0120081959
07-18-2012
Gregory R. Chatman, Complainant, v. Mary L. Schapiro, Chairman, Securities and Exchange Commission, Agency.
Gregory R. Chatman,
Complainant,
v.
Mary L. Schapiro,
Chairman,
Securities and Exchange Commission,
Agency.
Appeal No. 0120081959
Hearing No. 520-2006-00443X
Agency No. SEC-30-05-06
DECISION
On March 20, 2008, Complainant filed an appeal from the Agency's March 18, 2008, final order 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. and the Age Discrimination in Employment Act of 1967 (ADEA), as amended, 29 U.S.C. � 621 et seq. The Commission accepts the appeal pursuant to 29 C.F.R. � 1614.405(a). The Commission AFFIRMS in part the Agency's final order.
ISSUES PRESENTED
The issues presented are: (1) whether the EEOC Administrative Judge (AJ) properly issued a decision without a hearing in favor of the Agency concerning Complainant's disparate treatment claim; and (2) whether the claims in Complainant's complaint have been fully addressed.
BACKGROUND
At the time of events giving rise to this complaint, Complainant (Black, 52, prior EEO activity) worked as a Staff Accountant, GS-14, at the Agency's Regional Office in Boston, Massachusetts. In this capacity, he was supervised by a Branch Chief and an Assistant District Administrator, who served respectively as his first and second-line supervisors (S1 and S2). Complainant was responsible for examining broker-dealers (i.e., entities regulated by the Agency that buy and sell securities) to ensure compliance with federal securities laws, which required that he visit the broker-dealers' offices, analyze their operations, and draft reports addressing whether those operations complied with federal regulations.
On December 13, 2005, Complainant filed an EEO complaint in which he alleged discrimination on the above-referenced bases when the Agency did not give him a two to three-step merit increase award for the rating period spanning May 1, 2004, to April 30, 2005. We note that the Agency acknowledged that Complainant amended his complaint in an e-mail dated January 17, 2006. Complainant amended his complaint when, among other things, he alleged that the Agency's manner of deciding merit step-increases resulted in a "glass ceiling" preventing Black employees and employees who filed EEO complaints from moving up in the Agency. See Complainant's January 12, 2006, Amended Complaint.1
The Agency accepted this issue for investigation and at the conclusion thereof provided Complainant with a copy of the report of investigation (ROI) and notice of his right to request a hearing before an AJ. Complainant timely requested a hearing. When the Complainant did not object, the AJ assigned to the case granted the Agency's October 30, 2007, motion for a decision without a hearing and on March 7, 2008, issued a summary judgment decision in which she found Complainant had not proven discrimination.
Specifically, the AJ found that Complainant established a prima facie case of race and age discrimination because a White female in her late thirties, the sole employee at the Agency who held the same title as Complainant and was in the same chain of command (Comparator), received a two-step merit pay increase whereas Complainant received only one. Administrative Judge March 7, 2008, Decision, at 7. The AJ found that Complainant did not establish a prima facie case of reprisal discrimination because his prior EEO activity took place in October 2002, and the employment action at issue herein took place in August 2005, a temporal period regarded as too long to infer a connection between the two. Id. at 8. Nevertheless, the AJ assumed that Complainant established a prima facie case of reprisal but found that Complainant could not prevail on his race, age, or reprisal claims because the Agency stated legitimate nondiscriminatory reasons which Complainant failed to prove were pretexts for discrimination.
Regarding the Agency's reasons, the AJ noted that Complainant's first-line supervisor (S1) indicated that Complainant made no significant contribution beyond an acceptable level of performance and that his "performance was just barely acceptable and not anywhere above acceptable in order to get him to a ['one'] on the merit pay system."2 The AJ further noted that S1 indicated that Complainant could not perform at the level that someone who is a Grade 14 Staff Accountant would be expected to perform, did not have the requisite knowledge to perform his job well, and did not demonstrate an aptitude to acquire that knowledge. Finally, the AJ noted that S1 indicated that Complainant performed his work in an untimely manner; required too much guidance from her and his colleagues; planned out his work poorly; asked the wrong questions of persons he was interviewing; maintained his work papers in an unorganized manner; submitted reports with missing sections, inaccurate information, and poor grammar; and failed to prepare reports in accordance with SEC standards. She also noted that S1 referenced Complainant's poor work on two examinations and that the Compensation Committee, a group comprised of upper management who made the final recommendation regarding merit pay increases for each employee, agreed with S1's assessment. Id. at 8-9.
Concerning Complainant's burden to show that the Agency's reasons were a pretext for discrimination, the AJ noted that the Agency stated of Comparator that "she organized her work effectively; questioned firms thoroughly; completed her work timely; communicated well verbally; made presentations at two industry conferences; and provided regular updates to [S1]." She then found that Complainant failed to prove that the Agency's statements regarding his or Comparator's work was a pretext for discrimination because, by his own admission, he had no knowledge of Comparator's work and when asked how many merit step-increases he believed he deserved, Complainant stated, "I don't know what the standards are, but it's hard to say. I know I deserve - I think I did better than I got ... I think I did better than what I was recommended for." Id. at 11. The AJ concluded that Complainant's speculation was "all we have here," and thus found that he had not proven discrimination as alleged. The AJ's decision is silent on Complainant's disparate impact claim.
On March 18, 2008, the Agency issued a final order adopting the AJ's finding of no discrimination. Complainant thereafter initiated this appeal.
CONTENTIONS ON APPEAL
On appeal, Complainant argued that in a complaint filed with the Federal Labor Relations Authority (FLRA) by the National Employees Treasury Union (NTEU) on March 15, 2004, the FLRA found that Black employees in grades 8 through 16 and employees aged 40 and over received significantly fewer pay increases than would be expected given their representation at the Agency, and that the Agency's "subjective program was poorly conceived ... implemented without providing adequate guidelines to employees and supervisors, and ... executed in a haphazard and inconsistent fashion across the [A]gency." See Complainant's July 22, 2008, Statement in Support of Appeal. Complainant believes that the FLRA findings have a direct bearing on this appeal. The Agency argues that the AJ properly found no discrimination and requests that we affirm its final order.
STANDARD OF REVIEW
In rendering this appellate decision we must scrutinize the AJ's legal and factual conclusions, and the Agency's final order adopting them, de novo. 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 Chap. 9, � VI.B. (Nov. 9, 1999) (providing that both an AJ's determination to issue a decision without a hearing pursuant, and the decision itself, 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 AJ's, and Agency's, factual conclusions and legal analysis - including on 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 Chap. 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").
ANALYSIS AND FINDINGS
Summary Judgment
The Commission's regulations allow an AJ to issue a decision without a hearing when he or she finds that 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 Defense, EEOC Appeal No. 01A24206 (July 11, 2003). We find that the AJ properly issued a decision without a hearing with respect to Complainant's disparate treatment allegation because no genuine issues of material fact or need for credibility determinations existed.3 However, we further find that the Agency did not investigate and the AJ did not gather evidence on Complainant's disparate impact claim, an issue that was part of the amended complaint. This aspect of Complainant's claim was not dismissed by the Agency in the partial dismissal issued on January 30, 2006; therefore, we will remand this portion of Complainant's claim for further processing.
Disparate Treatment
Generally, claims of disparate treatment are examined under the tripartite analysis first enunciated in McDonnell Douglas Corporation v. Green, 411 U.S. 792 (1973); Hochstadt v. Worcester Foundation for Experimental Biology. Inc., 425 F. Supp. 318, 324 (D. Mass.), aff'd, 545 F.2d 222 (1st Cir. 1976). For a complainant to prevail, he must first establish a prima facie case of discrimination by presenting facts that, if unexplained, reasonably give rise to an inference of discrimination, i.e., that a prohibited consideration was a factor in the adverse employment action. McDonnell Douglas, 411 U.S. at 802; Furnco Construction Corp. v. Waters, 438 U.S. 567 (1978). For instance, to establish a prima facie case of reprisal, Complainant must show that (1) he engaged in protected EEO activity; (2) the Agency was aware of the protected activity; (3) subsequently, he was subjected to adverse treatment by the Agency; and (4) a nexus exists between his protected activity and the adverse treatment. Whitmire v. Dep't of the Air Force, EEOC Appeal No. 01A00340 (Sept. 25, 2000).
Once a complainant has established a prima facie case, the burden of production then shifts to the agency to articulate a legitimate, nondiscriminatory reason for its actions. Texas Dep't of Community Affairs v. Burdine, 450 U.S. 248, 253 (1981). If the agency is successful, the burden reverts to the complainant to demonstrate by a preponderance of the evidence that the agency's reason(s) for its action was a pretext for discrimination. At all times, the complainant retains the burden of persuasion, and it is his obligation to show by a preponderance of the evidence that the agency acted on the basis of a prohibited reason. St. Mary's Honor Center v. Hicks, 509 U.S. 502 (1993), 519; U.S. Postal Serv. Bd. of Governors v. Aikens, 460 U.S. 711, 715-16 (1983).
For purposes of analysis, we assume Complainant has established a prima facie case of discrimination based on race, age, and reprisal discrimination. We now look to the Agency's reasons for not giving Complainant a two or three-step merit increase for the 2004-2005 rating period. The record shows that the Agency's merit award system worked in the following manner. Each employee at the Agency was rated by their respective Branch Chief (i.e., first-line supervisor) who rated them "acceptable" or "unacceptable" based on four critical elements, namely, knowledge of field or occupation; planning and organizing work; execution of duties; and communications. Employees must have been rated "acceptable" in all four categories to be rated acceptable overall and become eligible for merit step-increases in pay which could range anywhere from zero to three steps. Administrative Judge's May 1, 2008 Decision, at 3. These employees were asked to prepare and submit to their supervisor a summary of their contributions, which the supervisor reviewed and then used in preparation and support of any proposed recommended merit pay increase. ROI, at 6-7.
The supervisor's recommendation and the employee's summary of contributions were then sent to a Compensation Committee (Committee), which made the final recommendation regarding any particular merit pay increase, then forwarded its recommendation to the Regional District Administrator (Administrator), who made the final decision. The Agency's goal for the 2004-2005 rating period was to place roughly one-third of the staff in the recommended pool, or those who rated "acceptable" overall, for one, two, and three step merit increases, respectively. Id. at 7. One representative from the Committee indicated that the committee members generally adopted the recommendation of the Branch Chief unless their was some reason to question it, and another indicated there were four to five instances where the committee changed the Branch Chief's recommendation. Id. at 8.
The Associate District Administrator (Associate Administrator), who assisted the Administrator in reviewing the committee's recommendations, indicated that the Agency looked closely at those employees for whom the committee recommended anything other than two-step increases, and that in the final decision-making process, he and the Administrator adjusted the recommended merit step-increases of fewer than ten employees. Id. The Administrator indicated that one such employee was Complainant, who went from a recommended zero-step increase to a one-step increase for the relevant period. Id. In the final counting, 25 employees received three-step increases; 45 received two-step increases; 15, including Complainant, received one-step increases; and three employees received zero-step increases.
S1 stated that he recommended that Complainant not receive a merit step-increase because his performance was "just barely acceptable." Id. at 10. He further stated that Complainant was particularly challenged in the critical elements of knowledge of field or occupation and communications, and received more guidance from him than during the relevant rating period than any other staff accountant or examiner. S1 explained that Complainant was challenged in planning and organizing his work and executing his duties, took a long time to perform certain tasks, and did not obtain readily available information from industry participants or demonstrate the ability to ask the right questions in order to elicit needed information. Id. at 10. S2, also a member of the Committee, indicated that she agreed with S1's recommendation. According to her, S1's recommendation was consistent with how he described Complainant's work performance throughout the year. Id. at 13.
The Administrator stated that he changed Complainant's recommended increase from zero to one step even though he knew S1 was not satisfied with Complainant's performance because he considered that zero sent a signal stronger than necessary for someone trying to make an effort. Id. at 14. He further stated that he wanted to encourage Complainant to try a little harder. The Associate Administrator indicated that he and the Administrator thought Complainant deserved some merit-pay increase. Id. We find, as did the AJ, that the Agency's reasons for giving Complainant one-step increase as opposed to a two or three-step increase are legitimate, nondiscriminatory reasons.
To prevail, Complainant must show how those reasons are pretext for discrimination. Complainant believed he deserved a two or three-step increase for 2005 because he worked on three major market timing examinations, two of which he conducted concurrently, with no assistance excluding the help he received from an intern. Complainant indicated that prior to the current system, implemented in fiscal year 2003 pursuant to the Investors and Capital Markets Fee Relief Act ("Pay Parity Act"),4 enacted by Congress on January 16, 2002, which authorized the Agency to pay its employees higher levels of compensation comparable to other financial regulatory agencies in a manner consistent with long-standing merit system principles, he received bonuses and step-increases every year and was recommended for quality step-increases. See EEO Counselor's Report at 5.
The AJ found that the only other Staff Accountant within the same chain of command as Complainant was a White female under the age of 40 (CW). CW received a two-step increase. According to S1, CW received a two-step increase because she organized her work effectively, questioned brokerage firms thoroughly, completed her work timely, communicated well verbally, made presentations at two industry conferences, and provided him regular work updates. AJ Decision at 9. The AJ noted that Complainant testified in his deposition that he did not work with CW and had no knowledge of her work. Id. at 10. The AJ further noted that when asked what level of increase he felt he deserved, Complainant stated the following, "I don't know what the standards are, but it's hard to say. I know I deserve - I think I did better than I got ... I think I did better than what I was recommended for." Id. at 11. The AJ concluded that Complainant's speculation was "all we have here," and ultimately found such speculation to be insufficient to meet his burden of proving discrimination by a preponderance of the evidence. Id. at 11. We agree with the AJ's assessment regarding the quality of Complainant's disparate treatment evidence, and also find that he failed to meet his burden of showing pretext.
Disparate Impact
In a disparate impact case, the burden rests on Complainant to show that a challenged policy or practice, although facially neutral, has significant discriminatory impact on his protected group. Griggs v. Duke Power Co., 401 U.S. 424, 430-32 (1971); Connecticut v. Teal, 457 U.S. 440, 446 (1982); Watson v. Ft. Worth Bank & Trust, 487 U.S. 977, 987 (1988). To establish a prima facie case of disparate impact, Complainant must: (1) identify the specific practice or policies being challenged; (2) show statistically significant disparities; and (3) show a nexus between the practice or policy and the statistically significant disparities. Watson, 487 U.S. at 994; Wards Cove Packing Co. v. Atonio, 490 U.S. 642, 656-58 (1989); D'Leo v. Dep't of the Navy, EEOC Petition No. 03920085 (November 20, 1992).
On appeal, as he did when he amended his initial complaint, Complainant alleged that the Agency's practice of distributing merit step-increases demonstrated patterns of prohibited discrimination. In support of this position, Complainant noted a decision issued by the FLRA, which found that the Agency used a subjective and discretionary process for determining whether and how many merit step-increases to award its employees that had a disparate impact on Blacks in grades 8 through 16 and employees 40 and over, and thus violated Title VII and the ADEA. It appears this decision regarded the merit step-increases awarded by the Agency for the 2002-2003 rating period. See NTEU (Chapter 23) v. Securities and Exchange Comm'n, SEC Case No. AR-04-054, at 19 (Sep. 4, 2007) (stating that the Union hired an industrial psychologist with a Ph.D. to conduct statistical analysis on the Agency's 2003 pay-for-performance program as it regarded merit pay increases). We note that Complainant's allegation concerned the 2004-2005 rating period, and there is no evidence in the record this claim was ever investigated by the Agency. We also note that the Administrator indicated that he raised Complainant's award and took a careful look at the awards given to other Blacks because he saw "that there was some, it was weighted, there were lower scores for people who were African-American." See ROI, Volume II, Affidavit of Witness No. 8, at 12. Because the disparate impact evidence in the file regards the 2002-2003 rating period, and the Administrator's statement is not the kind of evidence sufficient to rule on a disparate impact matter, we shall remain this portion of Complainant's complaint to the Agency for further investigation.
CONCLUSION
Based on a thorough review of the record and the contentions on appeal, including those not specifically addressed herein, we find that the AJ's findings of fact with respect of Complainant's disparate treatment claim are supported by a de novo review of the record, and that her application of the law to those facts are legally sound. We find no reason to disturb that aspect of the AJ's decision and hereby AFFIRM the Agency's adoption thereof. However, we also find that the Agency did not investigate Complainant's disparate impact claim, nor was the issue addressed by the AJ; we REMAND this allegation for action in accordance with this decision and the Order below.5
ORDER ( E0610)
The agency is ordered to process the remanded claims in accordance with 29 C.F.R. � 1614.108. The agency shall acknowledge to the complainant that it has received the remanded claims within thirty (30) calendar days of the date this decision becomes final. The agency shall issue to complainant a copy of the investigative file and also shall notify complainant of the appropriate rights within one hundred fifty (150) calendar days of the date this decision becomes final, unless the matter is otherwise resolved prior to that time. If the complainant requests a final decision without a hearing, the agency shall issue a final decision within sixty (60) days of receipt of complainant's request.
A copy of the agency's letter of acknowledgment to complainant and a copy of the notice that transmits the investigative file and notice of rights must be sent to the Compliance Officer as referenced below.
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 (T0610)
This decision affirms the Agency's final decision/action in part, but it also requires the Agency to continue its administrative processing of a portion of your complaint. You have the right to file a civil action in an appropriate United States District Court within ninety (90) calendar days from the date that you receive this decision on both that portion of your complaint which the Commission has affirmed and that portion of the complaint which has been remanded for continued administrative processing. 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 your appeal with the Commission, until such time as the Agency issues its final decision on your complaint. 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. If you file a request to reconsider and also file a civil action, 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
July 18, 2012
Date
1 Complainant also alleged discrimination when he received a one-step merit pay increase from August 2003 to August 2004; was not given certain assignments, which denied him the opportunity to compete for awards, recognition and promotion; and most of the work he was assigned involved solo examinations rather than teamwork. These claims were dismissed on January 30, 2006, for various reasons pursuant to the procedure outlined in 29 C.F.R. � 1614.107(b). Complainant did not challenge these dismissals on appeal. We exercise our discretion to review only the issues specifically raised in Complainant's appeal. Therefore the sole issue in this decision regards the merit step-increase spanning the Agency rating period of 2004-2005. See Equal Employment Opportunity Commission Management Directive for 29 C.F.R. Part 1614, at 9-10 (Nov. 9, 1999).
2 S1 recommended that Complainant receive no merit step-increase, but the deciding official approved Complainant for a one-step increase.
3 We note that Complainant does not contest on appeal the AJ's decision to issue a summary judgment ruling.
4 Public Law 107-123.
5 Complainant's amended complaint did not allege age as a basis of discrimination in his disparate impact claim.
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0120081959
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
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0120081959