Dale	Real	Estate	Services

1357	Heatherwood	Lane

Ann	Arbor,	Michigan	48108

U.S.	Department	of	Transportation	Docket	Management	System

1200	New	Jersey	Avenue SE

Washington,	D.C.	20590

Re:	Exemption	Request	for	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	

Federal	Aviation	Regulations	from	14	C.F.R.	91.7	(a),	14	C.F.R.	91.9	(b)(2),	14	C.F.R.	

91.103,	14	C.F.R.	91.119,	14	C.F.R.	91.121,	14	C.F.R.	91.405	(a),	14	C.F.R.	91.407	

(a)(1),	14	C.F.R.	91.409	(a)(1)&(2),	14	C.F.R.	91.417	(a)&(b)

To	Whom	It	May	Concern

This	application	is	being	submitted	on	my	own	behalf.

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	

Reform	Act)	and	14	C.F.R.	Part	11,	Dale	Real	Estate	Services,	operator	of	Small	

Unmanned	Aircraft	Systems	(UASs)	equipped	to	conduct	aerial	photography	and	

videography for	the	real	estate	industry, hereby	applies	for	an	exemption	from	the	

listed	Federal	Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of	its	

UASs,	as long	as	such	operations	are	conducted	within	and	under	the	conditions	

outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by	Section	333.

This exemption	would	permit	the	operation	of	small,	unmanned, and	relatively	

inexpensive	UAS	under	controlled	conditions	in	airspace	that	is	1)	limited	2)	

predetermined	3)	controlled	as	to	access	and	4)	would	provide	safety	

enhancements	to	the	already	safe	operations	in	the	real	estate industry presently	

using	conventional	aircraft.	Approval	of	this	exemption	would	enhance	safety	and	

fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)	responsibilities	to	

“...establish	requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	

national	airspace	system.” Section	333(c)	of	the	Reform	Act.	The	name	and	address	

of	the	applicant	is:	 Dale	Real	Estate	Services

Please		contact:	

Mark	Dale

1357	Heatherwood	Lane

Ann	Arbor,	Michigan		48108

734-276-9008

mark.c.dale@comcast.net
Regulations	from	which	the	exemption	is	requested:	14	C.F.R.	91.7	(a),	14	C.F.R.	91.9	

(b)(2),	14	C.F.R.	91.103,	14	C.F.R.	91.119,	14	C.F.R.	91.121,	14	C.F.R.	91.405	(a),	14	

C.F.R.	91.407	(a)(1),	14	C.F.R.	91.409	(a)(1)&(2),	14	C.F.R.	91.417	(a)&(b)

This	application	is	submitted	to	fulfill	Congress’ intent	in passing	Section	333(a)	

through	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary	of	Transportation	to	

consider	whether	certain	unmanned	aircraft	systems	may	operate	safely	in	the	

national	airspace	system	(NAS)	before	completion	of	the	rulemaking	required	under	

Section	332	of	the	Reform	Act.	In	making	this	determination,	the	Secretary	is	

required	to	determine	which	types	of	UASs	do	not	create	a	hazard	to	users	of	the	

NAS	or	the	public	or	pose	a	threat	to	national	security in	light	of	the	following:	

The	UAS’s	size,	weight,	speed,	and	operational	capability;	•	Operation	of	the	UAS	in	

close	proximity to	airports	and	populated	areas;	and	•	Operation	of	the	UAS	within	

visual	line	of	sight	of	the	operator. 

Reform	Act	§	333	(a).	Lastly,	if	the	Secretary	determines	that	such	vehicles	“may	

operate	safely	in	the	national	airspace	system,	the	Secretary	shall	establish

requirements	for	the	safe	operation	of	such	aircraft	in	the	national	airspace	system.”

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,	that	includes	UASs,	from	the	

requirement	that	all	civil	aircraft	must	have	a	current	airworthiness	certificate. 

Applicant interprets this provision to place the duty on the Administrator to not 

only process applications for exemptions under section 333, but for the 

Administrator to craft conditions for the safe operation of the UAS, if it should be 

determined that the conditions set forth herein do not fulfill the statutory 

requirements for approval. 

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation	

prescribed	under	subsection	(a)	or	(b)	of	this	section	or	any	sections	44702-

44716	of	this title	if	the	Administrator	finds	the	exemption	in	the	public	interest.	49	

U.S.C.	§44701(f)	See	also	49	USC	§44711(a);	49	USC	§44704;	14	CFR	§91.203	(a)	(1).	

Dale	Real	Estate	Services UASs	are	rotorcraft,	weighing	5	or	fewer	lbs.	including	

payload.	They	operate,	under	normal	conditions	at	a	speed	of	no	more	than	30	knots	

and	have	the	capability	to	hover,	and	move	in	the	vertical	and	horizontal	plane	

simultaneously.	They	will	operate	only	in	line	of	site.	Such	operations	will	insure	

that	the	sUAS	will	not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	

public.

Given	the	small	size	of	our UASs,	the	applicant	falls	squarely	within	that	zone	
of	safety	(an	equivalent	level	of	safety)	in	which	Congress	envisioned	that	the	FAA	

must,	by	exemption,	allow	commercial	operations	of	UASs	to	commence	

immediately.	Also	due	to	the	size	of	the	UASs	and	the	restricted	areas	in	which	the	

relevant	UASs	will operate,	approval	of	the	application	presents	no	national	security	

issue.	Given	the	clear	direction	in	Section	333	of	the	Reform	Act,	the	authority	

contained	in	the	Federal Aviation	Act,	as	amended;	the	strong	equivalent	level	of	

safety	surrounding	the	proposed	operations,	and	the	significant	public	benefit,	

including	enhanced	safety,	reduction	in	environmental	impacts,	including	reduced	

emissions	associated	with	allowing	UASs	for	photography,	the	grant	of	the	

requested	exemptions	is	in	the	public	interest.	Accordingly,	the	applicant	

respectfully	requests	that	the	FAA	grant	the	requested	exemption	without	delay.	

Aircraft	and	Equivalent	Level	of	Safety

The	applicant	proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	

that	have	the	characteristics	and	that	operate	with	the	limitations	listed	herein.	

These	limitations	provide	for	at	least	an	equivalent	or even	higher	level	of	safety	to	

operations	under	the	current	regulatory	structure	because	the	proposed	operations	

represent	a	safety	enhancement	to	the	already	safe	movie	and	television	filming	

operations	conducted	with	conventional	aircraft. 

These	limitations	and	conditions	to	which	Dale	Real	Estate	Services agrees	to	be	

bound	when	conducting	commercial	operations	under	an	FAA	issued	exemption	

include:	

1) The	sUAS	will	weigh	less	than	5 lbs.;	2) Flights	will	be	operated	within	line	of	

sight	of	a	pilot	and/or	observer; 3) Maximum	total	flight	time	for	each	operational	

flight	will	be	25 minutes. Flights	will	be	terminated	at	25%	battery	power	reserve	

should	that	occur	prior	to	the	25 minute	limit; 4) Flights	will	be	operated	at	an	

altitude	of	no	more	than	200	feet	AGL	or,	not	more	than	200	feet	above	an	elevated	

platform	from	which	filming	is	planned;5) Minimum	crew	for	each	operation	will	

consist	of	the	UAS	Pilot,	and	the	Visual	Observer; 6) sUAS	Pilot	will	be	Pilot	in	

Command	(PIC); 7) The	UAS	will	only	operate	within	a	confined	area; 8)	A	briefing	

will	be	conducted	in	regard	to	the	planned	UAS	operations	prior	to	each	project.	It	

will	be	mandatory that	all	personnel	who	will	be	performing	duties	be	present	for	

this	briefing; 9) The	operator	will	obtain	the	consent	of	all	persons	involved	in	the

photography	and	filming and	ensure	that	only	consenting	persons	be	allowed	within	

50	feet	of	the	flight	operation; 10) Pilot	and	observer	will	have	been	trained	in	

operation	of	UAS	generally	and	received	up-to-date	information	on	the	particular	

UAS	to	be; 11) Observer	and	pilot	will	at	all	times	be	able	to	communicate	by	voice	

and/or	text; 12)	Written	and/or	oral	permission	from	the	relevant	property	holders	

will	be	obtained; 13) If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	

UAS	will	have	capability	to	return	to	a	pre-determined	location	within	the security	

perimeter	and	land and; 14) The	UAS	will	have	the	capability	to	abort	a	flight	in	case	

of unpredicted	obstacles	or	emergencies.	
14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)	

Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	

requirements	for	the	issuance	of	airworthiness	certificates	as	required	by	FAR	

§91.203	(a)	(1).	Given	the	size	and	limited	operating	area	associated	with	the	

aircraft	to	be	utilized	by	the	Applicant,	an	exemption	from	Part	21	Subpart	H	meets	

the	requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of	

the	Reform	Act.	The	Federal	Aviation	Act	(49	U.S.C.§44701	(f))	and	Section	333	of	

the	Reform	Act	both	authorize	the	FAA	to	exempt	aircraft	from	the	requirement	for	

an	airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed,	

operational	capability,	and	proximity	to	airports	and	populated	areas	of	the	

particular	UAS.	In	all	cases,	an	analysis	of	these	criteria	demonstrates	that	the	UAS	

operated	without	an	airworthiness	certificate,	in	the	restricted	environment	and	

under	the	conditions	proposed	will	be	at	least	as	safe,	or	safer,	than	a	conventional	

aircraft	(fixed	wing	or	rotorcraft)	operating	with	an	airworthiness	certificate	

without	the	restrictions	and	conditions	proposed.

The	sUAS to	be	operated	hereunder	is	less	than	5lbs.	fully	loaded,	carries	neither	a	

pilot	nor	passenger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and	

operates	exclusively within	a	secured	area.	Unlike	other	civil	aircraft,	operations	

under	this	exemption	will	be	tightly	controlled	and	monitored	by	the	operator.	

These	safety	enhancements	provide	a	greater	degree	of	safety	to	the	public	and	

property	owners	than	conventional	operations	conducted	with	airworthiness	

certificates	issued	under	14	C.F.R.	Part	21,	Subpart	H.	Lastly,	application	of	these	

same	criteria	demonstrates	that	there	is	no	credible	threat	to	national	security

posed	by	the	UAS,	due	to	its	size,	speed	of	operation,	location	of	operation,	lack	of	

explosive	materials	or	flammable	liquid	fuels,	and	inability	to	carry	a	substantial	

external	load.	14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft	The	regulation	requires:	

When	marks	include	only	the	Roman	capital letter	"N"	and	the	registration	number	

is	displayed	on	limited,	restricted	or	light-sport	category	aircraft	or	experimental	or	

provisionally	certificated	aircraft,	the	operator	must	also	display	on	that	aircraft	

near	each	entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	

inches	nor	more	than	6	inches	high,	the	words	"limited,"	"restricted,"	"light-sport,"	

"experimental,"	or	"provisional,"	as	applicable.	

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS although there is no entrance to a cabin, cockpit or pilot 

station on which the word “Experimental” can be placed. Given the size of the 

UAV, two-inch lettering will be impossible. The word “Experimental” will be 

placed on the fuselage in compliance with §45.29 (f). The equivalent level of 

safety will be provided by having the sUAV marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the sUAV will see 

the identification of the UAS as “Experimental.” No person may operate a U.S.-

registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is 

not required by §21.5 of this chapter, unless there is available in the aircraft a 
current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The sUAS, given its size 

and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room 

or capacity to carry such an item on the aircraft. 

The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	flight	manual	at	the	

ground	control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	access	to	

it.	The	FAA	has	issued	the	following	exemptions	to	this	regulation:	Exemption	

Nos.8607,	8737,	8738,	9299,	9299A,	9565,	9565B,	10167,	10167A,	10602,	32827,	

and	10700.	14	C.F.R.	§	91.103:	Preflight	action	This	regulation	requires	each	pilot	in	

command	to	take	certain	actions	before	flight	to	insure	the	safety	of	flight.	As	FAA	

approved	rotorcraft	flight manuals	will	not	be	provided	for	the	aircraft	an	

exemption	will	be	needed.	An	equivalent	level	of	safety	will	be	provided	as	set	forth	

in	Sections	J	and	K	of	the	Manual.	The	PIC	will	take	all	actions	including	reviewing	

weather,	flight	battery	requirements,	landing	and	takeoff	distances	and	aircraft	

performance	data	before	initiation	of	flight.	14	C.F.R.	§91.109:	Flight	instruction:	

Section	91.103	provides	that	no	person	may	operate	a	civil	aircraft	(except	a	

manned	free	balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has	

fully	functioning	dual	controls.	sUASs	and	remotely	piloted	aircraft,	by	their	design	

do	not	have	fully	functional	dual	controls.	Flight	control	is	accomplished	through	the	

use	of	a	control	box	that	communicates	with	the	aircraft	via	radio	communications.	

The	FAA	has	approved	exemptions	for	flight	training	without	fully	functional	dual	

controls	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	

See	Exemption	Nos.5778K	&	9862A.	The	equivalent	level	of	safety	provided	by	the	

fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the	aircraft	and	by	the	size	

and	speed	of	the	aircraft.	14	C.F.R.	§91.119:	Minimum	safe	altitudes	Section	

91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section	91.119	(d)	

allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed,	provided	

the	person	operating	the	helicopter	complies	with	any	route	or	altitudes	prescribed	

for	helicopters	by	the	FAA.	As	this	exemption	is	for	a	UAS	that	is	a	helicopter	and	the	

exemption	requests	authority	to	operate	at	altitudes	up	to	400	AGL,	or	not	more	

than	200	above	an	elevated	platform	from	which	filming	is	planned,	an	exemption	

may	be	needed	to	allow	such	operations.	As	set	forth	herein,	except	for	the	limited	

conditions	stated	in	the	Manual,	the	UAS	will	never	operate	at	higher	than	400	AGL.	

It	will	however	be	operated	in	a	restricted	area	with	security	perimeter,	where	

buildings	and	people	will	not	be	exposed	to	operations	without	their	pre-obtained	

consent.

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the	

UAS	as	well	as	the	location	where	it is	operated.	No	flight	will	be	taken	without	the	

permission	of	the	property	owner	or	local	officials.	Because	of	the	advance	notice	to	

the	property	owner	and	participants	in	the	filming	activity,	all	affected	individuals	

will	be	aware	of	the	planned	flight	operations.	Compared	to	flight	operations	with	

aircraft	or	rotorcraft	weighting	far	more	than	the	maximum	55lbs.	proposed	herein	
and	the	lack	of	flammable	fuel,	any	risk	associated	with	these	operations	is	far	less	

than	those	presently	presented	with	conventional	aircraft	operating	at	or	below	500	

AGL.	In	addition,	the	low-altitude	operations	of	the	sUAS	will	ensure	separation	

between	these	small-UAS	operations	and	the	operations	of	conventional	aircraft	

that	must	comply	with	Section	91.119.	14	C.F.R.	§91.121	Altimeter	Settings	

This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising	

altitude	by	reference	to	an	altimeter	that	is	set	“...to	the	elevation	of	the	departure	

airport	or	an	appropriate	altimeter	setting	available	before	departure.” As	the	UAS	

may	not	have	a	barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	

exemption	may	be	needed.	An	equivalent	level	of	safety	will	be	achieved	by	the	

operator,	pursuant	to	the	Manual	and	Safety	Check	list,	confirming	the	altitude	of	

the	launch	site	shown	on	the	GPS	altitude	indicator	before	flight.	14	C.F.R.	

§91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions	Section	91.151	(a)	

prohibits	an	individual	from	beginning	“a	flight	in	an	airplane	under	VFR	conditions	

unless	(considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	

fly	to	the	first	point	of	intended	landing,	and,	assuming	normal	cruising	speed	–

(1)	During	the	day,	to	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after

that	for	at	least	45	minutes.”	

The	battery	powering	the	sUAS provides	approximately	30minutes	of	powered	

flight.	To	meet	the	reserve	requirement	in	14	CFR	§91.151,	sUAS	flights	would	be	

limited	to	approximately	10-12minutes	in	length.	Given	the	limitations	on	the	UAS’s	

proposed	flight	area	and	the	location	of	its	proposed	operations	within	a	

predetermined	area,	a	longer	time	frame	for	flight	in	daylight	or	night	VFR	

conditions	is	reasonable.	

Applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	

of	prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	

to	operate	without	compliance	with	FAR	91.151	(a)).	Operating	the	small	UAS,	in	a	

tightly	controlled	area	where	only	people	and	property	owners	or	official	

representatives	who	have	signed	waivers	will	be	allowed,	with	less	than	30	minutes	

of	reserve	fuel,	does	not	engender	the	type	of	risks	that	Section	91.151(a)	was	

intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS.	Additionally,	limiting	

sUAS	flights	to	10	minutes	would	greatly	reduce	the	utility	for	which	the	exemption	

will	be	granted.	

Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by	limiting	

flights	to	30	minutes	or	25%	of	battery	power	whichever	happens	first.	This	

restriction	would	be	more	than	adequate	to	return	the	UAS	to	its	planned	landing	

zone	from	anywhere	in	its	limited	operating	area.	

Similar	exemptions	have	been	granted	to	other	operations,	including	Exemptions	

2689F,	5745,	10673,	and	10808.	14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	

Aircraft	Certification	and	Registration	The	regulation	provides	in	pertinent	part:	
(a)	Except	as	provided	in	§	91.715,	no	person	may	operate	a	civil	aircraft	unless	it	

has	within	it	the	following:	

(1)	An	appropriate	and	current	airworthiness	certificate.

(b)	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate	

required	by	paragraph	(a)	of	this	section	or	a	special	flight	authorization	issued	

under	§91.715	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	

passengers	or	crew.	

The	UAS	fully	loaded	weighs	no	more	than	55	lbs. and	is	operated	without	an	

onboard	pilot.	As	such,	there	is	no	ability	or	place	to	carry	certification	and	

registration	documents	or	to	display	them	on	the	UAS.	

An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	

ground	control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	access	to	

them,	to	the	extent	they	are	applicable	to	the	UAS.	The	FAA	has	issued	numerous	

exemptions	to	this	regulation.	A	representative	sample	of	other	exceptions	includes	

Exemption	Nos.	9565,	9665,	9789,	9789A,	9797,	9797A,	9816A,	and	10700.	14	

C.F.R.	§91.405	(a);	407	(a)	(1);	409 (a)	(2);	417(a)	&	(b):	Maintenance	Inspections	

These	regulations	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft	

inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between	required	

inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have	discrepancies	

repaired	as	prescribed	in	part	43	of	this	chapter...,”	and	others	shall	inspect	or	

maintain	the	aircraft	in	compliance	with	Part	43.	Given	that	these	section	and	Part	

43	apply	only	to	aircraft	with	an	airworthiness	certificate,	these	sections	will	not	

apply	to	the	applicant.	The	operator	pursuant	to	the	flight	manual	will	accomplish	

maintenance.	An	equivalent	level	of	safety	will	be	achieved	because	these	small	

UASs	are	very	limited	in	size	and	will	carry	a	small	payload	and	operate	only	in	

restricted	areas	for	limited	periods	of	time.	If	mechanical	issues	arise	the	UAS	can	

land	immediately	and	will	be	operating	from	no	higher	than	400	feet	AGL.	As	

provided	in	the	Manual,	the	operator	will	ensure	that	the	UAS	is	in	working	order	

prior	to	initiating	flight,	perform	required	maintenance,	and	keep	a	log	of	any	

maintenance	performed.	Moreover,	the	operator	is	the	person	most	familiar	with	

the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an	airworthy	condition	to	

provide	the	equivalent	level	of	safety.	

The	operation	of	small	UASs,	weighting	less	than	55	lbs.,	conducted	in	the	strict	

conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	

grant	of	the	exemptions	requested	herein,	including	exempting	the applicant	from	

the	requirements	of	Part	21	and	allowing	commercial	operations.	These	lightweight	

aircraft	operate	at	slow	speeds,	close	to	the	ground,	and	in	a	sterile	environment	

and,	as	a	result,	are	far	safer	than	conventional	operations	conducted	with	turbine	

helicopters	operating	in	close	proximity	to	the	ground	and	people.	Privacy	All	flights	

will	occur	over	private	or	controlled	access	property	with	the	property	owner’s	

prior	consent	and	knowledge.	Filming	will	be	of	people	who	have	also	consented	to	
being	filmed	or	otherwise	have	agreed	to	be	in	the	area	where	filming	will	take	

place.	

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012--size,	

weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	areas	and	

operation	within	visual	line	of	sight	and	national	security	–provide	more	than	

adequate	justification	for	the	grant	of	the	requested	exemptions	allowing	

commercial	operation	of	applicant’s	UAS	in	the	real	estate	industry.

Sincerely,

Mark	C.	Dale

Dale	Real	Estate	Services

1357	Heatherwood Lane

Ann	Arbor,	MI		48108

734-276-9008

mark.c.dale@comcast.net