UNITED STATES OF AMERICA

MERIT SYSTEMS PROTECTION BOARD

DAVID A. FARGNOLI,

Appellant,

v.

DEPARTMENT OF COMMERCE,

Agency.

DOCKET NUMBER

DC-0752-15-0266-B-1

DATE: February 9, 2023

THIS FINAL ORDER IS NONPRECEDENTIAL1

Lawrence Berger, Esquire, Glen Cove, New York, for the appellant.

Adam Chandler, Esquire, Washington, D.C., for the agency.

BEFORE

Cathy A. Harris, Vice Chairman

Raymond A. Limon, Member

Tristan L. Leavitt, Member

FINAL ORDER

¶1 The appellant has filed a petition for review of the remand initial decision, 

which sustained his removal. Generally, we grant petitions such as this one only 

in the following circumstances: the initial decision contains erroneous findings 

of material fact; the initial decision is based on an erroneous interpretation of 

 

1 A nonprecedential order is one that the Board has determined does not add 

significantly to the body of MSPB case law. Parties may cite nonprecedential orders, 

but such orders have no precedential value; the Board and administrative judges are not 

required to follow or distinguish them in any future decisions. In contrast, a 

precedential decision issued as an Opinion and Order has been identified by the Board 

as significantly contributing to the Board’s case law. See 5 C.F.R. § 1201.117(c).
2

statute or regulation or the erroneous application of the law to the facts of the 

case; the administrative judge’s rulings during either the course of the appeal or 

the initial decision were not consistent with required procedures or involved an 

abuse of discretion, and the resulting error affected the outcome of the case; or 

new and material evidence or legal argument is available that, despite the 

petitioner’s due diligence, was not available when the record closed. Title 5 of 

the Code of Federal Regulations, section 1201.115 (5 C.F.R. § 1201.115). After 

fully considering the filings in this appeal, we conclude that the petitioner has not 

established any basis under section 1201.115 for granting the petition for review. 

Therefore, we DENY the petition for review and AFFIRM the remand initial 

decision, which is now the Board’s final decision. 5 C.F.R. § 1201.113(b). 

BACKGROUND

¶2 Prior to his entry on duty as a Criminal Investigator in the agency’s Bureau 

of Industry and Security, the appellant previously had been employed by the 

Department of Labor (DOL), Office of Inspector General (OIG). The agency 

removed him on the charges of unauthorized possession of equipment, conduct 

unbecoming a Law Enforcement Officer (four specifications), and lack of candor 

(three specifications). Fargnoli v. Department of Justice, MSPB Docket No. DC0752-15-0266-I-1, Initial Appeal File (IAF), Tab 5 at 39-54.2

 The charged 

misconduct generally centered on a shotgun, which came into the appellant’s 

possession when he worked at DOL, and his possessing that shotgun and another 

personal weapon during his employment at the agency, as well as sworn 

statements he made when interviewed about these matters. 

¶3 On appeal, and after a hearing, the administrative judge sustained all three 

charges, although he did not sustain specification 4 of the conduct unbecoming 

 

2

The deciding official found that the evidence did not support the first three of the six 

specifications set forth in the notice of proposed removal under the lack of candor 

charge. IAF, Tab 5 at 45-46.
3

charge. IAF, Tab 19, Initial Decision (ID) at 3-28. He further found that the 

agency established that a nexus existed between the sustained misconduct and the 

efficiency of the service and that the penalty of removal was reasonable. ID 

at 29-31.

¶4 On the appellant’s petition for review, the Board found that, although the 

administrative judge did not correctly construe the unauthorized possession 

charge, it was still sustained.3 Fargnoli v. Department of Commerce, 

123 M.S.P.R. 330, ¶¶ 6-11 (2016). Of the three remaining specifications under 

the conduct unbecoming charge, the Board sustained only the first two but found 

that they were sufficient to sustain that charge. Id., ¶¶ 12-15. The Board then 

found that the administrative judge did not fully analyze the lack of candor charge

because, although he determined that the appellant’s statements described in 

specifications 4, 5, and 6 were not true, he made no findings as to whether the 

“element of deception” was present; that is, whether the appellant gave incorrect 

or incomplete information and did so knowingly. Id., ¶¶ 16-18 (citing Ludlum v. 

Department of Justice, 278 F.3d 1280, 1284 (Fed. Cir. 2002) and Rhee v. 

Department of the Treasury, 117 M.S.P.R. 640, ¶ 11 (2012), overruled in part on 

other grounds by Savage v. Department of the Army, 122 M.S.P.R. 612 (2015)). 

In remanding the case, the Board directed the administrative judge to reanalyze 

the lack of candor charge and to make a new finding as to whether the sustained 

misconduct warrants removal.4 Fargnoli, 123 M.S.P.R. 330, ¶ 18.

 

3

The appellant states on review that he “reserves for further appeal, if the removal is 

sustained by the Board, the Board’s conclusion that Reason 1 (‘Unauthorized 

Possession of Equipment’) was sustained.” Fargnoli v. Department of Justice, MSPB 

Docket No. DC-0752-15-0266-B-1, Remand Petition for Review (RPFR) File, Tab 5 

at 6 n.1. That finding by the Board, however, is not subject to further administrative 

review.

4

The Board also directed the administrative judge, on remand, to consider and address 

as appropriate the appellant’s claim, raised below, that the agency violated his due 

process rights. Fargnoli, 123 M.S.P.R. 330, ¶ 18 n.5. The administrative judge did so, 

finding that the appellant did not present preponderant evidence that the agency failed 

to afford him the due process to which he was entitled. Fargnoli v. Department of 
4

¶5 On remand, the administrative judge again affirmed the agency’s action. 

Fargnoli v. Department of Justice, MSPB Docket No. DC-0752-15-0266-B-1, 

Remand File, Tab 3, Remand Initial Decision (RID) at 9. As directed, he 

reconsidered the three specifications under the lack of candor charge. Finding, in 

all three, that the appellant made false statements and did so knowingly, RID 

at 3-7, the administrative judge sustained that charge, RID at 7. Having found 

that all three charges remained sustained, the administrative judge further found 

unchanged his earlier findings that the agency’s action promoted the efficiency of 

the service and that the removal penalty was reasonable. RID at 8.

¶6 The appellant has filed a petition for review of the remand initial decision, 

Fargnoli v. Department of Justice, MSPB Docket No. DC-0752-15-0266-B-1, 

Remand Petition for Review (RPFR) File, Tab 5, to which the agency has 

responded, RPFR File, Tab 7, and the appellant has filed a reply, RPFR File, 

Tab 8.

ANALYSIS

¶7 In specification 4 of the lack of candor charge, the agency asserted that, in a 

sworn interview, when the appellant was asked why he did not return the shotgun, 

he stated that “[he] intended to” and that when asked why he kept the shotgun 

after leaving DOL, he stated that “[his] intent was to T&E [test and evaluat e] it 

and present the package to [his current employer].” The agency contended that 

these statements evidenced a lack of candor on the appellant’s part because they 

were not supported by the record evidence. IAF, Tab 5 at 273.

¶8 In finding that the appellant’s statements in this specification exhibited a 

lack of candor, the administrative judge first repeated the findings that he had 

earlier made that, based on the record as a whole, the appellant’s explanation 

 

Justice, MSPB Docket No. DC-0752-15-0266-B-1, Remand File, Tab 3, Remand Initial 

Decision at 7-8. Because the appellant has not challenged that finding on petition for 

review, RPFR File, Tab 1, we will not consider it further.
5

made no sense because he lacked any authority to evaluate a shotgun or any 

firearm, he never sought permission from anyone from the agency to conduct an 

evaluation, he never notified the gun manufacturer that he was no longer 

“evaluating” the shotgun for DOL but was now “evaluating” it for his current 

agency, he never told anyone at the agency that he possessed the shotgun, he 

never produced any report/evaluation of the shotgun, even though he possessed it 

for 3 years after changing jobs, and such possession would have continued 

indefinitely but for the inadvertent discovery of the shotgun in the appellant’s 

possession at the time of his vehicle accident, which formed the basis for the 

conduct unbecoming charge. On this basis, the administrative judge found that he 

could not credit the appellant’s claim. ID at 24; RID at 4. In the remand initial 

decision, the administrative judge found that the appellant’s statements evidenced 

deception. The administrative judge found that they were false and that the 

appellant knew they were false when he made them because he could point to no 

facts to support his claims, thereby demonstrating irrefutably that he had no 

thought or plan to return the shotgun. RID at 4-5. The administrative judge again 

found not credible the appellant’s explanation that he intended to return the 

shotgun, particularly since he possessed the shotgun for 3 years and the 

possession ended involuntarily. RID at 5.

¶9 The appellant challenges the administrative judge’s findings on review, 

arguing that the gun manufacturer had no expectation that the shotgun would be 

returned and never asked for it back and neither did DOL, such that any return of 

the shotgun was indefinite and open-ended, and rendered the appellant’s decision 

what to do with the shotgun at some future time a “judgment call.” The appellant 

further argues that the intent to deceive cannot be shown in the absence of 

unambiguous instruction as to the timing of the return. RPFR File, Tab 5 at 7-8. 

¶10 The appellant disputes the administrative judge’s conclusion that the 

statements at issue in this specification were false and that the appellant knew 

they were false when he made them. However, he has not challenged the 
6

underlying facts supporting the administrative judge’s conclusion. Moreover, in 

making his findings, the administrative judge relied on the Board’s decision in 

Hillen v. Department of the Army, 35 M.S.P.R. 453, 458 (1987),5explaining in 

detail why he found the appellant’s explanation for his statements to be inherently 

improbable. RID at 4-5. The appellant also argues on review that the 

administrative judge’s credibility determinations were not based on demeanor and 

therefore should not be afforded deference. RPFR File, Tab 5 at 11-12. 

However, it is well established that when, as here, an administrative judge has 

heard live testimony, his credibility determinations must be deemed to be at least 

implicitly based upon the demeanor of the witnesses. Purifoy v. Department of 

Veterans Affairs, 838 F.3d 1367, 1373 (Fed. Cir. 2016); Little v. Department of 

Transportation, 112 M.S.P.R. 224, ¶ 4 (2009). The Board must defer to an 

administrative judge’s credibility determinations when they ar e based, explicitly 

or implicitly, on observing the demeanor of witnesses testifying at a hearing, and 

the Board may overturn credibility findings only when it has “sufficiently sound” 

reasons for doing so. Haebe v. Department of Justice, 288 F.3d 1288, 1301 (Fed. 

Cir. 2002). Beyond his mere disagreement, the appellant has not provided such 

reasons, and we discern no reason to reweigh the evidence or substitute our 

assessment of the record evidence for that of the administrative judge. See 

Crosby v. U.S. Postal Service, 74 M.S.P.R. 98, 105-06 (1997). Regarding the 

appellant’s argument that, because the evidence is unclear as to whether he knew 

that he should have returned the shotgun on a date certain or believed he could do 

 

5

To resolve credibility issues, an administrative judge must identify the factual 

questions in dispute, summarize the evidence on each disputed question, state which 

version he believes, and explain in detail why he found the chosen version more 

credible, considering such factors as: (1) the witness’s opportunity and capacity to 

observe the event or act in question; (2) the witness’s character; (3) any prior 

inconsistent statement by the witness; (4) a witness’s bias, or lack of bias; (5) the 

contradiction of the witness’s version of events by other evidence or its consistency 

with other evidence; (6) the inherent improbability of the witness’s version of events; 

and (7) the witness’s demeanor. Hillen, 35 M.S.P.R. at 458.
7

so at any time, there can be no finding of an intent to deceive, RPFR File, Tab 5 

at 14, there is no requirement of intent in a lack of candor charge, Ludlum, 

278 F.3d at 1284-85. In sum, we find that the administrative judge properly 

sustained specification 4 of the lack of candor charge.

¶11 In specification 5, the agency asserted that, during a sworn interview, the 

appellant stated that he received permission from a named Special Agent in 

Charge from DOL’s OIG to acquire and test the shotgun. IAF, Tab 6 at 273. The 

agency further asserted, however, that the Special Agent in Charge denied ever 

giving the appellant permission to obtain the shotgun and that, because the 

Special Agent in Charge had no incentive to misrepresent the truth, his statement 

was more credible than the appellant’s. Id. 

¶12 In finding that the appellant’s statement exhibited a lack of candor, the 

administrative judge repeated the findings he had earlier made that the appellant’s 

statement was not credible because, if it was so, there would have been some type 

of follow-up or accountability to assure that the testing occurred, but that there 

was no testing, either at DOL or at the agency. The administrative judge further 

found that, if the appellant had received such approval from the Special Agent in 

Charge or anyone with authority, the appellant would have been ethically 

obligated to complete the authorized activity and that his failure to do so 

undermined any legitimacy his claim might otherwise have. The administrative 

judge credited the statement of the Special Agent in Charge that he did not know 

the appellant had acquired the shotgun for any purpose and found therefore that 

the appellant lacked candor in his response regarding his having received 

permission from the Special Agent in Charge to obtain the shotgun. ID at 26; 

RID at 5-6. In the remand initial decision, the administrative judge further found 

that the appellant’s statement was not an inadvertent mistake but was false, 

unsupported by any facts, and that he knew it was false in that it was a conscious 

attempt at deception. RID at 6.
8

¶13 The appellant challenges those findings on review, arguing that, in fact, an 

Assistant Special Agent in Charge permitted him to borrow the shotgun from the 

manufacturer and that therefore his statement was not untrue. The appellant 

contends that, to the extent, given the passage of time, he might have been 

confused about whether it was the Special Agent in Charge or the Assistant 

Special Agent in Charge who gave him permission to borrow the shotgun, his 

recollection was in good faith and evidenced no intent to deceive. RPFR File, 

Tab 3 at 14-15. In addition, the appellant argues that the Special Agent in Charge 

did not deny knowing that someone may have informed him that the appellant had 

obtained the shotgun for training and evaluation. Id. at 9, 14.

¶14 The appellant’s arguments again challenge the administrative judge’s 

credibility determinations. After hearing the testimony, the administrative judge 

found not credible the appellant’s statement that the Special Agent in Charge 

gave him permission to acquire and test the shotgun, finding the statement 

contradicted by the Special Agent in Charge’s own statement, IAF, Tab 6 at 71, 

as well as the appellant’s own behavior in not completing any testing of the 

shotgun over a period of 3 years, Hillen, 35 M.S.P.R. at 458; RID at 6. Because 

these findings were at least implicitly based on demeanor, and because the 

appellant has not shown “sufficiently sound” reasons for overturning them, we 

defer to those findings. See Haebe, 288 F.3d at 1301. Moreover, as noted, there 

is no requirement of an intent to deceive in a lack of candor charge. Ludlum, 

278 F.3d at 1284-85. We therefore find that the administrative judge properly 

sustained specification 5 of the lack of candor charge.

¶15 In specification 6, the agency asserted that, in a sworn interview, the 

appellant stated that he felt the shotgun was a “personal assignment,” not 

assigned to the agency. IAF, Tab 6 at 273-74. 

¶16 In finding that this statement exhibited lack of candor, the administrative 

judge repeated his earlier findings that the appellant made an internally 

inconsistent claim by also stating that he acquired the shotgun for testing and 
9

evaluation and that his compete failure to conduct any testing, either personally 

or officially, demonstrated that his statement was misleading or demonstrably 

inaccurate. ID at 28. In the remand initial decision, the administrative judge 

found that the statement was knowingly false, lacking any evidentiary support, 

and was made to deceive, misdirect, and hide the truth. RID at 6-7.

¶17 The appellant challenges the administrative judge’s findings on review, 

again disputing the administrative judge’s credibility findings, arguing that his 

belief that the shotgun was not assigned to the agency was sincerely held, even if 

incorrect, and that it did not establish an intent to deceive. RPFR File, Tab 5 

at 16. In making his finding, the administrative judge explained why he found the 

appellant’s explanation for his statement to be inconsistent with his other 

statement and with his actions. Hillen, 35 M.S.P.R. at 458; RID at 6-7. Because 

these findings were based at least implicitly on demeanor, and because the 

appellant has not shown “sufficiently sound” reasons for overturning them, we 

defer to those findings. Haebe, 288 F.3d at 1301. Moreover, as noted, there is no 

requirement or an intent to deceive in a lack of candor charge. Ludlum, 278 F.3d 

at 1284-85. We therefore find that the administrative judge properly sustained 

specification 6 of the lack of candor charge and, having sustained all three 

specifications of the charge, properly sustained the charge itself. 

¶18 Other than stating that “[t]he penalty of removal should be mitigated,” the 

appellant has advanced no reason why the agency’s chosen penalty should not be 

upheld. RPFR File, Tab 5 at 16. He has not shown error in the administrative 

judge’s findings that all of the sustained misconduct arose from the appellant’s 

official duties. RID at 8. When the agency’s charges are sustained, the Board 

will review the agency’s penalty selection only to determine if the agency 

considered all the relevant factors and exercised management discretion within 

the tolerable limits of reasonableness. Luongo v. Department of Justice, 

95 M.S.P.R. 643, ¶ 6 (2004), aff’d, 123 F. App’x 405 (Fed. Cir. 2005). We agree 

with the administrative judge that the agency in this case did consider all the 
10

relevant factors, RID at 8; IAF, Tab 5 at 47-51, Tab 18, Hearing Compact Disc 

(testimony of the deciding official), and that removal is a reasonable penalty for 

the sustained misconduct.

¶19 On review, the appellant argues that the Board should apply “Chevron

deference,”6 which is generally concerned with issues of statutory construction, to 

a portion of the deciding official’s testimony. RPFR File, Tab 5 at 12-13. The 

appellant did not raise this argument below and has not shown that it is based on 

new and material evidence not previously available despite his due diligence. 

Therefore we will not considerate it. See Banks v. Department of the Air Force, 

4 M.S.P.R. 268, 271 (1980).

¶20 Accordingly, we affirm the remand initial decision.

NOTICE OF APPEAL RIGHTS7

You may obtain review of this final decision. 5 U.S.C. § 7703(a)(1). By 

statute, the nature of your claims determines the time limit for seeking such 

review and the appropriate forum with which to file. 5 U.S.C. § 7703(b). 

Although we offer the following summary of available appeal rights, the Merit 

Systems Protection Board does not provide legal advice on which option is most 

appropriate for your situation and the rights described below do not represent a 

statement of how courts will rule regarding which cases fall within their 

jurisdiction. If you wish to seek review of this final decision, you should 

immediately review the law applicable to your claims and carefully follow all 

filing time limits and requirements. Failure to file within the applicable time 

limit may result in the dismissal of your case by your chosen forum.

 

6 Chevron, USA, Inc. v. Natural Resources Defense Council, Inc., 487 U.S. 837 (1984).

7

Since the issuance of the initial decision in this matter, the Board may have updated 

the notice of review rights included in final decisions. As indicated in the notice, the 

Board cannot advise which option is most appropriate in any matter.
11

Please read carefully each of the three main possible choices of review 

below to decide which one applies to your particular case. If you have questions 

about whether a particular forum is the appropriate one to review your case, you 

should contact that forum for more information. 

(1) Judicial review in general. As a general rule, an appellant seeking 

judicial review of a final Board order must file a petition for review with the U.S. 

Court of Appeals for the Federal Circuit, which must be received by the court 

within 60 calendar days of the date of issuance of this decision. 5 U.S.C. 

§ 7703(b)(1)(A). 

If you submit a petition for review to the U.S. Court of Appeals for the 

Federal Circuit, you must submit your petition to the court at the 

following address: 

U.S. Court of Appeals 

for the Federal Circuit 

717 Madison Place, N.W. 

Washington, D.C. 20439 

Additional information about the U.S. Court of Appeals for the Federal 

Circuit is available at the court’s website, www.cafc.uscourts.gov. Of partic ular 

relevance is the court’s “Guide for Pro Se Petitioners and Appellants,” which is 

contained within the court’s Rules of Practice, and Forms 5, 6, 10, and 11. 

If you are interested in securing pro bono representation for an appeal to 

the U.S. Court of Appeals for the Federal Circuit, you may visit our website at 

http://www.mspb.gov/probono for information regarding pro bono representation 

for Merit Systems Protection Board appellants before the Federal Circuit. The 

Board neither endorses the services provided by any attorney nor warrants that 

any attorney will accept representation in a given case. 

(2) Judicial or EEOC review of cases involving a claim of 

discrimination. This option applies to you only if you have claimed that you 
12

were affected by an action that is appealable to the Board and that such action 

was based, in whole or in part, on unlawful discrimination. If so, you may obtain 

judicial review of this decision—including a disposition of your discrimination 

claims—by filing a civil action with an appropriate U.S. district court (not the 

U.S. Court of Appeals for the Federal Circuit), within 30 calendar days after you 

receive this decision. 5 U.S.C. § 7703(b)(2); see Perry v. Merit Systems 

Protection Board, 582 U.S. ____ , 137 S. Ct. 1975 (2017). If you have a 

representative in this case, and your representative receives this decision before 

you do, then you must file with the district court no later than 30 calendar days

after your representative receives this decision. If the action involves a claim of 

discrimination based on race, color, religion, sex, national origin, or a disabling 

condition, you may be entitled to representation by a court-appointed lawyer and 

to waiver of any requirement of prepayment of fees, costs, or other security. See

42 U.S.C. § 2000e-5(f) and 29 U.S.C. § 794a. 

Contact information for U.S. district courts can be found at their respective 

websites, which can be accessed through the link below: 

http://www.uscourts.gov/Court_Locator/CourtWebsites.aspx. 

Alternatively, you may request review by the Equal Employment 

Opportunity Commission (EEOC) of your discrimination claims only, excluding 

all other issues. 5 U.S.C. § 7702(b)(1). You must file any such request with the 

EEOC’s Office of Federal Operations within 30 calendar days after you receive

this decision. 5 U.S.C. § 7702(b)(1). If you have a representative in this case, 

and your representative receives this decision before you do, then you must file 

with the EEOC no later than 30 calendar days after your representative receives

this decision. 

If you submit a request for review to the EEOC by regular U.S. mail, the 

address of the EEOC is: 
13

Office of Federal Operations 

Equal Employment Opportunity Commission 

P.O. Box 77960 

Washington, D.C. 20013 

If you submit a request for review to the EEOC via commercial delivery or 

by a method requiring a signature, it must be addressed to: 

Office of Federal Operations 

Equal Employment Opportunity Commission 

131 M Street, N.E. 

Suite 5SW12G 

Washington, D.C. 20507 

(3) Judicial review pursuant to the Whistleblower Protection 

Enhancement Act of 2012. This option applies to you only if you have raised 

claims of reprisal for whistleblowing disclosures under 5 U.S.C. § 2302(b)(8) or 

other protected activities listed in 5 U.S.C. § 2302(b)(9)(A)(i), (B), (C), or (D). 

If so, and your judicial petition for review “raises no challenge to the Board’s 

disposition of allegations of a prohibited personnel practice described in section 

2302(b) other than practices described in section 2302(b)(8), or 2302(b)(9)(A)(i), 

(B), (C), or (D),” then you may file a petition for judicial review either with the 

U.S. Court of Appeals for the Federal Circuit or any court of appeals of 

competent jurisdiction.8 The court of appeals must receive your petition for 

review within 60 days of the date of issuance of this decision. 5 U.S.C. 

§ 7703(b)(1)(B). 

 

8

The original statutory provision that provided for judicial review of certain 

whistleblower claims by any court of appeals of competent jurisdiction expired on 

December 27, 2017. The All Circuit Review Act, signed into law by the President on 

July 7, 2018, permanently allows appellants to file petitions for judicial review of 

MSPB decisions in certain whistleblower reprisal cases with the U.S. Court of Appeals 

for the Federal Circuit or any other circuit court of appeals of competent jurisdiction. 

The All Circuit Review Act is retroactive to November 26, 2017. Pub. L. No. 115-195, 

132 Stat. 1510. 
14

If you submit a petition for judicial review to the U.S. Court of Appeals for 

the Federal Circuit, you must submit your petition to the court at the 

following address: 

U.S. Court of Appeals 

for the Federal Circuit 

717 Madison Place, N.W. 

Washington, D.C. 20439 

Additional information about the U.S. Court of Appeals for the Federal 

Circuit is available at the court’s website, www.cafc.uscourts.gov. Of particular 

relevance is the court’s “Guide for Pro Se Petitioners and Appellants,” which is 

contained within the court’s Rules of Practice, and Forms 5, 6, 10, and 11. 

If you are interested in securing pro bono representation for an appeal to 

the U.S. Court of Appeals for the Federal Circuit, you may visit our website at 

http://www.mspb.gov/probono for information regarding pro bono representation 

for Merit Systems Protection Board appellants before the Federal Circuit. The 

Board neither endorses the services provided by any attorney nor warrants that 

any attorney will accept representation in a given case. 

Contact information for the courts of appeals can be found at their 

respective websites, which can be accessed through the link below: 

http://www.uscourts.gov/Court_Locator/CourtWebsites.aspx. 

 

 

FOR THE BOARD:

Washington, D.C.

 /s/ for 

Jennifer Everling

Acting Clerk of the Board