Free Response to Motion - District Court of Federal Claims - federal

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Case Nos. 98-621C and 04-103C (Consolidated) (Judge Hewitt) _____________________________________________________________________________ IN THE UNITED STATES COURT OF FEDERAL CLAIMS _____________________________________________________________________________ COMMONWEALTH EDISON COMPANY and EXELON GENERATION COMPANY, LLC, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. _____________________________________________________________________________ PLAINTIFFS' RESPONSE TO DEFENDANT'S MOTION FOR POSTPONEMENT OF EXPERT DISCLOSURE DEADLINE AND OTHER RELIEF _____________________________________________________________________________ OF COUNSEL: DONALD R. CASSLING NORMAN M. HIRSCH DAVID JIMÉNEZ-EKMAN CHRISTOPHER TOMPKINS Jenner & Block LLP One IBM Plaza Chicago, IL 60611 (312) 222-9350 THOMAS S. O'NEILL Exelon Nuclear Cornerstone II 5th Floor 4300 Winfield Road Warrenville, IL 60555 (630) 657-3770 May 18, 2004 Attorneys for Plaintiffs DAVID A. HANDZO Jenner & Block LLP 601 Thirteenth Street, N.W. Suite 1200 South Washington, D.C. 20005 (202) 639-6000 telephone (202) 639-6066 fax

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Table Of Contents Table Of Contents ............................................................................................................................ i Table of Authorities ........................................................................................................................ ii Table Of Contents To Appendix.................................................................................................... iii Introduction..................................................................................................................................... 1 Discussion ....................................................................................................................................... 2 I. II. The Government's Request For A Postponement Of Its Expert Disclosure Deadlines Should Be Denied. .............................................................................................................. 2 Exelon Is Not Required To Disclose A Report For The Previously-Identified Occurrence Witness Whom Exelon Disclosed As "Experts" Only Because Their Fact Testimony May Involve Technical Subjects............................................................... 9 The Court Should Not Order Further Written Disclosures By Mr. Emmert. ................... 11

III.

Conclusion .................................................................................................................................... 13

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Table of Authorities Cases Sprague v. Liberty Mutual Insurance Co., 177 F.R.D. 78 (D.N.H. 1998).....................................10 Zurba v. United States, 202 F.R.D. 590, 591 (N.D. Ill. 2001) ......................................................10 Rules of the United States Court Of Federal Claims RCFC 26(a)................................................................................................................................9, 10

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Table Of Contents To Appendix Preliminary Expert Damages Report Of Michael P. Emmert (April 15, 2004)...............................1 Transcript Of Deposition Of Adam H. Levin (January 7, 2004) ...................................................54 Letter From Norman M. Hirsch To Sharon A. Snyder (January 26, 2004)...................................95

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS COMMONWEALTH EDISON COMPANY and EXELON GENERATION COMPANY, LLC, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

Nos. 98-621C and 04-103C (Consolidated) (Judge Hewitt)

PLAINTIFFS' RESPONSE TO DEFENDANT'S MOTION TO FOR POSTPONEMENT OF EXPERT DISCLOSURE DEADLINE AND OTHER RELIEF Introduction The Government's motion for certain relief regarding expert discovery filed May 14, 2004 (the "Motion"1) should be denied because the Government has not made any case for the drastic relief it seeks. While the Government's Motion does not confront the effect of its request for an extension of its expert disclosure deadline, the unspoken fact is that there is insufficient room in the existing schedule to accommodate an entire month's extension without postponing the trial. Because a trial postponement would be highly prejudicial to plaintiffs Exelon Generation Company, LLC and Commonwealth Edison Company (collectively "Exelon" or the "Plaintiff"), unlike the situation with prior Government requests, Exelon is not able to work out a compromise that will address the Government's concerns. Consequently, Exelon opposes the Government's Motion.

1

The full title of the Motion is "Motion For An Enlargement Of Time To Complete Expert Discovery, Motion Seeking An Order Requiring Plaintiff To Complete Production Of All Expert Materials By A Date Certain And To Identify Expected Testimony Regarding 17 Identified Expert Witnesses, And Motion For Expedited Consideration."

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Discussion I. The Government's Request For A Postponement Of Its Expert Disclosure Deadlines Should Be Denied. At the outset, Exelon wants to point out that this is not a case in which counsel have been unable to cooperate and make reasonable accommodations. As Your Honor observed at the hearing on Friday, May 14, 2004, this has been a "low decibel" case during discovery: since the Court entered its July 22, 2003 scheduling order, there have been no disputed discovery motions between the parties presented to the Court. Indeed, without Court intervention, the parties have negotiated and agreed upon: (i) a higher number of fact depositions and interrogatories than permitted by rule (for the Government); (ii) a two-week extension of the fact discovery deadline (for the Government); (iii) permission to take a fact deposition outside the discovery period (for the Government); and (iv) a twenty-day extension of Exelon's expert disclosure deadline (for Exelon).2 In this same spirit, on May 4, 2004 (ten days before the Government filed its Motion), when counsel for the Government first raised the issue of an extension of the Government's expert disclosure deadline, Exelon's counsel indicated that Exelon would be willing to consider agreeing to a reasonable extension that could be worked in to the existing schedule without affecting the trial date. However, Exelon opposes this Motion because the extension sought is not reasonable and would, in fact, postpone the trial date that Exelon has waited six years to obtain. There are five reasons why the Court should deny the Government's motion. First, and most fundamentally, the Government has not shown ­ and cannot show ­ that it has insufficient time under the current schedule to disclose its expert reports. The current
2

The Court may recall that the time for this extension was "borrowed" from Exelon's period in which to make its own expert rebuttal disclosures; no time period for the Government to take any action was shortened as a result of this extension. Exelon asked for this extension in part because the time between the close of fact discovery and Exelon's disclosure deadline was shortened by two weeks as the result of the Government's request to extend fact discovery.

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schedule provides the Government with eleven weeks to prepare its disclosures. On the day the Government filed its Motion, the Government still had almost seven weeks before its disclosures were due, more time than is typically allotted in total for responsive disclosures, even in complex cases. Moreover, in a case like this, reasonable diligence requires a party to retain experts and begin the analysis of damages in advance of the period specifically dedicated to expert discovery ­ and that is what the Government has done. The fact deposition record reflects that Government experts have been attending fact depositions over the last several months. The Government's Motion acknowledges (at 5) that the Government's experts "have spent the past several months reviewing and analyzing the" materials provided by Exelon. Against this backdrop, we simply do not see how the Government can legitimately claim it needs so much additional time that the trial date must be moved. It is difficult to imagine any expert damages analysis that could not be performed in the time the Government has had ­ and still has left. The "sheer amount of materials" involved in the case (Gov't Mot. at 2) does not justify postponing the trial; the Government should be required to devote whatever resources are necessary to bring the matter to trial on the reasonable schedule set by the Court. Moreover, the fact that the Government first raised the issue with Exelon's counsel when there were approximately eight weeks remaining before the Government's reports are due shows that the Government has not made a reasonable effort to comply with the schedule set by the Court. Second, Exelon has done everything reasonably possible to facilitate the Government's receipt of information necessary for its expert's analysis and reports. We recently described the extensive and timely fact discovery Exelon has provided in our response to the Government's motion for additional fact discovery ­ including more than 200,000 pages of documents, more than 10,000 electronic documents and e-mails, and 19 depositions ­ and we will not repeat that

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description here. Suffice it to say that the Government did not file any motions during fact discovery asserting that any part of our compliance was deficient,3 and the Government's recent motion for additional fact discovery had a very limited focus; even the Government has acknowledged that "fact discovery in this case has resulted in the flow of a vast amount of information" and that "the parties have conducted discovery in good faith" since early fall 2003. (Reply In Supp. Of Mot. For Supplemental Fact Discovery at 1; Mot. at 4.) Likewise, in expert discovery, Exelon has made and is making a similar effort to promptly provide the Government with the information it seeks. In response to expert document requests first served on April 19, 2004, Exelon made the following document productions: · April 29, 2004. Substantially complete production relating to Exelon's retained experts Eileen Supko and Tom Dignan and a substantially complete production (2 CD-ROMs) of electronic files and 15 notebooks containing Michael P. Emmert's damages report and work papers.4 May 6, 2004. Substantially complete production relating to Exelon's retained expert Leonard Bickwit.5 May 8, 2004. Substantially complete production relating to Exelon's retained expert Terry Dodge.

· ·

As of the date this response is filed (May 18, 2004), Exelon has made a substantially complete production from all of its experts. In addition, deposition dates have already been set by agreement for all but one expert (the scheduled date of which the Government has now asked to postpone twice).6

The Government filed a motion to compel against non-party Holtec International; as Your Honor knows, Exelon had already produced all of its documents relating to its relationship with Holtec. 4 Exelon has located an additional two boxes of Ernst & Young material which Ernst & Young prepared in a consulting capacity early in this case and which is therefore not directly called for by RCFC 26. However, out of an abundance of caution, Exelon will be producing that material as well by Friday, May 21, 2004. 5 This production also included one additional document from Tom Dignan. 6 To the extent that the Government's assertion (at 6-7) that "the earliest that Mr. Emmert can be deposed is June 1516, 2004" is meant to imply that Exelon would not make him available earlier, that implication is incorrect. As with all other deponents, Exelon's counsel worked with the Government to find mutually agreeable dates.

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Third, the Government cannot fairly say that Exelon's conduct has created a need for more time before the Government's expert disclosures. The Government's assertion (at 4-6) that the basis for Exelon's damages claims has repeatedly changed is, with all due respect, misleading and inaccurate. In the first instance, each of Exelon's disclosures have disclosed identical categories of damages. (Gov't App. at 12, 28, 36.7) With respect to the calculation of each category, Exelon has continued to provide additional information as it became available. Because the Government's breach as well as Exelon's attempts to address and mitigate the effects of that breach are both ongoing, Exelon continued to incur additional actual expenses and obtain additional information as fact discovery progressed. In addition, discovery itself resulted in additional information regarding damage issues. To comply with our discovery obligations, as more information has become available, we have made detailed supplemental damages calculation disclosures under Rule 26(e). The last of those disclosures ­ on December 23, 2003 ­ took place before the Government took seventeen of the nineteen depositions in this case. We also note that, as more information became available, Exelon's total damages claim ultimately decreased, and the first supplement to our initial disclosures dropped a very substantial damages claim for Exelon's Dresden Unit 1, greatly simplifying fact discovery. Moreover, the Government's argument (at 5) that the "basis of Mr. Emmert's damage claim may be different from the basis of the multiple Initial Disclosures that ComEd produced during fact discovery" is also inaccurate. Mr. Emmert did not base his damages report on any underlying factual information that was not also discussed as a basis for damages estimates by Exelon employee Adam Levin in his fact deposition testimony and disclosed by Exelon in Rule
References to "Gov't App." refer to the Government's Appendix. References to "App." are to pages of the separate appendix filed with this response. Because the appendix contains proprietary material that has been designated as "Confidential Material" pursuant to the Protective Order, the appendix is being filed with the Clerk's office under seal.
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26 disclosures and/or correspondence. If anything, Mr. Emmert's analysis narrowed the information which is most relevant. In particular: · Dry Cask Storage Costs. To estimate damage for this category Mr. Levin repeatedly testified that he relied on (1) actual cost information from Exelon's experience in providing dry cask storage at Dresden Units 2 and 3 (see, e.g., App. at 70-71, 79), and (2) the budget for the Quad Cities ISFSI project (see, e.g., App. at 71, 73, 77-78). Indeed, Mr. Levin repeatedly identified the Quad Cities ISFSI budget as the primary source of many of his estimates. (Id.) Mr. Emmert's report discloses that he also relied upon (1) actual cost information from Dresden Units 2 and 3 and (2) the Quad Cities capital expenditure authorization and budget. (Emmert Rep., App. at 34-35, 38-39.) Mr. Levin stated that he also considered the costs of providing dry cask storage at two other Exelon station, Peach Bottom and Oyster Creek. (See, e.g., App. at 79-81.) Mr. Emmert also considered the costs incurred at those units. (Emmert Rep., App. at 27.) Post-Shutdown Operations And Maintenance. Mr. Levin testified that he considered the actual costs incurred at Exelon's Zion station, and decommissioning cost estimate studies prepared for Exelon's Quad Cities and Limerick stations to calculate these costs (App. at 8990); Mr. Emmert's report discloses that he also relied primarily on Exelon's costs at Zion station to calculate these costs, although he also considered "outside consultants reports" regarding decommissioning costs. (Emmert Rep. App. at 45-46.) In addition to Mr. Levin's testimony itself, and even though it was not required of Exelon, the likely bases for Mr. Emmert's report were specifically disclosed to the Government in correspondence during fact discovery. For example, on January 26, 2004, with more than six weeks left in fact discovery, counsel for Exelon wrote to counsel for the Government (App. at 96, emphasis supplied): [Y]our statement that Mr. Levin "relied only" on the Limerick decommissioning study to estimate post-shutdown costs is incorrect. Mr. Levin testified that the principal source of the post-shutdown cost estimate was Exelon Generation's cost experience at the shut-down Zion station. (Tr. at 144.) As you know, we produced documents related to those costs some time ago. In addition, Mr. Levin relied on the Limerick decommissioning study because it happened to be the most recent study at the time produced by TLG. We expect that ultimately our damage expert will likely rely on the Zion cost figures, as well as any recent TLG decommissioning reports, such as those done at Limerick and Quad Cities. * * *

·

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I note that in [explaining the basis for his calculations], Mr. Levin testified repeatedly that he had relied on the Quad Cities ISFSI budget, cost documentation regarding the last two campaigns for loading SNF into casks from the Dresden 2 and 3 pools, and, in certain instances, on the costs incurred for building an ISFSI for the Dresden unit 1 SNF. I specifically directed you to those documents by bates number in my November 7, 2003 letter. In short, there was no change in position or reliance on any type of underlying cost information that could justify a trial postponement. Fourth, a delay is not warranted by Exelon's disclosure that certain non-retained occurrence witnesses who were previously disclosed as fact witnesses might offer testimony that could be characterized by the Government as falling within the scope of Federal Rules of Evidence 702, 703 or 705. As Exelon's counsel previously explained to the Government's counsel, the purpose of Exelon's disclosure was not to expand the areas of testimony in this case but only to ensure that legitimate occurrence witness testimony that might be scientific or technical in nature would not be vulnerable to an unfounded objection that it was from an "undisclosed expert." Here are the circumstances: with one exception,9 all of the witnesses mentioned by the Government were disclosed, along with a description of their areas of factual knowledge, in our initial Rule 26(a)(1) disclosures made back in August 2003 or in supplemental disclosures (Gov't App. at 16-20). Fourteen of the witnesses were deposed by the Government during fact discovery, on whatever topics the Government considered appropriate regarding the scope of their knowledge and the occurrence documents relating to the witnesses. However, most of these

Francis Seymore, the only witness not listed on Exelon's initial or supplemental disclosures, was deposed by the Government on March 11, 2004. 11 Contrary to the Government's request, as demonstrated in Part II below, the plain terms of Rule 26(a)(2)(B) also do not require Exelon to submit an expert report for these occurrence witnesses.

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witnesses also have a financial, technical or scientific background ­ for example, many are nuclear engineers ­ and their occurrence testimony often relies on that background. Exelon identified these previously-disclosed occurrence witnesses under Rule 26(a)(2) out of an abundance of caution that it might be unfairly suggested that their fact testimony should not be admitted because it concerned "scientific, technical, or otherwise specialized knowledge" as described by Rule 702. For example, we did not want the Government to attempt to bar testimony from an employee, Kenneth Petersen, whose duties involve projections, made in the scope of his employment, about the amount of spent nuclear fuel that will be discharged from Exelon reactors in the future simply because such projections require technical and specialized knowledge. Consequently, this issue does not warrant a postponement of the Government's disclosure deadline.11 At the outset, the scope of these witnesses' knowledge has not changed since they were disclosed; the Government has already had the opportunity to depose them on their knowledge; and, with almost all of the witnesses, the Government has taken that opportunity and spent a day or more with the witness. Moreover, it is has been over a month since the possibility that these witnesses could offer technical testimony was specifically disclosed, and while the Government has indicated orally that it might seek to re-depose some or all of these witnesses, the Government has still not actually asked to do anything with respect to these witnesses. Exelon's "disclosure" of these witnesses under Rule 26(a)(2) cannot, in the absence of a refusal to make them available or even a request from the Government to do so, provide support for the Government's postponement request here. Fifth, given the history of Government delay in this case and the unavailability of prejudgment interest, a trial postponement is fundamentally unfair. This case was filed in 1998.

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Your Honor entered a finding that the Government was liable for breach of contract in August 2001. The Government's summary judgment motions have been denied. As the Government knows, no prejudgment interest is available to Exelon. As reflected in the report of Exelon's damages expert included in the appendix to the Government's recent motion for additional fact discovery, Exelon's damages are very substantial. Under these circumstances, every single day of additional delay is in some sense a victory for the Government, and highly prejudicial to Exelon. II. Exelon Is Not Required To Disclose A Report For The Previously-Identified Occurrence Witness Whom Exelon Disclosed As "Experts" Only Because Their Fact Testimony May Involve Technical Subjects. The Government's request (at 10) that the Court order Exelon to "identify the expected testimony of [17 individuals identified as non-retained experts] so that [the Government] can evaluate whether it will be necessary to depose any of these individuals regarding their expert opinions" is not authorized by the rules or warranted by the situation. Rule 26(a)(2) requires Exelon to "disclose to other parties the identity of any person who may be used at trial to present evidence under" the expert testimony rules of evidence. RCFC 26(a)(2)(A). As described above, Exelon has done that with respect to 17 persons who were also previously disclosed as potential fact witnesses under Rule 26(a)(1). Rule 26(a)(2)(B) only requires an expert report for "[i] a witness who is retained or specially employed to provide expert testimony in the case or [ii] whose duties as an employee of the party regularly involve giving expert testimony . . ." RCFC 26(a)(2)(B). As the Government knows with respect to most of these witnesses, none of the 17 persons we have disclosed falls into either of those two categories ­ none was retained or specially employed to provide expert testimony in this case, and none is an Exelon employee who regularly provides expert testimony for the company. The rules do not require that Exelon

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do any more than it has12 ­ even if these persons were actually intended by Exelon to be "expert" (not fact) witnesses within the meaning of the rules. But, as described above (at 7-8), that is not the situation here. Our reasons for disclosing these fact and occurrence witnesses under Rule 26(a)(2) as potentially offering testimony falling within Rules 702, 703 or 705 is to protect against the possible but unfounded argument that their fact testimony should be restricted because it is in areas that involve specialized and technical knowledge and education. We have already identified the subject matter of all of these fact witnesses' knowledge ­ in our Rule 26(a) disclosures made in August 2003, and subsequent supplements. (Gov't App. at 16-20.) The Government had the opportunity to depose all of these witnesses (and did depose 14 of them) and the Government has long had the documents associated with them No further disclosure is warranted. We also reiterate that this is not a dispute over whether any previously deposed fact witnesses can be re-deposed as an "expert." While the Government's Motion threatens that it might do so, over a month after we first made these disclosures, the Government has not yet made any actual request to re-depose anyone. At this time, in the absence of any Government request, we do not believe the witness' areas of knowledge have changed or that any additional depositions would be justified. However, if and when such a request is made, we would consider that request and attempt to accommodate the Government's concerns, as we have through the rest of discovery, before bringing the issue to the Court.

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RCFC 26(a)(2)(B); Zurba v. United States, 202 F.R.D. 590, 591 (N.D. Ill. 2001) (noting that a written report is required only for an expert retained or specially employed to provide testimony); Sprague v. Liberty Mutual Insurance Co., 177 F.R.D. 78, 81 (D.N.H. 1998) (noting the clear distinction between retained and unretained experts).

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III.

The Court Should Not Order Further Written Disclosures By Mr. Emmert. The Government also requests (at 9) that the Court order Exelon "to identify all

documentation that Mr. Emmert reviewed or considered in developing his opinions in this case . . ." This issue has been the subject of several discussions between counsel, and Exelon respectfully believes the issue has not been resolved by the parties only because the Government is unable to articulate precisely what additional disclosure it wants, at a tangible level which would permit Exelon or Mr. Emmert to reasonably comply. Mr. Emmert's disclosure is extensive, and the Government's vague request for more should therefore be denied. Mr. Emmert's disclosure thus far of his opinions and the data or other information he considered is comprehensive ­ he prepared and submitted a 50 page report with numerous exhibits and schedules. In addition, in expert discovery, we have produced an additional 15 binders containing Mr. Emmert's report and related workpapers and documents which gather, in one spot, all of the information Mr. Emmert considered most important to his opinions. Mr. Emmert's report also contains a five-page, single-spaced bullet point list of documents he and his team considered. (Gov't App. at 54-58.) These sources disclose all of the materials Mr. Emmert believes to be most relevant to his analysis. It also should be emphasized that this is not a dispute over any documents being withheld from the Government; we believe that the Government already has everything that Mr. Emmert considered in forming his opinions. The dispute appears to be over whether Mr. Emmert must list specifically all additional documents which he or Ernst & Young may have received but were not within the first or even second tier of relevance. The problem is that Mr. Emmert was, in fact, provided with virtually Exelon's entire document production to the Government in this case: more than 200,000 pages of paper and 10,000 electronic documents. It was left to Mr. Emmert to determine what of these additional materials were relevant to his analysis, but he received all of them. We have advised 11

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the Government of these facts. We have also specifically advised the Government that the 22 boxes of materials mentioned in the Government's Motion (at 6, 9) are, with extremely limited exceptions, a subset of documents Exelon previously produced, and we have offered to let the Government come look at these documents or copy them. But it would be overly burdensome (and of no utility) for Mr. Emmert to have to catalog the contents of these boxes, or, obviously, Exelon's entire document production to the Government, and the Government has said it does not want him to do that, either. As a consequence, on a practical, "what-should-we-actually-do" level, we are just unsure as to what further the Government wants Exelon or Mr. Emmert to do to "identify all documents that [he] reviewed or considered in developing his opinions in this case . . ." The Government has all of the documents; it has a list and collection of the documents Mr. Emmert considered of principal relevance; and the Government has declined our invitation to review the additional paper documents that Ernst & Young possesses. The Government's vague request should therefore be denied. We think the Government's concerns can be best addressed at Mr. Emmert's deposition. The Government can use that deposition to (i) query Mr. Emmert regarding the relative importance of the data he considered and (ii) assure itself that materials received by Mr. Emmert but not included in his workpaper collection or listed in his report, even if "considered" in the sense that they were received and perhaps reviewed, played no substantive role in forming his opinions. This discovery supplemental to the expert report is contemplated by the rules and is an appropriate way to get at the issue which appears to be concerning the Government.

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Conclusion The Government's Motion should be denied. There is no legitimate reason for an extension that would result in a postponement of the trial ­ a trial that Exelon has waited six years to obtain ­ and any postponement would be prejudicial to Exelon.

Dated: May 18, 2004 Respectfully submitted, By: /s David A. Handzo (by /s Christopher Tompkins) DAVID A. HANDZO Jenner & Block LLP 601 Thirteenth Street, N.W. Suite 1200 South Washington, D.C. 20005 (202) 639-6000 telephone (202) 639-6066 fax COUNSEL FOR PLAINTIFFS EXELON GENERATION COMPANY LLC and COMMONWEALTH EDISON COMPANY, on their own behalf and on behalf of MidAmerican Energy Company, successor-in-interest to IowaIllinois Gas and Electric Company Thomas S. O'Neill Exelon Nuclear Cornerstone II 5th Floor 4300 Winfield Road Warrenville, IL 60555 (630) 657-3770

Of Counsel: Donald R. Cassling Norman M. Hirsch David Jiménez-Ekman Christopher Tompkins Jenner & Block LLP One IBM Plaza Chicago, IL 60611 (312) 222-9350

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Certificate of Filing and Service I hereby certify that on this 18th day of May 2004, a copy of the foregoing "Plaintiffs' Response To Defendant's Motion For Postponement Of Expert Disclosure Deadline And Other Relief" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. I also hereby certify that on this 18th day of May 2004, I caused a copy of the "Appendix In Support Of Plaintiffs' Response To Defendant's Motion For Postponement Of Expert Disclosure Deadline And Other Relief," which was filed separately under seal, to be served via hand delivery on:

HAROLD D. LESTER U.S. Department of Justice Commercial Litigation Section Civil Division 1100 L Street, N.W. Room 12068 Washington, D.C. 20005 SHARON A. SNYDER U.S. Department of Justice Commercial Litigation Section Civil Division 1100 L Street, N.W. Room 12068

/s Christopher Tompkins Christopher Tompkins