3099 In a claim for disability harassment or failure to reasonably accommodate an employee's disability, an employer's series of unlawful actions should be viewed as a single, actionable course of conduct if (1) the actions are sufficiently similar in kind; (2) they occur with sufficient frequency; and (3) they have not placed employees on notice that further efforts at informal conciliation with the employer to obtain accommodation or end harassment would be futile. CitationRICHARDS v CH2M HILL (Continuing Violation) 26 C4 798 [See: GovC 12960; Richards v CH2M Hill 79 CA4 570 T/AT 5/00; Accardi v Superior Court 17 CA4 341, T/AT 9/93; Walnut Creek v FEHC 54 C3 245]
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