Professional Documents
Culture Documents
ARVIN A. PASCUAL,
Complainant,
Respondents.
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REPLY
(To Respondents Position Paper)
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alleges that he is being singled out by Mr. Aswin Sukumar from among all the
Respondent Sitels thousands of employees.
Complainant could only wonder how could Respondents alleged that Complainant
fabricated several illnesses such as cervical disc prolapse, peripheral neuropathy,
cervical stenosis, cervical radiculopathy, myofascial pain syndrome, migraine headache,
and acute pharyngitis. Where did Respondents get all these medical terms if
Complainant truly did not submit any medical certificate?
Whereas, the truth is that Complainant has never verbally communicated to any
of the Respondents that he (Complainant) is in extreme pain and unable to report for
work due to the foregoing illnesses which Respondents alleged are but mere
fabrications of Complainants very creative mind. Neither did Complainant communicate
in writing to any of the Respondents that he (Complainant) could not report for work
and merely feigned the foregoing illnesses to justify absences which Respondents
alleged are but mere fabrications of Complainants very creative mind.
The truth is that the Respondents are the one with a very creative mind. They
suppressed the truth that Complainant in fact submitted medical certificates duly
verified by Respondent Sitels Clinic Team1 All of these verified medical certificates
[1] Attached hereto as Annex A up to Annex A-11 and made integral parts hereof are copies of
Complainants verified medical certificates duly copy circulated to Respondents
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were copy circulated via electronic mail correspondence to Respondents Canda, Reyes,
and Argana by Ms. Laureen T. Cabungcal Respondent Sitels Company Nurse. The vile
goals of Respondents in suppressing the truth about the submission of verified medical
certificates by Complainant are as follows:
In The Philippine American Life and General Insurance Co. vs. Angelita Gramaje,
G.R. No. 156963 [November 11, 2004], the Supreme Court explained
[2] Attached hereto as Annex B and made integral part hereof is a copy of Respondent Amor Reyes 2
December 2014 email to Ms. Laureen T. Cabungcal Respondent Sitels Company Nurse
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Bad faith has been defined as a state of mind affirmatively operating with
furtive design or with some motive of self-interest or ill will or for an ulterior
purpose. It implies a conscious and intentional design to do a wrongful act for a
dishonest purpose or moral obliquity.
In SHS Perforated Materials, Inc. vs. Manuel F. Diaz, G.R. No. 185814 [October
13, 2010], the Supreme Court ruled:
(a) In cases where the worker is insured with his consent by the employer, and
the deduction is to recompense the employer for the amount paid by him as
premium on the insurance;
(b) For union dues, in cases where the right of the worker or his union to
check-off has been recognized by the employer or authorized in writing by the
individual worker concerned; and
(c) In cases where the employer is authorized by law or regulations issued by
the Secretary of Labor.
As correctly pointed out by the LA, "absent a showing that the withholding
of complainants wages falls under the exceptions provided in Article 113,
the withholding thereof is thus unlawful."
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What made it impossible, unreasonable or unlikely for respondent to continue
working for SHS was the unlawful withholding of his salary. For said reason,
he was forced to resign (underscoring supplied).
XX XX XX
What is significant is that the respondent prepared and served his resignation
letter right after he was informed that his salary was being withheld. It would
be absurd to require respondent to tolerate the unlawful withholding of his
salary for a longer period before his employment can be considered as so
impossible, unreasonable or unlikely as to constitute constructive dismissal.
Even granting that the withholding of respondents salary on November 30,
2005, would not constitute an unlawful act, the continued refusal to release his
salary after the payroll period was clearly unlawful (underscoring supplied).
The petitioners claim that they prepared the check ready for pick-up cannot
undo the unlawful withholding.
Complainant denies the foregoing allegation having no basis in fact. The truth is
that Respondents Canda and Reyes are well informed that Respondent Sitel had been
incurring pecuniary losses ever since Diosdado Remion was placed on off-the-phone
status effective 14 May 2014 because he continuously receive salary without productive
output. The electronic mail correspondence of Zaldy Espaola dated 29 June 2014
addressed to Shiela Morales HR Generalist and direct report of Respondent Argana
copy circulated to Respondents Canda and Reyes is patently evident of this fact.3
[3] Attached hereto as Annex C and made an integral part hereof is a copy of the electronic mail
correspondence of Zaldy Espaola, coach of Diosdado Remion, dated 29 June 2014
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4. Respondents, in the same paragraph #5, page #4 of their position paper
further alleged that - The Operations Manager for the Comcast account then
instructed Complainant to coordinate with Respondent Sitels Quality Team to review
the complaint and to consult with Human Resources Department on how to proceed
with Mr. Remions case. Despite these very clear instructions, Complainant opted not
to act on this.
Complainant denies the foregoing allegations having no basis in fact. The truth
is that Complainant, on his own volition, coordinated with the Comcast Quality Team as
evidenced by an electronic mail correspondence dated 21 July 2014.4 He requested for
a transcription of the call between Remion and the customer who accused the latter of
exhibiting rude behavior on 13 May 2014. But the Comcast Quality Team failed to
provide him with the transcript of call. The more than sixty (60) days of inaction by
Respondents rendered the retrieval of the call impossible. The transcript of call is a
condition precedent in the issuance of CARE Form 1 (Notice to Explain). Briefly stated,
without the transcript of call, there is no case against Remion.
Complainant admits that in fact he submitted another letter. Aforesaid letter has
the subject: Reply to Revision #2 Notice to Explain (NTE) Dated 4 November 2014
(Annex H up to Annex H-5 of Complainants Position Paper). It was sent to
Respondent Argana via electronic mail on 9 November 2014 at 8:21 A.M.
[4] Attached hereto as Annex D and made an integral hereof is a copy of the electronic mail
correspondence of Complainant Pascual dated 21 July 2014
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On November 11, 2014, an administrative hearing was scheduled. Complainant did
not attend. He only sent the HR Manager an email reiterating his demands in the letter
he submitted. Again, Complainant was insistent that he be provided with a clearer
discussion on his infractions.
The contents of Annex I up to Annex I-3 undeniably established the fact that
it was the inaction of Respondent Argana that rendered Complainant unable to
participate in the administrative hearing.
In Dr. Danilo T. Ting and Mrs. Elena Ting VS. Court of Appeals, G.R. No. 146174,
July 12, 2006, the Supreme Court said
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Complainant denies the foregoing allegation. It has no knowledge or information
sufficient to form a belief as to the truth and correctness of the foregoing allegations.
Complainant denies any omission on his part. Hence, his suspension has no
basis in fact and in law. The real parties who are grossly negligent are the
Respondents themselves. Their combined inaction is the proximate and immediate
cause why Sitel sustained pecuniary losses occasioned by Remions continued
employment. For had anyone among the Respondents been faithful in the performance
of their obligations as required by Sitel Code of Conduct, as follows:
I. FUNDAMENTAL RESPONSIBILITIES
XX XX XX
then even before 1 July 2014 the Remion case is already closed or settled.
Unfortunately, all of them had been remiss in the performance of their duties causing
the Remion case to drag on and remain unresolved until such time Complainant joined
Comcast CSG account as Coach (Supervisor).
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that if he has any concern about the due process and if he thought the decision was
unfair, Complainant could talk to him so that further discussion could be had with him.
Complainant refused to speak up and said that his lawyer instructed him to say
anything at all.
10. Respondents, in paragraph #2, page #6 of their position paper alleged that
On November 22, 2014, after the issuance of the Notice of Decision for the 5-day
suspension, Complainants Operations Manager (Respondent Reyes) sent him a text
message asking if he was reporting for work on that day, then out of nowhere,
Complainant accused Aswin Sukumar of being a racist, he even stated that as a Filipino,
I am totally devastated emotionally and psychologically consequent to the kind of image
I was made to appear by a non-Filipino right in our homeland. Deeply sorry but I cant
muster the emotional strength to be in the same workplace today where my reputation
was injured.
Complainant admits that he was unable to report for work on 22 November 2014
because he was so depressed (a) his right to due process was trampled upon, and (b)
aspersions were casted against his person (reputation) during the 21 November 2014
service of Notice of Suspension.
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11. Respondents, in pages #6 and #7 of their position paper reproduced the
contents of an electronic mail correspondence sent by Respondent Sukumar to
Complainant on 26 November 2014.
Respondent Sukumars reply was obviously sugar coated to dampen the impact
of the aspersions he verbally casted against Complainant on 21 November 2014. It is
most logical that Sukumar will never put in writing anything that will cause him to be
branded as truly anti-Filipino and will reinforced the contents of Complainants 25
November 2014 email.
The events that transpired during the service of 5-day suspension at the 31st
floor conference room of Respondent Sitel on the early morning of 21 November 2014
and the tenor of the words and phrases by which Respondent Sukumar couched his 25
November 2014 reply email are two separate but inter-locking events. The first being
the real scenario (vividly described in Complainants email dated 25 November 2014
[Annex P up to Annex P-1 of Complainants position paper] and 30 November 2014
[Annex Q up to Annex Q-2 of Complainants position paper]) that transpired when
three managers of Sitel in the persons of Respondents Sukumar, Reyes, and Argana
bonded together solely for the purpose of serving the 5-day Notice of Suspension to
Complainant. The second is the response of Respondent Sukumar to Complainants
email wherein he (Complainant) narrated the deplorable treatment he received from
Respondent Sukumar.
12. Respondents, in paragraph #4, page #7 of their position paper alleged that
On December 12, 2014, Complainant asked his manager to receive a similar letter
dated December 9, 2014 where Complainant expressed his intention to resign. His
manager, however, did not receive it as it was already December 12, 2014 when the
letter was tendered to her. Thus, Complainant was asked to update the date on the
letter. Complainant said that he will make a phone call to his lawyer first but he never
returned to have the letter received by his manager.
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On December 18, 2014, Complainant tendered a resignation letter to
management effective that same date which was formally accepted by management on
December 19, 2014.
[a] Complainant tendered his resignation letter, albeit against his will, via
electronic mail to Respondent Lee on 8 December 2014.
[d] Helpless as Respondent Reyes did not grant her signature despite
Complainants pleadings exacerbated by a deep concern that Respondent Reyes will
impute on him (Complainant) an offense of job abandonment, Complainant resorted to
the following courses of action:
[d.2] Printed another copy of the same notice and sent it to Respondent
Reyes via registered mail with return card on 15 December 2014
(Annex V up to Annex V-3 of Complainants position paper).
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13. Respondents, in pages #8 and #9 of their position paper, reproduced an
alleged Complainants Team Performance vs. Goal result as well as Focus Group
Discussion (FGD) result alleged to have been conducted on 13 November 2014.
If these results have basis in fact and Respondent Reyes is truly fair to
Complainant as what she asserts to be, then she should have discuss these results to
Complainant. This is what effective supervision is all about.
This introduction of alleged results (Team Performance vs. Goal and FGD) is but
a desperate attempt by Respondents to prove that Complainant is so inept in the
performance of his duties and responsibilities as coach.
It is rather peculiar, though, that the alleged ineptness of Complainant did not
prompt Respondents to discuss these results to Complainant considering that the
solemnity of Complainant's alleged non-performance was so immense.
Shortly after Complainants transfer to Comcast CSG, his worst nightmare began.
He (Complainant) was made a scapegoat by Respondent Sitels managers like Glenn
Kuan including Respondents Argana, Reyes, and Canda. Respondents and Glenn Kuan,
in cahoot with one another, framed-up Complainant for him to be blamed solely for the
continued employment of Diosdado Jayson Remion (Agent - Comcast CSG) even after
an alleged violation of Comcast Zero Tolerance Policy on or about 13 May 2014.
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induced in Complainant an immense sense of insecurity with his job the threat of
immediate termination from work, if not aggression. This is a heavy burden carried on
Complainants shoulder which resulted to a resolution on his part to protect himself
from uncertainty. Thus, Complainant felt compelled to give up his employment.
14. Respondents, in pages #9 of their position paper, alleged that - During the
mediation, SENa Mediator Ma. Zenaida Nicolas consistently advised Complainant to
speak up and air out his concerns to reach an amicable settlement between the
parties. However, Complainant neither spoke nor uttered even a single word as he just
pointed to his adviser who was allegedly an HR practitioner who did all the talking.
Complainant denies the foregoing allegation. The truth is that during the 1st
conciliation conference on 7 January 2015, Respondents legal counsel, who arrived one
hour late, requested for a re-scheduling of the conciliation conference on 21 January
2015 adducing reason that she has not studied the documents provided her by
Respondent Sitel.
15. Respondents, in paragraph #1, page #11 of their position paper for the nth
time re-stated their fantastically imagined sheer fabrication-by-the-Complainant theory.
Respondents, in their vain attempt to mislead the Honorable Labor Arbiter stated that -
These alleged discrimination and singling out were neither substantiated nor proven by
the Complainant in the mandatory conferences. Such are all sheer fabrications of the
Complainant.
Complainant denies the foregoing allegation. The truth is that there has never
been an instance during any of the mandatory conferences before the Honorable Labor
Arbiter that issues of discrimination and singling out alleged to be alluded to by
Complainant against the Respondents have ever been placed on the table. But the
irrefutable fact is that during the mandatory conference before the Honorable Labor
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Arbiter on 9 June 2015, Respondents, thru counsel, were very emphatic in their reply
to the query of the Honorable Labor Arbiter if there is still a way to amicably settle the
controversy Wala na po! Once again, Respondents shut the door. Thus, the parties
in the instant case were ordered to submit their respective position papers on 3 August
2015.
16. Respondents, in paragraph #2, page #11 of their position paper, alleged that
If any, the only disciplinary action Complainant was ever subjected to was the five-day
suspension for his omission when it appeared that Complainant took no action about his
unproductive agents situation since July 2014 and simply allowed the agent to report
for work every day without taking calls. The penalty of suspension is clearly warranted
under the circumstances.
Complainant denies any omission on his part. Hence, his suspension and
withholding of salaries have no basis in fact and in law. The real parties who are
grossly negligent are the Respondents themselves. Their inaction is the proximate and
immediate cause why Sitel sustained pecuniary losses occasioned by Remions
continued employment. For had anyone among the Respondents been faithful in the
performance of their obligations as required by Sitel Code of Conduct, as follows:
I. FUNDAMENTAL RESPONSIBILITIES
XX XX XX
then even before 1 July 2014 the Remion case is already closed or settled.
Unfortunately, all of them (Respondents) had been remiss in the performance of their
duties causing the Remion case to drag on and remain unresolved until such time
Complainant joined Comcast CSG account as Coach (Supervisor).
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17. Respondents, in page #12 of their position paper, alleged that Complainant
jump the gun on Respondents.
Complainant denies the foregoing allegation. The truth is that it was the
high ranking officials of Sitel in the persons of Respondents Sukumar, Canda, Reyes,
and Argana together with former Operations Manager Kuan who pounced on
Complainant. These high ranking officials of Sitel imposed misplaced "superiority" over
the person of the Complainant. In cahoots with one another, Respondents framed-up
Complainant in order to foreclose even the slightest opportunity of the Complainant to
exculpate himself from liability and be held as the party solely liable for the Diosdado
Remion fiasco.
18. Respondents, in paragraph #5 page #14 of their position paper, alleged that
If he felt aggrieved by the decision of management, he could have appealed to
management pursuant to the grievance procedure.
Complainant denies the foregoing allegation. The truth is that Complainant filed
a grievance in relation to the five day suspension imposed on him by Respondents.
Complainant sent his grievance notice via an electronic mail correspondence first on 25
November 2014 (Annex P up to Annex -1 of Complainants position paper) with a
follow-up on 30 November 2014 (Annex Q up to Annex Q-2 of Complainants
position paper) to (but said grievance notice was treated with cold disdain by)
Respondent Sukumar.
19. Respondents, also in paragraph #5, page #14 of their position paper,
alleged that Instead, he did not air his concerns in the meeting with Aswin Sukumar
and only kept quiet for the entire duration of the meeting insisting that he was advised
by his lawyer not to speak at all.
Complainant admits the allegation above only with regards to the conduct of a
meeting; provided, that such meeting was the one held at the 31st floor conference
room of Respondent Sitel on 21 November 2014. It bears stressing that there has
never been any occasion whereby Complainant had an opportunity to have a meeting
with Respondent Sukumar on one-on-one basis.
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This meeting, which was called by three senior officials of Respondent Sitel in the
persons of Respondents Sukumar, Reyes, and Argana, is solely for the purpose of
serving to Complainant the five-day suspension notice.
20. Respondents, in paragraph #3, page #15 of their position paper alleged that
- Losses in revenue at the rate of almost Php100,000.00 a month suffered by Sitel due
to an inactive employee is not a joking matter. This notwithstanding, it is also
undisputable fact that Complainant allowed Mr. Remion to just sit around and do
nothing for four (4) months and for Sitel to pay the latter his salary totalling
Php70,578.09.
Respondents believed that they are INFALLIBLE being managers and senior
manager of Respondent Sitel. This belief of INFALLIBILITY is supported by
Respondents own admission (page #3 of Sitel CARE Form 2 [Notice of Decision
Imposing 5-Day Suspension against Complainant]) and re-stated in page #16 of
Respondents Position Paper, quote:
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Management, however, recognizes the fact that Diosdado Remion has
been off-the-phones since May, and prior to your appointment as a
coach. It is unfortunate that the employees who were initially
responsible for insuring that proper action was taken on the agents
case have left the company and that the responsibility was inevitably
transferred to you.
In other words, Respondents would like to deliver a message that managers and
senior managers are shielded from any liability despite having absolute knowledge on
the details and status of a customer complaint against an employee such as the alleged
violation of Comcast Zero Tolerance Policy by Diosdado Remion. Only
coaches/supervisors must be subjected to disciplinary actions. This is a patent case of
discrimination.
In The Philippine American Life and General Insurance Co. vs. Angelita Gramaje,
G.R. No. 156963 [November 11, 2004], the Supreme Court explained that
Additionally, the clear import of the above-quoted contents of Sitel CARE Form 2
above is that the investigation of an infraction will inevitably be put to a halt the
moment the supervisor/coach leave Respondent Sitel even though the company stands
to incur financial losses and worst stands to lose its business on account of any
infraction made by its employees that could cause the clients to lose their trust and
confidence (phrase in quotation marks lifted from paragraph #3, page #4 of
Respondents Position Paper).
Be that as it may, Annex C and Annex D hereof clearly show that all
electronic mail correspondences pertaining to Remions alleged violation of Comcast
Zero Tolerance Policy commencing on 14 May 2014 were copy circulated to
Respondents. So that they could not claim innocence that Remion has been receiving
compensation effective 14 May 2014 despite on off-the-phone status. Respondents,
most especially Respondent Canda, could not claim innocence that his Quality Team
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was unable to prepare a transcript of call which is condition precedent by Human
Resources Department in the preparation of Sitel CARE form 1. Hence, a notice to
explain (NTE) could not be served to Remion.
Therefore, the inescapable conclusion is that the real parties who are grossly
negligent are the Respondents themselves who are occupying the ranks of either
manager or senior manager in Respondent Sitel. It is not the hapless coach
(Complainant Pascual) whom Respondents, in cahoots with one another, tried in futility
to be held liable solely and ultimately. Logic dictates that if the combined efforts of
Respondents failed to produce the desired result of getting rid of Remion, how could a
lowly coach like Complainant, who is barely new in the Comcast account, could be able
to accomplish what Respondents are unable to accomplish.
21. Respondents, in paragraph #4, page #15 of their position paper alleged
that - As can be culled from the facts and evidence on record, management had a
valid cause to impose the penalty of suspension on account of Complainants failure to
report his agents fraudulent acts.
Complainant denies the foregoing allegation. In the first place, there is nothing
on record that will show Remion ever committed a fraudulent act. Hence, Respondents
have no basis in fact and in law to impute an offense against Complainant of failure to
report an agents fraudulent act. Such being the case, Complainants suspension and
withholding of salaries are tainted with illegality.
22. Respondents, in the same paragraph #4, page #15 of their position paper
alleged that - The severity of Complainants inaction warranted his dismissal. Hence,
the 5-day suspension is clearly just and within the bounds of reasonableness.
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23. Respondents, in paragraph #6, page #17 of their position paper alleged
that - The fact thus remains is that Complainant was an absentee coach as assessed
by his agents. His repeated failure to report Mr. Remions inactive status to
management is a clear indication that Complainant was not doing his job, or at the
very least, he was not doing it properly.
In Dr. Danilo T. Ting and Mrs. Elena Ting VS. Court of Appeals, G.R. No. 146174,
July 12, 2006, the Supreme Court said
24. Respondents, in paragraph #7, pages #17 and #18 of their position paper
further alleged that - Notwithstanding the above justification for dismissal, herein
Respondents imposed only the penalty of a five-day suspension for Complainants
infractions. This goes to show that the companys policies which regulate their
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employees attendance are not only reasonable and just; they also reflect the
Respondents compassion and understanding for their employees plight.
The chronicle of events from 15 October 2015 (the day Complainant was first
served a Notice to Explain [NTE] and bluntly advised by Kuan hearing yan for
termination, unahan mo na ) upto and until 16 December 2014 (the day Complainant
pleaded in vain to Respondent Argana to release his (Complainant) withheld salaries
betrays a sinister effort by Respondents to do away with Complainant.
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Hearing yan for termination. Unahan mo na.; Complainant had been very
transparent in his dealings with Respondents. Complainant tirelessly communicated
with Respondents. Upon the other hand, Respondents treated everything with cold
disdain. They simply shrugged their shoulders down to all of Complainants
communication efforts.
Quite relevantly, the case of The Philippine American Life and General Insurance
Co. vs. Angelita Gramaje, G.R. No. 156963 [November 11, 2004] is instructive, to wit:
Fifth, as clearly pointed out by respondent, she formally rejected the offer
of P250,000 for her to leave the company. The refutation was done in writing
and duly received by the three highest offices of petitioner, namely: the Office
of the President; the Office of the Executive Vice-President; and the Office of
the Senior Vice-President and Head of Human Resources. Incongruously,
taking into consideration the said contents of the formal letter of rejection, there
was no response whatsoever from the aforesaid offices (underscoring supplied).
It may be true, as stated by petitioner, that "the alleged memorandum pertaining
to the meeting held on 18 November 1998 on the alleged P250,000 settlement
offer was prepared by respondent alone without any participation from the
company," but the fact remains that no formal response was ever made by any
of the three offices which received the same. The contents thereof, if untrue,
would have elicited a stark and strong reaction from any of the three offices
(underscoring supplied).
26. Respondents like a broken music record of the old days incessantly pressed
on their allegation that former Operations Manager Glenn Kuan [who was hired by
Respondent Sitel on 15 June 2014, but for unknown reason suddenly stopped to report
for work commencing on 1 November 2014] allegedly instructed Complainant to refer
the alleged violation of Comcast Zero Tolerance Policy by Diosdado Remion and seek
assistance from the Human Resources Department and the Quality Team are nothing
but hearsay, uncorroborated, and untrustworthy. It deserves scant consideration
because Respondents are unable to proffer any evidentiary support of this alleged
instruction of Kuan.
[a] Result of Focus Group Discussion (FGD) alleged to have been conducted on
13 November 2014. The alleged respondents/interviewees are agents of
Complainant himself who, without a tinge of doubt, will posture protectiveness of
Respondents interest for fear of retaliation and backlash;
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[b] Team Performance vs. Goal result which, similar to the FGD result, was never
discussed with or divulged to Complainant by Respondent Reyes;
It is here that the following, the teaching from De Leon vs. Juyco, [G.R. No. L-46153,
June 5, 1942], citing I Wigmore on Evidence, sec. 277, pp. 566-568, finds relevancy,
viz:
"A party's falsehood or other fraud in the preparation and presentation of his
cause, his fabrication or suspension of evidence by bribery or spoliation, and
all similar conduct, is receivable against him as an indication of his
consciousness that his case is weak or unfounded, and from that
consciousness may be inferred the fact itself of the cause's lack of truth and
merit."
Finally, Complainant respectfully prays for such and other reliefs as may be
deemed just and equitable under the premises.
ARVIN A. PASCUAL
Complainant
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Republic of the Philippines)
: s.s
Quezon City )
VERIFICATION
3. That the allegations therein are correct and true to the best of my own
knowledge and belief and based on authentic records.
ARVIN A. PASCUAL
Complainant/Affiant
SUBSCRIBED AND SWORN to before me, this 17th day of August 2015, in
Quezon City, Metro Manila, Affiant exhibiting to me his Drivers License No. 2-93-
203385 (Expiration Date on July 20, 2016) issued by the Land Transportation Office.
____________________
Administering Officer
Copy furnished:
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