Afton C.,1 Complainant,v.Sonny Perdue, Secretary, Department of Agriculture, Agency.

Equal Employment Opportunity Commission

Nov 6, 2018

0120172275 (E.E.O.C. Nov. 6, 2018)

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013

Afton C.,1
Complainant,

v.

Sonny Perdue,
Secretary,
Department of Agriculture,
Agency.

Appeal No. 0120172275

Agency No. NIFA201601019

DECISION

Complainant timely appealed, pursuant to 29 C.F.R. § 1614.403(a), from the May 17, 2017 Final
Agency Decision (“FAD”) concerning her equal employment opportunity (“EEO”) complaint
alleging employment discrimination in violation of Title VII of the Civil Rights Act of 1964
(“Title VII”), as amended, 42 U.S.C. § 2000e et seq. and the Age Discrimination in Employment
Act of 1967 (“ADEA”), as amended, 29 U.S.C. § 621 et seq.

BACKGROUND

At the time of events giving rise to this complaint, Complainant worked as a Supervisory
Program Assistant, GS-10, Institute of Bioenergy Climate and Environment ("IBCE"), at the
National Institute of Food and Agriculture (“NIFA”) in Washington, D.C.

On October 27, 2016, Complainant filed an EEO complaint alleging that she had been subjected
to discriminatory harassment by the Agency on the bases of race (African-American), sex
(female), age (50), and reprisal (prior EEO activity) when:

1. On September 19, 2016, her name was removed from the system as a Unit
Coordinator for the IBCE team,

1 This case has been randomly assigned a pseudonym which will replace Complainant’s name
when the decision is published to non-parties and the Commission’s website.
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2. On August 20, 2016, her SF-182 training request was re-routed within the Agleam
on-line tracking system, delaying in the approval of her request,

3. September 1, 2016, her supervisor sent an email to all staff explaining the end-of-
year performance evaluation requirements, and stated in the email that the
instructions did not apply to Complainant, and

4. In April or May 2016, Management rescinded a “Certificate of Eligibles,”
preventing Complainant from filling her vacant program assistant positions.

On December 14, 2016, the Agency issued a “Partial Acceptance” letter to Complainant, which
accepted Claim 1 for investigation, and dismissed the remaining claims on procedural grounds.
The letter also dismissed reprisal as a basis for Complainant’s discrimination claim. These issues
have been included for review in accordance with 29 C.F.R. § 1614.107(b).2

On April 20, 2017, Complainant received a copy of the report of investigation (“ROI”) for the
accepted claim, and notice of her right to request a hearing before an Equal Employment
Opportunity Commission (“EEOC” or “Commission”) Administrative Judge. Complainant opted
for a FAD instead, which the Agency issued, pursuant to 29 C.F.R. § 1614.110(b).

2 In an October 18, 2016 email to her EEO Counselor Complainant asked to “amend” her
complaint, alleging further discrimination when she that she was denied a detail assignment, and
that ICBE Program Support staff were denied funding and awards provided to the other ICBE
Divisions. Complainant had not yet filed a Formal Complaint, having received her Notice of
Right to File a Formal Complaint (“NOTR”), on or about October 13, 2016, and sought to
include these claims before filing. The EEO Counselor did not respond, so Complainant filed her
Formal Complaint, and pursued adding her additional claims by contacting the EEO Office, her
Congressman, and, once assigned, the EEO Investigator.

In January 2017, Complainant’s EEO Investigator responded, explaining that even though
Complainant provided evidence that she already attempted to raise both claims with an EEO
Counselor, she could not investigate them because they were not included the Formal Complaint.
The EEO Investigator notified Complainant in multiple emails that claims that were not in the
Formal Complaint must be raised with an EEO Counselor, because as a contract investigator, she
lacked authority to add new claims to the complaint. The EEO Investigator also offered to
provide further clarification by phone, and made clear that she would not include the claims in
her investigation unless they were part of a Formal Complaint accepted by the Agency. Once
placed on notice as to how to amend her complaint, Complainant ceased pursuing the matter, as
there is no evidence Complainant contacted the EEO Counselor, therefore, it was appropriate
that the additional allegations were not included her complaint.

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ROI Rebuttal

The FAD erroneously states that Complainant did not rebut the contents of the ROI, even though
the Agency received Complainant’s timely submitted Rebuttal Statement and supporting
evidence on May 22, 2017.3 Moreover, the Agency was on notice that Complainant intended to
respond to the ROI. In a January 2017 email exchange (included in the ROI), Complainant
informed the EEO Investigator that she would submit a rebuttal once the ROI was issued.
Complainant’s May 15, 2017 email requesting a FAD, received by multiple officials at the
Agency’s Office of Civil Rights, stated that she still had time to send a Rebuttal Statement, and
requested the fax number for where to send it. The Agency does not offer an acceptable
explanation for ignoring Complainant’s rebuttal and evidence, nor does it explain why it issued
the FAD prior to the deadline for Complainant to respond. Therefore, we have accepted and
incorporated Complainant’s properly submitted Rebuttal Statement and supporting evidence into
the record, and applied it to this Decision.

Relevant Facts

During the relevant time frame, Complainant’s first level supervisor (“S1”) was the Acting
Division Director for Global Climate Change, GS-15, (male, Caucasian, 62)., and Complainant’s
Third Level Supervisor (“S3”) was the Senior Deputy Director, SAS, (male, Asian American,
63). Of her then-current supervisors, Complainant alleges that S2 orchestrated the alleged
discrimination, acting “behind the scenes” with her prior direct supervisor (“S4”), the Division
Director, GS-15, IBCE Division of Environmental Systems (male, White/Egyptian, 66).
Complainant argues that she experienced harassment and discrimination by both S2 and S4 for
about 3 years. Complainant alleges that since S4 is no longer her supervisor, the harassment has
gotten worse and she believes he lacks respect for women of color in supervisory positions.

As Supervisory Program Assistant, Complainant served “as principal advisor and technical
expert on electronic grant submissions.” She used the Agency’s REEPorts system to assign and
monitor grant requests and ensure National Program Leaders (“NPLs”) completed them within
deadline. Her role also entailed directing a team of Program Assistants, GS-5/7, (“PAs”) for
deadline driven assignments, such as travel and meeting arrangements for peer review panels and
directors, and on the effectiveness of funding and program objectives using multiple data
sources. Complainant contends that she was supposed to have up to 5 PAs as her direct reports.
However, throughout the relevant time frame, she had only one PA (“P1”). Complainant
delegated grant monitoring tasks in REEPorts to P1, who was designated access to the system as
the ICBE Team Unit Coordinator. Complainant was granted access under the same title.
Usually she would just access the system to check that P1’s progress, but for a year prior to the
instant complaint, Complainant took on P1’s responsibilities while P1 was on disability leave or
on a detail due to lack of PA’s.

3 Complainant had 30 calendar days to submit a rebuttal statement and/or supporting evidence.
As 30 days from April 20, 2017 fell on Saturday May 20, 2017, the deadline for Complainant’s
submissions was the next business day, Monday, May 22, 2017.
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Complainant was granted permission to fill the PA vacancies in her office in January 2016, only
to have it revoked in May or April 2016. According to Complainant’s Second Level Supervisor
(“S2”), the Deputy Director, ES-00, (male, Asian Pacific Islander, 54), the Directors determined
that it would be best to stop hiring PAs for individual institutes. Instead, they would implement
a “PA Model,” meaning that institutes could “borrow” PAs from each other if they required
assistance. IBCE had the most PA vacancies and was the only institute that required PA
assistance.

In addition to staffing challenges, in September and August 2016, Complainant felt her position
was intentionally undermined when she experienced technical difficulties with her government-
issued tablet, her training request was rerouted and significantly delayed, and, when S2 included
her on an email with the other supervisors about performance appraisals for their direct reports,
yet stated in the email it did not apply to her. Then, on or about September 19, 2016,
Complainant learned that her name had been removed as ICBE Team Unit Coordinator within
the REEPorts System.

Complainant contacted the Planning, Accountability and Reporting Staff (“PARS”), which
administrated the REEPorts System database, and was informed that her name had been removed
at the request of Complainant’s previous direct supervisor, who was still responsible for
authorizing access to the REEPorts System for ICBE.

In its FAD, the Agency concluded that Complainant failed to prove that the Agency subjected
her to discrimination as alleged. The instant appeal followed.

ANALYSIS AND FINDINGS

As this is an appeal from a decision issued without a hearing, pursuant to 29 C.F.R.
§ 1614.110(b), the Agency's decision is subject to de novo review by the Commission. 29 C.F.R.
§ 1614.405(a). See Equal Employment Opportunity Management Directive for 29 C.F.R. Part
1614, at Chapter 9, § VI.A. (Aug. 5, 2015) (explaining that the de novo standard of review
“requires that the Commission examine the record without regard to the factual and legal
determinations of the previous decision maker,” and that EEOC “review the documents,
statements, and testimony of record, including any timely and relevant submissions of the
parties, and . . . issue its decision based on the Commission’s own assessment of the record and
its interpretation of the law”).

Procedural Dismissals

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Reprisal Claim

As an initial matter, we find that the reason provided in the Agency’s “Partial Acceptance” letter
for dismissing Complainant’s alleged basis of reprisal as improperly addresses the merits of her
complaint without an investigation, as required by EEOC regulations. See Osborne v. Dep’t of
the Treasury, EEOC Request No. 05960111 (July 19, 1996) other citations omitted. The
Agency’s articulated reason i.e., that Complainant did not identify prior EEO activity, is a
merits-based argument because it is necessary for establishing a prima facie case for reprisal.
The Agency did not provide sufficient evidence to warrant dismissal on the merits, and its
explanation is irrelevant to the procedural issue of whether Complainant has stated a viable claim
under Title VII and the 29 C.F.R. Part 1614 regulations.

Complainant identifies a 2014 performance grievance she filed against S4 and S2 disputing her
Performance Appraisal as the cause for the alleged retaliation, stating that since then, S4 has
been “harassing [her] for several years.” The Agency has not offered evidence to support its
assertion that the grievance did not also reference EEO matters. See Complainant v. Dep't of the
Navy, EEOC Request No. 05980598 (June 5, 2000) (participation in protected EEO activity may
occur by filing a grievance procedure when the employee raises issues of employment
discrimination); Complainant v. EEOC, EEOC Appeal No. 0120070356 (Apr. 18, 2011)
(establishing that the complainant failed to present a prima facie case of reprisal by showing she
did not raise EEO issues during the grievance procedure).

On appeal, Complainant describes retaliation by S4 as a “major factor” in her complaint,
contending, that it is common knowledge in ICDE that “[S4] does not have any respect for
woman of color or [women] in supervisory or leadership positions.” She also mentions (without
evidence) that she “complained to NIFA's EEO Deputy Director” about S4’s alleged treatment of
women of color in ICDE without results. If true, Complainant engaged in “protected activity.”
See Anthony v. Dep’t of the Interior, EEOC Appeal No. 01A20111 (Mar. 10, 2004). We find the
Agency erred in dismissing Complainant’s alleged basis of reprisal prior to its investigation.

Claims 2 & 3

The Agency dismissed Claims 2 and 3 for failure to state a claim pursuant to 29 C.F.R. §
1614.107(a)(1), reasoning that the alleged actions, delaying approval of a training request and
singling Complainant out in a staff email, did not render Complainant “aggrieved.” The
Commission long defined an "aggrieved employee" as one who suffers a present harm or loss
with respect to a term, condition, or privilege of employment for which there is a remedy. See
Diaz v. Dep’t of the Air Force, EEOC Request No. 05931049 (April 21, 1994).

While ultimately correct, the Agency erred in its analysis, as it did not consider Complainant’s
alleged basis for discrimination, retaliation, and her harassment claim. The Commission has
stated that adverse actions need not qualify as "ultimate employment actions" in order to
constitute retaliation.
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Lindsey v. United States Postal Serv., EEOC Request No. 05980410 (Nov. 4, 1999) Instead,
claims based on statutory retaliation clauses are reviewed “with a broad view of coverage.”
Maclin v. United States Postal Serv., EEOC Appeal No. 0120070788 (Mar. 29, 2007).
Moreover, the Commission has held that where, as here, a complaint does not challenge an
agency action or inaction regarding a specific term, condition, or privilege of employment, the
claim of harassment may survive if it alleges conduct that is sufficiently severe or pervasive to
alter the conditions of the complainant’s employment. See Harris v. Forklift Systems, Inc., 510
U.S. 17, 23 (1993).

Even applying the broad view of coverage afforded retaliation claims to the alleged
discriminatory acts in Claims 2 and 3, we do not find Complainant was rendered “aggrieved” for
purposes of stating a disparate treatment claim. Likewise, considering Claims 2 and 3
collectively with Claims 1 and 4 as one harassment complaint, we find that the events described,
even if proven to be true, would not indicate that complainant has been subjected to harassment
that was sufficiently severe or pervasive to alter the conditions of her employment. See Cobb v.
Dep’t of the Treasury, Request No. 05970077 (Mar. 13, 1997).

Claim 4

The Agency dismissed Claim 4 as untimely pursuant to 29 C.F.R. § 1614.107(a)(2), which states
that an agency shall dismiss a complaint or a portion of a complaint that fails to comply with the
applicable time limits contained in §1614.105. Specifically, § 1614.105(a)(1), requires
discrimination complaints to be brought to the attention of the EEO Counselor within 45 days of
the date of the alleged discriminatory action, or, for personnel actions, within 45 days of the
effective date of the action. The Commission has adopted a "reasonable suspicion" standard (as
opposed to a "supportive facts" standard) to determine when the 45-day limitation period is
triggered. See Howard v. Dep't of the Navy, EEOC Request No. 05970852 (Feb. 11, 1999).
Thus, the limitation is not triggered until a complainant reasonably suspects discrimination, but
before all the facts that support a charge of discrimination have become apparent. See
Complainant v. United States Postal Serv., EEOC Appeal No. 0120120499 (Apr. 19, 2012).

Here, the alleged discriminatory action, canceling a “Certificate of Eligibles” so Complainant
could not fill her program assistant vacancies, occurred in May or April of 2016. We find that
“reasonable suspicion” existed at the time of the alleged act based on Complainant’s allegation
that she was subject to ongoing harassment and discrimination since 2014. Complainant’s initial
EEO contact was September 7, 2016, well past the 45-day limitation period. Claim 4 was
properly dismissed for untimely contact with an EEO Counselor.

Decision on Merits – Claim 1
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Disparate Treatment

A claim of disparate treatment based on indirect evidence is examined under the three-part
analysis first enunciated in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). For
Complainant to prevail, he or she must first establish a prima facie case of discrimination by
presenting facts that, if unexplained, reasonably give rise to an inference of discrimination, i.e.,
that a prohibited consideration was a factor in the adverse employment action. McDonnell
Douglas, 411 U.S. at 802; Furnco Construction Corp. v. Waters, 438 U.S. 567 (1978). The
burden then shifts to the Agency to articulate a legitimate, nondiscriminatory reason for its
actions. Texas Dep’t. of Cmty. Affairs v. Burdine, 450 U.S. 248, 253 (1981). Once the Agency
has met its burden, Complainant bears the ultimate responsibility to persuade the fact finder by a
preponderance of the evidence that the Agency acted on the basis of a prohibited reason. St.
Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (1993).

This established order of analysis in discrimination cases, in which the first step normally
consists of determining the existence of a prima facie case, need not be followed in all cases.
Where the Agency has articulated a legitimate, nondiscriminatory reason for the personnel action
at issue, the factual inquiry can proceed directly to the third step of the McDonnell Douglas
analysis, the ultimate issue of whether Complainant has shown by a preponderance of the
evidence that the Agency’s actions were motivated by discrimination. U.S. Postal Serv. Bd. of
Governors v. Aikens, 460 U.S. 711, 713-714 (1983); Hernandez v. Dep’t. of Transp., EEOC
Request No. 05900159 (June 28, 1990); Peterson v. Dep’t. of Health and Human Serv., EEOC
Request No. 05900467 (June 8, 1990); Washington v. Dep’t. of the Navy, EEOC Petition No.
03900056 (May 31, 1990).

An employer has the discretion to determine how best to manage its operations and may make
decisions on any basis except a basis that is unlawful under the discrimination statutes. Grappone
v. Dep’t of the Navy, EEOC No. 01A10667 (Sept. 7, 2001) request for reconsideration denied,
EEOC Request No. 05A20020 (Dec. 28, 2002) citing Furnco, Nix v. WLCY Radio/Rayhall
Communications, 738 F.2d 1181 (11th Cir. 1984). An employer is entitled to make its own
business judgments. The reasonableness of the employer's decision may, of course, be probative
of whether it is pretext. The trier of fact must understand that the focus is to be on the
employer's motivation, not its business judgment. Loeb v. Textron, Inc., 600 F.2d 1003, 1012
n.6 (1st Cir. 1979).

Here, the Agency’s legitimate, nondiscriminatory reason S4 purportedly only wanted one
REEPorts Unit Coordinator per division to prevent “confusion,” citing an instance where
Complainant and P1 were accessing the REEPorts system at the same time, doing “double”
work. Both S2 and S4 cite a June 20, 2016 email sent by Complainant to the Head Secretary
(“HS”) reporting a technical glitch in REEPorts, which led them to believe Complainant no
longer wanted access to the System. There is no evidence that either consulted with
Complainant before requesting her name be removed as Unit Coordinator.

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Complainant argues that the Agency’s explanation was not reasonable, and therefore was pretext
for discrimination. She states that she has had access to the system throughout her 10 years in
the position, and that as a supervisor, she requires daily access to monitor P1, and ensure grants
are processed in P1’s absence as they are ultimately her responsibility. She contends that the
incident of “double” work S4 describes happened once, and notes that the June 20, 2016 email
never requested that her access be revoked. However, witness testimony supports that the double
access did cause confusion among others attempting to work in REEPorts. S4 was not
Complainant’s direct supervisor at the time he requested her access to be revoked, and unaware
of her day to day need for access since P1 had returned from her detail assignment. S2 promptly
restored Complainant’s access when she requested it. While Complainant demonstrated lack of
communication by Management (to its detriment both for morale and efficiency), she has not
established that the stated reason was unreasonable business judgment from Management’s point
of view so as to indicate pretext.

We are also not convinced by Complainant’s comparator argument, that HS (Caucasian, female,
age not specified) maintained her access to the REEPorts system despite S4’s explanation that he
only wanted a single designated Unit Coordinator per division. It is well established that in order
for comparative evidence relating to other employees to be considered relevant, all relevant
aspects of the employees' work situation must be identical or nearly identical, i.e., that the
employees report to the same supervisor, perform the same job function, and work during the
same time periods. See Anderson v. Dep’t of Treasury, EEOC Appeal No. 01A22092 (Mar. 13,
2003); Stewart v. Dep’t of Def., EEOC Appeal No. 01A02890 (Jun, 27, 2001); Jones v. United
States Postal Serv., EEOC Appeal No. 01983491 (Apr. 13, 2000). Based on the organization
chart in the record, HR was not in the same Division as Complainant. Although it appears their
responsibilities may have overlapped, and that they worked together, coordinating panels, they
had different functions. HR was a non-supervisory employee who supported the Directors, and
Complainant was in a supervisory role for Program Support. Complainant and HR also reported
to different direct supervisors.

In sum, Complainant has not established that she was subjected to disparate treatment.

Harassment/Hostile Work Environment

Complainant also argues that her removal from the REEPorts System constituted harassment
because it stymied her ability to do her job. However, S2 corrected the issue the same day
Complainant requested that her access be restored. While we acknowledge the alleged context of
Complainant’s removal from the REEPorts System, particularly the lack of communication,
given the quick correction, we do not find Complainant established the requisite hostility or
motive. Moreover, the action alleged is not so severe or pervasive to constitute discriminatory
harassment or create a hostile work environment. See Henson v. City of Dundee, 682 F.2d 897
(11th Cir. 1982); Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment
by Supervisors, EEOC Notice 915.002 (June 18, 1999).

New Allegations Raised on Appeal
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On appeal, Complainant raises additional allegations of harassment by a new supervisor, and
other instances of alleged harassment by S4. If Complainant wishes to pursue these new claims
in an EEO complaint, then she must contact an EEO Counselor pursuant to 29 C.F.R. §
1614.105. See Hall v. United States Postal Serv., EEOC Appeal No. 0120031342 (Apr. 24,
2003). Complainant did not include these claims in her formal complaint, so they will not be
adjudicated in this decision.

Dissatisfaction with Complaint Processing

Allegations of dissatisfaction with an agency’s processing of a previously filed or pending
complaint cannot be the subject of an EEO complaint. Equal Employment Opportunity
Management Directive for 29 C.F.R. Part 1614 (EEO MD-110), Ch. 5, IV.A.12 and IV.D (Aug.
3, 2015); Morris v. Dep’t of Def., EEOC Request No. 0520130316 (Aug. 27, 2013).

Our guidance provides that “a complainant must raise any dissatisfaction with the processing of
his or her complaint before the Administrative Judge issues a decision on that complaint, the
agency takes final action on the complaint, or either the Administrative Judge or the agency
dismisses the complaint.” See EEO-MD-110.

Complainant’s timely May 22, 2017 Rebuttal Statement includes extensive details about her
dissatisfaction with the processing of her complaint. Although the Agency’s final action is dated
prior to the receipt of Complainant’s FAD, we find that she submitted it within the statutory time
limit, and therefore, the Agency failed to properly address her concerns in accordance with our
regulations.

CONCLUSION

Based on a thorough review of the record and the contentions on appeal, including those not
specifically addressed herein, we AFFIRM the Agency’s finding that Complainant did not
establish discrimination as alleged.

STATEMENT OF RIGHTS - ON APPEAL
RECONSIDERATION (M0617)
The Commission may, in its discretion, reconsider the decision in this case if the Complainant or
the Agency submits a written request containing arguments or evidence which tend to establish
that:
1. The appellate decision involved a clearly erroneous interpretation of material fact
or law; or
2. The appellate decision will have a substantial impact on the policies, practices, or
operations of the Agency.
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Requests to reconsider, with supporting statement or brief, must be filed with the Office of
Federal Operations (OFO) within thirty (30) calendar days of receipt of this decision. A party
shall have twenty (20) calendar days of receipt of another party’s timely request for
reconsideration in which to submit a brief or statement in opposition. See 29 C.F.R. § 1614.405;
Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614 (EEO MD-110),
at Chap. 9 § VII.B (Aug. 5, 2015). All requests and arguments must be submitted to the
Director, Office of Federal Operations, Equal Employment Opportunity Commission.
Complainant’s request may be submitted via regular mail to P.O. Box 77960, Washington, DC
20013, or by certified mail to 131 M Street, NE, Washington, DC 20507. In the absence of a
legible postmark, the request to reconsider shall be deemed timely filed if it is received by mail
within five days of the expiration of the applicable filing period. See 29 C.F.R. § 1614.604. The
agency’s request must be submitted in digital format via the EEOC’s Federal Sector EEO Portal
(FedSEP). See 29 C.F.R. § 1614.403(g). The request or opposition must also include proof of
service on the other party.
Failure to file within the time period will result in dismissal of your request for reconsideration
as untimely, unless extenuating circumstances prevented the timely filing of the request. Any
supporting documentation must be submitted with your request for reconsideration. The
Commission will consider requests for reconsideration filed after the deadline only in very
limited circumstances. See 29 C.F.R. § 1614.604(c).
COMPLAINANT’S RIGHT TO FILE A CIVIL ACTION (S0610)
You have the right to file a civil action in an appropriate United States District Court within
ninety (90) calendar days from the date that you receive this decision. If you file a civil action,
you must name as the defendant in the complaint the person who is the official Agency head or
department head, identifying that person by his or her full name and official title. Failure to do
so may result in the dismissal of your case in court. “Agency” or “department” means the
national organization, and not the local office, facility or department in which you work. If you
file a request to reconsider and also file a civil action, filing a civil action will terminate the
administrative processing of your complaint.
RIGHT TO REQUEST COUNSEL (Z0815)
If you want to file a civil action but cannot pay the fees, costs, or security to do so, you may
request permission from the court to proceed with the civil action without paying these fees or
costs. Similarly, if you cannot afford an attorney to represent you in the civil action, you may
request the court to appoint an attorney for you. You must submit the requests for waiver of
court costs or appointment of an attorney directly to the court, not the Commission.
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The court has the sole discretion to grant or deny these types of requests. Such requests do not
alter the time limits for filing a civil action (please read the paragraph titled Complainant’s Right
to File a Civil Action for the specific time limits).
FOR THE COMMISSION:

______________________________ Carlton M. Hadden’s signature
Carlton M. Hadden, Director
Office of Federal Operations

November 6, 2018
Date