0120101848
05-25-2012
Paulette Jones, et al., Complainant, v. Patrick R. Donahoe, Postmaster General, United States Postal Service, Agency.
Paulette Jones, et al.,
Complainant,
v.
Patrick R. Donahoe,
Postmaster General,
United States Postal Service,
Agency.
Appeal No. 0120101848
Hearing No. 570-2009-00123X
Agency No. 6H-000-0002-05
DECISION
On March 23, 2010, Complainant, as the class agent, filed an appeal from the Agency's final order concerning her class equal employment opportunity (EEO) complaint of unlawful employment discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII), as amended, 42 U.S.C. � 2000e et seq. The appeal is accepted pursuant to 29 C.F.R. � 1614.405. For the reasons that follow, the Agency's final order is REVERSED.
ISSUE PRESENTED
The issue presented on appeal is whether the EEOC Administrative Judge (AJ) properly determined that the class complaint should not be certified on the grounds that it failed to meet the criteria set forth in the Commission's regulations at 29 C.F.R. � 1614.204(a)(2).
BACKGROUND
At the time of events giving rise to this complaint, Complainant worked as a Postal Inspector, ISLE-14, at the United States Postal Inspection Service, Philadelphia Division. Complainant filed an EEO complaint dated March 29, 2005, alleging that on November 10 and 17, 2004, she was denied promotional opportunities based on her race (African-American) and sex. Complainant alleged that these non-selections are part of a continuing pattern and practice of discriminatory promotion practices at the Agency. Complainant sought certification of a class that includes all African-American female Postal Inspectors at the ISLE-12 level and above who were systematically denied, or deterred from applying for, promotions at the Agency. The promotion deterrence/denial claim also includes a claim that the Agency delayed giving time-in-grade promotions to African-American female Postal Inspectors at the ISLE-12 level and above.
Complainant's complaint was forwarded to the EEOC Washington Field Office for a decision on class certification. The AJ issued a decision on August 2, 2005, denying certification of the class. Thereafter, Complainant appealed the Agency's final order adopting the AJ's decision to the EEOC's Office of Federal Operations (OFO). In Paulette Jones, et al. v. United States Postal Service, EEOC Appeal No. 0120060367 (October 8, 2008), we vacated the Agency's final order adopting the AJ's decision and remanded the case for further processing. We noted that the record was lacking information to determine whether the Agency properly denied certification of the purported class. We ordered the Agency to forward the entire record to the EEOC Washington Field Office and request that an AJ be assigned for the purpose of taking additional discovery to obtain information absent from the record. We ordered that discovery must include the race and sex of persons who were not selected for the Career Leadership Program (CLP) and ISLE-13 through ISLE-15 level positions. We also ordered that discovery must include the race and sex of persons not placed on the ISLE-15 Selection Register during the relevant period. We ordered the Agency to request that an AJ be assigned to render another decision on class certification after completion of the discovery phase.
On remand, the same AJ was again assigned to the matter, and issued a second decision on February 4, 2010, once more denying class certification. The AJ noted that on March 9, 2009, the Agency provided supplemental discovery materials in accordance with the OFO's October 8, 2008, decision and order. The AJ also noted that Complainant failed to respond to her Order to Show Cause to determine whether any discovery disputes remained.
With respect to class certification, as in her first decision, the AJ found that Complainant failed to establish the commonality, typicality, and numerosity. The AJ, with regard to commonality, again found that Complainant failed to identify a centralized selection policy applicable to all Postal Inspectors at the ISLE-12 level and above. The AJ once more noted that the promotion processes for the ISLE-12, 13, 14, and 15 levels are different. The AJ noted that the promotional process for the ISLE 12 and 13 levels is noncompetitive, unlike the process for ISLE-14. The AJ therefore found no thread of commonality. With regard to typicality, the AJ again noted that Complainant failed to identify a uniform employment practice or policy that had a discriminatory effect or impact on the putative class as a whole. With respect to numerosity, the AJ once more noted that because Complainant had not satisfied the commonality and typicality requisites, it was difficult to determine how many employees share any factual or legal issues common to the class. As such, the AJ found that Complainant failed to show that the number of potential class members was sufficiently large enough to satisfy the numerosity requirement. As, such the AJ determined that the class should not be certified.
Thereafter, on February 23, 2010, the Agency issued its final order, which again fully implemented the AJ's decision denying class certification. Following the Agency's final order, Complainant filed the instant appeal.
CONTENTIONS ON APPEAL
Complainant's Contentions on Appeal
On appeal, Complainant contends that the Agency utilizes a highly-centralized training and promotion system to select Postal Inspectors. Complainant contends that this centralized advancement system has been off-limits to almost all of the Agency's African-American female Postal Inspectors. Complainant contends that she applied for approximately 25 vacancies for ISLE-15 level positions over a two-year period and every vacancy went to an employee who was not an African-American female. Complainant contends that she has spoken to other African American-female Postal Inspectors about their own troubles in career advancement. Complainant indentifies another potential class member who reportedly applied for at least 12 ISLE-14 level positions and was never selected.
Complainant additionally contends that promotion to the ISLE-13 level is supposed to be non-competitive, but instead is subject to the discretion of Agency management, negatively affecting African-American female Postal Inspectors. Complainant identifies another potential class member who testified that other Postal Inspectors were promoted to the ISLE-13 level while she was not. Complainant contends that although this class member was eventually promoted to the ISLE-13 level, it took much longer than other similarly-situated employees outside of her protected classes.
Complainant contends that during Fiscal Year 2004, out of 43 promotions to the ISLE-14 level, only one was as an African-American female Postal Inspector. Complainant contends that only 6 of the 136 candidates accepted to the CLP were African-American females. Complainant contends that admission to the CLP is determined by the Chief Postal Inspector and the CLP Review Board. Complainant contends that the CLP is a very important gateway for advancement because ISLE-14 Postal Inspectors who complete it are to be automatically included on the Selection Register for ISLE-15 positions. Complainant contends that only two African-American females have been included on the ISLE-15 Selection Register for the period of January 1, 2002, to February 18, 2005. Complainant further contends that no African-American females have been promoted to the ISLE-15 level since January 1, 2001. Complainant contends that African- American females represent less than two percent of all Postal Inspectors holding ISLE-15 level Assistant Inspector-in-Charge positions.
Complainant also contends that in 2009, a routine e-mail was sent to an Inspector-in-Charge (IC) along with the Agency's Miami Division Distribution List. The e-mail summarized a conference call and read, "[T]his week's quote: 'A true friend should be held with both hands' - African Proverb." Complainant contends that this IC by mistake hit the "reply all" e-mail function and sent the following message: "is this the same as 'cuidado con el negro?'" Complainant contends that this phrase is translated as "be careful with Blacks." Complainant contends that this IC was the primary architect of the Agency's CLP and served as the CLP Review Board Chairman. Complainant contends that the e-mail is direct evidence of discriminatory animus.
Complainant additionally contends that the Chief Postal Inspector plays a controlling role in the entire system of promotion determinations for Postal Inspectors. Complainant contends that promotion decisions are either made by the Chief Postal Inspector, or by a panel appointed by the Chief Postal Inspector. Complainant contends that the Chief Postal Inspector participates as part of the CLP Review Board, in addition to designating the other board members. Complainant contends that an internal review of the Agency's personnel system emphasized problems with the Agency's centralized selection system. The Agency's internal review noted:
[T]he methodology for assignment of new inspectors is problematic. . . . [I]t fixes accountability for placement directly in the hands of the Chief Inspector and the Assistant Chief Inspector of Administrative Operations. If a class action law suit were ever filed based on adverse impact (i.e., facially neutral employment practice which impacts disparately on a particular group), the Chief and the [Assistant] would be called to testify. Most organizations try to avoid this possibility as it applies to a national practice that would make a class action law suit more difficult to defend.
Complainant contends that the Agency's promotion system is far more unitary than systems involved in other class complaints certified by the Commission. Complainant contends the Agency's promotion system for Postal Inspectors is centralized under an overarching policy structure that is under the complete control of the Chief Postal Inspector, the Assistant Chief Inspector, and selecting boards and panels established by the Chief. Complainant contends that the Agency's centralized advancement system has been off limits to almost all of the Agency's African-American female Postal Inspectors, a class of approximately 85 potential members.
The Agency's Response
In response, the Agency asserts that Complainant has not established the existence of a centralized selection policy. The Agency asserts that there are separate and distinct selection processes for level ISLE-13, 14, and 15 positions, which are made by different managers nationwide. The Agency also asserts that the purported class is impossible to indentify without an individual inquiry for each member. The Agency asserts that there are members of the purported class who have never applied for a competitive promotion or admission to the CLP. The Agency asserts that only 13 African-American females have applied to the CLP and 10 were selected. The Agency asserts that neither Complainant nor any other indentified class member adequately represent the class of African American females who have applied for an ISLE-14 level position and were rejected because each of them have been promoted to that level years ago. The Agency also asserts that it has operated with three African-American females in ISLE-15 level positions since 2001.
The Agency further asserts that Complainant as the class agent has failed to establish a prima case of disparate treatment. The Agency asserts that the IC's e-mail translated to "Be careful with Blacks" was written in 2009, five years after Complainant applied for ISLE-15 vacancies that triggered her complaint. The Agency asserts that Complainant was accepted to both the CLP and the ISLE-15 Selection Register as soon as she became eligible.
The Agency additionally asserts that Complainant failed to establish all of the following elements of class certification: commonality, typicality, numerosity, and adequacy of representation. With respect to commonality, the Agency asserts that affidavits of prospective class members reveal that their class claims are different than Complainant's. The Agency asserts that no testimony points to a specific policy or practice of discrimination. Regarding typicality, the Agency asserts that Complainant is seeking to represent Postal Inspectors at different job levels in different locations throughout the country. The Agency asserts that some of these Postal Inspectors might have been ineligible for the CLP process and others might not have applied or been accepted. With regard to numerosity, the Agency asserts that Complainant can point to no African-American female who could not advance to the ISLSE-13 level. The Agency asserts that Complainant could only point to two ISLE-14 applicants and three CLP applicants who could possibly be included in the class. As such, the Agency asserts that potential class members are not so numerous as to make a consolidated complaint impractical. Regarding adequacy of representation, the Agency asserts that it is not clear whether Complainant has a discrimination claim at all. The Agency asserts that Complainant can not adequately represent the many diverse factual situations of the class. The Agency asserts that Complainant as the class agent has a conflict of interest with other prospective members of the class because Complainant was competing against class members for a limited amount of vacant positions. Therefore, the Agency requests that we affirm the AJ's decision rejecting class certification.
ANALYSIS AND FINDINGS
EEOC Regulation 29 C.F.R. � 1614.204(a)(2) states that a class complaint is a written complaint of discrimination filed on behalf of a class by the agent of the class alleging that: (i) the class is so numerous that a consolidated complaint of the members of the class is impractical; (ii) there are questions of fact common to the class; (iii) the claims of the agent are typical of the claims of the class; and (iv) the agent of the class, or if represented, the representative will fairly and adequately represent the interests of the class. EEOC Regulation 29 C.F.R. � 1614.204(d)(2) provides that a class complaint may be dismissed if it does not meet the four requirements of a class complaint or for any of the procedural grounds for dismissal set forth in 29 C.F.R.
� 1614.107.
Commonality and Typicality
The purpose of the commonality and typicality requirements is to ensure that a class agent possesses the same interests and has experienced the same injury as the members of the proposed class. See General Telephone Co. of Southwest v. Falcon, 457 U.S. 147 (1982). While these two criteria tend to merge and are often indistinguishable, they are separate requirements. Id. Commonality requires that there be questions of fact common to the class; that is, that the same agency action or policy affected all members of the class. Typicality, on the other hand, requires that the bases of the class agent be typical of the claimed bases of the class. The underlying rationale of the typicality and commonality requirement is that the interests of the class members be fairly encompassed within the class agent's claim. Id.
In the instant case, we find that the AJ improperly determined that the legal requirements of commonality and typicality were not met. Complainant's and other African-American female Postal Inspector's lack of promotional opportunity combined with the Agency's internal review, which noted that the Chief Inspector and the Assistant Chief Inspector were directly accountable for the assignment of Postal Inspectors, is a sufficient factual basis to infer a policy or practice of discrimination at work. We note that the Agency does not address its internal review on appeal. We further note that there is no dispute that the IC was chairman of the CLP review board and involved in many promotional decisions for Postal Inspectors, and his e-mail translated to "be careful with Blacks" is further evidence to infer that a policy or practice of discrimination is at work. See Fitzgerald v. Dep't of Defense, Appeal No. 0720090003 (Mar. 26, 2010) (finding that a lack of promotional opportunity together with ranking done by a central rating board with commander approval was a sufficient factual basis to infer that a policy or practice of discrimination was at work).
In applying the legal requirements of commonality and typicality, we note that Complainant asserts that she applied for approximately 25 vacancies for ISLE-15 positions over a two-year period. Complainant asserted that every one of these vacancies went to a Postal Inspector who was not an African-American female. Further, we note that another African-American female Postal Inspector testified that she interviewed for at least 12 ISLE-14 positions from January 2002 to March 2005, but was not selected. This African-American female Postal Inspector testified that it was her belief, with the exception of one position, that the Agency's selections were not African-American females. Another African-American female Postal Inspector testified that she applied for seven ISLE-14 level positions in one year, but was not selected. She testified that it was her belief that six of the seven vacancies went to candidates who were not African-American female. Also, an additional African-American female Postal Inspector testified that her promotion to the ISLE-13 position was initially rejected, and she was only promoted when she initiated an EEO complaint. This African-American female Postal Inspector testified, "I have seen many similarly-qualified Postal Inspectors who were not African-American quickly promoted to the ISLE-13 level, and I believed that my race and sex were motivating factors in the Agency's decision not to promote me." We find that Complainant has established commonality.
We also find that Complainant's injury and interests are typical to the class. The Agency asserts that Complainant is seeking to represent Postal Inspectors at different job levels in different locations throughout the country. However, we note that the Commission has previously certified classes where a policy or practice affects a group of employees at different grade levels nationwide. See McConnell, et al. v. U.S. Postal Serv., EEOC Appeal No. 0720080054 (Jan. 14, 2010) (certifying a class of employees that were affected by an agency policy that had been implemented nationwide); Tarrats, Rivera, et al. v. Federal Deposit Insurance Corp., EEOC Appeal No. 01A41422 (Nov. 15, 2004) (certifying a class of all Hispanic employees at all grade levels who were not recruited, promoted, or assigned to positions of greater responsibility, including upper and senior management positions). The Agency also asserts that it is not clear whether Complainant has a discrimination claim at all. However, we note that Complainant need not prove discrimination at the class certification stage. See Fitzgerald, Appeal No. 0720090003. Rather, the Agency's assertion that Complainant was not promoted due to a legitimate, non-discriminatory reason goes to the merits of the complaint. Therefore, we find that Complainant has established the Commonality and Typicality requirements for class certification.
Numerosity
The numerosity prerequisite states that the potential class must be sufficiently numerous so that a consolidated complaint by the members of the class, or individual, separate complaints from members of the class is impractical. See 29 C.F.R. � 1614.204(a)(2)(i). The focus in determining whether the class is sufficiently numerous for certification is the number of persons affected by the agency's alleged discriminatory practice(s). See White, et al. v. Dept of the Air Force, EEOC Appeal No. 01A42449 (Sep. 1, 2005). The Commission has held that the relevant factors to determine whether the numerosity requirement has been met are the size of the class, the geographical dispersion of the class, the ease with which class members may be identified, the nature of the action at issue, and the size of each member's claim. Carter, et al. v. U.S. Postal Serv., EEOC Appeal No. 01A24926 (Nov. 14, 2003). The United States Supreme Court has held that the numerosity requirement of Federal Rule of Civil Procedure 23 does not impose a numerical minimum or cut-off point for the size of the class but, instead, requires an examination of the facts of each case. General Telephone Co. of the Northwest, Inc. v. EEOC, 446 U.S. 318, 330 (1980); Harriss v. Pan American World Airways, Inc. 74 F.R.D. 24 (N.D. Cal. 1977).
In the present case, Complainant specifically indentifies three other African-American female postal inspectors who also allege that their attempts at receiving a promotion and advancement were either denied or delayed by the Agency. Additionally, Complainant stated her belief that other African-American female Postal Inspectors, as many as 85, suffered similar treatment from January 1, 2001 until the present.
We note that although the Commission's requirements for an administrative class complaint are patterned on the Rule 23 requirements, Commission decisions in administrative class certification cases should be guided by the fact that an administrative complainant has not had access to pre-certification discovery in the same manner and to the same extent as a Rule 23 plaintiff. See Tschappat v. Dep't of Labor, EEOC Appeal No. 07A40074 (May 5, 2005), req. for recon. den'd, EEOC Request No. 05A50938 (Sep. 15, 2005) (citing Moten, et al. v. Federal Energy Regulatory Commission, EEOC Request No. 05910504 (Dec. 30, 1991)). Moreover, the exact number of class members need not be shown prior to certification. Id. However, in the administrative process, as in the court process, the correct focus in determining whether a proposed class is sufficiently numerous for certification purposes is on the number of persons who possibly could have been affected by the Agency's allegedly discriminatory practices and who, thus, may assert claims. Id. Therefore, we find that Complainant has met the numerosity requirement, bearing in mind that even after the class is certified, the AJ retains the authority to redefine a class, subdivide a class, or recommend dismissal of a class if it becomes apparent that there is no longer a basis to proceed with the class complaint as initially defined. 1 See Cyncar v. U.S. Postal Serv., EEOC Appeal No. 0720030111 (Feb. 1, 2007) req. for recon. den'd, EEOC Request No. 0520070348 ( May 1, 2007) (citing Hines, et al. v. Dep't of the Air Force, EEOC Request No. 05940917 (Jan. 29, 1996)).
Adequacy of Representation
The final requirement is that the Class Agent, or his or her representative, adequately represents the class. To satisfy this criterion, the agent or representative must demonstrate that he or she has sufficient legal training and experience to pursue the claim as a class action, and will fairly and adequately protect the interests of the class. Besler, et al. v. Dep't of the Army, EEOC Appeal No. 01A05565 (Dec. 6, 2001); Woods v. Dep't of Housing and Urban Development, EEOC Appeal No. 01961033 (Feb. 13, 1998). In this regard, it is necessary for the class agent, or the representative, to demonstrate sufficient ability to protect the interests of the class so that the claims of the class members do not fail for reasons other than their merits. Id.
Upon review of the record, we find that the law firm representing Complainant as the class agent in the instant matter is clearly experienced in class actions. The record shows that the legal team has more than sufficient legal training and experience to pursue the instant claim as a class action and will protect the interests of the class. We note that the Agency has challenged neither the skills nor experience of the attorneys representing the potential class. Accordingly, we find that Complainant as the class agent found representation to adequately represent the class. We find that Complainant as the class agent has no apparent conflict of interest with other members of the class and is represented by adequate counsel.
CONCLUSION
Therefore, we REVERSE the Agency's final order adopting the AJ's decision rejecting class certification and we REMAND this matter to the Agency to take action in accordance with the ORDER below.
ORDER
The Agency is ORDERED to take the following actions:
1. Notify potential class members of the accepted class claim within fifteen (15) calendar days of the date this decision becomes final, in accordance with 29 C.F.R. � 1614.204(e).
2. Forward a copy of the class complaint file and a copy of the notice to the Hearings Unit of the Washington Field Office within thirty (30) calendar days of the date this decision becomes final. The Agency must request that an Administrative Judge be appointed to hear the certified class claim, including any discovery that may be warranted, in accordance with 29 C.F.R.
� 1614.204(f).
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 actions.
IMPLEMENTATION OF THE COMMISSION'S DECISION (K0610)
Compliance with the Commission's corrective action is mandatory. The Agency shall submit its compliance report within thirty (30) calendar days of the completion of all ordered corrective action. The report shall be submitted to the Compliance Officer, Office of Federal Operations, Equal Employment Opportunity Commission, P.O. Box 77960, Washington, DC 20013. The Agency's report must contain supporting documentation, and the Agency must send a copy of all submissions to the Complainant. If the Agency does not comply with the Commission's order, the Complainant may petition the Commission for enforcement of the order. 29 C.F.R. � 1614.503(a). The Complainant also has the right to file a civil action to enforce compliance with the Commission's order prior to or following an administrative petition for enforcement. See 29 C.F.R. �� 1614.407, 1614.408, and 29 C.F.R. � 1614.503(g). Alternatively, the Complainant has the right to file a civil action on the underlying complaint in accordance with the paragraph below entitled "Right to File a Civil Action." 29 C.F.R. �� 1614.407 and 1614.408. A civil action for enforcement or a civil action on the underlying complaint is subject to the deadline stated in 42 U.S.C. 2000e-16(c) (1994 & Supp. IV 1999). If the Complainant files a civil action, the administrative processing of the complaint, including any petition for enforcement, will be terminated. See 29 C.F.R. � 1614.409.
STATEMENT OF RIGHTS - ON APPEAL
RECONSIDERATION (M0610)
The Commission may, in its discretion, reconsider the decision in this case if the Complainant or the Agency submits a written request containing arguments or evidence which tend to establish that:
1. The appellate decision involved a clearly erroneous interpretation of material fact or law; or
2. The appellate decision will have a substantial impact on the policies, practices, or operations of the Agency.
Requests to reconsider, with supporting statement or brief, must be filed with the Office of Federal Operations (OFO) within thirty (30) calendar days of receipt of this decision or within twenty (20) calendar days of receipt of another party's timely request for reconsideration. See 29 C.F.R. � 1614.405; Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614 (EEO MD-110), at 9-18 (November 9, 1999). All requests and arguments must be submitted to the Director, Office of Federal Operations, Equal Employment Opportunity Commission, P.O. Box 77960, Washington, DC 20013. In the absence of a legible postmark, the request to reconsider shall be deemed timely filed if it is received by mail within five days of the expiration of the applicable filing period. See 29 C.F.R. � 1614.604. The request or opposition must also include proof of service on the other party.
Failure to file within the time period will result in dismissal of your request for reconsideration as untimely, unless extenuating circumstances prevented the timely filing of the request. Any supporting documentation must be submitted with your request for reconsideration. The Commission will consider requests for reconsideration filed after the deadline only in very limited circumstances. See 29 C.F.R. � 1614.604(c).
COMPLAINANT'S RIGHT TO FILE A CIVIL ACTION (R0610)
This is a decision requiring the Agency to continue its administrative processing of your complaint. However, if you wish to file a civil action, you have the right to file such action in an appropriate United States District Court within ninety (90) calendar days from the date that you receive this decision. In the alternative, you may file a civil action after one hundred and eighty (180) calendar days of the date you filed your complaint with the Agency, or filed your appeal with the Commission. If you file a civil action, you must name as the defendant in the complaint the person who is the official Agency head or department head, identifying that person by his or her full name and official title. Failure to do so may result in the dismissal of your case in court. "Agency" or "department" means the national organization, and not the local office, facility or department in which you work. Filing a civil action will terminate the administrative processing of your complaint.
RIGHT TO REQUEST COUNSEL (Z0610)
If you decide to file a civil action, and if you do not have or cannot afford the services of an attorney, you may request from the Court that the Court appoint an attorney to represent you and that the Court also permit you to file the action without payment of fees, costs, or other security. See Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. � 2000e et seq.; the Rehabilitation Act of 1973, as amended, 29 U.S.C. �� 791, 794(c). The grant or denial of the request is within the sole discretion of the Court. Filing a request for an attorney with the Court does not extend your time in which to file a civil action. Both the request and the civil action must be filed within the time limits as stated in the paragraph above ("Right to File a Civil Action").
FOR THE COMMISSION:
______________________________
Carlton M. Hadden, Director
Office of Federal Operations
May 25, 2012
Date
1 In Paulette Jones v. United States Postal Service, EEOC Appeal No. 0120060367 (Oct. 8, 2008), we found that the record was insufficient and ordered the Agency to conduct additional discovery to include the race and sex of persons who were not selected for the CLP, ISLE-13 through ISLE-15 level positions, and not placed on the ISLE-15 Selection Register. On March 9, 2009, the Agency provided supplemental discovery materials to the AJ and Complainant in reference to our October 8, 2008, decision and order. After reviewing these discovery materials provided by the Agency, we can find no documentation clearly listing the race and sex of persons who were not selected for ISLE-13 to ISLE-15 level positions. However, we find that Complainant has provided sufficient evidence to support class certification.
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0120101848
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
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