U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Office of Federal Operations P.O. Box 77960 Washington, DC 20013 Micheline L.,1 Complainant, v. Megan J. Brennan, Postmaster General, United States Postal Service (Great Lakes Area), Agency. Appeal No. 0120151957 Hearing Nos. 440-2012-00122X & 440-2013-00162X Agency Nos. 4J-530-0088-11 & 4J-530-0012-13 DECISION On May 6, 2015, Complainant filed a timely appeal, pursuant to 29 C.F.R. § 1614.403(a), from a final Agency decision (FAD) dated April 3, 2015, concerning her two her equal employment opportunity (EEO) complaints that alleged employment discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII), as amended, 42 U.S.C. § 2000e et seq., Section 501 of the Rehabilitation Act of 1973 (Rehabilitation Act), as amended, 29 U.S.C. § 791 et seq., and the Age Discrimination in Employment Act of 1967 (ADEA), as amended, 29 U.S.C. § 621 et seq.2 BACKGROUND At the time of events giving rise to her complaints, Complainant worked as a Letter Carrier (City) at the Agency's Arlington Heights Post Office in Arlington Heights, Illinois. On November 28, 2011, Complainant filed EEO Complaint 1 (4J-530-0088-11/440-2012-00122X). On December 20, 2012, she filed EEO Complaint 2 (4J-530-0012-13/440-2013-00162X). She alleged therein that she was discriminated against based on her race/color (White), disability (neck and back), age (47/48), sex (female - only Complaint 1) and reprisal for prior protected EEO activity when: 1. from July 1, 2011, and ongoing she has not been awarded her new bid assignment (Complaint 1); 2. on August 8, 2011, she was taken off her Rehabilitation Modified assignment - Route 0571, and told she was an unassigned regular (Complaint 1); and 3. on September 26, 2012, she was issued a Notice of 7-Day Suspension. The Agency separately investigated Complaints 1 and 2. After Complaint 1 was investigated, in March 2012, Complainant requested a hearing thereon. In August 2012, an Equal Employment Opportunity Commission (EEOC or Commission) Administrative Judge (AJ) sent Complainant an Acknowledgment and Scheduling Order setting forth the discovery schedule, etcetera, on Complaint 1. On or about September 26, 2012, Complainant retained a law firm to represent her on Complaint 1. Complainant retained the same law firm to represent her on Complaint 2 before formally filing it in December 2012. During the investigation of Complaint 2, Complainant withdrew her age discrimination claim on this complaint. After the Agency investigated Complaint 2, in May 2013, Complainant requested a hearing thereon. In August 2013, the above AJ issued his Acknowledgement and Scheduling Order on this complaint. The parties separately conducted discovery on Complaints 1 and 2 - first on Complaint 1, then on Complaint 2. Complainant filed three motions with the AJ to consolidate Complaint 2 with Complaint 1 - first in January 2013 - prior to the Agency accepting Complaint 2 for investigation, then in May 2013 - days after filing her hearing request on Complaint 2, and lastly in September 2013 - shortly after the AJ issued his Acknowledgement and Scheduling Order on Complaint 2. In denying the first motion the AJ wrote in part that at this point Complainant's allegations on Complaint 2 are simply that and no evidence connected the two complaints. In denying the second motion, the AJ added that if hearings on both cases are deemed appropriate, he may consolidate them for hearings purposes. On May 6, 2014, the AJ granted Complainant's third motion to consolidate for hearing purposes. Sometime prior to the hearing, Complainant withdrew her age claim on Complaint 1, characterized her race/color claim was a race claim, and then withdrew her race claim. During the hearing, Complainant withdrew her sex claim. At the very end of the second day of the hearing on Complaints 1 and 2, Complainant withdrew Complaint 2. Following the three-day hearing, the AJ found the following. The Agency failed to accommodate Complainant's disability when effective on or about June 4, 2011, it modified her route (0571) in a way that violated her medical restrictions - adding walking relays. On June 21, 2011, Complainant bid on Route 08015 (which she believed was within her medical restrictions). While she was the senior bidder, around July or August 2011, the Agency denied her bid because she did not provide medical documentation verifying she could fully assume the duties thereof within six months, and became an unassigned regular. The Agency did not engage in the interactive process to find a solution - a reasonable accommodation. The Rehabilitation Act only permits requests for medical documentation where it is necessary to determine that an individual has a covered disability for which an accommodation is necessary, the Agency already possessed medical documentation, and while an update would be helpful it was not necessary to engage in the interactive process. While the Agency argued that it reasonably accommodated Complainant as an unassigned regular by providing her various daily assignments in her craft within her medical restrictions, it violated its duty to reasonably accommodate her disability by restructuring her job rather than effectively reassign her. The AJ found discrimination based on disability, and did not make a ruling on reprisal. As relief, the AJ ordered the Agency to pay $15,000 non-pecuniary damages, train all managers and supervisors at the Arlington Heights and Rolling Meadows, Illinois facilities on anti-discrimination laws focusing on the distinction between the Agency's light and limited duty policies and the requirements of the [Rehabilitation Act] and the Act's requirement to engage in the interactive process, to post a notice concerning non-discrimination, and process the fee petition which Complainant's attorney files. By final action dated February 5, 2015, the Agency decided to fully implement the AJ's decision. Complainant did not appeal. In March 2015, Complainant's law firm submitted a fee petition to the Agency. It asked for $367,362.50 in attorney fees, and no costs. The breakdown is as follows. Attorney 1's hourly rate was $490, and Attorney 2's was $240. The law firm worked on Complaints 1 and 2 for a total of 751.25 hours. Of this, Attorney 1 worked 748.25 hours, and Attorney 2 worked 3 hours. Accordingly, the sum is arrived at as follows: 748.25 hours X $490 = $366,642.50; 3.0 hours X $240 = $720; $366,642.50 + $720 = $367,362.50. The Agency cut the requested fees, awarding a total of $73,242.45. It reasoned as follows. The reasonable hourly rate for Attorney 1 is $323.40. Attorney 2's hourly rate is not disputed. Prior to the law firm's October 5, 2012 notice of representation to the Agency, on Complaint 1 Attorney 1 worked 1.75 hours and Attorney 2 worked 1 hour. The Commission has ruled that only two hours is reasonable to determine whether to represent a client. Also, this time was duplicative of Attorney 1's work. Accordingly, .75 hours of Attorney 1's billing is cut. An across the board reduction of 40% is made for excessive and repeated billing, unnecessary legal research, time entries for "organizing" files where Attorney 1 did not explain how any issue was advanced, combining tasks in billing/time entries so that it is impossible to determine whether a reasonable amount of time was expended on each task, insufficiently specific research time entries, and not identifying in time entries whether the work was for Complaint 1 or Complaint 2, even though Complainant did not prevail on Complaint 2. Some illustrations of referenced time entries were given. An additional across the board cut of 50% of the remaining bill is made for withdrawn and lost issues, i.e., the bases of race, sex, and reprisal, and Complaint 2. On appeal, Attorney 1 argues that his hourly rate of $490 is reasonable. In his fee petition, Attorney 1 wrote "the hourly rate of the attorneys who rendered services in this proceeding is: [Attorney 1] $490 per hour...." On appeal, he submits an affidavit clarifying that $490 is the normal hourly rate his firm applies for his services to clients, not a rate formulated for this litigation. Attorney 1 concedes that Complainant withdrew Complaint 2, but argues both complaints are connected because they flowed from the Postmaster's indifference to Complainant's disability and failure to accommodate such, and the prosecution of Complaint 2 provided evidence to buttress the finding of discrimination on Complaint 1 - i.e., the Postmaster's indifference. On the withdrawal and/or loss of Complainant's race, sex, and reprisal claims, Attorney 1 argues that that the evidence on them for the most part was the same as on the meritorious disability claims, and involved a common core of facts. Attorney 1 argues that his research was necessary, the time he billed was reasonable, not repetitious or exaggerated, and the time/billing entries were not vague. Attorney 1 argues that he should be awarded the full amount billed. In opposition to the appeal, the Agency argues that the FAD should be affirmed. In reply to the opposition, Attorney 1 argues again that he should be awarded the full amount billed. ANALYSIS AND FINDINGS The starting point for determining attorney fees is multiplying the number of hours reasonably expended by a reasonable hourly rate (known as the lodestar), and there is a strong presumption that this amount represents the reasonable fee. 29 C.F.R. § 1614.501(e)(2)(ii)(B); Hensley v. Eckerhart, 461 U.S. 424, 434 (1983). A reasonable hourly rate is based on "prevailing market rates in the relevant community" for attorneys of similar experience in similar cases. Cooley v. Dep't. of Veterans Affairs, EEOC Request No. 05960748 (July 30, 1998) (quoting Blum v. Stenson, 465 U.S. 886 (1984)). For private attorneys, the best evidence of a reasonable hourly rate is the hourly rate customarily charged by the attorney for fee paying clients. Id. Here, Attorney 1 affirms that his normal billing rate to clients is $490 hourly. Applying Cooley, we find this is sufficient to show by a preponderance of the evidence that $490 is a reasonable hourly rate for Attorney 1. We add that Attorney 1 has been practicing law for over 50 years with a concentration in employment and labor relations, and practices in the Chicago, Illinois. Given this, Attorney 1's affirmation that his normal hourly rate applied to clients is $490 is not unexpected. EEOC Regulation 29 C.F.R. § 1614.501(e)(1)(iv) provides attorney fees shall be paid for services performed by an attorney after the filing of a written complaint, provided that the attorney provides reasonable notice of representation, except that fees are allowable for a reasonable time prior to the notification of representation for any services performed in reaching a determination to represent the complainant. Accordingly, no billing before the date the formal complaint is filed is usually eligible for reimbursement, with the above exception. Mellea v. Department of Veterans Affairs, EEOC Appeal No. 01963152 (Nov. 27, 1996). Here, Attorney 1 used the services of Attorney 2, another attorney in his law firm who bills at a lower rate, to assist him in determining whether to represent Complainant. While in cases the Commission has generally held that up to two hours is reasonable to make this determination, we find 2.75 hours was reasonable in this case because it involved complex issues of denial of reasonable accommodation and was already in the discovery phase when Complainant went to the law firm. Koehler v. General Services Administration, EEOC Appeal No. 01A02276 (Sept. 4, 2002) (seven hours to determine whether to represent client was reasonable). We also find that the Agency has not shown that Attorney 2 assisting Attorney 1 was duplicative - other than Attorney 2 reviewing Attorney 1's notes of his interview of Complainant, they performed different work. The number of hours requested should not include excessive, redundant, or otherwise unnecessary hours. Hensley v. Eckerhart, 461 U.S. 424, 434; Bernard v. Dep't. of Veterans Affairs, EEOC Appeal No. 01966861 (July 17, 1998). In determining the number of hours expended the Commission recognizes that the attorney "is not required to record in great detail the manner in which each minute of his time was expended." Bernard v. Dep't of Veterans Affairs, EEOC Appeal No. 01966861 (July 17, 1998). However, the attorney does have the burden of identifying the subject matters which he spent his time by submitting sufficiently detailed and contemporaneous time records to ensure that the time spent was accurately recorded. Id. We decline to affirm the Agency's 40% across the board cut to the remaining attorney fees. We disagree that the law firm's time/billing entries were insufficiently specific. By comparing the time entries with the record, the latter of which shows when Complainant filed Complaints 1 and 2, when they were investigated, when discovery on each occurred, and contains many of the documents referenced in the time entries, for the most part we could discern what Attorneys 1 and 2 were working on at any given time.3 Based on our review, even when entries were combined, such as talking to the client on the telephone and drafting a document, we find that Attorneys 1 and 2 did not engage in excessive billing (meaning taking an unreasonable amount of time to complete a task), nor duplicate billing. In the practice of law, time must often be devoted to matters that may not ultimately be reflected in a final work product, but attorney time, if reasonably expended, is nevertheless compensable. Amaro v. United States Postal Service, EEOC Appeal No. 01A43288 (Jul. 20, 2005). The Agency found Attorney 1's research on burdens of proof, disparate impact, mixed case appeal procedures,4 the effect on EEO remedies caused by filing a union grievance on the same matter; as well as filing a motion with the AJ to issue a subpoena to the Office of Workers' Compensation Programs (OWCP) to obtain Complainant's OWCP files from 1989 forward was unnecessary or wasteful. We disagree. Legal research often goes up blind alleys before yielding fruit. While the AJ did not have authority to issue a subpoena to OWCP, he directed the Agency to send to OWCP his order requesting OWCP to produce the documents. Agencies are not required to pay attorney fees for tasks that are clerical in nature. Martina S. v. Department of Homeland Security, EEOC Appeal No. 0120160001 (Jan. 24, 2017). This includes "organizing exhibits for opposing counsel." Id. See also, Jacobsen & Taft v. Dep't of the Navy, EEOC Appeal Nos. 0720100046 & 0720100047 (Sept. 7, 2012) (disallowing time to "organize file"). We find that a time entry by Attorney 1 for 3.5 hours on January 9, 2015, to "organize and prepare files" is clerical in nature, and hence disallowed.5 This organization/preparation was done after the hearing, after Complainant's last submission to the AJ, and before the AJ's decision. While Attorney 1 made a few prior time entries on organizing evidence, documents, and files on Complaint 1, we find that it is more likely than not that this activity was not clerical in nature, but rather part of the process of selecting evidence to support different points. Attorney fees may not be recovered for work on unsuccessful claims. The fact that a complainant did not prevail on every aspect of her complaint does not, in itself, justify a reduction in the hours expended where the claims are intertwined, making it impossible to segregate the hours involved in each claim. Hensley, at 433, 448. Courts have held that fee applicants should exclude time expended on "truly fractionable" claims or issues on which they did not prevail. National Association of Concerned Veterans (NACV) v. Secretary of Defense, 675 F.2d 1319, 1337 n. 13 (D.C. Cir. 1982). Claims are fractionable or unrelated when they involve "distinctly different claims for relief that are based on different facts and legal theories." Hensley, 461 U.S. at 434-35. Complainant did not prevail on Complaint 2, which regarded her seven-day suspension. On September 3, 2011, Complainant broke her ankle, returned to duty in May 2012, and in July 2012 was awarded Route 08015. In September 2012, the Postmaster gave Complainant a Notice of 7-Day Suspension for nine days of intermittent unscheduled leave from June 2012 - August 2012. Complainant contended her absences were because she was sick on antibiotics, had a migraine headache, and her sister had emergency surgery and almost died. We agree with the Agency's position that Complainant is not entitled to attorney fees for work done on Complaint 2. Complaints 1 and 2 do not share a common core of facts, and are different in nature. First, the events are separated in time - Complainant was suspended more than a year after being taken off Route 0571, denied her bid on Route 08015, and becoming an unassigned regular. Second, Complaint 1 concerned the Agency failing to reasonably accommodate Complainant by adding work to her route outside her medical restrictions and then in effect reassigning her by giving her various and sundry duties outside her bid assignment. Complaint 2 regarded the Agency not excusing Complainant's absences, none of which she attributed to being assigned work outside her medical limitations or being an unassigned regular. Further, Complaints 1 and 2 were filed more than a year apart, were separately investigated, and discovery on them was separately conducted - at least eight or nine months apart. The Agency also found that Complainant should not be paid attorney fees for work done on her race, sex, and reprisal claims, since they were either withdrawn/the AJ did not make a finding of discrimination on them. We only address Complaint 1 on this matter since we already ruled Complainant is not entitled to attorney fees on Complaint 2. The relief the AJ ordered which was personal to Complainant for disability discrimination completely overlapped any relief he could have ordered for other bases, and all the bases were about a common core of facts - Complainant's routes and assignments. Accordingly, we reverse any cut in fees the Agency made because of the bases matter. We disagree with the Agency's decision to make a 50% across the board cut on the remaining portion of the attorney fees because Complainant did not prevail on certain matters. First, we reversed the Agency's deduction for Complainant not prevailing on certain bases of discrimination. Second, after reviewing the law firm's billing entries and comparing them to the record, we were generally able to discern when work was on Complaint 1, Complaint 2, or both simultaneously. Contributing to this was that the complaints were filed a year apart, separately investigated, discovery on them was eight or nine months apart, and they involved distinctly different matters, so written submissions on them during the hearing process were distinguishable. Also, we reviewed the hearing transcript, which shows substantially more time was spent in the hearing on Complaint 1 than Complaint 2. We don't claim that that the hours we attribute to each complaint is precisely correct, but find in this case counting the hours spent on Complaint 2 is more accurate than an across-the-board cut approach. We agree with the Agency, and disagree with Attorney 1 that the time he spent successfully blocking the Agency's discovery request for Complainant's medical records on her visits to psychotherapist she started seeing in September 2013, was work solely on Complaint 2. This was part of the discovery process on Complaint 2, about a year after discovery on Complaint 1 was completed. We attribute all work to consolidate the complaints to Complaint 2. We attribute all settlement negotiations to Complaint 1 since more likely than not such negotiations on Complaint 2 would also be on Complaint 1 and be inseparable therefrom. We attribute all work on the logistics of the pre-hearing conference held around June 2014 to Complaint 1 since it regarded both complaints and similar logistics would occur regardless of whether there were one or two complaints. After the AJ on May 6, 2014, consolidated Complaints 1 and 2 for hearing purposes, there were many time entries which more likely than not were for work on both Complaints 1 and 2 that included work which would not have occurred absent Complaint 2. For this work, we cut the hours by 50%. The earliest example is part of a time entry on June 6, 2014, to review evidence and prepare a pre-trial brief, and most of the time entries from June 12, 2014 through September 8, 2014. Of these referenced time entries, we attribute a few solely to Complaint 1 or Complaint 2, e.g., a motion on a pretrial ruling on evidence relating to only Complaint 2, preparing a witness who testified only on Complaint 1, and reviewing evidence and formulating a position on the suspension. After Complainant withdrew Complaint 2, we attribute all work to Complaint 1. We find that of the 751.25 hours billed, 452 hours were spent on Complaint 1, 3.5 of which are not allowable because they were clerical in nature. Of the remaining 448.50 hours spent on Complaint 1, three are at the hourly rate of $240, and 445.50 are at the hourly rate of $490. Accordingly, we award $219,015. This sum was arrived at as follows: 445.50 X $490 = 218,295; 3 X 240 = $720; $218,295 + $720 = $219,015. The FAD is Modified. The Agency shall comply with the Order below. ORDER (D0617) The Agency is ordered to take the following remedial action: Pay $219,015 in attorney fees to Attorney 1 and/or his law firm, less attorney fees the Agency already paid in this case to Attorney 1 and/or his law firm. The Agency shall make this payment within 60 calendar days of the date of this decision. The Agency is further directed to submit a report of compliance in digital format as provided in the statement entitled "Implementation of the Commission's Decision." The report shall be submitted via the Federal Sector EEO Portal (FedSEP). See 29 C.F.R. § 1614.403(g). The report must include evidence that the corrective action has been implemented. ATTORNEY'S FEES (H1016)6 If Complainant has been represented by an attorney (as defined by 29 C.F.R. § 1614.501(e)(1)(iii)), she is entitled to an award of reasonable attorney's fees incurred in the processing of the complaint. 29 C.F.R. § 1614.501(e). The award of attorney's fees shall be paid by the Agency. The attorney shall submit a verified statement of fees to the Agency -- not to the Equal Employment Opportunity Commission, Office of Federal Operations -- within thirty (30) calendar days of the date this decision was issued. The Agency shall then process the claim for attorney's fees in accordance with 29 C.F.R. § 1614.501. IMPLEMENTATION OF THE COMMISSION'S DECISION (K0617) 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 in the digital format required by the Commission, and submitted via the Federal Sector EEO Portal (FedSEP). See 29 C.F.R. § 1614.403(g). 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 (M0617) 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. A party shall have twenty (20) calendar days of receipt of another party's timely request for reconsideration in which to submit a brief or statement in opposition. See 29 C.F.R. § 1614.405; Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614 (EEO MD-110), at Chap. 9 § VII.B (Aug. 5, 2015). All requests and arguments must be submitted to the Director, Office of Federal Operations, Equal Employment Opportunity Commission. Complainant's request may be submitted via regular mail to P.O. Box 77960, Washington, DC 20013, or by certified mail to 131 M Street, NE, Washington, DC 20507. 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 agency's request must be submitted in digital format via the EEOC's Federal Sector EEO Portal (FedSEP). See 29 C.F.R. § 1614.403(g). The request or opposition must also include proof of service on the other party. Failure to file within the time period will result in dismissal of your request for reconsideration as untimely, unless extenuating circumstances prevented the timely filing of the request. Any supporting documentation must be submitted with your request for reconsideration. The Commission will consider requests for reconsideration filed after the deadline only in very limited circumstances. See 29 C.F.R. § 1614.604(c). COMPLAINANT'S RIGHT TO FILE A CIVIL ACTION (R0610) This is a decision requiring the Agency to continue its administrative processing of your complaint. However, if you wish to file a civil action, you have the right to file such action in an appropriate United States District Court within ninety (90) calendar days from the date that you receive this decision. In the alternative, you may file a civil action after one hundred and eighty (180) calendar days of the date you filed your complaint with the Agency, or filed your appeal with the Commission. If you file a civil action, you must name as the defendant in the complaint the person who is the official Agency head or department head, identifying that person by his or her full name and official title. Failure to do so may result in the dismissal of your case in court. "Agency" or "department" means the national organization, and not the local office, facility or department in which you work. Filing a civil action will terminate the administrative processing of your complaint. RIGHT TO REQUEST COUNSEL (Z0815) If you want to file a civil action but cannot pay the fees, costs, or security to do so, you may request permission from the court to proceed with the civil action without paying these fees or costs. Similarly, if you cannot afford an attorney to represent you in the civil action, you may request the court to appoint an attorney for you. You must submit the requests for waiver of court costs or appointment of an attorney directly to the court, not the Commission. The court has the sole discretion to grant or deny these types of requests. Such requests do not alter the time limits for filing a civil action (please read the paragraph titled Complainant's Right to File a Civil Action for the specific time limits). FOR THE COMMISSION: ______________________________ Carlton M. Hadden's signature Carlton M. Hadden, Director Office of Federal Operations August 8, 2017 __________________ Date 1 This case has been randomly assigned a pseudonym which will replace Complainant's name when the decision is published to non-parties and the Commission's website. 2 We advise the Agency that while it provided Complainant a current Notice of Appeal/Petition form, the address it gave her in the FAD to file an appeal with this office is years out of date. Our current address is in the letterhead of this decision. 3 The record includes the documents the Agency submitted with its opposition brief. 4 Because the mixed case appeals research was done in the context of reviewing procedures for initiating Complaint 2 and raising the matter of Complaint 2 in the form of an amendment, we attribute this time entry to Complaint 2. 5 Since Complainant previously withdrew Complaint 2, we attribute this organizing work to be on Complaint 1. 6 This order applies to all fees incurred after Attorney 1's last billing/time entry in his fee petition. The last billing/time entry was on January 22, 2015. --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ 2 0120151957 10 0120151957