Footnote 247

CPR Institute, supra note 111, at 18. According to a USCS representative: "Often what presents as a discrimination complaint is not really that." Remarks at In-House ADR Open House, a program at the Ass'n of the Bar of the City of N.Y., May 23, 2001 [hereinafter ADR Open House] (unpaginated). Yet, the Customs program, like REDRESS at the USPS, still purports to cover only equal employment opportunity complaints. See, e.g., Jerome T. Barrett & Hugh D. Jascourt, ADR in the Federal Government, ACResolution, Winter 2003, at 26, 27 ("[M]any employees use the EEOC procedure to seek relief even if their case has nothing to do with EEO rights or protections."); Lauren B. Edelman et al., Internal Dispute Resolution: The Transformation of Civil Rights in the Workplace, 27 Law & Soc'y Rev. 497, 511 (1993) (noting that complaint handlers in employer ADR programs often recast "allegations of rights violations... as typical managerial problems").