January 28, 2015

C4C
The Coalition For
Change, Inc. (C4C)
P.O. Box 142
Washington, DC 20044

T. Ward Jordan
Founder/President

W. Berry
Treasurer

I. Decatur
Outreach Chair

T. Williams
Greetings Chair

K. Karriem
Advisory
Committee Chair

A. Holmes-Martin
Mental and Spiritual
Well-being Chair

P. Taylor
Civil Rights Chair

D. Williams
Legislative Research Chair

www.coaltion4change.org
C4C@coalition4change.org
1-866-737-9783

EEOC Executive Officer

U.S. Equal Employment Opportunity Commission
131 M Street, NE
Washington, DC 20507
Re: EEOC Commission Meeting - Workplace Harassment
To Whom It May Concern:
The Coalition For Change, Inc. (C4C), a non-profit organization comprised of
former and present employees who have been injured or ill-treated due to workplace
race discrimination and /or reprisal, is very pleased that the Equal Employment
Opportunity Commission (EEOC) is focusing on workplace harassment. However,
we are again disappointed that the EEOC has omitted any reference to the problems in
the federal workplace which is just as pernicious as the private sector workplace.
The C4C agrees with the EEOC Chair Jenny R. Yangs statement, made at the
January 14th forum, that --- workplace harassment remains a persistent problem.
Understanding this premise, the C4C asserts that the federal government, the nations
largest employer, needs to do better in addressing unlawful harassment within its own
ranks. Toward this goal, C4C submits the following seven (7) accountability and
transparency measures to more effectively address the problem.
Measure 1: Announce Unlawful Violations via E-Notice to Employees
Measure 2: Issue Sanctions Against Agencies Violating EEOC Regulations
Measure 3: Post Class Action Complaints on Website
Measure 4: Post Federal Violations on EEOC Homepage
Measure 5: Disband Anonymity: Identify the Discriminating Official
Measure 6: Support Mandatory Discipline
Measure 7: Refer Actively and Post Referrals to the Office Special Counsel
(OSC) on the EEOC Website
Measure 1: Announce Unlawful Violations via E-Notice (E-mail) to Employees
The EEOC should require agencies to announce unlawful violations to employees via
E--notice. When an agency, or the Commission, in an individual case of
discrimination, finds that an applicant or an employee has been discriminated against,
require the agency to provide full relief to include electronic notification(via email) to all employees of the agency in the affected facility of their right to be free of
unlawful discrimination. The E-notice to employees shall, at a minimum, identify the
specific office where violation occurred, the statute that was violated, the name of the
party found culpable, and a statement assuring that the particular types of
discrimination found will not recur.
Measure 2: Issue Sanctions against Agencies Violating EEOC Regulations
The EEOC should make more effective and regular use of its authority to issue
sanctions to combat harassment when a federal agency violates an EEOC
regulation governing federal sector complaint processing. For example, the EEOC

should enter a judgment in favor of employee when a federal agency fails to timely
comply with the 180 day EEO complaint investigative requirement, as prescribed in
29 CFR 1614.108. Notably, many federal agencies consistently defy the EEOC
regulation and subject federal workers to prolong abuses. No FEAR 2014 statistical
data provided by the U.S. Social Security Administration (SSA) and the U.S.
Department of Interior reflect that both federal entities exceeded prescribed EEO
complaint investigative timeframes.
SSA: Average Number of Days 265
(as of 9/30/14)
Interior: Average Number of Days 237 (as of 6/20/14)
Moreover, the U.S. Department of Agriculture is an agency that historically has
mishandled EEO complaints for decades. Sanctions should be levied against the
agency that allows hostile treatment to persist as it has against minorities and women,
in particular. Hear video where former employee, Ms. Alicia Dabney (a Native
American) was sexually harassed by her employer and later fired after reporting the
incident. https://www.youtube.com/watch?feature=player_embedded&v=sjZwLEFLAhI
Measure 3: Post Class Action Complaints on Website
The EEOC should post, no less than annually, all class action complaints filed against
a federal agency along with the complaint status on its website. When posting class
action data, the EEOC should identify the agency name, the case number of the class
action filed, the basis and the claims alleged against the agency. [Agencies are failing
to timely resolve complaints costing taxpayers in the millions of dollars each year.
Reference: Taylor et al vs Social Security Administration (10 year+) and Garcia v
Holder (20 years)].
Measure 4: Post Federal Violations on the EEOC Homepage
The EEOC should post on its homepage the violations occurring in the federal
sector like it display the unlawful transgressions occurring in the private sector.
Measure 5: Disband Anonymity: Identify the Discriminating Official
The EEOC should list on its Federal Sector Appellate Decision on-line page the name
of the agency official who has been found guilty of violating civil rights laws. The
EEOC should list the public official by name in lieu of such acronyms as S1 or
Supervisor 1. When the EEOC issues a final finding of discrimination and no
further recourse exists for appeal at the administrative level the names of violators
should appear in Federal Sector Appellate Decisions.
Measure 6: Support Mandatory Discipline
Administrative Level -- When a supervisor is found guilty of an unlawful violation
and the EEOC issues a finding against the supervisor/agency and all appeal rights are
exhausted--- the EEOC should at the very least, recommend discipline. If the
EEOC is unable to order discipline as it stated in a letter to C4C member Isaac
Decatur, who proved managers discriminated against him, the EEOC should strongly
recommend discipline. Mr. Decatur proved discrimination against the U.S.
Department of Veterans Affairs as did Mr. Ralph Saunders. In the case of Saunders v
Veterans Affairs -200L-0629-2004-100828 - the EEOC had knowledge that Veterans
Affairs officials maintained a BLACKLIST.

Unequivocally, the EEOC found managers Cassandra Holiday, Jeanette Butler, and
Linda Cosey guilty of abusing the rules and retaliating against Saunders for his
protected EEO activity. The EEOC also found evidence that officials retaliated
against other employees who filed EEO complaints." Nonetheless, the EEOC failed
to refer a single manager to OSC for enforcement proceedings to face discipline
for breaking the law.
Court Level- The EEOC should also follow employment discrimination lawsuits filed
against a federal agency through resolution and when a court finds that an agency or
an officer or employee thereof has discriminated against any employee or applicant
for employment, the EEOC should get involved by referring the names of civil rights
violators to the OSC for disciplinary enforcement. The cases of Schmidt v. Solis,
Civil Action No. 07-2216 (D.D.C.) (JMF); Uzlyan v. Solis, Civil Action No. 09-1035
(D.D.C.) (RMC); and Weng v. Solis, Civil Action No. 10-2051 (D.D.C.) (BJR).
disclose how some federal managers at the Labor Department escaped discipline and
repeatedly engaged in discriminatory actions. Managers named in employment
lawsuits filed in related court cases include Eric A. Raps, Ivan L. Strasfeld and
Lyssa E. Hall. Court records disclosed that the three cases cost taxpayers an
estimated $1.5 million dollars.
Measure 7: Refer Actively and Post Referrals to the Office Special Counsel
(OSC) on the EEOC Website
The EEOC should post quarterly, on its website the number of discrimination findings
by agency; the number of cases, identified by agency, that it has referred to the OSC
for enforcement. Similarly, the EEOC should report the number of cases, identified
by agency, it chose not to refer to the OSC and provide an explanation for electing not
to make an OSC referral in cases where unlawful action has been proven.
Notably, despite the EEOCs Memorandum of Understanding with the OSC to
strengthen the enforcement of civil rights laws, a C4C Freedom of Information Act
inquiry made to the EEOC last year disclosed that the EEOC had failed to refer any
cases to the OSC for enforcement.

In closing, it is key to note that last year the C4C submitted a detailed report
about federal workplace discrimination to the EEOCs former Chair Jacqueline
Berrien. An electronic copy of the C4C report: Obstacle 1: The Denial of a Reality,
can be obtained at the link https://www.scribd.com/doc/156357758/Obstacle-1-TheDenial-of-A-Reality The C4C is truly committed to transforming the hostile
workplace culture found in far too many federal entities into an efficient setting where
all employees are treated fairly, one where civil servants can truly uphold the public
trust and provide for a safer America. Should you have questions about the measures
presented in this correspondence, I can be reached either by email
(c4c@coalition4change.org) or by phone on 1-866-737-9783.

Sincerely,
| Tanya Ward Jordan |
Tanya Ward Jordan, Founder and PresidentThe Coalition For Change, Inc. (C4C)