DENIED:  May 14, 2009 
CBCA 1264 
SOUTHWESTERN SECURITY SERVICES, INC., 
Appellant, 
v. 
DEPARTMENT OF HOMELAND SECURITY, 
Respondent. 
Edward Gregorowicz, Jr., of the Law Offices of Edward Gregorowicz, Jr., Fairfax, 
VA, counsel for Appellant. 
Christine L. Krell, U.S. Immigration and Customs Enforcement, Department of 
Homeland Security, Washington, DC, counsel for Respondent. 
Before Board Judges SOMERS, GILMORE, and POLLACK. 
SOMERS , Board Judge. 
Southwestern Security Services, Inc. (Southwestern) seeks reimbursement for 
additional expenses related to guard services provided to the Department of Homeland 
Security (DHS or the Government), Federal Protective Service, in southern Louisiana, 
immediately post-Hurricane Katrina.  The parties have elected to submit this appeal for 
decision on the written record pursuant to Rule 19 of the Board’s Rules of Procedure.  The 
record consists of the pleadings, appeal file, Southwestern’s memorandum of points and 
authorities in support of its record submission, the Government’s memorandum of law in 
support of its record submission, and Southwestern’s reply brief in support of its record 
submission.  For the reasons set forth below, we deny the appeal. 

 
 
 
    
  
 
   
 
 
  
 
  
     
    
  
2 CBCA 1264 
Background 
On June 30, 2005, Southwestern and the Government entered into Contract No. 
GS-07F-0306L, Task Order No. HSCEFC-05-F-F00014 (the contract).  Pursuant to the task 
order, Southwestern agreed to provide armed guard services at federal buildings and facilities 
located in the southern part of Louisiana.  Appeal File, Exhibit 1.
1   The contract began on 
July 1, 2005, and was in effect when Hurricane Katrina made landfall in Louisiana in August 
2005.  Answer ¶ 10.  
Pursuant to the contract, Southwestern provided guards for specific posts for a firm 
fixed hourly rate.  The statement of work (SOW) contained instructions to be used for 
preparing the proposed rate, and required Southwestern to include all direct costs, indirect 
costs, and profit in its proposed hourly rate. When the Government awarded the task order 
to Southwestern, the firm fixed hourly rate proposed by Southwestern formed the basis for 
the contract price.  Exhibit 1 at 99-101.  The contract required Southwestern to provide 
approximately eighty guards per month for regular, permanent posts.  Exhibit 1; 
Government’s Memorandum of Law, Attachment 2.  
As part of the contract requirements, in addition to providing guard services for the 
permanent posts, Southwestern had to maintain a reserve guard force of sufficient size to 
enable it to provide the amount of temporary or emergency staffing needed in the event of 
natural disasters, civil disturbances, emergencies, and other situations.  Exhibit 1 at 18.  As 
with the firm fixed hourly rate for the permanent guard posts, the SOW required 
Southwestern to factor the costs for maintaining a reserve guard force into the bid price.  The 
SOW warned that the contractor would not be reimbursed for additional costs outside of the 
fixed hourly rate once the task order was awarded.  Exhibit 1 at 18-19. As to the costs of the 
temporary posts, the SOW stated expressly that:  
c. The hourly prices that are offered on your production 
spreadsheets shall be the same hourly prices that will be paid for 
TAS/SAS [Temporary Additional Services/Special Additional 
Services].  These prices shall be inclusive of all the Offeror’s 
direct costs, indirect costs, and profit.  Offerors shall include all 
costs associated with providing the services described in and 
required by this SOW.  
1
 All exhibits are found in the appeal file, unless otherwise noted. 

 
 
   
   
    
 
     
 
 
 
    
  
 
 
3 CBCA 1264 
d. The Government  shall not  be responsible for 
compensating the Contractor for any costs tied to 
Solicitation/Contract requirements but not factored into the 
Contract prices, either by the Contractor’s intention or by 
mistake.  
Exhibit 1 at 102 (emphasis in original).  
Under the contract, either the contracting officer (CO) or the contracting officer’s 
technical representative (COTR) could modify, amend, and/or revise the shift duties, start 
and stop times, and post locations, so long as the change did not impact the overall contract 
price.  Exhibit 1 at 9.  The COTR could divert uniformed personnel from their usual assigned 
duties.  Id . at 13.  However, only the contracting officer could make changes to the terms and 
conditions of the contract, and those changes had to be in writing:  
Changes to the post orders that increase or decrease the number 
of hours specified, increase or decrease the amount of 
equipment/supplies required, or otherwise affect the 
Contractor’s cost or the Task Order price, must be made by the 
CO through a written modification to the Task Order.  The 
Contractor may be financially liable for accepting or 
implementing changes made by any unauthorized FPS 
personnel or tenant agency staff other than the CO; 
therefore, the Contractor shall be responsible for verifying 
with the CO whether any requested changes should be 
provided pending issuance of a modification. 
Id. at 9 (emphasis in original).  The contract required the contractor to report to the CO any 
requested work that it believed was outside the scope of the contract and, therefore, not 
included in its firm fixed rate.  Id . at 3-4, 9. 
When Hurricane Katrina weather forecasts projected a path directly impacting the area 
of southern Louisiana, the Federal Emergency Management Agency (FEMA) anticipated that 
it would need additional guards to support the increased requirements that would arise as a 
result of the emergency conditions.  Accordingly, FEMA asked DHS to obtain guards to 
provide temporary services for various locations and posts in New Orleans.  Deposition of 
Contracting Officer John Quackenbush (Nov. 5, 2008) (Quackenbush Deposition) at 21. 
FEMA immediately provided additional funding to cover the services requested.  Deposition 
of Pamela Briggs (Nov. 5, 2008) (Briggs Deposition) at 28; Quackenbush Deposition at 
86-87.  Pamela Briggs, the COTR, contacted Southwestern on August 28, 2005, and asked 

  
    
 
   
 
 
 
 
 
 
 
  
 
     
 
   
   
  
 
 
4 CBCA 1264 
whether Southwestern would be able to provide temporary guard services in support of 
FEMA’s request if Hurricane Katrina made landfall in southern Louisiana.  Deposition of 
Jose Manuel Morales (Nov. 12, 2008) (Jose Morales Deposition) at 13, 17-18; Briggs 
Deposition at 24, 62-63. If Southwestern could not or would not fulfill the requirement, the 
Government could contract with other guard companies.  Jose Morales Deposition at 23-25; 
Briggs Deposition at 19-20; Deposition of Joseph Michael Morales (Nov. 12, 2008) (Joseph 
Morales Deposition) at 29-30.  Southwestern voluntarily agreed to supply the additional 
guard services as requested.  Jose Morales Deposition at 23.  The initial request, on 
August 28 and 30, sought four guards for one FEMA facility.  Government’s Record 
Submission, Attachment 1.  At the same time, immediately after the hurricane, most of 
Southwestern’s guards in the New Orleans area (approximately fifty guards) no longer 
performed guard services as required under the contract because most of the federal buildings 
were closed.  Jose Morales Deposition at 21; Joseph Morales Deposition at 20, 39.  
The parties contacted each other numerous times over the course of the next few days. 
On September 6, 2005, Jose Morales of Southwestern contacted Ms. Briggs by electronic 
mail (email):  
I know that you are very busy, but I really need to get the 
documentation for all the services that you have requested us for 
FEMA.  Please send me the documentation as soon as possible. 
Also, I need to get the letter about the extra expenses incurred 
by our company due to Katrina that you told me that you were 
going to send me. 
. . . [W]e also need for you to send us documentation on what 
requirements will be waived in order for us to work out guards 
there in Louisiana.  We need this ASAP as well because we are 
in the process of moving guards to Louisiana to fill all the posts 
that FPS is requesting for FEMA and Additional Services.  We 
don’t want to move guards that will not be allowed to work.  We 
also need to know if there will be some type of housing and food 
provided to them by FEMA. Joseph advised that either you or 
Mr. Boyle had told him that FEMA would provide a place for 
them to stay. I need to know this because if FEMA is not going 
to put them up, then we would need to find something for them. 
Exhibit 2.  Ms. Briggs responded on September 7, 2005, also by email: 

 
 
 
 
 
 
 
 
 
 
  
 
 
   
 
5 CBCA 1264 
Jose -- I am working on the confirmation of service letters right 
now.  There is no letter about the extra expense incurred by your 
company in relation to the disaster.  I advised you to have SWSS 
[Southwestern] keep track of any additional expenses incurred 
due to the emergency situation and that from prior experience, 
someone there should know how to proceed with this 
information.  I cannot advise you on this, but can encourage you 
to look into this further.  
The only locations that were going to be provided lodging and 
meals were those guards assigned to the Critical Infrastructure 
Protection posts.  Originally, the Office of Emergency 
Preparedness was trying to lodge and feed all first responders 
but due to the volume of personnel needing these services, has 
had to suspend until further notice.  
Exhibit 2.
2 
By letter dated September 8, 2005, Jesse Morales, the president of Southwestern, 
requested that the hourly rate be increased from $21.05 to $32 for all FEMA and other 
Hurricane Katrina-related additional services.  He noted that the last time that Southwestern 
provided FEMA services, during the Columbia Space Shuttle disaster, it received $32 per 
hour for services provided during the crisis.  Exhibit 3.  
Southwestern sent a second letter dated September 14, 2005, in which it itemized 
various expenses that it had incurred in support of FEMA’s request for additional services. 
Southwestern claimed that it purchased a motor home to use as a command center. 
Southwestern listed the following expenses:  
One Time Expenses 
Conversion of trailer to sleeping quarters $8,500 
10,000 watt generator   3,800 
30 foot shelter tent   2,100 
Portable 200 gallon water tank with gas water pump   1,300 
Lighting equipment  400 
F a n s      4 0 0 
2
 Ms. Briggs testified that she did not know specifically what these additional 
expenses included.  Briggs Deposition at 35.  

  
  
 
      
    
       
 
 
 
   
      
 
 
 
6 CBCA 1264 
Cots ($70 each x 20)
Uniforms ($387.54 per guard x 20)
Weapons ($250 per guard x 20)
  1,400 
  7,750 
  5,000 
Recurring Expenses 
Command Center (per month) 
Fuel (per month)
Meals and Drinks ($25 per guard x 20)(daily)
Portable toilets rental (each per month)
Portable showers rental (each per month)
Guard transportation (daily)
$1,000 
  1,000 
500 
110 
150 
60 
Exhibit 4.  
By letter dated September 28, 2005, in response to Southwestern’s claim for expenses, 
the contracting officer, John Quackenbush, stated that “the Government cannot agree to 
reimburse Southwestern Security Services, Inc., for company-owned equipment.  Should any 
reimbursement be agreed to by the Contracting Officer, based upon the above, such approved 
property shall become Government-furnished property . . . .  The Government will not agree 
to reimbursement for uniforms, as you are required to purchase uniforms for your armed 
guards performing under your Task Order.”  Exhibit 5.  The contracting officer requested 
Southwestern identify who directed it to incur the claimed costs, and to specify when the 
order occurred. In addition, the contracting officer requested that Southwestern provide 
additional details about the costs claimed, including, for example, identifying the location of 
the command center, trailer, generator, tent, and other equipment for which it was seeking 
reimbursement.  Id.  Southwestern did not respond to the contracting officer’s request at that 
time. 
During the next few months, DHS requested between thirty-five to forty guards per 
month to perform temporary FEMA-related guard services.  The Government agreed to 
modify the contract to increase the wages to the higher firm fixed rate of $32 per hour, and 
agreed to apply the rate retroactively to include all guard services performed for FEMA. 
Exhibits 3, 7; Briggs Deposition at 56. The parties increased the hourly rate to cover “all the 
extra expenses that were being incurred by having to supply all those guards due to the 
emergency.”  Jose Morales Deposition at 32.  The parties eventually signed a bilateral 
modification on February 7, 2006, memorializing the agreement.  The modification stated, 
in part:  
a. This modification is issued for separate additional guard 
services required by FEMA due to Hurricane Katrina at various 

   
  
 
  
 
 
 
   
    
 
 
 
 
     
7 CBCA 1264 
southern Louisiana locations and hours as indicated in the 
attached [Southwestern] invoice numbers 701-706, covering the 
period of August 29, 2005 through November 30, 2005.   
b. The previously negotiated productive hourly rate of $32 
is limited to FEMA disaster-related armed guard service. 
Exhibit 7. The modification did not address Southwestern’s request for additional expenses. 
Ultimately, Southwestern submitted its claim for $73,275, for extra expenses, on 
August 22, 2007.  On December 10, 2007, Southwestern identified the COTR, Ms. Briggs, 
as the person who had authorized reimbursement for the expenses.  Exhibit 11.  In her 
deposition testimony, Ms. Briggs denied that she authorized the additional expenses.  Briggs 
Deposition at 36, 52, 73.  Her testimony is consistent with her email message of September 7, 
2005. 
DHS denied Southwestern’s claim by letter dated February 22, 2008, on the grounds 
that the contracting officer did not authorize the expenses.  Exhibit 12.  Southwestern 
submitted additional information on April 4, 2008, and reduced its claim to $44,000.  The 
contracting officer denied the claim again on April 11, 2008, on the ground that 
Southwestern failed to provide any documentation to support its claim.  Exhibit 13. 
Southwestern filed its appeal on July 9, 2008, and, in its complaint, asserts entitlement to 
damages of $43,723.69, plus applicable interest, alleging breach of a contract implied in fact. 
Discussion 
The Positions of the Parties 
Southwestern’s theory is that the additional services provision relied upon to obtain 
guard services can only apply to the Government’s short-term, non-recurring needs for 
services.  This provision cannot cover the additional services ordered by DHS, says 
Southwestern, because the services extended for almost one year and involved more guards 
than the amount of guards called for under the original contract.  Appellant’s Memorandum 
of Points and Authorities in Support of its Record Submission at 8-9.  Thus, when the 
contracting officer’s technical representative contacted appellant for additional guard 
services for FEMA support, this request did not fall within the scope of the contract.  An 
implied-in-fact contract arose between the parties, and as a result, the Government must 
reimburse Southwestern for its additional expenses.  In Southwestern’s view, the 
Government knew that it could not provide the services without incurring the additional 
expenses. Thus, according to the contractor, when the Government ordered the services 

  
   
 
  
    
 
 
    
   
   
   
      
  
 
    
 
  
8 CBCA 1264 
anyway, it had acquiesced to paying for the expenses, either under an implied-in-fact contract 
theory or under an institutional ratification theory.  
The Government disagrees.  It contends that this firm fixed price contract anticipated 
any claimed increased costs, including those related to the provision of temporary guard 
services. The contract did not limit the additional services to a specific time period or 
number of guards.  In fact, the Government points out that the number of guards provided 
by Southwestern did not actually increase. The actual number of temporary guards provided 
by Southwestern, approximately forty guards, represented fifty percent of its monthly 
permanent guard force.  After the hurricane, many of the permanent posts did not require 
guards because the federal buildings had closed.  Thus, the Government concludes, 
Southwestern was not providing significantly more, if any more, guards than it usually 
provided. In any event, even if DHS were liable for the costs, the Government asserts that 
Southwestern received compensation through the increase in the firm fixed rate paid for 
FEMA services. 
Second, the Government asserts that if Southwestern believed that the contracting 
officer’s technical representative’s request for additional services fell outside the scope of 
the original contract, the contract required it to immediately notify the contracting officer. 
Southwestern’s failure to tell the contracting officer that it considered the orders to be outside 
the contract prevents it from receiving additional reimbursement for the expenses, according 
to the Government.  No implied-in-fact contract arose from these circumstances.  
Firm Fixed Price Contract 
It is undisputed that the contract was a firm fixed price contract.  It is well-established 
that absent a special adjustment clause, a contractor with a fixed price contract assumes the 
risk of increased costs not attributable to the Government.  Gulf Shores, LLC v. Department 
of Homeland Security , CBCA 802, 09-1 BCA ¶ 34,024 (2008).  
Here, the parties agreed that compensation for guard services would be paid through 
fixed hourly rates, to include all direct and indirect expenses, as well as profit.  The contract 
contemplated that Southwestern would provide additional guard services in response to 
natural disasters, with compensation provided in accordance with the temporary or special 
additional services provisions.  The fact that Southwestern’s performance was rendered more 
burdensome or costly due to the severity of Hurricane Katrina does not entitle the contractor 
to compensation beyond that provided for in the contract.   Gulf Shores, LLC , 09-1 BCA at 
168,305 (citations omitted). 

  
      
 
  
 
 
    
    
  
        
 
 
    
  
  
      
  
    
   
9 CBCA 1264 
In fact, Southwestern knew that additional expenses should be included in the hourly 
rate, and it sought an increase in that rate in light of the unexpected scope of the emergency. 
The Government agreed to modify the contract at Southwestern’s request, increasing the 
hourly rate paid for guard services in order to cover Southwestern’s unanticipated increased 
expenses, including housing, through a bilateral modification to the contract.  The evidence 
in the record supports the conclusion that the hourly rate had been increased to cover these 
expenses. Southwestern has not produced any evidence to support its claim that the parties 
intended that the Government would assume any risk if appellant incurred unanticipated 
expenses.  Since the contract did not obligate the Government to pay any expenses not 
encompassed in the hourly rate, we conclude that Southwestern’s claim for additional 
expenses must be denied. 
Implied-In-Fact Contract 
Southwestern’s theory that an implied-in-fact contract arose when the contracting 
officer’s technical representative ordered the additional services in support of FEMA does not 
lead to a more successful resolution.   The requirements for an implied-in-fact contract are the 
same as for an express contract; only the nature of the evidence differs.  An implied-in-fact 
contract is founded upon a meeting of the minds and is “inferred, as a fact, from the conduct 
of the parties showing, in light of the surrounding circumstances, their tacit understanding.” 
Hercules, Inc. v. United States , 516 U.S. 417, 424 (1996) ( quoting Baltimore & Ohio R. Co. 
v. United States , 261 U.S. 592, 597 (1923)); see also Flexfab, L.L.C., v. United States , 
424 F.3d 1254, 1265 (Fed. Cir. 2005).  In order to prove an implied-in-fact contract with the 
Government, appellant must demonstrate: (1) mutuality of intent; (2) consideration; (3) an 
unambiguous offer and acceptance; and (4) “actual authority” on the part of the Government 
representative.  Flexfab, 424 F.3d at 1265; see Federal Crop Ins. Corp. v. Merrill , 332 U.S. 
380, 384 (1947).  
In this case, no one disputes that the contracting officer’s technical representative had 
the authority to order the additional services for FEMA support under the terms of the 
contract. Indeed, Southwestern’s argument is premised upon this in part -- the theory is that 
because the COTR could legitimately order these services under the contract, she could also 
agree on behalf of the Government to pay for the additional expenses, which, in the words of 
the contractor, are “part and parcel” of the FEMA additional services.  Appellant’s 
Memorandum at 12.    
 Southwestern’s main argument, however, is that these additional services fall outside 
the contract, and so the obligation to pay Southwestern’s extra expenses was not governed by 
the contract (and, ultimately, not limited by the fixed pricing in the contract.).  The issue, then, 
is not whether the contracting officer’s technical representative had authority to bind the 

 
  
   
  
   
 
  
   
   
 
10 CBCA 1264 
Government under the contract, but, instead, whether the contracting officer’s technical 
representative had authority to bind the Government independent of the contract.   See H. 
Landau & Co. v. United States , 886 F.2d 322, 324 (Fed. Cir. 1989) (limiting inquiry to 
whether government officials possessed binding authority).   
Actual authority may be express or implied.  Anderson v. United States , 344 F.3d 1343, 
1353 n.3 (Fed. Cir. 2003). A Government agency possesses express actual authority to bind 
the Government in contract only when the Constitution, a statute, or a regulation grants it to 
the agency in unambiguous terms.  City of El Centro v. United States , 922 F.2d 816, 820 
(Fed. Cir. 1990).  
Here, the applicable regulation, the Federal Acquisition Regulation (FAR), provides 
in pertinent part:  
Contracts may be entered into and signed on behalf of the 
Government only by contracting officers.  
48 CFR 1.601(a) (2004).  The FAR further provides: 
(a) Contracting officers have authority to enter into, 
administer, or terminate contracts and make related 
determinations and findings. Contracting officers may bind the 
Government only to the extent of the authority delegated to them.
 . . . 
(b)  No contract shall be entered into unless the contracting 
officer ensures that all requirements of law, executive orders, 
regulations, and all other applicable procedures, including 
clearances and approvals, have been met. 
48 CFR 1.602-1. Furthermore, the FAR provides that “only contracting officers acting within 
the scope of their authority are empowered to execute the contract modifications on behalf of 
the Government.”  48 CFR 43.102(a);  see also Corners and Edges, Inc. v. Department of 
Health and Human Services , CBCA 648, 07-2 BCA ¶ 33,706, at 166,891; Flexfab, 424 F.3d 
at 1260 (“A party seeking to enter into an agreement with the government can abate the risk 
by taking particular care to insure [sic] that it negotiates with a government agent whose status 
is that of a ‘contracting officer.’”)  
Southwestern posits that the “authorization for the reimbursement of the extra expenses 
comes not from the contract, but from the terms under which Ms. Briggs orally requested the 

   
  
 
  
      
 
 
     
 
  
 
    
   
       
 
 
       
 
11 CBCA 1264 
services and Southwestern orally accepted the order.”  Appellant’s Memorandum at 14-15. 
Outside of this bold conclusion, Southwestern has not provided any evidence to show that the 
contracting officer’s technical representative had any authority to bind the Government.  As 
mentioned above, to the extent that she had authority to issue orders for services, that 
authority arose from the terms of the contract -- contract terms which, under Southwestern’s 
theory, are inapplicable here.  
Without any evidence that the contracting officer’s technical representative had been 
expressly granted authority to bind the Government, we turn to examine whether the COTR 
possessed implied actual authority to contract on behalf of the Government based on her 
position.  A government official with implied actual authority can bind the Government 
“when such authority is considered to be an integral part of the duties assigned to a 
government employee.”  H. Landau & Co. , 886 F.2d at 324 (quoting John Cibinic, Jr. & 
Ralph C. Nash, Jr.,  Formation of Government Contracts  43 (1982)).  Contracting authority 
is integral to an employee’s duties when the employee cannot perform the assigned tasks 
without such authority and when the relevant agency’s regulations do not grant the authority 
to other agency employees.  Id . 
In this case, the express language of the contract stated that only the contracting officer 
could make changes to the terms and conditions of the contract affecting price (and those 
changes had to be in writing). At the very least, the contract placed Southwestern on notice 
as to the limited authority of the contracting officer’s technical representative.  Southwestern 
should have investigated further into the issue of authority when it believed that it was 
entering into a separate contract with the contracting officer’s technical representative.  We 
find that the contracting officer’s technical representative’s actions cannot be considered to 
bind the Government in a separate contract. 
Institutional Ratification 
Finally, Southwestern argues that even if Ms. Briggs did not expressly authorize the 
extra expenses at the time that she ordered the services, “contracting principles and 
fundamental fairness dictate that they be deemed institutionally ratified by the agency’s 
actions.” Appellant’s Memorandum at 15.  Institutional ratification of an implied-in-fact 
contract may occur where a government agency accepts benefits followed by a promise of 
payment by the agency.  Janowsky v. United States , 133 F.3d 888, 891-92 (Fed. Cir. 1998); 
D&F Marketing, Inc. , ASBCA 56043, 2009 WL 810850 (Mar. 9, 2009).  A key element of 
institutional ratification is knowledge of all the facts related to unauthorized action by officials 
who are empowered to ratify agreements.  City of El Centro , 922 F.2d at 821; Gary v. 
United States , 67 Fed. Cl. 202, 217 (2005).  

  
  
     
   
 
 
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12 CBCA 1264 
Here, there is no evidence that either an authorized official or DHS as an institution 
ratified Southwestern’s request for reimbursement of its costs.  As noted previously, the 
contracting officer and the contracting officer’s technical representative both testified that 
they were unaware of the specifics of Southwestern’s additional costs, only that the contractor 
sought reimbursement of certain costs.  In addition, the contracting officer and the contracting 
officer’s technical representative clearly informed Southwestern that the Government would 
not pay any of Southwestern’s additional costs.  In fact, as discussed previously, in his 
September 28, 2005, letter to Southwestern, the contracting officer told Southwestern that it 
would not be entitled to reimbursement for any additional expenses incurred without 
authority, and specifically asked Southwestern to provide information to support its claim, 
which Southwestern failed to provide until two years later.  Nothing in the record supports 
Southwestern’s contention that the agency, or, specifically, officials with ratifying authority, 
knew about the alleged promise to Southwestern to pay for expenses in addition to paying the 
negotiated hourly rate for temporary additional guard services, accepted the benefits of the 
promise, and took actions to ratify the promise.  
Decision 
The appeal is hereby DENIED . 
JERI KAYLENE SOMERS 
Board Judge 
We concur:  
BERYL S. GILMORE HOWARD A. POLLACK 
Board Judge Board Judge