08-003375
Florida Elections Commission vs.
Charles J. Grapski
Status: Closed
DOAH Final Order on Tuesday, March 31, 2009.
DOAH Final Order on Tuesday, March 31, 2009.
1STATE OF FLORIDA
4DIVISION OF ADMINISTRATIVE HEARINGS
8FLORIDA ELECTIONS COMMISSION, )
12)
13Petitioner, )
15)
16vs. ) Case Nos. 08-2765
21) 08-3375
23CHARLES J. GRAPSKI, )
27)
28Respondent. )
30)
31FINAL ORDER
33A duly-noticed final hearing was held in these cases by
43Administrative Law Judge T. Kent Wetherell, II, on March 30,
532009, in Tallahassee, Florida.
57APPEARANCES
58For Petitioner: Eric M. Lipman, Esquire
64Florida Elections Commission
67Collins Building, Suite 224
71107 West Gaines Street
75Tallahassee, Florida 32399
78For Respondent: No appearance
82STATEMENT OF THE ISSUE
86The issue is whether Respondent committed the violations alleged in the Orders of Probable Cause, and, if so, what penalty should be imposed.
109PRELIMINARY STATEMENT
111The Florida Elections Commission (Commission) determined in
118an Order of Probable Cause dated June 1, 2007, that there was
130probable cause to believe that Respondent violated Section
138106.07, Florida Statutes (2006), by failing to timely file a
148quarterly campaign treasurers report for the 2006 election in
157which he was a candidate for state office. On June 11, 2008, 1 /
171this matter was referred to the Division of Administrative
180Hearings (DOAH) and designated DOAH Case No. 08-2765.
188The Commission determined in an Order of Probable Cause
197dated May 30, 2008, that there was probable cause to believe
208that Respondent violated Section 106.07, Florida Statutes
215(2007), by failing to file two campaign treasurers reports and
225by filing an incomplete report for the 2007 election in which he
237was a candidate for local office. On July 14, 2008, this matter
249was referred to DOAH and designated DOAH Case No. 08-3375.
259The final hearing in DOAH Case No. 08-2765 was initially
269scheduled for August 28, 2008. The hearing was subsequently
278rescheduled for September 29, 2008, based upon the Commissions
287motion.
288The final hearing in DOAH Case No. 08-3375 was initially
298scheduled for October 7, 2008. The hearing was subsequently
307rescheduled for October 13, 2008.
312On September 11, 2008, the cases were consolidated for all
322further proceedings, including the final hearing scheduled for
330September 29, 2008. The hearing was subsequently rescheduled
338for October 28 and 29, 2008, based upon Respondents unopposed
348motion.
349Respondents motion to strike two counts of the Order of
359Probable Cause in DOAH Case No. 08-3375 was denied in an Order
371dated October 6, 2008. Reconsideration of that Order was denied
381in an Order dated October 16, 2008.
388On October 24, 2008, the final hearing was cancelled
397because the Commission informed the undersigned in writing that
406Respondent was being held in jail without bond on several
416criminal charges. On December 1, 2008, the cases were placed
426into abeyance pending Respondents release from jail. The cases
435remained in abeyance until March 2, 2009, when the Commission
445advised the undersigned in a status report that Respondent had
455been released from jail.
459On March 3, 2009, a Notice of Hearing was issued scheduling
470the final hearing for March 30, 2009. The Notice of Hearing was
482mailed to Respondent at his address of record, Post Office Box
493190, Alachua, Florida 32616.
497The final hearing was held as scheduled. Respondent did
506not appear at the hearing. The Commission presented the
515testimony of Erin Nesmith, Malcolm Chellman, Diane Morgan, Alan
524Henderson, and Donna Maphurs. The Commissions Exhibits 1
532through 5 were received into evidence.
538No transcript of the final hearing was filed. The
547Commission presented an oral closing argument in lieu of filing
557a proposed final order.
561FINDINGS OF FACT
5641. Respondent was a candidate for election to the Florida
574House of Representatives in 2006.
5792. The Division of Elections (Division) was the filing
588office for that election.
5923. On March 27, 2006, the Division sent a letter to
603Respondent acknowledging his candidacy and informing him of the
612filing deadline for the first campaign treasurers report. The
621letter also informed Respondent that all of the Divisions
630publications, including the 2006 Calendar of Reporting Dates,
639were available on the Divisions website.
6454. The filing deadline for the campaign treasurers report
654July 10, 2006.
6575. Respondent did not file his Q2 report by that deadline.
6686. On July 12, 2006, the Division sent Respondent a letter
679informing him that his Q2 report had not been received. The
690Division sent a second letter (by certified mail) on October 17,
7012006, and the Commission sent several additional follow-up
709certified letters in November and December 2006.
7167. Respondent filed his Q2 report on February 9, 2007,
726which is 214 days after the deadline.
7338. Respondent was a candidate for election to the Alachua
743City Council in 2007.
7479. The City Clerk was the filing officer for that
757election.
75810. Respondent submitted his campaign paperwork to the
766City Clerk on February 23, 2007. 2 / The paperwork included a
778Statement of Candidate form signed by Respondent stating that
787he received, read, and understand[s] the requirements of
795Chapter 106, Florida Statutes.
79911. On February 23, 2007, the City Clerks office provided
809Respondent a copy of Chapters 104 and 106, Florida Statutes, a
820and a calendar of the election dates. The handbook contained
830the applicable filing deadlines for the campaign treasurers
838reports that Respondent was required to file.
84512. The first report was due on March 14, 2007, and
856covered the period between the candidates filing date and
865March 14.
86713. The second report was due on March 23, 2007, and
878covered the period of March 15 to March 23.
88714. The third report was due on April 6, 2007, and covered
899the period of March 24 to April 6.
90715. Respondent did not file the first report even though
917he had contributions and expenditures during the period covered
926by the report.
92916. On March 15, 2007, the City Manager sent a certified
940letter to Respondent informing him that his first campaign
949treasurers report had not been received. The letter advised
958Respondent that fines had started to accrue.
96517. Respondent did not file the second report, nor did he
976file a waiver report reflecting that he did not have any
987contributions or expenditures during the period covered by the
996report.
99718. On March 27, 2007, the City Manager sent a certified
1008letter to Respondent informing him that his second campaign
1017treasurers report had not been received. The letter advised
1026Respondent that fines were accruing.
103119. On April 9, 2007, Respondent filed an untimely and
1041incomplete report for the third reporting period. The report
1050included only the itemized contribution page and the itemized
1059expenditure page; it did not include the required summary page
1069that contains the candidates certification of the reports
1077truth, correctness, and completeness.
108120. On April 9, 2007, the City Manager sent a certified
1092letter to Respondent informing him that his third campaign
1101treasurers report was incomplete. The letter gave Respondent
1109three days to submit a complete report.
111621. To date, Respondent has not filed the first or second
1127reports or a complete third report.
113322. In each of the circumstances described above,
1141Respondent was aware of the requirement to file a complete
1151campaign treasurers report as well as the deadline for doing so
1162by virtue of having been provided copies of the applicable laws
1173and the candidates handbook.
117723. Respondents failure to file complete and timely
1185reports was clearly more than an oversight. Indeed, even though
1195Respondent was sent certified letters by the filing officer on
1205each occasion advising him that the reports had not been
1215received, he did not make any subsequent filings with the City
1226Clerk and it took him over six months to file his Q2 report with
1240the Division.
124224. Respondent was provided notice of the date, time, and
1252location of the final hearing, through a Notice of Hearing
1262mailed to his address of record.
126825. Respondent failed to appear at the final hearing
1277despite having been provided proper notice of the hearing.
1286CONCLUSIONS OF LAW
128926. DOAH has jurisdiction over the parties to and subject
1299matter of this proceeding pursuant to Section 106.25(5), Florida
1308Statutes (2008).
131027. The Commission has the burden to prove the violations
1320alleged in the Orders of Probable Cause by clear and convincing
1331evidence. See Diaz de la Portilla v. Fla. Elections Commn , 857
1342So. 2d 913, 917 (Fla. 3d DCA 2003).
135028. The clear and convincing standard of proof is greater
1360than the preponderance of the evidence standard that applies in
1370most civil cases, but it is less than the beyond a reasonable
1382doubt standard that applies in criminal cases; it requires that:
1392the evidence must be found to be credible;
1400the facts to which the witnesses testify
1407must be distinctly remembered; the testimony
1413must be precise and explicit and the
1420witnesses must be lacking confusion as to
1427the facts in issue. The evidence must be of
1436such weight that it produces in the mind of
1445the trier of fact a firm belief or
1453conviction, without hesitancy, as to the
1459truth of the allegations sought to be
1466established.
1467In re Davey , 645 So. 2d 398, 404 (Fla. 1994).
147729. The Commission must not only prove that Respondent
1486violated a provision of the campaign finance laws, but also that
1497the act or omission that resulted in the violation was
1507willful. See § 106.25(3), Fla. Stat. (2008); Diaz de la
1517Portilla , 857 So. 2d at 916-17.
152330. Willfulness is a question of fact. See § 106.25(3),
1533Fla. Stat. (2008); McGann v. Fla. Elections Commn , 803 So. 2d
1544763, 764 (Fla. 1st DCA 2001).
155031. The determination of willfulness in this case is
1559governed by the definition in Section 106.37, Florida Statutes
1568(2006), which was in effect at the time of the acts and
1580omissions that gave rise to the Orders of Probable Cause. 3 / See
1593Diaz de la Portilla , 857 So. 2d at 917 n.2; McGann , 803 So. 2d
1607at 764.
160932. Section 106.37, Florida Statutes (2006), provided:
1616A person willfully violates a provision of
1623this chapter if the person commits an act
1631while knowing that, or showing reckless
1637disregard for whether, the act is prohibited
1644under this chapter, or does not commit an
1652act while knowing that, or showing reckless
1659disregard for whether, the act is required
1666under this chapter. A person knows that an
1674act is prohibited or required if the person
1682is aware of the provision of this chapter
1690which prohibits or requires the act,
1696understands the meaning of that provision,
1702and performs the act that is prohibited or
1710fails to perform the act that is required.
1718A person shows reckless disregard for
1724whether an act is prohibited or required
1731under this chapter if the person wholly
1738disregards the law without making any
1744reasonable effort to determine whether the
1750act would constitute a violation of this
1757chapter.
175833. The Commission alleged that Respondent violated
1765Subsections (1), (5), and (7), of Section 106.07, Florida
1774Statutes (2006 and 2007), which provide:
1780(1) Each campaign treasurer designated by
1786a candidate . . . shall file regular reports
1795of all contributions received, and all
1801expenditures made, by or on behalf of such
1809candidate . . . . Reports shall be filed on
1819the 10th day following the end of each
1827calendar quarter from the time the campaign
1834treasurer is appointed, except that, if the
184110th day following the end of a calendar
1849quarter occurs on a Saturday, Sunday, or
1856legal holiday, the report shall be filed on
1864the next following day which is not a
1872Saturday, Sunday, or legal holiday.
1877Quarterly reports shall include all
1882contributions received and expenditures made
1887during the calendar quarter which have not
1894otherwise been reported pursuant to this
1900section.
1901* * *
1904(5) The candidate and his or her campaign
1912treasurer, in the case of a candidate, or
1920the political committee chair and campaign
1926treasurer of the committee, in the case of a
1935political committee, shall certify as to the
1942correctness of each report; and each person
1949so certifying shall bear the responsibility
1955for the accuracy and veracity of each
1962report. . . .
1966* * *
1969(7) Notwithstanding any other provisions
1974of this chapter, in any reporting period
1981during which a candidate, political
1986committee, or committee of continuous
1991existence has not received funds, made any
1998contributions, or expended any reportable
2003funds, the filing of the required report for
2011that period is waived. However, the next
2018report filed must specify that the report
2025covers the entire period between the last
2032submitted report and the report being filed,
2039and any candidate, political committee, or
2045committee of continuous existence not
2050reporting by virtue of this subsection on
2057dates prescribed elsewhere in this chapter
2063shall notify the filing officer in writing
2070on the prescribed reporting date that no
2077report is being filed on that date.
208434. The Commission met its burden to prove that Respondent
2094violated these statutory provisions.
209835. The evidence clearly and convincingly establishes that
2106(1) Respondent failed to timely file the Q2 report due on
2117July 10, 2006, for the 2006 House of Representatives election;
2127(2) Respondent failed to file the campaign treasurers report
2136due on March 14, 2007, for the 2007 City Council election;
2147(3) Respondent failed to file the campaign treasurers report
2156due on March 23, 2007, for the 2007 City Council election, or a
2169waiver report for that period; (4) Respondent filed an
2178incomplete campaign treasurers report for the third reporting
2186period for the 2007 City Council election; and (5) Respondents
2196failure to file these reports was willful, as defined in Section
2207106.37, Florida Statutes (2006).
221136. Each violation that was proven was contained in a
2221separate count of the Orders of Probable Cause, and, therefore,
2231a separate fine may be imposed for each violation. See Diaz de
2243la Portilla , 857 So. 2d at 924; McGann , 803 So. 2d at 765-66.
225637. Section 106.265(1), Florida Statutes (2006, 2007, and
22642008), provides:
2266(1) The commission is authorized upon the
2273finding of a violation of this chapter . . .
2283to impose civil penalties in the form of
2291fines not to exceed $ 1,000 per count. In
2301determining the amount of such civil
2307penalties, the commission shall consider,
2312among other mitigating and aggravating
2317circumstances:
2318(a) The gravity of the act or omission;
2326(b) Any previous history of similar acts
2333or omissions;
2335(c) The appropriateness of such penalty
2341to the financial resources of the person . .
2350.; and
2352(d) Whether the person . . . has shown
2361good faith in attempting to comply with the
2369provisions of this chapter . . . .
237738. Properly reporting campaign contributions and filing
2384campaign treasurers reports go to the heart of the campaign
2394finance laws, and, as a result, a candidates willful failure to
2405comply with the statutory reporting requirements justifies the
2413imposition of the maximum fine of $1,000 per count. See , e.g. ,
2425Beardslee v. Fla. Elections Commn , 962 So. 2d 390 (Fla. 5th DCA
24372007) (affirming $1,000 fine for candidates willful failure to
2447report a $143 contribution).
245139. Respondent has the burden to prove the existence of
2461any mitigating circumstances that would justify imposition of a
2470lesser fine. See Diaz de la Portilla , 857 So. 2d at 925.
248240. No mitigating evidence was presented at the final
2491hearing.
2492ORDER
2493Based upon the foregoing Findings of Fact and Conclusions
2502of Law, it is
2506ORDERED that:
25081. Respondent is guilty of:
2513(a) willfully violating Section 106.07(1), Florida
2519Statutes (2006), as alleged in Count 1 of the Order of Probable
2531Cause dated June 1, 2007;
2536(b) willfully violating Section 106.07(1), Florida
2542Statutes (2007), as alleged in Count 1 of the Order of Probable
2554Cause dated May 30, 2008;
2559(c) willfully violating Section 106.07(7), Florida
2565Statutes (2007), as alleged in Count 2 of the Order of Probable
2577Cause dated May 30, 2008; and
2583(d) willfully violating Section 106.07(5), Florida
2589Statutes (2007), as alleged in Count 3 of the Order of Probable
2601Cause dated May 30, 2008.
26062. Respondent is assessed an administrative fine of $4,000
2616($1,000 for each count), which must be paid to the Florida
2628Elections Commission within 30 days of the date of this Final
2639Order.
2640DONE AND ORDERED this 31st day of March, 2009, in
2650Tallahassee, Leon County, Florida.
2654S
2655T. KENT WETHERELL, II
2659Administrative Law Judge
2662Division of Administrative Hearings
2666The DeSoto Building
26691230 Apalachee Parkway
2672Tallahassee, Florida 32399-3060
2675(850) 488-9675
2677Fax Filing (850) 921-6847
2681www.doah.state.fl.us
2682Filed with the Clerk of the
2688Division of Administrative Hearings
2692this 31st day of March, 2009.
2698ENDNOTES
26991 / An explanation of the more than one-year delay between the
2711first Order of Probable Cause and the referral of the case to
2723DOAH is contained in the Motion for Summary Final Order filed by
2735the Commission on July 11, 2008.
27412 / The record also includes campaign paperwork submitted by
2751Respondent on March 7, 2007. The February 23 paperwork
2760identifies the office that Respondent was seeking as
2768Commissioner Group 2, whereas the March 7 paperwork identifies
2778the office that Respondent was seeking as Commissioner Group
27871. An explanation of these different sets of paperwork is
2797contained in Exhibit 2, at page P39.
28043 / Section 106.37, Florida Statutes, was repealed effective
2813January 1, 2008. See Ch. 2007-30, Laws of Fla., at §§ 51, 57.
2826Because the statute was still in effect at the time of the acts
2839and omissions that gave rise to the Orders of Probable Cause, it
2851is unnecessary to consider whether, in light of the repeal of
2862Section 106.37, Florida Statutes, it is appropriate to resort to
2872case law or other sources to define willful for purposes of
2883Chapter 106, Florida Statutes. Cf. Fugate v. Fla. Elections
2892Commn , 924 So. 2d 74, 75 (Fla. 1st DCA 2006) (In the absence
2905of a statute or properly promulgated rule defining the term
2915[willful for purposes of Chapter 104, Florida Statutes], the
2924case-law derived definition used by the ALJ was reasonable.).
2933COPIES FURNISHED :
2936Charles J. Grapski
2939Post Office Box 190
2943Alachua, Florida 32616
2946Eric M. Lipman, Esquire
2950Florida Elections Commission
2953The Collins Building, Suite 224
2958107 West Gaines Street
2962Tallahassee, Florida 32399-1050
2965Barbara M. Linthicum, Executive Director
2970Florida Elections Commission
2973The Collins Building, Suite 224
2978107 West Gaines Street
2982Tallahassee, Florida 32399-1050
2985Patsy Rushing, Clerk
2988Florida Elections Commission
2991The Collins Building, Suite 224
2996107 West Gaines Street
3000Tallahassee, Florida 32399-1050
3003NOTICE OF RIGHT TO JUDICIAL REVIEW
3009A party who is adversely affected by this Final Order is
3020entitled to judicial review pursuant to Section 120.68, Florida
3029Statutes. Review proceedings are governed by the Florida Rules
3038of Appellate Procedure. Such proceedings are commenced by
3046filing one copy of a Notice of Appeal with the agency clerk of
3059the Division of Administrative Hearings and a second copy,
3068accompanied by filing fees prescribed by law, with the District
3078Court of Appeal, First District, or with the District Court of
3089Appeal in the appellate district where the party resides. The
3099Notice of Appeal must be filed within 30 days of rendition of
3111the order to be reviewed.
- Date
- Proceedings
- PDF:
- Date: 10/06/2009
- Proceedings: Transmittal letter from Claudia Llado forwarding Petitioner's Exhibits numbered 1 through 5, to the agency.
- PDF:
- Date: 04/06/2009
- Proceedings: Official Response to Unlawful, Unjust, and Purely Fictional Procedure of this Court filed.
- PDF:
- Date: 04/06/2009
- Proceedings: Statement of Ex-Parte Communication and Other Misconduct by the Judge in this Case filed.
- PDF:
- Date: 04/06/2009
- Proceedings: Memorandum of Facts Deliberately Ignored by this Court Proving Defendant Innocent of Charges and Proving the Deliberate Unlawful and Unethical Misrepresentations to this Court by Charles Finkel and Barbara Linthicum filed.
- Date: 03/30/2009
- Proceedings: CASE STATUS: Hearing Held.
- PDF:
- Date: 03/23/2009
- Proceedings: Notice of Filing Exhibit List and Exhibits (exhibits not available for viewing) filed.
- PDF:
- Date: 03/03/2009
- Proceedings: Notice of Hearing (hearing set for March 30, 2009; 9:00 a.m.; Tallahassee, FL).
- PDF:
- Date: 03/02/2009
- Proceedings: Florida Elections Commission`s Response to Order Placing Case in Abeyance filed.
- PDF:
- Date: 01/07/2009
- Proceedings: Order Continuing Case in Abeyance (parties to advise status by February 27, 2009).
- PDF:
- Date: 01/06/2009
- Proceedings: Florida Elections Commission`s Response to Order Placing Case in Abeyance filed.
- PDF:
- Date: 12/01/2008
- Proceedings: Order Placing Case in Abeyance (parties to advise status by January 5, 2009).
- PDF:
- Date: 11/26/2008
- Proceedings: Florida Elections Commission`s Response to Amended Order Granting Continuance filed.
- PDF:
- Date: 10/24/2008
- Proceedings: Order Granting Continuance (parties to advise status by November 26, 2008).
- PDF:
- Date: 10/23/2008
- Proceedings: Notice of Telephonic Motion Hearing (motion hearing set for October 24, 2008; 2:00 p.m.).
- PDF:
- Date: 10/23/2008
- Proceedings: Petitioner`s Response to Respondent`s Request for Admissions: FEC 06-421 filed.
- Date: 10/22/2008
- Proceedings: CASE STATUS: Motion Hearing Held.
- PDF:
- Date: 10/22/2008
- Proceedings: Notice of Respondent`s Incarceration and Suggestion for Continuance of Final Hearing filed.
- PDF:
- Date: 10/07/2008
- Proceedings: Motion for Rehearing and Holding an Actual Hearing on Judge`s Unfounded Motion Denying Respondent`s Motion to Strike and for Clarification for Basis of Judge`s Conclusion that Matters Clearly not in the Original Petition aas Required by Law are Actually there filed.
- PDF:
- Date: 10/06/2008
- Proceedings: Emergency Motion to Clarify Court`s Instructions given in Motion Hearing on Discovery/Deposition Process Pertaining to the Requirement of Petitioner to Utilize an Official Court Reporter as Video Operator and to Issue Order Clarifying the Court`s Order Establishing that it does not Require Petitioner to Pay for and Utilize Two Court Reporters when Video Depositions are taken According to Court`s Instructions to Petitioner filed.
- Date: 10/03/2008
- Proceedings: CASE STATUS: Motion Hearing Held.
- PDF:
- Date: 10/03/2008
- Proceedings: Respondents Motion in Opposition to Ms. Rush`s Emergency Motion to Invalidate and Quash Subpoena and Issue a Protective Order for Deposition Noticed for October 6th 2008 filed.
- PDF:
- Date: 10/03/2008
- Proceedings: Respondent`s Motion in Opposition to Petitioner`s Motion to Strike Notice of Depositions and Motion to Suspend Depositions filed.
- PDF:
- Date: 10/02/2008
- Proceedings: Petitioner`s Motion to Strike Notice of Service of Respondent`s First Set of Interrogatories filed.
- PDF:
- Date: 10/02/2008
- Proceedings: Emergency Motion to Invalidate and Quash Subpoena and Issue a Protective Order for Depositions Noticed for October 6, 2008 filed.
- PDF:
- Date: 10/02/2008
- Proceedings: Amended Petitioner`s Motion to Strike Notice of Deposition and Motion to Suspend Depositions filed.
- PDF:
- Date: 10/02/2008
- Proceedings: Petitioner`s Motion to Strike Notice of Deposition and Motion to Suspend Depositions filed.
- PDF:
- Date: 10/01/2008
- Proceedings: Notice of Service of Respondents First Set of Interrogatories filed.
- PDF:
- Date: 09/19/2008
- Proceedings: Order Granting Continuance and Re-scheduling Hearing (hearing set for October 28 and 29, 2008; 9:00 a.m.; Tallahassee, FL).
- PDF:
- Date: 09/19/2008
- Proceedings: Petitioner`s Response to Respondent`s Motion for Continuance filed.
- PDF:
- Date: 09/19/2008
- Proceedings: Letter to Judge Wetherell from C. Grapski regarding electronic filing filed.
- PDF:
- Date: 08/25/2008
- Proceedings: Amended Order (amended only to insure Respondent has a full seven days to respond with five days for mailing).
- PDF:
- Date: 08/14/2008
- Proceedings: Order (on or before August 20, 2008, Respondent Grapski shall file, with the Division of Administrative Hearings, a written answer or other pleading setting forth the disputed issues of fact with reference to the factual allegations of the three counts in the Order of Probable Cause dated May 30, 2008).
- PDF:
- Date: 08/13/2008
- Proceedings: Florida Elections Commission`s Motion to Consolidate Cases filed.
- PDF:
- Date: 08/06/2008
- Proceedings: Notice of Service of Petitioner`s First Set of Interrogatories filed.
- PDF:
- Date: 07/29/2008
- Proceedings: Amended Notice of Hearing (hearing set for October 13, 2008; 10:00 a.m.; Tallahassee, FL; amended as to date).
Case Information
- Judge:
- T. KENT WETHERELL, II
- Date Filed:
- 07/14/2008
- Date Assignment:
- 09/09/2008
- Last Docket Entry:
- 10/06/2009
- Location:
- Tallahassee, Florida
- District:
- Northern
- Agency:
- Florida Elections Commission
Counsels
-
Charles J. Grapski
Address of Record -
Eric M. Lipman, General Counsel
Address of Record -
Marian B. Rush, Esquire
Address of Record