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March 2002 Council of the District of Columbia Vol. 8, No. 1

|| The Budget Process|| D.C. Official Code || Significant Federal Legislation|| Highlights of the D.C. Appropriations Act, 2002|| Litigation ||
|| End of Council Period XIV ||  Election Year Mailings || Council Review of Contracts|| Message from the General Counsel ||












Every even year three things happen -- the second year of a Council Period, the Congressional adjournment sine die, and the elections for half of the positions in the Council. This issue of Legalese addresses the effect of these events on the ways the Council conducts its affairs. Council legislation that has not had final reading, with few exceptions, will die at the end of the Council Period. Bills that have not concluded their mandatory review periods prior to the date of the Congressional Adjournment Sine Die will have to restart the count when the 108th Congress convenes in January 2003. Members of the Council who are seeking reelection to their positions may not send mass mailing as official mail after certain deadlines. If you are affected by any of these matters, this issue of Legalese should address your questions.

In addition, this issue summarizes Congressional actions that apply exclusively to the District of Columbia; an update on the way in which days are counted for the review of contracts by the Council; important information from the Codification Counsel on the D.C. Official Code; and a status of some of the litigation involving the Council or enactments of the Council. Finally, during each Spring, while some are following the road to the final four college basketball teams, the Mayor and the Council are on the road to the final adoption of the District's budget. To assist in the understanding of the budget process, an article is included to outline the steps that are taken by the CFO, Mayor, and the Council which culminate in the transmission of a Budget Request Act to the President of the United States and the United States Congress. As usual, the Office of the General Counsel is available to answer any questions you may have about these and other matters.


The District of Columbia Home Rule Act prescribes a procedure for the approval of the annual budget for the District of Columbia government. Using the estimates of the Chief Financial Officer, the Mayor submits a budget to the Council for approval by the Council. If approved, it is transmitted to Congress, which appropriates the funds.

Under section 424(a)(5), the Chief Financial Officer prepares and submits to the Mayor and the Council annual estimates of all revenues of the District of Columbia (without regard to the source of such revenues), including proposed revenues. These revenue estimates are binding on the Mayor and the Council for purposes of the annual budget to be submitted to Congress, except that the Mayor and the Council may base the budget on estimates of revenues which are lower than those prepared by the Chief Financial Officer.

Under section 442(a), the Mayor prepares and submits a proposed annual budget to the Council. In preparing the annual budget, the Mayor may utilize a budget prepared by the Chief Financial Officer for this purpose under section 424(a)(2).

Under section 603(c), the Mayor is required to submit a balanced budget and identify any tax increases which shall be required in order to so. The Council is required to adopt such tax increases to the extent the budget is approved. The annual budget submitted shall include, among other items, a multiyear plan for all agencies of the District government (as required under section 443) and a multiyear capital improvements plan for all agencies of the District government (as required under section 444).

Under section 446, the Council must hold a public hearing on the budget submission and, within 50 calendar days after receipt of the budget proposal from the Mayor, adopt a budget by act. The act is styled as the Budget Request Act (of the year of adoption) and requires only one reading. If the Mayor approves the budget act, he or she submits it to the President for transmission to Congress.

However, unlike other acts submitted to the Mayor for signature, the Mayor may exercise a line-item veto under section 404(f). If the Mayor disapproves an item or provision, he or she must attach to the act a statement of the item or provision which is disapproved and, within the 10-day period for approval or disapproval, return a copy of the act and statement with his or her objections to the Council.

The Council has 30 calendar days to reenact a disapproved item or provision by a two-thirds vote of the members of the Council present and voting. If an item or provision is reenacted, the Chairman submits it to the President for transmission to Congress. If the Mayor fails to return timely a disapproved item or provision to the Council, he or she shall be deemed to have approved the item or provision and the Chairman submits it to the President for transmission to Congress.

Unlike other legislation, the Budget Request Act does not become effective after a period of Congressional review--it never becomes law. Congress must appropriate all funds for the District of Columbia by Congressional Act, which may, but is not required to, include some or all of the provisions of the Budget Request Act.

The District government may not expend any funds until they are so appropriated by Congress. This includes all funds which were dedicated to revolving funds in a prior fiscal year. If money in a revolving fund was appropriated for expenditure in a prior fiscal year, but was not spent, it must be reappropriated for expenditure in the next fiscal year in order to be utilized.

As stated above, the Budget Request Act requires only one reading and is not subject to Congressional review. It does not become law and, therefore, will not be assigned a D.C. Law number. The appropriations act for the District government is a Congressional Act and is assigned a Public Law number.

In conjunction with the annual budget, the Council enacts additional legislation, styled as the Budget Support Act (of the year of adoption), as may be necessary to implement the items and provisions of the annual budget. For example, legislation to adopt tax increases approved in the budget, as required under section 603(c), would be included in the Budget Support Act.

The Budget Support Act is subject to the usual provisions for the passage of legislation contained in section 404(e), including Congressional review. Because of the Congressional review, in order to ensure that provisions of the Budget Support Act become effective by the beginning of the fiscal year, the Council customarily passes the Budget Support Act as an emergency act after the second reading of the permanent bill, except for those provisions which may have already been the subject of emergency legislation.

Accordingly, despite the inclusion of prior emergency legislation in the permanent Budget Support Act, Council staff must continue to monitor the expiration dates of the prior emergency legislation and move separate Congressional review emergency legislation as may be necessary.

In addition to the annual budget requests, the Mayor, under section 442(c), may at any time prepare and submit to the Council proposed supplemental or deficiency budget requests. In addition to the requests initiated by the Mayor, the Mayor, under section 442(d), shall prepare and submit to the Council proposed supplemental or deficiency budget requests if the Council, by resolution, requests the Mayor to do so.

A supplemental or deficiency budget request is governed by the provisions of section 446. It may be adopted by the Council after a public hearing and, subject to the line-item veto provisions of section 404(f), signed by the Mayor and submitted to the President for transmission to Congress. [DSK]

2002 D.C. Official Code Supplement Pamphlet Now Available

The 2002 D.C. Official Code Supplement Pamphlet has arrived at the Council. All amendments to the D.C. Official Code, 2001 Edition, through D.C. Law 14-27, are contained in this one volume paperback supplement. [BFB]

Electronically, all amendments to the D.C. Official Code through D.C. Law 14-28, the Fiscal Year 2002 Budget Support Act of 2001, are available on the Council's V-drive under the subdirectory "code_sup", along with the most recent Code Update Chart.


Highlights of the District of Columbia Appropriations Act, 2002(Public Law 107-96)
Federal Payment for Incentives for Adoption of Children

In addition to extending the availability of the $5,000,000 initially earmarked for the creation of incentives to promote the adoption of children who are in the District's foster care system to September 30, 2003, the Act sets aside $1,000,000 of the $5,000,000 for the establishment of a scholarship fund for District of Columbia children of adoptive families, and District of Columbia children without parents due to the September 11, 2001, terrorist attack, to be used for post-high school education and training.

Crime Victims Compensation Fund

The Act eliminates the $250,000 reserve requirement in the Crime Victims Compensation Fund and the Congressional approval requirement before funds can be expended for direct compensation payments to crime victims. The Act also requires that 50 percent of the Fund balance be used for direct compensation payments to crime victims and 50 percent be used for outreach activities designed to increase the number of crime victims who apply for such direct compensation payments.

Payments for Representation of Indigents

The Act increases the hourly rate for attorneys appointed to represent indigents from $50 to $65 and increases the maximum amounts attorneys can receive for each case.

Public Safety and Justice

The Act makes the provision of the Fiscal Year 2002 Budget Support Act of 2001 (D.C. Law 14-28) that prohibits overtime compensation for senior managers in the Metropolitan Police Department and the Fire and Emergency Medical Services Department applicable to employees hired before 1980.

Certification of Need by Chief Technology Officer

The Act amends the law governing the assignment of private-sector employees to District agencies by allowing the Chief Technology Officer, instead of the Director of Personnel, to certify the need for such employees assigned to the Office of the Chief Technology Officer.

Salary of the Chief Financial Officer

The Act sets the Chief Financial Officer's annual salary equal to the rate of basic pay payable for level I of the Executive Schedule.

Federal Contribution for Enforcement of Law Banning Possession of Tobacco Products by Minors

The Act approves a $100,000 federal contribution to the Metropolitan Police Department if the District government enacts legislation banning the possession of tobacco products by minors in the District of Columbia and imposing certain civil penalties for violation of the law.

Reserve Funds

Regarding the Reserve Fund, the Act makes the following changes:

  1. Reduces the amount required to remain in the Fund from $150,000,000 to $120,000,000 in FY 2002 and $70,000,000 in FY 2003;
  2. Eliminates the congressional reporting requirements, and the requirement that an annual positive fund balance of 4% of the projected general fund expenditures for the following fiscal year be retained at the end of each fiscal year, and the requirement that not more than 50 percent of the excess funds be used for authorized non-recurring expenses and not less than 50 percent of the excess funds be used to reduce the debt of the District of Columbia;
  3. Requires a cumulative cash reserve of $50,000,000 for fiscal years 2004 and 2005; and
  4. Changes the conditions by which the moneys in the Fund may be used.

Contingency Reserve Fund

The Act renames the "Emergency Reserve Fund" established by section 450A of the Home Rule Act to the "Contingency Reserve Fund", reduces the balance maintenance amount from 4% to 3% of the total budget appropriated for operating expenditures, and reduces the applicable percentage for fiscal years 2002 and 2003 from 2% and 3%, respectively, to 0% for each year.

Change in Effective Date for Law 14-41

Section 138 of the Act changes the effective date of Law 14-41, the Closing of Portions of 2nd and N Streets, N.E. and Alley System in Square 710, S.O. 00-97, Act of 2001 (intended to be developed for the ATF National Headquarters Building ), from October 13, 2001, to December 21, 2001. [BFB]

District of Columbia Police Coordination Amendment Act of 2001 (Public Law 107-113)

The Act amends the National Capital Revitalization and Self-Government Improvement Act of 1997 (Public Law 105-33) to permit any federal law enforcement agency to enter into a cooperative agreement with the

Metropolitan Police Department to assist the Department in carrying out crime prevention and law enforcement activities if deemed appropriate by the Chief of the Department and the United States Attorney for the District of Columbia.

District of Columbia Family Court Act of 2001 (Public Law 107-114)

The Act redesignates the Family Division of the Superior Court of the District of Columbia as the Family Court of the Superior Court for the stated purposes of recruiting and retaining trained and experienced judges to serve in the Family Court, and promoting consistency and efficiency in the assignment of judges to the Family Court and in the consideration of actions and proceedings in the Family Court.

Among other things, the Act:

1) Sets the number of judges on the Family Court at 15, with leave for the Chief Judge to assign more judges during emergency circumstances;

2) Sets 5 years as the initial term of service for judges assigned to the Family Court, with less time required for judges currently serving in the Superior Court, and allows judges the option of serving their entire term with the Superior Court in the Family Court;

3) Expands the role of mediation in Family Court cases;

4) Adopts a One Family, One Judge rule where a new case involving an individual who has an immediate family member involved in a case assigned to a particular judge will be assigned to the same judge;

5) Establishes training requirements for judges and nonjudicial personnel in the Family Court, magistrate judges, and attorneys who practice in the Family Court;

6) Requires computerized tracking and management of cases and proceedings in the Family Court;

7) Requires the Mayor to appoint a social services liaison between the Family Court and the executive branch; and

8) Designates all hearing commissioners in the Superior Court as "magistrate judges" and requires all magistrate judges serving in the Family Court, among other things, to be bona fide residents of the District of Columbia. [BFB]

Proposed Federal Legislation Would Tax Nonresidents

On March 11, 2002, Delegate Eleanor Holmes Norton introduced the District of Columbia Fair Federal Compensation Act of 2002. The Act subjects each nonresident individual employed in the District to a tax equal to 2 percent of their wages from employment in the District or 2 percent of net earnings from self-employment in the District, but also amends the Internal Revenue Code of 1986 to ensure that the taxpayer who is subject to this tax receives a corresponding credit against his or her federal tax liability. Partners in partnerships

and sole proprietors already subject to District tax and members of the military on active duty are exempt from the tax. Congresswoman Norton estimates that the tax will generate $413 million for the District in FY 2003. The revenue generated by the imposition of this tax would be dedicated to building and facility maintenance, construction, and capital improvement projects for District public and public charter schools, transportation related activities, improvement in the local government's information technology systems, and debt service. [BFB]


U.S. District Court Grants Councilmember Ambrose's Motion to Dismiss Boystown Suit in Father Flanagan's Boys Home v. The District of Columbia, et al.

Father Flanagan's Boys Home (more commonly known as Boystown) is seeking to construct and operate a group home in the District of Columbia, but has received significant community opposition. When it did not receive a building permit after eight months, it filed an action in federal court against the District of Columbia and several other defendants, including Councilmember Ambrose, alleging that they intentionally discriminated against Boystown on the basis of handicap and race under the Fair Housing Act.

Boystown's legal theory was that because of the activities of Councilmember Ambrose, as well as other defendants, Boystown was denied, by unjustified continuing delay, a building permit to construct its project, a group home for juveniles alleged to be handicapped and predominantly members of racial minorities.

As to Councilmember Ambrose, Boystown alleged that she "publicly announced her opposition to Plaintiff's project," "attended opposition meetings and activities," "gave interviews and statements to the public media," and "publicly advocated that the Girls & Boys Town project be subjected to a costly, time-consuming environmental impact study." In

addition, it alleged that she introduced unfavorable legislation in the Council.

Councilmember Ambrose, represented by the General Counsel, filed a motion to dismiss the complaint. As a matter of law, Councilmember Ambrose was not within the reach of the Fair Housing Act because she did not have the authority to grant or deny the building permit. Moreover, it was argued, the application of the Fair Housing Act under these circumstances would violate the First Amendment because Councilmember Ambrose's actions constituted pure advocacy. The Court granted her motion, dismissing the case without a formal opinion. [DSK]

U.S. District Court Dismisses Suit Challenging ANC Reform Amendment Act of 2000 in Burnetta Coles v. Cropp, et al.

On February 25, 2002, the United States District Court for the District of Columbia (Hogan, C.J.), granted the Council's request to dismiss a lawsuit filed against all 13 members of the Council. The plaintiff sought monetary damages and repeal of the Advisory Neighborhood Commission Reform Amendment Act of 2000, alleging that the Council had usurped the personnel authority of the Advisory Neighborhood Commissions and denied her right to vote in a referendum, and to equal protection of the laws. The Council's position was that the plaintiff had suffered no injury as a result of the Council's action, and that there was no requirement for a referendum on changes to laws affecting Advisory Neighborhood Commissions.

The Court held, in agreement with the Council's position, that the plaintiff did not establish an actual injury, and thus did not have standing to maintain the action.

The Advisory Neighborhood Commission Reform Amendment Act of 2000 established the Office of Advisory Neighborhood Commissions to provide technical, administrative, and financial reporting assistance to the Advisory Neighborhood Commissions. The Office is intended to support the efforts of ANCs, but is not empowered to direct or supervise their actions. [BKF]

Suit Alleges District Ward Boundaries Unlawfully Drawn in Kingman Park Civic Association v. Anthony A. Williams, et al.

The Kingman Park Civic Association has filed a suit in the U.S. District Court for the District of Columbia against the Mayor and all 13 Councilmembers alleging that the District's recently redrawn ward boundaries were drawn in violation of federal and local law.

Plaintiff claims that the boundaries drawn pursuant to the Ward Redistricting Amendment Act of 2001 unlawfully dilute the voting strength of African-Americans citywide, and particularly in the community of Kingman Park, by "packing" African-American voters in Wards 5, 7, and 8 in violation of the Voting Rights Act of 1965, the Equal Protection Clause, 42 U.S.C. 1983, and D.C. Official Code 1-1011.01.

Plaintiff also alleges that the District, in drawing the boundaries, violated D.C. Official Code 1-1011.01 by failing to divide the District into eight compact and contiguous wards approximately equal in size; observe natural geographic boundaries; respect neighborhood cohesiveness; and conform the boundaries to those established by U.S. Bureau of the Census.

Lastly, Plaintiff alleges that Councilmember Ambrose intentionally excluded it from her Ward 6 Redistricting Task Force in violation of 42 U.S.C. 1983, and the Due Process and Equal Protection clauses.

On behalf of the 13 Councilmembers, the Office of the General Counsel has filed a motion to dismiss or, alternatively, motion for summary judgment. The motion urges the court to dismiss the matter against all 13 Members of the Council on the grounds that plaintiff lacks standing to bring this action, the complaint fails to meet the threshold requirements for establishing a case under the Voting Rights Act of 1965, and the action against the Councilmembers is precluded by the District's Speech or Debate Clause.

The redistricting of the District's eights wards resulted in the community of Kingman Park being transferred from Ward 6 to Ward 7. The Kingman Park Civic Association claims to represent 1,840 residents of that community. [JH]

Board of Elections and Ethics Rejects Initiative*

On March 12, 2002, the Board of Elections and Ethics rejected the proposed Treatment Instead of Jail for Nonviolent Drug Offenders Initiative on the grounds that it "seeks to establish a law which would appropriate funds in violation of District of Columbia law." The proposed initiative provided that if an eligible offender requested drug treatment, the court shall stay all proceedings against the offender pending the outcome of treatment. Certain offenders who are ineligible for treatment as a matter of right must, upon request, be provided treatment. The initiative also establishes an Ombudsman's office in the Department of Health, and establishes a Substance Abuse Treatment Fund.

The D.C. Election Code allows the Board of Elections to consult with the Council's Office of General Counsel to ensure that initiatives are in the proper legislative form, or are the proper subject for an initiative. Proposed initiatives are reviewed for compliance with the requirements of District law, including the Charter, the Initiative, Referendum, and Recall Procedures Act of 1979, the District of Columbia Appropriations Act, 2002, and judicial interpretations of those statutes. Based on this review, the Office of General Counsel concluded that the Initiative, as currently drafted, was not a proper subject for an initiative under District law because it is a law appropriating funds, and a measure that would negate or limit an act of the Council relating to the budget.

The prohibition on an Initiative containing provisions which appropriate funds is further clarified in the Initiative Procedures Act, which provides that a proposed initiative is not a proper subject for initiative if "[t]he measure would negate or limit an act of the Council of the District of Columbia pursuant to section 446 of the Home Rule Act (D.C. Official Code 1-204.46)." Section 446 of the Home Rule Act sets forth the process by which the Council enacts the budget for the District of Columbia, and transmits the budget to the President and to Congress.

The Council's response to the drug treatment issue, was to enact the Choice in Drug Treatment Act of 2000, effective July 18, 2000 (D.C. Law 13-146; 47 DCR 4350). This act included the establishment of an Addiction Recovery Fund. Monies from the fund are to be used only for payments directly to treatment providers, and as the sole source for payments to treatment providers under the Drug Treatment Choice Program. Appropriations for this purpose were included in both the District's Budget Request Act, and the Human Support Services title in the District of Columbia Appropriations Act, 2002. The initiative, if approved, could have had the effect of limiting, or negating these actions, as those terms have been construed by the D.C. Court of Appeals. The Initiative's requirements, to the extent they necessitate increased funding, would affect the Council's ability to prioritize and allocate funds among competing programs.

The District of Columbia Court of Appeals has interpreted this "negate or limit an act of the Council" language to mean that an initiative could not be used to negate or limit the provisions of a Budget Request Act passed by the Council, because the Council had preserved its ultimate control over the allocation of revenues. The court specifically stated that an initiative "could not amend the allocation in a Budget Request Act, to require, for example, that additional revenues be devoted to [housing] or that all revenues from a particular source, new or old, be devoted to a specific purpose." The proposed Treatment Instead of Jail Initiative seeks to do precisely what the Court of Appeals has said is prohibited - require that additional revenue be devoted to drug treatment, and that all revenues from this source be devoted to that purpose. For that reason, it is not the proper subject of an initiative.

A final point of discussion concerned the impact of section 127 of the D.C. Appropriations Act, 2002 ("Barr Amendment"), which prohibited the use of appropriated funds to pass a law that would legalize or reduce penalties associated with marijuana. One proposed Initiative was submitted containing language which appeared to conflict with the Barr Amendment, and another proposed Initiative was submitted without that language.

Because the proposed Initiative would interfere with the appropriation power to identify revenues and allocate them among competing programs and activities, it violates the appropriation limitation on initiatives under D.C. Official Code 1-204.101(a), would negate or limit a budget act of the Council under D.C. Official Code 1-1001.16(b)(1)(D), and was therefore found not a proper subject for an initiative. [BKF]
*Note: This initiative was redrafted and subsequently approved by the
Board of Elections and Ethics.


How To Make Sure Your Bill Clears Congress Before End of 2002

Congress is scheduled to adjourn sine die with a target date of October 4, 2002. When the Congress adjourns sine die, any Council enacted legislation that has not concluded its 30- or 60-day Congressional review prior to the adjournment will have to start a new count when the 108th Congress convenes sometime in January 2003. Legislation for which a new count begins in January 2003 will not become law until, at the earliest, the end of February or March 2003.

If enactment in 2002 or Council Period XIV is a goal, legislation requiring a 30-day Congressional review must have its second reading by the Council no later than July 1, 2002. For legislation requiring a 60-day period of Congressional review, the deadline for final Council passage is May 7, 2002. These calculations are based on the worst-case scenario of the Mayor taking his full 10 business days to review legislation.

Legislation must be transmitted to Congress no later than May 22nd to conclude its 60-day review period and July 17th to conclude its 30-day review period prior to the scheduled October 4th adjournment. Congress is scheduled to be out from May 25 through June 2; June 29 through July 7; July 29 through July 31; the entire month of August; and September 1 through 3. This means that there are 20 review days in June, 15 in July, 0 in August, 19 in September, and maybe 4 in October available to complete Congressional review prior to their scheduled adjournment date. [CB-H]

Will End of Council Period XIV Mean the End of Your Legislation?

Council Period XIV will end on December 31, 2002. This means that any introduced legislation, other than temporary legislation, that has not received final Council approval prior to December 31, 2002, will lapse, subject to reintroduction in Council Period XV. Council Rule 449(a) prevents the lapse of any temporary legislation that has had first reading by December 31, 2002. Consequently, any bill or resolution that has not had final Council approval by the last legislative session in December 2002 will lapse except for a temporary bill that has had first reading. Any matter that has lapsed at the end of a Council period can be introduced in the new Council period, subject to committee referral, committee action, and Committee of the Whole and Council approval.

However, legislative matters (resolutions, reprogramming requests, contracts in excess of $1 million, etc.) that have an unexpired

Council review period at the end of Council Period XIV will not lapse. Council Rule 449(a) prevents the lapsing of any matter that has been transmitted by the Mayor or an independent agency for a designated period of Council review. It allows such legislation that is pending at the end of a Council period to retain the same status in the new Council period as it had at the end of the prior Council period.

This means that if a legislative measure required a 60-day period of Council review and Council Period XIV ends on the 30th day of review, the first day of the new Council Period XV will be day 31, not day 1, of the 60-day review period. [CB-H]

Official Mail, Mass Mailings and the Upcoming Elections

With two elections fast approaching, the Office of the General Counsel would like to remind everyone of the Council's rules regarding official mail and mailing deadlines. According to Council Rule 805, a Councilmember who is a candidate for office may not mail, as official mail at public expense, a mass mailing within the 90-day period immediately preceding a primary, general, or special election.

"Official mail" is defined in Council Rule 801(3) as correspondence pertaining directly or indirectly to the legislative process or a legislative function, to the official duties of a Councilmember, or to other matters of public concern or public service. "Mass mailing," according to Council Rule 801(1), is the transmission through the mails of more than 100 substantially identical newsletters, news releases, or similar material during any 30-day period.

The District's Board of Elections and Ethics has scheduled this year's primary election for Tuesday, September 10, 2002, and the general election for Tuesday, November 5, 2002. June 11, 2002 will be the last date to have a mass mailing of official mail for this year's primary election. August 6, 2002, will be the last date to have a mass mailing of official mail for this year's general election.

As usual, the Office of the General Counsel is available to answer any questions you may have regarding this matter and to review any material to determine if it qualifies as official mail. [JIB]


The Council has two procedures for reviewing contracts - its streamlined review and the standard review process. The streamlined review procedure is scheduled to expire December 31, 2002. This article will outline both processes.

1. Council Streamlined Review of Contracts in Excess of $1 Million and Multiyear Contracts (D.C. Official Code 2-301.05a(j))

2. Council Standard Review of Contracts in Excess of $1 million and Multiyear Contracts (D.C. Official Code 2-301.05a((a)-(i); HRA 451; Council Rule 309)

Contracts in Excess of $1 million (D.C. Official Code 2-301.05a(a)(b)); HRA 451(b):

Multiyear Contracts (D.C. Official Code 2-301.05a; HRA 451(c)):


John Hoellen


Charlotte Brookins-Hudson, Brian K. Flowers,
Benjamin Bryant, Johnnie Barton, John Hoellen, and Donald Kaufman

Editorial Assistant:

Karen R. Barbour
To contact staff in the Office of the General Counsel.