Showing posts with label Indiana Public Access Counselor. Show all posts
Showing posts with label Indiana Public Access Counselor. Show all posts

Tuesday, December 31, 2019

Donald Trump and Jeff Gahan have the same self-serving explanation for not obeying the law.


Both of them, Donald and Jeffie, blame their own illegality on their political enemies. Their sycophants chortle, and the only clear winner is two-party hypocrisy.

As we contemplate the extent of City Hall's newfound (purported) compliance with a law about information requests, a law that makes no mention of the questioner's party affiliation or history as candidate, don't kid yourself. Team Gahan has treated these requests like toilet paper before, refusing full 100% disclosure, and they'll continue doing so.

There is considerable irony in the fact that the News and Tribune itself could clear up some of these questions about taxpayer dollars and advertising revenue.

And it won't. Why is it no one, including the alleged newspaper of record, seems to want to tell the truth about the money?

New Albany officials provide records after missing deadlines, by John Boyle (Hanson's Non-Disclosure Journal)

NEW ALBANY — One of the plaintiffs in a lawsuit filed against the City of New Albany has stated that city officials have complied with a records request.

The legal battle began Nov. 1, when Floyd County residents Irvin Stumler, Stephen Roberts and Heather Rae Peters sued the city for failing to respond to public records requests that were submitted in August. The trio sought documents related to River Run Family Water Park, Denton Floyd Real Estate Group, ProMedia Group and advertising in the News and Tribune.

Up until Monday, the city had missed multiple deadlines to provide the information requested. Now, Stumler said he has learned that city officials have made a delivery to the office of his attorney.

“I heard that sometime yesterday afternoon, the city brought some records and a check to my attorney’s office," he said. "I haven’t seen it. I don’t know what all’s in there. My attorney’s out of town.”

The presence of the check is likely the product of a default judgment issued by special judge Vicki Carmichael on Dec. 18. Her order mandated that the city produce the documents no later than 10 days after the judgment — with a fine of $50 for each subsequent day. Payment of $1,642.50 for plaintiffs' attorney fees, $162.10 for filing feels and $300 to the plaintiffs by the city was also required.

New Albany officials maintained the administration's position that the request was politically motivated in a statement to the News and Tribune.

"At this time, we have supplied documents per the request," city spokesman Mike Hall said in an emailed statement. "As mentioned before, Mr. Stumler is a former mayoral candidate and critic of this administration who has unsuccessfully sought local elected office numerous times" ...

Local Democrats angrily rally against openness and transparency as "The City of New Albany Defies Court Order on Records’ Requests."

Monday, December 30, 2019

Local Democrats angrily rally against openness and transparency as "The City of New Albany Defies Court Order on Records’ Requests."


At this point just about any fair-minded citizen can't avoid the only real question.

Gahan's public records scandal: WDRB's Marcus Green breaks it down as the News and Tribune flails ineffectually.


Exactly what is Gahan hiding?

Go to The Aggregate for the scoop.

The City of New Albany Defies Court Order on Records’ Requests, by Nick Vaughn (The Aggregate)

 ... The default judgement, issued on December 18th, ordered the city to provide the plaintiffs with the documents they requested back in August within 10 days and the payment of over $2,000 in legal fees.

On December 30th, The Aggregate News staff checked in with one of the plaintiffs, Irv Stumler, regarding whether the city had provided the documents and court fees by the December 28th deadline.

In a text message, Mr. Stumler stated that "No, we have not heard from anyone at the city" ...

Thursday, December 26, 2019

Gahan's public records scandal: WDRB's Marcus Green breaks it down as the News and Tribune flails ineffectually.


On Christmas Eve, Marcus Green of WDRB broke down Jeff Gahan's public records scandal; the screenshots and transcriptions follow. Green concludes with three questions:

  1. Why didn't (city hall) respond to the citizens' request before (the judge's ruling)?
  2. Does it believe it doesn't have to respond to requests it deems politically motivated?
  3. Why didn't it respond to the access counselor?

To which I can add only one additional query:

Where the hell was the News and Tribune for all those weeks prior to the judge's ruling?

The Aggregate reports: "The City of New Albany was ordered to pay over $2,000 after it failed to fulfill a public records request."


Green makes it so simple that even a Democratic precinct committee-person can understand it.

---




Marcus Green @MarcusGreenWDRB

This is an interesting public records case from New Albany.

A judge rules that @NewAlbanyIN must release records sought by citizens: https://bit.ly/39b6yoc

Ok. Let's break this down.

Judge rules New Albany must release requested public records

NEW ALBANY — Just under two months after a lawsuit was filed against the City of New Albany for failing to respond to public records requests made by three residents ...
The city's attorney, Shane Gibson, told the @newsandtribune this:

“The city was sued by former political opponents and non-city residents' days before the November mayoral election to try and influence the outcome," Gibson said in an emailed statement. "We are pleased those efforts failed. While these actions were politically motivated, the City of New Albany intends to comply with any court order regarding the matter.”
First, the citizens filed the lawsuit only after @NewAlbanyIN ignored their records request, which was made in August, per @newsandtribune. They then asked for Indiana's public access counselor for an opinion.

The counselor, the state office that addresses public records disputes, says @NewAlbanyIN's city attorney, city controller and parks director refused to respond to its questions.

The state then found New Albany violated the law: https://in.gov/pac/advisory/files/19-FC-105.pdf

Then the citizens sued.

The city attorney now says @NewAlbanyIN will comply with the court order.

Questions: Why didn't it respond to the citizens' request before? Does it believe it doesn't have to respond to requests it deems politically motivated? Why didn't it respond to the access counselor?

Sunday, December 22, 2019

The Aggregate reports: "The City of New Albany was ordered to pay over $2,000 after it failed to fulfill a public records request."


Did the News and Tribune just get scooped ... again?

The story goes back months -- well, years, actually. Now The Aggregate is reporting that a judge has ruled in favor of plaintiffs who seek nothing more than Mayor Jeff Gahan's compliance with Indiana public records laws.

First, the background.


Then the most recent news. The city's caterwauling should come as no surprise to anyone who has been paying attention to the Gahan administration's congenital paranoia.

You're advised to click straight through and read the entire piece, highlighted here.

New Albany Sued for Failure To Produce Public Records, by Jake Sipes-Salter(The Aggregate)

Last Wednesday, the City of New Albany was ordered to pay over $2,000 after it failed to fulfill a public records request.

On November 1st, a trio of Floyd County residents filed a civil lawsuit against the city of New Albany for failing to provide access to public records in violation of the Access to Public Records Act. In a public statement, the plaintiffs claim that, “at its core, it is all about the ideal of open and transparent government.”

snip

The plaintiffs, Floyd County residents Irvin Stumler, Steve Roberts, and Heather Archibald-Peters, claim their rights to access public records were violated when the city of New Albany did not respond to their records requests. Their inquiries, hand-delivered by the plaintiffs to the city on August 28, ranged from legal fees concerning the city of New Albany to revenue data of the River Run Water Park.

snip

On December 10th, Judge Hancock recused himself from the case and the case was given to a special judge. Taking over for Judge Hancock was Judge Vicki Carmichael who presides over Clark County’s 4th Circuit Court.

Shortly afterward on December 18, the waiting game came to an end and the court granted default judgement in the case, meaning that the Court found against the City of New Albany for their failure to adequately respond, despite being granted an extension. As a result, the defendants have been ordered produce the records within 10 days (by December 28th), and are ordered to pay the plaintiffs’ fees in the amount of $162.10 each as well as their attorney fees amounting to $1,642.50.

Even after the city’s extension was granted by the court, they still did not respond to the summons ...

Monday, November 11, 2019

Gahan begins search for a disposable scapegoat as Indiana's Public Access Counselor finds the mayor in violation of the state's public records law.


Thanks to WDRB's Marcus Green for tagging me at Twitter. Here's the link to Public Access Counselor Luke H. Britt's advisory opinion.

"This case involves a dispute over a municipality’s lack of responses to multiple public records requests."

Here's the conclusion.


In the instance of Randy Smith's ignored request, these three posts are relevant background.

River Run Family Water Park: Why won't the city of New Albany comply with the law and grant Randy Smith's public records request to view the financials?

Reader writes about River Run: "I was under the impression public records HAD to be made public."

Team Gahan's failure to fulfill open records requests? That's Gahan's political conspiracy against transparency, and it's HIS problem, not anyone else's.


Britt informed Smith that his complaint was taken into consideration in formulating the advisory opinion.

I didn't realize the story had made it to the Associated Press. WDRB has it, dated November 4.

Indiana city faces records lawsuit after counselor's opinion

NEW ALBANY, Ind. (AP) — Three southern Indiana residents are suing the city of New Albany for allegedly failing to fulfill their public records requests.

The Floyd County lawsuit comes after Indiana's Public Access Counselor, Luke Britt, found that New Albany had violated Indiana's public records law.

The three plaintiffs say they requested public records in August, including electronic correspondence related to River Run Family Water Park. They sought Britt's opinion after officials in the Ohio River city failed to acknowledge their records requests.

The News and Tribune reports the trio say their suit was filed in response to "a consistent pattern of failing to acknowledge, let alone respond, to a citizen's inquiry into the affairs of local government."

New Albany Mayor Jeff Gahan says city officials "greatly look forward" to their day in court.

———

Information from: News and Tribune, Jeffersonville, Ind. 

Friday, November 01, 2019

Team Gahan's failure to fulfill open records requests? That's Gahan's political conspiracy against transparency, and it's HIS problem, not anyone else's.


It's like this.

These information requests are about money. The money comes from taxes, not an elected official's alchemy lab.

Taxpayers in the broadest sense have a perfect right to ask how their money is being spent. If there is day-to-day institutional transparency and the expenditures are available for open perusal and discussion, it's all good, but when these conditions are absent, these citizens also have the right to pursue a resolution according to state-established procedures, and this is what some of those who have been deprived of answers have found it necessary to do.

Why? Because Team Gahan has not complied with procedure, because this non-compliance is illegal, and because the buck stops with Jeff Gahan.

Gahan would have you believe that the Indiana public access counselor's findings on behalf of complainants is a political conspiracy against him, but his self-serving paranoia isn't relevant, because the issue of timing cuts both ways.

Just remember this: these requests date back months. At any point over a period of months, Gahan's underlings might have cooperated in the spirit of doing the bare minimum required of their job descriptions -- not to mention honoring the stipulations of Indiana state law.

However, as we've observed so many times before, Gahan's political imperatives always intrude -- the habitual secrecy, the lust for control, and the bizarre certainty that anyone who differs with his power games is a threat to be checked stymied rather than the person who pays his inflated effing salary.

In a final instance of raging hypocrisy, Gahan informs the typically somnolent News and Tribune in effect that he believes someone living outside city limits forfeits the right to ask questions of him.

And yet, how many hundred thousand dollars has he been given by special interests with mailing addresses ... that's right, outside city limits?

Suit filed against City of New Albany over public records

NEW ALBANY — Three Floyd County residents have filed a civil lawsuit against the City of New Albany, for failing to fulfill open records requests.

The lawsuit was filed by Irvin Stumler, Stephen Roberts and Heather Peters in Floyd County Superior Court No. 2. The suit comes following the opinion of Public Access Counselor Luke Britt that the city violated the Access to Public Records law.

The trio filed the suit Friday. The requests for information covered a variety of topics, including legal fees incurred or paid by the City of New Albany, electronic correspondence and revenue and expenses of the River Run Family Water Park.

“What is at play here goes far beyond individuals request for information. At its core, it is all about the ideal of open and transparent government,” states a news release from the three. “What brings us here today is a consistent pattern of failing to acknowledge, let alone respond, to a citizen’s inquiry into the affairs of local government” ...

Saturday, April 01, 2017

Transparency in schools is a relative term, redevelopmentally non-binding in the sense of ... "Is Hibbard gone yet?"


By the way, New Albany's Redevelopment Commission spent money to support the school corporation's property tax referendum last November (minutes from the September meeting, above). Note that the President is Irving Joshua, and the Director is David Duggins ... and the secretary taking notes is Adam Dickey.

Yep, the fix remains in.

Now, to the topic of this post.

I'm the first to concede these past weeks have been fractured, to say the least. My head hasn't been in the game, but still, I'd have sworn that something appeared here at NAC about the "open door" complaint.

It's unanimous as the NAFC school board rejects Hibbard's rollover.



We think this means Dickey wants Gahan's bedmate Hibbard to keep his job, but it's such bad writing that it's hard to tell.



Lee Cotner is appointed to a third stint on the NAFC school board.


Maybe it was a Facebook discussion instead.

Obviously, I favor the greatest amount of transparency possible. More daylight and greater openness always are preferable to less.

That said, contrast the chain newspaper's headline with the content; the ruling is "non-binding," and and access counselor himself concedes it to be a "technicality."

Damn, I wish New Albany had a newspaper.

NA-FC school board violated the Open Door Law, rules public access counselor, by Danielle Grady (Hanson Pay to Play Gazette)

Board decided upon a replacement at an executive session

NEW ALBANY — The Indiana Public Access Counselor has issued a non-binding ruling that the New Albany-Floyd County school board violated the Open Door Law during the replacement process of former board member DJ Hines.

A complaint was filed against the school board earlier this year by former board member Mark Boone after the board agreed upon — but did not take a vote on — a replacement for Hines during an executive session on Jan. 18.

Sunday, March 26, 2017

Mt. Tabor Road euphemism project: If City Hall looks bad, that's only because it's doing the damage to itself.


Colin Receveur is to be commended for pursuing every legal mechanism in an effort to compel Team Gahan to practice transparency.

It isn't just that those federal 80/20 construction grants are like crack. It's that to Team Gahan, openness is like Ebola.

'Bune snoozes and IL gets the scoop: "City of New Albany, residents head to court over road improvement project."

The Indiana Public Access Counselor has affirmed that the city of New Albany has unlawfully denied public records to a landowner who is pushing back against the city’s use of eminent domain in a Mount Tabor Road expansion project.

"We've also reached out to the city of New Albany and have yet to hear a response."

Really? Is Mike Hall on spring break?

Land owners complain about upcoming changes to Mt. Tabor Road in New Albany, by Amber Powell (WAVE-3)

People who own property on Mt. Tabor Road in New Albany are concerned about planned construction that will change the size of the road.

Friday, March 24, 2017

'Bune snoozes and IL gets the scoop: "City of New Albany, residents head to court over road improvement project."


We have all been here before, haven't we?

Shane Gibson is unaccountable yet again as "City of New Albany Withholding Public Records in Mount Tabor Road Land Grab."

The Indiana Public Access Counselor has affirmed that the city of New Albany has unlawfully denied public records to a landowner who is pushing back against the city’s use of eminent domain in a Mount Tabor Road expansion project.

I'm happy to see Insider Louisville step up; meanwhile, over yonder lies Hanson's 'Bama Folly, scooped once again. Apparently the N & T is delighted to receive tips about New Albany stories, just as long as they can't be traced to NA Confidential.

Remind me again: Why have I been sending website traffic to their advertising clickers in good faith these past 12 years?

Verily, you can trust those corporate types ... they'll ALWAYS let you down.

City of New Albany, residents head to court over road improvement project, by Caitlin Bowling (IL)

The city of New Albany is trying to use eminent domain to secure land from more than a dozen property owners for the Mt. Tabor Road Restoration and Pedestrian Safety project, but some property owners have raised concerns about the plan.

Earlier this month, the city filed complaints in Floyd County Circuit Court against 17 property owners asking the court to rule that the city can take ownership of a portion of their properties that run along Mt. Tabor Road. The property will allow the city to reconstruct nearly 1.1 miles of road, install full curbs and gutters, and build sidewalks on both sides of the road.

SNIP

 ... In a letter to the Indiana Department of Natural Resources, Dennis Feiock, who owns property at the corner of Mt. Tabor Road and Klerner Lane, said residents don’t oppose improvements to the road, but adding two sidewalks is superfluous and would create more impervious surfaces in an area with flooding problems.

“From all the discussion on this subject over the past 4 years, it has become apparent that the only person supporting dual sidewalks at this location is the Mayor of New Albany,” Feiock wrote in the email ...

Wednesday, March 22, 2017

Shane Gibson is unaccountable yet again as "City of New Albany Withholding Public Records in Mount Tabor Road Land Grab."


(6:00 p.m. update: Typo has been corrected in banner)

(6:30 p.m. update: Receveur has launched a web site where you can read all the documents pertaining to this case: New Albany Land Grab)

Following is a press release, courtesy of local businessman Colin Receveur. Municipal corporate counsel Shane Gibson's cavalier disregard for public information requests is legendary. I'm delighted to him snared in arrogance of his own making. But just remember that taking metaphorical bullets for the mayor is why Gibson gets the big money -- the really, really big money. Jeff Gahan's the one who should be answering for this, isn't he?

---

City of New Albany Withholding Public Records in Mount Tabor Road Land Grab

New Albany, IN — The Indiana Public Access Counselor has affirmed that the city of New Albany has unlawfully denied public records to a landowner who is pushing back against the city’s use of eminent domain in a Mount Tabor Road expansion project.

Colin Receveur — a local business owner, entrepreneur, and land developer — had sent three formal requests for the city of New Albany to supply building permits, curb cut, and driveway permit for two of his properties, 815 and 819 Mount Tabor Road. These are two of the many properties being affected by the city’s long and winding $6.5 million federally funded project to repair drainage and erosion issues and provide sidewalk space.

All of Receveur’s requests for public records to the city were denied without cause. Luke H. Britt, Indiana’s public access counselor, has found that those denials have put the city of New Albany in violation of Indiana Public Records Access Act.

“The city has switched gears and project proposals more times than I can count, and the property owners affected by the project are being left in the dark,” Receveur said.

“This recent decision to keep public records out of the hands of property owners makes it plain to see that the city is expecting landowners to cough up their properties in exchange for unjust sums and virtually zero documentation.”

Receveur appealed to the Indiana Public Access Counselor after outright public record refusals from New Albany City Attorney Shane Gibson, members of the New Albany City Council, and members of the New Albany Board of Works and Safety.

Receveur isn’t the only New Albany landowner upset with the city’s handling of the Mount Tabor Road project. Residents have packed city councils meetings to oppose the project, and Receveur has compiled 117 pages of complaints.

“It’s unfortunate that the city is ignoring such a large portion of its constituents,” Receveur said. “This has been a boondoggle from start to finish. It’s a project that is said to help erosion issues on the road, but the city’s tactics have eroded the trust between local landowners and our local government.”

Receveur’s chief concern is the fate of his apartment building at 815 Mount Tabor Road. The city’s proposal will snatch all six of the available parking spaces for the apartment residents. The plan brings a dangerous change to Receveur’s tenants and his business.

He worries that his business will not be able to operate under the proposed road changes. Even worse, he said his current tenants will not have access to available parking and may have to park their vehicles across Mount Tabor Road or the busy Grant Line Road.

The city has informed Receveur that those parking spaces at 815 Mount Tabor Road are unpermitted but has denied document verification. Receveur said he hopes the Indiana Public Access Counselor decision helps other local residents who have also been denied records or explanations from the city.

“Our goal here is to have the city provide adequate documentation, transparency, and just compensation,” Receveur said. “Right now, the city of New Albany is asking us to forfeit our land but is slamming the door in our faces when we request documentation that we are legally entitled to see.”

For more information, contact Colin Receveur at 502-443-1082 or creceveur@gmail.com

Wednesday, October 26, 2016

SHANE'S EXCELLENT NEW WORDS: Indiana Public Access Counselor.

Welcome to another installment of SHANE'S EXCELLENT NEW WORDS, a regular Wednesday feature at NA Confidential.

But why all these newfangled words?

Why not the old, familiar, comforting words, like the ones you're sure to hear when asking the city's corporate attorney why the answers to my FOIA/public records request for Bicentennial commission finances, due to be handed over on July 8, still haven't arrived on October 26?

Bicentennial commission financial trail? What's two (yawn) weeks (shrug) after 463 days?

October 26 update: Make that 16 weeks since the FOIA record request's due date and 560 days since I asked Bullet Bob Caesar to tell us how many coffee table books were left unsold, and how much the city's 200-year "summer of love" fest actually cost us. 

No, it's because a healthy vocabulary isn't about intimidation through erudition. Rather, it's about selecting the right word and using it correctly, whatever one's pay grade or station in life.

Even these very same iniquitous, paving-bond-slush-engorged municipal corporate attorneys who customarily are handsomely remunerated to suppress information can benefit from this enlightening expansion of personal horizons, and really, as we contemplate what they knew and when they knew it, all we have left is plenty of time -- and the opportunity to learn something, if we're so inclined.

Consequently, today's word is a phrase: Indiana Public Access Counselor.

Mission Statement

The Public Access Counselor provides advice and assistance concerning Indiana's public access laws to members of the public and government officials and their employees.

Resources


A copy of my original request for information from the city of New Albany:

Roger A. Baylor
NA Confidential
1117 East Spring Street
New Albany, Indiana 47150

10 June 2016

Shane Gibson
Corporate Attorney
City of New Albany, Indiana
Hauss Square
New Albany, Indiana 47150

Dear Mr. Gibson:

Under the Indiana Access to Public Records Act § 5-14-3-1 et seq., I am requesting an opportunity to obtain copies of public records that pertain to the financial dealings of the Bicentennial Commission, the creation and operation of which is detailed in New Albany’s code of ordinances (33.165; attached).

The period being requested encompasses the Bicentennial Commission’s inception through the present time.

Details should include all bids, contracts and expenditures for Bicentennial Commission activities, prime among them the process through with the Bicentennial book (“Historic New Albany, Indiana: By the River’s Edge,” by James Crutchfield) was contracted, published and sold, and the status of the Redevelopment Commission’s loan to make publication of this volume possible.

As part of this request, I am requesting to know the current status of inventory with regard to these books. If books remain unsold, how many remain, and where are they stored? Also, when a Bicentennial book is given away at a public ceremony, who paid for it? These invoices are to be considered part of this request.

As part of this request, I am further requesting copies of the official e-mail correspondence between Robert Caesar and other members of the Bicentennial Commission pertaining to these plans and transactions.

I would also like to request a waiver of all fees in that the disclosure of the requested information is in the public interest and will contribute significantly to the public’s understanding of what it cost to honor the city’s Bicentennial, and how these decisions were made, under the aegis of a free press (NA Confidential blog). My request is strictly for news gathering purposes and is not being sought for commercial purposes.

The Indiana Access to Public Records Act requires a response time within seven business days. If access to the records I am requesting will take longer than seven days, please contact me with information about when I might expect copies of the requested records.

If you deny any or all of this request, please cite each specific exemption you feel justifies the refusal to release the information and notify me of the appeal procedures available to me under the law.

Thank you for considering my request.

Sincerely,

Roger A. Baylor
1117 E. Spring St.
New Albany IN 47150
mayorbaylor@gmail.com
502-468-9710

The city's corporate attorney has been informed of PAC's receipt of my complaint, and PAC promises a decision by December 5.

I'll keep you informed. Have they laundered all the paving stone books yet?

Thursday, June 27, 2013

My note to the Indiana Public Access Counselor, informing the office of my request of the Floyd County Health Department.


Just in case of stonewalling. 

Having received a choice bit of unsolicited advice, for which I'm quite grateful, I've sent the following note to the State of Indiana's Public Access Counselor, providing details of the ongoing PourGate imbroglio, wherein the Floyd County Health Department decides to begin inventing interpretations from thin air

It may at last be time to contact the state health department, although so far, at least two calls have been made, with no coherent reply.

This is becoming somewhat fun.


-----

Good day,

I have sent the following letter to the Floyd County Health Department. The reply I've gotten after four business days is that my request has been forwarded to the board's attorney for review, and that the attorney will be contacting me. I am confused, given that your template shows replies and actions emanating from the agency itself, not the agency's attorney.

I am making this request because recently, for the very first time ever, the Health Department has been enforcing temporary food service permits for beer vendors, hitherto under the control of the ATC and permitting procedures of the ATC. The Health Department is not being forthcoming in providing evidence of some as yet undisclosed change in the law. I am asking for five years' citation history in order to determine whether the department's claim to have been enforcing this "all along" is accurate.

Thanks for you input into this situation.

-----

Roger A. Baylor
1117 E. Spring Street
New Albany IN 47150
502-468-9710

June 21, 2013

Floyd County Health Department
Attn.: Dr. Tom Harris
1917 Bono Road
New Albany IN 47150
(Hand Delivered)

Re: Public Records Request

Dear Dr. Harris:

The Floyd County Health Department is a public agency as defined by Indiana Statute. Pursuant to Indiana Public Access statutes (Indiana Code 5-14-3), I am requesting copies of all citations and/or tickets issued by the Floyd County Department of Health to any vendor, person, company and/or individual regarding “Temporary Food Service Permit” for the last five (5) years. In addition, I am requesting that each citation and/or ticket be identified as to whether those cited were serving food or alcoholic beverages.

If there is a cost associated with this request, please inform me of the amount. I look forward to the response and compliance with this request. If you have any questions, please feel free to contact me.

Roger A. Baylor