Free Motion to Strike - District Court of Colorado - Colorado

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THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-cv-1263-PSF-MEH ROBERT M. FRIEDLAND, Plaintiff, v. TIC-- THE INDUSTRIAL COMPANY and GEOSYNTEC CONSULTANTS, INC. f/k/a GEOSERVICES, INC Defendants. __________________________________________________________________________ DEFENDANTS' JOINT MOTION TO STRIKE PLAINTIFF' DESIGNATION OF S REBUTTAL EXPERT WITNESSES AND TO PRECLUDE DESIGNATION OF FURTHER EXPERTS __________________________________________________________________________ Defendants TIC ­The Industrial Company and Geosyntec Consultants, Inc. respectfully submit the following Motion to Strike Plaintiff' Designation of Rebuttal Expert s Witnesses and to Preclude Designation of Further Experts. INTRODUCTION Plaintiff Robert M. Friedland (" Friedland" seems to have forgotten that a Modified ) Scheduling Order exists in this case. Neither his improper November 17, 2006 Motion for Extension of Time to Designate Expert Rebuttal Witnesses nor his November 20, 2006 Designation of Rebuttal Expert Witnesses even acknowledged that the Scheduling Order exists, and in fact, should control both requests. Rather than moving to modify the Scheduling Order, which would require a showing of " exceptional cause,"Friedland cited

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Rule 26(a)(2) as the basis for his filings. A scheduling order, however, " not a frivolous is piece of paper, idly entered, which can be cavalierly disregarded by counsel without peril." Hannah v. Roadway Express, Inc., 200 F.R.D. 651 (D. Colo. 2001) (quoting Gestetner Corp. v. Case Equipment Co., 108 F.R.D. 138, 141 (D. Me. 1985)). Friedland cannot make the required showing of exceptional cause, or of good cause under Rule 16(b)' default standard, and his rebuttal reports and experts should be stricken. s Further, experts Mitchell Gropper and Jennifer Johnson also should be stricken because they rebut only a corporate veil piercing theory, which no expert or other defense witness has articulated in this case. Neither counsel' time, nor the parties'expense, nor this Court' s s attentions should be wasted and distracted by considering an evaluation that is both untimely and entirely irrelevant to the case. Defendants therefore request that the Court grant Defendants'Joint Motion to Strike Plaintiff' Designation of Rebuttal Expert Witnesses, order Friedland to reimburse s Defendants'costs in responding to these designations and preclude the Plaintiff from endorsing any further expert witnesses, rebuttal or otherwise. PROCEDURAL BACKGROUND 1. On June 26, 2006, the Court entered an Order on Motion for Modification of

Scheduling Order and Related Relief (the " Modified Scheduling Order" establishing the ) following deadlines: August 11, 2006: Deadline for Friedland to serve " Plaintiff' expert reports on s damage and allocation issues, and all documents considered by Plaintiff' expert(s) in the preparation of such reports[.]" s

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October 15, 2006:

Deadline for Defendants to serve " Defendants'expert reports on damages and allocation issues, and all documents considered by Defendants'expert(s) in the preparation of such reports[.]" Deadline for filing dispositive motions.

October 30, 2006:

November 17, 2006: Close of all discovery related to damages and allocation issues. 2. In the Modified Scheduling Order, the Court stated that it " consider any will

further requests for extensions of time only for exceptional cause." [Proposed Scheduling Order, filed 1/19/05; Order on Mot. for Modification of Scheduling Order and Related Relief, filed 1/6/06, Docket # 131, at 1.] 3. On November 13, 2006, Friedland' counsel sent a letter to TIC counsel s

requesting that he agree to an extension of time for Friedland to designate rebuttal experts, to and including December 15, 2006. [Exhibit A.] Counsel for GeoSyntec was neither addressed nor copied on the letter. 4. By letter dated November 17, 2006, Mr. Deihl reminded Friedland' attorney s

that " [t]he June 26, 2006 scheduling order, agreed to by all parties and entered by the Court, does not provide for rebuttal reports." [Exhibit B.] 5. Friedland filed a Motion for Extension of Time to Designate Expert Rebuttal

Witnesses (the " Motion for Rebuttal Extension" on November 17, 2006. [Docket #166.] ) 6. In the Motion, Friedland cited Rule 26, saying: " [p]ursuant to Fed.R.Civ.P.

26(a)(2)(b), [sic] Plaintiff must designate rebuttal experts and serve their reports within 30 days[.]" [Docket # 166, at 2.] This reference most likely was meant to cite Rule 26(a)(2)(C), which allows a party to submit rebuttal expert disclosures within 30 days after a disclosure made by the other party in the absence of any direction by the Court or a stipulation by the
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parties. Fed. R. Civ. P. 26(a)(2)(C). Friedland did not reference the Modified Scheduling Order in his motion. 7. In effect, the relief sought by the Motion for Rebuttal Extension was not to

modify or extend an existing deadline in the Modified Scheduling Order, as it was captioned, but to allow Plaintiff to make an entirely new round of expert disclosures that was neither contemplated by the Modified Scheduling Order nor anticipated by the Defendants. And the proposed date for submission ­December 15, 2006 ­was only six days before the scheduled date for the Final Pretrial Conference. [See Minute Order Clarifying the Record, filed 9/1/06, Docket # 141.] A few days after the Motion for Rebuttal Extension was filed, the Final Pretrial Conference was postponed by 30 days, to January 29, 2007. [Minute Order, filed 11/21/06, Docket # 172.] 8. On November 20, 2006, Friedland served a " Designation of Rebuttal Expert

Witnesses"and corresponding reports by two experts, attorneys Jennifer J. Johnson and Mitchell H. Gropper. [Pl.' Designation of Rebuttal Expert Witnesses, filed 11/20/06, s Docket # 168]. 9. In their reports, these experts opined that defense expert Luke Danielson, in

his own report, had not established the factors necessary to justify a piercing of the corporate veil between Friedland and his companies. [Exhibit C, p. 2 (Johnson) and Exhibit D, pp. 5-7 (Gropper).] They also opined that, under applicable law, Friedland could not be held liable through a corporate veil piercing theory. [Exhibit C, p. 2; Exhibit D, pp. 1-7.] However, nowhere in his report did Mr. Danielson even mention a " corporate veil"theory, or purport

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to analyze the legal elements relevant to such a determination. 10. On November 22, 2006, the Court entered a Minute Order granting the Motion

for Rebuttal Extension, stating that " Plaintiff' deadline for designation of rebuttal expert s witnesses is changed to December 15, 2006." [Minute Order, filed 11/22/06, Docket # 175 (emphasis added).] However, contrary to Friedland' characterization, there had been no s deadline for rebuttal expert designations by Friedland in the first instance, as such witnesses were never contemplated by the Modified Scheduling Order. 11. On December 11, 2006, during a telephone call, counsel for defendants

explained that they were not seeking to pierce the corporate veil between Friedland and his companies, and were not seeking to hold him liable under CERCLA on a veil piercing theory. Friedland' counsel then agreed to withdraw his designation of experts Gropper and s Johnson. [Exhibit E, 12/12/06 letter from M. Carlson to K. Mueller, copied to C. Deihl, confirming this conversation.] 12. On December 15, 2006, Friedland Served a " Designation of Rebuttal Expert

Witnesses"and corresponding reports of Andy Davis, Kenneth L. Meyers, Christopher M. Wittenbrink, and Garth H. Allen. [Pl.' Designation of Rebuttal Expert Witnesses, filed s 12/15/06, Docket # 190.] 13. On January 10, 2007, joint defense expert Luke Danielson was deposed. He

testified, consistent with his report that had been served in October 2006, that he believed Friedland was the dominant actor behind the Summitville project. [Exhibit F, pp. 130-131.] Plaintiff' counsel suggested that Mr. Danielson was trying to pierce the corporate veil. Mr. s

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Danielson replied " think it is for the lawyers in this case and the judge in this case to decide I what the law is, what the legal arguments are about. I think my role here is to testify as to my opinions and testify as to the facts on which I' basing those opinions. Whether you m think that those facts and opinions are relevant to piercing the corporate veil or not is for others to decide." [Id., p. 130.] 14. As counsel discussed the proposed Final Pretrial Order submitted to this Court

on January 25, 2007, Plaintiff' counsel insisted on including experts Gropper and Johnson, s on the premise that Defendants are, in effect, " covertly"seeking to pierce the corporate veil. Counsel for co-defendants TIC and Geosyntec denied they are pursuing such a claim.
ARGUMENT

Friedland flouted the Modified Scheduling Order by serving rebuttal expert disclosures that violated this Order on their face, then moved to extend deadlines that did not exist in the Order. This unilateral expansion of expert discovery imposed unnecessary costs on Defendants and represents exactly the type of surprise Rule 16 is meant to avoid. In addition, it would waste this Court' time and resources to allow Friedland to offer s testimony from two expert witnesses whose only role is to rebut a legal theory that Defendants have never put forth, and in fact, have confirmed they are not pursuing. Defendants have said to Friedland' counsel, and inform this Court, that they are not seeking s to pierce the corporate veil between Friedland and his companies. The legal opinions of Gropper and Johnson accordingly are irrelevant and unnecessary. Rather than rebutting any opinions actually put forth by any defense experts, Friedland has endorsed these witnesses

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simply to buttress the arguments in his Motion for Summary Judgment on CERCLA liability. I. The Modified Scheduling Order does not allow for rebuttal expert designations or reports. The Modified Scheduling Order established that Friedland would serve expert reports on damage and allocation issues in mid-August 2006, and that Defendants would serve their responsive reports approximately 60 days later. No provision for rebuttal reports was made. Friedland' counsel did not object to this schedule, nor request an opportunity to endorse s " rebuttal"experts. The Modified Order accordingly should control this case. a. The Parties never intended to allow for rebuttal expert discovery regarding damages and allocation issues.

The parties jointly sought modification of the original Scheduling Order on June 19, 2006 in order to obtain an additional, finite amount of time in which to complete discovery on damages and allocation issues. [Stipulated Mot. for Modification of Scheduling Order and Related Relief, filed 6/19/06, Docket #127.] The parties acknowledged that they faced discovery disputes related to damages and allocation issues. Id. at p. 2. Due to the foreseeable inability to meet the June 30 discovery deadline, the parties " conferred at length and good faith"and " agreed... upon the process [to] facilitate the remaining discovery." Id. at p. 3. The agreed process was incorporated into the Modified Scheduling Order. [Compare Docket # 127, at p. 4, to Docket # 131.] The Stipulated Motion did not contemplate the possibility that after Defendants' expert disclosures, Friedland would serve yet another round of " rebuttal expert"reports. [Docket # 127.] The parties agreed that " foregoing modification of the Scheduling Order the

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would promote fairness, economy, and reduce the burden on judicial resources by resolving complex and disputed issues[.]" Id. at 5. Defendants negotiated with Friedland in good faith to extend the discovery deadlines, agreeing at the same time to withdraw a portion of a Motion to Bifurcate and to withdraw a previously filed Motion to Compel. Friedland has now completely ignored his agreement with Defendants and seeks to circumvent it. b. The Modified Scheduling Order controls the expert discovery schedule in this case, not Rule 26(a)(2)(C) of the Federal Rules of Civil Procedure.

Friedland attempts to justify his alleged rebuttal expert designations under Rule 26(a)(2)(C) of the Federal Rule of Civil Procedure. Rule 26(a)(2)(C) is a default rule that allows a party to disclose rebuttal expert testimony within 30 days after the expert disclosure of an opposing party. Fed. R. Civ. P. 26(a)(2)(C). However, when a scheduling order is in effect that includes provisions for expert discovery, then " plan controls and not the the explicit provisions of Rule 26(a)(2)(C)." Akeva L.L.C. v. Mizuno Corp., 212 F.R.D. 306, 310 (D.N.C. 2002); See also IBM Corp. v. Fasco Indus., Inc., 1995 WL 115421 at *2 (N.D.Cal. Mar. 15, 1995) [attached as Exhibit G]. This reading is supported by the explicit language of Rule 26(a)(2)(C), which states that the timeline in the Rule only applies " the absence of other directions from the court [i]n or stipulation by the parties[.]" The Modified Scheduling Order' silence on Friedland' right to rebuttal experts s s should not be interpreted to mean that the provisions of Rule 26(a)(2)(C) apply, as Friedland seems to imply. In IBM Corp., the defendant attempted to make this argument to justify

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rebuttal witness disclosures three weeks after the cutoff for expert discovery. The court rejected the argument, saying that the critical question was " whether the court has spoken on the subject of expert disclosures generally, not whether it has specifically substituted its own deadlines for those proposed in Rule 26(a)(2)(C)." IBM Corp., 1995 WL 115421 at *2. When the court has crafted its own schedule, the default timelines in Rule 26(a)(2)(C) are nullified. Id.; See also Akeva L.L.C., 212 F.R.D. at 310 (" discovery plan simply did not the provide a third-tier time for rebuttal experts. To meet this problem, plaintiff relies on the remaining provisions of Rule 26(a)(2)(C)... The Court rejects all of plaintiff's constructions." 3 Moore' Federal Practice, § 16.13(2)(a)(iii). ); s One reason justifying this result is the November 17, 2006 cutoff date for all discovery contained within the Modified Scheduling Order. Imposing the default Rule 26 timeline over this schedule would result in Plaintiff' ability to disclose rebuttal experts three s days after the close of all discovery. This is not an outcome the parties or the Court intended. See IBM Corp., 1995 WL 115421 at *2 and *4. II. The reports of Ms. Johnson and Mr. Gropper are both untimely and irrelevant, and therefore should not be allowed. After receiving defense expert Luke Danielson' report, which addresses at length the s equitable reasons why Friedland has not paid more than his fair share of the response costs in this case [Exhibit H], Friedland submitted designations from " rebuttal"experts Johnson [Exhibit C] and Gropper [Exhibit D]. As noted above, their reports address the legal theories that would govern a piercing of the corporate veil between Friedland and his companies and critique Danielson' purported efforts to meet those criteria. s

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However, Mr. Danielson gave no opinion in his report related to piercing the corporate veil between Friedland and his companies, and defense counsel repeatedly have stated that they do not intend to pursue this legal theory at trial. Counsel for Friedland seem disturbed by Danielson' factual testimony about the s dominance Friedland exercised over the companies he created, and his direct control over critical decisions. After Danielson provided factual support for his opinion that Friedland " created a reasonably complex corporate structure,"Friedland' counsel bristled, and s characterized Mr. Danielson' testimony as contravening the Defendants'representation that s they were not pursuing a " piercing"theory. [Exhibit F, pp. 128-130.] veil Friedland' counsel suggested that the only possible relevance to Friedland' s s corporate control could be veil piercing, then asked Danielson " what I' like to know now So d is what the significance of this statement, those corporations, to your opinion with respect to Mr. Friedland' culpability or liability in this case?" Danielson answered: " s Well, I ­I think my point is that in assessing this on any realistic basis, it' a mistake to get hung up on the s details of corporate organization when the organization is this fluid." [Exhibit F, p. 130.] Still not satisfied, Friedland' counsel said " s Well, I still don' know why you think t this corporate structure' relevant to your opinions in this case. It doesn' matter what I s t think, quite honestly. I need to know what you think." Danielson answered: " think that I the corporations came and went and one constant in this project was Mr. Friedland." [Exhibit F, pp. 130-131.] By suggesting that Friedland' dominance and manipulation of the corporations s

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involved with Summitville has relevance only to a veil piercing theory, his lawyers completely misunderstand the applicable law. As is outlined in the joint defense response to Friedland' motion for summary judgment on his CERCLA liability, Friedland' individual s s conduct should be judged by the other standard set forth in Bestfoods, that which determines whether any type of actor is a CERCLA operator: did the actor " manage, direct or conduct operations specifically related to pollution"or make " decisions about compliance with environmental regulations." 524 U.S. at 66-67; see also Browning-Ferris Ind. of Ill., Inc. v. Ter Maat, 195 F.3d 953, 955-956, 961 (7th Cir. 1999) (applying Bestfoods; reversing a judgment that Ter Maat was not individually liable and remanding for consideration of his management and direction of operations related to pollution; not referring to normal or eccentric corporate oversight as the relevant standard). Before Bestfoods and after Bestfoods, a corporate executive' personal liability is s evaluated based on how involved he was in the wrongful acts. Norfolk Southern Ry. Co. v. Gee Co., 1999 WL 286287 *2-3 (N.D. Ill. Apr. 23, 1999) [attached as Exhibit I]. If an executive' only link to the wrongful conduct is by virtue of his corporate association, then s he is not personally liable. See Browning-Ferris, 195 F.3d at 956 (" an individual is hit by If a negligently operated train, the railroad is liable in tort to him but the president of the railroad is not[,]"unless the president had been driving the train). Ordinary corporate oversight and management activities " unrelated to pollution"or the environment accordingly do not lead to CERCLA liability. Id. (emphasis added). If the executive is more closely connected to pollution or environmental compliance,

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however, through contract negotiations, making critical decisions about the property, directing measures that have to do with environmental compliance, or participating in meetings where these issues are addressed, then he does have personal CERCLA operator liability, jointly with his corporation. Browning-Ferris, 195 F.3d at 956 (after Bestfoods); FMC Corp. v. Aero Ind., Inc., 998 F.2d 842, 846 (10th Cir. 1993) (before Bestfoods) (finding personal operator liability for actions including " decision for Aero to purchase the the property,"" decision to reopen operations at the site,"" the controll[ing] its finances,"and receiving " regular reports concerning the operation and handling of hazardous wastes" ). When executives play a critical role in directing environmental policy and deciding on courses of action that relate to hazardous substances, as Friedland did, courts are willing to impose personal CERCLA operator liability on them for resulting releases. FMC Corp. v. Aero Ind., Inc., 998 F.2d 842, 846 (10th Cir. 1993); City of Wichita, Kan. v. Trustees of the Apco Oil Corp. Liqu. Trust, 306 F. Supp. 2d 1040, 1055-56 (D. Kan. 2003) (finding individual operator liability when the person attended weekly meetings where environmental compliance issues were addressed and supplied approval for decisions about what to do). Friedland' claim that he did not pay attention to critical junctures in the Mine' s s development is contradicted by numerous witnesses and documents. His claim that he was not involved in key decisions about the Mine' development, and that he does not recall them s either, defies credibility. [Set forth in Defendants'Memorandum of Law in Opposition to Robert Friedland' Motion for Partial Summary Judgment Regarding Plaintiff' CERCLA s s Liability, filed 11/29/06, Docket # 178]. Yet he persists.

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And the extent to which he dominated the corporations that developed and operated the Mine, and the extent to which he gained financially from these corporations, sheds relevant illumination on the issues. The credibility of Friedland' protestations of ignorance s will be informed by the Court' understanding of just how deeply his own interests infused s these companies, by just how extensively he drove their existence. Defendants are entitled to every inference that could be drawn from the extent of Friedland' domination and use of the corporate structures. This is true when assessing his s straightforward operator liability under Bestfoods, entirely separate from any evaluation about the corporate veil. Finally, Friedland cannot establish any " good cause"for excusing his late expert disclosure on this issue, as would be required under Rule 16(b), and certainly cannot establish the " exceptional cause"referenced in the Modified Scheduling Order. Even good cause requires a showing that " party seeking the extension was diligent in its discovery the efforts yet could not complete discovery by the court-ordered deadline."Marcin Eng'g, LLC v. Founders at Grizzly Ranch, LLC, 219 F.R.D. 516, 521 (D. Colo. 2003) (emphasis added). Friedland' own operator liability has been an issue in this case all along, if he s intended to raise it. Friedland' prima facie burden, of course, is to establish that he paid s more than his fair share of the response costs at Summitville. Sun Co., Inc. (R&M) v. Browning-Ferris, Inc., 124 F.3d 1187, 1193 (10th Cir. 1997); United States v. Colo., 50 F.3d at 1536. If he intended to do this by saying that his share is zero, since he has no liability, then he should have disclosed the experts and evidence that would support this claim.

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III.

Sanctions are appropriate to remedy the prejudice caused by Friedland' s improper designation of rebuttal expert witnesses. Given that Friedland' designation of rebuttal witnesses was not authorized by the s

Modified Scheduling Order, the designation should be stricken and Defendants'should be awarded the expenses incurred as a result of Friedland' improper designations. Since s Friedland' filing of the witness disclosures came over three months after the Modified s Scheduling Order' deadline for Friedland' expert reports, the Court should look to Federal s s Rule of Civil Procedure 16(f) to determine appropriate sanctions. See Akeva L.L.C., 212 F.R.D. at 309. Federal Rule of Civil Procedure 16(f) states " a party or party' attorney [i]f s fails to obey a scheduling or pretrial order... the judge, upon motion or the judge' own s initiative, may make such orders with regard thereto as are just, and among others any of the orders provided in Rule 37(b)(2)(B), (C), or (D)." Fed. R. Civ. P. 16(f). a. Friedland' improper designation of rebuttal expert witnesses should be s stricken.

Federal Rule of Civil Procedure 37(b)(2)(C) allows the Court to issue an order " striking out pleadings or parts thereof." Fed. R. Civ. P. 37(b)(2)(C). Moreover, exclusionary sanctions under Rule 16(f) are especially appropriate where, as here, " party the has typically engaged in a pattern of disobedience or noncompliance with court orders." 6A Charles A. Wright & Arthur A. Miller, Federal Practice and Procedure § 1531 (2d ed. 1990). Friedland' violation of the Scheduling Order' expert disclosure requirements harm s s Defendants in a number of ways. First, an additional round of expert discovery will add considerably to Defendants'expenses in this case, as Defendants'will need to prepare for

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and depose additional experts. The delay and additional costs would be faced by Defendants because of Friedland' lack of diligence to designate these experts at the appropriate time. s In addition, Defendants prepared for expert discovery on damages and allocation issues with the expectation that each side would have one deadline to present expert reports. Allowing Friedland to have an additional round of expert discovery violates the expectations of the parties in preparing for trial. At some point discovery and expert endorsements must end. b. Directing Friedland to pay Defendants'reasonable costs in responding to his illicit designation of rebuttal witnesses is appropriate.

Friedland' failure to designate experts according to the Modified Scheduling Order is s also grounds for ordering Friedland to pay Defendants'expenses in preparing this motion. If the Court chooses to accept Friedland' rebuttal expert designations, then Plaintiff should s also pay Defendants'expenses in deposing these rebuttal expert witnesses. Rule 16(f) of the Federal Rules of Civil Procedure states that, in addition or in lieu of other sanctions, the Court is to order a party or party' attorney who fails to obey a s scheduling order to " the reasonable expenses incurred because of any noncompliance pay with this rule, including attorney' fees, unless the judge finds that the noncompliance was s substantially justified or that other circumstances make an award of expenses unjust."Fed. R. Civ. P. 16(f). A purpose of this rule is to " compensate opposing parties for inconvenience and expense incurred because of any noncompliance with the reasonable management orders of the court."Matter of Sanction of Baker, 744 F.2d 1438, 1441 (10th Cir. 1984). Even absent a finding of bad faith, Defendants are entitled to the fees and expenses resulting from Friedland' noncompliance with the Modified Scheduling Order. See Turnbull v. Wilcken, s

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893 F.2d 256, 259 (10th Cir. 1990). In Akeva L.L.C., the Court ruled that Plaintiff' submission of additional expert s reports, in violation of the discovery order, constituted sanctionable behavior under Rule 16(f). The Court found that Defendants " were forced by plaintiff' non-compliance to file s two motions to exclude the expert reports... In order to protect defendants against prejudice, the Court will require plaintiff to pay the costs and expense of the Field' deposition, s including the expert fees, if any, of Dr. Fields, and the attorney' fees incurred by defendants s in connection with these motions[.]" Akeva L.L.C. v. Mizuno Corp., 212 F.R.D. at 312. Likewise, this Court should order Friedland to reimburse the Defendants for expenses incurred due to his failure to abide by the Modified Scheduling Order. CONCLUSION Accordingly, for all the reasons set forth above, Defendants'Joint Motion to Strike Plaintiff' Designation of Rebuttal Expert Witnesses and to Preclude Designation of Further s Experts should be granted. Respectfully submitted on this 5th day of February, 2007.

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s/ Colin C. Deihl____________________ Colin C. Deihl, Esq. Faegre & Benson LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, CO 80203 Telephone: (303) 607-3651 FAX: (303) 607-3600 Delmar R. Ehrich, Esq. Faegre & Benson LLP 2200 Wells Fargo Center 90 South Seventh Street Minneapolis, Minnesota 55402 Attorneys for Defendant The Industrial Company

s/ Terence M. Ridley Terrence M. Ridley, Esq. Marian L. Carlson, Esq. Wheeler Trigg Kennedy, LLP 1801 California Street, Suite 3600 Denver, CO 80202-2617 Attorneys for Defendant Geosyntec Consultants, Inc.
fb.us.1800342.01

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