DEPARTMENT OF 

-.^ET OPERATIONS 

^ ' 1 AUG 25 P 2: i \ 

U. S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC. 

IN THE MATTER OF 

EMPIRE AIRWAYS 

Respondent ^^ ^ loU<er A 

FAA DOCKET NO. GTIOCAOOOS " CPi O £ A OOO t 

(Civil Penalty Proceeding) 

DMSN0.FAA-2&W-SWi-— f^^ ^ ^^ ^ ^^ ' 

HONORABLE ISAAC D. BENKIN 

ADMINISTRATIVE LAW JUDGE 

RESPONDENT'S NUNC PRO TUNC APPLICATION 

FOR AN AWARD OF ATTORNEY FEES AND OTHER EXPENSES 

PURSUANT TO THE EQUAL ACCESS TO JUSTICE ACT (EAJA) 

COMES NOW, Empire Airways, Respondent herein, by and through undersigned 

cqunscl, and pursuant to 5 U.S.C. §504 hereby applies for attorney fees and other expenses 

incurred fn the Matter of Empire Airways, FAA Docket No. C?l OEA0002 (Civil Penalty).' 

The following points are made in support of this application; 

' Although the Honorable Isaac D, Bcnkin, Adminislrative Law Judge, served an Order 

Dismissing Proceeding and Canceling Hearing on June 23,2010, Respondent's counsel of 

record never received a copy of the Order until July 26,2010. The lack of service of the 

Order was caused by a clerical error. Specifically, Respondent's counsel, Gregoiy S. 

V/inton, filed a Notice of Appearance and Substitution of Counsel on June 1, 2010, and a 

Notice of Appearance on July 6,2010. However, by no fault of Respondent or its counsel, 

I 

8LO/L00ia SWO <• VVd StLS8GtZ02 XVd 38:21 0L02/SS/80 
The official record discloses that on June 23,2010, the Honorable Isaac D. Benkin, 

Administrative Law Judge, issued an Order Dismissing Proceeding and Canceling Hearing, 

thereby dismissing all of the charges against Applicant, with prejudice. As such. Applicant 

is the prevailing party. 

As more fully discussed below, the Administraior was not substantially justified in 

commencing the complaint and there are no special circumstances which would make an 

award unjust. As a result. Empire Airways Incurred attorney fees and expenses in excess of 

$4,980.00. 

Therefore the Respondent must be awarded the cost of attorney fees and expenses. 

LEGAL AUTHORITY 

Under the Equal Access to Justice Act (EAJA), a prevailing party may recover 

reasonable litigation costs if the agency's positions in the underlying litigation was not 

"substantially justified." 5 U.S.C. §504(a)(l). The Act provides for the award for aitomey 

fees and other expenses to eligible individuals and entities who are parties to certain 

adminisuative proceedings before agencies such as the Federal Aviation Administration 

(FAA). 

counsel, Mr. Winton's name was never added to the law judge's service list. 

Accordingly, this application is timely made as if the law judge's Order was served upon 

Mr. Winton on July 26,2010, when he first received a copy via facsimile and email. 

2 

810/200 0 SWQ * VVd 31?LSSei7202 XVd 2S:SL 0L0S/S2/8 0 
The purpose of Equal Access to Justice Act is to eliminate financial disincentive to 

challenge unreasonable goverrmient actions, not to conserve financial resources. Richard v 

Hinson (1995. CA3) 70 F3d415, cert. den. (1996) 518 US 1004, 135 L Ed 2d 1047, 116S 

Cr 2322. Legislative history of the Equal Access to Justice Act is cleai- that Congress 

intended it to be remedy for individuals and small businessmen who face tremendous costs 

of litigation against the federal government. Fidelity Consir. Co. (1982, DOT BCA) 82-1 

BCA P 15633, o^d (1983, CA) 700 F2d 1379. 30 CCF P 70827, cert. den. (1983) 464 US 

826, 104 S O 97, 78 L Ed 2d 103 and (superseded by statute on other grounds as stated in 

Maitland Bros. Co. (1986, ASBCA) 86-2 BCA P 18796) and (superseded by statute on 

odier grounds as staled in Great Western Utiliiy Corp. (1986, ENG BCA) 86-3 BCA P 

19011) and (superseded by statute on other grounds as stated in Escobar v U.S. INS (1991, 

CA4) 935 F2d 650). 

An eligible party may receive an award when it prevails over the FAA, unless the 

agency's position in the proceeding was substantially justified or special circumstances 

make an award unjust. The EAJA requires decision makers to determine whether the 

government's position was substantially justified based upon the administrative record, as a 

whole. The FAA implements the EAJA pursuant to 14C.F.R. § 14.04. Furthermore under 

under the agency's rules, the FAA attorney bears the burden of proving substantial 

justification. See In the Matter of Richard W. Kuhling, 2005 FAA Lexis 700, 115-17 (FAA 

3 

SLO/eOO E SWQ * VVd St?LSS6tS0S XVd eeiS L 0L02/S2/8 0 
(FAA 2005). 

The Supreme Courr has explained that the term "substantially justified," as used in 

the EAJA, means "justified to a degree that could satisfy a reasonable person," or having a 

"reasonable basis both in law and fact." Immigration and Naturalization Service v. Jean, 

496 U.S. 154, 158 n.6 (1990), citing Pierce v. Underwood, 487 U.S. 552, 565-566 (1988). 

In the present case, (he agency's caae lacked reasonable basis in both law and fact 

Therefore, an EAJA award must be granted. 

ARGUMENT 

1. THE APPLICANT WAS THE PREVAILING PARTY 

In order to be eligible for a fee award, under the EAJA, the applicant must be the 

prevailing party. In Nackel v. DOT, FAA, 884 F.2d 1378,1379 (Fed. Cir. 1985). Based 

upon the United States Supreme Court's decision in Buckhannon Board and Care Home. 

Inc. V. West Virginia Department of Health and Hvman Resources^ 532 U.S. 598 (2001), die 

U.S. Court of Appeals for the Di strict of Columbia Circuit has distilled a three^part test for 

detennining whether a party has ""prevailed" for purposes of the Equal Access to Justice Ad 

(EAJA): 

HO/tOO ® SWQ * VVd Sl7LSeG1?S02 XVd Se:2 L 0L02/S2/8 0 
(1) there must be a "court-ordered change in the legal relationship" of the 

parties; (2) the judgment must be in favor of the party seeking fees; and (3) the 

judicial pronouncement must be accompanied by judicial relief. 

Turner andCoonan v. N.T.S.B.. 608 F.3d 12; 2010 U.S. App. LEXIS 11648, * (D.C. Cir. 

2010). 

In the present case, considering the &ct that the proceeding was dismissed with 

prejudice, it is irrefutable thai Applicant was the prevailing party in the underlying 

proceeding and achieved complete success in that (1) there was a "court-ordered change in 

the legal relationship" of the parties; (2) the judgment was in favor of the party seeking fees; 

and (3) the judicial pronouncement was accompanied by judicial relief. 

Accordingly, Empire Airways is the prevailing party. 

11. THE ADMINISTRATOR WAS NOT SUBSTANTIALLY JUSTIFIED IN 

INITIATING THE ACTION. 

For the Govenunent's position to be substantiallyjustified, its position must be 

reasonable in fact and law. Thus, the legal theory propounded must be reasonable, the facts 

ailleged must have a reasonable basis in truth, and the facts alleged must reasonably support 

the legal theory. Nicolai v Del Balzo. (I993)NTSB EA-3951. 

In the case at bar, the mere fact that the case was dismissed before a hearing on the 

merits speaks volumes as to the Complainant's lack of substantial justification in bringing 

forth the maner, The Complainant's complete lack of evidence to support its conclusion 

5 

8L0/S00i a SWQ * VVd 21?L9eG1?S02 XVd Z£Z l OL02/9S/80 
conclusion suggests that a reasonable person would not have proceeded with the action 

against tlie Applicant. 

In the instant case, the Complainant did not make a diligent investigation before 

initiating the matter. Furthermore, the agency did noi fiilly evaluate potential and asserted 

defenses, exculpatory materials, and constantly ask at every stage whether proceeding 

further was justified. As a result, the Complainant's investigation was neither objective nor 

complete. 

If the agency's investigation was objective and complete, the Complainant would 

have realized that Entire Airways did not operate or maintain the aircraft in question; and, 

aa a result, was not the proper party. The Complainant's case suffered fi-om an insufficiency 

of evidence. A reasonable person faced with a mound of unrebutted evidence contradicting 

the agency's position, cannot find that the agency had a reasonable basis in law or fact or 

was substantiallyjustified in pursuing the matter. Without substantial justification or special 

circumstances, and with the Applicant prevailing on all counts, the Applicant satisfies the 

requirements to receive fee awards under the EAJA. 

Therefore, the Applicant respectfully submits this application for attorney fees and 

expenses. 

8L0/900i a SMQ * VVd Sl7L9e6t202 XVd 68:^ 1 OLOS/SS/80 
NET WORTH STATEMENT 

In accordance with 14 CFR. § 14.03 (b)(5). Applicant is a corporation with a net 

^vorth of not more than $7 million and not more than 500 employees at the time the 

adversary adjudication was initialed. 

TOTAL FEES AND EXPENSES SOUGHT 

Total fees and expenses for which an award is sought: $4,980. 

EAJA Claim 

Attorney fees $4,440.00 

(Gregory S. Winton, Esq,) 

Paralegal 

Legal A.ssistanl 

Total 

jigurs 

14.8 

5.1 

.6 

Rate 

$300 

$100 

$50 

$510.00 

$30.00 

S4,980.00 

I hereby certify under penalty of perjury that the information proyi3.3d' in tajs application 

is true and correct. 

Dated: August 6,2010 Respejttu^iy/u^mitted, 

GRBQGF^S. WINTON, ESQ. 

The AWwnon Lav/ Firm 

One El^earch Court, Suite 450 

Rookville, MD 20850 

Te/r 301-294-8550 

Fax; 301-294-2525 

Counsel for Applicant 

SLO/iOOia S W Q <• VVd sfrLseet^sos xvd se:sL OLOS/SS/SO 
9 Aviation Lavt^ Experts 

1 Research Court 

Suite 450 

Rockville, MD 20850 

Bill To 

Empire Airways 

John Zaremba 

Route 109, Hangar 3 

Famiingdalc, NY 11735 

Invoice for Legal Services 

Date 

5/31/2010 

Invoice # 

ISO) 

Date 

5/3/2010 

1 5/5/20 JO 

5/7/2010 

5/17/ZOIO 

5/18/2010 

5/19/2010 

Description 

Empire Alr*ays: Legal Services 

Call with Ed So$a re: status and stratsgy. 

Empire Airways: Legal Services 

Meeting with diem re; ststua and strategy. 

Empire Airways: Legal Services 

Cull;; with John Zaremba re: stoius and strategy; 

Review notice of propoied civil penally. 

Empire Airways: Legal Services 

Review email from client re: status and strategy: 

Draft letter to FAA re; status; Review nie. 

Empire Airways; Legal Services 

Call with John Zaremba re: status and strategy; 

Discussed FAA failure to conduct airman checkride. 

Empire Airways; Legal Services 

Review and respond lo multiple emiils from FAA 

re: status; Call widi client re; status and strategy; 

Review letter from attorney Casolaro; Send email 

re; same; Call FAA re: status; Review multiple 

emails re: status. 

Qty 

0.1 

1.5 

0.4 

0.4 

0.1 

0.3 

Thank you for your business. 

1 Phon«« 

1-877J.AJR-LAW 

Fax * 

301 29d 2525 

E-mail 

greB@A¥i*ionL?iwExpens.eoin 

Rate 

300.00 

300,00 

300,00 

300.00 

300.00 

300.00 

Amount 

30.00 

450.00 

120.00 

120.00 

30.00 

90.00 

Total 

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810/800 ® SWQ * VVd 2171588^202 XVd e8'2 L OL02/S2/8 0 
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Aviation Law Experts 

1 Research Court 

Suite 450 

Rockville, MD 20850 

Invoice for Legal Services 

Date 

5/31/2010 

Invoice # 

1801 

Bin To 

Empire Airways 

John Zaremba 

Route 109, Hangar 3 

Fartniogdale, >fY 11735 

Diite 

5/24/20)0 

5/25/2010 

5/2i$«0l0 

Description 

Empire Airways: Legal Services 

Review email from FAA; Draft emails to client re; 

status and strategy; Review file. 

Empire Airways: Legal Services 

Call with client re; flight instruction and aircraft 

charter. 

Empire Airways: Legal Services 

Review multiple emails re: status and strategy. 

Qly 

0.1 

0.3 

0.1 

Thank you for your busiaess. 

Phone# 

|-B77-4-Aia-LAW 

fax if 

301 294 25J5 

E-mail 

ene®A»i3t)onUwExiie(u,c6m 

Rate 

300.00 

300.00 

300.00 

Amount 

30.00 

90.00 

30.00 

Tota l S990.00 

Web Site 

www.AvjaliDnLawExpc(TS,cgrn 

Page 2 

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9 Aviation Law Experts 

1 Research Court 

Suite 450 

Rockville, MD 20850 

Invoice for Legal Services 

Data 

5/2S/2010 

Invoice # 

1781 

Bill To 

Empire Airways 

John Zaiemba 

Route 109, Hangar 3 

Farmingdale, NY 11735 

Date 

5/17/2010 

5/17/2010 

5/17/2010 

Description 

Photocopies 

Fax Transmissions 

Postage 

Qty 

3 

2 

2 

TTiank you for your business. 

Phoned 

]-m-A-AJR.-lAVI 

Fax* 

30\ 294 2525 

E-mail 

6nte@Av i«donLjwe?;p*rts.«iii 

Rate 

o.n 

1.00 

0.44 

Amount 

0.33 

2.00 

0.88 

T^^tal j3,2i 

Web Site 

uiww AviuJonUiwCxpcns.cun 

SLO/OLOE S WO * VVd 2tLS8et20 2 XVd 88:2 1 0L02/S2/8O 
9 Aviation Lavr Experts 

1 Research Court 

Suite 450 

RockviUc, MD 20850 

Invoice for Legal Services 

Date 

6/30/2010 

Invoice # 

1913 

Bill To 

Empire Airways 

John Zaremba 

Rotjte 109, Hangar 3 

Faimingclale,bfY 11735 

Date 

6/21/2010 

Description 

Empire Paralegal Services: 

Research law; Review file; Drai^ Motion for 

DecisivnErapire Paralegal Services: 

Review and revise Motion for Decision. 

Qly 

4.5 

0.6 

Thank you for your business. 

Plione# 

|.g77.^-AlR-UW 

Fax # 

301 294 2SJ5 

£-mail 

£cci;@AvialiDnLawE)(pen9.ajm 

Rate 

100.00 

100.00 

Amount 

450.00 

60.00 

Tota l S510.00 

Web She 

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8L0/LL0 ® SWQ ^ VVd 21?LS86t'202 XVd 88:2 1 0102/S2/8 0 
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Aviation Law Experts 

1 Research Court 

Suite 450 

Rockville, MD 20850 

BiPTo 

Empire Airways 

John Zaremba 

Route 109, Hangar 3 

Farmingdole, NY 11735 

Invoice for Legal Services 

1 Date 

6/30/2010 

Invoice # 

1874 

Date 

6/1/2010 

6/2/2010 

6/.V20I0 

6/10/2010 

6/11/2010 

Thank you fo: yi 

Description 

Empire Airways: Legal Services 

Review FAA enforcement investigative repon; 

Revievv file; Draft email re: status and strategy; 

Review Prehcarlne order; Draft motion for 

continuance; Draft notice ofsubsiiiution; Dnft 

discovery requests; Draft amended affinnaiive 

defenses; Research case lavir. 

Empire Airways; Legal Services 

Review anil revise amended answer. File same; 

Review FAA discovery requests; Draft email 

requesting records; Dinfl response to FAA 

discoveiy; Revise djacoveiy; Review emails re: 

status and strategy; Multiple calls with Ray Toircs 

re: insurance policy. 

Empire Airways: Legal Services 

Review and respond to email from FAA attorney re: 

status of discovery; Review file re; samo. 

Empire Airways: Legal Services 

Call with Law Judge re: hearing date. 

Empire Airways: Legal Services 

Review file; Conference re: status and strategy; Call 

with client re: same; Research law. 

Qty 

4.2 

1.8 

0.1 

0,1 

0.4 

3ur business. 

Phone # 

l-i77-4iAlR-LAW 

Fax# 

}0I 29<t 2S2S 

E-mail 

ljr4fi@AviixiMLivrEKpeni.com 

Rate 

300.00 

300.00 

300.00 

300.00 

300.00 

Amount 

1,260.00 

540.00 

30.00 

30.00 

120.00 

Total 1 

Web Site 1 

wvwv.Avi«i«nljwe> (IKru.cDin 

Page l 

810/210 ® S W Q *• VVd 2l7LSeGt202 XVd es:2 L 0L02/S2/8 0 
9 Aviation Law £xperts 

1 Research Court 

Suite 450 

Rockville, MD 208S0 

Bill To 

Empire Airways 

John Zaremba 

Route 109, Hangar 3 

Faxmingdale, NY 11735 

Invoice for Legal Services 

Dale 

6/30/2010 

Invoice * 

1874 

Date 

6/18/2010 

(5/21/2010 

fi/22/2010 

Description 

Empire Airways: Legal Services 

Review and respond lo FAA email re: stanis and 

strategy; Review FAA motion to withdraw. 

Empire Airways: Legal Services 

review and revise motion to dismiss. 

Empire Airways: Legal SCTVICCS 

Review Mid revise motion to dismiss; Prepare for 

filing. 

Qly 

0.4 

0.1 

1.6 

Thank )(pu for your business. 

Phone # 

l-«77-«-AlR-LAW 

Fax# 

301 294 253J 

E-mail 

grcg@AviiliatiLawEtper(S,com 

Rale 

300.00 

300.00 

300.00 

Amount 

120.00 

30.00 

480,00 

Tota l $2,610.00 

Web Site 

ww.Avi3tionLBwExpcns,com 

Page 2 

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9 Aviation Law Experts 

1 Research Court 

Suite 450 

Rvckvillc MD 20S50 

Invoice for Legal Services 

Date 

6/30/2010 

Invoicntf 

1859 

BHlTo 

Empire Airways 

John Zaremba 

Route 109, Hangar 3 

Farmingdale, NY 11735 

Date 

6/1/2010 

6/22/2010 

Description 

Empire: Legal Assistant Services: Research. 

Empire: Legal Assistant Services: Mailed 

information to client. 

Qty 

0.5 

0.1 

Thank you for your business. 

Phone l» 

l-877-J-AlR-UW 

Fax # 

301294 2525 

E-mail 

Ereg(gAviaiiortLawExpem,ajin 

Rate 

50.00 

50.00 

Amount 

25.00 

5.00 

Total $30.00 

W a b Site 

u-wx<.'.A.vlariDnLawExpent.t:uni 

8L0/t?L0ia S W Q <• VVd 21?LS86t202 XVd ts:2 L 0L02/S2/8 0 
9 Aviation Law Experts 

1 Research Court 

Suite 450 

Rockville, MD 20850 

invoice for Legal Services 

Bill To 

Empire Ainvays 

Jolin Zaremba 

Route 109, Hangars 

Farmingdale, NY 11735 

Data 

6/30/2010 

Invoico # 

1849 

Date 

6/1/2010 

6/1/20)0 

6/1/2010 

6/l/ZfllO 

6/2/2010 

6/2/2010 

6/2/2010 

6/2/2010 

6/22/2010 

16/22/2010 

6/22/2010 

Description 

Photocopies 

Postage 

Postage 

Fax Transmissions 

pax Transmissions 

Photocopies 

Postage 

Postage 

photocopies 

Postage 

Postage 

Qty 

20 

2 

1 

7 

12 

48 

2 

1 

36 

I 

2 

Thank you for your business. 

r Phone # 

l-«77-'1.AIR-LAW 

FBX # 

30119^ 2S25 

E-mail 

Ercj^v-iaiionLawExpcni-CQni 

Tot 

Rate 

0.11 

0.78 

0.61 

1.00 

1.00 

0.11 

0.61 

0.78 

O.n 

1.73 

1.22 

Amount 

2.20 

1.56 

0.61 

7.00 

12.00 

5,28 

1.12 

0.78 

3.96 

1.73 

2.44 

3l $38.78 1 

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flp Aviation Law Experts 

1 Research Court 

Suite 450 

Rocloille, MD 20850 

Invoice for Legal Services 

Bill To 

Empire Airways 

John Zaremba 

Route 109. Hangar 3 

Farmingdale, NY 11735 

Date 

7/14/2010 

Invoice* 

1929 1 

Date 

7/6/2010 

7/6/2010 

7/6/2010 

7/V2010 

Description 

Fax Transmissions 

Photocopies 

Postage 

Postage 

Qty 

10 

20 

2 

1 

Thank you for your buainess. 

1 Phone# 

l-f77-4-AIR-UW 

Fax # 

30I294 242S 

E-mail 

[in:g@AvJB»ionUwExpefW,Mm 

Rate 

1.00 

0.11 

0.44 

0.61 

Amount 

10.00 

2.20 

0.88 

0,61 

1 

Tota l $13.69 

Web site 

vvww,AviiUionLawExp«rt$,eani 

810/910 0 S W Q <• VVd 2*1586*20 2 XVd te:2 L OL02/S2/8 0 
^p 

Aviation Law Experts 

1 Researcli Court 

Suite 450 

Roclfville, MD 20850 

Invoice for Legal Services 

Dale 

7/31/2010 

Invoice # 

1953 

Bill To 

Empire Airways 

Jo!(m ZEiremba 

Route 109, Hangar 3 

hamiingdale, NY 11735 

1 Dale 

7/1/20J0 

7/6/2010 

7/23/2010 

Description 

Empire Airways; Legal Services 

Review FAA notice of witlidrtiwal; Review file re: 

status. 

Empire Airways: Legal Services 

Review file; Call with law judge TC: siatus; Draft 

motion; Send email to judge re: status of case; 

Review file re: status and strategy. 

Etopiie Airways: Legal Services 

Review file re: status; Draft email to judge re; same; 

Call wiih judge's office re; service of order; Draft 

EAJA applicfltjon; Research law; Review file; 

Review and revise EAJA application. 

Qty 

0.1 

0.7 

2 

Thank you for your business. 

Phone# 

l.g17-4-A]R-LAW 

Fax# 

301294 252S 

E-malt 

eitK@Avi»lKmLjnvF~"«pens.CBm 

Ral e 

Total 

300.00 

300.00 

300.00 

Amouffl 

30.00 

210.00 

600.00 

$840.00 

Web Site 

•»^vw.AviationLa*E» pens, com 

8L0/iL0i a SWO * VVd 2t?LSeei?202 XVd 1^8:21 0L02/S2/80 
CERTIFICATE OF SERVICE 

I liereby certify that I have this date mailed, postage prqiaid, an original and three copies of 

the foregoing NUNC PRO TUNC Application for an Award of Attorney Fees and Other 

Expenses Pursuant to the Equal Access to Justice Act (EAJA) addressed to; 

Attention: Hearing Docket Clerk, AGC-430 

Federal Aviation Administration 

800 Independence Avenue. S.W. 

Room 924A 

Washington, D.C. 20591 

I hereby certify that J have this date sent via facsimile and U.S. mail, postage prepaid, copies 

of the foregoing NUNC PRO TUNC Application for an Award of Attorney Fees aiKl Other 

Expenses Pursuant to the Equal Access to Justice Act (EAJA) addressed to: 

Honorable Isaac D. Beokin 

Office of Hearings, M-20 

Room 5411 

U.S. Department of Transportation 

400 Seventh Street, S.W. 

Washington, DC 20590 

Tel; (202) 366-2132 

Fax; (202) 366-7536 

Zachary M. Berman, Esq. 

Office of Assistant Chief Counsel 

F AA Eastern Region, AEA-7 

1 Aviation Plaza, Room 561 

Jamaica, NY 11434 

Tel; 718-553-3258 

Fax: 718-995-5699 

Dated: August 6.2010 

GREGORY S. WINTON, ESQ. 

On^Research Court, Suite 450 

Rockville, MD 20850 

8L0/8L0@ S W Q <• VVd 2t?lS8Gt?202 XVd 178:2L 0L02/S2/8 0