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December 9, 2015 

Electronic Submission 

U.S. Department of Transportation 

Docket Operations Management System 

1200 New Jersey Ave., S.E. 

Washington D.C. 20590 

Eckert Seamans Cherin & Mellott, LLC 

1717 Pennsylvania Avenue, N.W. 

12tl' Floor 

Washington, D.C. 20006 

Ta 202 659 6600 

FAX 202 659 6699 

www.eckertseamans.com 

Edward J. Longosz, II 

elongosz@eckertseamans.com 

Direct: (202) 659-6610 

RE: Petition of The Zurich Services Corporation for an Exemption Pursuant to Section 

333 of the FAA Modernization and Reform Act of2012 

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 

11, The Zurich Services Corporation (ZSC) hereby applies for an exemption from Federal 

Aviation Regulations permitting it to operate small unmanned aerial systems (UAS) for aerial 

data collection and research and development (R&D) purposes. 

ZSC requests that FAA review Zurich's application and grant the requested exemption 

authority on an expedited basis as the operations proposed herein differ in no material respect 

from those proposed in applications submitted by a variety of insurance providers and that the 

FAA has approved on a regular basis. See, e.g. , Exemption Nos. 11367 to ADM Crop Risk 

Services; 11293 to Erie Insurance Group; 11 188 and 11175 to State Farm; 11273 to AIG; and 

11309 and 11274 to USAA. 

ZSC is seeking authority to operate UAS for the following purposes: 

• Aerial Data Collection- ZSC will utilize UAS for aerial data collection in support of its 

operations related to risk assessment, risk improvement, loss prevention, claim assessment 

surveys, and catastrophe response of ZSC's clients. 

• Research and Development- ZSC will perform R&D activities to evaluate how UAS can be 

utilized as part of ZSC risk assessment activities, to better understand potential uses of UAS 

across the many industries that our clients represent, and to better understand the risks of 

operating UAS in order to develop mitigation guidance. 

Because ZSC's Petition for Exemption and Operations and Safety manual contain 

commercially sensitive information and operational data that ZSC would not disclose in the 
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ordinary course of business, ZSC requests that its submissions in this docket be afforded 

confidential treatment pursuant to 14 CFR § 11.35(b ). Similarly, these documents contain 

operating conditions and procedures that are not available to the public and are thus protected 

from release under the Freedom oflnformation Act, 5 U.S.C. §552 et. seq., and any other 

requirements established by the FAA pursuant to Section 333 of the FAA Reform Act. 

ZSC's petition is organized as follows: 

1. Description of the Petitioner 

2. Types of Operations Proposed 

3. Proposed UAS 

4. Relevant Statutory Authority 

5. Application Information 

6. Regulations From Which an Exemption is Requested 

7. Public Interest 

8. Operating Parameters 

9. Federal Register Summary 

10. Conclusion 

1. The Petitioner 

The Zurich Services Corporation (ZSC) is an Illinois Company and a wholly owned subsidiary of 

Zurich Holding Company of America, Inc., a Delaware Corporation. ZSC provides a number of 

services to the member companies of Zurich in North America (Zurich), to Zurich insureds, and to other 

third parties. These services include among other things underwriting risk assessments and postincident surveys and assessments. 

2. Proposed UAS Operations 

a. Operate UAS for R&D purposes at test sites owned or controlled by ZSC 

ZSC is requesting an exemption pursuant to Section 333 to conduct research and development 

at ZSC owned or controlled facilities or property, and facilities owned by third party vendors. 

The facilities are not open to the general public and access during UAS operations will be 

limited to those employees or contractors engaged in the development work itself. All UAS 

operations will occur outside of controlled air space and will be conducted in accordance with 

all applicable federal aviation regulations and in accordance with any special conditions or 

limitations specific to ZSC's exemption. 

The testing proposed above will allow ZSC: 

• to identify the best and most appropriate uses ofUAS technology; 
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• to refine its understanding of the data it is able to capture by a UAS; 

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• to identify operational environments where the sensing technology is most effective 

(e.g., how do the sensors perform over different type of paved surfaces) ; 

• to refine ZSC's UAS operational procedures; 

b. Operate UAS in connection with ZSC's various risk assessment, risk management, 

and loss prevention surveys, and related claim assessment activities 

As a leading provider of property and casualty related insurance, Zurich constantly seeks to 

understand the causes and effects of accidents and losses in the market place. ZSC regularly 

conducts risk assessments and risk improvement surveys and uses that information to advise 

Zurich's policyholders on best practices and suggest various safety improvements. ZSC 

intends to use UAS to perform a number of these risk assessment and improvement surveys 

since the subjects are often large areas (e.g., roof surveys, walking and surface areas, including 

sidewalks, lobbies, parking areas, construction sites, etc.) best observed from an aerial 

perspective. Use of U ASs will be less costly and safer than employing the use of a full-size 

rotorcraft and ZSC's research activities will identify how to best utilize UASs in context of risk 

assessment and improvement survey work. 

It will be ZSC policy and practice to operate UASs in connection with these risk surveys only 

after obtaining written permission from the relevant policyholder(s) and in accordance with all 

FAA regulations governing UAS operations and the conditions and limitations specific to 

ZSC's exemption authority. 

3. Proposed UAS 

ZSC proposes to conduct its operations with DJI Phantom 3 Pro and DJI Inspire 1 UAS. As 

FAA is aware, thousands ofDJI UAS are in use throughout the United States and DJI's UAS 

are among the safest and highly-automated aircraft currently available. 

The DJI Phantom 3 Pro is a lightweight multi-rotor copter weighing less than 3 lbs. that will be 

operated at a maximum speed of less than 40 mph. The DJI Phantom 3 Pro has numerous 

features to ensure safe flight operations including pre-programmed operating modes that can 

limit altitude and speed, and provide geo-fencing to ensure flight operations are conducted 

within safe parameters. If lost link occurs between the controller and the UAS, the DJI 

Phantom 3 Pro's Failsafe and Return-to-Home features will activate and return to the take-off 

point. 

The DJI Inspire 1 is a lightweight multi-rotor copter weighing less than 7 lbs. that will be 

operated at a maximum speed of less than 40 mph. Similar to the Phantom 3 Pro, the Inspire 1 

also has features to ensure safe operations including Failsafe and Return-to-Home features in 

the event of lost link from the controller to the U AS. 
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4. Relevant Statutory Authority and Precedent 

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This petition for exemption is submitted in accordance with Section 3 3 3 of the FAA 

Modernization and Reform Act of2012. Section 333 directs the Secretary of Transportation to 

consider whether certain UASs may operate safely in the National Airspace System before 

completion of the rulemaking required under section 332 of the FMRA. The Secretary is 

required to determine which types ofUASs do not create a hazard to users of the NAS or the 

public or pose a threat to national security in light of the UASs' size, weight, speed and 

operational capability and whether operations will occur near airports or populated areas and 

within the visual line of sight of the operator. The FMRA illustrates Congress's intent to have 

the FAA issue exemptions and allow civil UASs, so long as they operate within the necessary 

safety parameters. 

In addition, the Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term 

is defined under §40101 of the act which includes UAS, from the requirement that all civil 

aircraft have a current airworthiness certificate. The administrator may grant an exemption 

from a requirement of a regulation prescribed under §§44701(a) or (b) or in §§44702-44716 of 

the act if the Administrator finds the exemption is in the public interest. 

Finally, the FAA has issued exemptions authorizing the use of small UAS for aerial data 

collection in support of similar inspection and surveying activities. See, e.g, Exemption No. 

11273, Docket No. FAA-2014-0913 (authorizing AIG's use ofUAS for insurance underwriting 

and inspection purposes); Exemption No. 11293, Docket No. FAA-2014-0692 (authorizing 

Erie Insurance's proposal to operate UAS in connection with its insurance underwriting and 

claims adjustment business). 

5. Applicant Information 

The Name and Address of the applicant is: 

The Zurich Services Corporation 

1400 American Lane 

Schaumburg, Il 60196 

E-Mail: Jon.Tate@ZurichNA.com 

Telephone: + 847-605-7533 

Fax: +847-413-5407 

6. Regulations from which exemptions are requested. 

a. 14 C.F.R. Part 21, Subpart H: Airwmihiness Certificates and 14 C.F.R § 91.203 
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b. 14 C.F.R §§ 45.23(b), 45,27(a) , 91.9(c): Aircraft Marking and Identification 

Requirements 

c. 14 C.F.R. 61.113: Private Pilot Privileges and Limitations: Pilot In Command. 

d. 14 C.P .R § 91.9(b )(2): Civil Aircraft Flight Manual In The Aircraft 

e. 14 C.P.R. § 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration 

f. 14 C.P.R 91.7(a): Civil Aircraft Airworthiness 

g. 14 C.P.R 91.109(a): Flightlnstruction 

h. 14 C.P.R.§ 91.119: Minimum Safe Altitudes 

1. 14 C.P.R.§ 91.121: Altimeter Settings 

j. 14 C.P.R. § 91.151(a): Fuel Requirements for Flights in VFR Conditions 

k. 14 C.P.R. §§ 91.405(a), 91.407(a)(l ), 91.409(a)(2), 91.417(a) and (b): Maintenance 

Inspections 

We request an exemption from the following Federal Aviation Requirements (FARS) to the 

extent necessary to request the requested UAS operations for the reasons listed below. 

a. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates and 14 C.F.R § 

91.203 

14 C.F.R Part 21 Subpart Hand 14 C.F.R § 91.203 establish the need for and protocols for 

airworthiness certificates. The two UAS models ZSC intends to operate (the DJI Phantom 3 Pro 

and DJI Inspire 1) will, by design, provide an equivalent level of safety for the following 

reasons: 

They will weigh Jess than 40 pounds including payload. 

They will travel at less than 40 miles per hour. 

There will be no pilots or passengers on board the aircraft. 

They will be powered by batteries and will use no flammable fuels. 

They will be operated within the parameters described in the Operations Manual and in 

accordance with all FAA operational regulations. 

They will only be operated under VFR conditions. 
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They will be operated under the close control of an actual operator and observer and only within 

the operator's line of sight. 

They will be operated in accordance with any applicable NOT AMs (Notice to Airmen) 

and will never be operated in controlled airspace. 

In summary, ZSC will guarantee that an equivalent level of safety is achieved by operating 

pursuant to the standards enumerated above, the procedures outlined in the Operations and 

Safety manuals, and all applicable FAA regulations, limitations, and conditions. 

b. 14 C.F.R §§ 45.23(b), 45,27(a), 91.9(c): Aircraft Marking and Identification 

Requirements 

ZSC requests an exemption from FAA's regulations governing aircraft markings since the 

markings cited in these regulations are too large to be affixed to the UAS ZSC intends to 

operate. ZSC will achieve an equivalent level of safety by marking its UAS in accordance with 

FAA's VAS-specific guidance and with letters and numbers of an appropriate size. (ZSC has 

been following the activities of FAA's UAS Registration Task Force and will comply with any 

VAS-specific registration requirements FAA issues on a going forward basis.) 

c. 14 C.F.R. 61.113 

Under Section 61.113, private pilots may not operate aircraft for compensation or hire. ZSC 

seeks an exemption from this limitation given the unique qualities ofUAS operation and 

because ZSC's UAS: 

• will be flown by pilots appropriately-trained in the safe operation of the UAS; 

• will not carry pilots or passengers; 

• will not operate in controlled airspaces; 

• will be in visual range of the PIC at all times; and 

• will be flown in flights that are planned and controlled in advance. 

The risks associated with operating UASs are markedly diminished from the risks associated 

with the typical commercial aircraft. A properly trained holder of an airline transport, 

commercial, private, recreational, or sport pilot certificate will have the skills together with the 

necessary aeronautical knowledge to safely operate UASs for commercial purposes; and, as a 

result, the safety standards contemplated by Section 61 .113 will be exceeded by the operations 

proposed by ZSC and ZSC requests that its pilots be exempted from 61 .113 's prohibition on 
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commercial operations provided that the UAS operations conducted are undertaken pursuant to 

its Operations and Safety manuals and all applicable FAA regulations. 

d. 14 C.F.R § 91.9(b)(2): Civil Aircraft Flight Manual In The Aircraft; 14 

C.F.R. § 91.203(a) & (b): Carrying Civil Aircraft Certification and 

Registration 

Due to the small size of the UAS, is simply not possible to stow copies of the flight manual or 

any other documentation on board the UAS itself. Instead, ZSC requests an exemption that 

will allow the PIC to maintain copies of the Flight Manual and other required documentation at 

his or her control station provided they are ready for inspection at all times. ZSC understands 

that this arrangement has already been approved by the FAA Chief Counsel's office. 

e. 14 C.F.R 91.7(a): Civil Aircraft Airworthiness 

This section requires that no aircraft be operated unless it is airworthy condition. The FAA has 

stated that no exemption is required to the extent that the requirements of Part 21 are waived or 

found inapplicable. Accordingly, we request that the requirements for §91. 7 be treated in 

accordance with the section above covering: 14 C.F.R. Part 21, Subpart H: Airworthiness 

Certificates and 14 C.F.R § 91.203 

f. 14 C.F.R 91.109(a): Flight Instruction 

ZSC requests an exemption from 91.1 09( a)'s requirement that all flight training take place in 

aircraft equipped with dual controls. The UAS ZSC intends to operate is controlled via 

sophisticated radio transmitters, not traditional flight controls positioned on the aircraft itself. 

A level of safety equivalent with 91.1 09(a) will be achieved by ensuring ZSC's UAS pilots 

have received adequate training in advance of operating in a "live" environment, the pilot in 

command is at the operations center during all flight instruction operations. the pilot in 

command maintains constant line of sight contact with the UAS, NOTAMs are appropriately 

filed, and flights are conducted in accordance with ZSC's Operations and Safety manual and 

away from any members of the public. 

g. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

ZSC requests an exemption from Section 91.119's mandate that the UAS be operated above 

non-congested areas at an altitude of 500 feet AGL or higher. The UAS operations envisioned 

by ZSC will comply with FAA's guidance by operating at altitudes less than 400 feet AGL. An 

equivalent level of safety is achieved due to the small size, low speed, and low weight of the 

UAS, its operation under VFR rules by an appropriately trained pilot and its operation in areas 

away from persons or structures not involved in the operation; including crowded or congested 

areas. 
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h. 14 C.F.R. § 91.121: Altimeter Settings 

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ZSC requests an exemption from this section requiring the use of a barometric altimeter to 

maintain proper cruising altitude or flight level. ZSC intends to operate UAS equipped with 

GPS, not barometric, altimeters. An equivalent level of safety will be achieved by having the 

PIC confirm altitudes using the GPS altimeter. 

i. 14 C.F.R. § 91.151(a): Fuel Requirements for Flights in VFR Conditions 

As FAA is aware, UASs are powered by lithium polymer batteries in lieu of flammable fuels. 

ZSC requests an exemption to the fuel requirements of this section, allowing it to conduct 

flight operations while maintaining a 25% reserve on the battery life of the UAS. An 

equivalent, if not improved level of safety will exist as there are no flammable fuels stored 

onboard, the UAS flies at lower elevations and speeds, and within the line of sight of the PIC. 

As such, that PIC is easily able to determine battery life and safely land the UAS quickly when 

the 25% limit is reached. Furthermore, ZSC will employ industry best practices when charging 

and storing the lithium batteries that will power its aircraft. For the aforementioned reasons, 

ZSC's UAS operations will achieve an equivalent level of safety to that mandated by Section 

91.151(a). 

j. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2), 91.417(a) and (b): 

Maintenance Inspections 

ZSC requests that it be exempted from the regulations cited above to the extent they are 

applicable to aircraft that have been issued airworthiness certificates by FAA. ZSC will 

achieve equivalent levels of safety by ensuring its UASs are maintained in accordance with 

manufacturer recommendations and pursuant to ZSC's Operations and Safety manuals. Please 

note that the manufacturer's manual establishes requirements for: 

• a flight operations checklist that includes all the aircraft's components; 

• maintenance log books and records; 

• routine maintenance; 

• annual maintenance; 

• post flight maintenance; and 

• maintenance based on hours of flight. 

The manufacturer's manual contemplates that the UAS owner will undertake the outlined 

maintenance as the owner/operator is in the best position to judge whether maintenance is 

required and is the party most familiar with the aircraft's performance. By complying with the 

manufacturer's maintenance standards and the standards in its own Operations and Safety 
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Manuals, ZSC will ensure it achieves levels of safety equivalent to those mandated in the F ARs 

enumerated above. 

7. Public Interest 

Granting ZSC's request for exemption(s) furthers the public interest. The UAS operations 

proposed by ZSC will further Congress' national policy goal of integrating UASs into the 

National Airspace System in a safe and controlled way. 

By operating UASs instead of full-scale fixed wing aircraft or rotorcraft, ZSC will be reducing 

the already minimal risks to the public posed by its surveying activities. UASs can perform 

many visual or infra-red surveys far more safely than either a typical fixed wing aircraft or 

helicopter can. By definition, the smaller size and low weight of the UAS reduces any risks 

posed to persons on the ground should an accident occur. Taking photos with UAS-mounted 

camera also reduces the risk to members of the public employed in bridge, roof, construction or 

other types of site surveys as they would no longer be exposed to the perils of falling from 

these elevated structures. 

The additional insight gained from these UASs will allow ZSC to provide the funds needed to 

allow for relief from the event and allow Zurich to settle claims faster for those members of the 

public it insures. 

Finally, the risk assessment and risk management surveys that the UAS enable will allow ZSC 

to better prevent accidents and advise on accident reduction methods, which is clearly in the 

public interest. The UAS system will accomplish by allowing ZSC to identify problems from 

that air that ZSC simply cannot see using today's technology. Particularly on large scale sites, 

ZSC needs to be able to employ better survey methods than the typical walk around or drive 

around methods currently used. An aerial view would give ZSC a much better vision of the loss 

producing conditions that may exist on a specific site. This will give ZSC the opportunity to 

offer recommendations for risk reduction and loss prevention, both of which are clearly in the 

public interest. 

8. Operating Parameters 

The proposed operations in this Petition for Exemption qualify for expedited approval under 

Section 333 ofthe Reform Act. Each ofthe statutory criteria and other relevant factors are 

satisfied. 

a. Approval is warranted based on the VAS's size, weight, and operational 

capability 
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ZSC will employ the U AS s identified in the accompanying Operations Manual. These U ASs 

will be used for all of the operations as set forth in the Operations Manual. Each of these 

UASs have characteristics in common that warrant approval. All of the UASs will be limited 

to a maximum flight speed of 40 mph , and vertical ascent speed will be limited to 15 mph, 

and none of the devices have a weight in excess of 40 pounds. Each of the U ASs have an 

integrated GPS system to calculate the U AS position and height and to relay that information 

via secure connection to the operator. In addition, each contains a failsafe mode if its 

connection to the remote control is lost. The system permits the vehicle to return to a 

predetermined location and land to prevent injury or damage. 

b. Approval is warranted based on the operational restrictions set forth in 

ZSC's operations manual 

ZSC's Operations Manual and the manufacturers' maintenance and flight manuals contain all 

of the procedures and limitations necessary to successfully perform R&D and inspections of 

Zurich's customers' property before, during and after catastrophes or other loss events. To 

assist the FAA in its safety assessment of ZSC's operations, below is a summary of 

operational limitations and conditions which will ensure a level of safety equal to or exceeding 

the level of safety for operations conducted under current regulatory guidelines: 

1. The UAS employed by ZSC will weigh less than 40 pounds including 

payload. 

2. The UAS will be operated within visual line of sight of the pilot in control (PIC) 

at all times. 

3. U AS operations will not be conducted during night, as defined in 14 CFR § 1.1. 

All operations will be conducted under visual meteorological conditions 

("VMC"). If flight at night is required, a special request will first be made at the 

FAA office closest to the proposed area of operations. 

4. All flight operations will utilize a visual observer (VO). The UAS will be 

operated within the visual line of sight of the PIC and VO at all times. The VO 

may be used to satisfy the visual line of sight requirement. The VO and PIC will 

always be able to communicate verbally at all times. 

5. Maximum total flight time for each operational flight will be limited to the 

amount of time the U AS can be flown and still maintain a reserve battery 

power of no less than 25%. 

6. Flights will be operated at an altitude of no more than 400 feet AGL and will 

not be conducted within controlled airspace. 
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7. Flights will be operated at a lateral distance of at least 500 feet from any 

persons or property not associated with the operation who have not given 

pnor perrn1sswn. 

8. Flights will be limited to a speed of 40 m.p.h., and vertical ascent will be 

limited to 15 m.p.h. 

9. Minimum crew for each operation will consist of the UAS Pilot, one or more 

Visual Observers as necessary to safely conduct the mission, and a Sensor 

Operator, if the sensor requires human direction or control. 

10. The pilot will hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The pilot will also hold a current 

FAA airman medical certificate or a valid U.S . driver's license issued by the 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the 

Federal government. 

11 . The pilot will have sufficient experience and recurrent training to safely 

conduct flights in accordance with the standards set forth in the Operations 

Manual. 

12. The UAS will operate in accordance with the safety and operational 

requirements of its respective manuals. 

13. Prior to each flight the PIC will inspect the UAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft will be prohibited from operating until 

the necessary maintenance has been performed and the U AS is found to be in a 

condition for safe flight. At the same time, a Mission Plan will be prepared 

that will set forth the operating limitations for the flight and will identify 

any potential hazards associated with the mission. 

14. The UAS will not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted on 

the current FAA-published aeronautical chmi, unless a letter of agreement with 

that airport's management is obtained or otherwise permitted by a GOA issued to 

the exemption holder. The letter of agreement with the airport management will 

be made available to the Administrator or any law enforcement official upon 

request. 
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15. If the U AS loses communications with its operator, it will have the 

capability to return to a pre-dete1mined location within the operational area 

and land. 

16. Contingency plans will be in place to safely terminate flight if there is a 

loss of communication between the pilot and the observer. 

17. The UAS will have the capability to abort a flight in case ofunpredicted 

obstacles or emergencies. 

9. Federal Register Summary 

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

ZSC seeks an exemption from the following rules: 

1. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates and 14 C.F.R § 91.203 

2. 14 C.F.R §§ 45.23(b), 45,27(a), 91.9(c): Aircraft Marking and Identification 

Requirements 

3. 14 C.P.R. 61.113: Private Pilot Privileges and Limitations: Pilot In Command. 

4. 14 C.F .R § 91.9(b )(2): Civil Aircraft Flight Manual In The Aircraft 

5. 14 C.F.R. § 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration 

6. 14 C.F.R 91.7(a): Civil Aircraft Air Worthiness 

7. 14 C.F.R 91.109(a): Flight Instruction 

8. 14 C. F .R. § 91.119: Minimum Safe Altitudes 

9. 14 C.F.R. § 91.121: Altimeter Settings 

10. 14 C.F.R. § 91.151(a): Fuel Requirements for Flights in VFR Conditions 

11. 14 C.P.R. §§ 91.405(a), 91.407(a)(l ), 91.409(a)(2), 91.417(a) and (b): Maintenance 

Inspections 

The exemptions will improve safety by reducing the risks of accidents to the general public as 

well as property owners from the substantial risk of performing similar work using typical fixed 

wing or helicopter aircraft, currently available today. 

10. Conclusion 

ZSC believes that the information contained in this petition and its Operations and Safety 

manuals satisfy the criteria provided in Section 333 of the Federal Modernization and Reform 

Act of 2012 and FAA's standards for granting exemptions under Section 3 3 3 that authorize the 

use ofUASs in connection with commercial activities. 
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If you have any questions or require any additional information, please do not hesitate to 

contact us. 

Eckert Seamans Cherin & Mellott, LLC 

Edward J. LonMosz, II, Esquire 

Evelyn D. Sahr, Esquire 

Jonathan Linde, Esquire