Statement of Issues To Be Raised Filed

USCA Case #19-5119 Document #1795595 Filed: 07/02/2019 Page 1 of 18
UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT
Case No. 19-5119
EDWARD RICHARDSON,
Plaintiff-Appellant,
v.
JEROME H. POWELL, CHAIR, FEDERAL RESERVE BOARD OF

GOVERNORS OF THE FEDERAL RESERVE SYSTEM
Defendant-Appellee.
On Appeal from the United States District Court

for the District of Columbia
The Honorable Rosemary M. Collyer,
Senior District Judge
1:14-cv-1673-RMC
PETITION FOR EN BANC REVIEW

AND UNDERLYING DECISION FROM WHICH APPEAL ARISES AND
STATEMENT OF ISSUES TO BE RAISED
Edward Richardson, Appellant, Pro Se

1819 Meadow Drive
Fredericksburg, Virginia 22405
P. 540/207-1666
E. edwardrichardson27@yahoo.com
BACKGROUND
The Appellant, Edward Richardson, filed his cause of action into the District
Court on October 8, 2014 and amended his claim on March 20, 2015. See
Richardson v. Powell, 14-cv-1673, also regarded as Richardson I, the
Rehabilitation Act claim. The Appellant filed related causes of action; Richardson
v. Sauls, et al., 16-cv-794,1 re Richardson II and Richardson v. Board of
Governors, et al., 16-cv-867, re Richardson III. Richardson II and Richardson III
were both generated by way of incriminating [on the Board’s behalf] discovery
materials released by the Board in Richardson I. Although the Appellant produced
sufficient and preponderant evidence in Richardson I in addition to related cases
Richardson II and Richardson III, the District Court has dismissed each of the
Appellant’s valid causes of action while deliberately ignoring evidence in favor of
the Appellant, also falsifying facts in its March 21, 2019 Memorandum Opinion
that otherwise further sabotage the Appellant’s character and cause of action in
order to favor the Board and support a dismissal of the cause of action. See
1
In Richardson I, the Appellant named various individual-defendants’ in his claim but failed to
state a Constitutional claim for relief under Bivens. The District Court alleged that the Appellant
had stated Constitutional claims and ruled on those nonexistent claims in its March 8, 2016
Memorandum & Opinion [Dkt. 25]. However, in Richardson II the District Court seems to claim
that were dismissed in that case could have been litigated in Richardson I, including the claims
brought under Richardson III. See Richardson v. Sauls, et al, 16-cv-794 [Dkt. 40].
2
Richardson I [Dkt. 148].2 The Appellant seeks review en banc and complete
reversal of the District Court’s March 21, 2019 decision of Richardson I.
STATEMENT OF ISSUES
Issue #1.
In making her rulings in Richardson I and related cases, Richardson II and
Richardson III, Judge Rosemary M. Collyer [as well as the Board] was very well
aware that she had represented member financial institutions of the Board while
serving as legal counsel where the Board itself had financial, political and social
interests representing the same party in those cases. Financial disclosure records
make the revelation that Judge Collyer should not only have recused herself from
the Appellant’s three causes of action, but she should have also recused herself
from related case Burford v. Powell, 15-cv-2074, where the Appellant is highly
referenced. See [Dkt. 64] of said cause of action.
Judge Collyer’s secondary representation of the Board and her bias against
the Appellant is quite evidenced under the various instances that she attempts to
establish defenses for the Board that the Board itself had not established in its own
filings. See Richardson I Memorandum Opinion [Dkt. 148]. Judge Collyer was
well aware that she had also maintained contact with the Board, thereby conspiring
2
The Appellant proceeds page by page of the District Court’s perjurious March 21, 2019
Memorandum Opinion, showing clear and obvious partiality in favor of the Board and violations
of the Judicial Code of Conduct and the Canons that lay therein. And because the violations are
so serious, callous and improper, the Appellant feels that notification to United States Congress
is proper in this matter.
3
to deliberately sabotage Richardson I, as well as Richardson II and Richardson III
before that, in addition to Burford v. Powell. In the Appellant’s Motion for
Summary Judgment [Dkt. 139], he is quite explicit that on June 28, 2018 at 7:07
p.m., [far outside the discovery period and the day prior to the submission of
summary judgment motion] he received an email for Board Counsel Joshua
Chadwick attempting to fabricate and additional Law Enforcement Unit (LEU)
General Order #168 which was now date June 10, 2009 which is two days after the
Appellant’s June 8, 2009 employment date with the Board.3 The fabricated June
10, 2009 G.O. #168 just so happens to be the policy that the District Court relied
on in its Memorandum Opinion even after the Appellant notified the Court that the
document was fabricated in nature.
G.O. #168 dated June 1, 2005 is the Leave Policy that covered the
Appellant’s employment period at the Board. Depositions of Larence Dublin and
Robert Bakale prove this point. Although the Appellant only need to submit a
3
During the Appellant’s administrative investigation by the EEOC, the Board provided the EEO
counselor and investigator with an altered G.O. #168 dated June 30, 2010 that did not apply to
the Plaintiff’s employment as the Plaintiff was terminated by the Board outside of his
probationary period on June 7, 2010, and was a deliberate attempt to obstruct an official
investigation. See [Dkt. 145] ¶ Exhibit X. The Board and Michael Bagley of the Board’s LEU
fabricated a declaration under the penalty of perjury alleging the June 10, 2009 General Order to
be in place during the Appellant’s employment at the Board. This in itself is materially false
because Michael Bagley was not in the Plaintiff chain-of-command and worked in supply and as
a defensive tactics instructor. Therefore, Michael Bagley had no say so whatsoever over leave or
the updating of LEU policies and/or general orders. But here, by backdating G.O. #168 from
June 30, 2010 to June 10, 2009, Judge Collyer and the Board would completely work around the
actual G.O. #168 [dated June 1, 2005] that actually applies to the Appellant’s entire employment
period at the Board from June 8, 2009 to June 7, 2010. See FRB-ER000740-745 of Appellant’s
Exhibit G.
4
calloff slip only after three consecutive days of being off from work, the Appellant
submitted documentation for all of his calloffs. The District Court has severely
construed the evidence in this matter by favoring the Board and allowing for
fabricated documents to enter into the record.
The Appellant hereby seeks complete reversal of the District Court’s March
21, 2019 Memorandum Opinion and Order and for Judge Collyer to be recused for
judicial misconduct and for deliberate bias and prejudice toward the Appellant.
Issue #2.
The District Court has ignored every piece of evidence submitted by the
Appellant proving pretextual discrimination, harassment and disparate treatment
and impact and in support of his Rehabilitation Act claim. Here, the District Court
alleges that the Appellant lied on his SF86 background investigation forms and his
Board application regarding matters related to his employment with the Prince
William County Police Department.4 This is far from fact. First, this materially
4
In a callous and surreptitious effort to undermine the Appellant’s January 22, 2009 resignation
letter, several members of the Prince William County Police Department secretly and falsely
reported that the Appellant had been terminated on January 21, 2009, therefore illegally coercing
the Appellant into two Loudermill Hearings only to find out what evidence the Appellant held as
a whistleblower. The Loudermill hearings were in complete violation of Federal and Virginia
State employment laws as the Appellant had absolutely no clue that he had been illegally listed
as terminated from that department. The Board and District Court’s claim is meritless at best.
The claim that the Appellant violated PWCPD general orders is fabricated. The two cruiser
accidents are not disciplinary in which the actual documents make this point. Lastly, the letter of
reprimand alleging that the Appellant failed to arrest a security guard clearly states “unfounded”
even though PWCPD lied to Billy Sauls about the matter. The goal of PWCPD was to sabotage
the Appellant’s employment with that agency. Neither PWCPD nor the Board for that matter,
have produced a single piece of evidence supporting their allegations.
5
false allegation was [n]ot apart of the Appellant’s June 7, 2010 wrongful
termination from the Board and was only generated during the Appellant’s appeal
process by Board Ombudsman Margaret Shanks out of retaliation only after the
Appellant had received a threatening telephone call and refused to meet with her
without legal representation. By no stretch of the imagination can an agency
ombudsman add an additional charge to an employee’s work record during the
appeals process.
Additionally, Shanks tells the Appellant clearly in his appeal denial letter
that the charge is final and binding and cannot be appealed any further completely
denying the Appellant’s right to due process. Shanks lied about this very fact
during the EEO administration process. See Appellant’s Ex. A, Aff. of Margaret
Shanks, EEO Investigative Summary, pg 36 of 40; compare to Board Ex. B,
Margaret Shanks Appeal Denial Letter. In Keisha Hargo’s deposition she makes
perfectly clear that it is against policy for a Board ombudsman to add an additional
charge to an already terminated employee. See Hargo dep. ¶ 46; ER-FRB001247
of Appellant’s Ex. A.
With regards to the Appellant’s psychological exam, he at no time states that economic issues
were his basis for leaving PWCPD as the District Court has falsely alleged on the record. The
Prince William County Government was experiencing a pay freeze in which no county
employees would receive a merit increase. Additionally, some officers did in fact voice concerns
of a possible layoff from the PWCPD.
6
Furthermore, the Appellant never falsified any information on his SF86 or
Board application. But here, the District Court seeks to undermine the Appellant’s
evidence by providing defenses for similarly situated LEU officers who did in fact
deliberately falsify statements and make omissions on their Board applications and
SF86 background investigation forms.5 See Appellant’s Ex. E. The District Court
alleges that Shandra Love provided exigent circumstances as to why she lied on
both her Board application and SF86 and that Darren Harris was actually talking
about his separation from his wife, and although Rocco Christoff was terminated
by the Manassas City Police Department for knowingly and falsely arresting and
imprisoning an innocent male victim while generating fabricated and material false
police reports in deliberate violation of the United States Constitution, Judge
Collyer alleges that Christoff was truthful, which is far from fact. Christoff alleges
that he was terminated from the Manassas City Police Department for forgetting to
5
The Appellant met with LEU Chief Billy Sauls on May 12, 2010 regarding the issues with
Prince William County where he was a whistleblower, the East court incident, as well as the
Plaintiff’s disability related call offs for which he provided medical documentation for. See
Sauls’ notes ¶ 000187-000190 of Appellant’s Ex. A. The Appellant informed Sauls that he was
not even employed by Prince William County at the time of the falsely alleged termination and
was working for G4S months before the false allegation. See ER-G4S002000-002001; 002048;
and, 002383 of Appellant’s Ex. D. If the Appellant was hired by G4S on January 26, 2009 he
could not have been righteously terminated from Prince William County. However, the facts
remains that the Appellant discussed the matters with Sauls who advised the Appellant that he
would [n]ot be terminated from Board employment.
7
write a police report. See ER-FRB-OPM000129 of Appellant’s Ex. E and Y. The
circumstances surrounding Christoff’s termination are much greater.6
Not only did Shandra Love lie on both her Board application and SF86, she
had more the several bouts of on and off the job misconduct while employed by the
Board, several of which resulted in negative police contact. Official evidence of
these events are all contained in the Appellant’s Exhibits submitted to the District
Court and outlined in his motion for summary judgment. The District Court
follows the Board falsification that Darren Harris was referring to a separation
from his wife with regards to his “separation.” Harris has worked for the
Portsmouth, Virginia Sheriff’s Office and its Police Department. The Sheriff’s
Office employment period was completely omitted from his Board application and
SF86 where he was terminated. Harris himself alleges that he left the Portsmouth
because the job was too hard to perform. See Doc. ER-FRB-OPM000319 of
Appellant’s Ex. Y. The reality of the matter is that Harris resigned from the
Portsmouth Police Department before his termination could be fully processed.
Therefore, Harris lied on both his Board application and SF86 and the District
Court erred in attempting to provide defenses for criminal conduct in effort to
protect the Board.
6
In addition to his prior employment misconduct, Christoff was reprimanded by the Board for
calloffs without supporting documentation.
8
The Appellant also brought up the fact regarding LEU Officer Sean Waye
who embezzled approximately $37,000 gambling at an out of town casino using
the Board’s credit card. Sean Waye was not terminated for his criminal conduct
and remained employed by the Board. LEU Officer Troy Granger was arrested for
driving under the influence of alcohol while serving as a Board police officer and
remained employed by the Board. The Appellant pointed out that Love was
arrested for hit and run and has remained employed by the Board. Board LEU
Officer Alexander Roman has been arrested by the Prince William County Police
Dep’t on various charges and has remained employed by the Board. Although the
Appellant clearly points out the discriminatory pattern by which the Board
operates, the District Court has failed to acknowledge these instances of official
misconduct.7 Now the Appellant reports that Board LEU Supervisor Robert Bakale
brutally assaulted his wife, the mother of his two small children, and has remained
employed by the Board.
As an additional matter, during the Plaintiff’s June 7, 2010 termination
meeting with Kevin May, Marvin Jones and Charles O’Malley, the Appellant was
told by Kevin May that he was being terminated for “call-offs”. There was no
mention of tardies during the meeting. The Appellant recorded the meeting and
7
In the Board’s motion for summary judgment, it clearly admits that the Appellant requested a
reasonable accommodation. The instances of abuse are so clear and concise that the ‘sole’ or
‘but-for’ reason for the Board’s actions and inactions, regardless of whether the Appellant
advances a claim of discrimination based on disparate treatment, mixed-motive, or retaliation.
9
submitted audio files ER-FRB0505171AUD and ER-FRB0505152AUD as
evidence to the Board during the discovery period.8
The District Court makes no mention of these files, but the Appellant
provides this information in detail in his motion for summary judgment ¶ 24. And
the Appellant in no way, shape or form, by law, had to resubmit medical
documents to the Board regarding his disabilities and disability related calloffs that
was already submitted and deliberately destroyed by Board LEU personnel. The
Board was aware of its actions against the Appellant the entire time. The Appellant
respectfully directs this Court to the deposition of Kevin May. See ER-FRB001287
– 001288 of Appellant’s Ex. A.
Here, the District Court’s decision is in direct conflict with the Denial of
Appeal Letter generated by Margaret Shanks which is in conflict with the June 7,
2010 termination meeting. Shanks states that the Appellant wasn’t terminated for
calloffs, but for unapproved tardies. See pg. FRB-ER000167, para. 2 of Board Ex.
B. The Appellant prepared his timely appeal for the reasons the Board set forth
during the June 7, 2010 termination meeting. The Board cannot produce obviously
different reasons for termination after learning of the Appellant’s evidence during
8
To the extent the District Court continues to harp on the fabricated tardies generated by the
Board, it fails in that regard. Call records in the Appellant’s Ex. I provide explicit proof that the
Appellant maintained adequate contact with Bakale and other Board supervisors and managers
even if the Appellant thought that he would be late for work.
10
the appeals process. The Appellant’s due process rights have been severely
violated as a matter of law.
The District Court intentionally failed to act on these discrepancies violating
the Appellant rights as a pro se litigant. The Appellant hereby seeks complete
reversal of the District Court’s March 21, 2019 Memorandum Opinion and Order
and for Judge Collyer to be recused for judicial misconduct and for deliberate bias
and prejudice toward the Appellant.
Issue #3.
The District Court has erred by not recognizing that the Appellant was no
longer on probationary status when he was terminated by the Board. Once the
Appellant began his workday on June 7, 2010, his probationary status was
complete. Moreover, the Board’s own documents prove this point. Doc. 000212 of
Appellant’s Ex. J proves this point. The Board conducted an override in its system
but clearly shows that the Appellant had worked on June 7, 2010. The override
proves that the Appellant was never terminated on June 7, 2010 as the Board tried
to coerce the Appellant into a resignation, thereby backdating the effective date of
the wrongful termination to June 8, 2010.
11
Issue #4.9
With regards to the East court incident, the Appellant never received any
form of disciplinary action by the Board whatsoever of an alleged violation. The
courts have expressly held that no employer can build a portfolio of violations
against an employee with the deliberate intent of termination when counseling,
suspension or retraining could have remedied the employee’s workplace violation
or behavior. Here, the Appellant was accused of the violation in the month of
March 2010. Between March 2010 and June 7, 2010, the Appellant repeatedly
worked lead and secondary at the Board’s East court with absolutely no
counseling, suspension or retraining.
Second, forcing the Appellant to work three separate shifts continuously
when no other LEU officers were forced or even asked to do same was pretextual
discrimination and harassment as a direct result of the Appellant’s reasonable
accommodation requests. The Appellant has proven with preponderant evidence
that he is a person with a disability and the Board has advance notice of the
Appellant’s disability. Contrary to the District Court’s decision, the Board has
9
Although the Board and the District Court both argue that the Appellant is some sort of martyr,
the opposite is true. In the depositions contained in Ex. A., each supervisor in the Appellant’s
chain-of-command admit that the Appellant was a good officer.
12
admitted in its motion for summary judgment that the Appellant made a reasonable
accommodation requests. Furthermore, it was the responsibility of the Board to
engage the Appellant in the interactive process if it felt the Appellant had issues
with disability related calloffs or tardies as so alleged. But again, the deposition of
Frank Williams makes it perfectly that the Appellant had submitted numerous
disability related calloff documents that the Board removed from the Appellant’s
file which was supposed to be secured in a locked file cabinet. See ER-FRB001274
– 001275 of Appellant’s Ex. A. There would be no need to resubmit medical
documents when the Board’s actions were pretextual and the goal was to subject
the Appellant to an adverse action.
Issue 5.10
The District Court once again disregards the Appellants evidence with
regards to his promotion. The Vacant Position Policy clearly states that employees
10
Due to the corruption involved in this case, the Appellant is under no obligation to keep any
evidence, including but not limited to, sealed documents on the records. Congress and the
general public have a right to access matters regarding corruption in its government. Nor is the
Appellant under obligation to refrain from using or referring to said evidence in academic
articles or publications, etc., where the Appellant is author.
13
who do not satisfy the above eligibility requirements may, under certain
circumstances, be allowed to apply for a vacancy. Being 10 point preference
eligible allowed the Appellant the right by law to apply for, and be selected for a
senior officer position. See Board’s Vacancy Position Policy, pgs. 22 – 23 of
Appellant’s Ex. G. As pointed out in the Appellant’s summary judgment motion,
the failure to promote, the deliberate and harsh name calling (“Sumo”) do to the
Appellant’s disability related weight gain, and the Board’s refusal to include the
Appellant of the Hybrid Shift were all pretextual circumstances connected to the
Appellant’s disability, his reasonable accommodation requests, as well as the fact
that he reported that his medical documents were deliberately being removed from
his file to LEU managers and supervisors even before he was subjected to an
adverse action. Indeed, it’s not a matter of when the Hybrid Shift actually began;
it’s a matter that the Appellant was deliberately excluded from the Hybrid Shift
selection process while he was still employed with the Board.
Lastly, the District Court alleges that the harsh name calling he endured by
LEU officer, Himanshu Bhatia was mere teasing. The fact that Bhatia and the
Appellant worked the Chairman’s Detail together where Bhatia observed the
Appellant utilize his albuterol inhalant device, and actually had conversations
about the Appellant’s asthma is far from mere teasing. As the Appellant points out,
Bakale lied about having knowledge of the harsh name calling in the
14
administrative process, but describes his knowledge of the name calling in his
deposition contained in Appellant’s Ex. A. The Appellant notified both Bakale and
Dublin of the instances of harsh disability related name calling but the name
calling continued. Therefore, the name calling endured by the Appellant was
indeed severe and pervasive. No one suffering from morbid obesity should ever
have to listen to a federal judge describe harsh name calling against him or her as
mere teasing as a direct result of disability. And as a matter of fact, asthma is not
the only of Appellant’s disabilities. Morbid obesity is also a disability carried by
the Appellant and diagnosed by the U.S. Dep’t of Veteran Affairs. Morbid obesity
is clear and obvious and as the District Court states was caused by medications
used to treat the Appellant’s asthma.
CONCLUSION
WHEREFORE, the Appellant respectfully requests that this Honorable
15
Court reverse the decision of the District Court in entirety.
Dated: July 2, 2019
Respectfully submitted:
/s/ Edward Richardson

1819 Meadow Drive
Fredericksburg, Virginia 22405
P. 540/207-1666
E. edwardrichardson27@yahoo.com
16
CERTIFICATE OF COMPLIANCE
1. This document complies with the type-volume limitation of Fed. R.
App. P. 32(a)(7)(B) because this brief contains 4,021 words, excluding parts
exempted by Fed. R. App. P. 32(a)(7)(B)(iii).
2. This filing complies with Fed. R. App. P. 32(a)(5) and the type style
requirements of Fed. R. App. P. 32(a)(6) because this brief has been prepared in a
proportionally spaced typeface using Microsoft Word in Times New Roman 14
point type.
3. This brief has been scanned for viruses pursuant to Rule 27(h)(2).

17
CERTIFICATE OF SERVICE
I HEREBY DECLARE that on this 2nd Day of July 2019, I served the
foregoing on the following by CM/ECF Notification; FedEx; United States Postal
Service; electronic mail, and / or hand delivery:
JOSHUA P. CHADWICK, ESQ.,

E. joshua.p.chadwick@frb.gov
KATHERINE POMEROY, ESQ.,
E. katherine.pomeroy@frb.gov
20th and C Streets, N.W.
Washington, D.C. 20551
P. 202/452-3436
Legal Counsels for Appellee
Jerome H. Powell, Chair, Federal Reserve Board
of Governors of the Federal Reserve System

Edward Richardson, Appellant Pro Se
18

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USCA Case #19-5119 Document #1795595 Filed: 07/02/2019 Page 1 of 18

UNITED STATES COURT OF APPEALS

Case No. 19-5119

JEROME H. POWELL, CHAIR, FEDERAL RESERVE BOARD OF

On Appeal from the United States District Court

PETITION FOR EN BANC REVIEW

Edward Richardson, Appellant, Pro Se

Richardson v. Powell, 14-cv-1673, also regarded as Richardson I, the

v. Sauls, et al., 16-cv-794,1 re Richardson II and Richardson v. Board of

Governors, et al., 16-cv-867, re Richardson III. Richardson II and Richardson III

materials released by the Board in Richardson I. Although the Appellant produced

sufficient and preponderant evidence in Richardson I in addition to related cases

Appellant’s valid causes of action while deliberately ignoring evidence in favor of

reversal of the District Court’s March 21, 2019 decision of Richardson I.

In making her rulings in Richardson I and related cases, Richardson II and

referenced. See [Dkt. 64] of said cause of action.

to deliberately sabotage Richardson I, as well as Richardson II and Richardson III

before that, in addition to Burford v. Powell. In the Appellant’s Motion for

summary judgment motion] he received an email for Board Counsel Joshua

Chadwick attempting to fabricate and additional Law Enforcement Unit (LEU)

document was fabricated in nature.

Appellant’s employment period at the Board. Depositions of Larence Dublin and

fabricated documents to enter into the record.

Appellant proving pretextual discrimination, harassment and disparate treatment

without legal representation. By no stretch of the imagination can an agency

ombudsman add an additional charge to an employee’s work record during the

Shanks, EEO Investigative Summary, pg 36 of 40; compare to Board Ex. B,

charge to an already terminated employee. See Hargo dep. ¶ 46; ER-FRB001247

Furthermore, the Appellant never falsified any information on his SF86 or

police reports in deliberate violation of the United States Constitution, Judge

write a police report. See ER-FRB-OPM000129 of Appellant’s Ex. E and Y. The

circumstances surrounding Christoff’s termination are much greater.6

Board, several of which resulted in negative police contact. Official evidence of

Portsmouth Police Department before his termination could be fully processed.

Court erred in attempting to provide defenses for criminal conduct in effort to

protect the Board.

who embezzled approximately $37,000 gambling at an out of town casino using

employed by the Board.

As an additional matter, during the Plaintiff’s June 7, 2010 termination

submitted audio files ER-FRB0505171AUD and ER-FRB0505152AUD as

evidence to the Board during the discovery period.8

the Appellant in no way, shape or form, by law, had to resubmit medical

– 001288 of Appellant’s Ex. A.

violated as a matter of law.

The District Court intentionally failed to act on these discrepancies violating

and prejudice toward the Appellant.

the wrongful termination to June 8, 2010.

The District Court intentionally failed to act on these discrepancies violating

and prejudice toward the Appellant.

form of disciplinary action by the Board whatsoever of an alleged violation. The

against an employee with the deliberate intent of termination when counseling,

suspension or retraining could have remedied the employee’s workplace violation

counseling, suspension or retraining.

Second, forcing the Appellant to work three separate shifts continuously

discrimination and harassment as a direct result of the Appellant’s reasonable

accommodation requests. The Appellant has proven with preponderant evidence

accommodation requests. Furthermore, it was the responsibility of the Board to

– 001275 of Appellant’s Ex. A. There would be no need to resubmit medical

the Appellant to an adverse action.

The District Court intentionally failed to act on these discrepancies violating

and prejudice toward the Appellant.

circumstances, be allowed to apply for a vacancy. Being 10 point preference

senior officer position. See Board’s Vacancy Position Policy, pgs. 22 – 23 of