0720080048
12-10-2009
Gilbert H. Amis, III, Complainant, v. Janet Napolitano, Secretary, Department of Homeland Security, (Transportation Security Administration), Agency.
Gilbert H. Amis, III,
Complainant,
v.
Janet Napolitano,
Secretary,
Department of Homeland Security,
(Transportation Security Administration),
Agency.
Appeal No. 0720080048
Hearing No. 430-2007-00078X-WMS
Agency No. HS-05-TSA-002222
DECISION
Following its May 30, 2008 final order, the agency filed an appeal which
the Commission accepts pursuant to 29 C.F.R. � 1614.405(a). On appeal,
the agency requests that the Commission affirm its rejection of an EEOC
Administrative Judge's (AJ) finding of discrimination in violation of
Section 501 of the Rehabilitation Act of 1973 (Rehabilitation Act),
as amended, 29 U.S.C. � 791 et seq. The agency also requests that the
Commission affirm its rejection of the relief ordered by the AJ. For the
following reasons, the Commission MODIFIES the agency's final order.
ISSUES PRESENTED
The issues presented are whether the agency properly rejected the
findings of the AJ that complainant had been discriminated against based
on reprisal when he was denied light duty, and whether the relief awarded
by the AJ was properly determined.
BACKGROUND
At the time of events giving rise to this complaint, complainant worked
as a Federal Air Marshal at the agency's facility in Charlotte, North
Carolina. On February 27, 2006, complainant filed an EEO complaint
alleging that he was discriminated against on the bases of disability
(Eustachian tube dysfunction and dyslexia) and in reprisal for prior
protected EEO activity arising under the Rehabilitation Act when:
1. on July 27, 2005, he was denied an in-position-increase (IPI) of 3%;
2. on August 10, 2005, he was denied a restricted light duty position;
and
3. on January 3, 2006, he was not selected for an Assistant Training
Officer position.
At the conclusion of the investigation, complainant was provided with a
copy of the report of investigation and notice of his right to request
a hearing before an EEOC Administrative Judge (AJ). Complainant timely
requested a hearing. The AJ held a hearing on May 24, 2007, and issued
a decision on May 2, 2008.
The AJ found the facts of the case to be as follows. Complainant is a
Federal Air Marshal who has been employed by the agency since June 2002.
He suffers from Eustachian tube dysfunction, which affects his ability to
fly on aircraft, at times, and to walk; his condition is controlled with
medication. He also has been diagnosed with dyslexia. Complainant had
engaged in prior EEO activity on the bases of disability and reprisal
by virtue of a complaint filed on October 14, 2004, which was heard by
an AJ on February 28, 2006. In that complaint, he also named the same
two management officials who were involved in the present complaint.
Complainant alleged that he was denied a 3% in-position-increase (IPI)
for discriminatory reasons. IPI's were distributed to the top 25%
of the Federal Air Marshals in the office, based on factors such as
attitude, submission of surveillance detection reports, and missing
scheduled flights. Complainant had requested light/restricted duty on
August 10, 2005, when he submitted his restriction from flight status
to his first level supervisor, the Assistant Special Agent in Charge
(ASAC). He asked to be assigned to training or to surveillance at
the airport due to his Eustachian tube dysfunction. The ASAC refused
his request and sent him home. That same afternoon, at 5:10 p.m.,
the Special Agent in Charge (SAC) changed the Charlotte Field Office
policy to limit light/restricted duty to two employees at a time.
Complainant was placed on Continuation of Pay (COP) as there were already
two employees on light/restricted duty. The SAC testified that he had
begun the process to change the light/restricted duty policy on July 18,
2005, but that it was finalized on August 10, 2005. Finally, complainant
applied for an Assistant Training Officer position, was interviewed by
the five-member panel who rated and ranked the candidates, but was not
one of the seven candidates selected.
In his decision, the AJ found that complainant was not an individual with
a disability in that he had not shown that his conditions substantially
limited him in one or more major life activities. The AJ also noted
that complainant's Eustachian tube dysfunction was well controlled by
medication. Turning to complainant's claim of discrimination based on
reprisal, the AJ found that complainant had established a prima facie
case of reprisal. Complainant engaged in protected activity in September
2004, and the SAC and ASAC were both aware of it. He suffered adverse
actions in the form of the IPI denial, the light/restricted duty denial
and the non-selection.
The agency offered legitimate, nondiscriminatory reasons for each
of its actions. Regarding the IPI denial, the agency claimed that
complainant was not among the top 25% of the Federal Air Marshals in the
Charlotte Field Office. Complainant was not given a light/restricted
duty position because the policy was that only two employees could be on
light/restricted duty at a time, and two Federal Air Marshals with more
seniority occupied those positions at the time of complainant's request.
The agency noted that complainant did receive COP from the Office
of Workers' Compensation Programs (OWCP) while he was out. Finally,
complainant was not selected for the Assistant Training Officer position,
because he was not among the best qualified.
The AJ then examined whether complainant had shown that any of the
agency's reasons to be pretext for discrimination. He found that as to
issue 1, although the SAC was the approving official for awarding the
IPIs, he did not select which Federal Air Marshals were considered to
be the top 25%. Rather, a panel of supervisors forwarded the names to
the SAC. Regarding issue 3, the AJ found that there was no evidence
that complainant had not been selected for the Assistant Training
Officer position for retaliatory motives. Complainant had not shown
that he was better qualified than those candidates who were selected
for the position.
With respect to issue 2, however the AJ found that complainant had shown
facts that supported a finding of discrimination. Complainant requested
light/restricted duty on August 10, 2005, and the agency changed the
policy within hours of his request in a way that would deny him the
light/restricted duty. Complainant made his request before the new
policy was put into effect, but it was applied to him. Additionally,
the SAC was the named responsible management official in complainant's
previous EEO case, and the SAC was the official who decided to issue
the new policy the same day as complainant's request. The AJ noted
that another Federal Air Marshal was allowed to work light/restricted
duty a few months later, even though there were already two Federal Air
Marshals on light/restricted duty. The AJ concluded that complainant had
been discriminated against on the basis of reprisal when he was denied
light/restricted duty.
The AJ awarded as relief for the discrimination: $47.01 in lost Sunday
pay; compensatory damages of $10,000.00; mileage expenses of $54.62;
and attorney's fees of $8,750.00. He also ordered that the agency
post a notice informing employees at complainant's work location that:
it had discriminated against an employee; it would cease discriminating
on the basis of reprisal; it would not retaliate against complainant;
and it would take corrective, curative or preventive action to ensure
that future violations such as this do not recur.
The agency subsequently issued a final order rejecting the AJ's finding
that complainant proved that he was subjected to discrimination as
alleged.
CONTENTIONS ON APPEAL
The agency argued on appeal that the finding of discrimination based
on reprisal was in error. The agency claimed that the AJ's conclusion
that complainant established a prima facie case of reprisal was incorrect
because complainant was not aggrieved when he was denied light/restricted
duty because he received COP from OWCP during the time period he was
off work. Complainant had experienced an on-the-job injury to his right
inner ear on August 6, 2005, which is what precipitated his request for
light/restricted duty on August 10, 2005. Because it was an on-the-job
injury, complainant was approved for OWCP benefits until he was cleared
to work again by his doctor. The agency argued that complainant was
fully compensated by OWCP while he was off work and that therefore,
he was not aggrieved.
The agency further argued that there was no causal connection between
complainant's prior EEO activity in September 2004 and the change in the
light duty policy on August 10, 2005. The agency's argument centers on
the amount of time between the protected activity and the adverse action
being too long. Finally, the agency asserted that the decision to change
the light/restricted policy had been made by the SAC on July 18, 2005,
because there were issues with the administration of the previous light
duty policy.
The agency argued, in the alternative, that if the Commission upholds the
AJ's decision finding reprisal discrimination, the amount of compensatory
damages awarded was too high, and unsupported by any findings by the AJ.
The agency also argued that the attorney's fees award was too high, based
on the complainant's degree of success on his three claims. The agency
claimed that the total fee requested should have been reduced by 67%
to reflect that complainant only prevailed on one of three claims.
Complainant did not submit any contentions in support of the AJ's
decision, or in opposition to the agency's brief in support of the
appeal.
ANALYSIS AND FINDINGS
Pursuant to 29 C.F.R. � 1614.405(a), all post-hearing factual findings by
an AJ will be upheld if supported by substantial evidence in the record.
Substantial evidence is defined as "such relevant evidence as a reasonable
mind might accept as adequate to support a conclusion." Universal
Camera Corp. v. National Labor Relations Board, 340 U.S. 474, 477 (1951)
(citation omitted). A finding regarding whether or not discriminatory
intent existed is a factual finding. See Pullman-Standard Co. v. Swint,
456 U.S. 273, 293 (1982). An AJ's conclusions of law are subject to a
de novo standard of review, whether or not a hearing was held. An AJ's
credibility determination based on the demeanor of a witness or on the
tone of voice of a witness will be accepted unless documents or other
objective evidence so contradicts the testimony or the testimony so
lacks in credibility that a reasonable fact finder would not credit it.
See EEOC Management Directive 110, Chapter 9, � VI.B. (November 9, 1999).
To prevail in a disparate treatment claim such as this, complainant must
satisfy the three-part evidentiary scheme fashioned by the Supreme Court
in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Complainant
must initially establish a prima facie case by demonstrating that he or
she was subjected to an adverse employment action under circumstances
that would support an inference of discrimination. Furnco Construction
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,
411 U.S. at 804 n. 14. The burden then shifts to the agency to articulate
a legitimate, nondiscriminatory reason for its actions. Texas Department
of Community Affairs v. Burdine, 450 U.S. 248, 253 (1981). To ultimately
prevail, complainant must prove, by a preponderance of the evidence, that
the agency's explanation is pretextual. Reeves v. Sanderson Plumbing
Products, Inc., 530 U.S. 133, 120 S.Ct. 2097 (2000); St. Mary's Honor
Center v. Hicks, 509 U.S. 502, 519 (1993).
Complainant can establish a prima facie case of reprisal discrimination
by presenting facts that, if unexplained, reasonably give rise to
an inference of discrimination. Shapiro v. Social Security Admin.,
EEOC Request No. 05960403 (Dec. 6, 1996) (citing McDonnell Douglas).
Specifically, in a reprisal claim, and in accordance with the burdens
set forth in McDonnell Douglas, Hochstadt v. Worcester Foundation for
Experimental Biology, 425 F. Supp. 318, 324 (D. Mass.), aff'd, 545 F.2d
222 (1st Cir. 1976), and Coffman v. Department of Veteran Affairs, EEOC
Request No. 05960473 (November 20, 1997), complainant may establish
a prima facie case of reprisal by showing that: (1) he engaged in a
protected activity; (2) the agency was aware of the protected activity;
(3) subsequently, he was subjected to adverse treatment by the agency;
and (4) a nexus exists between the protected activity and the adverse
treatment. Whitmire v. Department of the Air Force, EEOC Appeal
No. 01A00340 (September 25, 2000).
We note that the agency had argued to the AJ prior to the hearing that
complainant's claim of denial of light/restricted duty should be dismissed
because complainant was not aggrieved. The AJ did not grant the agency's
motion for dismissal. We agree that complainant was aggrieved when he
was denied the light/restricted duty, even though he was compensated by
OWCP for his time out of work. The Commission has stated that adverse
actions need not qualify as "ultimate employment actions" or materially
affect the terms and conditions of employment to constitute retaliation.
Lindsey v. United States Postal Service, EEOC Request No. 05980410
(Nov. 4, 1999) (citing EEOC Compliance Manual Section 8, "Retaliation,"
No. 915.003 (May 20, 1998)). Instead, the statutory retaliation clauses
prohibit any adverse treatment that is based upon a retaliatory motive and
is reasonably likely to deter the charging party or others from engaging
in protected activity. Id. The Commission finds that complainant
was aggrieved for the purposes of a claim of reprisal discrimination
in that the actions of the SAC were likely to have a chilling effect,
not just on complainant, but on other employees in the workplace.
Contrary to the agency's argument that there was no causal connection
between complainant's previous EEO activity and the decision to implement
a new light/restricted duty policy, we note that proximity in time to
the original EEO activity is not the only way to establish a connection.
On August 10, 2005, when the complainant was denied light/restricted duty,
his previous complaint was still being processed, with an investigation
conducted subsequent to the filing of the formal complaint on October 15,
2004, and a hearing conducted in February 2006. We note that in Jenkins
v. U.S. Postal Service, EEOC Appeal No. 0120064579 (July 8, 2008), the
Commission found that the named responsible management official would have
been recently reminded of the previous EEO complaint due to the ongoing
investigation and any recent activity in the processing thereof.
Finally, the agency argued that the decision to change the
light/restricted duty policy was made on July 18, 2005, a little
over 3 weeks before complainant made his request for restricted duty.
In his affidavit, the SAC says it was "coincidental" that he decided
to implement the revised policy on the very day that complainant made
his request. While a change to the policy may have been contemplated,
the decision to implement it, on August 10, 2005, at 5:10 p.m. and to
decide that it should apply to a request previously made under the old
policy, was entirely within the SAC's discretion. Thus, we find the
AJ's determination that the change was made for discriminatory reasons
to be reasonable and supported by substantial evidence in the record.
Relief awarded
Compensatory damages
Pursuant to section 102(a) of the Civil Rights Act of 1991, a complainant
who establishes unlawful intentional discrimination under either Title VII
of the Civil Rights Act of 1964 (Title VII), as amended, 42 U.S.C. � 2000e
et seq., or the Rehabilitation Act may receive compensatory damages for
past and future pecuniary losses and non-pecuniary losses. 42 U.S.C. �
1981a(b)(3). In West v. Gibson, 527 U.S. 212 (1999), the Supreme Court
held that Congress afforded the Commission the authority to award
compensatory damages in the administrative process.
The AJ awarded complainant $10,000.00 in compensatory damages, but did
not discuss how he arrived at this amount in his decision. The agency
argued that the award was unsupported by the record. We find that
there was testimony at the hearing in support of complainant's claim
for compensatory damages. Complainant claimed that he has suffered
from insomnia, anxiousness, and stomach upset.1 He testified that he
had not seen a psychiatrist out of fear that he would lose his security
clearance. There was no testimony as to the duration of these conditions.
Non-pecuniary damages must be limited to the sums necessary to compensate
the injured party for the actual harm and should take into account the
severity of the harm and the length of the time the injured party has
suffered from the harm. Carpenter v. Department of Agriculture, EEOC
Appeal No. 01945652 (July 17, 1995).
Based on the record before us, we find that the agency failed to
establish that the AJ's award was not reasonable. On the contrary,
the AJ's award is supported by substantial evidence in the record
as set forth in complainant's testimony and is consistent with the
amounts awarded in similar cases. See Daniels v. United States Postal
Service, EEOC Appeal No. 07A30028 (September 3, 2003) ($10,000.00
award in non-pecuniary, compensatory damages based on complainant's
statements of vomiting, anxiety, sleeplessness, digestive problems,
and emotional distress resulting from the agency's discrimination);
Williams v. Department of Transportation, EEOC Appeal No. 01A10856
(July 6, 2001) ($9,000.00 award in non-pecuniary, compensatory damages
where complainant experienced depression, anxiety, sleeplessness, and
difficulty in his marital relations).
Attorney's fees
The agency is required to award attorney's fees for the successful
processing of an EEO complaint in accordance with existing case
law and regulatory standards. Bernard v. Department of Veterans
Affairs, EEOC Appeal No. 01966861 (July 17, 1998). Attorney's fees
are computed by determining the lodestar, i.e., the number of hours
reasonably expended multiplied by a reasonable hourly rate. 29 C.F.R. �
1614.501(e)(2)(ii)(B); Equal Employment Opportunity Commission Management
Directive (MD) 110 at 11-5 (citing Hensley v. Eckerhart, 461 U.S. 424,
434 (1983)). All hours reasonably spent in processing the complaint
are compensable, and the number of hours should not include excessive,
redundant or otherwise unnecessary hours. MD 110 at 11-5 (citing
Hensley, 461 U.S. at 434; and Bernard, EEOC Appeal No. 01966861).
A reasonable hourly rate is based on prevailing market rates in the
relevant community for attorneys of similar experience in similar
cases. MD-110 at 11-6 (citing Cooley v. Department of Veterans Affairs,
EEOC Request No. 05960748 (July 30, 1998)). In determining the degree of
success, the Commission will consider all relief obtained in light of a
complainant's goals, and, if a complainant achieved only limited success,
s/he should recover fees that are reasonable in relation to the results
obtained. Hensley, 461 U.S. at 434. While a reasonable fee should not
be determined simply by mathematical formula, hours spent on unsuccessful
claims should be excluded from the amount of a reasonable fee. Id.
The attorney requested a total of $10,975.00 in fees. The AJ awarded
$8,750.00, after reducing the award by $2,225.00 for charges for the
work done prior to the filing of the formal complaint. The agency
argued that the award should be further reduced by 67% to reflect the
degree of success by the complainant. Although we agree with the agency
that complainant should only recover for the hours spent pursuing the
claim he was successful on, the agency, however, failed to set forth in
any detail the specific hours that it believes should be disallowed.
For example, complainant's attorney may have spent a disproportionate
amount of time on the issue that he prevailed upon; therefore, the 67%
across the board reduction called for by the agency would not be proper.
Based on its appeal, we find that the agency simply failed to establish
that the AJ's attorney fee award should be reduced.
CONCLUSION
Based on a thorough review of the record and the contentions on appeal,
including those not specifically addressed herein, we MODIFY the agency's
Order as reflected above.
ORDER
Within sixty (60) days of the date this decision becomes final:
1. The agency shall issue complainant a check for $10,000.00 for
non-pecuniary compensatory damages.
2. The agency shall pay complainant $8,750.00 for attorney's fees.
3. The agency shall pay complainant $47.01 in lost Sunday pay, and $54.62
in mileage expenses.
4. The agency shall provide training to the responsible management
officials regarding their responsibilities under EEO laws, with a special
emphasis on the Rehabilitation Act.
5. The agency shall consider taking appropriate disciplinary action
against the responsible management officials. The Commission does not
consider training to be disciplinary action. The agency shall report
its decision to the Compliance Officer. If the agency decides to take
disciplinary action, it shall identify the action taken. If the agency
decides not to take disciplinary action, it shall set forth the reason(s)
for its decision not to impose discipline. If any of the responsible
management officials have left the agency's employ, the agency shall
furnish documentation of their departure date(s).
6. The agency shall post a notice in accordance with the paragraph below.
The agency is further directed to submit a report of compliance, as
provided in the statement entitled "Implementation of the Commission's
Decision." The report shall include supporting documentation verifying
that the corrective action has been implemented.
POSTING ORDER (G0900)
The agency is ordered to post at its Charlotte, North Carolina facility
copies of the attached notice. Copies of the notice, after being
signed by the agency's duly authorized representative, shall be posted
by the agency within thirty (30) calendar days of the date this decision
becomes final, and shall remain posted for sixty (60) consecutive days,
in conspicuous places, including all places where notices to employees are
customarily posted. The agency shall take reasonable steps to ensure that
said notices are not altered, defaced, or covered by any other material.
The original signed notice is to be submitted to the Compliance Officer
at the address cited in the paragraph entitled "Implementation of the
Commission's Decision," within ten (10) calendar days of the expiration
of the posting period.
ATTORNEY'S FEES (H0900)
If complainant has been represented by an attorney (as defined by
29 C.F.R. � 1614.501(e)(1)(iii)), he/she is entitled to an award of
reasonable attorney's fees incurred in the processing of the complaint.
29 C.F.R. � 1614.501(e). The award of attorney's fees shall be paid
by the agency. The attorney shall submit a verified statement of fees
to the agency -- not to the Equal Employment Opportunity Commission,
Office of Federal Operations -- within thirty (30) calendar days of this
decision becoming final. The agency shall then process the claim for
attorney's fees in accordance with 29 C.F.R. � 1614.501.
IMPLEMENTATION OF THE COMMISSION'S DECISION (K1208)
Compliance with the Commission's corrective action is mandatory.
The agency shall submit its compliance report within thirty (30) calendar
days of the completion of all ordered corrective action. The report shall
be submitted to the Compliance Officer, Office of Federal Operations,
Equal Employment Opportunity Commission, P.O. Box 77960, Washington,
DC 20013. The agency's report must contain supporting documentation,
and the agency must send a copy of all submissions to the complainant.
If the agency does not comply with the Commission's order, the complainant
may petition the Commission for enforcement of the order. 29 C.F.R. �
1614.503(a). The complainant also has the right to file a civil action
to enforce compliance with the Commission's order prior to or following
an administrative petition for enforcement. See 29 C.F.R. �� 1614.407,
1614.408, and 29 C.F.R. � 1614.503(g). Alternatively, the complainant
has the right to file a civil action on the underlying complaint in
accordance with the paragraph below entitled "Right to File A Civil
Action." 29 C.F.R. �� 1614.407 and 1614.408. A civil action for
enforcement or a civil action on the underlying complaint is subject
to the deadline stated in 42 U.S.C. 2000e-16(c) (1994 & Supp. IV 1999).
If the complainant files a civil action, the administrative processing of
the complaint, including any petition for enforcement, will be terminated.
See 29 C.F.R. � 1614.409.
STATEMENT OF RIGHTS - ON APPEAL
RECONSIDERATION (M1208)
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 or within twenty (20) calendar days of
receipt of another party's timely request for reconsideration. See 29
C.F.R. � 1614.405; Equal Employment Opportunity Management Directive for
29 C.F.R. Part 1614 (EEO MD-110), 9-18 (November 9, 1999). All requests
and arguments must be submitted to the Director, Office of Federal
Operations, Equal Employment Opportunity Commission, P.O. Box 77960,
Washington, DC 20013. 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 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 (R0408)
This is a decision requiring the agency to continue its administrative
processing of your complaint. However, if you wish to file a civil
action, you have the right to file such action in an appropriate United
States District Court within ninety (90) calendar days from the date
that you receive this decision. In the alternative, you may file a
civil action after one hundred and eighty (180) calendar days of the date
you filed your complaint with the agency, or filed your appeal with the
Commission. 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. Filing a civil
action will terminate the administrative processing of your complaint.
RIGHT TO REQUEST COUNSEL (Z1008)
If you decide to file a civil action, and if you do not have or cannot
afford the services of an attorney, you may request from the Court that
the Court appoint an attorney to represent you and that the Court also
permit you to file the action without payment of fees, costs, or other
security. See Title VII of the Civil Rights Act of 1964, as amended,
42 U.S.C. � 2000e et seq.; the Rehabilitation Act of 1973, as amended,
29 U.S.C. �� 791, 794(c). The grant or denial of the request is within
the sole discretion of the Court. Filing a request for an attorney with
the Court does not extend your time in which to file a civil action.
Both the request and the civil action must be filed within the time
limits as stated in the paragraph above ("Right to File A Civil Action").
FOR THE COMMISSION:
______________________________
Carlton M. Hadden, Director
Office of Federal Operations
_______12/10/09___________
Date
1 Complainant testified that:
[I] get to the point at times when I'm driving to the office or I just -
-I'm ready to shake, it's just - it's nerve racking just going there.
If I stay all day at the office, when I leave the office I have a hard
time sleeping at night, I've had insomnia, I'm taking Tums and its been
on my medicals, I talked to my doctors about it, I'll take a roll of
Tums a day and it's just - it's killing me.
Hearing Transcript at pg 60.
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0720080048
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
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0720080048