0720080050
12-08-2009
Kathryn L. Snyder, Complainant, v. John E. Potter, Postmaster General, United States Postal Service (Eastern Region), Agency.
Kathryn L. Snyder,
Complainant,
v.
John E. Potter,
Postmaster General,
United States Postal Service
(Eastern Region),
Agency.
Appeal No. 0720080050
Hearing No. 530-2006-00266X
Agency No. 1C-195-0006-06
DECISION
Following its June 23, 2008 final order, the agency filed a timely
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 a violation of Section
501 of the Rehabilitation Act of 1973 (Rehabilitation Act), as amended,
29 U.S.C. � 791 et seq. The appeal is deemed timely and is accepted
pursuant to 29 C.F.R. � 1614.405(a). For the following reasons, the
Commission REVERSES the agency's final order.
ISSUES PRESENTED
1. Whether the AJ erred when he found that the agency violated the
Rehabilitation Act when the agency ordered complainant to undergo a
fitness for duty examination (FFDE), although this issue was not an
accepted issue during the investigation.
2. Whether substantial evidence supports the AJ's conclusion that the
agency violated the Rehabilitation Act when it ordered complainant to
undergo a FFDE.
BACKGROUND
At the time of events giving rise to this complaint, complainant worked
as a mail processing clerk at the agency's Southeastern, Pennsylvania
Processing and Distribution Center. Because of medical restrictions,
complainant was assigned to work in the Nixie Section of the facility,
where her primary duty was to place address labels on pieces of mail
that had been repaired so that they could be resent to customers.
In mid October 2005, complainant sent letters to the Senior Plant Manager
(Plant Manager) and the Postmaster General in which she alleged that
Nixie personnel discarded deliverable mail in a Gaylord box waste basket.
In the letter to the Plant Manager, complainant further alleged that a
mailhandler (C) was an "angry old man" who was unpleasant toward her and
discarded deliverable magazines into the Gaylord box. Affidavit D, p. 37.
In the letter to the Postmaster, complainant also alleged that she had
been reprimanded by management in a meeting for telling C that she would
work his flats duty and stated that she was "plagued" with gynecological
symptoms that "strike as a form of discipline" during meetings with
management. Affidavit D, p. 35. Complainant further alleged that C
felt that he could perform shoddy work and discard mail because he had
43 yeas of service with the agency and is a veteran, and C protested
when complainant tried to retrieve good mail from the waste basket.
Additionally, complainant stated that she wished that someone would
check into C's "nastiness" toward her and asked if C could retire.
After receiving copies of the letters, the Plant Manager ordered the
agency to conduct an investigation regarding complainant's allegations.
In a memorandum dated November 1, 2005, the Manager of Distribution
Operations concluded that the discarded mail in question was actually of
"no obvious value" or undeliverable bulk business mail. The memorandum
further stated that complainant's supervisor reported that complainant
went through the waste basket on a daily basis although she had been
instructed not to do so.
On November 2, 2005, the Manager of Distribution Operations requested
and the Plant Manager ordered complainant to undergo a FFDE to ascertain
whether she was able to perform her job duties. On November 17, 2005,
the agency informed complainant that she must undergo a FFDE on November
25, 2005. On November 25, 2005, complainant underwent a FFDE, which
was conducted by a physician (M.D.).
On December 1, 2005, M.D. submitted a report to the agency concerning his
evaluation of complainant. In the report, M.D. stated that complainant
displayed an inability to stop filtering mail that was discarded in the
Gaylord box, although management had repeatedly warned her not to engage
in this behavior. M.D. further stated that complainant needed psychiatric
treatment because of her failure to follow management's instructions
regarding discarded mail in the Gaylord box and inability to control her
behavior. Based on his two and a half hour examination of complainant,
M.D. determined that she was unfit for duty and diagnosed her as having
a delusional disorder of a mixed type and depressive disorder. "The
reason that I find her not fit for duty without treatment is that she
continues to disrupt normal activities of others where she works, partly
due to her frequent complaints based on her abnormal mental processes,"
M.D. concluded. Agency Hearing Exhibit 1.
The agency received M.D.'s report on December 9, 2005, and the agency's
Associated Area Medical Director (D) reviewed the report. On December 9,
2005, D agreed with M.D.'s conclusion that complainant was unfit for duty
and sent a memorandum to the Occupational Health Nurse Coordinator (Nurse)
in which he stated that he had reviewed M.D.'s report and outlined the
actions complainant had to take in order to return to work. On December
20, 2005, the Nurse sent a letter to complainant in which she informed
complainant that the agency had received M.D.'s report and D agreed that
complainant was not fit for duty. The letter also stated that in order to
return to work, complainant must initiate treatment with a psychiatrist,
and once her psychiatrist believed that complainant was fit for duty,
the psychiatrist must submit a written recommendation to the agency's
medical unit that would be reviewed by D.
On January 26, 2006, complainant began treatment with a private
psychiatrist. On March 24, 2006, complainant's psychiatrist sent a
medical report to the agency in which he recommended that complainant be
allowed to return to work. Complainant returned to work on April 17,
2006. On March 23, 2006, complainant filed an EEO complaint alleging
that she was discriminated against on the basis of disability when it
placed her in off-work status from December 19, 2005 until March 2006.
AJ's Decision
At the conclusion of the investigation, complainant was provided 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, and the AJ held a hearing on January 9 and 10,
2007. In a decision dated May 9, 2008, the AJ found that the agency
violated the Rehabilitation Act when it ordered complainant to submit to
a psychiatric FFDE, which led to placing her in a non-pay/off-duty status
from December 19, 2005 until April 17, 2006. The AJ reasoned that because
the Plant Manager and other managers agreed that complainant performed the
essential functions of her job and did not show that she posed a direct
threat to herself or others in the workplace, the agency did not have
justification to order complainant to undergo a FFDE. In so finding,
the AJ noted that the Plant Manager was concerned that complainant
engaged in irrational behavior because she was preoccupied with looking
through the Gaylord box for deliverable mail, treated a co-worker in a
discourteous manner, and claimed that managers caused her to experience
gynecological problems; however, the AJ rejected the agency's contention
that this behavior justified ordering complainant to undergo a FFDE.
The AJ further determined that complainant's behavior should have
been dealt with administratively through proposed discipline, and that
there was no competent evidence presented that disciplining complainant
would not have stopped her objectionable behavior. The AJ noted that
when complainant was disciplined in the past, she ceased engaging in
objectionable behavior.
Next, the AJ examined complainant's claim that she was subjected to
disability discrimination when the agency placed her in an off-duty,
non-pay status from December 19, 2005 until April 17, 2006. With respect
to this claim, the AJ found that although complainant was not an
individual with a disability, the agency regarded her as being disabled
because it thought that she was not capable of performing the essential
functions of her position. "Because of that erroneous perception, the
complainant was placed in a non-work status and required to submit to
a FFDE, then complete prescribed treatment prior to returning to work.
There being direct evidence of unlawful discriminatory motive, it is
unnecessary to engage in a shifting burden analysis," the AJ concluded.
AJ's Decision, p. 15.
The AJ ordered the agency to provide the following remedies: conduct
training on disability discrimination for all managers, supervisors,
and human resource specialists at the Southern, Pennsylvania Processing
and Distribution Center within 60 days of his decision; post copies of
a discrimination notice in the postal facility; pay complainant back
pay for the period she was in a non-work status; credit complainant's
annual and sick leave balances for the leave she used from December 19,
2005 to April 17, 2006; credit complainant's leave balances for any
leave she would have accumulated from December 19, 2005 to April 17,
2006; and, pay complainant $31,918.75 in attorney's fees and costs.
In a final order dated June 23, 2008, the agency rejected the AJ's
finding that it violated the Rehabilitation Act. Simultaneously, the
agency appealed the AJ's decision to the Commission.
CONTENTIONS ON APPEAL
On appeal, the agency argues that the AJ erred when he found that it
violated the Rehabilitation Act when it ordered complainant to undergo
an FFDE on November 25, 2005, because this issue was not the subject
of the EEO investigation and the AJ did not identify it as an accepted
issue in a prehearing memorandum dated December 12, 2006. The agency
contends that the prehearing memorandum stated that the only issue for
hearing was whether the agency discriminated against complainant on the
basis of "perceived mental disability" when it placed her in a forced
leave or non-work status from December 19, 2005 until March 27, 2006.
The agency further argues that the FFDE issue should have been dismissed
as untimely because complainant received notice on November 17, 2005
that she must undergo a FFDE, but she did not initiate EEO counselor
until January 6, 2006.
The agency also argues that the AJ erred when he found that it violated
the Rehabilitation Act when it placed complainant in a non-pay, off-duty
status from December 19, 2005 until March 27, 2006. Regarding the
non-pay status claim, the agency argues that the AJ improperly found
that complainant was regarded as disabled by the agency; improperly
found that there was direct evidence of disability discrimination;
and, failed to analyze this claim under the proper McDonnell Douglas
v. Green, 411 U.S. 792 (1973), tripartite analysis. The agency further
argues that under a McDonnell Douglas analysis, it provided legitimate,
non-discriminatory reasons for placing complainant in non-pay, off-duty
status that were not proven to be pretext for unlawful discrimination
by complainant.
Complainant contends that the Commission should affirm the AJ's decision.
Complainant contends that the FFDE is an important background issue that
is related to her placement in non-pay, off-duty status. With respect to
the timeliness of the FFDE issue, complainant contends that she timely
initiated counseling after the agency informed her that she was deemed
unfit for duty and was placed on forced leave. Complainant further
contends that substantial evidence supports the AJ's conclusion that
the agency discriminated against her on the basis of disability when it
placed her on forced leave status because there was no evidence that
she could not perform the essential functions of her position or that
she was disruptive to the workplace.
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).
As an initial matter, we note that the agency contends that the AJ
improperly addressed the FFDE examination, although the only accepted
issue was whether the agency discriminated against complainant when it
placed her in off-duty status. The record reveals that the accepted
issue for investigation was whether the agency discriminated against
complainant on the basis of disability when it placed her in non-work
status on December 19, 2005. The AJ identified the same matter as the
issue presented for hearing in a prehearing memorandum.
We find that the issue of whether the agency properly required complainant
to undergo a FFDE is inextricably intertwined with the issue of whether
the agency discriminated against complainant when it placed her on
off-duty status. The FFDE is the precipitating event that led to
the agency's conclusion that complainant was not fit for duty, which
culminated in the agency placing complainant on off-duty status. As a
natural outgrowth of the examination of the off-duty issue, witnesses
provided ample hearing testimony regarding the agency's reasons for
sending complainant for a FFDE and determining that she was unfit
for duty. Because of the interrelatedness of the FFDE to complainant's
off-duty status, the agency had adequate notice that its decision to order
complainant to undergo a FFDE was at issue. Consequently, we find that
the agency was not prejudiced when the AJ made a finding of unlawful
medical inquiry/examination under the Rehabilitation Act, because we
are not persuaded that the evidence that was presented at the hearing
by the agency would have been significantly different had the agency
been instructed prior to the hearing that a finding of discrimination
under the Rehabilitation Act could result. See Morrow v. United
States Postal Service, EEOC Appeal No. 0720070058 (November 13, 2009)
(Commission found that it was incumbent upon the AJ not to turn a blind
eye to the evidence in the record that an FFDE was an unlawful inquiry
under the Rehabilitation Act although sex discrimination was the only
identified issue before the hearing).
The agency also contends that the FFDE should also be dismissed on
the basis that it was initiated by untimely EEO counselor contact.
Specifically, the agency argues that because complainant was notified
that she had to undergo a FFDE on November 17, 2005, she should have
contacted an EEO Counselor within 45 days of the notice, instead of
waiting 50 days from the notice to do so. However, EEOC Regulation
29 C.F.R. � 1614.105(a)(1) requires that complaints of discrimination
should be brought to the attention of the Equal Employment Opportunity
Counselor within forty-five (45) days of the personnel action, not the
notice of the action. In this case, the relevant personnel action
occurred on November 25, 2005, when complainant underwent the FFDE.
We find that complainant initiated timely EEO counselor contact for the
FFDE claim because her January 6, 2006 initial EEO counselor contact
was within 45 days of the date of the FFDE.
Thus, we find that the AJ did not abuse his discretion in this case.
In so finding, we note that AJs have broad discretion in the conduct
of hearings. See 29 C.F.R. � 1614.109(e); Equal Employment Opportunity
Management Directive for 29 C.F.R. Part 1614 (EEO- MD-110) at 7-8 to
7-14 (revised November 9, 1999); Bennett v. Department of the Navy,
EEOC Request No. 05980746 (September 19, 2000).
Medical Inquiries and Examinations
Section 501 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. �
791 et seq. places certain limitations on an employer's ability to make
disability-related inquiries or require medical examinations of employees.
The inquiry made be made or the examination ordered only if it is
job-related and consistent with business necessity. See 29 C.F.R. ��
1630.13(b), 14(c). This means that the employer must have a reasonable
belief based on objective evidence that an employee will be unable to
perform the essential functions of her job because of a medical condition.
Objective evidence is reliable information, either directly observed or
provided by a credible third party, that an employee may have or has
a medical condition that will interfere with his ability to perform
essential job functions or will result in direct threat. Id., p. 7.
Where the employer forms such a belief, its disability-related inquiries
and medical examinations are job-related and consistent with business
necessity, if they seek only the information necessary to determine
whether the employee can perform the essential functions or work without
posing a direct threat to self or others. Id. It is the burden of the
employer to show that its disability-related inquiries and requests
for medical examination are job-related and consistent with business
necessity. See Cerge v. United States Department of Homeland Security,
EEOC Appeal No. 0120060363 (October 9, 2007).1
Upon review of the evidence, we agree with the AJ's conclusion that the
record is devoid of any evidence that would support a reasonable belief
that complainant could not perform the essential functions of her job or
posed a direct threat to herself or other employees. The agency claimed
that although complainant was able to perform the essential functions
of her job, it sent her for an FFDE because she displayed "irrational
behavior" when she accused C of improperly discarding mail, had strained
relationships with co-workers, disrupted co-workers, and failed to follow
instructions regarding the monitoring of the waste basket. However,
we agree with the AJ that, while such conduct may warrant discipline,
the agency has not provided any evidence that would lead us to conclude
that the agency had a reasonable belief that complainant posed a direct
threat or could not perform the essential functions of her position.
Likewise, while complainant made the claim that her gynecological
symptoms were exacerbated by interactions with management, it does not
indicate that complainant posed a direct threat or was unable to perform
the essential functions of her position. We note that in Whiting
v. United States Postal Service, Appeal No. 01A14923 (May 8, 2003),
the agency ordered an employee to undergo a FFDE because, according to
the supervisor, that employee "exhibited irrational behavior" when she
rudely interrupted, confronted, and refused to obey the supervisor during
a meeting. The Commission found that the FFDE was improper because while
such conduct was disruptive and argumentative, it was insufficient to
provide the agency with a reasonable belief that the employee posed a
direct threat.
Consequently, we find that the record contains substantial evidence that
supports the AJ's determination that the agency did not have a reasonable
belief that complainant's ability to perform the essential functions of
her job was impaired by a medical condition, or that she posed a direct
threat to herself or other employees. Because we find that the agency
violated the Rehabilitation Act when it ordered her to undergo a FFDE,
we need not address her placement on off-duty status because the relief
for both actions is the same.2
CONCLUSION
Based on a thorough review of the record and the contentions on appeal,
including those not specifically addressed herein, we REVERSE the final
agency order which rejected the AJ's finding that the medical examination
was unlawful under the Rehabilitation Act. The agency shall comply with
the Order below.
ORDER
Within sixty (60) days of this decision becoming final, and to the extent
it has not already done so, the agency is ordered to take the following
remedial actions:
1. Expunge all documentation associated with complainant's November 25,
2005 fitness-for-duty examination from her personnel files, including the
results of the FFDE examination, recommendations, and correspondences.
2. Pay complainant any pay lost for the period she was in non-work status
from December 19, 2005 to April 17, 2006.
3. Credit complainant's annual and sick leave balances for any leave
she took from December 19, 2005 to April 17, 2005.
4. Credit complainant's leave balances for any leave she would have
accumulated from December 19, 2005 to April 17, 2006.
5. Provide a minimum of sixteen (16) hours EEO training, with a minimum of
eight (8) hours on the Rehabilitation Act and managers' responsibilities
under the Act, particularly with respect to appropriate medical inquiries
and examinations, to all managers, supervisors, and human resource
specialists at the Southern, Pennsylvania Processing and Distribution
Center.
6. 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).
7. Pay complainant $31,918.75 in attorney's fees and costs.
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 Southeastern, Pennsylvania
Processing and Distribution Center 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)), 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
____12/08/09______________
Date
1 We note that whether complainant is an individual with a disability
is irrelevant to the issue of whether the agency properly ordered
complainant to undergo FFDEs because the Rehabilitation Act's limitations
regarding disability-related inquiries and medical examinations apply
to all employees. See EEOC Enforcement Guidance on Disability-Related
Inquiries and Medical Examinations of Employees Under the Americans with
Disabilities Act (Enforcement Guidance on Disability-Related Inquiries),
No. 915.002 (July 27, 2000).
2 We further note that we decline to review the relief ordered by
the AJ because neither party contests the AJ's remedies on appeal.
EEOC Management Directive 110, 9-10 (November 9, 1999).
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0720080050
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
11
0720080050