Eulalia B.,1 Complainant,v.Megan J. Brennan, Postmaster General, United States Postal Service (Pacific Area), Agency.

Equal Employment Opportunity Commission

Dec 18, 2019

0120182164 (E.E.O.C. Dec. 18, 2019)

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

Eulalia B.,1
Complainant,

v.

Megan J. Brennan,
Postmaster General,
United States Postal Service
(Pacific Area),
Agency.

Appeal No. 0120182164
Hearing No. 480-2015-00166X
Agency No. 1F901003413

DECISION

On June 8, 2018, Complainant filed an appeal with the Equal Employment Opportunity
Commission (EEOC or Commission), pursuant to 29 C.F.R. § 1614.403(a), from the Agency’s
May 7, 2018, final decision 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 Section 501 of the Rehabilitation Act of 1973
(Rehabilitation Act), as amended, 29 U.S.C. § 791 et seq. For the following reasons, the
Commission AFFIRMS the Agency’s final decision.

ISSUES PRESENTED

Whether the Agency correctly determined that Complainant failed to establish that she was
subjected to discriminatory harassment based on disability, and retaliation when:

1. Beginning February 6, 2013, and ongoing, she was rotated among six to seven machines
per night; after she complained about being rotated on so many machines per shift, the
Agency failed to accommodate her or engage in the interactive process;
2. On or about February 6, 2013, her supervisor mocked her voice and manner of speech;
3. On February 21, 2013, a coworker made derogatory comments about her and management
failed to take appropriate action;

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.
0120182164

2
4. On March 4, 2013, her management staff discouraged her from filing an EEO complaint;
5. On March 13, 2013, the Attendance Coordinator responded in a derogatory manner to her
request for documentation;
6. On March 13, 2013, her supervisor responded to her in a rude manner when she said, “good
morning” to her;
7. On March 29, 2013, she was given an investigative interview regarding her attendance;
and
8. On April 9, 2013, a supervisor spoke to her in a threatening manner by stating, “If my boss
would let me, I would hit you upside your head” while waving papers over her head and
then hugged her shoulders.

BACKGROUND

At the time of events giving rise to this complaint, Complainant worked as a Mail Processing Clerk
at the Agency’s Processing & Distribution Center in Los Angeles, California. On May 16, 2013,
Complainant filed an EEO complaint alleging that the Agency discriminated against her on the
bases of disability (physical) and in reprisal for engaging in prior protected EEO activity as set
forth above.

Complainant alleged that various management officials subjected her to discriminatory harassment
from February 6, 2013 and ongoing. They were Supervisors, of Distribution Operations, SDO1,
SDO2, SDO3, SDO4, and SDO5; Acting SDO, A1; and Managers, of Distribution Operations,
MDO1 and MDO2.

Complainant testified that she was diagnosed with Adductor Spasmodic Dysphonia (ADSD), a
permanent condition that causes sudden involuntary muscle movements or spasms. According to
Complainant, her vocal cords will “slam” together and stiffen; making it difficult for the vocal
folds to vibrate and produce her voice. She stated that this often caused her words to cut off or
made it difficult to start talking. She also stated that it made her voice sound strained or strangled.
Complainant explained that her impairment substantially limited her ability to perform major life
activities, such as speaking. She further testified that her condition was intermittent and was
triggered by negative behavior towards her, stress, and fatigue.

Complainant stated that, in approximately 2006, she provided medical documentation to the
Family and Medical Leave Act office explaining how her physical impairment affected her work;
and that on January 19, 2013, she told SDO1 about her condition and explained how the Botox
injections she received would make her talk with a whisper and cause her voice to sound hoarse
and raspy. Complainant testified, and MDO1 affirmed, that she had a reduced work schedule of
no more than six hours as of July 15, 2013, due to her disability.

Complainant had been involved in four prior EEO complaints. The most recent on January 14,
2012, in a matter that was settled on July 5, 2012. She asserted that the 2012 complaint served as
basis for the instant complaint. SDO1 and SDO2, and MDO2 testified that they were unaware of
Complainant’s EEO activity and that they were not listed as responsible management officials
0120182164

3
(RMOs) or witnesses in any prior complaint. MDO1, who had been named RMO in the 2012
complaint, testified that she was aware of Complainant’s prior EEO activity.

Claim 1

Complainant alleged that management rotated her among six to seven machines per night,
asserting that prior to that time, she was never rotated among machines. She testified that
management told her she was being rotated because they did not have enough people and they
“had holes.” She asserted that she should not have been rotated among machines because regular
employees were stable, and Support Employees (SEs) were supposed to flow (rotate) before the
regular employees. She added that management knew that rotating her between machines would
raise her level of anxiety, and that would cause her not to be able to speak because of muscle
spasms.

Complainant testified, however, that rotating among 6 to 7 machines a night did not violate her
medical restrictions. She maintained that she did not need an accommodation, but that because
she was often unable to speak she wanted to work with a partner who had patience with her. She
also testified that she accepted the accommodation that management offered her on July 28, 2013
on the Priority Belt. Complainant testified that she believed her EEO activity and physical
impairment were factors in being rotated on 6 to 7 machines per night because she filed an EEO
about a manager mocking her. Complainant maintained that the rotations were made to make her
feel unwanted and annoyed, and to worsen her disorder to the point where she could not speak at
all.

According to A1, Complainant was assigned to lunch relief for one machine and break relief for
approximately two others. She indicated that with Complainant’s limited hours and union time,
she would not have been able to rotate among six to seven machines; and that since Complainant’s
hours were limited, she could not be assigned to a machine as a second person. She testified that
if there were SEs in the area, they were used for lunch and break relief. There was supporting
testimony from other managers, who added that there were times when all SEs were asked to assist
with a final dispatch due to service needs and to meet service standards.

MDO2 testified that when Complainant returned to duty after having surgery, he asked her if she
could work six hours a day, Complainant, he stated, maintained that she was not ready to go back
to the machines. MDO2 asserted that Complainant told him that after spending two to three hours
performing union-related duties, she could work the remaining six hours of her shift performing
manual priority duties, an assignment which did not require her to perform all the essential
functions of her Mail Processing position including feeding and sweeping the machines.

Claim 2

Complainant alleged that SDO4 discriminated against her when she mocked her voice and manner
of speech. Complainant testified that she believed her EEO activity and physical impairments were
factors in this incident because the manager was mocking her disability.
0120182164

4

SDO4 denied making any gestures or verbal or nonverbal remarks concerning Complainant.
SDO5, who was also present at the time, supported SDO4’s version of the incident. SDO4 also
stated that she took great pride in being sensitive to employees’ feelings and disabilities; and that
she took offense to fabricated hearsay about her mocking anyone.

Claim 3

Complainant alleged that she received a very derogatory letter written by a coworker (C1),
delivered to her by her Chief Shop Steward (CSS), which mentioned that she must have a speech
impediment; and that her number one problem was her ability to communicate orally. She stated
her belief that her EEO activity and physical impairment were factors in management failing to
take appropriate action about this incident because C1 was aware of her accusing someone of
mocking her.

Management denied awareness of the letter written by C1; and Complainant admitted that she did
not bring it to their attention.

Claim 4

Complainant alleged that MDO1 and SDO1 discriminated against her during a meeting when they
discouraged her from filing an EEO complaint, explaining that MDO1 kept saying “well we don’t
need no EEOs or grievances filed because the Postal Service don’t have no money for that.” She
added that MDO1 then turned to SDO1 and stated “this is all your fault [SDO1]. You should have
took care of it within five days after [Complainant] complained.” Complainant stated her belief
that her EEO activity and physical impairment were factors in the alleged incident because, at that
point, management could feel that this matter affected her emotionally.

SDO1 denied any recollection of a conversation where MDO1 made the statements Complainant
attributed to her. She testified that she did not discourage employees from filing EEO complaints,
asserting that she did not talk to Complainant about any EEO complaints. MDO1 explained that
she told Complainant if she wanted to file an EEO complaint that was her right and she could not
stop her, adding that if there were any issues, she would continue working with the union to resolve
the situation at the lowest level, so they could avoid escalation to step 2 or step 3 of the grievance
process or an EEO complaint. She denied making the alleged statements about SDO1.

Claim 5

Complainant alleged that SDO5, who was the Attendance Coordinator, discriminated against her
when she called to ask if SDO6 could pull her call-ins from December 2012 through February
2013; and SDO6 stated, “you must be cuckoo,” and told her to go see her supervisor. Complainant
believed that her EEO activity was a factor when SDO6 responded to her in a derogatory manner
when she requested documentation because she knew that an investigative interview was
0120182164

5
forthcoming and did not want Complainant to be prepared for it; and that her physical impairment
was a factor because SDO5 was frustrated because she could not hear Complainant well.

SDO5, who had retired at the time of the instant complaint, did not provide an affidavit. However,
CSS testified that although she did not hear the conversation, SDO5 told her that she would never
“play” with Complainant again.

Claim 6

Complainant alleged that SDO1 discriminated against her when she responded to her in a rude
manner. According to Complainant, she approached SDO1 to discuss her attendance records.
Complainant stated that when she asked, “how are you doing today,” SDO1 replied “why?” She
stated that SDO1 was very arrogant in responding to her and that the look on her face led her to
believe SDO1 did not want to talk to her. Complainant maintained that her EEO activity was a
factor in SDO1’s rude response to her because before she reported on SDO4 mocking her, she
could have a pleasant conversation with SDO1; and that her physical impairment was a factor
because if someone talked to her in a harsh way, her voice would “clamp up,” a fact of which
SDO1 was aware.

SDO1 denied replying in a rude manner, explaining that when Complainant asked her how she
was doing, she answered “why,” because she wondered if she looked sick or sad, adding that
Complainant’s question caught her off guard because Complainant had never inquired about her
feelings.

Claim 7

Complainant alleged that SDO2 discriminated against her when she was given an investigative
interview. She believed that her EEO activity was a factor in being given an investigative
interview because she had pursued an EEO complaint against SDO4; and that her physical
impairment was a factor because management knew that the investigative interview would upset
her and make her condition worse.

SDO2 stated that Complainant was given an investigative interview because it was warranted. He
explained that she had a number of unscheduled absences that were not substantiated, which had
not been addressed by her previous supervisor. He stated that he reviewed the unit’s overall
attendance records and noted that Complainant’s attendance stood out as unsatisfactory; and that
the investigative interview was held in a progressive manner because steps had been taken by the
previous supervisor who had given Complainant a verbal attendance review prior to his, SDO2,
taking over the unit. He stated that he relied on the attendance policy for the Los Angeles Cluster
when he gave Complainant an investigative interview; and that her physical impairment and EEO
activity were not factors.

The record indicated that Complainant had numerous unscheduled absences in 2012 and from
January 1, 2013, to March 28, 2013. The record also indicated that there were six other Mail
0120182164

6
Processing Clerks at the Los Angeles P&OC who had not engaged in EEO activity, and three of
whom did not have medical impairments, who were also issued discipline and/or given
investigative interviews for unscheduled absences.

Claim 8

Complainant alleged that MDO1 discriminated against her when she spoke to Complainant in a
threatening manner on April 9, 2013, after Complainant greeted her with “hi.” MDO1, according
to Complainant, replied in a very threatening and hoarse tone, “if my boss would let me, I would
hit you upside your head,” and began to wave papers above Complainant’s head. Complainant
testified that D1, a union official, witnessed the incident. Complainant added that she was sitting
and MDO1 was standing and when she asked, “who is your boss,” MDO1 walked back to her and
attempted to hug her shoulders. Complainant stated that her EEO activity was a factor because, in
the meeting that she had with MDO1, she kept saying that they did not need any more EEOs; and
that her physical impairment was a factor, because she complained of SDO4 mocking her physical
impairment.

MDO1 asserted, corroborated by record evidence, that she was not at work on the date of the
alleged incident, because she was on sick leave. The CSS testified that she did not hear the
conversation between MDO1 and Complainant, but she saw MDO1 wave a piece of paper over
Complainant’s head. D1 denied knowing Complainant or anything about the incident.

At the conclusion of the investigation, the Agency provided Complainant with a copy of the report
of investigation and notice of her right to request a hearing before an Equal Employment
Opportunity Commission Administrative Judge. Complainant timely requested a hearing but
subsequently withdrew her request. Consequently, the Agency issued a final decision pursuant to
29 C.F.R. § 1614.110(b). The decision concluded that Complainant failed to prove that the
Agency subjected her to discrimination as alleged.

CONTENTIONS ON APPEAL

On appeal, among other things, Complainant reiterates her allegations. She also contends that the
Agency’s explanations lack credibility, asserting that her rotation to six or seven machines had a
nexus with her EEO complaint since she had never been previously rotated; and that rotating
between machines was not a violation of her medical restrictions, but it was a punitive action for
having complained about SDO4 mocking her for her disability. She further explains that the
accommodation request was to be partnered with a coworker with whom she had a good and
effective working relationship and who, she adds, understood and accepted her vocal limitations.
Complainant also contends that the Agency failed to provide her with the minutes of a meeting
with SDO1 and MDO1 which would support her allegations concerning Claim 4. Finally,
Complainant asks that the Commission find in her favor.

The Agency did not submit a brief on appeal.

0120182164

7
STANDARD OF REVIEW

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 Chap. 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”).

ANALYSIS AND FINDINGS

Denial of Reasonable Accommodation

Claim 1

To establish that she was denied a reasonable accommodation, Complainant must show that: (1)
she is an individual with a disability, as defined by 29 C.F.R. § 1630.2(g); (2) she is a “qualified”
individual with a disability pursuant to 29 C.F.R. § 1630.2(m); and (3) the Agency failed to provide
her with a reasonable accommodation. See, e.g., Bill A. v. Dep’t of the Army, EEOC Appeal No.
0120131989 (Oct. 26, 2016). An individual with a disability is “qualified” if he or she satisfies the
requisite skill, experience, education, and other job-related requirements of the employment
position that the individual holds or desires and, with or without reasonable accommodation, can
perform the essential functions of such position. 29 C.F.R. § 1630.2(m). Reasonable
accommodation includes modifications to the work environment or to manner or circumstances
under which the position held or desired is customarily performed, that enable a qualified
individual with a disability to perform the essential job functions. 29 C.F.R. §1630.2(o)(ii).

Assuming, arguendo, that Complainant is a qualified individual with a disability, we do not find
that she was denied a reasonable accommodation with respect to the actions set forth in claim 1.
According to Complainant’s testimony, she was never worked outside of her medical restrictions,
and that she did not need an accommodation. Complainant maintained that she wanted to work
with a specific individual as an accommodation because he was patient with her, but we find no
evidence that such a specific request, accompanied by medical documentation, was ever made.
Moreover, we find no persuasive evidence that Complainant needed to be partnered with a specific
coworker in order to perform the essential functions of her position, or that the accommodations
that were provided to her were not effective. In this regard, we note that there is no evidence that
Complainant at any time informed management that her reasonable accommodation was
ineffective. On July 28, 2013, she accepted management’s offer to work on the Priority Belt as an
accommodation. Based on the above, we find no evidence that she was ever denied a reasonable
accommodation. Furthermore, to the extent Complainant maintained that the Agency did not
engage in an interactive process with her, we note that an agency cannot be held liable solely for a
failure to engage in the interactive process; liability for a failure to engage occurs when the failure
0120182164

8
to engage in the interactive process results in agency’s failure to provide a reasonable
accommodation. See Broussard v. United States Postal Service, EEOC Appeal No. 01997106
(Sept. 13, 2002), req. to recon. den., EEOC Request No. 05A30114 (Jan. 9, 2003). Here, we find
no evidence that Complainant was ever denied a reasonable accommodation.

Disparate Treatment

Claim 7

To prevail in a disparate treatment claim absent direct evidence of discrimination, Complainant
must satisfy the evidentiary scheme fashioned by the Supreme Court in McDonnell Douglas Corp.
v. Green, 411 U.S. 792, 802-04 (1973). Complainant carries the initial burden of establishing a
prima facie case by demonstrating that she was subjected to an adverse employment action under
circumstances that would support an inference of discrimination. Furnco Constr. Co. v. Waters,
438 U.S. 567, 576 (1978). Proof of a prima facie case will vary depending on the facts of the
particular case. McDonnell Douglas, 441 U.S. at 802 n.13. 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 prove, by a preponderance of the evidence, that the reason proffered
by the Agency was a pretext for discrimination. Reeves v. Sanderson Plumbing Prod., Inc., 530
U.S. 133, 143 (2000); St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502, 519 (1993).

Assuming Complainant established a prima facie case of discrimination based on disability and
reprisal, we find that the Agency articulated a legitimate, non-discriminatory reason for its action.
SDO2 stated, and his testimony was corroborated by record evidence, that Complainant was given
an investigative interview because she had a number of unscheduled absences that were not
substantiated, which had not been addressed by her previous supervisor. Record evidence also
revealed that six other Mail Processing Clerks at the same location who had not engaged in EEO
activity, and three of whom had no medical impairments, were issued discipline and/or given
investigative interviews for unscheduled absences. Therefore, Complainant failed to show that
she was singled out for an investigative interview. Consequently, we find no persuasive evidence
of pretext or discriminatory animus here.

Harassment

Regarding Complainant’s hostile work environment claim, we find that under the standards set
forth in Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993) that Complainant’s claim of a hostile
work environment must fail with regard to claims 1 and 7. See Enforcement Guidance on Harris
v. Forklift Systems, Inc., EEOC Notice No. 915.002 (Mar. 8, 1994). A finding of a hostile work
environment is precluded by our determination that Complainant failed to establish that any of the
actions taken by the Agency with regard to claims 1 and 7 were motivated by discriminatory
animus. See Oakley v. United States Postal Service, EEOC Appeal No. 01982923 (Sep. 21, 2000).

Claims 2, 3, 4, 5, and 6
0120182164

9

In order to establish a claim of hostile-environment harassment, Complainant must show that: (1)
she belongs to a statutorily protected class; (2) she was subjected to harassment in the form of
unwelcome verbal or physical conduct involving the protected class; (3) the harassment
complained of was based on her statutorily protected classes; (4) the harassment affected a term
or condition of employment and/or had the purpose or effect of unreasonably interfering with the
work environment and/or creating an intimidating, hostile, or offensive work environment; and (5)
there is a basis for imputing liability to the employer. See Henson v. City of Dundee, 682 F.2d
897 (11th Cir. 1982).

With respect to claims 2, 3, 5, and 6, we find that Complainant did not establish a claim of
harassment. Assuming these matters occurred as alleged, we find no evidence that indicates that
they were based on Complainant’s disability or prior EEO activity. As the Commission has
repeatedly held, the discrimination laws are not civility codes. Rather, they forbid “only behavior
so objectively offensive as to alter the conditions of the victim’s employment.” Oncale v.
Sundowner Offshore Serv., Inc., 523 U.S. 75, 81 (1998). Complainant failed to describe any
severe or pervasive conduct that was based on her disability or prior protected EEO activity that
created a work environment so unbearable that the terms and conditions of her employment were
altered or otherwise negatively impacted.

Claims 4 and 8

We find no persuasive evidence that these claims took place as alleged. With regard to claim 4,
MDO1 and SDO1 denied that the comments attributed to them were ever made, and the record
contains no evidence indicating that they were made.2 With regard to claim 8, MDO1 testified
that she was on sick leave on the day Complainant maintains that the incident occurred. Although
a witness stated that she saw MDO1 waiving a paper over Complainant’s head, we find that even
if we assume that this was the same incident Complainant described, there is no evidence that
MDO1’s actions were based on Complainant’s disability or prior EEO activity. As Complainant
withdrew her request for hearing, we do not have the benefit of an Administrative Judge’s
credibility determinations after a hearing; therefore, we can only evaluate the facts based on the
weight of the evidence presented to us. We also note Complainant’s contentions on appeal
including that the Agency did not provide her with the minutes of her meeting with SDO1 and
MDO1. However, as noted above, she withdrew her hearing request and did not avail herself of
the discovery process through which the Agency could have been compelled to provide these
documents.
CONCLUSION

2 We do, however, question the wisdom of MDO1 telling Complainant that “if she wanted to file
an EEO complaint that was her right and she could not stop her,” because this might be interpreted
as a threat. Given that Complainant had already filed EEO complaints in the past, we assume that
she was aware of her rights.
0120182164

10
Based on a thorough review of the record and the contentions on appeal, including those not
specifically addressed herein, we AFFIRM the Agency’s final decision.

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.
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
0120182164

11
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. 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

December 18, 2019
Date