Kim S.,1 Complainant,v.Robert M. Speer, Acting Secretary, Department of the Army, Agency.

Equal Employment Opportunity Commission

Apr 21, 2017

0120150575 (E.E.O.C. Apr. 21, 2017)

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013

Kim S.,1
Complainant,

v.

Robert M. Speer,
Acting Secretary,
Department of the Army,
Agency.

Appeal No. 0120150575

Hearing No. 531-2014-00099X

Agency No. ARAPG12MAR04368

DECISION

On November 21, 2014, Complainant filed an appeal, pursuant to 29 C.F.R. § 1614.403(a),
from the Agency’s October 23, 2014, final order concerning her 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. For
the following reasons, the Commission AFFIRMS the Agency’s final order.

BACKGROUND

At the time of events giving rise to this complaint, Complainant worked as a Program Analyst,
GS-0304-11, in the Department of the Army, Communications Electronics Command Logistics
and Readiness Center (CECOMLRC), Enterprise Soldier Aviation Directorate (ESA), in
Aberdeen, Maryland. On November 20, 2012, Complainant filed an EEO complaint alleging
that the Agency discriminated against her on the basis of disability (Cerebral Palsy) when: (1)
on March 13, 2012, her first-line supervisor (S1) denied her reasonable accommodation
request to telework; (2) in mid-February 2012, CECOM denied her union representation
because she was on 100% telework and not on the base one day a week; (3) from February
2011 to February 2012, she received work request e-mails on her personal computer; (4) on
January 14, 2012, she was placed on 4.25 hours of leave without pay (LWOP); and (5) on

1 This case has been randomly assigned a pseudonym which will replace Complainant’s name
when the decision is published to non-parties and the Commission’s website.
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November 30, 2011, she received a “2” rating on her performance appraisal for the rating
period November 1, 2011 to October 31, 2011.

Following the investigation, the Agency provided Complainant with a copy of the report of
investigation and notice of her right to request a hearing before an EEOC Administrative Judge
(AJ). Complainant timely requested a hearing.

When the Complainant did not object, the AJ assigned to the case granted the Agency’s April
15, 2014, motion for a decision without a hearing and issued a decision without a hearing on
September 24, 2014. The Agency subsequently issued a final order adopting the AJ’s finding
that Complainant failed to prove that the Agency subjected her to discrimination as alleged.

UNDISPSUTED FACTS

Complainant has Cerebral Palsy. Her condition is permanent. She was diagnosed with the
condition as a child. Her condition is progressive; she has significant secondary right arm and
leg weakness, grand mal seizures, hernias, chronic sprains to her arm, migraines, panic
disorder, and asthma.

Complainant’s responsibilities involved managing the travel needs of the people within her
department. She made travel arrangements for employees, controlled disbursements for travel,
and she performed bookkeeping functions for the ESA travel budget. Complainant began
working at the Agency in 1987 at Fort Monmouth, New Jersey. Under the Base Closure and
Realignment Commission (BRAC), her duty station was transferred to Aberdeen Proving
Ground, in Aberdeen, Maryland. In 2010, her condition progressed to the point where she
could not travel to work. In March 2010, the Agency granted her reasonable accommodation
request of 100% working from home (telework). Complainant lives in New Brunswick, New
Jersey, which is roughly 150 miles away from Aberdeen, Maryland.

The telework agreement was a temporary agreement, renewable at regular intervals. Through
the telework agreement, the Agency gave Complainant a laptop for regular use and an alternate
laptop in case of computer malfunction. It also provided Complainant with a printer. During
Complainant's telework period, her computer or internet connection stopped working. As an
accommodation, the Agency sent an information technology (IT) person to Complainant's
home to fix the computer problem. During Complainant's telework agreement, she
infrequently travelled to Aberdeen Proving Ground to meet some work obligations.

On October 6, 2011, Complainant’s doctor (MD) wrote S1, stating that he strongly advised
that Complainant take medical leave from September 27 to October 11, 2011. He attributed
the need for her medical leave to her increased risk of seizures, exacerbated by excessive
stress. Notwithstanding the October 11, 2011 date in his letter, MD asserted that he would not
be able to provide the Agency with a date for Complainant to return to work until her condition
stabilized. On the same day, Complainant also sent S1 an e-mail with a “pdf” file of MD’s
letter. Complainant sent the e-mail from her personal e-mail address to S1’s Agency e-mail.
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In her e-mail, Complainant asked S1 to reply to the personal e-mail address stating that he
received her letter. She also asked S1 to call her at home if he had any questions.

On October 20, 2011, MD wrote S1 to inform him that Complainant's condition had
stabilized, and he anticipated that she could return to work on Monday, October 24, 2011. On
October 23, 2011, Complainant again e-mailed S1 using her personal e-mail address to ask
whether he had received MD’s October 20 letter. In her email, Complainant asked whether
there were any tasks that would require her immediate attention when she returned to work on
October 24. Complainant re-sent the same e-mail the following morning, October 24, from
her work e-mail address.

On November 1, 2011, MD wrote that Complainant's disability prevented her from commuting
and ambulating in an office. He ruled out the use of a wheelchair due to her hand and arm
weakness. MD recommended that Complainant permanently telework. Complainant returned
to work. On or about November 30, 2011, she also received her annual performance appraisal
in which S1 rated her performance element as “Excellent,” and rated her overall performance
as “Successful.” On December 5, 2011, Complainant e-mailed S1, her second-line supervisor
(S2) and a Human Resources Specialist (HR) to contest her evaluation. HR responded that to
contest her appraisal, she should contact her union representative (U1).

Complainant was seen again by MD on December 6, 2011, who determined that her condition
required that she take an indefinite medical leave. The same day, a social worker (SW) who
was working with MD, e-mailed S1 and S2 to inform them that Complainant would be out of
work on an indefinite leave of absence due to her medical condition. SW’s email directed that
“[Complainant] has been ordered by her neurologist to take a break and recuperate with no
disruptions.” During her absence from work, S1 communicated with MD about the nature of
Complainant’s disability and possible reasonable accommodations. Their correspondence
focused on an alternative work schedule for Complainant. During that correspondence, MD
told S1 that Complainant would be able to return to work on January 18, 2012. S1 told MD
that Complainant’s work was mission critical, and that she was needed on Mondays and
Fridays. Any alternative work schedule in which she was absent on Mondays or Fridays was
not acceptable. On Friday, January 13, 2012, Complainant e-mailed S1 and S2 using her
personal e-mail address. She stated that, in contrast to what S1 claimed, prior to 2010 she had
always worked a compressed work schedule in which her regular day off was on Monday. She
claimed that her work schedule was changed in 2010, and her subsequent attempts to alter it
back had been denied, as recently as November 2011. Finally, she framed the need for
Mondays as a day off in the context of her disability, stating that she required three days out of
work to recuperate and reduce the chance of a disability-related injury.

S1 responded to Complainant's e-mail from her personal e-mail address the following day. He
told Complainant that he was happy to have her back to work, and that there would be a staff
meeting that Wednesday. He suggested that she call in to listen to the meeting. On the
alternate work schedule issue, he informed her that having every Monday off was not an
option, given their work requirements. He suggested three options: (1) a four-day compressed
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work schedule with a regular day off on Tuesday, Wednesday, or Thursday; (2) her current
alternate work schedule of every other Monday off; or (3) a regular 40-hour work week.
Complainant responded to S1’s e-mail with a proposed fourth option, where she worked a
compressed work schedule, with her regular day off alternating each week between Mondays
and Tuesdays.

On Tuesday, January 17, 2012, Complainant sent S1 another e-mail from her private e-mail
account. In her e-mail, she reiterated her request for an alternating regular day off and asked
S1 to confirm that he received her messages. The same day, Complainant and S1 traded
another set of e-mails, also from Complainant’s personal e-mail. They confirmed the work
arrangement Complainant proposed. Complainant also stated that she would not be returning
to work based on their disagreement about Complainant’s proposed alternate work schedule.
S1 sent Complainant a final e-mail on January 17 stating that he spoke with his supervisors and
they determined that any work schedule in which Complainant would be absent on Mondays or
Fridays would not be in keeping with the Agency’s mission requirements. He asked
Complainant to speak with her medical team and advise. On January 19, 2012, U1 e-mailed
S1 and S2 to inform them that the union was representing Complainant. In his e-mail, U1
stated that, pursuant to MD, all correspondence concerning Complainant must be sent through
him.

On January 21, 2012, S1 e-mailed Complainant. He sent the message to Complainant’s work
and personal e-mail, and he copied U1 in the body of the message. S1 reminded Complainant
to fill out the SF-71, requesting leave, if she intended to be out the following week. He also
stated that the Agency would be meeting with U1 the following week to discuss Complainant’s
alternate work schedule. S1 wrote Complainant on February 2, 2012, stating that the Agency
was willing to try, on a provisional basis, Complainant's proposal of a compressed work
schedule, with alternating regular days off on Monday and Tuesday. He requested additional
information about Complainant’s medical restrictions and diagnoses by no later than February
17, 2012. He also reminded Complainant that he expected her to return to work on February
6, 2012, and that if she did not return to work, her absence would be identified as Absent
Without Leave until she produced updated medical records. In response, Complainant stated
that S1’s letter contained inaccurate information about her request to change her schedule.
Complainant referred S1 to U1, who she stated would speak with him about their ongoing
dispute.

S1 and U1 met on February 3, 2012. They agreed that Complainant could have a compressed
work schedule where her regular day off was on Mondays. Due to concerns about its impact
on the department, they agreed to a 90-day trial, with an assessment in 60 days. Finally, S1
approved Complainant’s sick leave through February 12, 2012. The Agency approved
Complainant’s 20l2 and 2013 request for 100% telework from home. Complainant’s 2012
telework agreement, approved in March 2012, states that Complainant also works a
compressed work schedule, with her regular day off on Monday.

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ANALYSIS AND FINDINGS

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 (EEO MD-110), at Chap. 9, § VI.B. (Aug. 5, 2015) (providing that an administrative
judge’s determination to issue a decision without a hearing, and the decision itself, will both 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 Chapter 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”).

We must determine whether it was appropriate for the AJ to have issued a decision without a
hearing on this record. 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
Def., EEOC Appeal No. 01A24206 (July 11, 2003). Finally, an AJ should not rule in favor of
one party without holding a hearing unless he or she ensures that the party opposing the ruling
is given (1) ample notice of the proposal to issue a decision without a hearing, (2) a
comprehensive statement of the allegedly undisputed material facts, (3) the opportunity to
respond to such a statement, and (4) the chance to engage in discovery before responding, if
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necessary. According to the Supreme Court, Rule 56 itself precludes summary judgment
“where the [party opposing summary judgment] has not had the opportunity to discover
information that is essential to his opposition.” Anderson, 477 U.S. at 250. In the hearing
context, this means that the administrative judge must enable the parties to engage in the
amount of discovery necessary to properly respond to any motion for a decision without a
hearing. Cf. 29 C.F.R. § 1614.109(g)(2) (suggesting that an administrative judge could order
discovery, if necessary, after receiving an opposition to a motion for a decision without a
hearing).

Upon review of the record, we agree with the AJ’s findings and analysis as set forth below.

Timeliness Issues

On January 27, 2014, Complainant filed a document titled “additional charges that were
previously dropped by the APG, EEO Office.” Complainant’s document recounted twelve
incidents of alleged discrimination and harassment. In his decision, the AJ noted that many of
these allegations were duplicative of the charges the Agency previously investigated, such as
Complainant’s allegations of discrimination concerning the alternate work schedule, and the
allegations of hostile work environment in the e-mail correspondence between S1 and
Complainant. Others were new, such as the allegations of violations of the Health Insurance
Portability and Accountability Act and overtime denial. The AJ concluded that such new
allegations were untimely raised. We agree with the AJ’s findings with respect to these new
allegations.2

Claim 1 – Denial of Reasonable Accommodation

For the purposes of his decision, the AJ assumed, without deciding, that Complainant is a
qualified individual with a disability, within the meaning of the Rehabilitation Act. The AJ
noted that Complainant presented no evidence to support her contention that she was ever

2 We note that one of these allegations concerns Complainant’s claim that the Aberdeen
Proving Ground facilities (offices and restrooms) are not accessible to the disabled. If
Complainant believes that the facilities remain inaccessible, she may wish to pursue filing a
complaint with the U.S. Access Board for the failure of the Agency to ensure its compliance
with the Architectural Barriers Act (ABA), which requires that the design, construction, and
alteration of Federal buildings be done in an accessible manner. See 42 U.S.C. §§ 4151 et
seq. See also Gondos v. Dep't of Health and Human Services, EEOC Request No.
0520120589 (Feb. 25, 2015) (agency failure to insure that newly-constructed facility was
accessible to complainant on move-in date stated a claim of failure to reasonably
accommodate); Latarsha A. v. Fed. Energy Regulatory Comm., EEOC Appeal Nos.
0120123215 & 0120131079 (March 15, 2016) (Complainant was denied a reasonable
accommodation when agency did not insure that agency facility met standards of accessibility
under the Rehabilitation Act).
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denied full-time telework. In fact, the record contains documentary and testimonial evidence
to the contrary.

The AJ further noted that Complainant’s statements to the EEO investigator suggested that she
may have been conflating a denial of telework with a denial of an alternate work schedule for
which her regular day off would be on Mondays. To the extent that Claim 1 includes such an
allegation, the AJ concluded that Complainant’s claim was unsuccessful in that she could not
show an adverse employment action. The AJ noted that the record showed that the parties
engaged in discussions regarding reasonable accommodations, discussions which resulted in
Complainant obtaining the reasonable accommodation that she initially proposed. Specifically,
the undisputed record shows that in January 2012, both Complainant and S1 were engaging in
the interactive process to determine whether the Agency could provide Complainant with a
reasonable accommodation of an alternate work schedule. The process began when MD
requested on Complainant’s behalf a reasonable accommodation of a compressed work
schedule with Complainant’s regular day off on Mondays. S1 informed Complainant’s
representatives, and then Complainant directly when she contacted him, that her proposal
would create an undue hardship. Complainant proposed an alternate work schedule of a
compressed work week with her regular day off alternating between Monday and Tuesday. On
February 2, 2012, S1 granted that request. The same day, Complainant wrote to S1 to state
that she did not make that request for an alternate work schedule. The following day, S1
informed Complainant that, after discussion with her union representative, her initial request of
a compressed work schedule with a regular day off on Mondays was granted. The AJ noted
that Complainant had not disputed the authenticity of the documentary evidence or presented
contrary evidence.

Claim 2 – Denial of Union Representation

The AJ concluded that the record was devoid of evidence suggesting that Complainant’s
disability was connected to the alleged denial of union representation. The AJ noted that the
undisputed record showed that in January and February 2012, U1 represented Complainant in
her reasonable accommodation dispute with the Agency, U1 held himself out to be
Complainant’s agent, and he negotiated the alternative work schedule Complainant requested.
The record is devoid of evidence that U1 ever stopped being her representative. Further, the
AJ noted that Complainant stated in her submission to the EEO Counselor in November 2012
that U1 was her representative and he hand-delivered her complaint to the EEO Counselor.
However, the AJ concluded that even assuming without deciding that at some point in
February 2012, U1 decided to no longer represent Complainant, she offered no evidence to
suggest that the reason for this decision was discrimination on the part of the Agency.

Claim 3 – Emails Between Complainant and S1

Complainant described her e-mail exchanges with S1 as creating a hostile work environment.
Specifically, she alleged that S1 created a hostile work environment by: (a) denying an
alternate work schedule; (b) sending-mails to Complainant's personal computer, using her
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personal e-mail address, and giving her personal e-mail address to the Civilian Personnel
Advisory Center; (c) requesting unnecessary medical documentation from her physicians; and
(d) disseminating her confidential medical information by giving her telework agreement to
third parties. The AJ concluded that Complainant’s allegations were insufficient to create a
hostile work environment. Specifically, the AJ stated that even if true, Complainant’s claims
were not objectively offensive, and had neither the severity nor the pervasiveness necessary to
create a hostile work environment. First, the AJ noted that Complainant initiated the e-mail
communications with S1. The record showed that she e-mailed him from November 2011
through January 2012 using her personal computer and personal e-mail address to discuss her
disability, reasonable accommodations, and time and attendance matters. While the content of
the communications deal with Complainant’s disability, the AJ noted that nothing in the
communications themselves were objectively offensive or derogatory. Second, the AJ noted
that S1 had a duty through the Rehabilitation Act to engage in the interactive process with
Complainant once she indicated that she needed a reasonable accommodation. The record
shows that S1 proposed three options for alternate work plans. As he stated in his email, these
proposals were all made in the context of the Agency’s need for a point of contact to be
available to do travel matters on Mondays. The record shows that Complainant rejected S1’s
proposals. Complainant insisted on her preferred work schedule, both directly and through her
union representative. The AJ found that nothing about that e-mail exchange reflected
harassment rising to the level of a hostile work environment.

The AJ also concluded that S1’s request for medical records was appropriate under the
Rehabilitation Act. The AJ noted that the Agency’s inquiries were spurred by Complainant’s
two requests for reasonable accommodations (i.e., an alternate work schedule and frequent
breaks during her work day). The AJ also noted that S1's inquiries were directed to the
specific concerns Complainant raised in her communications with him and found nothing about
his inquiry constituted harassment based on disability. With respect to Complainant’s
allegation of harassment concerning the dissemination of her medical information, the AJ noted
that the Rehabilitation Act provides that employers may be informed concerning necessary
medical restrictions of employee work duties and necessary accommodations. See 42 U.S.C.
§ 12112(d)(4), incorporating 42 U.S.C. § 12112(d)(3)(B). The AJ further noted that the
undisputed record shows that the people Complainant alleged should not have access to her
telework agreement were human resources personnel who had a right to have this information.
The AJ concluded that Complainant had not established the objectively severe or pervasive
element for a hostile work environment claim based solely on the allegation that a human
resources person reviewed her telework agreement.

Claim 4 - LWOP for 4.25 hours on January 14, 2012

The AJ concluded that Claim 4 was unsuccessful because there was no adverse employment
action established. Specifically, the AJ noted that Complainant alleged that S1 placed her on
leave without pay on January 14, 2012. However, January 14, 2012 was a Saturday which
was not one of Complainant’s work days. The documentary evidence in the record indicates
that Complainant was on medical leave for the whole week preceding January 14, 2012. In
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addition, the Agency's time and attendance records show that Complainant was on paid leave
on January 13, 2012. The AJ further noted that Complainant had not offered contradictory
evidence to the Agency's claims, or suggested that the documents reflecting her time and
attendance were not accurate. Complainant also did not move to amend her complaint to a
different date.

Claim 5 – Performance Appraisal

Assuming the facts in the light most favorable to Complainant, the AJ concluded that the
record is devoid of evidence of disability animus on the part of the responsible management
official. The AJ also noted that Complainant offered no comparators (outside of her protected
class) who received a higher rating. Lastly, the AJ concluded that the comment that an
employee must “walk on water” to get a higher rating was insufficient (without more) to prove
discriminatory animus.

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 Agency's final order, because the Equal Employment Opportunity Commission
Administrative Judge’s issuance of summary judgment was appropriate and a preponderance of
the record evidence does not establish that discrimination occurred.

STATEMENT OF RIGHTS - ON APPEAL
RECONSIDERATION (M0416)

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 Chap. 9 § VII.B (Aug. 5, 2015). All requests and arguments
must be submitted to the Director, Office of Federal Operations, Equal Employment
Opportunity Commission. The requests may be submitted via regular mail to P.O. Box 77960,
Washington, DC 20013, or by certified mail to 131 M Street, NE, Washington, DC 20507. In
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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 (S0610)

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. 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 (Z0815)

If you want to file a civil action but cannot pay the fees, costs, or security to do so, you may
request permission from the court to proceed with the civil action without paying these fees or
costs. Similarly, if you cannot afford an attorney to represent you in the civil action, you may
request the court to appoint an attorney for you. You must submit the requests for waiver of
court costs or appointment of an attorney directly to the court, not the Commission. The court
has the sole discretion to grant or deny these types of requests. Such requests do not alter the
time limits for filing a civil action (please read the paragraph titled Complainant’s Right to File
a Civil Action for the specific time limits).

FOR THE COMMISSION:

______________________________ Carlton M. Hadden’s signature
Carlton M. Hadden, Director
Office of Federal Operations

April 21, 2017
Date