0120100344
12-15-2011
Vincent C. Duncan, Complainant, v. Tom Kilgore, President and Chief Executive Officer, Tennessee Valley Authority, Agency.
Vincent C. Duncan,
Complainant,
v.
Tom Kilgore,
President and Chief Executive Officer,
Tennessee Valley Authority,
Agency.
Appeal No. 0120100344
Agency No. 04202009040
DECISION
On October 29, 2009, Complainant filed an appeal from the Agency’s
September 30, 2009, final decision concerning his 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
REVERSES the Agency’s final decision.
ISSUES PRESENTED
The issues presented are: (1) whether the Agency erred in failing to
accept and investigate Complainant’s retaliatory reassignment claim;
and (2) whether the Agency met its obligation to provide a legitimate,
nondiscriminatory reason for Complainant’s non-selection for a
Maintenance Supervisor position.
BACKGROUND
At the time of events giving rise to this complaint, Complainant worked
as a Maintenance Coordinator at the Agency’s Shawnee Fossil Plant in
Paducah, Kentucky. In May 2008, Complainant applied for the position of
Maintenance Supervisor, advertised under internal vacancy announcement
number 24017. The Maintenance Manager (SO1) and the Outage Manager
(SO2)1 were the management officials involved in the selection process.
The record reflects that the selection process consisted of three
stages and involved a position selection matrix. First, SO1 scored the
candidates on four weighted qualifications: (Q1) experience managing and
supervising maintenance employees in power plant maintenance activities;
(Q2) translation and integration of maintenance goals into work unit
activities; (Q3) leadership skills demonstrated on a leadership assessment
test; and (Q4) education. Second, SO1 and SO2 scored the candidates’
responses to nine weighted interview questions. Third, SO1 ranked the
candidates based on their combined qualification and interview scores.
A weight of 30 was applied to the qualification score and a weight of
70 was applied to the interview score.
Complainant met the minimum qualifications, received an interview,
but was not selected for the position. The position selection matrix
reflects that 12 candidates applied, 9 candidates received an interview,
2 candidates were offered the position but declined, and 2 candidates
(SE1 – Caucasian; SE2 – Caucasian) were selected. SE1 was ranked
third, SE2 was ranked fourth, and Complainant was ranked eighth.
On April 20, 2009, Complainant filed an EEO complaint alleging that the
Agency discriminated against him on the basis of race (African-American)
when, in February 2009, he was not selected for the Maintenance Supervisor
position. Complainant requested the following remedy: “I want to be
made whole, I want to be protected from any retaliation, and I want a
stop to the discriminatory use of temporary positions.”
In his May 8, 2009 affidavit, Complainant alleged that the Agency
discriminated against him on the basis of reprisal for prior protected
EEO activity under Title VII when, in April 2009, he was reassigned to a
different position. Specifically, Complainant stated, “[W]hen I filed
my complaint, I was moved out of my long time job to another position,
two days after they received my complaint.” On May 15, 2009, the
Agency amended Complainant’s non-selection claim to include the basis
of reprisal.2 The Agency, however, failed to amend Complainant’s
complaint to include the reassignment claim.
At the conclusion of the investigation, the Agency provided Complainant
with a copy of the report of investigation and notice of his right to
request a hearing before an EEOC Administrative Judge. In accordance with
Complainant’s request, the Agency issued a final decision pursuant to
29 C.F.R. § 1614.110(b). The decision concluded that Complainant failed
to prove that the Agency subjected him to discrimination as alleged.
Regarding Complainant’s non-selection, the Agency initially found that
Complainant established a prima facie case of discrimination on the basis
of race, but not on the basis of reprisal. Next, the Agency summarized
the affidavits of SO1 and SO2 and found that those constituted legitimate,
nondiscriminatory reasons for management’s actions. Finally, the Agency
found that Complainant failed to show that management’s articulated
reasons were a pretext for unlawful discrimination.
CONTENTIONS ON APPEAL
On appeal, Complainant initially argued that the Commission should remand
his reassignment claim to the Agency for a supplemental investigation
because the ROI did not contain documentation regarding his April 6, 2009
transfer. In addition, Complainant argued that the Agency’s articulated
reason for his non-selection – his lower score on the position selection
matrix, which was designed to select the most qualified candidates –
was a pretext for race discrimination. Among other things, Complainant
asserted that SO1 “subjectively manipulated” the Q1 scores by not
objectively evaluating each candidate’s supervisory experience.
Complainant also noted that the Agency could not demonstrate the
quality of the selectees’ credentials because SE1’s resume failed
to include dates for the alleged work experience and the ROI did not
include SE2’s resume.
On January 8, 2010, the Agency submitted a brief in opposition to
Complainant’s appeal.
29 C.F.R. § 1614.403(f) provides that any statement or brief in
opposition to an appeal must be submitted to the Commission within 30
days of receipt of the brief supporting the appeal, or, if no brief
supporting the appeal is filed, within 60 days of receipt of the appeal.
Complainant filed his appeal on October 29, 2009 and submitted a brief on
November 27, 2009. The Agency stated that it received Complainant’s
appeal on November 3, 2009, but denied having received a copy of
Complainant’s brief. In either case, the Agency submitted its brief
more than 30 days after Complainant’s November 27, 2009 brief and more
than 60 days after receiving Complainant’s appeal on November 3, 2009.
Therefore, the Commission declines to consider the Agency’s January 8,
2010 brief, as it was untimely pursuant to 29 C.F.R. § 1614.403(f).
ANALYSIS AND FINDINGS
Standard of Review
As this is an appeal from a decision issued without a hearing, pursuant to
29 C.F.R. § 1614.110(b), the Agency's decision is subject to de
novo review by the Commission. 29 C.F.R. § 1614.405(a). See Equal
Employment Opportunity Management Directive for 29 C.F.R. Part 1614 (EEO
MD-110), at Ch. 9, § VI.A. (Nov. 9, 1999) (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”).
Retaliatory Reassignment Claim
A complainant may amend a complaint at any time prior to the conclusion
of the investigation to include issues or claims like or related to
those raised in the complaint.
29 C.F.R. § 1614.106(d). In deciding if a subsequent claim is “like
or related” to the original claim, a determination must be made as to
whether the later incident adds to or clarifies the original claim, and/or
could have reasonably been expected to grow out of the investigation
of the original claim. EEO MD-110, at Ch. 5, § III.B.2 (citing Scher
v. U.S. Postal Serv., EEOC Request No. 05940702 (May 30, 1995); Calhoun
v. U.S. Postal Serv., EEOC Request No. 05891068 (Mar. 8, 1990)).
Complainant asserted in his May 8, 2009 affidavit that management
reassigned him in retaliation for filing the instant complaint. In this
case, we find that Complainant’s subsequent reassignment claim is
“like or related” to his original non-selection claim because it grew
out of the investigation into that claim. The Agency, however, failed
to properly amend Complainant’s complaint to include the reassignment
claim and failed to investigate that claim. We note that the record does
not contain any documentation regarding the reassignment, any affidavits
from the management official(s) responsible for the reassignment,3 or any
detailed testimony from Complainant about the reassignment. Accordingly,
we find that the Agency erred in not amending Complainant’s complaint
to include his subsequent, but related, reassignment claim.
Non-Selection Claim
To prevail in a disparate treatment claim absent direct evidence of
discrimination, a complainant must satisfy the three-part evidentiary
scheme fashioned by the Supreme Court in McDonnell Douglas Corp. v. Green,
411 U.S. 792, 802-04 (1973). A complainant carries the initial burden of
establishing 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 Constr. Co. v. Waters, 438
U.S. 567, 576 (1978). Proof of a prima facie case will vary depending
on the facts of the particular case. McDonnell Douglas, 441 U.S. at 802
n.13. The burden then shifts to the agency to articulate a legitimate,
nondiscriminatory reason for its actions. Texas Dep’t of Cmty. Affairs
v. Burdine, 450 U.S. 248, 253 (1981). Once the agency has met its
burden, the complainant bears the ultimate responsibility to prove,
by a preponderance of the evidence, that the reason proffered by the
agency was a pretext for discrimination. Reeves v. Sanderson Plumbing
Prod., Inc., 530 U.S. 133, 143 (2000); St. Mary’s Honor Ctr. v. Hicks,
509 U.S. 502, 519 (1993).
Complainant’s Prima Facie Case
In the non-selection context, Complainant may establish a prima facie
case of race discrimination by showing that: (1) he is a member of
a protected class; (2) he was qualified for the position; (3) he
was not selected for the position; and (4) he was accorded treatment
different from that given to persons otherwise similarly situated who
are members outside of his protected group. EEOC Enforcement Guidance on
O’Connor v. Consolidated Coin Caterers Corp., EEOC Notice No. 915.002
(Sept. 18, 1996); Williams v. Dep’t of Educ., EEOC Request No. 05970561
(Aug. 6, 1998). Regarding his non-selection, the record reflects that
Complainant has shown that: (1) he is an African-American employee;
(2) he met the minimum qualifications for the position; (3) he was not
selected for the position; and (4) two Caucasian employees (SE1 and SE2)
were selected for the position.
Agency’s Legitimate, Nondiscriminatory Reason
Once a complainant has established a prima facie case, the burden then
shifts to the agency to articulate a legitimate, nondiscriminatory reason
for its actions. Texas Dep’t of Cmty. Affairs v. Burdine, 450 U.S. at
253. The Supreme Court has described this burden as being met “if the
[agency’s] evidence raises a genuine issue of fact as to whether it
discriminated against the [complainant],” and that “[t]o accomplish
this, the [agency] must clearly set forth, through the introduction of
admissible evidence, the reasons for the [complainant’s] rejection.”
Id. at 254-55. Moreover, the agency must “frame the factual issue
with sufficient clarity so that the [complainant] will have a full
and fair opportunity to demonstrate pretext,” with the adequacy of
its evidence “evaluated by the extent to which it fulfill[ed] these
functions.” Id. at 255-56. The burden incumbent upon the agency
to respond to a complainant’s prima facie case with a legitimate,
nondiscriminatory reason for its actions is a burden of production,
not persuasion. Reeves, 530 U.S. at 142. While the agency’s burden of
production is not onerous, it must nevertheless provide a specific, clear,
and individualized explanation for the treatment accorded a complainant.
Lorenzo v. Dep’t of Def., EEOC Request No. 05950931 (Nov. 6, 1997).
An agency may fail to adequately meet its burden of production in
several ways. When a complainant challenges an agency’s ratings
or rankings of the complainant, an agency may fail to articulate a
legitimate, nondiscriminatory reason when it fails to provide specific
information to explain why agency officials assigned their respective
ratings to the complainant. See, e.g., Clemente v. Dep’t of Justice,
EEOC Appeal No. 0720080012 (Sept. 24, 2008) (finding that an agency failed
to meet its burden of production when it provided a mere description
of the selection process, generally stated that the selectees were more
qualified than complainant, and provided no clarification in the record
about the specific qualities that made the selectees better qualified
than complainant).
Upon review of the record, we find that the Agency failed to meet
its burden of articulating a legitimate, nondiscriminatory reason.
Specifically, we find that SO1 failed to provide a specific, clear,
and individualized explanation for Complainant’s non-selection.
SO1 averred that he used the position selection matrix to determine
who was best qualified for the position and described its role in the
selection process. ROI, Ex. 2, at 10-12. At no point in his affidavit,
however, did SO explain why he chose SE1 and SE2 over Complainant.
First, SO1 failed to provide an individualized explanation for
Complainant’s scores on the position selection matrix. When asked by
the EEO Investigator to compare Complainant’s qualifications with those
of SE1 and SE2, SO1 listed the numbers on the position selection matrix
but did not provide any additional information. Id. at 9-10, 12-13.
For example, the following testimony by SO1 provides no explanation
as to why Complainant received lower scores or what qualities, if any,
made SE2 better qualified for the position than Complainant:
The first criteria talked about experience managing, supervising
maintenance employees and power plant maintenance activities. It appears
that we gave a 2 for [SE2] and a 1 for [Complainant]. And, the criteria
was greater than ten years, they would score a 4; less than ten, but
greater than five is a 3. Between five and two was a two. And, so it
appears that [SE2] fell in the category of more than two and less than
five years and score out a 2 and [Complainant], less than two years,
scored out as a 1. The second question translates maintenance goals,
integrates them into work activities. [SE2] score a 3; [Complainant]
a 1. The leadership skills demonstrated on the leadership assessment,
both individuals scored out as a 2. And, education, [SE2] scored out
as a 1 and [Complainant] as a 3. Id. at 9-10.
Second, SO1’s statements about the candidates’ supervisory experience
are not sufficiently specific and clear to meet the Agency’s burden
of production. When asked by the EEO Investigator to respond to
Complainant’s statement that he had more seniority and experience than
the selectees, SO1 averred:
Well, as far as seniority, we don’t consider seniority … That’s not
necessarily, it is not a basis for selection in this particular position.
We go by -- the first criteria was experience and managing employees and
power plant maintenance activities … And, he was what we call a dual
rate foreman for, I want to say a year, a year and a half was really the
extent of his supervision over employees as compared to several of these
individuals and some of those that we did select and a couple that we
offered and declined have ten to twelve to fifteen years experience in
supervising employees … Seniority, he may have seniority over someone,
but he doesn’t have experience supervising employees, the years of
experience that many of the candidates did. Id. at 14-15.
It is unclear which specific individuals – SE1, SE2, or other candidates
not selected – SO1’s statements refer to when me mentions “several
of these individuals and some of those that we did not select and a
couple that we offered and declined.” In addition, the Q1 scores
on the position selection matrix indicate that SE1 and SE2 received
credit for having two to five years of supervisory experience, and that
only one candidate received credit for having more than ten years of
supervisory experience. ROI, at 137. Moreover, the applications of SE1
and SE2 provide us with no insight on how SO1 evaluated their supervisory
experience in comparison with Complainant’s supervisory experience.
For example, SE1’s application included a list of his Agency work
experience from “1992-Present,” but did not specify how long he had
worked in each position. ROI, at 162-64. Similarly, SE2’s application
did not list any work experience or any relevant dates. ROI, at 139-40.
Based on the above, we find that the Agency failed to articulate a
specific, clear, and individualized explanation for Complainant’s
non-selection, and consequently, Complainant was denied a fair opportunity
to demonstrate pretext. See Young v. Dep’t of the Treasury, EEOC
Request No. 05940517 (Oct. 13, 1995). Thus, the Agency failed to rebut
the inference of discrimination, which was created when Complainant
established a prima facie case of race discrimination, by articulating
a legitimate, nondiscriminatory reason for its actions. Therefore,
we find that Complainant was subjected to discrimination based on his
race when he was not selected for the Maintenance Supervisor position.
CONCLUSION
Based on a thorough review of the record and the contentions on appeal,
including those not specifically addressed herein, we REVERSE the
Agency’s final decision. The Agency will comply with the Order below.
ORDER
The Agency is ORDERED to take the following actions:
1. Retaliatory Reassignment Claim
a. The Agency shall conduct a supplemental investigation and compile
evidence regarding Complainant’s reprisal claim. The Agency shall
obtain all pertinent evidence needed to address Complainant’s reprisal
claim including, but not limited to, documents pertaining to the April
2009 reassignment and affidavits from Complainant and the responsible
management official(s).
b. The Agency shall complete its supplemental investigation and
issue a new final decision, together with the appropriate appeal rights,
within ninety (90) calendar days of the date this decision becomes final,
unless the matter is otherwise resolved prior to that time. A copy of
the Agency’s final decision must be sent to the Compliance Officer as
referenced below.
2. Non-Selection Claim
Unless otherwise indicated, the Agency is ordered to take the following
remedial action within sixty (60) days of the date this decision becomes
final:
a. The Agency shall offer Complainant the position of Maintenance
Supervisor, or a substantially equivalent position, at the Shawnee Fossil
Plant in Paducah, Kentucky, retroactive to the date of his non-selection,
in or about February 2009. Complainant shall have fifteen (15) days from
the date of the offer to accept or decline the position. If Complainant
should decline the Agency’s offer of a position, the date of his
rejection shall be the end date for any back pay due Complainant.
b. The Agency shall determine the appropriate amount of back pay,
with interest, and other benefits due Complainant, pursuant to 29
C.F.R. § 1614.501, no later than sixty (60) calendar days after the
date this decision becomes final. Complainant shall cooperate in the
Agency’s efforts to compute the amount of back pay and benefits due,
and shall provide all relevant information requested by the Agency.
If there is a dispute regarding the exact amount of back pay and/or
benefits, the Agency shall issue a check to Complainant for the
undisputed amount within sixty (60) calendar days of the date the Agency
determines the amount it believes to be due. Complainant may petition for
enforcement or clarification of the amount in dispute. The petition for
clarification or enforcement must be filed with the Compliance Officer,
at the address referenced in the statement entitled “Implementation
of the Commission’s Decision.”
c. The Agency shall conduct a supplemental investigation on
compensatory damages, including providing Complainant an opportunity to
submit evidence of pecuniary and non-pecuniary damages. For guidance on
what evidence is necessary to prove pecuniary and non-pecuniary damages,
the parties are directed to EEOC Enforcement Guidance: Compensatory and
Punitive Damages Available Under § 102 of the Civil Rights Act of 1991
(July 14, 1992) (available at eeoc.gov.) The Agency shall complete
the investigation and issue a final decision appealable to the EEOC
determining the appropriate amount of damages within 150 calendar days
after this decision becomes final.
d. The Agency shall provide eight (8) hours of EEO training to the
responsible management officials regarding their responsibilities under
EEO laws.
e. 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).
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 (G0610)
The Agency is ordered to post at its Shawnee Fossil Plant in Paducah,
Kentucky 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 (H0610)
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 (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
___12/15/11_______________
Date
1 SO2 averred that he was not the selecting manager and was not at the
facility when the selections were made.
2 Complainant did not allege reprisal in connection with his
non-selection.
3 The record contains supplemental affidavits from SO1 and SO2.
When asked about Complainant’s reassignment, both averred that they
had no knowledge it. ROI, at Ex. 9-10.
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U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
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