U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Office of Federal Operations P.O. Box 77960 Washington, DC 20013 Bok T.,1 Complainant, v. Carolyn W. Colvin, Acting Commissioner, Social Security Administration, Agency. Appeal No. 0720150014 Hearing No. 420-2012-00145X Agency No. ATL110712SSA DECISION Following its December 4, 2014, final order, the Agency filed a timely appeal which the Commission accepts pursuant to 29 C.F.R. § 1614.405(a). On appeal, the Agency requests that the Commission affirm its partial rejection of an Equal Employment Opportunity Commission Administrative Judge's (AJ) decision. Specifically, the AJ's award of attorneys' fees and costs. For the following reasons, the Commission REVERSES the Agency's final order. ISSUES PRESENTED Whether the AJ made an error of law or abused her discretion when deciding: (1) to award attorneys' fees for Complainant's dismissed claim; (2) to award one of Complainant's attorneys an hourly rate of $450 and; (3) to award Complainant her costs based only on an itemized list. BACKGROUND Complainant worked as a Service Representative in the Agency's field office in Albertville, Alabama. In January 2009, Complainant learned that a coworker (C1) alleged that she was being sexually harassed by an Agency management official. C1 initiated EEO counseling on April 17, 2009. Complainant's first line supervisor (S1) and second line supervisor (S2) were aware of Complainant's involvement as a witness in C1's EEO case because one of them would escort Complainant to meetings with EEO investigators when they came to the office. Additionally, Complainant provided witness affidavits for C1's case in February and April 2010. After Complainant provided testimony in C1's EEO case, she alleges that she was repeatedly called into the office and written up with "Fact Finding Interviews" (FFIs), which were considered part of the "pre-disciplinary process." FFIs remained in an employee's file and the information was considered when making promotion decisions. C1 was removed from the Agency in May 2010, and her complaint proceeded to arbitration in November 2010, and January 2011. Complainant did not participate in the arbitration. However, the Agency's counsel who participated in the arbitration suspected that an Agency employee provided C1 with Agency records because C1 had been terminated from the Agency and she did not have access to those records. S2 tried to determine if queries into those records were related to business reasons. Upon looking into the system traffic, the Agency determined that all employees who had accessed those specific records had input a corresponding action (Ex. change an address or update direct deposit information), except for Complainant. Complainant's managers decided to conduct an FFI and the district manager of a different field office (DM), who did not know Complainant, was asked to conduct the FFI. When DM asked Complainant why she accessed those records, she stated that she could not remember accessing the records; why she accessed the records or; that she had a business reason to access the records. On or about June 21, 2011, Complainant applied for Claims Representative vacancies announced for the Bessemer, Birmingham East and Birmingham Downtown offices. During the selection process, the selecting officials solicited supervisor recommendations. The recommendation form allowed for supervisors to select Highly Recommended, Recommended, or Not Recommended. On July 18, 2011, S1 gave Complainant a rating of Recommended. S2 agreed that Complainant was not Highly Recommended due to recent "integrity issues." The selecting official for the Birmingham Downtown location (SO1) received a best qualified list with approximately 180 candidates. SO1 only considered 50 candidates who received Highly Recommended ratings from their supervisors and therefore Complainant was not considered. SO1 made nine selections and forwarded only the candidates with Highly Recommended ratings to the selecting official for the Bessemer location, who made four selections. The selecting official for Birmingham East received about 150 applications and selected five who were rated Highly Recommended. On July 8, 2011, Complainant initiated EEO counseling alleging that she was being discriminated against and subject to a hostile work environment based on sex (female), age (44), and in retaliation for her participation in C1's EEO complaint.2 Complainant filed a formal EEO complaint on October 10, 2011, and the Agency accepted the following issues for investigation that she was discriminated against when: 1. On May 27, 2011, DM conducted an FFI with Complainant; 2. On June 9, 2011, DM issued a "Record of Interview" of the FFI, which Complainant alleges is a written reprimand; 3. On August 8, 2011, the Agency did not select Complainant for a position of Social Insurance Specialist (Claims Representative) under Vacancy Number SB-493204-11-VC; 4. On August 16, 2011, the Agency did not select Complainant for a position of Social Insurance Specialist (Claims Representative) under Vacancy Number SB-493107-11-RBS and; 5. On August 18, 2011, the Agency did not select Complainant for a position of Social Insurance Specialist (Claims Representative) under Vacancy Number SB-493135-11-TBW.3 Complainant requested a hearing before an EEOC AJ and a hearing was conducted from May 23-25, 2014. On August 29, 2014, the AJ issued a non-final decision finding that Complainant was discriminated against based on reprisal when she was not selected for any of the Claims Representative positions. The AJ found that S1 and S2 retaliated against Complainant when they rated her as "Recommended" to the selecting officials, which prevented her from being considered for the promotion. However, the AJ dismissed Complainant's claims of retaliatory harassment because she had elected to pursue these actions under the grievance process. The AJ also determined that Complainant's qualifications were plainly superior to one of the selected Claims Representatives (SCR) because Complainant had scored one hundred percent each time she took the test for the Claims Representative position; worked at the Agency for approximately twelve years; received nine performance awards; completed over 100 hours of additional social security training and; completed courses at various community colleges. Meanwhile, SCR had only been with the Agency for approximately five years; only received one performance award; had no additional social security training beyond basic proficiency and; had no college degree. As a remedy, the AJ ordered the Agency to provide Complainant with: 1. Back-pay and all other monetary benefits, including cost of living adjustments, from the date of SCR's promotion; 2. Interest on such back-pay at the same rate that the Internal Revenue Service charges on underpayment of taxes, compounded quarterly; 3. Training Complainant would have received had she been selected to fill SCR's position; 4. An adjustment of Complainant's pay scale, retirement contributions and all other employment benefits from the date of SCR's placement in the position until three years after this decision is enforced or until Complainant is placed in a Claims Representative position, whichever is first; 5. If placed in a Claims Representative position, Complainant would have seniority in the position, from the date of SCR's placement into that position, and the salary level she would have occupied in the absence of retaliation; 6. Three years of front pay or place Complainant in a Claims Representative position, in lieu thereof and; 7. $10,000 in non-pecuniary compensatory damages for emotional pain and suffering. Additionally, the AJ instructed Complainant to submit a petition for attorney's fees and costs. In her Verified Statement of Attorney's Fees and Costs, Complainant requested a total of $191,635 in attorneys' fees and $4,792.22 in costs. In regards to the attorneys' fees, Complainant provided a breakdown for 255.30 hours at an hourly rate of $450 for a member of a law firm (Attorney 1) and two other attorneys at an hourly rate of $250 for 294 hours for Attorney 2 and 13 hours for Attorney 3. In support of the $450 hourly rate for the Attorney 1, Complainant provided an August 2014, arbitration award where Attorney 1 was awarded attorney's fees at $450 per hour. Complainant also provided an itemized list of various copies, scans and legal research totaling $4,792.22. On October 24, 2014, the AJ issued the Decision and an Order Entering Judgment. In addition to the remedies listed above, the AJ awarded attorneys' fees in the amount of $189,785 and Complainant's costs in the amount of $4,792.22. The Agency issued its Final Order partially rejecting the AJ's decision and filed an appeal on December 4, 2014. In its Final Order, the Agency decided that it would not fully implement the AJ's decision with respect to the award of the attorneys' fees and Complainant's costs. On January 22, 2015, the Agency submitted its Brief in Support of Appeal. Complainant filed a Reply in Support of Fee Petition on February 20, 2015, requesting that the Commission affirm the attorneys' fees and Complainant's costs awarded in full. CONTENTIONS ON APPEAL In its appeal, the Agency contends that the AJ erred when she determined: 1. A dismissed claim was not an unsuccessful claim; 2. Complainant's two claims were intertwined due to the fact that her attorneys did not specify which hours they worked on each claim; 3. To award an hourly rate of $450 for one of Complainant's attorneys and; 4. To award Complainant all of her costs based only on an itemized list. ANALYSIS AND FINDINGS Standard of Review Pursuant to 29 C.F.R. § 1614.405(a), all post-hearing factual findings by an AJ will be upheld if supported by substantial evidence in the record. Substantial evidence is defined as "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." Universal Camera Corp. v. National Labor Relations Board, 340 U.S. 474, 477 (1951) (citation omitted). A finding regarding whether or not discriminatory intent existed is a factual finding. See Pullman-Standard Co. v. Swint, 456 U.S. 273, 293 (1982). An AJ's conclusions of law are subject to a de novo standard of review, whether or not a hearing was held. An AJ's credibility determination based on the demeanor of a witness or on the tone of voice of a witness will be accepted unless documents or other objective evidence so contradicts the testimony or the testimony so lacks in credibility that a reasonable fact finder would not credit it. See EEOC Management Directive 110, Chapter 9, at § VI.B. (Aug. 5, 2015). The First Circuit in Coutin v. Youna & Rubicam, 124 F.3d 331, 337 (1st Cir. 1997), a case cited by Equal Employment Opportunity Commission Management Directive (MD)-110 for 29 C.F.R. Pan 1614 (Nov. 9, 1999), provides guidance as to the appropriate standard of review for an AJ's determination of attorney's fees: We review fee awards deferentially, according substantial respect to the trial court's informed discretion. See Brewster v. Dukakis, 3 F.3d 488, 492 (1st Cir. 1993). We will disturb such an award only for mistake of law or abuse of discretion. See United States v. Metropolitan Dist. Comm'n, 847 F.2d 12, 14 (1st Cir. 1988). In this regard, an abuse of discretion occurs "when a material factor deserving significant weight is ignored, when an improper factor is relied upon, or when all proper and no improper factors are assessed, but the court makes a serious mistake in weighing them." Foster v. Mvdas Assocs., Inc., 943 F.2d 139, 143 (1st Cir. 1991) [internal quotation marks and citations omitted], 124 F.3d at 336. Therefore, in this appeal, the Commission will determine if the AJ erred as a matter of law or abused her discretion. Attorney's fees Attorney's fees may not be recovered for work on unsuccessful claims. Hensley, 461 U.S. at 434-35. Courts have held that fee applicants should exclude time expended on "truly fractionable" claims or issues on which they did not prevail. See Nat'l Ass'n of Concerned Veterans v. Sec'y of Defense, 675 F.2d 1319, 1327 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. In cases where a claim for relief involves "a common core of facts or will be based on related legal theories," however, a fee award should not be reduced simply because the plaintiff failed to prevail on every contention raised in the lawsuit. Id. at 435. "The hours spent on unsuccessful claims should be excluded in considering the amount of a reasonable fee only where the unsuccessful claims are distinct in all respects from the successful claims." EEO MD-110, at Ch. 11 § VI.F (citing Hensley, 461 U.S. at 440). On appeal, the Agency argues that the AJ should not have awarded attorneys' fees for work on Complainant's dismissed hostile work environment claim because she did not prevail on that claim. The Agency further notes that the dismissed hostile work environment claim was the majority of Complainant's case, which occurred over a nearly three year span while the non-selection claim involved a narrower timeline and was a significantly smaller portion of her case. The Agency notes that Complainant's Post-brief hearing was 56 pages but only a few pages discussed her non-selection and her hearing transcript totaled over 300 pages but only referenced the vacancies a few times. Complainant counters that the AJ appropriately concluded that her unsuccessful hostile work environment claim was inseparable as a factual matter from the non-selection claim, warranting a full compensatory award. Complainant explains that the evidence relating to the hostile work environment claim was necessary to prevail on her retaliation claim. We find that the AJ did not err or abuse her discretion when determining that Complainant's attorneys' fees should be awarded because the AJ found that Complainant was discriminated against based on reprisal when her supervisors "held Complainant's association with the former employee and participation in EEO arbitration against [Complainant] in making a recommendation." We find that Complainant's dismissed retaliatory hostile work environment claim is not truly fractionable from her retaliatory non-selection claim due to a common core of facts. We note that the facts regarding Complainant's involvement in C1's EEO case, which started in 2009, provided evidence of her supervisors' retaliatory animus that supported Complainant's non-selection claim. By federal regulation, the agency is required to award attorney's fees and costs for the successful processing of an EEO complaint in accordance with existing case law and regulatory standards. EEOC Regulation 29 C.F.R. § 1614.501(e)(1)(ii). To determine the proper amount of the fee, a lodestar amount is reached by calculating the number of hours reasonably expended by the attorney on the complaint multiplied by a reasonable hourly rate. Blum v. Stenson, 465 U.S. 886 (1984); Hensley v. Eckerhart, 461 U.S. 424 (1983). There is a strong presumption that the number of hours reasonably expended multiplied by a reasonable hourly rate, the lodestar, represents a reasonable fee, but this amount may be reduced or increased in consideration of the degree of success, quality of representation, and long delay caused by the agency. 29 C.F.R. § 1614.501(e)(2)(ii)(B). The circumstances under which the lodestar may be adjusted are extremely limited, and are set forth in EEO MD-110, Ch. 11 § VI.F. A fee award may be reduced: in cases of limited success; where the quality of representation was poor; the attorney's conduct resulted in undue delay or obstruction of the process; or where settlement likely could have been reached much earlier, but for the attorney's conduct. Id. The party seeking to adjust the lodestar, either up or down, has the burden of justifying the deviation. Id. All hours reasonably spent in processing the complaint are compensable, but the number of hours should not include excessive, redundant or otherwise unnecessary hours. EEO MD-110, at Ch. 11 § VI.F. The Commission has ruled that, when reviewing fee petitions which contain many excessive, redundant, unnecessary or inadequately documented expenditures of time, in lieu of engaging in a line-by-line analysis of each charge claimed, the Commission may calculate the number of hours compensable by applying an across-the-board reduction to the number of hours requested. See Bernard v. Dep't of Veterans Affairs, EEOC Appeal No. 01966861 (July 17, 1998). The Agency argues that the AJ erred when making the determination that the claims were intertwined based on the fact that the attorneys did not specify which hours were devoted to each claim and is requesting to reduce Complainant's attorneys' fees by 75%. The Agency also contends that the attorneys demonstrated a lack of billing judgment when they "pressed on with trying to introduce a claim that they should have known was subject to dismissal." Complainant argues that had she not introduced some of the evidence that was relevant to her dismissed retaliatory hostile work environment claim, she would not have prevailed on her retaliatory non-selection claim because she needed to establish the credibility of her testimony. Before awarding fees, the AJ considered not only Complainants' Petition but also the Agency's objections and Complainants' Reply. Complainants sought $191,635 in attorneys' fees, which the AJ reduced to $189,785. As discussed above, we find that the AJ was correct in finding that the claims were inextricably woven together and agree that it is "impossible to apportion in percentage of time spent on either claim." Apart from its contention that Complainant's attorneys spent unnecessary hours developing her dismissed retaliatory hostile work environment claim, the Agency has not shown that the hours billed were excessive, redundant or otherwise unnecessary; the quality of the representation was poor or; that the attorneys caused an undue delay or obstruction. The reasonable hourly rate is generally determined by the prevailing market rate in the relevant legal community for similar services by lawyers of reasonably comparable skill, experience and reputation. See Blum v. Stenson, supra. The Agency argues that the AJ erred in awarding an hourly rate of $450 to Attorney 1 in Complainant's case. In support of its argument, the Agency provided declarations from two attorneys from the area, one receiving an hourly rate of $350 per hour and the other $300. However, Attorney 1 notes that in 2012, the AJ awarded him attorney's fees at a rate of $400 per hour and since that time; he has gained additional experience and honors. Specifically, he was elected as a fellow to the College of Labor and Employment Lawyers, an honor that none of the comparator lawyers provided by the Agency has achieved. According to Attorney 1 this justifies the fifty-dollar increase in his hourly fee. Moreover, Complainant provided a recent Arbitration Award where Attorney 1 was awarded an hourly rate of $450. Accordingly, we find support for the AJ's determination and further find that she did not err or abuse her discretion when awarding an hourly rate of $450 for the member attorney. A review of the instant record reflects that the AJ did not make a mistake as a matter of law or abuse her discretion in her award of attorneys' fees. The AJ's determinations are sufficiently supported by the documentation provided by Complainant. Accordingly, we affirm the AJ's award of $189,785 in attorneys' fees. Regarding costs, the Agency argues that the AJ erred when awarding Complainant costs based only on an itemized list and that Complainant did not provide receipts or a verified statement of costs. Additionally, the Agency argues that Complainant should not receive costs related to the claim in which she failed to prevail. Complainant counters that the Agency did not provide evidence that the amounts requested were unreasonable or that the AJ abused her discretion in awarding them. We note that the AJ determined that Complainant's costs were compensable and reasonable. The Commission finds that the AJ's award for costs does not indicate an abuse of discretion and we are not persuaded by the Agency's contentions that the award should be reduced as a matter of law. Accordingly, we affirm the AJ's award of $4,792.22 for Complainant's costs. CONCLUSION Based on a thorough review of the record and the contentions on appeal, including those not specifically addressed herein, we REVERSE the Agency's final decision to not implement the AJ's award of attorneys' fees and Complainants costs and AFFIRM the AJ's award. The complaint is REMANDED to the Agency for further processing in accordance with this decision and the ORDER below. ORDER The Agency, to the extent it is has not already done so, is ordered to take the following remedial actions within one hundred and twenty (120) calendar days of the date this decision becomes final: 1. Pay Complainant back-pay and all other monetary benefits, including cost of living adjustments, from the date of SCR's promotion. 2. Pay Complainant interest on such back-pay at the same rate that the Internal Revenue Service charges on underpayment of taxes, compounded quarterly. 3. Provide training to Complainant that she would have received had she been selected to fill SCR's position. 4. Provide an adjustment of Complainant's pay scale, retirement contributions and all other employment benefits from the date of SCR's placement in the position until three years after this decision is enforced or until Complainant is placed in a Claims Representative position, whichever is first. 5. If placed in a Claims Representative position, provide Complainant with seniority in the position, from the date of SCR's placement into that position, and the salary level she would have occupied in the absence of retaliation. 6. Provide Complainant with three years of front pay or place Complainant in a Claims Representative position, in lieu thereof. 7. Pay Complainant $10,000 in non-pecuniary compensatory damages for emotional pain and suffering. 8. Pay Complainants' counsel $189,785 in attorneys' fees and $4,792.22 in costs. 9. Provide eight (8) hours of EEO training to the responsible management officials regarding their responsibilities under EEO laws. 10. Consider taking appropriate disciplinary action against the responsible management officials. The Commission does not consider training to be disciplinary action. The Agency shall report its decision to the Compliance Officer. If the Agency decides to take disciplinary action, it shall identify the action taken. If the Agency decides not to take disciplinary action, it shall set forth the reason(s) for its decision not to impose discipline. If the responsible management officials have left the Agency's employ, the Agency shall furnish documentation of their departure dates. A copy of a report of compliance shall be sent to the Compliance Officer as referenced below. POSTING ORDER (G0914) The Agency is ordered to post at its field office in Albertville, Alabama, copies of the attached notice. Copies of the notice, after being signed by the Agency's duly authorized representative, shall be posted both in hard copy and electronic format by the Agency within 30 calendar days of the date this decision becomes final, and shall remain posted for 60 consecutive days, in conspicuous places, including all places where notices to employees are customarily posted. The Agency shall take reasonable steps to ensure that said notices are not altered, defaced, or covered by any other material. The original signed notice is to be submitted to the Compliance Officer at the address cited in the paragraph entitled "Implementation of the Commission's Decision," within 10 calendar days of the expiration of the posting period. ATTORNEY'S FEES (H0610) If Complainant has been represented by an attorney (as defined by 29 C.F.R. § 1614.501(e)(1)(iii)), he/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 this decision becoming final. 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 (K0610) Compliance with the Commission's corrective action is mandatory. The Agency shall submit its compliance report within thirty (30) calendar days of the completion of all ordered corrective action. The report shall be submitted to the Compliance Officer, Office of Federal Operations, Equal Employment Opportunity Commission, P.O. Box 77960, Washington, DC 20013. 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 (M0815) The Commission may, in its discretion, reconsider the decision in this case if the Complainant or the Agency submits a written request containing arguments or evidence which tend to establish that: 1. The appellate decision involved a clearly erroneous interpretation of material fact or law; or 2. The appellate decision will have a substantial impact on the policies, practices, or operations of the Agency. Requests to reconsider, with supporting statement or brief, must be filed with the Office of Federal Operations (OFO) within thirty (30) calendar days of receipt of this decision or within twenty (20) calendar days of receipt of another party's timely request for reconsideration. See 29 C.F.R. § 1614.405; Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614 (EEO MD-110), 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, P.O. Box 77960, Washington, DC 20013. In the absence of a legible postmark, the request to reconsider shall be deemed timely filed if it is received by mail within five days of the expiration of the applicable filing period. See 29 C.F.R. § 1614.604. The request or opposition must also include proof of service on the other party. 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 Complainants 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 __3/31/16________________ 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 Complainant later abandoned her claims that she was discriminated against based on sex and age. 3 The Agency consolidated Complainant's two EEO cases, ATL-11-0712-SSA and ATL-11-0860-SSA. --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ 2 0720150014 2 0720150014