Free Motion in Limine - District Court of Colorado - Colorado

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 1 of 15

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Honorable Marcia S. Krieger Civil Action No. 04-cv-00020-MSK-BNB DANA MARTINEZ, individually and on behalf of the minor children as next of kin and parent, JACOB MARTINEZ, a minor, ADAM MARTINEZ, a minor, MICHAEL MARTINEZ, a minor, SAMUEL MARTINEZ, a minor, ISAIAH MARTINEZ, a minor, PATRICE GOMEZ, a minor, GABRIELLE GOMEZ, a minor, ROMAN GOMEZ, a minor, Plaintiffs, v. THE LOCHBUIE POLICE DEPARTMENT, LOCHBUIE POLICE CHIEF JOE SISKAR, in his official and individual capacity, LOCHBUIE POLICE OFFICER MATT CLARK, in his official and individual capacity, LOCHBUIE POLICE OFFICER CONRAD VANEGAS, in his official and individual capacity, LOCHBUIE POLICE OFFICER TOM BACKER, in his official and individual capacity, Defendants.

DEFENDANTS' MOTIONS IN LIMINE

Defendants, THE LOCHBUIE POLICE DEPARTMENT, JOE SISKAR, MATT CLARK, CONRAD VANEGAS, and TOM BACKER, by their attorneys, ERIC M. ZIPORIN and GILLIAN M. FAHLSING, of the law firm SENTER GOLDFARB & RICE, L.L.C., hereby submit the following motions in limine to preclude or limit certain testimony and/or evidence at trial as follows:

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 2 of 15

I.

CERTIFICATE OF CONFERRAL

Pursuant to D.C.COLO.LCivR 7.1(A), the Court's April 30, 2004 Trial Preparation Order ­ Jury Trial (Civil), and MSK Civ. Practice Standard V.F.1, undersigned counsel conferred with counsel for Plaintiffs, Mr. John McKendree, prior to the filing of this motion. Counsel for Plaintiffs indicates that his clients object to the relief requested herein. II. INTRODUCTION

The following combined Motions in Limine request the exclusion of trial evidence and testimony with regard to the remaining claims for relief asserted against Defendants. Specifically, Defendants seek the preclusion of testimony and evidence concerning the following: (1) personnel matters and other changes taking place concerning the Lochbuie Police Department which predate the events giving rise to this litigation; (2) unrelated contacts between Defendants and Plaintiffs and/or their family members on September 23, 2001, September 28, 2001, September 30, 2001, on or about November 18, 2001, in December of 2001, and on October 18, 2002; (3) evidence of the children's alleged damages, such as loss of reputation; and (4) the dismissal of the criminal charges against Plaintiff Dana Martinez. III. FACTUAL BACKGROUND

This case arises from the following contacts amongst Plaintiffs and Joe Siskar, Matt Clark, Conrad Vanegas, Tom Backer, Marc Robinson, and Danny Sanodval, each of whom is a current or former police officer with the Lochbuie Police Department: 1

Plaintiffs have voluntarily dismissed Marc Robinson and Danny Sandoval from this lawsuit pursuant to Fed.R.Civ.P. 41. [See, May 4, 2005 Order of Dismissal of Plaintiff Esperanza Gomez and Defendants Robinson and Sandoval With Prejudice.]

1

2

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 3 of 15

1.

On September 23, 2001, Backer and Siskar entered Plaintiffs' residence with law

enforcement personnel from other jurisdictions in pursuit of a dangerous fleeing felon, Plaintiff Dana Martinez's brother, Daniel Pino. That evening, Mr. Pino broke into and vandalized the Lochbuie Police Department. 2. On September 28, 2001, Backer and Vanegas arrested and took Plaintiff Dana

Martinez's brother, Eusebio "Chevo" Luiz, into custody when they observed him yelling outside the Lochbuie Police Department with a bottle of beer in his hand. Mr. Luiz was under 21 years of age at that time. Earlier in the day, Sandoval observed Chevo make obscene gestures to him and yell profanities at him outside the Lochbuie Police Department. 3. On September 30, 2001, after observing a traffic code violation, Vanegas pulled

over a vehicle driven by Claudia Miller, Plaintiff Dana Martinez's sister-in-law, and occupied by Charles Miller. Dispatch advised Vanegas there was a restraining order in effect between the Millers and, therefore, he arrested Mr. Miller, which Vanegas was statutorily mandated to do. 4. On or about November 18, 2001, Clark made contact with Plaintiff Dana

Martinez's common-law husband, Paul "Pablo" Gomez. Clark suspected Mr. Gomez was selling drugs, and proceeded to Plaintiffs' residence to write down the license plate numbers of the vehicles parked in the driveway of the residence. 5. Plaintiffs claim that in or around December of 2001, Clark called the Weld

County Sheriff's Office and the Brighton Police Department to Plaintiffs' home in retaliation for their following up with the Lochbuie Police Department concerning Clark's contact with Paul Gomez on or about November 18, 2001. Plaintiffs allege that law enforcement personnel from

3

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 4 of 15

these other jurisdictions conducted an illegal search of Plaintiffs' residence in an attempt to locate Daniel Pino. 6. On January 22, 2002, Clark, Backer, Sandoval, and Robinson executed a search

warrant at Plaintiffs' residence and found illegal drugs, drug paraphernalia, and weapons. This took place after a series of undercover drug buys at Plaintiffs' residence. During the search, Plaintiff Dana Martinez and Paul Gomez arrived at the residence in a van occupied by seven of the minor Plaintiffs. The officers smelled burned marijuana in the van and arrested Paul Gomez pursuant to a previously obtained arrest warrant. Plaintiff Dana Martinez was also arrested for seven counts of child abuse without injury for failure to stop Paul Gomez from smoking marijuana while driving the van occupied by their children. Additionally, upon execution of the search of Plaintiffs' residence, the officers observed filthy living conditions, bringing into question the health and safety of the children. 7. On October 18, 2002, Backer, Siskar, and Sandoval made contact with some of

the Plaintiffs and Eusebio Luiz at Plaintiffs' residence in conjunction with a welfare check performed by the Weld County Department of Social Services. IV. PLAINTIFF'S CLAIMS FOR RELIEF

In their Complaint, Plaintiffs assert the following claims against all of the Defendants: (1) First Claim for Relief ­ Violation of the Fourth Amendment to the United States Constitution; (2) Second Claim for Relief ­ False Arrest, Malicious Prosecution, and Abuse of Process in violation of 42 U.S.C. § 1983; and (3) Third Claim for Relief ­ Outrageous Conduct in Violation of the Eighth Amendment. Plaintiffs made the following concessions in Plaintiffs' Response to Defendants' Motion

4

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 5 of 15

for Summary Judgment (hereinafter "Response") and Plaintiffs' Brief in Support of Their Response to Defendants' Motion for Summary Judgment (hereinafter "Response Brief"), which are still pending before the Court: · There are no claims concerning contacts amongst Plaintiffs and Defendants that occurred on or before January 7, 2002. [See, Response at pp. 2-3; Response Brief at p. 4.] · There are no viable claims against Defendant Vanegas. [See, Response at pp. 3-4; Response Brief at p. 4.] · There was not an illegal search of Plaintiffs' residence on January 22, 2002. [See, Response at pp. 5-6.] · There were no claims pled for contacts on October 18, 2002. [See, Response at p. 9; Response Brief at p. 8.] · Plaintiffs do not have any viable Eighth Amendment claims. [See, Response at p. 11; Response Brief at p. 8.] · The Lochbuie Police Department is not a proper party amenable to being sued. [See, Response at pp. 11-12; Response Brief at p. 9.] · No claims have been asserted against the Town of Lochbuie. [See, Response at p. 12; Response Brief at p. 9.] Based on the foregoing, the only claims remaining for trial are for false arrest, malicious prosecution, abuse of process, and supervisory liability claims against Siskar, Clark, Vanegas, and Backer stemming from the contact with Plaintiffs on January 22, 2002.

5

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 6 of 15

V. A.

ARGUMENT

MOTION IN LIMINE TO EXCLUDE ANY EVIDENCE OR TESTIMONY PERTAINING TO PERSONNEL MATTERS AND OTHER CHANGES TAKING PLACE CONCERNING THE LOCHBUIE POLICE DEPARTMENT WHICH PREDATE THE EVENTS GIVING RISE TO THIS LITIGATION. During the depositions of Defendants, Plaintiffs sought some information concerning

personnel changes and other matters associated with the Lochbuie Police Department, specifically with respect to Defendants Clark and Backer. However, said inquiries predated the events giving rise to this litigation, are irrelevant, and thus are inadmissible. Further, the probative value of such testimony would be outweighed by its prejudicial nature as the fact finder might assume that there was wrongdoing on the part if Defendants and, accordingly, such testimony should be precluded at trial. Pursuant to Rule 404(b) of the Federal Rules of Evidence, "[e]vidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show action and conformity therewith." Fed.R.Evid. 404(b). However, such evidence may be admissible to establish "proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident . . .." Id. Evidence of other crimes, wrongs, or acts may be properly admitted under Rule 404(b) if the following four requirements are met: (1) the evidence was offered for a proper purpose under Fed.R.Evid. 404(b); (2) the evidence was relevant under Fed.R.Evid. 401; (3) the probative value of the evidence was not substantially outweighed by its potential for unfair prejudice under Fed.R.Evid. 403; and (4) the District Court, upon request, instructed the jury pursuant to Fed.R.Evid. 105 to consider the evidence only for the purpose for which it was admitted. See, United States v. Becker, 230 F.3d 1224, 1232 (10th Cir. 2000) (referring to Huddleston v. United States, 485 U.S. 681, 691-92, 108 S. Ct. 1496, 99 L. Ed. 2d

6

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 7 of 15

771 (1988)). analysis.

Such requirements have been referred to by the courts as the "Huddleston"

For the reasons set forth below, any evidence or testimony regarding personnel

changes or other matters taking place within the Lochbuie Police Department should be deemed inadmissible since Plaintiffs cannot meet their burden of satisfying the requirements of the Huddleston analysis. If, for some reason, Plaintiffs satisfy the first three elements of the

Huddleston analysis, a limiting instruction regarding the evidence or testimony is required. Evidence or testimony regarding personnel changes or other matters taking place within the Lochbuie Police Department will not be offered for a proper purpose under Rule 404(b). Rule 404(b) of the Federal Rules of Evidence permits evidence of other "acts" to establish "proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident . . ." Fed.R.Evid. 404(b). Defendants cannot contemplate how evidence or testimony regarding these personnel matters could be relied upon by Plaintiffs to establish motive, intent, preparation, plan, knowledge, identity, or absence of mistake or accident with regard to Defendants contacts with Plaintiffs. Instead, to the extent that Plaintiffs intend to offer evidence or testimony related to these personnel matters, it would be for the specific purpose of proving the character of Defendants in order to show action and conformity with the alleged acts of Defendants when they contacted Plaintiffs. Put simply, Plaintiffs may be attempting to rely upon evidence of other personnel matters to establish that the character of Defendants resulted in the alleged violations of Plaintiffs' constitutional rights. Such is in clear contravention of Rule 404(b) and, as a result, any evidence or testimony relating to these personnel matters should not be allowed for this purpose.

7

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 8 of 15

Evidence or testimony related to the personnel matters is also irrelevant under Rule 401. Relevant evidence is "evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence." Fed.R.Evid. 401; see also, United States v. Espinoza, 244 F.3d 1234, 1239, n.4 (10th Cir. 2001). Moreover, Rule 402 bars the introduction of any evidence that is not relevant. See, Fed.R.Evid. 402; see also, Koch v. Koch Indus., 203 F.3d 1202, 1227 (10th Cir. 2000). Evidence or testimony pertaining to these personnel matters does not survive this test. Plaintiffs' only remaining claims against Defendants are for false arrest, malicious prosecution, abuse of process, and supervisory liability claims stemming from the contact with Plaintiffs on January 22, 2002. It is believed that Plaintiffs may be attempting to use evidence or testimony regarding personnel matters to establish that Defendants had a propensity to violate a person's constitutional rights, and thus acted in conformity with this behavior during the applicable time frame. Such purpose is not permissible and is in clear violation of Rule 404(b). More

importantly, evidence or testimony related to these personnel matters does not make it more probable than not that Defendants violated Plaintiffs' constitutional rights. As a result, such testimony not only violates Rule 404(b), but also is irrelevant for purposes of Rule 401. In addition, the probative value of evidence or testimony related to personnel matters is substantially outweighed by unfair prejudice. As stated above, any evidence or testimony

regarding these matters is irrelevant for purposes of Rule 401. It therefore cannot be argued that such testimony has any probative value, let alone some probative value which would outweigh its significant prejudicial effect to Defendants. The Tenth Circuit has held that "[e]vidence is unfairly prejudicial if it `makes a [verdict] more likely because it provokes an emotional

8

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 9 of 15

response in the jury or otherwise tends to affect adversely the jury's attitude towards the Defendant wholly apart from his judgment as to his guilt or innocence of the crime charged.'" United States v. Roberts, 88 F.3d 872, 880 (10th Cir. 1996) (citing United States v. Yazzie, 59 F.3d 807, 811 (9th Cir. 1995)). Without any probative value to this evidence or testimony related to personnel matters, the admission of same would only serve to promote an emotional response from a jury or adversely affect the juror's attitude toward Defendants. Such evidence would not only likely result in the jury forming improper impressions with regard to Defendants' actions when contacting citizens, but, even more prejudicial, that such prior behavior made it more likely that Defendants acted inappropriately in contacting Plaintiffs. Plaintiffs will therefore be unable to establish that the probative value of the proposed evidence or testimony regarding these personnel matters significantly outweighs its unfair prejudice to Defendants. As such, this evidence fails the third requirement of the Huddleston analysis. Should the Court determine that the testimony or evidence pertaining to these personnel matters, a limiting jury instruction is necessary. Any evidence or testimony regarding personnel matters does not meet the requirements of Rule 404(b) under the Huddleston analysis. However, if the Court disagrees, Defendants respectfully request that the Court provide the jury with a limiting instruction that explains against whom the evidence is admitted and for what specific purpose such evidence or testimony may be relied upon. Such instruction must be given if requested. See, United States v. Wilson, 107 F.3d 774, 782 (10th Cir. 1997).

9

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 10 of 15

B.

MOTION IN LIMINE TO EXCLUDE ANY EVIDENCE OR TESTIMONY REGARDING BOTH PRIOR AND SUBSEQUENT UNRELATED CONTACTS WITH PLAINTIFFS AND/OR THEIR FAMILY MEMBERS.

Upon conferring with opposing counsel, Defendants have learned that at this point in time, Plaintiffs intend to offer (or have yet to decide if they intend to offer) evidence and testimony regarding contacts Defendants had with Plaintiffs and/or their family members both prior to and subsequent to January 22, 2002. For the reasons stated below, such evidence is irrelevant for purposes of Rule 401 and should be excluded from trial. As set forth in section III of this motion, Plaintiffs allege unconstitutional conduct on the part of Defendants on dates other than January 22, 2002. Specifically, Plaintiffs allege

unconstitutional conduct against them or members of their family on September 23, 2001, September 28, 2001, September 30, 2001, on or about November 18, 2001, in December of 2001, and on October 18, 2002. [See, section III of this Motion at ¶¶ 1, 2, 3, 4, 5, and 7]. Within Plaintiffs' Response and Response Brief to Defendants' Motion for Summary Judgment, Plaintiffs concede that none of their § 1983 claims concern contacts with Defendants that occurred prior to January 7, 2002. In addition, Plaintiffs concede that they did not plead any of their § 1983 claims based upon any alleged constitutional violations for the contact on October 18, 2002. For these reasons alone, any evidence and/or testimony concerning Defendants' contacts with Plaintiffs on these other dates are irrelevant under Rule 401 and should be excluded from trial. Even absent these confessions by Plaintiffs, any evidence regarding these contacts should be excluded pursuant to Rules 401, 402, and 403. The September 23, 2001 contact related to Defendants' investigation of Mr. Pino, not any of the Plaintiffs. Similarly, the contacts on

10

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 11 of 15

September 28 and 30, 2001 pertained to investigations of Plaintiff Dana Martinez's brother and her sister-in-law, respectively. The contact on or about November 18, 2001 was between Clark and Plaintiff Dana Martinez's husband. The contact in December of 2001 was again related to the investigation of Mr. Pino. None of these contacts provide evidence which would be relevant under Rule 401 and would thus be inadmissible under Rule 402. Plaintiffs' claims for relief pursuant to § 1983 are for false arrest, malicious prosecution, and abuse of process stemming only from their contact with Defendants on January 22, 2002. None of these prior contacts (investigations of Plaintiffs' family members) make it more probable than not that Defendants violated Plaintiffs' civil rights on January 22, 2002.2 Even assuming some relevancy to these contacts, any evidence in this regard should be excluded under Rule 403 as its limited evidentiary value is substantially outweighed by its danger of unfair prejudice, confusion of the issues, as well as its likelihood to mislead the jury. As for the contact on October 18, 2002 between Backer, Siskar, and Sandoval, such occurred roughly ten months after the incident (January 22, 2002) for which Plaintiffs base the entirety of their § 1983 claims. Accordingly, this contact has absolutely no value under Rule 401 and any evidence related to this contact should be excluded pursuant to Rule 402. C. MOTION IN LIMINE TO EXCLUDE ANY REFERENCE TO THE CHILDREN'S ALLEGED DAMAGES.

The only claims remaining for trial are for false arrest, malicious prosecution, abuse of process, and supervisory liability claims stemming from the contact with Plaintiffs on January
2

It should again be noted that Plaintiffs concede that the Lochbuie Police Department is not a proper party to this lawsuit and, in addition, that no claims for relief have been alleged against the Town of Lochbuie. Plaintiffs also have not asserted any conspiracy claims under either § 1983 or 42 U.S.C. § 1985. Accordingly, these prior contacts (Footnote continued.)

11

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 12 of 15

22, 2002. However, it is not disputed that none of the minor Plaintiffs were arrested or charged for the events taking place on January 22, 2002. Nevertheless, the minor Plaintiffs are making significant claims for non-economic damages. Specifically, the minor Plaintiffs seek damages for humiliation, loss of self esteem, pain and suffering, emotional distress, loss of enjoyment of life, and damages to reputation. The eight minor Plaintiffs in total seek almost $ 8.2 million in damages. This is ludicrous, especially based on the ages of the minor Plaintiffs at the time of the search. For example, one of the minor Plaintiffs was only about six months old at the time of the search. Any such reference to these exorbitant sums of money would only serve to prejudice the fact finder. This evidence is irrelevant and thus inadmissible. Further, its probative value, assuming it has any probative value, would be substantially outweighed by its prejudice. Thus, any such evidence should be excluded by the Court. D. MOTION IN LIMINE TO EXCLUDE ANY EVIDENCE OR TESTIMONY PERTAINING TO THE DISPOSITION OF PLAINTIFF DANA MARTINEZ'S CRIMINAL CHARGES.

It appears that Plaintiff Dana Martinez intends to admit evidence pertaining to the outcome of the various criminal charges brought against her. Specifically, as a result of the events giving rise to this litigation, she was arrested and charged with seven count of child abuse without injury. The charges were subsequently dropped against Plaintiff Martinez. Such

evidence is not relevant under Rule 401 of the Federal Rules of Evidence. Rule 401 states that evidence is relevant if it has "any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable
(Footnote continued.) simply have no relevance to the § 1983 claims against the individual Defendants stemming from their one contact with Plaintiffs on January 22, 2002.

12

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 13 of 15

than it would be without the evidence." Fed.R.Evid. 401. The mere fact that the charges against Plaintiff Martinez were dropped does not make it more probable that the individual Defendants violated her constitutional rights. Such evidence is not relevant under Rule 401 as to any of Plaintiff's claims, and therefore, under Rule 402 of the Federal Rules of Evidence, it is not admissible. The mere fact that Plaintiff Martinez was not convicted of the criminal charges brought against her does not, in and of itself, establish a lack of probable cause. See, Erickson v. Pawnee City Board of County Commr's., 263 F.3d 1151, 1154 (10th Cir. 2001); Evans v. Dugger, 48 F.3d 1231 (Table), *1 (10th Cir. 1995); Parkerson v. Carrouth, 782 F.2d 1449, 1452 (8th Cir. 1986). Moreover, as held by the United States Supreme Court, "the difference in the burden of proof in criminal and civil cases precludes application of the doctrine of collateral estoppel." One Lot Emerald Cut Stones & One Ring v. United States, 409 U.S. 232, 235 (1972). The rationale being that "[t]he acquittal of the criminal charges may have only represented `an adjudication that the proof was not sufficient to overcome all reasonable doubt of the guilt of the accused'" (citing Helvering v. Mitchell, 303 U.S. 391, 397 (1938)), and "does not constitute an adjudication on the preponderance-of-the-evidence burden applicable in civil proceedings." One Lot Emerald Cut Stones & One Ring, 409 U.S. at 232 (referring to Murphy v. United States, 272 U.S. 630 (1926); Stone v. United States, 167 U.S. 178 (1897)). Even if the Court determines that evidence or testimony pertaining to the disposition of Plaintiff Martinez's criminal case is relevant, it must be excluded pursuant to Rule 403 of the Federal Rules of Evidence as its probative value is substantially outweighed by the danger of unfair prejudice and confusion of the issues. See, Fed.R.Evid. 403; Roberts, 88 F.3d at 880.

13

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 14 of 15

"The district court has `broad discretion to determine whether prejudice inherent in otherwise relevant evidence outweighs its probative value.'" United States v. Magleby, 241 F.3d 1306, 1315 (10th Cir. 2001) (citing United States v. Youts, 229 F.3d 1312, 1319 (10th Cir. 2000)). Here, the probative value of the dismissal of the charges, if any, is substantially outweighed by the danger of unfair prejudice and confusion of the issues for the jury. Should such evidence be presented to the jury in this case, they might be unfairly persuaded by the district attorney's decision to dismiss the charges. Accordingly, all evidence and/or testimony pertaining to the dismissed charges should be excluded under Rule 403. VI. CONCLUSION

For the reasons stated herein, Defendants respectfully request that the Court enter an order, in limine, precluding the presentation of any evidence or testimony relating to personnel matters in the Lochbuie Police Department predating the events giving rise to this litigation, the minor Plaintiffs' alleged non-economic damages, and the dismissal of the charges brought against Plaintiff Dana Martinez. Respectfully submitted,

s/ Eric M. Ziporin Eric M. Ziporin Senter Goldfarb & Rice, L.L.C. 1700 Broadway, Suite 1700 Denver, CO 80290 Telephone: (303) 320-0509 FAX: (303) 320-0210 E-mail:[email protected] Attorney for Defendants

14

Case 1:04-cv-00020-MSK-BNB

Document 119

Filed 01/10/2006

Page 15 of 15

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 10th day of January, 2006, I electronically filed under seal a true and correct copy of the above and foregoing DEFENDANTS' MOTIONS IN LIMINE with the Clerk of Court using the CM/ECF system, which will send notification of such filing to the following email address: John W. McKendree, Esq. [email protected]

s/ Barbara A. Ortell

15
00208392