Mary Elizabeth Bullock

" EEOC 3710

does not hold itself
Alabama to theApt.
Street, same8 standard
of "impartiality" and integrity that it demands of
San Diego, California 92104
other agencies." {Personnel
Telephone: (619)info redated by C4C}
866-1194
Email: bullockmaryelizabeth1@gmail.com

February 14, 2019

Molly H. Young, Attorney

Disclosure Unit Via Email Only
U.S. Office of Special Counsel
1730 M Street, N.W., Suite 218
Washington, D.C. 20036-4505

Re: Responses To Questions Re: Alleged Wrongdoing at the EEOC

Dear Attorney Young,

Thank you for the opportunity to answer your questions about my disclosure of wrongdoing at
the EEOC. As you consider my responses, I respectfully urge you to be mindful of EEOC's role
as the lead federal agency responsible for ensuring equal employment opportunity in the
executive branch of the government. In this regard, you may find it helpful to review a
description of EEOC’s federal sector responsibilities which can be found at the following link:
https://www.eeoc.gov/federal/index.cfm

At its core, my disclosure implicates the integrity and legal sufficiency of EEOC's internal EEO
program. There is a serious question as to whether EEOC has somehow exempted itself from
having to comply with the rules and regulations it enforces against other agencies. With that said,
I offer the following responses to your specific questions.

1. I understand your allegations at large to be management abuses at EEOC’s headquarters.

Can you explain to me where the wrongdoing originated or is currently? Is this a systemic issue
throughout EEOC across the country or just in California (regional/national). Or, is it throughout
the OFO (office of federal operations) – and is this a local entity or nationwide?

You are correct that my disclosure alleges management abuses at EEOC's headquarters. The
disclosure focuses on headquarters because EEOC's internal EEO program has always been
controlled by high level officials in Washington, D.C. such as the Chief Operating Officer, the
General Counsel, the OFO Director and OEO Director (among others). These officials oversee
the internal processing of complaints and appeals involving claims of discrimination and
retaliation filed by EEOC employees against EEOC managers across the country, as well as in
headquarters.

My disclosure relies on information which strongly suggests that, when it comes to the internal
processing of EEO complaints, EEOC does not hold itself to the same standard of "impartiality"
and integrity that it demands of other agencies. For example, other agencies are subject to being
RE: OSC DISCLOSURE NO. 19-1357
FEBRUARY 14, 2019
PAGE 2

investigated or sanctioned by EEOC if they are found to have allowed their attorneys to be
involved in the "pre-complaint" and "investigation" stages of an employee's EEO complaint; yet,
EEOC's OGC routinely inserts itself at the early stages of the processing of an EEO complaint
against EEOC. OGC does this to exert influence over the process and to gain a tactical
advantage to defeat an EEOC employee's claims at the "hearing" stage.

Also, as previously noted, EEOC employees are the only federal employees not guaranteed an
impartial adjudicator at the hearing stage of their complaints. Contrary to the policy stated on its
website, EEOC routinely arranges for the complaints of its employees to be adjudicated by
private attorneys that EEOC pays to serve as a judge. These "contract" judges are financially
incentivized to rule in favor of EEOC regardless of the merits of an employee’s claim.

2. What laws, rules or regulations are implicated in your allegations – what ethics/EEOC
internal policies can you point me to that are instructive on these allegations?

The federal sector EEO complaint procedures, which all agencies must follow, are set forth in
EEOC's regulations at 29 CFR Part 1614. These regulations can be accessed through the
following link: https://www.govinfo.gov/content/pkg/CFR-2017-title29-vol4/xml/CFR-2017-
title29-vol4-part1614.xml . Guidance on how to interpret the regulatory scheme for processing
EEO complaints is set forth in EEOC Management Directive 110, which can be accessed
through this link: :https://www.eeoc.gov/federal/directives/md110.cfm

3. I understand your allegations to pertain solely to EEOC complaints against the EEOC by
employees of the EEOC. Is this accurate?

Yes

4. Can you provide me with specific cases (absent any identifying information, of course) that
demonstrate this systemic lack of neutrality in complaints by employees?

I'm not in a position to provide the "specifics" of any employee's case (other than my
own). However, I have no doubt that there are employees who would be willing to cooperate
with any inquiry into the integrity of EEOC's internal complaint process. I can say that I am
personally aware of at least 4 employees who have expressed concerns about EEOC's internal
complaint procedures. One current employee told me she had demanded that EEOC arrange for
her claims to be administratively adjudicated by a judge not paid by EEOC. She has been
waiting 2 years for the EEO office to respond to her.

5. You indicated you have not been with EEOC since 2007. Is this accurate?

It is true that I left EEOC in 2007 but would note that I pursued claims in court against the
agency until 2014, when my case was settled. I have also kept in touch with former colleagues
in the LA District and am regularly contacted by EEOC employees (familiar with my court case)
who reach out to me from around the country. It was through these contacts that I became
RE: OSC DISCLOSURE NO. 19-1357
FEBRUARY 14, 2019
PAGE 3

aware of employees who had complained to the union and to Congress about what they (and I )
believe to be ongoing "corruption" in EEOC's EEO program.

I hope I have answered your questions satisfactorily. Please note that I am available to
provide further information or clarification as desired.

Respectfully,
/s/
Mary Elizabeth Bullock