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More Documents from PERM FOIA Litigation (Gluckman v. DOL)

October 24, 2014 (1 min read)

Jonathan Moore writes: "David Gluckman and I wanted to pass along two additional documents that were produced in the Gluckman v. DOL PERM FOIA litigation (prior posts here and here).  Specifically, these two documents are directives from November 2009 from William Carlson, Administrator of the Office of Foreign Labor Certification.  The first directive addresses PERMs for finite employment opportunities.  The second directive addresses acceptable documentation to establish business necessity.  The second document may be particularly relevant for practitioners given that DOL appears to have recently changed its template audit notification letter to request business necessity documentation."