Sexual Stereotyping &
Gender Identity In The Workplace
Presented by:
Susan Fahey Desmond| Jackson Lewis LLP
Slide 1
SEXUAL STEREOTYPING QUIZ
1. Would you rather bake or grill?
2. Did you play with dolls or cars growing
up?
3. Where do you spend your spare time?
A. Clothing Stores
B. Home Improvement Stores
C. Bookstores
D. Sporting Goods Stores
E. At Home
Slide 2
SEXUAL STEREOTYPING QUIZ
4. How concerned are you about your
appearance?
A. Not very
B. Somewhat
C. Very
5. How much money do you spend per
month on your hair?
A. Less than $50
B. Less than $100
C. More than $200
6. Do you regularly receive manicures/
pedicures?
Slide 3
SEXUAL STEREOTYPING QUIZ
7. How many pairs of shoes do you own?
a. Do you own clogs?
b. Do you own cowboy boots?
c. Do you own golf shoes?
d. Do you own hiking boots?
8. In which subject did you excel at
school?
A. Math
B. Theater
C. English
D. Physical Education
Slide 4
SEXUAL STEREOTYPING QUIZ
9. What is your favorite form of
entertainment?
A. Boxing
B. Cher concerts
C. WNBA games
D. Book club meetings
E. Watching drag shows
F. TV sports
10. Who pays the bills in your household?
Slide 5
SEXUAL STEREOTYPING QUIZ
11. What did you dream of becoming when
you grew up?
A. Firefighter
B. Rock star
C. Athlete
D. Parent
E. Librarian
Slide 6
SEXUAL STEREOTYPING QUIZ
12. What type of magazine do you read most often?
A. Fashion/Entertainment
B. Automotive
C. Sports
D. Home Decor/Remodeling
E. Chess
13. What type of car do you drive?
A. Subaru
B. Porsche
C. Mustang
D. Mini
Slide 7
SEXUAL STEREOTYPING QUIZ
14. What best describes your job title?
A. CEO/Executive
B. Administrative/Support
C. Human Resources
D. Finance/Accounting
E. Management
15. Who cleans your home/apartment?
16. Who takes out the garbage?
Slide 8
SEXUAL STEREOTYPING QUIZ
17. Who makes the home furnishing
decisions?
A. You
B. Your partner
C. Your decorator
D. VALASSIS
18. Do you leave the toilet seat up or down?
19. As a child, did you imagine what your
wedding would be like?
Slide 9
Have you ever…..?
• Received flowers at work?
• Spent a weekend fishing? (If so, did
you bait your own hook?)
• Ever been afraid to walk outside at
night?
• Ever worn high heels?
• Worried about the thread count of
your sheets?
Slide 10
Gender Identity and How it
Differs from Gender Expression
• Gender identity is a person’s innate
sense of his or her gender.
• Gender expression is the way in
which a person presents his or her
gender to the outside world.
Slide 11
What is sex stereotyping?
• Whether individuals identify as male or
female, gay, lesbian, bisexual,
heterosexual or transgender, many people
transgress traditional gender roles:
– a female with short hair is called "sir" in public;
– a boyish-looking lesbian receives curious
glances or angry stares in the ladies room;
– a gay teenager is reprimanded for "not acting
like a man."
• All of these individuals face bias based on
preconceived notions of gender – what it
means to look and act like a man or a
woman.
Slide 12
Has Sex Stereotyping Become
Mainstream?
• During a Republican National Convention,
Arnold Schwarzenegger declared: "And to
those critics who are so pessimistic about
our economy, I say: Don't be economic
girlie men."
• Schwarzenegger first used the "girlie men"
term to attack his political opponents.
Then, he used it to characterize the
California legislators with whom he
disagreed regarding the state's budget.
Slide 13
Has Sex Stereotyping Become
Mainstream?
Slide 14
• Some individuals offended by
Schwarzenegger’s comments asked
for an apology.
• Instead of apologizing, a
spokesperson for Schwarzenegger
described the comment as an “an
effective way to convey wimpiness.”
Later, Schwarzenegger complained
that people should lighten up and
that the term was meant as “a joke.”
What Other Expressions Denote
Sex Stereotypes?
• She was told she should “show her softer
side” more often.
• At the meeting, she “took it like a man.”
• He needed to “be his own man.”
• He’s just being a “sissy.”
• “Man up.”
• He/She throws like a girl.
• Comparisons:
– Strong men vs. domineering women
– Assertive men vs. aggressive women
Slide 15
Overview of Federal Gender
Discrimination Laws
• There is no federal law that protects
against discrimination based on
gender identity or expression.
• As currently drafted, the
Employment Non-Discrimination Act
(“ENDA”) prohibits sexual
orientation discrimination but does
not include gender identity.
Slide 16
Overview of Federal Gender
Discrimination Laws
• Title VII of the Civil Rights Act of
1964 prohibits discrimination
“because of . . . sex.”
• What does the term mean “because
of … sex”?
Slide 17
Overview of Federal Gender
Discrimination Laws
• Initial view from federal courts was
that discrimination against
transgender plaintiffs is not
prohibited discrimination “because
of . . . sex.”
– See, e.g., Ulane v. Eastern Airlines, Inc.,
(7th Cir. 1984) (holding MTF
transsexual pilot not protected from
discrimination under Title VII).
Slide 18
Overview of Federal Gender
Discrimination Laws
• These courts viewed the term “sex” in Title
VII as narrowly confined to discrimination
“against women because they are women
and against men because they are men.”
– In Ulane v. Eastern Airlines, the court held
discrimination against Ulane was not based on
her sex (as male or female), but on her decision
to change sex.
– But underlying this claim is the fact the airline
discriminated because its belief someone born
with male anatomy should not identify, act,
dress or change sex designation to female.
Slide 19
Price Waterhouse v. Hopkins
(1989)
• U.S. Supreme Court decision in Price
Waterhouse v. Hopkins, 490 U.S. 228
(1989) called these rulings into
question.
• Held that a woman who failed to
conform to her employer’s gender
stereotypes regarding how women
should look and act was protected
from discrimination by Title VII.
Slide 20
Price Waterhouse v. Hopkins
(1989)
Slide 21
• Hopkins, a female accountant, was advised
by certain partners in the firm that she
could improve her partnership chances if
she would “walk more femininely, talk
more femininely, dress more femininely,
wear make-up, have her hair styled, and
wear jewelry.”
• Various partners described Hopkins as
“macho,” in need of “a course in charm
school,” “a lady using a foul language,”
and somebody who was a “tough-talking,
somewhat masculine, hard-nosed
manager.”
Price Waterhouse v. Hopkins
(1989)
Slide 22
• Hopkins sued under Title VII for sex
discrimination after she resigned
following the firm’s denial of
partnership.
• Justice Brennan, writing for the
plurality, held that “in the specific
context of sex stereotyping, an
employer who acts on the basis of a
belief that a woman cannot be
aggressive, or that she must not be,
has acted on the basis of gender.”
Price Waterhouse v. Hopkins
(1989)
Slide 23
• The Price Waterhouse decision
stands for the proposition that Title
VII’s prohibition of discrimination
“because of sex” encompasses
discrimination based upon an
individual’s failure to conform to
gender-specific stereotypes.
• Courts have applied this rationale to
cases involving male and female
stereotypes.
Supreme Court Rules on Same Sex
Harassment: Oncale v. Sundowner
Offshore Services, Inc. (1998)
• Plaintiff worked on an offshore oil
rig in an all-male working
environment. He was subjected to
numerous incidents of harassment
including:
– A co-worker with some supervisory
authority over him exposed himself.
– A co-worker/supervisor threatened to
rape him.
Slide 24
Supreme Court Rules on Same Sex
Harassment: Oncale v. Sundowner
Offshore Services, Inc. (1998)
• Plaintiff complained about the
conduct to another manager who
called Plaintiff a faggot and told
Plaintiff that is how these coworkers have acted in the past.
Plaintiff then quit, claiming he was
sexually harassed. Neither Plaintiff
nor his co-workers was an admitted
or “apparent” homosexual.
Slide 25
Supreme Court Rules on Same Sex
Harassment: Oncale v. Sundowner
Offshore Services, Inc. (1998)
• By a 9-0 decision, the Supreme
Court held same-sex harassment is
actionable under Title VII if it is
engaged in “because of … sex.”
Slide 26
– “We hold today that nothing in Title VII
necessarily bars a claim of
discrimination ‘because of … sex’ merely
because the plaintiff and the defendant
(or the person charged with acting on
behalf of the defendant) are of the same
sex.”
Supreme Court Rules on Same Sex
Harassment: Oncale v. Sundowner
Offshore Services, Inc. (1998)
• Argument against allowing same-sex
harassment claims:
– The workplace will now require “asexuality or
androgyny.”
• Justice Scalia’s Response:
Slide 27
– No! Following the statute will ensure that
courts and juries do not mistake ordinary
socializing in the workplace, such as male-onmale horseplay or intersexual flirtation for
discriminatory “conditions of employment.”
– Title VII requires “careful consideration of the
social context in which particular behavior
occurs and is experienced by its target.”
Supreme Court Rules on Same Sex
Harassment: Oncale v. Sundowner
Offshore Services, Inc. (1998)
• Justice Scalia’s Response (cont):
– For example, a football coach slapping the
buttocks of a player as he heads onto the field is
not the same as a coach slapping the buttocks of
his (male or female) secretary back in the office.
– Trust in judges and juries to distinguish
roughhousing among members of the same sex
and severely hostile or abusive conduct.
Slide 28
Supreme Court Rules on Same Sex
Harassment: Oncale v. Sundowner
Offshore Services, Inc. (1998)
• Guidance from the Court on the evidence
available to prove same-sex harassment:
Slide 29
– Proof the harasser was motivated by sexual
desire (i.e. the “homosexual harasser”);
– Proof the victim was harassed in such “sexspecific and derogatory terms” by another of the
same gender as to make it clear that the
harasser was motivated by general hostility to
the presence of members of his/her own gender
in the workplace (the “enmity harasser”); or
– Proof of discrimination “because of … sex” by
offering direct comparative evidence about how
the alleged harasser treated members of both
sexes in a mixed-sex workplace (the
“discriminatory harasser”).
Post-Oncale Decisions on Same-Sex
Harassment Law: Schmedding v.
Tnemec Co. (8th Cir. 1999)
Slide 30
• Schmedding’s co-workers patted his
buttocks, asked him to perform sexual
acts, called him a "homo" and a "jerk off,”
and simulated a sexual act using the
doorframe to his office.
• Plaintiff alleged that he was discriminated
against on the basis of his “perceived
sexual preference,” but stated this was
because of his gender in that by falsely
labeling the plaintiff as a homosexual, his
male co-workers were debasing his
masculinity, something they would not do
to female co-workers.
Post-Oncale Decisions on Same-Sex
Harassment Law: Schmedding v.
Tnemec Co. (8th Cir. 1999)
• The court found sufficient
allegations of harassment because
the plaintiff was willing to amend his
complaint to delete the term
“perceived sexual preference.”
Slide 31
Post-Oncale Decisions on Same-Sex
Harassment Law: Llampallas v. MiniCircuits Lab (11th Cir. 1998)
• Elba Llampallas had a consensual sexual
relationship with a woman who, after their
relationship began, became her supervisor at work.
• When the relationship ended, the supervisor
threatened to have Llampallas fired if she did not
resume their relationship.
• As part of a scheme to manipulate the company
into firing Llampallas, the supervisor told the
president of the company that she was resigning
because she could no longer work with Llampallas.
• After acting as though he would transfer Llampallas
to another facility, the president terminated her
employment.
Slide 32
Post-Oncale Decisions on Same-Sex
Harassment Law: Llampallas v. MiniCircuits Lab (11th Cir. 1998)
• The Eleventh Circuit found for the
employer, holding that Llampallas failed to
establish a causal link between her
termination and the supervisor’s
discriminatory animus towards her.
• The court explained the president “broke
the chain” of causation between the
supervisor’s harassment and the decision
to terminate Ms. Llampallas because:
– the president behaved reasonably in response to
the supervisor’s threat to quit; and
– Llampallas failed to avoid the consequences of
the supervisor’s threat by not informing the
president of her relationship and the
supervisor’s previous threat to have her fired.
Slide 33
Post-Oncale Gender Stereotyping &
“Feminine Men”: Nichols v. Azteca
Restaurant Enterprises (9th Cir. 2001)
• Antonio Sanchez, a male restaurant
employee, was subjected to a
relentless campaign of insults,
name-calling, and vulgarities, such
as being referred to as “she” and
“her”; being mocked for walking and
carrying his serving tray “like a
woman”; and being taunted as a
“f___king female whore.”
Slide 34
Post-Oncale Gender Stereotyping &
“Feminine Men”: Nichols v. Azteca
Restaurant Enterprises (9th Cir. 2001)
• The Ninth Circuit held, “the systematic
abuse directed at Sanchez reflected a
belief that Sanchez did not act as a man
should act … We conclude that this verbal
abuse was closely linked to gender.”
• “Price Waterhouse applies with equal force to a
man who is discriminated against for acting too
feminine.”
Slide 35
Sex Stereotyping to Prove Same-Sex
Harassment: Heller v. Columbia
Edgewater Country Club (D. Or. 2002)
• The plaintiff, an openly lesbian woman,
sued her former employer under Title VII
for discriminating against her because she
was too masculine.
• The plaintiff presented evidence that her
female supervisor made disparaging and
harassing comments based on gender
stereotypes, including:
– “Oh, I thought you were a man.”
– “I thought you wore the pants.”
Slide 36
Sex Stereotyping to Prove Same-Sex
Harassment: Heller v. Columbia
Edgewater Country Club (D. Or. 2002)
Slide 37
• In denying the defendant’s motion for
summary judgment, the court explained
that Title VII prohibits harassment based
on a perception that the person “did not
conform to [the defendant’s] stereotype of
how a woman ought to behave.”
• In this case, the defendant perceived the
plaintiff to be gender non-conforming
because she “is attracted to and dates
other women, whereas [the defendant]
believes that a woman should be attracted
to and date only men.”
Pregnancy Based Stereotypes: Back v.
Hastings on Hudson Union Free School
District (2d Cir. 2004)
• Elena Back was a psychologist at an
elementary school. She was placed on a
three-year tenure-track when she was
hired.
• During her first two years of employment,
she received excellent performance
reviews from her two female supervisors
and was repeatedly told she would receive
tenure.
• As Back’s tenure drew closer, however, she
took a three-month maternity leave.
Slide 38
Pregnancy Based Stereotypes: Back v.
Hastings on Hudson Union Free School
District (2d Cir. 2004)
• After her return from maternity
leave, Back’s supervisors began
criticizing her performance and
making comments about her
devotion to the job:
Slide 39
– She was asked how she was “planning
on spacing her offspring.”
– She was told she would not “show the
same level of commitment [she] had
shown because [she] had little ones at
home” and that the job was “not for a
mother.”
Pregnancy Based Stereotypes: Back v.
Hastings on Hudson Union Free School
District (2d Cir. 2004)
• Back sued after she was denied tenure and
her employment was subsequently
terminated.
• Citing Price Waterhouse v. Hopkins, the
court held that employment decisions
based on gender stereotypes constitute
gender discrimination:
– “notions that mothers are insufficiently devoted
to work, and that work and motherhood are
incompatible, are properly considered to be
themselves, gender-based.”
Slide 40
Lesbian Based Stereotypes: Dawson
v. Bumble & Bumble (2d Cir. 2005)
• Dawson, a lesbian, alleged she was denied
a promotion and eventually terminated for
her non-conformity to gender stereotypes.
• Dawson believed her employer wanted to
fire her because of her “dyke” attitude and
alleged that, when she was terminated,
her employer stated that she could not be
sent to a salon outside of New York City
because, “People won’t understand you . . .
you’ll frighten them.”
Slide 41
Lesbian Based Stereotypes: Dawson
v. Bumble & Bumble (2d Cir. 2005)
• Although acknowledging that one can fail
to conform to gender stereotypes through
behavior or appearance, the court rejected
Dawson’s Title VII claim of impermissible
gender stereotyping.
Slide 42
– The evidence indicated that the salon regularly
employed sexually non-stereotypical individuals,
including a female-to-male transsexual and both
bi-sexual and gay employees, some with very
androgynous appearances.
– Unlike the plaintiff in Price Waterhouse, Dawson
was never told by her employer that she needed
to act or speak in a more “feminine” manner.
The Reasonable Woman Standard:
EEOC v. National Education
Association (9th Cir. 2005)
• On September 2, 2005, the Ninth
Circuit Court of Appeals ruled a
“reasonable women” standard
applies to workplace abusive
conduct, even if there is no sexual
content to the behavior.
Slide 43
The Reasonable Woman Standard:
EEOC v. National Education
Association (9th Cir. 2005)
• Three female employees filed EEOC
charges against National Education
Association-Alaska (NEA) alleging the
organization created a sex-based hostile
work environment and constructively
discharged one of them.
• Female employees alleged a male
supervisor with little or no provocation,
shouted and screamed at them, used foul
language, invaded their personal space
and used threatening physical gestures.
Slide 44
The Reasonable Woman Standard:
EEOC v. National Education
Association (9th Cir. 2005)
•
The Ninth Circuit Court of Appeals held
that a reasonable juror could conclude
that the supervisor’s conduct, which was
directed primarily at women, was
“because of sex”, within the meaning of
the statute.
–
–
Slide 45
The real question is whether the behavior
“affected women more adversely than it
affected men”.
The questions can be analyzed in two ways: i)
is the effect of the behavior qualitatively
different; and ii) is the amount of the behavior
quantitatively different.
The Reasonable Woman Standard:
EEOC v. National Education
Association (9th Cir. 2005)
• Under the reasonable woman
standard devised in an earlier case,
Ellison v. Brady, 924 f. 2d 872 (9th
Cir. 1991), women found the
behavior is more intimidating then
men did and therefore, the conduct
affects women differently.
– The Director’s intent is irrelevant- what
matters is the effect of the behavior,
both subjectively and objectively.
Slide 46
The Reasonable Woman Standard:
EEOC v. National Education
Association (9th Cir. 2005)
• According to the Court, the quantitative
difference turns on whether women were
more frequently exposed to the abusive
behavior then men.
Slide 47
– Note: Although the NEA pointed out that as a
teacher’s union, most of its employees were
women and women had more contact with the
particular director, this argument did not
prevail.
– Other courts have ruled that an unbalanced
distributing of the sexes and the fact that some
men were harassed can defeat a showing of
differential treatment.
The Reasonable Woman Standard:
EEOC v. National Education
Association (9th Cir. 2005)
• If the abusive behavior will be
actually and reasonably perceived as
disadvantageous by women, the
behavior may be discrimination.
Slide 48
Transgender v. Sexual Orientation
• Transgender employees are often
discriminated against or harassed
because the discriminating agent or
harasser mistakenly perceives them
to be gay or lesbian.
Slide 49
Discrimination and Harassment of
Transgender Employees
• Examples of Discriminatory and Harassing
Conduct Regarding Transgender Employees
– Refusal to hire in a position requiring customer
interaction;
– Preventing appropriate restroom usage;
– Repeated failure to address an employee by
his/her proper name and pronoun (Mr./Ms.,
his/her);
– Invasive inquiries about medical history or
genitalia;
– Allowing teasing or intimidating behavior.
Slide 50
Transgender v. Sexual Orientation:
Enriquez v. West Jersey Health
Systems (N.J. 2001)
• Enriquez, a MTF transsexual pediatric
physician, sued for wrongful termination of
her employment as a medical director of a
learning behavioral center. She alleged
disability and sexual orientation
discrimination.
Slide 51
Transgender v. Sexual Orientation:
Enriquez v. West Jersey Health
Systems (N.J. 2001)
• After working for the facility for less than
one year, Enriquez began her external
transformation from male to female.
– Enriquez shaved her beard, sculpted and waxed
her eyebrows, pierced her ears, and began
growing breasts. A few months later, Enriquez
began manicuring and polishing her nails,
growing long hair and wearing a ponytail.
• Later that year, Enriquez was diagnosed
with gender dysphoria, a gender identity
disorder listed in the DSM-IV published by
the American Psychiatric Association.
Slide 52
Transgender v. Sexual Orientation:
Enriquez v. West Jersey Health
Systems (N.J. 2001)
• One year later, Enriquez underwent
surgery. Three executives confronted
her about their discomfort over her
transformation. One told her to “stop
all this and go back to your previous
appearance!”
• The executives terminated her
contract with the facility and refused
to enter into a new contract with her,
stating “No one is going to sign this
contract unless you stop this business
that you’re doing.”
Slide 53
Transgender v. Sexual Orientation:
Enriquez v. West Jersey Health
Systems (N.J. 2001)
• Sexual Orientation Discrimination?
– The court concluded Enriquez failed to
establish a case of sexual orientation
discrimination. There was no evidence
of mistreatment by the employer
because of Enriquez’ “affectional,
emotional or physical attraction” to
others.
Slide 54
Transgender v. Sexual Orientation:
Enriquez v. West Jersey Health
Systems (N.J. 2001)
• Gender Discrimination?
– Yes, even though the statute does not
define gender specifically to include
gender identity. The Court was
influenced in its decision by the
development of the concept of sex
stereotyping as actionable gender
discrimination.
Slide 55
Sexual Reassignment Surgery:
Goins v. West Group (Minn. 2000)
• Must one undergo sexual
reassignment surgery to be
protected under the law?
• Goins, a transgender employee,
claims West Group discriminated
against her and harassed her on the
basis of her sexual orientation by
designating restrooms on the basis
of biological gender.
Slide 56
Sexual Reassignment Surgery:
Goins v. West Group (Minn. 2000)
• Goins was born biologically male.
Since 1994, Goins has taken female
hormones and presented herself to
the public as a female since 1995. In
October 1995, Goins legally changed
her name. Goins referred to herself
as transgender or trans-identified.
Slide 57
Sexual Reassignment Surgery:
Goins v. West Group (Minn. 2000)
Slide 58
• In 1997, Goins used an employee
restroom designated for women.
Two biological females complained
to a supervisor.
• The HR Director deemed the two
female employees’ complaint to be a
complaint of a “hostile work
environment” and decided to
enforce the policy of restroom usage
according to biological gender.
Sexual Reassignment Surgery:
Goins v. West Group (Minn. 2000)
Slide 59
• The HR Director also decided to
allow Goins the use of a singleoccupancy restroom on a different
floor or one in another building.
• Goins objected, proposing instead
the complaining employees be
educated regarding transgender
individuals. Goins continued to use
the restroom.
• In 1998, Goins resigned, claiming
undue stress and hostility.
Sexual Reassignment Surgery:
Goins v. West Group (Minn. 2000)
• West’s designation of employee
restroom usage based on biological
gender is not sexual orientation
discrimination. Restriction on
employee’s usage and the fact coworkers stared at her with hostility
and gossiped about her was not
evidence of sexual orientation
harassment.
Slide 60
Sexual Reassignment Surgery:
Goins v. West Group (Minn. 2000)
• The court held that an employee born male
who changed her legal name to that of a
female and took female hormones to
identify herself as a female, even though
she elected not to undergo sexual
reassignment surgery, was protected
under that state’s anti-discrimination law
protecting persons whose self-image or
identity is not traditionally associated with
his/her biological sex.
Slide 61
Jespersen v. Harrah’s Operating
Co. (9th Cir. 2004)
• Harrah’s implemented grooming
requirements that, in addition to gender
neutral standards, required female servers
– to wear makeup and nail polish;
– to tease, curl or style their hair;
– to wear pantyhose.
• In contrast, male beverage servers were
prohibited from wearing makeup or
colored nail polish, and were required to
maintain short hair and neat, trim
fingernails.
Slide 62
Jespersen v. Harrah’s Operating
Co. (9th Cir. 2004)
• Jespersen, a bartender at Harrah’s for
almost twenty years, refused to comply
with the new makeup requirement,
explaining that makeup made her feel
“sick, degraded, exposed, and violated.”
• When she was unable to locate another
position in the company that did not
require wearing makeup, she was
terminated.
• Jespersen alleged that her termination
constituted illegal sex discrimination under
Title VII.
Slide 63
Jespersen v. Harrah’s Operating
Co. (9th Cir. 2004)
• The court found that the different
grooming standards for men and women
did not constitute an “unequal burden” on
females:
– “Even if … the application of makeup requires
some expenditure of time and money, Jespersen
would still have the burden of producing some
evidence that the burdens associated with the
makeup requirement are greater than the
burdens the ... policy imposes on male
bartenders, and exceeds whatever ‘burden’ is
associated with ordinary, good-grooming
standards.”
Slide 64
Jespersen v. Harrah’s Operating
Co. (9th Cir. 2004)
• Finding that Jespersen failed to
meet this burden, the court granted
summary judgment for the
Employer.
• Notably, the court declined to apply
the Price Waterhouse sex
stereotyping analysis to appearance
and grooming standards cases.
Slide 65
Questions?
• Susan Fahey Desmond
– Susan.desmond@jacksonlewis.com
Slide 66