos Santos v. Delta Airlines, Inc., 2012-AIR-20 (ALJ Jan. 11, 2013), an Administrative Law Judge (ALJ) of the U.S. Department of Labor (DOL) examined whether the facts alleged by the complainant required a territorial or extraterritorial application of one of the whistleblowing statutes enforced by the DOL.  This blog posting summarizes the ALJ’s decision … Continue Reading
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