IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

SIERRA CLUB,

Plaintiff,

vs.

LISA JACKSON, ADMINISTRATOR, U.S. 

ENVIRONMENTAL PROTECTION 

AGENCY,

Defendants.

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Case No. 1:11-CV-00100-JDB

 

[PROPOSED] ANSWER BY BCCA APPEAL GROUP

Intervenor BCCA Appeal Group (“BCCAAG”), intervening on behalf of Defendant Lisa 

Jackson, Administrator of the United States Environmental Protection Agency (“Defendant” or 

“EPA”), hereby responds to the correspondingly numbered paragraphs of Plaintiff’s Complaint:

I. INTRODUCTION

1. With respect to the first sentence of Paragraph 1, BCCAAG admits that groundlevel ozone is commonly referred to as “smog.” With respect to Paragraph 1 generally,

BCCAAG lacks sufficient information on which to admit or deny the allegations about specific 

effects of ground-level ozone. Paragraph 1 also contains expressions of opinion to which no 

response is required.

2. With respect to the first sentence of Paragraph 2, BCCAAG admits that EPA 

promulgated a National Ambient Air Quality Standard for ozone in 1979 based on one-hour 

measurements and that this standard may be referred to as the “1-hour ozone standard.” With 

respect to the second and third sentences of Paragraph 2, BCCAAG admits that certain air 

quality control regions were designated as nonattainment for the 1-hour ozone standard. The 
2

remainder of the second and third sentences of Paragraph 2 characterize statutory provisions that 

speak for themselves and are the best evidence of their contents, and therefore, no response is 

required. The second and third sentences of Paragraph 2 also contain conclusions of law that no 

require no response.

3. The first three sentences of Paragraph 3 characterize statutory provisions that 

speak for themselves and are the best evidence of their contents, and therefore, no response is 

required. The first three sentences of Paragraph 3 also contain conclusions of law that require no 

response. The fourth and fifth sentences of Paragraph 3 characterize Plaintiff’s complaint and the 

relief sought, and therefore, no response is required. To the extent a response is required, the 

allegations are denied.

II. JURISDICTION

4. The first sentence of Paragraph 4 characterizes Plaintiff’s complaint and therefore 

no response is required. The second sentence of Paragraph 4 contains conclusions of law that 

require no response. To the extent a response is required, BCCAAG denies that the Court has 

jurisdiction over this action.

5. Paragraph 5 contains conclusions of law that require no response. To the extent a 

response is required, BCCAAG denies that the Court has the authority to order the relief 

requested.

III. NOTICE

6. With respect to the first and second sentences of Paragraph 6, BCCAAG lacks 

sufficient information on which to admit or deny the allegations. The third and fourth sentences 

of Paragraph 6 contain conclusions of law to which no response is required.
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IV. VENUE

7. The first sentence of Paragraph 7 characterizes Plaintiff’s complaint and therefore 

no response is required. BCCAAG lacks sufficient information on which to admit or deny the 

allegations in the second and third sentences of Paragraph 7. The fourth and fifth sentences of 

Paragraph 7 contain conclusions of law to which no response is required.

V. PARTIES

8. BCCAAG is without knowledge or information sufficient to form a belief as to 

the truth or falsity of the allegations in Paragraph 8.

9. BCCAAG is without knowledge or information sufficient to form a belief as to 

the truth or falsity of the allegations in Paragraph 9.

10. Paragraph 10 contains conclusions of law to which no response is required. 

BCCAAG is without knowledge or information sufficient to form a belief as to the remaining 

allegations in Paragraph 10.

11. BCCAAG is without knowledge or information sufficient to form a belief as to 

the allegations in Paragraph 11.

12. The first sentence of Paragraph 12 is admitted. The second sentence of Paragraph 

12 characterizes statutory provisions that speak for themselves and are the best evidence of their 

contents, and therefore, no response is required.

VI. GENERAL ALLEGATIONS

13. The first sentence of Paragraph 13 characterizes a legislative document that 

speaks for itself and is the best evidence of its contents, and therefore, no response is required. 

The second and third sentences of Paragraph 13 characterize statutory provisions that speak for 

themselves and are the best evidence of their contents, and therefore, no response is required. 
4

The second and third sentences of Paragraph 13 also contain legal conclusions to which no 

response is required.

14. Paragraph 14 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 14 also 

contains legal conclusions to which no response is required.

15. Paragraph 15 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 15 also 

contains legal conclusions to which no response is required.

16. The first two sentences of Paragraph 16 characterize regulatory actions that speak 

for themselves and are the best evidence of their contents, and therefore, no response is required. 

The third sentence of Paragraph 16 characterizes regulatory and statutory provisions that speak 

for themselves and are the best evidence of their contents, and therefore, no response is required. 

The third sentence of Paragraph 16 also contains legal conclusions to which no response is 

required. With respect to the fourth sentence of Paragraph 16, BCCAAG admits that the 1979 

ozone national ambient air quality standard may be referred to as the “1-Hour Ozone” Standard 

or NAAQS.

17. The first sentence of Paragraph 17 is admitted. The second sentence of Paragraph 

17 characterizes statutory provisions and a regulatory preamble that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 17 also 

contains legal conclusions to which no response is required.

18. Paragraph 18 characterizes statutory and regulatory provisions that speak for 

themselves and are the best evidence of their contents, and therefore, no response is required.
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19. Paragraph 19 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 19 also 

contains legal conclusions to which no response is required.

20. Paragraph 20 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 20 also 

contains legal conclusions to which no response is required.

21. Paragraph 21 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 21 also 

contains legal conclusions to which no response is required.

22. Paragraph 22 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 22 also 

contains legal conclusions to which no response is required.

23. Paragraph 23 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 23 also 

contains legal conclusions to which no response is required.

24. Paragraph 24 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 24 also 

contains legal conclusions to which no response is required.

25. Paragraph 25 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 25 also 

contains legal conclusions to which no response is required.
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26. Paragraph 26 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 26 also 

contains legal conclusions to which no response is required.

27. Paragraph 27 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 27 also 

contains legal conclusions to which no response is required.

28. Paragraph 28 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 28 also 

contains legal conclusions to which no response is required.

29. Paragraph 29 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 29 also 

contains legal conclusions to which no response is required.

30. Paragraph 30 characterizes regulatory provisions which speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 30 also 

contains legal conclusions to which no response is required.

31. Paragraph 31 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 31 also 

contains legal conclusions to which no response is required.

32. Paragraph 32 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 32 also 

contains legal conclusions to which no response is required.
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33. Paragraph 33 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 33 also 

contains legal conclusions to which no response is required.

34. Paragraph 34 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 34 also 

contains legal conclusions to which no response is required.

35. Paragraph 35 characterizes regulatory provisions that speak for themselves and

are the best evidence of their contents, and therefore, no response is required. Paragraph 35 also 

contains legal conclusions to which no response is required.

36. Paragraph 36 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 36 also 

contains legal conclusions to which no response is required.

37. Paragraph 37 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 37 also 

contains legal conclusions to which no response is required.

38. Paragraph 38 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 38 also 

contains legal conclusions to which no response is required.

39. Paragraph 39 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 39 also 

contains legal conclusions to which no response is required.
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40. Paragraph 40 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 40 also 

contains legal conclusions to which no response is required.

41. Paragraph 41 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 41 also

contains legal conclusions to which no response is required.

42. Paragraph 42 characterizes regulatory actions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 42 also 

contains legal conclusions to which no response is required.

43. Paragraph 43 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 43 also 

contains legal conclusions to which no response is required.

44. Paragraph 44 characterizes a court opinion that speaks for itself and is the best 

evidence of its contents, and therefore, no response is required.

45. Paragraph 45 characterizes a court opinion that speaks for itself and is the best

evidence of its contents, and therefore, no response is required. Paragraph 45 also contains legal 

conclusions to which no response is required.

46. Paragraph 46 characterizes a court opinion that speaks for itself and is the best 

evidence of its contents, and therefore, no response is required. Paragraph 46 also contains legal 

conclusions to which no response is required.

47. Paragraph 47 characterizes a proposed regulatory preamble that speaks for itself 

and is the best evidence of their contents, and therefore, no response is required. Paragraph 47 

also contains legal conclusions to which no response is required.
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48. Paragraph 48 characterizes a court opinion that speaks for itself and is the best 

evidence of its contents, and therefore, no response is required. Paragraph 48 also contains legal 

conclusions to which no response is required.

49. Paragraph 49 characterizes a court opinion and regulatory preambles that speak 

for themselves and are the best evidence of its contents, and therefore, no response is required. 

Paragraph 49 also contains legal conclusions to which no response is required.

V. CLAIMS FOR RELIEF

CLAIM ONE

(EPA’s Failure to Make a Determination of Attainment by the 

Applicable Attainment Date for Nonattainment Areas Classified as 

Severe or Higher for the 1-Hour Ozone Standard)

50. BCCAAG incorporates its responses to Paragraphs 1-49 of the Complaint. 

51. Paragraph 51 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 51 also 

contains legal conclusions to which no response is required. 

52. Paragraph 52 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 52 also 

contains legal conclusions to which no response is required. 

53. Paragraph 53 characterizes statutory provisions that speak for themselves and are 

the best evidence of their contents, and therefore, no response is required. Paragraph 53 also 

contains legal conclusions to which no response is required. 

54. Paragraph 54 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 54 also 

contains legal conclusions to which no response is required. 
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55. Paragraph 55 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 55 also 

contains legal conclusions to which no response is required. 

56. Paragraph 56 contains legal conclusions to which no response is required. 

57. Paragraph 57 contains legal conclusions to which no response is required. 

58. With respect to Paragraph 58, BCCAAG admits that EPA has not made a 

determination whether the Houston-Galveston-Brazoria area has met its 1-hour ozone attainment 

date. To the extent that Paragraph 58 characterizes this determination as “required,” this is a 

legal conclusion to which no response is required. 

59. With respect to Paragraph 59, BCCAAG admits that EPA has not published 

notice in the Federal Register of a determination whether the Houston-Galveston-Brazoria area 

has met its 1-hour ozone attainment date. To the extent that Paragraph 59 characterizes this 

determination as “required,” this is a legal conclusion to which no response is required. 

60. Paragraph 60 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 60 also 

contains legal conclusions to which no response is required. 

61. Paragraph 61 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 61 also 

contains legal conclusions to which no response is required. 

62. Paragraph 62 contains legal conclusions to which no response is required. 

63. Paragraph 63 contains legal conclusions to which no response is required. 

64. With respect to Paragraph 64, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has made a determination whether the Baltimore area has met its 1-
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hour ozone attainment date. To the extent that Paragraph 64 characterizes this determination as 

“required,” this is a legal conclusion to which no response is required. 

65. With respect to Paragraph 65, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has published notice in the Federal Register of a determination 

whether the Baltimore area has met its 1-hour ozone attainment date. To the extent that 

Paragraph 65 characterizes this determination as “required,” this is a legal conclusion to which 

no response is required. 

66. Paragraph 66 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 66 also 

contains legal conclusions to which no response is required. 

67. Paragraph 67 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 67 also 

contains legal conclusions to which no response is required. 

68. Paragraph 68 contains legal conclusions to which no response is required. 

69. Paragraph 69 contains legal conclusions to which no response is required. 

70. With respect to Paragraph 70, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has made a determination whether the New York portion of the New 

York-Northern New Jersey-Long Island area has met its 1-hour ozone attainment date. To the 

extent that Paragraph 70 characterizes this determination as “required,” this is a legal conclusion 

to which no response is required. 

71. With respect to Paragraph 71, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has published notice in the Federal Register of a determination 

whether the New York portion of the New York-Northern New Jersey-Long Island area has met 
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its 1-hour ozone attainment date. To the extent that Paragraph 71 characterizes this 

determination as “required,” this is a legal conclusion to which no response is required. 

72. Paragraph 72 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 72 also 

contains legal conclusions to which no response is required. 

73. Paragraph 73 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 73 also 

contains legal conclusions to which no response is required. 

74. Paragraph 74 contains legal conclusions to which no response is required. 

75. Paragraph 75 contains legal conclusions to which no response is required. 

76. With respect to Paragraph 76, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has made a determination whether the New Jersey portion of the 

New York-Northern New Jersey-Long Island area has met its 1-hour ozone attainment date. To 

the extent that Paragraph 76 characterizes this determination as “required,” this is a legal 

conclusion to which no response is required. 

77. With respect to Paragraph 77, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has published notice in the Federal Register of a determination 

whether the New Jersey portion of the New York-Northern New Jersey-Long Island area has met 

its 1-hour ozone attainment date. To the extent that Paragraph 77 characterizes this 

determination as “required,” this is a legal conclusion to which no response is required. 

78. Paragraph 78 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 78 also 

contains legal conclusions to which no response is required. 
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79. Paragraph 79 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 79 also 

contains legal conclusions to which no response is required. 

80. Paragraph 80 contains legal conclusions to which no response is required. 

81. Paragraph 81 contains legal conclusions to which no response is required. 

82. With respect to Paragraph 82, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has made a determination whether the Connecticut portion of the 

New York-Northern New Jersey-Long Island area has met its 1-hour ozone attainment date. To 

the extent that Paragraph 82 characterizes this determination as “required,” this is a legal 

conclusion to which no response is required. 

83. With respect to Paragraph 83, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has published notice in the Federal Register of a determination 

whether the Connecticut portion of the New York-Northern New Jersey-Long Island area has 

met its 1-hour ozone attainment date. To the extent that Paragraph 83 characterizes this 

determination as “required,” this is a legal conclusion to which no response is required. 

84. Paragraph 84 contains legal conclusions to which no response is required. 

85. Paragraph 85 contains legal conclusions to which no response is required. 

CLAIM TWO

(EPA’s Failure to Make a Determination of Attainment by the 

Applicable Attainment Date for Nonattainment Areas Classified as 

Serious or lower the 1-Hour Ozone Standard)

86. BCCAAG incorporates by reference its responses to Paragraphs 1-85 of the 

Complaint. 

87. Paragraph 87 contains legal conclusions to which no response is required. 

88. Paragraph 88 contains legal conclusions to which no response is required. 
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89. Paragraph 89 contains legal conclusions to which no response is required. 

90. Paragraph 90 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 90 also 

contains legal conclusions to which no response is required. 

91. Paragraph 91 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 91 also 

contains legal conclusions to which no response is required. 

92. Paragraph 92 contains legal conclusions to which no response is required. 

93. Paragraph 93 contains legal conclusions to which no response is required. 

94. With respect to Paragraph 94, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has made a determination whether the Springfield (Western 

Massachusetts) area has met its 1-hour ozone attainment date. To the extent that Paragraph 94 

characterizes this determination as “required,” this is a legal conclusion to which no response is 

required. 

95. With respect to Paragraph 95, BCCAAG lacks sufficient information on which to 

admit or deny whether EPA has published notice in the Federal Register of a determination 

whether the Springfield (Western Massachusetts) area has met its 1-hour ozone attainment date. 

To the extent that Paragraph 95 characterizes this determination as “required,” this is a legal 

conclusion to which no response is required. 

96. Paragraph 96 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 96 also 

contains legal conclusions to which no response is required. 
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97. Paragraph 97 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 97 also 

contains legal conclusions to which no response is required. 

98. Paragraph 98 contains legal conclusions to which no response is required. 

99. Paragraph 99 contains legal conclusions to which no response is required. 

100. With respect to Paragraph 100, BCCAAG lacks sufficient information on which 

to admit or deny whether EPA has made a determination whether the Greater Connecticut area 

has met its 1-hour ozone attainment date. To the extent that Paragraph 100 characterizes this 

determination as “required,” this is a legal conclusion to which no response is required. 

101. With respect to Paragraph 101, BCCAAG lacks sufficient information on which 

to admit or deny whether EPA has published notice in the Federal Register of a determination 

whether the Greater Connecticut area has met its 1-hour ozone attainment date. To the extent 

that Paragraph 101 characterizes this determination as “required,” this is a legal conclusion to 

which no response is required. 

102. Paragraph 102 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 102 

also contains legal conclusions to which no response is required. 

103. Paragraph 103 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required. Paragraph 103 

also contains legal conclusions to which no response is required. 

104. Paragraph 104 contains legal conclusions to which no response is required. 

105. Paragraph 105 contains legal conclusions to which no response is required. 
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106. With respect to Paragraph 106, BCCAAG lacks sufficient information on which 

to admit or deny whether EPA has made a determination whether the New Hampshire portion of 

the Boston-Lawrence-Worcester area has met its 1-hour ozone attainment date. To the extent 

that Paragraph 106 characterizes this determination as “required,” this is a legal conclusion to 

which no response is required. 

107. With respect to Paragraph 107, BCCAAG lacks sufficient information on which 

to admit or deny whether EPA has published notice in the Federal Register of a determination 

whether the New Hampshire portion of the Boston-Lawrence-Worcester area has met its 1-hour 

ozone attainment date. To the extent that Paragraph 107 characterizes this determination as 

“required,” this is a legal conclusion to which no response is required. 

108. Paragraph 108 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required.

109. Paragraph 109 characterizes regulatory provisions that speak for themselves and 

are the best evidence of their contents, and therefore, no response is required.

110. Paragraph 110 contains legal conclusions to which no response is required.

111. Paragraph 111 contains legal conclusions to which no response is required.

112. With respect to Paragraph 112, BCCAAG lacks sufficient information on which 

to admit or deny whether EPA has made a determination whether the Massachusetts portion of 

the Boston-Lawrence-Worcester area has met its 1-hour ozone attainment date. To the extent 

that Paragraph 112 characterizes this determination as “required,” this is a legal conclusion to 

which no response is required.

113. With respect to Paragraph 113, BCCAAG lacks sufficient information on which 

to admit or deny whether EPA has published notice in the Federal Register of a determination 
17

whether the Massachusetts portion of the Boston-Lawrence-Worcester area has met its 1-hour 

ozone attainment date. To the extent that Paragraph 113 characterizes this determination as 

“required,” this is a legal conclusion to which no response is required. 

114. Paragraph 114 contains legal conclusions to which no response is required.

115. Paragraph 115 contains legal conclusions to which no response is required.

The remaining allegations in the Complaint are Plaintiff’s Prayer for Relief, which 

requires no response. To the extent a response is required, BCCAAG denies that Plaintiff is 

entitled to such relief.

FIRST AFFIRMATIVE DEFENSE

Statute of Limitations

116. Plaintiff’s claims are barred by the applicable statute of limitations.

SECOND AFFIRMATIVE DEFENSE

Res Judicata

117. Plaintiff’s claims are barred by res judicata.

THIRD AFFIRMATIVE DEFENSE

Failure to State a Claim

118. Plaintiff has failed to state a claim upon which relief can be granted.

FOURTH AFFIRMATIVE DEFENSE

Lack of Jurisdiction

119. Plaintiff has failed to allege facts sufficient to establish jurisdiction.
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Dated: June 8, 2011

Respectfully submitted,

/s/ Richard P. Sobiecki

Richard P. Sobiecki (D.C. Bar # 500163)

Baker Botts L.L.P.

1299 Pennsylvania Ave., N.W.

Washington, D.C. 20004

(202) 639-7906

rich.sobiecki@bakerbotts.com

Zachary L. Craft

Baker Botts L.L.P.

One Shell Plaza 

910 Louisiana

Houston, Texas 77002

(713) 229-1133

zachary.craft@bakerbotts.com

Attorneys for BCCA Appeal Group