Docstoc

EEOC Decisions

Document Sample
EEOC Decisions Powered By Docstoc
					                                         E.E.O.C.
                             *1 Office of Federal Operations

                       ANTHONY GUIDO, COMPLAINANT,
                                    v.
JO ANNE B. BARNHART, COMMISSIONER, SOCIAL SECURITY ADMINISTRATION, AGENCY.

                                 Appeal No. 07A10004
                       Agency Nos. 98-0060-SSA & 98-0188- SSA
                      Hearing Nos. 100-99-7574X & 100-99-7548X

                                      May 29, 2003

                                        DECISION

Following its October 2, 2000 final order, the agency filed a timely appeal which the
Commission accepts pursuant to 29 C.F.R. § 1614.405. On appeal, the agency requests
that the Commission affirm its rejection of an EEOC Administrative Judge's (AJ) finding
that the agency discriminated against complainant on the basis of his age. The agency
also requests that the Commission affirm its rejection of the AJ's order to retroactively
appoint complainant to the position in question, pay appropriate back pay, award
reasonable attorney's fees, and provide additional relief. For the following reasons, the
Commission REVERSES the agency's final order.

Complainant, an Attorney Advisor employed at the agency's Office of Hearings and
Appeals in Hattiesburg, Mississippi, filed formal EEO complaints with the agency on
August 30, 1997 and December 11, 1997, alleging that the agency had discriminated
against him on the basis of age (70 at the relevant time) when he was not selected for
the position of Administrative Law Judge (ALJ) in March, June, August and October 1997.

At the conclusion of the investigation, complainant was provided a copy of the
investigative report and requested a hearing before an AJ.

Following a hearing, the AJ found that complainant established a prima facie case of age
discrimination, noting that complainant applied and was qualified for the ALJ positions in
question, but was not selected and that numerous applicants significantly younger than
he were selected. The AJ found that the agency failed to articulate legitimate,
nondiscriminatory reasons for its actions. In so finding, the AJ noted that the
recommending official (RO) made the decision to eliminate complainant from
consideration for each of the vacancy announcements and that the selecting official (SO)
did not have the opportunity to review applications that RO did not recommend. The AJ
found that RO could not explain why he failed to recommend complainant to the selecting
official nor why he eliminated complainant from consideration after considering him three
times for each vacancy. The AJ noted that RO was unable to explain these actions even
when given the opportunity to review documents to refresh his recollection. The AJ found
that although RO stated that his decision to only consider complainant three times for
each of the four vacancy announcements was within his discretion and a legitimate
operation of the “Rule of Three,” RO could not explain why he exercised this discretion to
eliminate complainant, but considered 27 other applicants more than three times.[FN1]

The AJ noted that the agency has the burden of articulating a legitimate non-
discriminatory explanation with sufficient specificity and clarity to provide complainant
with an opportunity to demonstrate pretext. The AJ found that the agency failed to rebut
the inference of discrimination established by complainant and concluded that the non-
selections were motivated by complainant's age.
*2 The AJ went on to find that the statistical evidence provided by complainant's expert
established that, from a statistical perspective, complainant's non-selection was caused
by his age.

The agency's final order rejected the AJ's decision. On appeal, the agency raises a
number of contentions. First, the agency argues that because complainant was not
licensed and authorized to practice law and therefore did not meet the minimum
qualifications for the ALJ position at the time of his applications, he failed to establish a
prima facie case of discrimination. The agency noted that, after the hearing, it acquired
evidence which established that complainant was an inactive member of the Indiana Bar
between June 19, 1995 and January 4, 1999. The agency argued that had complainant
not withheld from OPM the fact that his bar license was inactive, OPM would not have
included him on the selection register, as he was not minimally qualified to be an ALJ. In
support of this argument, the agency noted that in order to meet the qualifications for an
ALJ positions, applicants must be able to establish continuous authorization to practice
law at and for the seven years immediately prior to application. Because complainant
could not do this, the agency contended that his complaint should be dismissed.

The agency then argued that even assuming complainant established a prima facie case,
the AJ committed reversible error by ignoring the agency's articulated legitimate non-
discriminatory explanations for the non-selections. It noted that RO gave numerous
explanations for recommending the selectees, including reliance upon panel interview
notes, reliance upon the recommendations of the interview panels, reliance upon
comments of references contacted by staff, continuity of legal experience, adjudicative
experience and relevant litigation experience. The agency noted that RO indicated that he
focused on the strengths of the selectees, not on the weaknesses of those he did not
select. The agency also argued that the record established the selectees had adjudication
and litigation experience whereas complainant, prior to becoming an Attorney-Advisor
with the agency in June 1995, limited his private practice largely to probate matters and
had, in fact, abandoned full-time practice for a time.

The agency concluded that because RO articulated legitimate non-discriminatory reasons
for his selections, it was incumbent on complainant to demonstrate why he was better
qualified than the selectees. The agency also argued that the AJ erroneously relied on
statistical information and erroneously substituted his opinion of the how the selection
process and the Rule of Three should work, rather than deferring to OPM's regulations.

In response to the agency's appeal, complainant argued that the AJ's decision is correct,
essentially restating arguments made during the investigation and at the hearing. In
response to the agency's contention that complainant failed to establish that he was
minimally qualified for the ALJ position due to his inactive status between June 1995 and
January 1999, complainant argues that the substantial evidence level of review does not
permit the agency to raise this argument for the first time on appeal. Complainant notes
that the appeal must be limited to the evidentiary record below and that the agency
waived this argument by not making it previously. Complainant contends that if this issue
was actually litigated, he would be entitled to discovery to determine if other candidates
selected or given consideration more than three times were also on inactive status.
Finally, he argues that even if this argument is considered, he met the minimum
qualifications for the ALJ position at the time of his application. In so arguing, he notes
that he began the process of getting on OPM's ALJ registry in May 1993 and that he was
duly licensed and authorized to practice law in the state of Indiana at that time.

*3 Pursuant to 29 C.F.R. § 1614.405(a), all post-hearing factual findings by an AJ will be
upheld if supported by substantial evidence in the record. Substantial evidence is defined
as “such relevant evidence as a reasonable mind might accept as adequate to support a
conclusion.” Universal Camera Corp. v. National Labor Relations Board, 340 U.S. 474,
477 (1951) (citation omitted). A finding regarding whether or not discriminatory intent
existed is a factual finding. See Pullman-Standard Co. v. Swint, 456 U.S. 273, 293
(1982).

After a careful review of the record, the Commission finds that the AJ's decision
summarized the relevant facts and referenced the appropriate regulations, policies, and
laws. The AJ's determination that complainant's non-selections were motivated by his age
is supported by substantial evidence. In so finding, we note that RO, while providing
vague explanations for why he selected the various selectees, provided no explanation as
to why he eliminated complainant from consideration after considering him three times
for each vacancy. Although RO is correct that such a decision is within his discretion, the
record establishes that RO considered numerous applicants significantly younger than
complainant more than three times and that several of these applicants were selected.
Moreover, many of the selectees who were considered more than three times and were
significantly younger than complainant, also received lower ratings than complainant
from the ALJ interview panel and were non-preference eligible, unlike complainant. As the
“Rule of Three” requires that preference eligible applicants be selected over non-
preference eligible applicants with lower scores who are considered together, had
complainant been considered more than three times and grouped with any of the thirteen
selectees who were non-preference eligible and received lower scores than he, he would
have been selected. RO was unable to provide any explanation whatever for his less
favorable treatment of complainant, despite being given several opportunities to do so.

In regard to the agency's argument that complainant was not qualified to be an ALJ
based on his status as an inactive member of the Indiana bar, we first note that this
argument does not, as the agency asserts, go to whether complainant established a
prima facie case of discrimination. Rather, we find that the evidence of complainant's
status with the Indiana Bar is after-acquired evidence which does not bar the agency's
liability for having engaged in unlawfully discriminatory conduct. See McKennon v.
Nashville Banner Publishing Co., 513 U.S. 352 (1995) (holding that an employee
discharged in violation of the ADEA is entitled to relief even if the employer subsequently
discovers evidence of wrongdoing that would have led to the employee's termination on
legitimate grounds); see also EEOC Enforcement Guidance on After-acquired evidence
and McKennon v. Nashville Banner Publishing Co. (McKennon Guidance) (December 14,
1995)(interpreting McKennon and noting that even where the agency proves that it would
have taken the same or more harsh adverse action had it known of the employee
misconduct, complainant will still be entitled to relief, but that relief may be subject to
some limitations).

*4 Here, after failing to select complainant for an ALJ position and, indeed, after the AJ
determined that this failure was motivated by complainant's age, the agency acquired
evidence which established that complainant was an inactive member of the Indiana Bar
between June 19, 1995 and January 4, 1999. The agency asserts that complainant was
therefore not minimally qualified for the ALJ position and that his complaint should be
dismissed. The Supreme Court has held, however, that after-acquired evidence such as
this does not defeat an employer's liability for violating the ADEA. See McKennon, supra.
The Court found that in such cases the ADEA violation that actually prompted the adverse
action could not be ignored. Id. Instead, the Court concluded that after-acquired evidence
bears upon the remedy afforded to the complainant.

The Court in McKennon stated that where an employer seeks to rely upon after-acquired
evidence of wrongdoing to limit the amount of damages, it must first establish that the
wrongdoing was of such severity that the employee in fact would have been terminated
on those grounds alone had the employer known of the conduct at the time of the
discharge. See McKennon, supra; see also Martindale v. Department of Veterans Affairs,
EEOC Appeal No. 01954423 (December 9, 1997).
Applying this principle to the case at hand, we find that in order to establish that
complainant is not entitled to reinstatement and back pay from the time of his non-
selection through the present, the agency must establish that complainant's inactive
status was such that had the agency known about it prior to making its selection
determinations, it would, on that basis alone, have rejected complainant's application.

We further note, however, that even assuming that the agency can, on remand, establish
that complainant's inactive status would have resulted in his non-selection even absent
discrimination, complainant is nonetheless entitled to back pay from the date of his non-
selection to the date that the agency discovered that complainant was allegedly not
qualified, i.e., the date on which it received information from the Indiana Bar that
complainant was in inactive status. See McKennon Guidance, p. 5 (where an employee's
misconduct is so severe that an employer would have taken the same or harsher adverse
action even absent discrimination, back pay may generally be limited to the period from
the date of the unlawful employment action to the date that the misconduct was
discovered).

Accordingly, we find that the AJ's determination that complainant was subjected to age-
based discrimination when he was not selected for an ALJ position is supported by
substantial evidence. However, we remand the matter for further processing in
accordance with this decision and the ORDER below.

                                         ORDER

*5 The agency is ordered to take the following remedial action:
1. The agency shall determine the appropriate amount of back pay (with interest, if
applicable) 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 initial
back pay period shall be from March 1997, the earliest date on which other applicants
were selected, to the date on which the agency received notification from the Indiana Bar
that complainant was in inactive status from June 1995 through January 1999. 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.”
2. Within thirty (30) calendar days of the date this decision becomes final, the agency
shall provide a minimum of eight (8) hours of training in the obligations and duties
imposed by the ADEA to RO.
3. The agency shall post the attached notice.
4. The issue of whether complainant's inactive status, had it been known by the agency
at the time the selections were made, would have prevented complainant's selection even
absent discrimination is REMANDED to the Washington D.C. Field Office for a hearing. If
the AJ determines that complainant's inactive status would not have prevented his
selection, the AJ shall award appropriate remedies, including retroactive appointment and
back pay beginning in March 1997, the earliest date on which other applicants were
selected. The back pay period shall continue through the date on which complainant is
offered and either accepts or rejects the position. If the AJ determines that complainant's
inactive status would have prevented his selection, had the agency been aware of it at
the relevant time, no further remedies shall be awarded, with the exception detailed in
paragraph 1, supra.
5. 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 (G0900)

The agency is ordered to post at its Headquarters in Baltimore, Maryland 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 (K0501)

*6 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 19848,
Washington, D.C. 20036. 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 (M0701)

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), 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 19848, Washington,
D.C. 20036. 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.

*7 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 (R0900)

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 (Z1199)

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 that the Court appoint an attorney to represent you and
that the Court 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 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

FN1. It is undisputed that for each of the four vacancy announcements, RO arranged for
a panel of three ALJs to interview and score applicants on the selection register compiled
by the United States Office of Personnel Management (OPM). RO then used the “Rule of
Three” in which he considered the first three applicants on the register and selected one,
grouping the remaining two applicants with the next applicant on the register list until all
the vacancies were filled. It is also undisputed that agency regulations only require an
applicant to be considered three times, but allow management officials to use their
discretion to consider an applicant more than three times.
       NOTICE TO EMPLOYEES POSTED BY ORDER OF THE EQUAL EMPLOYMENT
                        OPPORTUNITY COMMISSION

                       An Agency of the United States Government

*8 This Notice is posted pursuant to an Order by the United States Equal Employment
Opportunity Commission dated _______ which found that a violation of the Age
Discrimination in Employment Act of 1967 (ADEA), as amended, 29 U.S.C. § 621 et seq.,
has occurred at the Social Security Administration.

Federal law requires that there be no discrimination against any employee or applicant
for employment because of the person's RACE, COLOR, RELIGION, SEX, NATIONAL
ORIGIN, AGE, or DISABILITY with respect to hiring, firing, promotion, compensation, or
other terms, conditions or privileges of employment.

The agency supports and will comply with such federal law and will not take action
against individuals because they have exercised their rights under law.

The agency was found to have discriminated on the basis of age when it failed to select
the complainant for a position as an Administrative Law Judge. The agency was ordered
to: (1) pay complainant the appropriate amount of back pay; (2) provide training for the
management official responsible for the discrimination; and (3) post this notice. The issue
of whether complainant is entitled to further remedies was remanded for further
investigation.

The agency will not in any manner restrain, interfere, coerce, or retaliate against any
individual who exercises his or her right to oppose practices made unlawful by, or who
participates in proceedings pursuant to, federal equal employment opportunity law.

29 C.F.R. Part 1614

EEOC DOC 07A10004, 2003 WL 21302594 (E.E.O.C.)
END OF DOCUMENT
                                             (C) 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works.



                                         E.E.O.C.
                             *1 Office of Federal Operations

                        SHAUKAT SYED, COMPLAINANT,
                                     v.
       ANN M. VENEMAN, SECRETARY, DEPARTMENT OF AGRICULTURE, AGENCY.

                                 Request No. 05A20500
                                 Appeal No. 01A20187
                              Agency Nos. 980560; 990070
                               Hearing No. 100-AO-7679x

                                      June 12, 2002

                      DENIAL OF REQUEST FOR RECONSIDERATION

Shaukat Syed (complainant) timely initiated a request to the Equal Employment
Opportunity Commission (EEOC or Commission) to reconsider the decision in Shaukat
Syed v. Department of Agriculture, EEOC Appeal No. 01A20187 (February 25, 2002).
EEOC Regulations provide that the Commission may, in its discretion, reconsider any
previous Commission decision where the requesting party demonstrates 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. See 29 C.F.R. § 1614.405(b).

After a review of complainant's request for reconsideration, the previous decision, and
the entire record, the Commission finds that the request fails to meet the criteria of 29
C.F.R. § 1614.405(b). Complainant alleged that he was discriminated against on the
basis of religion (Muslim) and subjected to retaliation for prior EEO activity when he was
not selected for the position of Program Analyst (HAACP Implementation Project
Manager) in March 1998. Complainant further alleged that he was discriminated against
on the bases of race (Asian American) and religion and subjected to retaliation when he
was not selected for the position of Program Analysis Officer (Director, Review Staff) in
September 1998. The previous decision affirmed the agency's adoption of an EEOC
Administrative Judge's finding of no discrimination issued without a hearing. In so doing,
the previous decision noted that the AJ's issuance of a decision without a hearing was
appropriate and a preponderance of the record evidence did not establish that
discrimination occurred.

The AJ determined that although complainant established a prima facie case of
discrimination, he failed to raise a genuine dispute as to the agency's explanations for his
non-selections. Specifically, the AJ noted that management officials testified with
specificity as to the superior qualifications of the selectees. The AJ determined that
although complainant alleged that he is more qualified than the selectees, he did not
provide examples to support this conclusion, nor did he specifically rebut management
officials' testimony as to the selectees' qualifications. The AJ concluded that mere
conclusory allegations were not sufficient to raise a genuine issue of material fact.

We note that Commission precedent establishes that a mere recitation that there is a
factual dispute is insufficient to overcome a motion for summary judgment. The party
opposing summary judgment must identity the disputed facts in the record with
specificity. See Patton v. United States Postal Service, EEOC Request No. 05930055 (July
1, 1993) (summary judgment proper where complainant made only a general assertion
that his job performance was good, but set forth no specific facts regarding his
performance). Here, the AJ correctly determined that complainant's mere statement that
his qualifications are superior, absent specific examples to rebut the management
officials' testimony concerning the selectees' superior qualifications, was insufficient to
raise a genuine issue of material fact.

*2 In his request for reconsideration, complainant essentially reiterates arguments made
on appeal which were considered when issuing the previous decision. He argues, for
example, that he was not selected for 17 positions by the same management official and
contends that these allegations establish a continuing violation that was not addressed by
the AJ. We note, however, that complainant did not raise this argument in his complaint
or before the AJ, although he was given the opportunity to do so.

After a careful review of the record, including arguments and evidence not specifically
discussed in this decision, we find that complainant has failed to demonstrate that the
previous decision involved a clearly erroneous interpretation of material fact or law, or
that it will have a substantial impact on the operations, policies or practices of the
agency. Accordingly, it is the decision of the Commission to deny the request. The
decision in EEOC Appeal No. 01A20187 remains the Commission's final decision. There is
no further right of administrative appeal on the decision of the Commission on this
request for reconsideration.

                COMPLAINANT'S RIGHT TO FILE A CIVIL ACTION (P0900)
This decision of the Commission is final, and there is no further right of administrative
appeal from the Commission's decision. 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.

                          RIGHT TO REQUEST COUNSEL (Z1199)

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 that the Court appoint an attorney to represent you and
that the Court 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 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

EEOC DOC 05A20500, 2002 WL 1367550 (E.E.O.C.)
END OF DOCUMENT
                                              (C) 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works.

				
DOCUMENT INFO
Categories:
Tags:
Stats:
views:22
posted:1/15/2012
language:Latin
pages:9