0120103125
12-01-2010
Robert C. Wagner, Complainant, v. Ray H. LaHood, Secretary, Department of Transportation, (Federal Aviation Administration), Agency.
Robert C. Wagner,
Complainant,
v.
Ray H. LaHood,
Secretary,
Department of Transportation,
(Federal Aviation Administration),
Agency.
Appeal No. 0120103125
Agency No. 2010-22977-FAA-06
DECISION
On July 28, 2010, Complainant filed an appeal from the Agency's July 20,
2010, final decision concerning his equal employment opportunity (EEO)
complaint alleging employment discrimination in violation of Section
501 of the Rehabilitation Act of 1973 (Rehabilitation Act), as amended,
29 U.S.C. � 791 et seq. The Commission deems the appeal timely and
accepts it pursuant to 29 C.F.R. � 1614.405(a).
BACKGROUND
At the time of events giving rise to this complaint, Complainant worked
as an Aviation Safety Inspector at the Agency's Flight Standards District
Office facility in Scottsdale, Arizona.
The record indicated that in January 2000, Complainant was diagnosed with
Nasal Pharynx cancer, which was treated with radiation and chemotherapy.
Complainant fully recovered, but has had remaining side effects, including
high frequency hearing loss which required him to start wearing hearing
aids. In March 2005, while working at the Tucson Arizona Airport,
two military planes flew close by after takeoff and the noise blew out
both of his digital Phonak hearing aids. This on-the-job accident caused
severe trauma and 71% hearing loss. As a result, Complainant asserted
that he was unable to perform in his position at a satisfactory level.
He said he had difficulty using the telephone and interviewing pilots
and aircraft operations.
Complainant was provided with a Smartlink microphone and hearing aid
through the Department of Labor. However, Complainant indicated that he
needed the cooperation of others at meetings so that he could hear them.
Specifically, the Smartlink transmitter had to be either worn or held near
a speaker. The sound is then transmitted to a hearing aid receiver which
allows Complainant to hear the speaker. Complainant indicated, however,
that management has repeated resisted touching or using the Smartlink
device even after Complainant's repeated requests for them to do so.
Complainant also noted that this rejection by management to use the
Smartlink has carried over to line employees.
In December 2008, Complainant experienced further hearing loss.
As a result, Complainant requested an office that would allow him
to use a speaker phone so that he would not disturb his co-workers.
Complainant was provided with an office which Complainant initially
accepted. However, according to Complainant the office was small and
had no windows, causing him to feel claustrophobic. He requested an
office with a window, but that request was denied and he was returned
to his former cubicle. Complainant then requested a Caption Telephone
(Captel) which would transcribe speech into text. This way Complainant
would not require a separate office in which to work. If a Captel could
not be provided, Complainant requested an alternative job. Complainant's
manager (Manager 1) denied both requests. However, Complainant appealed
the matter to upper level management and was provided with a Captel.
Complainant alleged that in 2008 management began suggesting to
Complainant that he consider taking a disability retirement. Complainant
stated that Manager 1 mentioned that he should speak with a co-worker who
had received a disability retirement. He further alleged that Manager 2,
shortly thereafter, stated to Complainant that he should retire and buy
a motor home. Complainant told both managers that he had not reached
the full retirement age. In 2009, Complainant said that for the first
time in his many years of service he was asked to drive a government
owned vehicle from his worksite to the airport for investigations.
Complainant indicated that extended his day because he would have to
return the government vehicle and retrieve his own car. He stated that
he was the only person held to this requirement.
Complainant claimed that management did not comprehend the difficulty he
was having understanding people since his work injury. Complainant noted
that hearing sounds and actually understanding people were two different
things. One example Complainant provided of the difficulties he had with
management was a meeting on September 23, 2009. Complainant stated that
on that day he was called into a meeting with Manager 1, Manager 2 and a
Union Representative. The discussion between Complainant and management
was related to his documentation pertaining to his on-the-job injury.
During the meeting, Complainant indicated that management was not using
his Smartlink transmitter correctly. Complainant was threatened with
insubordination and he alleges that Manager 1 began jumping around,
stomping and flailing his arms. Complainant requested that Manager 1 and
Manager 2 put their questions in writing so that he could fully understand
what they were asking of him. They refused to do so. Complainant
left the meeting stressed and sought his physician. Complainant took
medical leave and did not return. Complainant subsequently applied for
a disability retirement.
On November 16, 2009, Complainant filed an EEO complaint alleging that
the Agency discriminated against him on the bases of disability (71%
hearing loss) and reprisal for prior protected EEO activity under Section
501 of the Rehabilitation Act of 1973 when:
1. Complainant was denied reasonable accommodation in the form of
an office, a Captel, and proper use by management of his Smartlink
transmitter;
2. Complainant was subjected to harassment; and
3. as a result of the harassment, Complainant was constructively
discharged when he took a disability retirement effective October 31,
2009.
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 (AJ). When
Complainant did not request a hearing within the time frame provided in
29 C.F.R. � 1614.108(f), the Agency issued a final decision pursuant to
29 C.F.R. � 1614.110(b).
FINAL AGENCY DECISION
The Agency's final decision concluded that Complainant failed to prove
that management subjected him to discrimination as alleged. As an
initial matter, the Agency found that Complainant established that he
has a disability based on his hearing loss within the meaning of the
Rehabilitation Act. The Agency then found that Complainant was provided
with adequate reasonable accommodations for his disability. The Agency
noted that Complainant was first given an office, as requested. When he
rejected it, he was returned to his cubicle and provided with a Captel.
As such, Complainant was permitted to continue to work within his Aviation
Safety Inspector position. Finally, as to Complainant's claim regarding
the meeting in September 2009, the Agency held that Complainant had his
Smartlink device with him at the meeting, management did not refuse to use
it, and Complainant was also allowed to bring in a union representative.
As such, the Agency's final decision concluded that Complainant was not
denied his requested accommodations.
As to Complainant's claim of constructive discharge, the Agency determined
that Complainant did not support claim that his retirement was not
voluntary. As already noted, the Agency determined that Complainant
was provided with adequate reasonable accommodations for his disability
and the single incident at the September 2009 meeting, even accepting
Complainant's version that management refused to put their questions
in writing for him, was not sufficient to establish that he was coerced
into retiring.
CONTENTIONS ON APPEAL
Complainant appealed asserting that the Managers lied in their affidavits.
Complainant indicated that he had been subjected to a hostile work
environment based on the treatment by his managers and the denial
of reasonable accommodation. Based on the actions by management,
Complainant was placed under so much stress, he was forced to resign.
The Agency requested that the Commission affirm its final decision
finding no discrimination.
ANALYSIS AND FINDINGS
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, at Chapter 9,
� VI.A. (November 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").
Denial of Reasonable Accommodation
Under the Commission's regulations, an agency is required to make
reasonable accommodation to the known physical and mental limitations of
an otherwise qualified individual with a disability unless the agency can
show that accommodation would cause an undue hardship. 29 C.F.R. � 1630.9.
Since the Agency does not contest that Complainant is a qualified person
with a disability, the Commission may proceed to the question of whether
he was accommodated.
The record indicated that Complainant made several requests for reasonable
accommodation. First, Complainant sought a separate office that would
allow him to put the phone on speaker in order to conduct his work.
The Agency provided Complainant with an office which Complainant accepted.
However, Complainant later rejected the room noting that it had no windows
and felt like a "jail cell." Feeling claustrophobic, Complainant asked
to be moved to an office with windows. The Agency did not provide him
with such an office. Management stated that the available window office
would be located too close to others and the noise from the speaker phone
would disrupt the workplace. Complainant was returned to his cubicle.
Complainant suggested alternative accommodations that would allow him
to continue his work without a private office. The first suggestion
Complainant made was for a Caption Telephone or Captel. This phone
would transcribe speech into text for Complainant to read. If the
Agency could not provide Complainant with the Captel, Complainant
requested a reassignment to a position that did not require him to
speak with individuals on the phone. The record showed that Manager
1 initially denied the request. Complainant appealed the issue to
upper-level management and was provided with a Captel so that he
could perform his job in a cubicle. As such, we find that the Agency
provided Complainant with an effective accommodation. We are concerned
that Manager 1 initially denied the request, however, Complainant was
provided with the accommodation. The record does not indicate how long
it took Complainant to receive the Captel. As such, we cannot find that
Manager 1's denial created an undue delay in providing Complainant with
a reasonable accommodation. Accordingly, we affirm the Agency's finding
that it provided Complainant with reasonable accommodation in the form
of the Captel.
Finally, Complainant used the Smartlink transmitter and receiver in order
to hear management and his co-workers. In order for Complainant to hear
individuals, Complainant indicated that the speaker needed to wear or
hold the Smartlink transmitter close. Complainant averred that Managers
did not use the transmitter correctly. He stated that the transmitter
would be placed in the middle of the meeting and the speakers would
not actually hold the transmitter. Complainant would ask speakers
to speak into the transmitter. He noted that Manager 1 and Manager
2 would not comply with his requests. Further, since management did
not set the appropriate example for how to use the Smartlink, other
co-workers would similarly reject holding the Smartlink. As such,
Complainant could not hear nor understand what speakers were saying
to him. Another example of this was the meeting Complainant had with
Manager 1, Manager 2, and the Union Representative in September 2009.
At the meeting, Complainant indicated that he could not understand
the management officials. Complainant averred that he tried to get
them to use the Smartlink transmitter properly, but they refused.
Complainant then requested that management write down their questions.
Again, management refused to do so and Complainant was not permitted
to understand what management was trying to convey at that meeting.
Upon review of the record, although Complainant has been provided with
the Smartlink transmitter and receiver, management has not provided
their cooperation to make the device effective. Complainant is not
able to hear management or co-workers. As a result, we conclude that
Complainant has been denied an effective accommodation. Therefore,
we reverse the Agency's final decision finding as to the Smartlink
cooperation by management and co-workers.
The record indicates that following the meeting with management
in September 2009, Complainant took leave for the remainder of his
time with the Agency and applied for disability retirement in October
2009. Although the Agency characterized complainant's claim as one of
constructive discharge, as stated above, we find that this claim is more
properly classified as a denial of reasonable accommodation resulting
in the inability to work. As such, the proper remedy following a finding
that Complainant was not reasonably accommodated is to order the Agency
to provide a reasonable accommodation to Complainant and to reinstate
him to his position prior to his retirement.
Harassment
We note that Complainant raised two separate actionable claims, one of
harassment and another of constructive discharge. We find that the Agency
erred in only addressing Complainant's claim of constructive discharge.
The record indicates that Complainant claimed that management created
the hostile work environment when they refused to provide him with an
effective accommodation, permitted co-workers to refuse to cooperate with
Complainant in used of the Smartlink, made statements indicating that
he has hygiene problems based on his coughing, and required him to use a
government car for the first time in 18 years. Complainant noted that
starting in March 2008; management began suggesting to Complainant that he
should take a disability retirement. Complainant also asserted that these
actions by the Agency culminated in his resignation in October 2009.
It is well-settled that harassment based on an individual's disability and
prior EEO activity is actionable. See Meritor Savings Bank FSB v. Vinson,
477 U.S. 57 (1986). In order to establish a claim of harassment under
those bases, Complainant must show that: (1) he is a qualified individual
with a disability covered under the Rehabilitation Act and/or engaged
in prior EEO activity; (2) he was subjected to unwelcome conduct;
(3) the harassment complained of was based on his disability and/or
prior EEO activity; (4) the harassment had the purpose or effect of
unreasonably interfering with his work performance and/or creating an
intimidating, hostile, or offensive work environment; and (5) there is a
basis for imputing liability to the employer. See Flowers v. Southern
Reg'l Physician Serv. Inc., 247 F.3d 229 (5th Cir. 2001); see also Fox
v. General Motors Corp., 247 F.3d 169 (4th Cir. 2001). The harasser's
conduct should be evaluated from the objective viewpoint of a reasonable
person in the victim's circumstances. Enforcement Guidance on Harris
v. Forklift Systems Inc., EEOC Notice No. 915.002 (March 8, 1994).
Upon review of the record, we find that Complainant has established
his claim of harassment based on his disability and protected activity.
As noted above, Complainant is a qualified individual with a disability
who has requested reasonable accommodations based on his hearing
limitations which were a result of cancer treatment in 2000 and the
on-the-job injury in 2005. Complainant has also filed prior EEO
complaints alleging violation of the Rehabilitation Act. Clearly,
Complainant was subjected to unwelcome conduct which was based on his
disability and his prior protected activity. We note that the conduct
complained by Complainant either involved his disability and/or began
only after he began requesting reasonable accommodations.
Finally, the Commission finds that Complainant has complained of events
which had the purpose and effect of unreasonably interfering with
Complainant's workplace. Complainant indicated that the harassment
began in 2008, when Manager 1 suggested that Complainant seek a medical
retirement. Complainant stated that Manager 1 reminded him that another
employee had received a medical retirement and that Complainant should
contact her. Shortly thereafter, Manager 2 told Complainant that he
should retire and buy a motor home event though he had not reached full
retirement age. In 2009, Complainant stated that he was told for the
first time in 18 years that he could no longer use his own vehicle during
work and needed to use the government vehicle. Complainant explained
that he needed to stop and snack often as a side effect from his cancer
treatment. In addition, Complainant noted that it would be difficult
for him to drive out to a location and return to the office in order to
retrieve his own car.
In addition, we find that the events Complainant raised regarding the
Smartlink were not only a denial of reasonable accommodation but also
created a hostile work environment. We note that Complainant averred
that management would regularly refuse to properly place the Smartlink
transmitter closer to the speaker so that Complainant could not only
hear but understand what was said. Based on management's lead regarding
the use of the Smartlink, Complainant's co-workers believed that they
were not required to use the transmitter properly either. As a result,
Complainant was treated poorly by both management and co-workers.
In connection with management's reason for not holding the Smartlink
device, Manager 1 stated that Complainant had poor hygiene as exhibited
by his excessive coughing and reports of not washing hands after use of
the restrooms. Complainant stated that he has a cough which is caused
by excessive post-nasal drip related to his cancer treatments from 2000.
We note that there is no support for Manager 1's statement regarding
Complainant's lack of hand washing. The Commission is concerned that
management used Complainant's coughing to assert that he had hygiene
issues particularly since Complainant's coughing is a remaining side
effect from his cancer treatment. In addition, Complainant averred
that he has a co-worker who does hold the Smartlink when speaking with
Complainant. Complainant also stated that this co-worker would not
hold the transmitter within view of management because of management's
negative attitude toward Complainant and the proper use of the Smartlink
device. Therefore, we find that the co-workers' resistance to holding
the Smartlink is based on management's discouragement rather than
Complainant's purported hygiene issues. As such, we conclude that
Complainant has been subjected to a hostile work environment based on
his disability and prior protected activity.
Finally, as to the part (5) of a claim, we find that Complainant has met
his burden in establishing that there is a basis for imputing liability on
the Agency. Accordingly, we conclude that Complainant has established
that he was subjected to harassment based on his disability and his
prior protected activity.
Constructive Discharge
We note that Complainant also asserted that the harassment and denial
of reasonable accommodation resulted in his disability retirement or
constructive discharge. The central question in a constructive discharge
case is whether the employer, through its unlawful discriminatory behavior
made the employee's working conditions so difficult that any reasonable
person in the employee's position would feel compelled to resign. The
Commission has established three elements which a complainant must prove
to substantiate a claim of constructive discharge: (1) a reasonable person
in the complainant's position would have found the working conditions
intolerable; (2) conduct that constituted discrimination against the
complainant created the intolerable working conditions; and, (3) the
complainant's involuntary resignation resulted from the intolerable
working conditions. See Walch v. Dep't of Justice, EEOC Request
No. 05940688 (April 13, 1995); Christoph v. Dep't of the Air Force,
EEOC Request No. 05880575 (April 6, 1990). After careful consideration,
viewing all of the circumstances presented here, we find that the same
discriminatory hostile work environment created by management and the
co-workers and the denial of reasonable accommodation was sufficiently
severe as to result in objectively intolerable working conditions, and
that Complainant reasonably felt compelled to resign because of these
conditions.
CONCLUSION
Based on a thorough review of the record and the contentions on appeal,
including those not specifically addressed herein, we AFFIRM in part
and REVERSE in part the Agency's final decision.
ORDER (D0610)
The Agency is ordered to take the following remedial action:
1. Within 30 days of the date this decision becomes final, the agency
shall offer complainant reinstatement to his position as an Aviation
Safety Inspector. Complainant must respond to the Agency's offer within 30
days of its receipt. The position must be at the level that Complainant
would have occupied but for the discrimination and constructive discharge,
including all promotions and step increases.
2. The Agency shall take steps to insure that Complainant is no longer
subjected to harassment by his co-workers and management. The Agency
shall monitor aggressively the environment to accomplish this.
3. The Agency shall provide EEO sensitivity training to all employees
in the office at issue, designed to eliminate acts of harassment in the
workplace.
4. The Agency shall consider taking disciplinary action against the
responsible management officials and the co-workers who engaged in the
harassing conduct. The Agency shall report its decision in its compliance
report to EEOC. 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. It should be noted that the Commission does
not consider training to be a disciplinary action.
5. The Agency shall conduct a supplemental investigation pertaining
to complainant's entitlement to compensatory damages incurred as a
result of the agency's discriminatory actions in this matter. The
Agency shall afford complainant sixty (60) days to submit additional
evidence in support of a claim for compensatory damages. Complainant
shall submit objective evidence (pursuant to the guidance given in
Carle v. Dep't of the Navy, EEOC Appeal No. 01922369 (January 5, 1993))
in support of his claim. Within forty-five (45) days of its receipt
of complainant's evidence, the agency shall issue a final decision
determining complainant's entitlement to compensatory damages, together
with appropriate appeal rights.
6. The agency shall complete all of the above actions within 120 calendar
days from the date on which the decision becomes final.
7. 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. The 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 the Complainant for the undisputed
amount within sixty (60) calendar days of the date the Agency determines
the amount it believes to be due. The 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."
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 of the
Agency's calculation of backpay and other benefits due Complainant,
including evidence that the corrective action has been implemented.
POSTING ORDER (G0610)
The Agency is ordered to post at its Flight Standards District
Office facility in Scottsdale, Arizona, 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 (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
December 1, 2010
__________________
Date
2
0120103125
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
2
0120103125