Free Response to Motion - District Court of Colorado - Colorado

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 00-cv-01841-LTB-PAC RICKY EUGENE CLARK, on behalf of himself and all others similarly situated, Plaintiff, v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, an Illinois corporation, Defendant.

STATE FARM' RESPONSE OPPOSING MOTION TO INTERVENE S

Defendant State Farm Mutual Automobile Insurance Company (" State Farm" submits ) the following response opposing the " Motion to Intervene,"filed May 14, 2007 on behalf of Roy McIntosh (" McIntosh" Florinda Reed (" ), Reed" and Matthias Hobza (" ), Hobza" (collectively, ) the " Proposed Intervenors" ). I. INTRODUCTION More than six and a half years after this case was commenced, more than a year after Plaintiff Ricky Clark' claims were fully adjudicated and satisfied, after three appeals to the s United States Court of Appeals for the Tenth Circuit, and on the cusp of resolving the issue of class certification in this case, Plaintiff' counsel now seek to add three new putative class s representatives. The Proposed Intervenors, however, do not meet the requirements for either intervention as of right or permissive intervention under Rule 24 of the Federal Rules of Civil Procedure. The untimely motion should be denied because the Proposed Intervenors have no interest that may be impaired or impeded if this case proceeds without them. Once the Motion

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for Class Certification has been decided, the Proposed Intervenors can, if a class is certified, join that class, provided that they meet the class definition, or commence their own action against State Farm. II. FACTS AND PROCEDURAL HISTORY Plaintiff Ricky Eugene Clark commenced this putative class action in Colorado state court on August 24, 2000. State Farm removed the case to this Court on September 19, 2000 and, on October 16, 2000, moved to dismiss the case in its entirety. See Docket No. 4. State Farm argued in its motion to dismiss that the Colorado Court of Appeals'decision in Brennan v. Farmers Alliance Mutual Insurance Co., 961 P.2d 550 (Colo. App. 1998), could not be applied retroactively to support Clark' claims based on an accident that occurred in July 1996. s As of the time the motion to dismiss was filed in this case in October 2000, all three of the Proposed Intervenors were represented by counsel in connection with their claims for benefits from State Farm. See Letter from S.B. Moore to State Farm (May 18, 2000), attached as Exh. A (advising that he represented Reed); Letter from J. Donaldson to State Farm (Apr. 5, 2000), attached as Exh. B (advising that she represented Hobza); Redacted Portion of State Farm' Activity Log (Feb. 5, 1999), attached as Exh. C (reflecting that an attorney with Azar & s Associates represented McIntosh). Reed' accident occurred on May 20, 1999; Hobza' accident s s occurred on April 27, 1998; and McIntosh' accident occurred on January 16, 1999 ­all after the s date of the Brennan decision. See Motion to Intervene at 2 & 3 (noting the accident dates for the Proposed Intervenors). Accordingly, none of their claims would have been subject to the same defense that State Farm argued against Clark in its motion to dismiss. Yet neither Reed, Hobza, nor McIntosh moved to intervene in the case at that time.

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On June 20, 2001, the Court granted State Farm' motion to dismiss, and dismissed the s case in its entirety, concluding that Brennan could not be applied retroactively to support Clark' s claims. See Docket No. 16. Judgment entered accordingly on June 28, 2001. On July 13, 2001, Clark filed a Notice of Appeal. See Docket No. 18. All of the Proposed Intervenors remained represented by counsel at that time. Yet none of them moved to intervene in the case, even when the claims of the putative class representative were dismissed in their entirety. Clark pursued an appeal to the United States Court of Appeals for the Tenth Circuit. On February 11, 2003, the Tenth Circuit issued a published opinion reversing this Court' order of s dismissal and remanding the case for further proceedings. Clark v. State Farm Mut. Auto. Ins. Co., 319 F.3d 1234 (10th Cir. 2003) (" Clark I" ). All of the Proposed Intervenors were

represented by counsel when that opinion was published, but none of them moved to intervene. On April 22, 2003, State Farm submitted a proposal for further proceedings in the case. s See Docket No. 29. By an Order dated April 24, 2003, this Court adopted State Farm' proposal. See Docket No. 31. That Order made clear that an effective date of reformation for Clark only would be the first issue resolved. See Order (Apr. 24, 2003) at (2)(a). Yet Reed, Hobza, and McIntosh still did not move to intervene to have their own effective dates of reformation determined. The case then proceeded through discovery on issues relating to the effective date of reformation for Clark. On November 3-5, 2003, the Court held an evidentiary hearing on the effective date of reformation for Clark. On December 19, 2003, the Court entered its Findings of Fact, Conclusions of Law and Order: (1) reforming the insurance policy at issue to provide Clark with the P4 level of PIP benefits; (2) establishing December 19, 2003 as the effective date of

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reformation for Clark; (3) imposing a $200,000 aggregate limit on additional benefits to which Clark might be entitled; (4) awarding Clark money damages in the amount of $132,276.02; and (5) dismissing Clark' contract and tort claims. That order was published in the official case s reporter. Clark v. State Farm Mut. Auto. Ins. Co., 292 F. Supp. 2d 1252 (D. Colo. 2003) (" Clark II" Yet none of the Proposed Intervenors moved to intervene to seek their own awards of ). money damages or other relief. In January 2004, State Farm and Clark filed cross-appeals in the Tenth Circuit, challenging certain rulings in the December 19, 2003 Order. State Farm posted a supersedeas bond dated February 6, 2004, and obtained a stay of execution of the judgment in Clark' favor s on February 11, 2004, pending resolution of the appeal in the Tenth Circuit. See Docket No. 123. On December 30, 2005, the Tenth Circuit, in a published decision, affirmed this Court' s December 19, 2003 Order in all respects, including the award of damages to Clark. Clark v. State Farm Mut. Auto. Ins. Co., 433 F.3d 703, 710 (10th Cir. 2005) (" Clark III" ). Beginning on approximately February 3, 2006, State Farm communicated to Clark' s counsel its intent to pay Clark the amount of the judgment, for which it had previously posted the supersedeas bond. See Expedited Motion to Deposit Funds with Court and to Release

Supersedeas Bond (Feb. 13, 2006), Docket No. 158, at 3-4 & Exhs. 1 & 2 to the Motion. Clark' counsel clearly understood the significance of such a payment, as they initially refused to s accept payment of the judgment and post-judgment interest without imposing certain conditions on the payment: We cannot accept any monies for Mr. Clark that limit his ability to serve as a class representative. If you will concede that his accepting these monies has no impact on his ability to serve as a class representative, or pursue any other claims that he may yet have, we can discuss the amounts further.

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See id. at Exh. 2 to the Motion.

By March 16, 2006, however, the parties agreed to an

arrangement where State Farm would pay the judgment and post-judgment interest to Clark, without Clark imposing any conditions. See Stipulated Motion for Entry of Order Regarding Payment of Judgment to Clark (Mar. 16, 2006), Docket No. 169. The payment was then made, and the supersedeas bond was released. At the time that these events transpired, and coincident with State Farm' payment of the s judgment to Clark, Clark' own counsel also represented Proposed Intervenor Reed. See Letter s from F. Johnson to State Farm (June 1, 2005), attached as Exh. D. 1 Yet despite the fact that her counsel anticipated ­no later than February 2006 ­the possibility that payment of the judgment to Clark might make him an inadequate class representative, Reed did not file a motion to intervene. Nor did Hobza or McIntosh, both of whom also were represented by counsel. 2 In September 2006, Clark and State Farm jointly requested a status conference which was scheduled for September 28, 2006. In anticipation of that status conference, on September 27, 2006, State Farm filed a Status Conference Statement, noting again that all of Clark' claims had s been fully and finally adjudicated. See Docket No. 182. Following the status conference, the Court entered an Order establishing a briefing schedule on Clark' proposed amended class s definition. See Docket No. 183. On October 27, 2006, Clark filed a Brief in Support of his Amended Proposed Class Definition. On November 20, 2006, State Farm responded. In its
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State Farm is unaware of the precise date when Plaintiff' counsel, The Carey Firm, first s communicated with Ms. Reed or her prior counsel, or when they undertook representation of Ms. Reed. State Farm has been able to locate correspondence sent by The Carey Firm, on behalf of Ms. Reed, as early as June 1, 2005. It is possible that The Carey Firm represented Ms. Reed long before that date. 2 State Farm is unaware when The Carey Firm first began representing Messrs. Hobza and McIntosh. It is possible that The Carey Firm already had communicated with Hobza or McIntosh, or their

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response, State Farm once again advanced its position that Clark could not be an adequate class representative because he has no live claims. See State Farm' Response Brief Regarding s Plaintiff' Proposed Amended Class Definition (Nov. 20, 2006), Docket No. 188, at 24-25. Yet s none of the Proposed Intervenors took any action. Not until April 27, 2007 did counsel for the Proposed Intervenors first give any indication that they might file a motion to intervene. See E-mail from R. Carey to M. McCarthy (Apr. 27, 2007) & E-mail from M. McCarthy to R. Carey (May 7, 2007), attached as Exh. E. The Motion to Intervene was filed on May 14, 2007 ­nearly seven years after this case first was commenced. Against this factual background, the Motion to Intervene must be denied. III. ARGUMENT A. The Proposed Intervenors are not entitled to intervention as of right because their interests will not be impaired or impeded absent intervention, and in any event, their motion is untimely. An applicant such as Reed, Hobza, or McIntosh is entitled to intervention as a matter of right, under Rule 24(a) of the Federal Rules of Civil Procedure, only when: (1) (2) (3) (4) the application is timely; the applicant claims an interest relating to the property or transaction that is the subject of the action; the applicant' interest may as a practical matter be impaired or impeded; s and the applicant' interest is not adequately represented by existing parties. s

Utah Ass' of Counties v. Clinton, 255 F.3d 1246, 1249 (10th Cir. 2001); see also Fed. R. Civ. n P. 24(a). Here, the Proposed Intervenors have not made a timely application to intervene, and

prior counsel, by this time. Even without that additional information, though, the Motion to Intervene is untimely.

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they have not shown that their interests relating to this case would be impaired or impeded without intervention. 1. The Proposed Intervenors'alleged interests will not be impaired if this case proceeds without them.

In order to establish a right to intervene, the Proposed Intervenors must show that " impairment of their substantial legal interest is possible if intervention is denied." Clinton, 255 F.3d at 1253. " Litigation impairs a third party' interests when the resolution of the legal s questions in the case effectively foreclose the rights of the proposed intervenor in later proceedings, whether through res judicata, collateral estoppel, or stare decisis." Ute Distrib. Corp. v. Norton, 43 Fed. Appx. 272, 279 (10th Cir. 2002), attached as Exh. F. Here, any interests that the Proposed Intervenors may have 3 in this case will not be impaired if the Motion to Intervene is denied. The Proposed Intervenors assert that, like Clark, they have claims for additional extended PIP benefits relating to State Farm' inclusion of the Pedestrian Limitation in its automobile s insurance policies. They further argue that, if State Farm successfully argues that Clark has no " standing" to act as a class representative, and they are not permitted to intervene, " then the intervenor Plaintiffs would be without a remedy in this action." Memorandum in Support of

Indeed, some or all of the Proposed Intervenors may not have any interest in this action. For example, McIntosh and Reed allegedly suffered injuries after January 1, 1999, and could not have suffered damages as a result of any alleged misconduct by State Farm related to inclusion of the Pedestrian Limitation in its automobile policies. See, e.g., Order & Memorandum of Decision (Nov. 18, 2005), Virgil Stickley v. State Farm Mut. Auto. Ins. Co., No. 04-cv-01685-EWN-OES (Nottingham, J.), attached as Exh. G (holding that elimination of the Pedestrian Limitation ­ which occurred no later than January 1, 1999 ­ remedied any alleged defects in the offer of extended PIP benefits); see also State Farm' Response Brief Regarding Plaintiff' Proposed Amended Class Definition (Nov. 20, 2006) at 23s s 24.

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Motion to Intervene (May 14, 2007) at 6. That is the only alleged impairment identified by the Proposed Intervenors. The Proposed Intervenors fail to acknowledge, however, that if the Motion to Intervene is denied, they may commence their own individual actions against State Farm after the Motion for Class Certification has been decided. If such actions are filed after class certification is denied, the doctrine of class action tolling would apply to save their individual claims from a statute of limitations defense. See, e.g., Crown, Cork & Seal Co. v. Parker, 462 U.S. 345, 353-54 (1983). This case would have no effect ­ through res judicata, collateral estoppel, stare decisis, or otherwise ­ on the Proposed Intervenors'right to bring separate actions. Compare Ute Distrib. Corp., 43 Fed. Appx. at 279, attached as Exh. F. Accordingly, the Proposed Intervenors have identified no impairment to their legal position that could possibly arise from a denial of the Motion to Intervene. " availability of a separate lawsuit cuts against intervention as of right." The Ross v. Donley, 2007 U.S. Dist. LEXIS 31037 (D. Kan. Apr. 26, 2007), attached as Exh. H (citing San Juan County v. U.S., 420 F.3d 1197 (10th Cir. 2005)). Because the Proposed Intervenors can bring separate lawsuits, and because they have demonstrated no impairment of their interests that would result from a denial of the Motion to Intervene, the motion should be denied. 2. The Proposed Intervenors'motion is untimely.

The Proposed Intervenors also have delayed far too long to seek intervention now. In the Tenth Circuit, the timeliness of a motion to intervene must be considered in light of all of the circumstances in a case, including: (1) the length of time since the applicant knew of his interest in the case; (2) prejudice to the existing parties; (3) prejudice to the applicant; and (4) the

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existence of any unusual circumstances. Clinton, 255 F.3d at 1250 (citing Sanguine, Ltd. v. U.S. Dep' of Interior, 736 F.2d 1416, 1418 (10th Cir. 1984)). The question of timeliness of a motion t to intervene is one of fact, committed to the sound discretion of this Court. See, e.g., Jicarilla Apache Tribe v. Hodel, 821 F.2d 537, 539 (10th Cir. 1987) (" The district court' determination s whether an application is timely is reviewable only under an abuse of discretion standard." Ute ); Distrib. Corp., 43 Fed. Appx. at 276, attached as Exh. F (same). The timeliness requirement " is of first importance" in resolving a Motion to Intervene. See, e.g., United Nuclear Corp. v. Cannon, 696 F.2d 141 (1st Cir. 1982). The Proposed Intervenors, however, cannot show that their motion is timely, in light of all of the relevant circumstances. As explained above, Hobza was involved in an accident on April 27, 1998, and was represented by counsel no later than April 5, 2000. McIntosh was involved in an accident on January 17, 1999, and was represented by counsel no later than February 5, 1999. Reed was involved in an accident on May 20, 1999, was represented by counsel no later than May 18, 2000, and was even represented by Clark' counsel, The Carey Law Firm, no later than June 1, s 2005. The Proposed Intervenors and their counsel are charged with knowledge of the law. See, e.g., U.S. v. Windrix, 405 F.3d 1146, 1157 (10th Cir. 2005), citing Jetton v. McDonnell Douglas Corp., 121 F.3d 423, 426 (8th Cir. 1997) (" parties are charged with knowledge of the district court' rules the same as with knowledge of the Federal Rules and all federal law" see also s ); Insurance Co. of North America v. Bath, 1992 WL 113746, *1 (10th Cir. 1992). Thus, no later than February 11, 2003, when the Tenth Circuit published its opinion in Clark I, the Proposed Intervenors and all of their counsel were on notice of a putative class action in which they might have an interest.

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Indeed, the Proposed Intervenors concede that they have known for a long time about their potential interest in this case: " Because State Farm proposed (and this Court Ordered) that Mr. Clark' reformation claim be adjudicated prior to the Court' consideration of certification, s s the intervenor Plaintiffs could only have believed that their interests were protected by Mr. Clark and the proposed Class action." Memorandum in Support of Motion to Intervene (May 14, 2007) at 6. By this statement, the Proposed Intervenors acknowledge that they had actual knowledge of their potential interest in this case no later than April 24, 2003, when the Court entered the Order to which they refer. Yet all of the Proposed Intervenors delayed for four more years before filing a motion to intervene. This delay in moving to intervene ­ despite having knowledge of their potential interests in the case for at least four years (and possibly longer) ­ is inexcusable. " party seeking to intervene must act as soon as he knows or has reason to know A that his interests might be adversely affected by the outcome of the litigation." Utah v. Kennecott Corp., 232 F.R.D. 392, 396 (D. Utah 2005) (citing U.S. v. Oregon, 913 F.2d 576 (9th Cir. 1990)). In Jicarilla Apache Tribe v. Hodel, the Tenth Circuit held that a potential intervenor who had notice of the pending lawsuit for over three and half years before filing a motion to intervene was untimely. In addition, because the intervenors would interject new issues and require another trial on issues different from those previously litigated, the motion to intervene was denied. See Jicarilla Apache Tribe, 821 F.2d at 539; see also Ute Distrib. Corp., 43 Fed. Appx. at 277, attached as Exh. F (holding that an Indian tribe' motion to intervene was untimely where s it was filed five years after commencement of the action). Indeed, the Tenth Circuit has upheld the discretion of a district court to deny a motion to intervene filed only four months after having

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actual notice of interest in a case. See Lumbermens Mut. Cas. Co. v. Rhodes, 403 F.2d 2, 5 (10th Cir. 1968) (" bonding company, after being apprised by letter of its potential liability the under the judgment, delayed more than four months before attempting to intervene. In these circumstances we certainly cannot say that the trial judge abused his discretion in rejecting Lumbermens'application as untimely." Here, the Proposed Intervenors should have known of ) the pending class action in which they now claim an interest no later than February 11, 2003, and admit they knew of the case no later than April 24, 2003, yet they failed to file the Motion to Intervene until May 14, 2007, more than four years later. This Court has ample discretion under Tenth Circuit precedent to conclude that a motion to intervene, filed four years after notice that interests might be affected, is untimely. The Proposed Intervenors ignore the primary factor ­the length of time since they knew of their interest in the case ­ and instead summarily allege that " there is no prejudice to State Farm, since the intervention motion is brought concurrently with the motion for class certification and no new allegations are lodged." Memorandum in Support of Motion to Intervene (May 14, 2007) at 6. But they never explain how this sequence of events might evidence a lack of prejudice to State Farm. Prejudice may exist where a motion to intervene will delay the ultimate disposition of the case. See, e.g., McMurtry v. Aetna Life Ins. Co., 2006 U.S. Dist. LEXIS 81220 (W.D. Okla. 2006), attached as Exh. I. Here, granting the Motion to Intervene would cause prejudicial delays in the case. If any one of the Proposed Intervenors are permitted to intervene, and assuming they are entitled to reformation (which State Farm does not concede), the Court will be required to take up the issue of the " effective date of reformation"for each of them. See Clark I, 319 F.3d at

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1243 (" effective date of reformation is an equitable decision to be determined by the trial the court based on the particular circumstances of each case" That issue would necessitate further ). discovery, briefing, and another evidentiary hearing to the Court in order to resolve the equitable issues presented in determining an effective date of reformation. Thus, granting the Motion to Intervene would continue to prolong this already extended litigation between Clark and State Farm, and would prejudice State Farm by so doing. See, e.g., McMurtry, 2006 U.S. Dist. LEXIS 81220, attached as Exh. I. In addition, the Motion to Intervene already has delayed disposition of this case. Contrary to the Proposed Intervenors'assertion, filing the Motion to Intervene simultaneously with the Motion for Class Certification actually increased the prejudice to State Farm caused by their untimely motion. As State Farm explained in its Motion for Entry of a Scheduling Order, if the Motion to Intervene is granted, there will be a need for additional discovery. See Motion for Entry of a Scheduling Order (May 18, 2007) at 3-4. The Proposed Intervenors themselves recognize that at the very least their depositions must be taken if the Motion to Intervene is granted. See Response to Motion for Entry of Scheduling Order (May 29, 2007) at 1.

Additionally, the Proposed Intervenors and Clark have agreed that State Farm should be permitted to wait until the Motion to Intervene has been decided before it can fairly be asked to respond to the Motion for Class Certification. See id. Thus, the Motion to Intervene already has prejudiced State Farm by extending the conclusion of this litigation, and will continue to cause prejudice to State Farm. The Proposed Intervenors, on the other hand, will not suffer any significant prejudice if the Motion to Intervene is denied. Once the Motion for Class Certification has been ruled on in

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this case, the Proposed Intervenors will be free to either join any certified class that may result from this case if they fall within the class definition, or to commence their own action against State Farm in the event certification is denied. So long as the Proposed Intervenors wait until after the Court' ruling on the Motion for Class Certification, the doctrine of class action tolling s will apply to save their individual claims from a statute of limitations defense. See, e.g., Crown, Cork & Seal Co., 462 U.S. at 353-54. The Proposed Intervenors have identified no other prejudice that they might suffer if the Motion to Intervene is denied. Thus, the certainty of prejudice to State Farm that would result from granting the motion, and the lack of prejudice to the Proposed Intervenors if the motion is denied, counsel in favor of denying the Motion to Intervene. To excuse their untimely motion, the Proposed Intervenors also argue that the " unusual circumstances"of this case ­apparently meaning the unique procedural course that this case has taken (which was largely dictated by the Tenth Circuit' ruling in Clark I) ­make it appropriate s to grant the Motion to Intervene. See Memorandum in Support of Motion to Intervene (May 14, 2007) at 6. Regardless of the manner in which this case has progressed, however, the fact remains that the Proposed Intervenors knew of their claimed interests in this case no later than April 2003, but did nothing about it until May 2007. They also were aware of the procedural posture of the case by virtue of the February 2003 published decision in Clark I, the December 2003 published decision in Clark II, and the December 2005 published decision in Clark III. They should not be permitted to sit back, watch a particular procedural course unfold, and still do nothing to attempt to protect their interests for more than four years. For all of these reasons, the Court should conclude, in the exercise of its discretion, that the Motion to Intervene is untimely.

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3.

The Proposed Intervenors concede Clark' inadequacy. s

Finally, the Proposed Intervenors concede that Clark may not be an adequate class representative on their behalf. See Motion at 6-7. State Farm agrees that Clark is an inadequate class representative. On all other factors relating to intervention as of right under Rule 24(a), however, the Proposed Intervenors have failed to carry their burden. The Motion to Intervene under Rule 24(a) should be denied. B. The Proposed Intervenors are not entitled to permissive intervention because their motion is untimely. Nor are the Proposed Intervenors entitled to permissive intervention under Rule 24(b) of the Federal Rules of Civil Procedure. To support intervention under Rule 24(b), the Proposed Intervenors must show both that their motion is timely, and also that their " claim or defense and the main action have a question of law or fact in common." Fed. R. Civ. P. 24(b)(2). Even though the Proposed Intervenors' claims may purport to have something in common with Clark' s claims, they nevertheless are not entitled to permissive intervention under Rule 24(b) because their motion is untimely. As explained above, the Proposed Intervenors have delayed too long in moving to intervene in this case to protect their claimed interests. State Farm urges the Court, in its broad discretion on this issue, to conclude that the Motion to Intervene is untimely, and that the Proposed Intervenors are not permitted to intervene in this action under either Rule 24(a) or Rule 24(b) of the Federal Rules of Civil Procedure. IV. CONCLUSION The Proposed Intervenors ­represented by Clark' own counsel ­seek to fundamentally s alter the nature and scope of this case nearly seven years after the case was commenced. Their Motion to Intervene comes too late, however, because: (1) the Proposed Intervenors have known

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of their interests in this case at least since April 2003; (2) granting the Proposed Intervenors'late motion would prejudice State Farm; (3) denial of the motion would not result in any impairment of the Proposed Intervenors'rights; and (4) there are no special circumstances excusing the belated motion. The Proposed Intervenors will be free to bring their own individual actions if the Motion for Class Certification is denied. For all of these reasons, as explained more fully above, the Court should deny the Motion to Intervene under both Rules 24(a) and 24(b). WHEREFORE, Defendant State Farm Mutual Automobile Insurance Company respectfully requests that the Court enter an Order denying the Motion to Intervene. Respectfully submitted this 4th day of June, 2007.

s/ Michael S. McCarthy Michael S. McCarthy Russell O. Stewart Marie E. Williams FAEGRE & BENSON LLP 1700 Lincoln Street, Suite 3200 Denver, Colorado 80203 Phone: (303) 607-3500 Fax: (303) 607-3600 E-mail: [email protected] [email protected] [email protected] ATTORNEYS FOR DEFENDANT STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY

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CERTIFICATE OF SERVICE I hereby certify that on this 4th day of June, 2007, I electronically filed the foregoing STATE FARM' RESPONSE OPPOSING MOTION TO INTERVENE with the Clerk of S the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses:
· · ·

Robert Bruce Carey [email protected],[email protected] Leif Garrison [email protected],[email protected] L. Daniel Rector [email protected],[email protected]

s/ Colleen H. Russell Colleen H. Russell
fb.us.2065722.02

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