ML20083P464
| ML20083P464 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/17/1984 |
| From: | Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| TASK-IR, TASK-SE OL, NUDOCS 8404200017 | |
| Download: ML20083P464 (19) | |
Text
-
- 9, LILCO, April 17, 1984 00CMETED i
USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.s Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL
)
(Shoreham Nuclear Power
)
Station, Unit 1)
)
LILCO'S RESPONSE TO JOINT OBJECTIONS OF SUFFOLK COUNTY AND THE STATE OF NEW YORK TO BOARD'S ORAL ORDER OF FEBRUARY 22, 1984, AND REQUEST FOR REVISION THEREOF On February 22, 1984, this Board orally ruled on numerous matters at a prehearing conference.
Among other matters, this Board excluded Suffolk County's proposed Contention IV and es -
tablished a schedule for discovery and subsequent filings lead-ing to hearings concerning the TDI diesel generators.
Neither the County nor the State of New York voiced any objection to the schedule set or any of the Board's rulings until April 10, 1984 when both filed Joint Objections of Suffolk County and the State of New York to Board's Oral Order of. February 22, 1984, and Request for. Revision Thereof.
The objections come too late practically, if not techni-cally.
No new reasons are a'dvanced'in support of the County's proposed Contention IV.
The County merely seeks rehearing of.a.
8404200017 840417 PDR ADOCK 0500032'2 9
matter already argued extensively, yet offers no compelling reason to revisit the issue.
With respect to discovery, it is nearly at an end.
Any request for reconsideration of this Board's rejection of Contention IV should have come within a reasonable time after the Board's February 22 ruling in order to avoid delay of an already protracted licensing proceeding.
Additionally, the County's alleged problems with the discovery schedule are largely self-inflicted in view of its failure ac-curately to apprise the Board of its anticipated discovery be-fore the schedule was set and to maximize those numerous dis-covery opportunities available to it.
Accordingly, as requested by the Board, LILCO hereby re-I sponds in opposition to the Joint Objections.
I.
Contention IV Was Properly Excluded This Board, in properly rejecting Suffolk County's Con-tention IV on quality assurance, stated that:
We are not admitting Contention 4.
as a result of applying the reopening criteria to Contention 4.
We find that given the litigation of the adequacy of the design, manufacture and performance of parts of the diesels, be they components or subsystems, which would take place under Contentions 1, j
2, and 3, that litigation would include the quality aspects of those items.
And given that Contention 4 is not likely to change the result that we would otherwise reach under those contentions. 4
4 Tr. at 21,613-14.
The County offers no new arguments that would justify reversing this ruling.
Significantly, the Board'c ruling permits litigation of specific quality assurance aspects-of those items which will be subjected to scrutiny.
This is entirely appropriate since quality assurance is intended to ensure the integrity of the design and manufacture of equipment.
Thus, if the County has a factual basis, rooted in quality assurance concerns, for challenging the integrity of.a specific component, it can do so.
What the Board has not permitted is a sterile " fishing ex--
pedition" conducted under the rubric of a broad quality assur-ance contention.
Moreover, to the extent the County's proposed Contention IV was supported by specific quality assurance problems, exclu-sion of the contention was justified because of its inherent duplication.
Indeed, the County's argument that it cannot' identify quality assurance problems on.a component-specific basis underscores the fact that litigation of_a broad quality assurance contention would deal only in generalities.
In sum, any realistic concerns.the County may have with
- regard to quality assurance for components: legitimately in
' doubt will be fully and adequately covered by'the litigation surrounding Contentions I, II and III.
No valid rationale c
6 exists for anending the Board's February 22 exclusion of Con-tention IV.
II.
The Schedule for Discovery and Hearings Should Not be Changed The County's description of discovery to date is mislead-ing in several respects.
An objective appraisal of the par-ties' efforts in discovery indicates-that no, or at most a min-imal, extension of the present discovery schedule is warranted.1/
4 A.
The County Failed to Provide the Board with an Accurate Assessment of Its Discovery Demands The Board's oral order scheduling discovery and hearings was apparently premised in part on the proposals for discovery submitted by the parties on February 17, 1984 in advance of the prehearing conference.
At that time,-the County 2/ indicated 1/
The Board should be aware that DG 103 experienced growth of a previously identified crack in its block during its two hour overload test on April 14, 1984.
As previously antici-pated, the adequacy of the block will be addressed by the DRQR program.
The parties were already aware of the existence of cracks in the block and, presumably, the County's consultants are in the process'of reaching their own conclusions.
Accord-ingly, this development should not necessitate further.protrac-tion of_the discovery schedule.
2/
The State of New York has propounded no discovery requests and has identified no consultants in its employ.
Therefore, it (footnote continued),
J
..m..
- m.
.m..
its intention to depose twelve specifically named witnesses and, possibly, some others described by generic category.
At the prehearing conference on February 22, 1984, the County did not indicate any expanded discovery proposal.
Yet, on March 1, 1984, the County notified LILCO that it desired to depose 25 specifically-named persons, one unnamed official of Elliott Turbochargers and possibly additional depositions of undetermined witnesses.
Between the County's February 17 filing and its March 1 letter, no discovery or other developments took place that would justify more than doubling the number of' deponents.
In-deed, there is no reasonable explanation for the County's ear-lier inability accurately to apprise the Board and LILCO of its discovery plans.
Accordingly, the County should be estopped now from complaining that the number of days allotted for dis-1
. covery is insufficient to complete the ever-expanding number of depositions.3/
(footnote continued) has no standing to complain of the impending discovery cutoff.
Nevertheless, all references in this response to "the County" apply equally to and include the State.
3/
Since the County continues to profess its inability to assess the issues, reach conclusions and provide witnesses, it is unclear whether the County's discovery plans are settled even now.
Therefore, LILCO will not address here its objec-(footnote continued).
m
1 B.
Substantial Numbers of Documents i
Have Been Produced to the County 1
On February 29, 1984, the County served LILCO with a broad 43-page document request.
In response, LILCO personnel and counsel have spent hundreds of hours in locating and re-viewing files.
As a result of this time-consuming review, LILCO has produced thousands of pages of documents to the Coun-ty.
LILCO began its production,on March 16, 1984 and produced additional documents on March 17, 20, 29 - and 30 and April 1, 4,
11 and 12.
These documents should have given the County much i
of the information it needed to' proceed with developing its i
case.4/
i (footnote continued) j tions to the burdensomeness and excessive breadth of the Coun-ty's present deposition' plans.
4/
For example, Stone & Webster job books have already been turned over to the County almost in their entirety.
These job i
books compile chronologically most documentation relating to purchases, installation and preoperational testing of the die-sel generators.
Thus, to a large extent these documents are responsive to a large percentage of the requests filed by the County.
In addition, the County has had access to many of the documents it seeks here in proceedings before the New York Pub-lic Service Commission, proceedings in which the County is a party.
- 4 h.
e V
. m m
l t to the Joint Objections of the County and State incorrectly claims that there are numerous requests for j
which the County has received no documents.
In fact, the Coun-ty has received documents in response to most of the requests.
(See Attachment 1, letter from LILCO's. counsel dated April 11, 1984 to Douglas J. Scheidt).
Documents responsive to the few i
l outstanding requests generally consist of incomplete owners group reports, DRQR matters, test reports and the like which have not been finalized.
LILCO also believes that it will have produced all documents responsive to requests not objected to within the next two weeks.
Additionally, on March 30, 1984, the County served LILCO with a supplemental document request seeking in large part nu-i merous treatises, engineering journals and publications, as well as documents duplicative of the original document request.
Most of the treatises, journals and publications are equally available to the County's consultants as to LILCO's.
i
]
Thousands of documents have also been produced to the County by TDI at LILCO's request.
Yet, the County complains i
that it was not able to loo;c at 'TDI documents until March 22 and that it has-not yet received copies of those documents from TDI.
As a result, the County contends its consultants are not able to make the necessary analyses to reach final conclusions i
I, I
to enable counsel for the County to take depositions.
The County's argument in this respect is again misleading.
Repre-sentatives of the County arrived at TDI's Oakland facility to review documents on March 22 and remained there until late on March 23.
LILCO is advised that TDI offered to allow the rep-resentatives of the County to continue to review documents for as many days as the County's representatives thought necessary.
The County's representatives, which included at least two Coun-ty consultants, declined this opportunity.
Accordingly, the l
l County should not now be heard to complain and seek further delay in these proceedings on the basis of any asserted delay in receiving copies of documents.
They had ample opportunity to review and study at TDI's facilities in March.
Moreover, the County inaccurately states that it has re-ceived no documents from TDI.
LILCO is advised by TDI's coun-sel that TDI had offered to copy documents designated by the County on an expedited basis.
Thus, on March 23, when the County's representatives departed TDI's Oakland facilities, they took with them 162 documents, including many drawings, approximating 250 pages.
Not only did the County's representa-tives receive certain documents they apparently deemed suffi-ciently critical to be copied immediately, they had the oppor-tunity to examine, analyze and review any of the documents or -
drawings they so desired.
Presumably, other critical documents could have been copied immediately had the County so requested.
It is also important for the Board to know that, subsequent to the County's filing of its objections, TDI sent the County all other documents that had been requested.
In addition to ample opportunity to review documents, the County could have conducted a substantial number of deposi-tions.
LILCO identified the majority of its intended witnesses on March 2 and urged the County to concentrate its discovery efforts on these individuals.
On March 22, LILCO responded to the County's expanded deposition notice.
Although LILCO ob-jected to the number of depositions proposed, LILCO provided information on witness availability and suggested that the County propose a deposition schedule.
Despite this offer to begin depositions, the County has not yet scheduled the first one.
In view of the bulk of documents produced for the Coun-ty's review and the numerous witnesses offered by LILCO for I
deposition, it simply is incredible for the County to claim that it could not have engaged the issues and conducted deposi-I tions by the close of the April 20 discovery cutoff.
9
4 i
i i
C.
Other Proceedings Constitute No Reason for Delay The County urges the Board to consider the hearings pend-ing before another' licensing board on LILCO's Supplemental Mo-tion for Low Power License as an additional reason for delay.
Motion for Low Power License pending before another licensing board.
LILCO seeks no extension on.that basis and opposes any delay in this proceeding.
The County's alleged inability to deal with both proceedings simultaneously is not an appropriate reason for delaying these proceedings.5/
Indeed, an interve-i nor's staffing problems are not generally considered an appro-
)
priate reason for delay.
See Houston Lighting & Power Co.
(South Texas Project, Units 1 and 2), ALAB-637, 13 NRC 367, 371 1
(1981).
l The County's reference to LILCO's request for an exten-sion of the PSC proceeding is similarly inapposite.
- Again,
.{
LILCO seeks no delay, extension or postponement here.
To the j
extent that the County relies on arguments in the PSC case, however, this Board should be aware of its positions in that case.
The County "strongly oppose (d)" any extension of time for LILCO.
The County stated:
1 4
5/
If this were so, parties could control hearing schedules by unilaterally adjusting staffing levels.
t,
e i
l j
With regard to the next two months LILCO exaggerates the demands placed on its witnesses by discovery in the operating license proceed-ing.
Only two of LILCO's current witnesses in this case are presently scheduled for deposi-tions in the operating license proceeding, Messrs. Museler and Youngling (See Exhibit A).
It should be possible for those witnesses to adjust their schedules in order to appear for depositions in the operating license proceeding and testify in this case.
It is not unusual for a corporation LILCO's size to be engaged in than one significant legal proceeding at more the same time.
LILCO has retained two law firms of substantial size as counsel in this and the operating license proceedings.
Conse-quently there is no reason to believe that LILCO will be seriously impaired in its prepa-ration for either case.
Response of Suffolk County and New York State Consumer Protec-tion Board to LILCO Motion for Extension of Time and f'r Exten-sion of Hearing Schedule, dated March 28, 1984, at 3-4.
Similarly, it is doubtful that the County will have many witnesses in this proceeding who are also engaged in the low power motion or in the PSC case.
Similarly, it should be pos-sible for the County's witnesses, employees and counsel to ad-just their schedules in order to complete discovery and prepare for all proceedings in accordance with the existing schedules.
And, similarly, the County has retained two law firms as coun-sel in this and the PSC proceedings.
Consequently, in the County's own words "there is no reason to believe that [the County) will be seriously impaired in its preparation for either case.".
D.
Even If an Extension is Granted, the County's Proposal is Excessive The County's 70-day discovery request includes 45 days for depositions.
In contrast, only 40 days were originally al-lowed by this Board for both document production and deposi-tions.
The County, therefore, seeks not only an extension based on its asserted inability to review documents largely available to it, but also wants to expand the number of days available for copositions.
There is no reason for such expan-sion.
It will lead only to more delay and more expense.
Al-though LILCO contests the need for the number of depositions to be taken, the schedule now in effect should be expanded by, at most, 20 days to give the County the same opportunity it would have had between April 1 and April 20, the earliest time it presumably would have been ready for depositions.
The present eleven-day period between the close of discovery and the Coun-ty's filing of the specifics of its contentions should be Lain-tained.
Consequently, if the Board finds that some extension of time is warranted, it should set a schedule with deadlines no later than the following:
May 10 Close of discovery May 21 SC to file statement of issues May 30 Responses to SC statement of issues
- k
i
]
In sum, the ll5-day delay proposed by the County is too 1
l long even if this Board finds, over LILCO's objection, that discovery should.be extended.
The County has failed to take
}
advantage of discovery opportunities and failed to request an t
i extension of the discovery schedule within a reasonable time after the Board's oral order.
Accordingly, this belated re-quest for an expanded, as well as extended, discovery opportu-nity should not be granted.
j III.
Conclusion I
]
The objections of the County and the State to this a
i j
Board's February 22 rulings are both untimely and' unsupported by fact or law.
Accordingly, the Board's order as announced should not be altered.
t Respectfully submitted, 1
LONG -ISLAND LIGHTING COMPANY A
I By u
%C 6,
y,
/
lf
'V' j
W. Taylor Reveley, III Robert M. Rolfe Anthony F.'Earley, Jr.
4 Hunton & Williams T. O. Box 1535 Richmond, Virginia 23212
-DATED:
April 17, 1984 i,
.l 1
4
DOCKETED MNRC LILCO, April 17, 1984 134 APR 19 A10:42 CERTIFICATE OF SERVICE j,
- ^NC.
In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
I hereby certify that copies of LILCO's Response to Joint Objections of Suffolk County.and the State of New York to Board's Oral Order of February 22, 1984, and Request for Revi-sion Thereof were served this date upon the following by first-class mail, postage prepaid, or by Federal Express, as indicated by an asterisk:
Lawrence Brenner, Esq.*
Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington,-D.C.
20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris
- Commission Administrative Judge Washington, D.C.
20555 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555-Dr. George A.
Ferguson*
Administrative Judge Robert E.
Smith, Esq.
Atomic Safety and Licensing Cuggenheimer & Untermyer Board Panel 80 Pine Street School of Engineering New York, N.Y.
10005 Howard University 2300 6th Street, N.W.
Washington, D.C.
20059.
Bernard M.
Bordenick, Esq.*
Martin Bradley Ashare, Esq.
David A. Repka, Esq.
Attn:
Patricia A. Dempsey, Esq.
Richard J. Goddard, Esq.
County Attorney U.S. Nuclear Regulatory Suffolk County Department of Law Commission Veterans Memorial Hospital Washington, D.C.
20555 Hauppauge, New York 11787 Herbert H. Brown, Esq.
Stephen B.
Latham, Esq.
Lawrence Coe Lanpher, Esq.
Twomey, Latham & Shea Alan R.
Dynner, Esq.*
33 West Second Street i
Kirkpatrick, Lockhart, Hill, P.
O.
Box 398 Christopher & Phillips Riverhead,- New York 11901 8th Floor 1900 M Street, N.W.
Ralph Shapiro, Esq.
Washington, D.C.
20036 Cammer and Shapiro, P.C.
9 East 40th Street Mr. Marc W.
Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road James Dougherty, Esq.
Waltham, Massachusetts 02154 3045 Porter Street Washington, D.C.
20008 MHB Technical Associates l
1723 Hamilton Avenue Jonathan D.
Feinberg, Esq.
~
Suite K New York State San Jose, California 95125 Department of Public Service Three Empire' State Plaza Mr. Jay Dunkleberger Albany, New York 12223 New York State Energy Office Agency Building 2 Fabian G.
Palamino, Esq.*
Empire State Plaza Special Counsel to the Albany, New York 12223 Governor Executive Chamber, Room 229 State Capitol Albany, New York 12224 su s
y --
Hunton & Williams
/
4 P.O. Box 1535 Richmond, Virginia 23212 1
DATED:
April 17, 1984
~
..a-
ATTACHMENT 1 Hux rON & WILLIAMS 4
8 8 4. T SviLoiNo A. O. Som 10 9
,o,caer.,= starre a o eenin3s R ALEtom, Nourn CAmoLINA 27eos so oo.c== s,6va....,c=w s. =,
meCasaeo=o,v'#o'"'4 333'8
- O som'Sa3e tt6se-o=a so* f ee 8:00 i
i was.=ovo= oe aoose ews v o.ess.coes Tc L g ssw o N E 9 9 628 9371 et6te=o=c aca.e s s-soo j
aso paaa avt=ws 333 souv= oma=o avt=ws
=ca -caa =c a v o=a ios?'
kos==orgas,cavaa n.. ooo,.
et.ce-o=a a a. coo eaoo testa =o=s ais e t so sa es En ?setos vassa 'se'c o r'a s' v.ao+ asia e4=a vowas r est et==ts st e ea== ew.6o,=o
= o aosasse a o son os.
=oneown. vino.u = ass s ve6te-o=s ace aas s s'oi amouve66t. vt==csset stoo.
ttwape.o=s e.s e st asu
- s6smtonese r>6t =o April 11, 1984 Dougla s J.
Scheidt K i r K;a t ric k, LocAhart, Hill Christo pher & Pnillips f3 ta floor i
1900 ". Street, N.W.
.asnington, E.C. 20036 212221 9.SDRE11cg_11112f.11Ea_2_ESSME2al_E11E912EI E12225.1 i
Lear '.r.
Scheidt:
i 4
This is in response to your letter of March 30, 1984 to Messrs. El li s, Folfe and Earley concerning the County 's document discovery request recently submitted to Lilco.
As you are well aware, during the past several weeks, we have submitted to the County documents responsive to various j
d oc um e n t requests under cover letters dated 3/16/84, 3/ 17/ 8 4, J/20/94, 3/29/84, 3/30/84, 4/2/E4 and 4/9/84, in addition te serving Lilco's formal response to the County's request on Marca 21, 1964 You have at this peint received thousands cf I
- agas of dccuments responsive te various requests, over a very l
snort period of time.
Because cf the tremendcusly broad scope anc na ture of the County's request and the re s ul t sn t time consuming effort required to locate and review flies that might i
1 contain documents responsive to these requests, there are some i
requests for which we have not been able yet to locate, review and produce the required documents.
he are diligently working towards completing this task and will be furnishing these documents to you as quickly as is possible.
However, while there are some requests outstanding, our records reflect that se have indeed furnished the County with documents responsive to most of the requests for which you indicated in your March 30, 1984 letter that the County had received no documents.
Thus, contrary to your previous indications, responsive documents have been produced for the following requests:
I.10 ( t )..
We are enclosing herewith the original pro-curement specs for the Shorehan Energency.. Diesel Generators, as well as the January 26, 1983 Revision 2.'
Our review of en ~.
" Hexrox & WILLIAMS Mr. Douglas J. Scheidt April 11, 1964 Page 2 I
cocuments at TDI's facility in Cakland, California indicated tnat TDI mad e many, if not all cf the addenda and changes to tne s;ece available to you in Oakland, California.
However, in tne next few days, we will be sending you copies of add enda or changes to specs even if cuplicative of those furnished by TDI.
I.20.
Four Owners Group Eeports have been produced to tne County relative to air start valves, rocker arm bolt cap screw:, connecting rod tearings and pistons, respectively.
As we noted previously, in our formal response, as the Owners Group Reports and the DEGh Peport becomes final, we will fur-nish these to you lamediately.
I.A.1.6.
We furnished en March 15, 1984 production routing snee ts on the replacement crannshaf ts and documenta tion snowing fatique strength thereof.
Additional documentation re-sponsive to this request was sent to you in Mr. Earley's April 2,
1984 letter to Alan R. Dynner.
I.A.1.10.
Documentation relating to this category was sent to fou with Mr. Earley's letter of April 2, 1984 to Alan E. Dynner.
I.A.2.1.
Based on our review of TDI cocuments, we believe docusents responsive to this request were made avail-i sble to you at the offices of TEI in Oakland, California on Maren 22 And 23, 1984.
I.A.3.
1 and 2, These documents were mad e av s11able to
)
you by TDI in Oakland, Calif ornia on March 22 and 23, 1984.
I.A.3. 3, We have previously f urnished you an FaA A heport dated February 27, 1984 on AF and AE pistons which Addresses this category.
I. A. J.4 (a ).
We have previously furnished you an FaAA Eeport dated February 27, 1964 on AF and AE pistons which addressus this category.
I.A.4.3.
The report on the cylinder head studs is in tne process of being finalized and.it may rela te to this re-quest.
As soon as this report. is completed, it will be f urnished to you immediately.
m i
HuxTox & WILLIAxs Mr. Dou;1a s J.
Scheict April 11, 1984 Page 3 II.A.1.2.
This information is contained in the Ownerr Group Report dated March 12, 1964 on connecting rod
Dearings,
previously furnisned to you.
II.A.1.3.
This inf ormation is con tained in the Owners 3roup Report dated March 12, 1984 on connecting r od bearings, previously furnished to you.
II.7.2.6.
As you are no doubt aware, an Owners Group Report on this subject matter is to be is s u ed, and as soon as it is finalired it will immediately be made available to you.
II.A.7.2.
On March 15, 1984, you were furnished with a letter from EcHugh to Xaamayer dated November 30, 1984 respon-sive to this category.
As additional information and docusen-tation is identified, it will be immediately provided to you.
II.A.8.2.
To the extent TDI has responsive documents, they would have been maae available for ycur inspection in Caxland, California on Xarch 22nd and 23rd.
We have also pro-vided you with the name of the lawyer at Elliott Co., the tarbocharger manufacturer, so that you could discuss your jocament r eq ues t with him.
II.A.S.4.
As indicated in our formal response, we have alrea dy ag reed to maxe photographs responsive to this request avs11able to the County for examination at the Shorehan site.
Additionally, we furnished you on harch 17, 1984 with a meno f rom Swanger f rom Milligan responsive to this request.
II.A.10.5(b).
We have previously furnished you a FaAA meso dated September 17, 1983 responsive to this request.
II.A.10.5(c).
Documents responsive to this request were made available by TDI to you in Oakland, California on March 22nd and 23rd.
It should also be pointed out that while your letter indicated you have yet to receive any substantial portion of documents from TDI, you did spend several days in Oakland re-viewing documents.. 4he understand that TDI placed no limits on the amount of tiae you had to review documents.
Moreover, we l
i
b
' HuxTox & WILLIuts Mr. Douglas J.
Scheidt April 11, 1984 Psge 4 also understand tha t TDI rade arrangements to produce certain documents you designated on an expedited ba' sis and that these documents have been produced.
Finally, we are in the process of preparing a fccmal response to your most recent document production request atta-caed to your
?. arch 30, 1964 letter and will prcvide 'you with this reponse in the next tew days.
I renain, Yours very truly, HUNTON & WILLIAP.S r
A g
5
'p '/C I i
J'. v Odes L. Strcupe, r
241/671 cc:
Eicha rd J. Ooddard, Esq.
Fatian G.
Falomino, Esq.
Focart E. Smith, Esq.
bc:
Rooert 5.
Eolfe, Esq.
Anthony F. Earley, Jr.
David Dreifus Jessica S. Jones, Esq.
Nancy Saylor o
k I
w, 9
D e w
+