UNITED STATES OF AMERICA

MERIT SYSTEMS PROTECTION BOARD

AQUETA CLARK,

Appellant,

v.

OFFICE OF PERSONNEL 

MANAGEMENT,

Agency.

DOCKET NUMBER

SF-0752-18-0530-I-2

DATE: July 15, 2024

THIS FINAL ORDER IS NONPRECEDENTIAL1

Jennifer Isaacs, Esquire, Atlanta, Georgia, for the appellant.

Katherine Brewer, Esquire, Washington, D.C., for the agency.

BEFORE

Cathy A. Harris, Chairman

Raymond A. Limon, Vice Chairman

Henry J. Kerner, Member

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which

sustained her 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 statute

1 A nonprecedential order is one that the Board has determined does not add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 Parties may cite nonprecedential orders,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).
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. Except as expressly MODIFIED to

find that the appellant intended to deceive the agency for her own private material

gain, we AFFIRM the initial decision.

BACKGROUND

The essential undisputed facts as set forth by the administrative judge are

as follows. The appellant was formerly employed by the agency as a Special

Agent/Investigator for the National Background Investigations Bureau in Long

Beach, California. Clark v. Office of Personnel Management, MSPB Docket

No. SF-0752-18-0530-I-2, Refiled Appeal File (RAF), Tab 22, Initial Decision

(ID) at 3. The appellant worked from home under a telework agreement and was

“expected to work independently with little daily supervision.” ID at 3-4. Her

job duties included conducting background investigations in the field, obtaining

records, and conducting interviews. ID at 4. Upon completion of a background

investigation, she was responsible for compiling and submitting an official report

of investigation (ROI). Id.

In or around February 2016, the appellant’s former supervisor became

concerned about the appellant’s productivity and began requiring her to submit

daily work reports accounting for the work that she performed each day. Id. In

August 2016, the appellant’s new first-level supervisor reviewed the appellant’s

2
productivity metrics and became concerned that misconduct might be involved.

ID at 5. At management’s request, the agency’s Integrity, Assurance,

Compliance, and Inspections (IA) division opened an investigation into

discrepancies between the appellant’s claimed hours worked and claimed work

produced. Id. After obtaining an affidavit from the appellant and reviewing

various evidence, including the appellant’s ROIs, time reports, daily work

reports, Personnel Investigations Processing System activity logs, field work

system (FWS) activity logs,2 and Government-owned vehicle fuel purchase

reports, the IA issued a report of investigation concluding that the appellant had

not been working the hours that she claimed in her time reports. ID at 5, 7-9;

RAF, Tab 18. Effective May 4, 2018, the agency removed her based on two

charges of failure to work reported hours (13 specifications) and inappropriate

behavior (two specifications). ID at 5.

The appellant filed a Board appeal challenging her removal and raised an

affirmative defense of harmful procedural error. Clark v. Office of Personnel

Management, MSPB Docket No. SF-0752-18-0530-I-1, Initial Appeal File (IAF),

Tab 1.3 After the appellant withdrew her request for a hearing, RAF, Tab 5, the

administrative judge issued an initial decision, based on the written record,

sustaining the appellant’s removal. The administrative judge sustained the failure

to work reported hours charge, although she found that the agency failed to prove

specifications 2, 7, and 8. ID at 6-17. The administrative judge also found that

the agency failed to prove its charge of inappropriate behavior because it failed to

prove specification 2, the only specification before the Board because the

agency’s deciding official did not sustain specification 1. ID at 17-20. The

2 The FWS is a system that investigators utilize as part of their daily duties to, among

other things, input the findings of their investigation and transmit an ROI. Clark v.

Office of Personnel Management, MSPB Docket No. SF-0752-18-0530-I-1, Initial

Appeal File, Tab 8 at 85.

3 The appeal was dismissed without prejudice and automatically refiled on

November 13, 2018. IAF, Tab 15.

3
administrative judge further found that the appellant failed to prove her

affirmative defense of harmful procedural error because the agency was not

required to place her on a performance improvement plan pursuant to 5 U.S.C.

chapter 43 when it elected to remove her pursuant to 5 U.S.C. chapter 75. ID

at 21-22. Finally, the administrative judge found that there was a nexus between

the penalty and the efficiency of the service and the penalty of removal was

reasonable. ID at 20, 22-25. 

The appellant has filed a petition for review, which the agency has

opposed. Petition for Review (PFR) File, Tabs 1, 7. 4

DISCUSSION OF ARGUMENTS ON REVIEW

The administrative judge properly found that the agency proved its charge of

failure to work reported hours.

In this charge, the agency alleged that on various dates from August 4,

2015, to June 2, 2016, the appellant reported that she had worked a full work -day,

but a review of her ROIs reflected that she did not report any leads, meaning that

she did not conduct any interviews or obtain any records, and did not access the

FWS to type any ROIs. IAF, Tab 8 at 10-15, 83-94. According to the agency,

given the duties and responsibilities of an investigator, the appellant could not

have worked a full day without performing any of those tasks. Id. Therefore, it

charged her with failing to work the number of hours claimed on her time sheets.

Without expressly so stating, the administrative judge evidently equated

the unusually worded charge with its more conventional formulation, that is,

falsification of time and attendance records, finding that it required the agency to

prove the following three elements: (1) the appellant reported to the agency that

she worked specified hours; (2) the appellant failed to work those hours; and

4 The agency’s opposition to the appellant’s petition is titled “Response to Petitioner’s

Petition for Review and Cross Petition;” however, “Cross Petition” appears to be a

typographical error to the extent the agency’s pleading does not identify any error in the

initial decision. PFR File, Tab 7.

4
(3) the appellant’s misreporting of those hours was intentional. ID at 6. Neither

party contests this charge construction on review. 5 

The administrative judge found that the agency proved the appellant

reported working a specified number of hours, generally 8 or more hours, on each

of the relevant dates, except where her time report reflected that she used sick

leave or annual leave. ID at 7-9. She further found that the agency proved the

appellant failed to work the hours she reported. ID at 10-12. In particular, the

administrative judge found it undisputed that, on the relevant dates, the appellant

did not conduct interviews, obtain records, or access the FWS to type or transmit

ROIs. ID at 10. She further found that the appellant failed to adequately explain

her claim that she was working diligently on the relevant dates. ID at 11. She

also rejected the appellant’s various explanations for the discrepancies between

the appellant’s time records, ROIs, and daily work reports, i.e., that she had

difficulty tracking down leads, had problems with the FWS, and/or that FWS

records were improperly used to assess the work she performed. ID at 13-16.

Finally, given the absence of any plausible explanation for these discrepancies,

the administrative judge inferred that the appellant intentionally misreported the

number of hours that she worked on the dates in question. ID at 15-17.

On review, the appellant argues that the administrative judge erred in

sustaining this charge for several reasons. First, she contends that the charge is

properly construed as a charge of falsification and that the agency failed to prove

that she knowingly provided incorrect information with the intent of defrauding,

deceiving, or misleading the agency as it relates to her reported work hours. 6

5 The agency argued below that its charge should not be construed as requiring proof of

intent. RAF, Tab 7, Tab 14 at 1-2. The administrative judge disagreed but found that

the agency had proven intent. ID at 6. Thus, the agency proved the charge under either

construction. The agency raises no argument regarding the intent requirement on

review, and therefore, we need not address it here.

6 The appellant also argues that the administrative judge erred in construing the

agency’s charge as alleging that the appellant either did not work at all or completed

only some of the work claimed on the relevant dates. PFR File, Tab 1 at 18. Such an

argument is unavailing because that is precisely what the agency charged the appellant

5
PFR File, Tab 1 at 19-21. However, as noted above, the administrative judge did,

in fact, require the agency to prove the appellant intended to falsify agency

records. IAF, Tab 13 at 4; ID at 6. Moreover, we find unpersuasive the

appellant’s argument that the agency failed to present evidence of intent or that it

only presented tangential circumstantial evidence. PFR File, Tab 1 at 21. To

meet its burden of proof, the agency did not need to produce direct evidence of

intent. See Rodriguez v. Department of Homeland Security, 108 M.S.P.R. 525,

¶ 9 (2008). Because there is rarely direct evidence of intent, the Board must rely

on circumstantial evidence. Id. Accordingly, we discern no error in the

administrative judge’s finding that the agency proved intent via circumstantial

evidence. See Nelson v. U.S. Postal Service, 79 M.S.P.R. 314, ¶ 7 (1998) (stating

that the lack of any credible explanation for the misrepresentation can constitute

circumstantial evidence of an intent to deceive).

Nonetheless, because, as previously noted, the administrative judge

essentially characterized the agency’s charge as falsification of time and

attendance records, we modify the initial decision to address the additional

element of such a charge, that is, whether the appellant intended to defraud the

agency for her own private material gain. See Boo v. Department of Homeland

Security, 122 M.S.P.R. 100, ¶ 12 (2014) (explaining that proof of the intent

element of a falsification charge requires both a showing that the employee

intended to deceive or mislead the agency and that such intent was for his own

private material gain); see also Bradley v. Veterans Administration, 900 F.2d 233,

237 (1990) (noting that examples of private material gain include, among other

things, compensation). As the administrative judge found the appellant received

with in its proposed removal. RAF, Tab 8 at 89. The appellant also contends that the

administrative judge erred in citing to Pope v. U.S. Postal Service, 114 F.3d 1144, 1147

(Fed. Cir. 1997), regarding the agency’s burden of proof for a charge of failure to work.

PFR File, Tab 1 at 15. Such an argument, however, misconstrues the citation, which

was properly cited for the general proposition that, in an adverse action appeal, an

agency must prove that the charged misconduct occurred, there is a nexus between such

conduct and the efficiency of the service, and that the penalty imposed is reasonable.

6
compensation for time during which she did not work, we correspondingly find

the agency established this additional element as well.

Next, the appellant argues that the administrative judge, having improperly

dismissed her argument that she worked on lesser matters on the dates in

question, erred in finding she did not perform the duties of her position on those

dates.7 PFR File, Tab 1 at 17. She also reiterates her contention that her failure

to conduct any leads or to access the FWS on the relevant dates does not render it

implausible that she was, in fact, working. Id. at 17-18. However, as the

administrative judge found, the appellant has failed to offer any details

concerning the work she allegedly performed on the cited dates. ID at 11. 

The appellant further reiterates other defenses to the agency’s charge,

including that she was not required to log in to FWS daily and that other factors,

outside of her control, such as difficulty tracking down leads, affected her overall

productivity. PFR File, Tab 1 at 17-18. However, the administrative judge

considered and rejected such arguments, finding that the appellant’s credibility

was seriously undermined by the unreconciled discrepancies between her daily

work reports and her ROIs, concluding that her daily work reports significantly

overstated the leads she actually conducted on the dates in question. ID at 13-16.

The appellant also contends that the administrative judge erred in

considering her calendar entries to determine what work she performed during the

hours she reported to have been working, asserting that she was not required to

fill out and retain a calendar and her calendar was not intended to justify the work

7 The appellant appears to assert that the agency failed to provide certain evidence in

discovery that would have established that she was working on the relevant dates. PFR

File, Tab 1 at 17-18. However, the record does not reflect that she filed a motion to

compel and, thus, she is precluded from raising this discovery issue for the first time on

review. See Szejner v. Office of Personnel Management, 99 M.S.P.R. 275, ¶ 5 (2005),

aff’d, 167 F. App’x 217 (Fed. Cir. 2006); see also Sanderson v. Office of Personnel

Management, 72 M.S.P.R. 311, 317 (1996) (finding that the appellant was not entitled

to obtain documents on review because he failed to avail himself of the Board’s

discovery procedures below in attempting to obtain them, including filing a motion to

compel), aff’d, 129 F.3d 134 (Fed. Cir. 1997) (Table).

7
that she performed. PFR File, Tab 1 at 14-15. However, the administrative judge

specifically considered the appellant’s calendar entries in evaluating her general

claim that she was working on other matters. ID at 11. Indeed, the appellant

herself states that she submitted them to the agency in order to “supplement her

testimonial evidence that she worked on the dates at issue.” Id. at 15. Moreover,

in finding the appellant failed to work the hours she reported working, the

administrative judge noted she did not dispute that, on the relevant dates, she

conducted no interviews, obtained no records, and never accessed the FWS, or

uploaded ROIs. ID at 10. Accordingly, we discern no error in the administrative

judge’s analysis of the relevant evidence. See, e.g., Crosby v. U.S. Postal

Service, 74 M.S.P.R. 98, 105-06 (1997) (finding no reason to disturb the

administrative judge’s findings when she considered the evidence as a whole,

drew appropriate inferences, and made reasoned conclusions); Broughton v.

Department of Health and Human Services, 33 M.S.P.R. 357, 359 (1987) (same).

The appellant also contends that her appeal is distinguishable from other cases in

which the Board has found that an appellant failed to work her reported hours,

such as Delorito v. Department of the Navy, MSPB Docket No. DC-0752-13-

0517-I-1, and Barber v. U.S. Postal Service, MSPB Docket No. CH-0752-10-

0277-I-1. PFR File, Tab 1 at 16-17. However, such nonprecedential Board

orders are not binding authority and have no precedential authority. 5 C.F.R.

§ 1201.117(c)(2). Furthermore, these cases are not analogous to the present

appeal, as Barber involved a removal based on a violation of a last chance

agreement and Delorito involved an involuntary resignation appeal.

Although the appellant disputes the administrative judge’s fact findings and

credibility determinations as to these various claims, PFR File, Tab 1 at 12-14,

we find she considered the evidence as a whole, drew appropriate inferences, and

made reasoned conclusions on issues of credibility, and therefore see no reason to

disturb her conclusions. Crosby, 74 M.S.P.R. at 105-06; Broughton, 33 M.S.P.R.

at 359. We also find that the administrative judge properly adapted the principles

8
for resolving credibility issues to this case where no testimony occurred. See

Donato v. Department of Defense, 34 M.S.P.R. 385, 389 (1987) (stating that,

when, as here, no hearing was held and the administrative judge’s findings were

based solely on the written record, the Board will give those findings only the

weight warranted by the record and the strength of his conclusions).

The administrative judge properly found that the penalty of removal was

reasonable.

When an agency proves fewer than all of its charges, the Board may

mitigate the agency’s selected penalty to the maximum reasonable penalty, so

long as the agency has not indicated that it desires a lesser penalty to be imposed

on fewer charges. Lachance v. Devall, 178 F.3d 1246, 1260 (Fed. Cir. 1999).

Alternatively, the Board may impose the penalty selected by the agency if, after

balancing the mitigating and aggravating factors, it determines that the agency

has justified its penalty selection as the maximum reasonable penalty. Gray v.

U.S. Postal Service, 97 M.S.P.R. 617, ¶ 11 (2004), aff’s per curiam,

No. 2005-3074, 2005 WL 1368093 (Fed. Cir. June 9, 2005). However, the Board

may not disconnect its penalty determination from the agency’s managerial will

and primary discretion in disciplining employees. Lachance, 178 F.3d at 1258.

The Board has articulated factors to be considered in determining the

propriety of a penalty, such as the nature and seriousness of the offense, the

employee’s past disciplinary record, the supervisor’s confidence in the

employee’s ability to perform his assigned duties, the consistency of the penalty

with the agency’s table of penalties, and the consistency of the penalty with those

imposed on other employees for the same or similar offenses. Douglas v.

Veterans Administration, 5 M.S.P.R. 280, 305-06 (1981). The Board places

primary importance upon the nature and seriousness of the offense and its relation

to the appellant’s duties, position, and responsibilities. See, e.g., Downey v.

Department of Veterans Affairs, 119 M.S.P.R. 302, ¶ 9 (2013).

9
Here, we find that the administrative judge properly weighed the Douglas

factors, including the nature and seriousness of the offense, the fact that the

misconduct was extensive and repeated, the public nature of the appellant’s

position, and the appellant’s supervisor’s loss of trust and confidence in the

appellant’s ability to perform her assigned duties, and concluded that the

discipline was warranted for the sustained misconduct and that the agency’s

penalty was reasonable. ID at 22-25. Based on our review of the record, we

discern no error in the administrative judge’s conclusions. See, e.g., Rohn v.

Department of the Army, 30 M.S.P.R. 157, 158-59 (1986) (sustaining the removal

of an employee who submitted false time cards for six pay periods). The

appellant’s arguments on review concerning the Douglas factors constitute mere

disagreement with the administrative judge’s findings, PFR File, Tab 1 at 22-27,

and are insufficient to disturb the initial decision, see Yang v. U.S. Postal Service,

115 M.S.P.R. 112, ¶ 12 (2010); see also Broughton, 33 M.S.P.R. at 359. Finally,

although the appellant argues that other similarly situated employees were not

removed for similar offenses, IAF, Tab 1 at 18; PFR File, Tab 1 at 25, she has not

identified any evidence that would allow the Board to make a finding on the

issue, see, e.g., Campbell v. Department of the Army, 123 M.S.P.R. 674, ¶ 27

(2016). Accordingly, we discern no reason to disturb the administrative judge’s

finding that the penalty of removal was reasonable.

NOTICE OF APPEAL RIGHTS8

The initial decision, as supplemented by this Final Order, constitutes the

Board’s final decision in this matter. 5 C.F.R. § 1201.113. 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

8

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.

10
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.

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 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. 

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

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. 420 (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

12
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: 

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. 9 The court of appeals must receive your

9 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

13
petition for review within 60 days of the date of issuance of this decision.

5 U.S.C. § 7703(b)(1)(B). 

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. 

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
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: ______________________________

Gina K. Grippando

Clerk of the Board

Washington, D.C.

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