0120102898
07-17-2012
Joanne Fitch, Complainant, v. Eric H. Holder, Jr., Attorney General, Department of Justice, (Federal Bureau of Prisons), Agency.
Joanne Fitch,
Complainant,
v.
Eric H. Holder, Jr.,
Attorney General,
Department of Justice,
(Federal Bureau of Prisons),
Agency.
Appeal No. 0120102898
Hearing No. 440-2009-00013X
Agency No. BOP-2008-0102
DECISION
On June 26, 2010, Complainant filed an appeal from the Agency's May 26, 2010, final order 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. The Commission accepts the appeal, pursuant to 29 C.F.R. � 1614.405(a). For the following reasons, the Commission VACATES the Agency's final order.
ISSUES PRESENTED
1. Whether an EEOC Administrative Judge (AJ) erred in dismissing two claims because Complainant did not properly raise or attempt to correct or clarify those claims to the Agency.
2. Whether the AJ erred in issuing summary judgment in favor of the Agency.
BACKGROUND
In August 2005, Complainant enrolled as an Agency trainee in an 18-month training program to become a safety manager. In April and June 2006, she told Agency officials that a former safety manager had sexually harassed her during a training session.1 As a result, the Agency's Office of Internal Affairs investigated Complainant's allegation of sexual harassment, and interviewed the National Safety and Environmental Compliance Administrator (National Administrator), among others.
While the sexual harassment investigation was pending, Complainant felt frustrated that management had not advanced her through the training program within the stated 18-month period. She felt her progress was stymied, in part, because management did not allow her to enroll in all the courses required to complete the training program.2 The most recent example occurred in the summer of 2007. On July 27, 2007, the Agency emailed Complainant informing her that she had been assigned training certification with a status of "in progress" for several specialized courses. But then on August 1, 2007, the Agency emailed Complainant, advising her to disregard the previous emails because they were the result of a new system currently being implemented.
On August 7, 2007, the Office of Internal Affairs closed the sexual harassment investigation. About a month and a half later, on September 21, 2007, the National Administrator reassigned Complainant from her current location at the Metropolitan Correctional Center in Chicago, Illinois, to another facility elsewhere in the country.
On October 31, 2007, Complainant learned that the Agency had issued a new program statement that did not include the training program under which she had been enrolled. By this time, she was the only person out of an initial group of about 20 trainees who had not yet completed the 18-month training program. As the last remaining trainee in the program, Complainant suspected that the National Administrator had abolished the training program, and had done so, in part, to punish her for opening a sexual harassment investigation against an individual that Complainant asserts was his friend, and involving him in the investigation, which had closed only about three months prior. She contacted an EEO counselor on October 31, 2007.
Formal EEO Complaint
Complainant filed a formal EEO complaint, alleging that the Agency retaliated against her for prior EEO activity when:
1. on September 21, 2007, she was reassigned to the Butner Federal Correctional Complex in North Carolina;
2. on October 23, 2007, she alleged that the Safety Trainee program was abolished, leaving her untrained as a Safety Trainee. Additionally, she alleged that several requests for training were denied and that her Trainee record was never signed.
The EEO investigator investigated the claims, and the Agency provided Complainant with a copy of the report of investigation and notice of her right to request a hearing before an EEOC Administrative Judge (AJ). Complainant timely requested a hearing.
Motion for Summary Judgment
On February 12, 2008, the Agency filed a motion for summary judgment. The Agency asked the AJ to dismiss the claims involving the denials of training. The Agency maintained that the denials of training were discrete acts that were untimely raised because the last denial occurred on August 1, 2007, but Complainant contacted an EEO counselor on October 31, 2007, which was beyond the 45-day time limit.
Complainant responded that she properly raised the denial of training claims and the Agency's EEO office had already accepted and investigated these claims. She argued that she began to reasonably suspect retaliation only after learning about her reassignment and the abolishment of the training program in September and October 2007, and therefore timely contacted an EEO counselor within 45 days.
The AJ assigned to the case granted the Agency's motion and issued a decision without a hearing on April 12, 2010.
AJ's Summary Judgment Decision
As a preliminary matter, the AJ dismissed the claims concerning the denials of training and the failure to sign Complainant's trainee record, finding nothing in the record to show that the Agency's EEO office had accepted those claims for investigation.
The AJ then considered the merits of the remaining claims. The AJ determined that Complainant failed to establish a prima facie case of reprisal because she did not show a temporal nexus between her protected activity and the adverse treatment. Specifically, the AJ found the temporal gap was not "very close" between the time Complainant reported and testified about the sexual harassment in June and October 2006 and the time the National Administrator discontinued the training program and reassigned Complainant in mid- to late-2007. The AJ also found Complainant's assertion of a nexus to be speculative when she averred, based on her personal observations, that the National Administrator was friends with the former safety manager accused of sexual harassment.
But even if Complainant had demonstrated a nexus and established a prima facie case of reprisal discrimination, the AJ determined that the Agency articulated legitimate, nondiscriminatory reasons for reassigning Complainant and "abolishing" the training program.
* The National Administrator explained that he reassigned Complainant because he wanted to have her work at a larger, more complex facility so she could get on-the-job training and become fully qualified to be a safety manager.
* The National Administrator had the authority to reassign Complainant before she finished training, under the "mobility requirement" found in the trainee's position description, which subjected trainees to "geographic relocation of employees in training . . . at the discretion of management in the interest of the efficiency of the service."3
* The National Administrator denied abolishing the training program. Rather, he suspended the training program as part of a revamping process to make the program more effective and efficient.
The AJ then considered whether Complainant established pretext. In her opposition to summary judgment, Complainant argued that the National Administrator's explanations were not believable and were designed to hide a retaliatory motive.
First, Complainant questioned whether the National Administrator had reassigned her, as he claimed, in order that she could get more on-the-job training and become "fully qualified." The National Administrator admitted that under the revised training program, Complainant would start over as a new trainee and would not be credited for on-the-job learning at the reassigned facility.4 According to Complainant, if acquiring on-the-job training does not help her complete the revised training program, and she has to start over again as a new trainee, regardless of where she is located, then the National Administrator presented no legitimate reason for abruptly reassigning her to another facility in September 2007. The National Administrator's explanation for reassigning her (wanting to help get Complainant "fully qualified") appears, according to Complainant, to be an after-the-fact explanation, calling into question the National Administrator's credibility.
Second, Complainant maintained that the National Administrator did not have the authority to reassign her to another location before she completed her training, pursuant to the terms of the "Standard Mobility Statement," P.S. 3000.02 (Nov. 18, 1994), Attachment 3-21, in which the signor agrees "to relocate anywhere at the convenience of the Bureau upon completion of [his or her] training."5 Moreover, the National Administrator and the Regional Administrator acknowledged that the National Administrator had deviated from past practice in reassigning Complainant before her training was complete.6 Complainant maintained that this challenged the believability of the National Administrator's explanation and suggests a retaliatory motive.
The AJ found that Complainant failed to show pretext. The Agency then issued a final order, adopting the AJ's finding that Complainant failed to prove that the Agency subjected her to discrimination as alleged.
CONTENTIONS ON APPEAL
On appeal, Complainant first contends that the AJ erred procedurally in dismissing the denial of training claims because:
* the documentary evidence in the record shows that the Agency's EEO office had actually accepted those claims and investigated them; and
* the claims were timely raised in that a reasonable person in a structured training program would not have suspected discrimination at the time of denial; a reasonable person would have expected the training to be rescheduled for a later time. But a reasonable person in a structured training program would suspect a denial of training to be discriminatory in retrospect, after she is reassigned to another location and is informed that her training has to start all over again.7
Complainant then presents several reasons for why the AJ erred in issuing summary judgment in favor of the Agency. First, there exists a genuine issue of material fact over whether the National Administrator exceeded his authority when he reassigned Complainant to a new facility before she finished the training program. The parties reference different "mobility requirements" and disagree over which provision controls. She argued that a hearing must be held to resolve this dispute.
Second, a hearing is necessary to determine the credibility and believability of the National Administrator's reasons for reassigning Complainant and "revising" the training program. As stated in her opposition to summary judgment, Complainant argues that there was no legitimate, non-retaliatory reason for the National Administrator to have reassigned her to a new facility in September 2007. The National Administrator admitted that Complainant would have to start over as a new trainee and would not get credit for whatever practical on-the-job training she received while the training program was revised. He also appeared to acknowledge that reassigning her was unusual.
Third, the AJ erred in determining that Complainant failed to establish a prima facie case of reprisal due to a lack of a close temporal nexus between her EEO activity and the adverse actions. The AJ should not have considered the temporal gap to be between the time she complained and testified about the sexual harassment (April, June, and October 2006) and the time when the Agency reassigned her and abolished the training program (September and October 2007). Rather, the AJ should have considered the temporal gap to be between the time when her sexual harassment case closed (August 2007) and the time when the Agency denied her training, reassigned her, and abolished the training program (August, September, and October 2007).
The Agency argues that the AJ properly dismissed the denial of training claims because they were untimely raised outside of the 45-day time limitation period for initiating EEO counselor contact. The Agency also contends that the AJ properly issued summary judgment in the Agency's favor.
ANALYSIS AND FINDINGS
Standard of Review
The Commission reviews de novo the AJ's legal and factual conclusions, and the Agency's final order adopting them. See 29 C.F.R. � 1614.405(a) (stating that a "decision on an appeal from an Agency's final action shall be based on a de novo review . . ."); see also Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614, at Chapter 9, � VI.B. (November 9, 1999) (providing that an administrative judge's "decision to issue a decision without a hearing pursuant to [29 C.F.R. � 1614.109(g)] will be reviewed de novo"). This essentially means that we should look at this case with fresh eyes. In other words, we are free to accept (if accurate) or reject (if erroneous) the factual conclusions and legal analysis of the AJ and Agency-including the ultimate fact of whether intentional discrimination occurred, and on the legal issue of whether any federal employment discrimination statute was violated. See id. at Chapter 9, � VI.A. (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 Dismissal of Claims
As a preliminary matter, the Commission first examines whether the AJ erred in dismissing Complainant's reprisal claims regarding denials of training and a refusal to sign her trainee record. The AJ justified dismissing those claims because there was no indication that the Agency had accepted or investigated the claims. We find that Complainant properly raised the denial of training claim in an attachment to her formal complaint, and the Agency accepted it for investigation.
We also find that Complainant timely raised this claim. EEOC regulation 29 C.F.R. � 1614.105(a)(1) requires that complaints of discrimination be brought to the attention of an EEO counselor within 45 days of the date of the matter alleged to be discriminatory or, in the case of a personnel action, within 45 days of the effective date of the action. The Commission has adopted a "reasonable suspicion" standard to determine when the 45-day limitation period is triggered. See Howard v. Dep't of the Navy, EEOC Request No. 05970852 (February 11, 1999). Thus, the time limitation is not triggered until a complainant reasonably suspects discrimination, but before all the facts that support a charge of discrimination have become apparent.
Here, we find that Complainant could reasonably suspect discrimination only after she was informed in September and October 2007 that she would be reassigned and have to start over in a new training program. When she received the most recent email denying her training request on August 1, 2007, the record indicates that Complainant still believed that she was part of a structured, viable training program, and that a message to disregard the previous status emails due to a "new system" did not necessarily constitute a denial of training. It was reasonable for Complainant to assume that the "new system" pertained to a new, automated system for assigning and notifying trainees of their enrollment in courses. And once the Agency finished implementing the "new system," Complainant would shortly be able to attend the specialized training courses. Therefore, we find that she timely raised the August 1, 2007 denial of training to the EEO counselor on October 31, 2007.8
As for the claim about the Agency refusing to sign Complainant's trainee record on October 23, 2007, we find that Complainant properly raised and clarified this claim to the Agency.
* In her formal complaint, Complainant listed October 23, 2007 as one of the dates she experienced discrimination.
* Then an EEO specialist emailed Complainant, asking her to clarify the October 23, 2007 event.
* Complainant replied by email, describing the Agency's refusal to sign off on her trainee record.
* Finally, the Agency issued an acceptance letter of that claim and investigated it.
Because the documentary evidence in the record shows that Complainant properly raised and clarified this claim to the Agency, we find that the AJ erred in dismissing the claim on the grounds that the Agency had neither accepted nor investigated the claims.
Appropriateness of AJ's Summary Judgment Decision
We must determine whether it was appropriate for the AJ to have issued a decision without a hearing on this record. An AJ may issue a decision without a hearing when there is no genuine issue of material fact. 29 C.F.R. � 1614.109(g). This regulation is patterned after the summary judgment procedure set forth in Rule 56 of the Federal Rules of Civil Procedure. The U.S. Supreme Court has held that summary judgment is appropriate where a court determines that, given the substantive legal and evidentiary standards that apply to the case, there exists no genuine issue of material fact. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986). In ruling on a motion for summary judgment, a court's function is not to weigh the evidence but rather to determine whether there are genuine issues for trial. Id. at 249. The evidence of the non-moving party must be believed at the summary judgment stage and all justifiable inferences must be drawn in the non-moving party's favor. Id. at 255. An issue of fact is "genuine" if the evidence is such that a reasonable fact finder could find in favor of the non-moving party. Celotex v. Catrett, 477 U.S. 317, 322-23 (1986); Oliver v. Digital Equip. Corp., 846 F.2d 103, 105 (1st Cir. 1988). A fact is "material" if it has the potential to affect the outcome of the case.
If a case can only be resolved by weighing conflicting evidence, issuing a decision without holding a hearing is not appropriate. In the context of an administrative proceeding, an AJ may properly consider issuing a decision without holding a hearing only upon a determination that the record has been adequately developed for summary disposition. See Petty v. Dep't of Def., EEOC Appeal No. 01A24206 (July 11, 2003). Finally, an AJ should not rule in favor of one party without holding a hearing unless he or she ensures that the party opposing the ruling is given (1) ample notice of the proposal to issue a decision without a hearing, (2) a comprehensive statement of the allegedly undisputed material facts, (3) the opportunity to respond to such a statement, and (4) the chance to engage in discovery before responding, if necessary. According to the Supreme Court, Rule 56 itself precludes summary judgment "where the [party opposing summary judgment] has not had the opportunity to discover information that is essential to his opposition." Anderson, 477 U.S. at 250. In the hearing context, this means that the administrative judge must enable the parties to engage in the amount of discovery necessary to properly respond to any motion for a decision without a hearing. Cf. 29 C.F.R. � 1614.109(g)(2) (suggesting that an administrative judge could order discovery, if necessary, after receiving an opposition to a motion for a decision without a hearing).
Genuine Issues of Material Fact
Upon review, the Commission finds that summary judgment was not appropriate because genuine issues of material fact exist. First, the parties dispute whether the Agency had the authority to reassign a trainee to another facility before that trainee finished the training program. Complainant avers that there is no such authority; rather, the Agency can only reassign a trainee after training is completed. The Agency disagrees, asserting that it can reassign a trainee at any time during the training process.
The extent of the Agency's authority to reassign trainees is material because it has the potential to affect the outcome of the case by raising an inference of a retaliatory motive. One way to support an inference of a retaliatory motive is to show that the Agency deviated from an applicable personnel policy, or a past practice. Here, establishing that the National Administrator did not have the authority to reassign Complainant at that particular time in her training would show that he deviated from an applicable personnel policy or past practice, thereby supporting an inference of a retaliatory motive.9
The Commission notes that when a party submits an affidavit and credibility is at issue, "there is a need for strident cross-examination and summary judgment on such evidence is improper." Pedersen v. Dep't of Justice, EEOC Request No. 05940339 (February 24, 1995). We find that the credibility of the National Administrator is at issue here. He explained that he reassigned Complainant so that she could obtain more on-the-job training and to help get her fully qualified as a safety manager. But he also admitted that Complainant would have to reenroll as a new trainee and essentially start over in the revamped training program, and that it could take her another two or three years to finish. Moreover, he acknowledged that Complainant would not be credited for the on-the-job learning she received at the new facility in the overhauled training program. We find a hearing to be necessary to gauge the credibility of the National Administrator with respect to his explanation for reassigning Complainant to another facility before he had finished revamping the training program.
CONCLUSION
Based on a thorough review of the record and the contentions on appeal, including those not specifically addressed herein, the Commission VACATES the Agency's final order and REMANDS Complainant's claims10 for a hearing in accordance with this decision and the Order below.
ORDER
The Agency is directed to submit a copy of the complaint file to the Hearings Unit of the EEOC Chicago District Office within fifteen (15) calendar days of the date this decision becomes final. The Agency shall provide written notification to the Compliance Officer at the address set forth below that the complaint file has been transmitted to the Hearings Unit. Thereafter, the Administrative Judge shall hold a hearing and issue a decision on the complaint in accordance with 29 C.F.R. � 1614.109 and the Agency shall issue a final action in accordance with 29 C.F.R. � 1614.110.
IMPLEMENTATION OF THE COMMISSION'S DECISION (K0610)
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 (M0610)
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), at 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 (R0610)
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 (Z0610)
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
___7/17/12_______________
Date
1 During her time in the program, Complainant had four different safety managers.
2 During her almost two years in the training program, Complainant was only able to take two of nine specialized training courses, and she completed those courses when she had no safety manager to supervise her training. Federal Bureau of Prisons Employee Transcript (Oct. 14, 2007).
3 Position Description 7.
4 "She's still learning down [in Butner], on-the-job learning, but no real official learning . . . . Once that [training] program is resurrected, and it's functioning the way it should be, she will be re-enrolled and given every training opportunity just as if she's a brand-new trainee." National Administrator Aff. 9.
5 We note that the Regional Administrator opined in his affidavit that the mobility statement signals a trainee's willingness to move at the end of the trainee program. Regional Administrator aff. 6.
6 The National Administrator averred that the Agency had never before reassigned a trainee to "continue her training program." National Administrator aff. 6. A Regional Administrator averred that he had never seen a reassigned trainee remain as a trainee with a mobility requirement still in effect. Regional Administrator aff. 7.
7 On page 6 of her brief on appeal, Complainant contends that the denial of training formed "a pattern of harassment and a reasonable person would not have suspected discrimination just because her training requests were denied." Because it appears that Complainant never raised harassment as a basis in her formal complaint, nor attempted to amend the complaint to include a claim of harassment before requesting a hearing, we decline to consider a harassment claim here.
8 As for the earlier incidents where the Agency denied training to Complainant, we find that they constitute, at minimum, relevant background information that properly supports Complainant's claim that management retaliated against her by failing to advance her through the Agency's 18-month training program.
All relevant evidence offered in support of a timely raised legal claim must be considered, at least as background, even if the evidence involves incidents that occurred outside the 45-day time limit. Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614 (EEO-MD-110), at 5-8 (Nov. 9, 1999). Because Complainant timely raised the August 1, 2007 claim, the earlier incidents in which the Agency allegedly denied Complainant's requests for training must be considered, at minimum, as background information for the timely claim.
9 We note that a reasonable fact finder could determine that Complainant in this case established a prima facie case of reprisal discrimination. It is undisputed that Complainant satisfied the first three elements of a prima facie case of reprisal. She engaged in prior protected activity when she reported that a former supervisor had sexually harassed her at an Agency training event. Agency officials were aware that Complainant had claimed that she had been sexually harassed. Both the National Administrator for the training program and Complainant's future supervisor had been at the training event, and were interviewed by investigators. The Regional Administrator also averred that he was aware of the sexual harassment investigation. It is also undisputed that Complainant was subjected to adverse treatment by the Agency in that she did not complete the 18-month training program before the National Administrator decided to reassign Complainant to another facility and suspend the training program for possible modification and change.
Viewing the evidence in the light most favorable to Complainant, a reasonable fact finder could then find that there is a temporal nexus where two of the responsible Agency officials in the present reprisal case were interviewed in the sexual harassment investigation; and the adverse actions that they took against Complainant occurred either contemporaneously with the sexual harassment case or shortly after the investigation closed on August 7, 2007.
10 The remanded claims are discrimination on the basis reprisal when the Agency failed to advance her through its eighteen month training program by denying her training, refusing to sign off on her trainee record, reassigning her to another facility before she completed training, and abolishing the training program.
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0120102898
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
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0120102898