0120083538
06-11-2010
Leemanuel Wakefield, Complainant, v. Eric K. Shinseki, Secretary, Department of Veterans Affairs, Agency.
Leemanuel Wakefield,
Complainant,
v.
Eric K. Shinseki,
Secretary,
Department of Veterans Affairs,
Agency.
Appeal No. 0120083538
Hearing No. 440-2006-00186X
Agency Nos.200J-0537-2005-103405
200J-0537-2007-100015
200J-0537-2007-1003391
DECISION
On August 12, 2008, complainant filed an appeal from the agency's July
16, 2008 final order concerning his equal employment opportunity (EEO)
complaint claiming unlawful 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 appeal is accepted pursuant to 29 C.F.R. �
1614.405(a). For the following reasons, the Commission AFFIRMS the
agency's final order.
ISSUE PRESENTED
The issue presented is whether the AJ's finding that complainant failed to
prove he was discriminated against as alleged is supported by substantial
evidence in the record.
BACKGROUND
At the time of the events giving rise to this complaint, complainant
was employed as the Maintenance and Operations Supervisor, WS-13,
at the agency's Jesse Brown Medical Center in Chicago, Illinois.
On November 28, 2005, complainant filed a formal complaint, Agency
No. 200J-0537-2005-103405 (Complaint 1). At the conclusion of the
investigation, complainant requested a hearing before an AJ. On October
23, 2006, the AJ assigned to the case issued an order reversing the
agency's dismissal of the certain claims and remanded the issues for an
investigation. Complainant requested that his November 28, 2005 complaint
be consolidated with a complaint he filed on October 29, 2006 (Agency
No. 200J-0537-2007-100015) (Complaint 2). The agency issued a Revised
Notice of Acceptance on December 16, 2006, reassigning both Complaint
1 and Complaint 2 as Agency No. 200J-0537-2007-100339 (Complaint 3).
On December 20, 2006, the same AJ issued an order to amend the complaint
with additional claims and remanded them for an investigation.
Complainant's consolidated complaints alleged that the agency subjected
him to a hostile work environment and disparate treatment on the basis
of reprisal (prior protected EEO activity under Title VII) when:
1. On July 7, 2005, he was threatened and insulted by the Director of the
Wakefield facility (DW) and learned that incomplete information in the
official position description was used to justify the downgrade position
of Maintenance Operation Supervisor, WS-13, prior to complainant's
assumption of the position, while another employee occupying the same
position was allowed to remain at the WS-14 grade until terminated;
2. On August 2, 2005, he was verbally harassed and abused by the Chief
Engineer (CE);
3. On October 28, 2005, he was issued a false performance evaluation
with an overall rating of "minimally successful";
4. He was assigned additional duties for a period of 90 days and these
duties have become a permanent part of his evaluated performance;
5. He applied but was not selected for the position of Maintenance and
Operation Supervisor, WS-4701-15, posted under Vacancy Announcement
No. 04-30H;
6. In June 2006, he applied but was not selected for the position
of Safety Manager, GS-0018-09, posted under Vacancy Announcement
No. 04-237B;
7. On or about October 25, 2006, he was counseled regarding a work
related situation and characterized as a problem employee because of
his EEO complaints;
8. On or about November 15, 2006, he discovered that derogatory
information was placed in his personnel file without his knowledge; and
9. Without being counseled concerning his unacceptable performance,
complainant learned that a request was made to issue an admonishment as
discipline for his unacceptable performance.
Following the investigation, complainant requested a hearing before an
Administrative Judge (AJ) pursuant to 29 C.F.R. � 1614.109. It appears
that, during the course of the hearing process, complainant filed another
complaint2 alleging that, based on his prior EEO activity, the agency
discriminated against him when:
10. On February 1 and 2, 2007, and on March 5 and 6, 2007, his requests
to be granted administrative leave or annual leave for the purpose of
attending to his EEO complaint were denied.
In an order dated May 4, 2007, the AJ found that "complainant has appealed
the Agency's denial of granting official time to allow complainant time to
prepare for the instant complaint. Although the dismissal of the complaint
may be found to be improper, issues of the use of official time that
arise during the hearing process should be raised with the (AJ) and not
by filing a complaint or seeking to amend a current complaint." AJ May
4, 2007 Order. The AJ permitted complainant to provide information on
these allegations as background evidence of the hostile work environment
claim before the AJ. Id. A hearing was held on August 16, and December
18, 2007.
AJ Decision
The AJ issued an amended decision on July 7, 2008.3 In his amended
decision, the AJ decided that claims 1 and 4 should be analyzed
together, stating that the claims are inextricably linked. AJ's Amended
Decision at FN2. The AJ also found that claim 5 was withdrawn during
the hearing. Id. The AJ noted that claim 8 "was determined to be the
result of complainant's confusion over documents received in discovery.
There was no evidence that complainant's official personnel file contained
any derogatory information." Id. Further, the AJ dismissed claim 9
as a potential proposed action. Id. The AJ found that 'there is no
evidence that any discipline for performance or conduct was ever issued
to complainant."
The AJ addressed the remaining claims, 1, 2, 3, 4, 6, 7, and 10, on
their merits. We note that on appeal, complainant explicitly requested
that the Commission review only claims 1, 2, 3, and 6. Complainant's
Brief at 7-10. The Commission has the discretion to only review those
issues specifically raised on appeal. Equal Employment Opportunity
Management Directive for 29 C.F.R. Part 1614 (MD-110), Ch. 9, Sec. IV(A)
at p. 9-10 (November 9, 1999). Accordingly, we note, without analyzing,
that with regard to claims 4 and 7, the AJ found that complainant failed
to prove he was retaliated against or discriminated against as alleged.
With regard to claim 10, the AJ found that the agency per se violated
Title VII when it failed to grant complainant reasonable official time
in order to work on his EEO matters.4 Id. at 9.
With regard to the remaining claims, the AJ found that complainant
established a prima facie case of reprisal. Id. at 8.
Claim 1
With regard to claim 1, the AJ found that after the consolidation of two
of the agency's Chicago facilities, the agency discovered discrepancies
among position grades for employees performing similar duties at each
facility. Id. at 5. Complainant requested an audit of his position
description and job duties, believing that he was performing duties at the
WS-14 level rather than the WS-13 level. Id. at 5-6. The result of the
audit determined that complainant's position was correctly graded as the
WS-13 level, but that the comparable position at the other facility was
incorrectly graded as WS-14. Id. at 6. On June 3, 2005, complainant
sent an email to the Director of the Westside facility (DW) to request
a meeting to discuss the agency's failure to respond to his requests
concerning his position description and the results of the audit. Id.
On June 23, 2005, DW and complainant met. Id. During the course of
the meeting complainant stated that he did not believe his position was
necessary. Id. In response, DW told complainant about the "unfunded
list" and stated that his position could be reposted to that list,
but was not threatening him with the loss of his job. Id.
The AJ found that the agency articulated legitimate nondiscriminatory
reasons for its action. Id. at 8. Specifically, the AJ found that DW
did not threaten complainant with the loss of his job. Id. Further,
the AJ found that nothing supports complainant's contentions that he was
entitled to the WS-14 grade, especially after an audit determined that
his position did not require a reclassification at a higher grade. Id.
The AJ noted that "the evidence shows that additional duties performed
by complainant were not at a significantly higer level to warrant or
justify a reclassification of his position to WS-14 level." Id.
Claim 2
The AJ also found that, with regard to claim 2, complainant alleged that
as a result of the meeting with DW, CE verbally assaulted him in a meeting
on August 2, 2005. Id. at 6. The AJ found that, during a regularly
scheduled staff meeting, CE expressed frustration at the negative
results of a survey and inspection of the Engineering division. Id.
When complainant failed to take responsibility for his areas, CE raised
his voice while discussing the matter with complainant. Id.
The AJ found that the record supports that CE "screamed" at complainant
during the meeting on August 2, 2005. Id. at 9. The AJ further noted
that "a contributing factor for [CE's] outburst was complainant's
continued EEO participation concerning his position description and
job responsibilities." Id. However, the AJ found that, because the
agency provided legitimate, nondiscriminatory reasons for all its other
actions, the single incident was not sufficient severe or pervasive to
render complainant's work environment hostile. Id.
Claim 3
With regard to claim 3, the AJ found that the performance evaluation
issued on October 28, 2005 was conducted by another supervisor (S1) who
retired from his position soon after issuing the evaluation. Id. at
7. The evaluation gave complainant an overall rating of "minimally
successful" after each of complainant's individual elements was rated
"fully successful." Id. The AJ found that the evidence revealed that
complainant's performance rating was "improper." Id. at 9. However,
complainant failed to demonstrate that he suffered any adverse impact
because of the improper performance rating. Id. Further, the AJ found
that the agency had a legitimate, nondiscriminatory reason for the 90-day
delay in reissuing complainant's performance rating; namely that the
supervisor replacing S1 (S2) could not issue a performance rating until
he had supervised complainant for at least 90 days. Id.
Claim 6
With regard to claim 6, the AJ found that, on or about December 2004,
complainant was not selected for the position of Safety Manager, GS-12,
Vacancy Announcement 04-64W. Complainant alleged that his non-selection
was based on race. Id. The AJ found that CE testified that although
complainant was rated by a selection panel as "highly recommended," he
chose not to offer the job to complainant due to "a bad recommendation."
Id. Instead, CE offered the position to a candidate who was not rated
as highly as complainant, "because of his education and training, his
background that he had in safety, and the fact that he had a degree in
fire and safety, whereas complainant did not." Id. The AJ found that
the agency articulated a legitimate, nondiscriminatory reason for its
actions, which complainant failed to rebut. Id.
Remedies
Because the AJ found the agency per se retaliated against complainant with
regard to claim 10, the AJ determined that complainant was entitled to
compensatory damages and remedies, including attorney's fees. The AJ
found that complainant failed to provide any evidence of pecuniary
or non-pecuniary damages during the hearing. AJ's Decision at 11.
Accordingly, no award of compensatory damages was made. The AJ ordered
the agency to pay reasonable attorney's fees pursuant to 29 C.F.R. �
1614.501(e).
The agency issued a final decision on July 15, 2008 on attorney's fees.
The agency determined that complainant was entitled to attorney's fees
at the rate of $ 175.00 per hour for 39.75 hours, the amount of time
the attorney spent on claim 10. Final Decision on Attorney's Fees at 5.
The agency awarded complainant a total of $6,956.25 in attorney's fees.
Id.
CONTENTIONS ON APPEAL
In complainant's statements on appeal, complainant explicitly requested
that the Commission only review claims 1, 2, 3, and 6. Complainant's
Brief at 7-10. The Commission has the discretion to only review those
issues specifically raised on appeal. Equal Employment Opportunity
Management Directive for 29 C.F.R. Part 1614 (MD-110), Ch. 9, Sec. IV(A)
at p. 9-10 (November 9, 1999). Accordingly, in the instant case, we
exercise our discretion to review only claims 1, 2, 3 and 6. In response,
the agency asks that we affirm the AJ's final decision in its entirety,
including the AJ's finding of retaliation with regard to claim 10.
With regard to claim 10, we note that neither the agency nor complainant
contest the AJ's finding of retaliation. Additionally, neither party
appealed the remedies awarded by the AJ. Accordingly, we decline to
address the merits of claim 10 and the remedies awarded.
ANALYSIS AND FINDINGS
Standard of Review
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). 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).
Disparate Treatment
To prevail in a disparate treatment claim such as these, complainant
must satisfy the three-part evidentiary scheme fashioned by the
Supreme Court in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973).
He must generally establish a prima facie case by demonstrating that
he 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). The prima facie inquiry may be
dispensed with in this case, however, since the agency has articulated
legitimate and nondiscriminatory reasons for its conduct. See United
States Postal Service Board of Governors v. Aikens, 460 U.S. 711,
713-17 (1983); Holley v. Department of Veterans Affairs, EEOC Request
No. 05950842 (November 13, 1997). To ultimately prevail, complainant must
prove, by a preponderance of the evidence, that the agency's explanation
is a pretext for discrimination. Reeves v. Sanderson Plumbing Products,
Inc., 530 U.S. 133, 143 (2000); St. Mary's Honor Center v. Hicks, 509
U.S. 502, 519 (1993); Texas Department of Community Affairs v. Burdine,
450 U.S. 248, 256 (1981); Holley v. Department of Veterans Affairs,
EEOC Request No. 05950842 (November 13, 1997); Pavelka v. Department of
the Navy, EEOC Request No. 05950351 (December 14, 1995).
Assuming arguendo that complainant has established a prima facie case
of retaliation, we find that the agency has articulated legitimate,
nondiscriminatory reasons for its actions with regard to claims 1, 2,
3, and 6. Further, we find that complainant failed to demonstrate
that the agency's proffered reasons were a pretext for discrimination
or retaliation.
Claim 1
With regard to claim 1, we find that the AJ's finding that the agency
articulated a legitimate nondiscriminatory reason for its actions is
supported by substantial evidence in the record. The record reveals
that DW testified that there was no indication that CE had done anything
to slow the process of reviewing complainant's position description.
Hearing Transcript (HT) at 647.
Turning to complainant's burden to prove that the agency's proffered
reasons were a pretext for discrimination, we find that complainant failed
to offer any evidence to corroborate his position that DW threatened or
insulted complainant during the meeting. Although complainant argues
on appeal that DW had a duty to investigate complainant's concerns,
complainant has failed to show that DW failed to do so due to retaliatory
or discriminatory animus. Further, we note that complainant appears
to argue on appeal that DW and CE should have addressed complainant's
concerns about his position grade but failed to do so. We note, however,
that complainant's claim in this case is that he was insulted by DW and
that he learned that the failure to upgrade his position was based on
"incomplete evidence." Complainant did not allege the failure to upgrade
his position or DW's failure to investigate his concerns as independent
claims. Accordingly, we decline to address the merits of those claims.
We find that the AJ's finding that complainant failed to prove he was
retaliated against or discriminated against is supported by substantial
evidence in the record.
Claim 3
With regard to claim 3, we note that the record is devoid of any testimony
from S1, who had left the agency at the time of this complaint. However,
CE provided affidavit testimony stating that S1 felt that complainant's
performance was lacking and needed improvement. CE Affidavit Testimony
at 7-10. Complainant argues on appeal that the agency violated its own
policy as articulated in the Performance Management Systems Handbook.
Complainant's Appeal Brief at 9. We find, however, that this alone is not
sufficient to establish that the agency was motivated by discriminatory
or retaliatory motives for rating complainant as "minimally successful."
Further, complainant has not identified any other evidence to support
his contentions that the agency bore unlawful animus when he was rated
as "minimally successful." Accordingly, we find the AJ's finding
that complainant failed to establish that the agency's actions were
discriminatory or retaliatory to be supported by sufficient evidence in
the record.
Claim 6
With regard to claim 6, the nonselection, complainant argues on appeal
that CE offered conflicting testimony and did not credibly testify as to
the interviews he conducted and how he chose the selecteee. We note,
however, that complainant failed to offer any evidence to support
his contentions. In nonselection cases, a complainant can establish
pretext by showing that his qualifications are "plainly superior" to
those of selectee. Bauer v. Bailar, 647 F.2d 1037, 1048 (10th Cir. 1981).
We find that complainant has failed to proffer any evidence to demonstrate
that his qualifications were plainly superior to those of the selectee.
Accordingly, we find that the AJ's determination that complainant failed
to establish he was discriminated against as he alleged is supported by
substantial evidence in the record.
Harassment and Claim 2
Because we find that the agency articulated legitimate, nondiscriminatory
reasons for claims 1,3, and 6, we analyze complainant's harassment
claim comprised of only claim 2.5 With regard to claim 2, verbal
abuse by CE, the record supports the AJ's finding that claim 2 was not
sufficiently severe or pervasive to render his work environment hostile.
The Commission has stated that in retaliation cases, adverse actions
need not qualify as "ultimate employment actions" or materially affect
the terms and conditions of employment to constitute retaliation. EEOC
Compliance Manual Section 8: Retaliation, No. 915.003, at 8-15 (May 20,
1998); see Burlington N. and Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006)
(finding that the anti-retaliation provision protects individuals from a
retaliatory action that a reasonable person would have found "materially
adverse," which in the retaliation context means that the action might
have deterred a reasonable person from opposing discrimination or
participating in the EEO process).
In any case involving a claim of harassment, the challenged conduct must
be judged by looking at all of the circumstances including the frequency
of the conduct; its severity, whether it is physically threatening or
humiliating, or a mere offensive uttering; and whether it unreasonably
interferes with an employee's work performance. Faragher v. Boca
Raton, 524 U.S. 775, 787-88. We find that this single incident is not
sufficiently severe to render complainant's work environment hostile.
Accordingly, we find that the AJ appropriately determined that complainant
failed to establish that he was subjected to a hostile work environment.
CONCLUSION
After a review of the record in its entirety, including consideration
of all statements submitted on appeal, it is the decision of the Equal
Employment Opportunity Commission to AFFIRM the final agency order.
The agency is required to comply with the Order of the Commission,
below.
ORDER
Within sixty (60) days of the date this decision becomes final, and to
the extent it has not already done so, the agency is ordered to pay to
complainant $6,956.25 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 Jesse Brown Medical Center, in
Chicago, Illinois, 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.
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
June 11, 2010
Date
1 We note that the record also refers to an Agency
No. 200J-0537-2007-100334. It appears from the record that the correct
complaint number is Agency No. 200J-0537-2007-100339. Agency's December
16, 2006 Revised Notice of Acceptance.
2 Neither the complaint nor the complaint number are included in the
record.
3 The AJ stated that "this decision is amended to correct Section
III-Findings." AJ's Amended Decision at 1.
4 The agency did not contest the AJ's finding with regard to claim 10.
5 Because complainant failed to establish that such actions either
occurred as alleged or were taken on the basis of his membership
in a protected class (because he failed to refute the legitimate,
nondiscriminatory reasons proffered by the agency), complainant failed to
establish that he was subjected to prohibited harassment. See Bennett
v. Department of the Navy, EEOC Request No. 05980746 (September 19,
2000); Applewhite v. Equal Employment Opportunity Commission, EEOC Appeal
No. 01994939 (April 6, 2000); Wolf v. United States Postal Service, EEOC
Appeal No. 01961559 (July 23, 1998); EEOC Guidance on Investigating,
Analyzing Retaliation Claims, No. 915.003 (May 20, 1998).
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2
***Appeal number TX***
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
2
0120083538