Free Motion for Leave to File - District Court of Federal Claims - federal

'-.
Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 123, 2002 May of 23

Page 154

not involve a time frame of when they are obligated
to accept it, just whether they are obligated to

accept it?
MR. CRAWFORD

Obj ection to the

foundation; objection to the extent it calls for a
legal conclusion.
THE WITNESS:
I I m going to try to ask a

clarification.
BY MR. STOUCK:

Sure.
Are you saying -- let me try this
Are you saying, if there is an approved DC
S,

again.

irrespecti ve of anything
accept that fuel?

else, do we have an

obligation, does the department have an obligation to
Is that what you

I re asking

me?

Actually the question I just asked was
about all of the fuel that' s not described and

approved.
Okay.

The fuel that I s not

described in an

approved DCS, do you have an obligation under the

contract as DOE to accept that spent fuel for

di sposal ?
MR. CRAWFORD

Same obj ections .
I really don

THE WITNESS:

I t know

because

Alderson Reporting Company, Inc.

1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 223, 2002 of 23 May

Page 155

that I S a si tuation that we never looked at.

You

know, the expectation is that both sides would
complete the contractual requirements for both the

delivery commitment schedules and then final delivery
schedules, you know, as we did the dance to the waste

acceptance - - you know, to actual waste acceptance. I don I t recall ever addressing the question of what
happens if,
you know, a utility did not do
I t

that.

the answer is I don

know.

BY MR. STOUCK:

So would it be fair based on that answer

to say that, during your tenure at RW, when you had
responsibility for these waste acceptance matters
which as we

I ve said or I have said many times I think
during that time you

is from 1985 to March of ' 95,

did not have any understanding one way or the other about whether or not DOE was obligated under the
standard contract to accept spent fuel that was not described in an approved delivery commitment
schedule; is that right?

I thought you said you

never thought about it.
Yeah.
As I recall my assumption was that

both sides would do

it.

What happens if somebody did
I don
I t

not do it?

I don

I t --

believe we ever really

had that discussion.

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 8oo-FOR- DEPO Washington , DC 20005

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 323, 2002 of 23 May

Page 165

And then 1' m

going to follow that up with a question

about what you knew at the

time.
I s a legal

Well, today,

I mean to me that

call, you know, in light of the court decision
you know, occurred after my responsibilities.

which,

that I S a legal
clear record.

question.

At the time --

Let me ask the question just so we have a

At the time you were working on waste

acceptance matters at RW from

' 85 to '

95, did you

have an understanding with respect to the spent fuel
that is described in an approved delivery commitment

schedule whether or not DOE had a binding obligation to accept that spent fuel pursuant to the standard

contracts?
MR. CRAWFORD

Obj ection to the extent it

calls for a legal conclusion.
THE WITNESS:

First of all at the time I

and I believe the department viewed the obligation as

a conditional obligation.

Now, putting that
The final

aside,

the contract required other steps.

delivery commitment schedule, because the specific
fuel was often not described, you know, in the
approved delivery commitment schedules which was fine
under the instructions.

So, with those two caveats, no, if we

Alderson Reporting Company, Inc.
1111 14th Street, No W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

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Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington , D.

Filed 07/14/2004

Page 423, 2002 of 23 May

:a,. 166

1 ' didn' t have a facility, with respect to the firs

caveat; with respect to the second, what would happen
if they had an approved DCS but took no action to

submit an FDS,

we never really addressed

that, I

never really addressed

that.
know, whether

You know, every stage -- you

it was the APR or the DCSs, I know in correspondence
we urged -- we told the utili ties this was consistent

with the contract, but we never said -- well, we
never did the what- if questions.
BY MR. STOUCK

So you didn'
the DCS, but you don

t have any understanding one

way or the other about my question which is you have

I t have

anything subsequent, you

just never thought about it, never focused on it; is

that fair?
MR. CRAWFORD:

Same

objections.

THE WITNESS:

did not think we had a

binding

obligation with

respect

first

caveat

which is because the commencement of facility

operations.

We never really addressed the second

caveat situation, where we had that and it
BY MR. STOUCK

stopped.

You never formed that understanding?

No.

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington , Do

Filed 07/14/2004

Page 523, 2002 May of 23

Page 167

You agree with my statement, never
an understanding?

Yes.
And you expected that utili ties, you

expected them in the course of the processes

discussed in the standard contract, that at some

point in time utilities would submit final delivery

schedules, that I s the

way you thought about it?

I had every reason to expect that

utilities, you know, participated, if you will, in
both the ACR, in the development of the APR, and in

responding to our instructions on the DCS.

Okay.

So you did expect that there would

be FDSs for all spent fuel described in a DCS?
I did.

And do you know whether it would be

possible for DOE to accept spent fuel from a utility
if that utility had submitted a DCS to DOE, proper

DCS, completely filled out, but had not submitted an
FDS?

And, just to amplify my question, is there

enough information specified in the DCS to allow DOE
to accept spent fuel for disposal even if DOE does

not subsequently get the addi tional
spec if i ed in
the FDS?

information

MR. CRAWFORD:

Objection, compound, vague,

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 623, 2002 of 23 May

Page 214

Okay.

Were there ever similar or

comparable instructions given to the purchasers regarding completion of final delivery schedules?

There were not.
Why is that?

At least through March of ' 95, we were

just in the DCS process, in the very -- I mean in the

very early stages of addressing FDS

issues.

Do you know whether subsequent to your
leaving FDS instructions were finalized and given to
the purchasers?
MR. CRAWFORD:

Objection, calls for

speculation.
THE WITNESS:

To the best of my knowledge,

they were not.
BY MR. STOUCK

Okay.

Now, on page 27 C of these

instructions please, Exhibit 34, take a look at that
for a moment.

Yes.

Okay.

It says in the second sentence the process

described herein assumes --

well, strike that.

Let I S go actually up to 7A and take a look
at 7A for a minute.
last sentence.

I I ve got a question about the

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 8oo- FOR- DEPO Washington, DC 20005

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.............

Case Brownstein 1:98-cv-00126-JFM Alan

Document 846-16
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Filed 07/14/2004

Page 7 23, 2002 of 23 May

Page 215

Okay.
In this last sentence, quote, due to the
limited annual acceptance capacity of the FWMS,

federal waste management system that stands for?

Yes.
Continuing on, reading, only DCSs

submitted by purchasers with an allocation in the

delivery year will be considered for

approval,

parentheses, e. g., in order for a purchaser to have a

DCS considered for approval for delivery in

1998, the

purchaser must have an allocation in

1998, correct?

Yes.
Okay.
Must have an allocation as shown in

the ACR, APR, current at the time of submittal of a

delivery commitment schedule, is that what this

means?
In the APR, yes.

Well, in one of those

documents, yes. Right.
at the time?

Okay.

Whichever one was current

Yes.
Okay.
And so here, in C now, it

says, in

the second sentence, the process described herein assumes that the FWMS will be able to accept the

purchasers I

SNF beginning in 1998 according to

the

IIII 14th Street ,

Alderson Reporting Company, Inc. N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 8 23, 2002 of 23 May

Page 216

acceptance rate reflected in the 1991

A. Yes.

ACR, right?

Okay.

Next sentence, in the event that

such circumstances change, all DCSs previously
approved by DOE may need to be reeval ua ted by DOE and
the purchasers.
I do.

Do you see that?

Those circumstances have changed, right?

Yes.
Okay.
In other words, DOE did not -- was

not able to or in any event did not begin accepting

purchasers' SNF beginning in

1998, right?

Yes.
And it follows that then that DOE did not

begin accepting fuel in 1998 according to the
acceptance rate reflected in the ' 91 ACR, right?

Yes.
Okay.
So, in light of those changed

circumstances, do you have an opinion whether DCSs

previously approved by DOE need to be reevaluated by
DOE and the purchasers?
This sentence says may.

asking you whether in your view they need to be?
MR. CRAWFORD:

Obj ection to the extent it

calls for a legal conclusion; objection, asked and

25 answered.
Alderson Reporting Company, Inc.
1111 14th Street, N. W. Suite 400 1- 8oo- FOR- DEPO Washington, DC 20005

.---.

CaseBrownstein 1:98-cv-00126-JFM Alan

Document 846-16
Washington, D.

Filed 07/14/2004

Page 923, 2002 May of 23

Page 217

THE WITNESS:

I would think that we would,

think both sides would want to do
BY MR. STOUCK

that.

Okay.

Why would you think that?

re going to jump from the time period
we I re talking about to today, for example?

Let I S

not

do thi s year by year.

Let I S talk about the

utilities.
If the utilities had submitted and gotten
approved DCSs, and let' s say they were very specific

about the fuel that they wanted to

deliver. Their
And it seems to

situation and views on what they want to deliver to

us could have substantially

changed.

me that that should give you -- we should in my
opinion give the utilities another opportunity to
review and see if that' s same fuel.

And I especially feel that way because the

department has not, you

know, procured casks.
example.

I may

feel differently if casks had been purchased based on

that information as an

Okay.

As an example would you agree wi th

the categorization that that would be a kind of

updating of the DCS information to deal with current

circumstances?
MR. CRAWFORD:

Objection, vague.

Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

...~

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Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D,

Filed 07/14/2004

Page 10 of 23

May 23, 2002

Page 218

THE WITNESS:
MR . CRAWFORD:

I think both sides --

And to the extent it calls

for a legal conclusion.
THE WITNESS:

I think both sides should

have the opportunity to update that
BY MR. STOUCK

information.

And you gave me an example of a reason why
utilities should be given the opportunity?

Right.
Can you give an example of reasons why DOE
should be given the opportunity to update that
information to deal with current circumstances?

The department may have better information

on the rate or the timing, both of which I would
think would influence utilities ' decisions.

Right. Well, you recall that the ' 91 -excuse me, the ' 91 ACR -- do you recall the rate in the ' 91 ACR?
No.
This has been previously marked as Exhibit

30.

It' s the ' 91 annual capacity report.

I have a

copy for you and your counsel.
look for the rate, right?

You know where to

Yes.
Page 5.
This was the so-called or I'

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005

\..
Case 1:98-cv-00126-JFM Alan Brownstein Document 846-16
Washington , D,

Filed 07/14/2004

Page 11 of2002 23 May 23,

~all it 400, 600, 900, and then 900 steady state
rate, right?

Page 219

Right.
And so that is not the acceptance rate
that is specified in DOE' s current planning

documents; is that correct?
MR. CRAWFORD

Objection, vague.
I believe you

THE WITNESS:
BY MR. STOUCK

I re accurate.

Okay.

The current planning documents for

the program indicate an acceptance rate that ramps up
to a steady state of 3, 000 tons per MTU per year?

MR. CRAWFORD:
THE WITNESS:

Obj ection.
I don

I t recall

what the

rampup rate is, but the steady state I believe is

000.
BY MR. STOUCK

Okay.

And so presumably, according to

your testimony earlier today, those current planning
documents are DOE' s current best estimate of what the

acceptance rate will be when the program actually
starts, correc
t ?

MR . CRAWFORD:

Objection, vague; and

objection to the extent it mischaracterizes prior
25

testimOny.
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

--'
Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington , D.

Filed 07/14/2004

Page 12 of 23

May 23 , 2002

Page 220

THE WITNESS:
BY MR. STOUCK

I believe that'

s accurate.

Okay.

And so that change in projected

acceptance rates, is that another reason why in the
language -- why in your view, in the language of

paragraph 7C of the instructions, Exhibit 34, all
DCSs previously approved by DOE need to be

reevaluated?
MR. CRAWFORD:

Objection to the

foundation; objection, asked and answered;

objection,

vague.
THE WITNESS:
So I agree.
BY MR. STOUCK

I use that as an example.

Okay.
as an example?

You used the acceptance rate change

Yes.
We have now got it in more detailed form
on the record.

That' s fine.
Do you expect that others in RW would
share your views about this need to reevaluate

previously approved DCSs in light of changed
circumstances as the instructions contemplate?
MR . CRAWFORD:

Obj ection to the extent it

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington, DC 20005

')

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 13 of 23
May 23, 2002

Page 245

Thank you.
(Whereupon, at

4: 25 p. m., the deposition

adjourned.

Signature of the Witness

SUBSCRIBED AND SWORN to before me this

of

i I;

day

u.

20

;2-

t-t
My Commission expires:

Iv/. lk5.~
r/I ~/:J. tJd6

. e.

.~JU

'" NOTARY PUBLI

IIII 14th Street,

~W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005

Alderson Reporting Company, Inc.

Case 1:98-cv-00126-JFM Document 846-16 Filed 07/14/2004 OF: Ef-.. ATA SHEET FOR THE TRANSCR.

Page 14 of 23

Notice Date: May 28 , 2002 Case Name: Yankee Atomic V5. United States Case Number: 98- 126C- 9874C Dep. Date: May 23 , 2002

Deponent: Alan Brownstein (continued)

Place: Washington DC
Ref. No. :

4269-

CORRECTIONS:

Page

Line

Now Reads

Should Read

Reasons Therefore

;2.3

frl'()(/

e. Oc.

?fl'dr/C
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Date of Signature

. , ,....

""-

- - - - - - - - - - -) - - - - - - - - - - - - - - - - - .- - - - - - - - Case 1:98-cv-00126-JFM
Alan Brownstein

).

Document 846-16
Washington, D.

Filed 07/14/2004

June 14, 2002

Page 15 of 23

Page 246

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

YANKEE ATOMIC ELECTRIC COMPANY

(98-

126C)

(Merow, S. J

CONNECTICUT YANKEE ATOMIC POWER COMPANY

(98- 154C) (Merow, S.
MAINE YANKEE ATOMIC POWER COMPANY

(98- 474C) (Merow, S.

C~RTjFIED

CO.

Plaintiffs,
THE UNITED STATES,

Defendant.

Washington, D. C .
Friday, June 14, 2002

Continued deposition of ALAN BROWNSTEIN, a

witness herein, called for examination by

counsel for
sworn,

Plaintiffs in the above-entitled matter, pursuant to

agreement, the witness being previously duly

taken at the offices of Spriggs & Hollingsworth, 1350
I Street, N. W., Washington, D. C., 20005- 3305,

at

8:40 a. m.,

Friday, June 14, 2002, the proceedings

being taken down by Stenotype by JAN A. WILLIAMS, RPR, and transcribed under her

direction.

Alderson Reporting Company, Inc.
1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington, DC 20005

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 16 of 23
June 14

2002

Page 423

legal significance of an approved DCS?
MR . CRAWFORD :

Objection to the extent it

calls for a legal conclusion.
THE WITNESS:
BY MR. STOUCK

m not a

lawyer.
But at this

Well, you re not a lawyer.

time you were working on the program and you were

working on these matters.
their jobs.

And sometimes nonlawyers

have understandings of legal things that relate to
Maybe you did and maybe you didn
t, but

I don t know that that

I s responsive to my question.

At this time did you have an understanding of the
legal significance of an approved DCS?
MR . CRAWFORD :

Obj ection to the extent it

calls for a legal conclusion.
THE WITNESS:

Probably not, because I

don t recall having a discussion with anybody about

that.
BY MR. STOUCK

Okay.

What about at some subsequent time

prior to the time that you ceased working on these

matters?

I I m looking for my notes here.

I think it

was March 1995.

Did you have any discussions with

anyone that would have given you, Alan Brownstein, an

understanding of the legal significance of approved

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington , DC 20005

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 17 of 23
June 14, 2002

Page 424

DCSs?
MR . CRAWFORD:

Same objection.

THE WITNESS:
BY MR. STOUCK

Not that I recall.

And subsequent to

that, in ' 95,

you have

had no such discussions; is that right or is that not

right?
MR . CRAWFORD:

Same objection.

THE WITNESS:

I think I testified earlier

that I may have reviewed a DOJ, you know, document, a

reply.
BY MR. STOUCK

In this litigation?

In this litigation.
Was that subsequent to the last time we
were here in this deposition room?

No.
It was

prior
prior

that?
to your first deposition?

Yes.
Was

Yes.
Do you know

whether

it was

prior

after the DOJ document was filed in court or was it a
DOJ document that was filed in court?
MR . CRAWFORD:

Objection to the extent it

1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

Alderson Reporting Company, Inc.

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 18 of 23
June 14, 2002

Page 425

calls for speculation.
THE WITNESS:

I reviewed it -- a draft DOJ

document.

And I testified to that before
BY MR. STOUCK

too.

Okay.

Again I really apologize.

Yeah.

It'

s been a long deposition, I just did
I I m not trying to ask you the same

not recall that.
questions over.

And I believe, you know, that addressed
some of that

issue.

So that I s what

jogged my memory.

So based on that you have an understanding

or at least at the time you read this you had an

understanding of what DOJ' s current position about
the legal significance of this is?
MR . CRAWFORD:

Well, objection, asked and

answered and to the extent that that may have

mischaracterized anything he previously testified
THE WITNESS:

to.

There was discussion

about -MR . CRAWFORD:

And 1' m going to instruct

the witness not to reveal anything about any
discussions with any DOJ lawyers about any kind of

matter discussed with respect to this litigation at

25 all.
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005

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'"Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington , D.

Filed 07/14/2004

Page 19 of 23
June 14, 2002

Page 426

THE WITNESS:

Okay.

Well, that' s fine.

think somewhere in that draft there was, you know,
some views expressed about what the government' s

--

Department of Justice s views were with respect to
the legal effect of the DCSs.
BY MR. STOUCK

I read those words.

Approximately when was that, do you
recall, within the last year?
MR . CRAWFORD :

Obj ection to the extent it

calls for speculation.
THE WITNESS:

Yeah, wi thin

a year, wi

thin

the las t year.
BY MR. STOUCK

Okay.

Can you place it any more

specifically than that in time?
MR . CRAWFORD :

Objection, asked and

answered.
THE WITNESS:
BY MR. STOUCK

No.

But, prior to reading that draft and prior

to whatever discussions grew out of that draft, you

had no understanding of the legal significance, you
had no discussions with anyone who would have given
you any other basis for having any understanding of
the legal significance of the DCSs; is that right?

Alderson Reporting Company, Inc. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005 1111 14th Street, N.

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
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Page 427

That I S right.

And why I brought that up

is because, you know, my reaction was, well, that'

interesting, when I read that it was

interesting.
before.

never discussed it or thought about that

Directing your attention to the very last

sentence of Exhibit No. 109, I'll read it, it says

what liabilities and obligations on the part of both
parties are locked in by the DCS submittal and

approval process.
Okay.
Now, that' s a question that -- you know,

the words are different.

But it'

s very similar to

this question about the legal significance, is that
right, do you agree with that?
I agree with your statement.

So, therefore, you had no understanding of

what liabilities and obligations on the part of both

parties are locked in by the DCS submittal and
approval process contemporaneous with this document

in August of '91; is that right? That I S right.
And you had no understanding about those matters as of the time you stopped working on waste
acceptance matters in March 1995?

That I S accurate.
Alderson Reporting Company, Inc. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005 1111 14th Street, N.

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
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Page 21 of 23
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Page 428

And you had no understanding about those

matters at least prior to the time that whatever
understanding you gained by reading this draft that
you just referred to?

That I S correct.
(Recess. )
BY MR. STOUCK

Do you know whether the standard contract
or any of these -- not these standard contracts but
any of these individual waste acceptance contracts

with the utilities were ever amended?
MR . CRAWFORD :

Well, object to the extent

of lack of foundation and to the extent it would call
for speculation.
Bu t go ahead.

MR. STOUCK:

m not asking for

speculation, 1' m

just asking if he knows if any of

them were ever amended.
MR . CRAWFORD:

Then maybe my obj ection

is

more appropriately obj ection, vague.
THE WITNESS:

Yeah, I believe there were
It would be hard for me to
Bu t

some

tell
some

modifications made. you what they were. modifications made.
BY MR. STOUCK :

I remember there were

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

Case 1:98-cv-00126-JFM
Alan Brownstein

Document 846-16
Washington, D.

Filed 07/14/2004

Page 22 of 23
June 14, 2002

Page 440

have been correct had that said ACR instead of

contract.
MR. STOUCK:

Mr. Brownstein, you are done

for today subject to what I just told
THE WITNESS:
MR . CRAWFORD :

you.

Thank you.
'll reserve any further

questioning of the wi tne&s
MR . CRAWFORD :

until the time of

trial.

(Discussion off the record.

I will reserve the right to

ask questions should Mr. Stouck succeed as he states

that he intends to do in getting Mr. Brownstein

before him again.

But I will say that we will oppose

that.
MR.

STOUCK:

Okay.
3: 30

Good.

Thanks

a lot.

(Whereupon,

m., the takin~ of

the instant deposition ceased.

Signature of the Witness

SUBSCRIBED AND SWORN to before me this
of

rJ;W!;

day

lIllf"

20u.

NOTARY PUBLIC

My Commission expires:

~jf/ob

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington, DC 20005

Case 1:98-cv-00126-JFM
ER~

Document 846-16 Filed 07/14/2004 fA SHEET FOR THE TRANSCRIF JF:

Page 23 of 23

Notice Date: June 17 , 2002
Case Name: Yankee Atomic vs. United States Case Number: 98- 126C- 9874C Dep. Date: June 14, 2002 Deponent: Alan Brownstein Washington DC

Place: 4269-45
Ref. No.

CORRECTIONS:

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Signature of Deponent
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