corps answer

UNITED STATES DISTRICT COURTDISTRICT OF SOUTH DAKOTA

CENTRAL DIVISION

)

SISSETON-WAHPETON OYATE OF THE )LAKE TRAVERSE RESERVATION, ROBERT )SHEPHERD, CHAIRMAN, )

)Plaintiffs, ) Civ. No. 11-3026-RAL

)v. )

) DEFENDANTS’ PARTIALUNITED STATES ARMY CORPS OF ) ANSWER TO PLAINTIFFS’ENGINEERS, ROBERT J. RUCH, IN HIS ) AMENDED COMPLAINTOFFICIAL CAPACITY AS DISTRICT )COMMANDER, AND STEVEN E. NAYLOR, )IN HIS OFFICIAL CAPACITY AS )REGULATORY PROGRAM MANAGER, )

)Defendants. )

)

By and through their undersigned counsel, Defendants United States Army Corps of

Engineers, Robert J. Ruch, in his official capacity as District Commander, and Steven E. Naylor,

in his official capacity as Regulatory Program Manager (hereinafter collectively “Defendants” or

“the Corps”), herein respond to Plaintiffs’ Amended Complaint. The Corps has also moved for

partial dismissal of Plaintiffs’ Amended Complaint for lack of subject matter jurisdiction.

Therefore, with respect to each and every paragraph in Plaintiffs’ Amended Complaint

(Paragraphs 1 through 247), Defendants respond that Defendants have moved to dismiss

Plaintiffs’ Amended Complaint to the extent Plaintiffs challenge any Corps action that occurred

more than six years prior to the filing of the Amended Complaint and/or original Complaint, to

the extent that Plaintiffs challenge the Corps’ August 30, 2010, letter to the Tribe, and to the

extent Plaintiffs challenge the Corps’ exercise of its enforcement discretion. In addition,

Case 3:11-cv-03026-RAL Document 28 Filed 03/09/12 of 30 PageID #: 1691

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Defendants respond to each paragraph of Plaintiffs’ Amended Complaint as follows:

1. Paragraph 1 is vague because Plaintiffs do not define the term “challenge.”

Paragraph 1 also states legal conclusions to which no response is required. To the extent a

further response may be deemed to be required to the allegations contained in Paragraph 1,

Defendants deny same.

2. Defendants are without knowledge or information sufficient to form a belief as to

the truth of the allegations contained in Paragraph 2 and therefore deny same. In addition, the

referenced Treaty is a document which speaks for itself.

3. Paragraph 3 states legal conclusions to which no response is required. In

addition, the referenced Treaties are documents which speak for themselves.

4. The first sentence of Paragraph 4 contains a legal conclusion for which no

response is required. Defendants admit that Mr. Ruch and Mr. Naylor are federal officials within

the Corps, but deny the remainder of the second sentence of paragraph 4. The third sentence of

Paragraph 4 states how Plaintiffs will refer to Defendants and requires no response.

5. Paragraph 5 states legal conclusions to which no response is required. In

addition, the Corps has moved to dismiss Plaintiffs Amended Complaint in part for lack of

subject matter jurisdiction.

6. Paragraph 6 states a legal conclusion to which no response is required.

7. The first two sentences of paragraph 7 are denied. The third sentence of

Paragraph 7 constitutes Plaintiffs’ characterization of their Complaint to which no response is

required. Defendants admit that Exhibit A to the Complaint is a 2003 aerial photograph of a

portion of Enemy Swim Lake and an area within some proximity to the Lake, that Exhibit B to


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the Complaint is a 2010 aerial photograph of a portion of Enemy Swim Lake and an area within

some proximity to the Lake, and that the Corps was provided with these photographs in

September 2011. The allegation that the Tribe was exhausting it administrative remedies in

2009 and 2010 is denied.

8. Defendants deny the allegations contained in the first sentence of Paragraph 8 and

aver that the Corps has issued three letters to Merlyn Drake concerning exemptions from the

Clean Water Act permitting requirement and three letters concerning nationwide permits, which

letters speak for themselves and are the best evidence of their contents. The second sentence of

Paragraph 8 states Plaintiffs’ state of mind and a legal conclusion to which no response is

required. To the extent a further response may be deemed to be required to the allegations

contained in the third sentence of Paragraph 1, Defendants deny same.


the truth of the allegations contained in Paragraph 9 and therefore deny same.

10. Defendants deny the allegations contained in Paragraph 10, which are also vague.

11. Defendants deny the allegations contained in Paragraph 11.

12. Defendants admit that they did not issue any individual permits to Merlyn Drake

under section 404 of the Clean Water Act.


the truth of the allegations contained in Paragraph 13 and therefore deny same, except that

Defendants deny that the Corps “coached” Drake as alleged in Paragraph 13.

14. Defendants admit that a road constructed by Merlyn Drake in the vicinity of

Enemy Swim Lake is approximately one mile in length. Defendants deny the remaining


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allegations in Paragraph 14, which are also vague.


the truth of the allegations contained in Paragraph 15 and therefore deny same

16. Defendants deny that the Tribe exhausted its administrative remedies because

there were no administrative remedies for the Tribe to exhaust.

17. Defendants admit that the Corps received photographs purported to have been

taken in August 2011, which photographs are the best evidence of what they depict.

18. Paragraph 18 states legal conclusions to which no response is required.

19. Defendants admit the Corps received a permit application dated November 18,

2003, which speaks for itself and is the best evidence of its contents.

20. The November 18, 2003, application speaks for itself and is the best evidence of

its contents.

21. The certification contained in the November 18, 2003, application speaks for

itself and is the best evidence of its contents



23. Defendants admit the first sentence of Paragraph 23. The Corps December 2,

2003, letter to Merlyn Drake speaks for itself and is the best evidence of its contents. In

addition, Defendants specifically deny that the December 2, 2003, letter constituted a

preliminary, as opposed to a final decision.

24. The Corps’ December 2, 2003, letter speaks for itself and is the best evidence of

its contents. In addition, Defendants specifically deny that the December 2, 2003, letter


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constituted a preliminary, as opposed to a final decision.

25. Defendants deny the allegations contained in Paragraph 25. In addition, the

allegation that Defendants “should have known” about Mr. Fleischacker’s alleged activity states

a legal conclusion to which no response is required.




28. Paragraph 28 states a legal conclusion to which no response is required. To the

extent a response may be deemed to be required to any factual allegation contained in Paragraph

28 Defendants deny same.

29. Defendants admit that during a site visit in 2009, Merlyn Drake informed the

Corps and Tribal officials that his road was not then complete. Defendants deny the remaining

allegations contained in Paragraph 29.




32. Defendants admit that the Corps has not modified its December 2, 2003,

exemption determination and specifically deny that the Corps is under any obligation or duty to

do so.

33. Defendants admit that the Corps made a final determination in 2006 that Drake’s

proposed bridge across Enemy Swim Lake’s primary inlet tributary was exempt as a farm road.

Defendants specifically deny the allegation that this determination was a preliminary


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determination, as opposed to a final determination.



35. The allegations contained in Paragraph 35 are vague because the term “recently”

is not defined. Defendants are therefore without knowledge or information sufficient to form a

belief as to the truth of the allegations contained in Paragraph 35 and therefore deny same.

36. Defendants are without information sufficient to form a belief as to the truth of

the

allegations contained in Paragraph 36 and therefore deny same

37. Defendants admit that steel I-beams are part of the bridge structure.

38. Defendants deny the allegation contained in Paragraph 38.

39. The Corps does not issue exemptions. Rather, section 404(f) of the Clean Water

Act exempts certain activities from the requirement to obtain a permit. The Corps has informed

the Tribe of each and every instance in which it notified Drake that a proposed activity by Drake

qualified for an exemption under section 404(f) of the Clean Water Act. The Corps has not

issued nationwide permits to Drake. Rather, the Corps has verified that certain activities

proposed by Drake fell within one or more nationwide permits, which permits were previously

issued. The Corps has informed the Tribe of each and every instance that it has notified Drake

that an activity proposed by Drake fell within one or more of the nationwide permits.

40. Paragraph 40 states legal conclusions to which no response is required. To the

extent a further response may be deemed to be required to the allegations contained in Paragraph

40, Defendants are without information sufficient to form a belief as to the truth of those


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allegations and therefore deny same.



allegations contained in Paragraph 42 are vague because Plaintiffs do not specifically identify

the alleged “evidence” they refer to.

43. Defendants admit the allegations contained in Paragraph 43 and aver that the

quoted language is contained in a telephone conversation record which speaks for itself and is

the best evidence of its contents.


45. The Corps’ January 14, 2009, letter to Senator Thune speaks for itself and is the

best evidence of its contents.

46. The quoted telephone conversation record speaks for itself and is the best

evidence of its contents.


48. Defendants admit that the quoted language is found in a newspaper article which

speaks for itself and is the best evidence of its contents.

49. Defendants’ September 9, 2009, letter, which mentioned land-leveling activity on

uplands speaks for itself and is the best evidence of its contents.

50. Defendants’ September 9, 2009, letter speaks for itself and is the best evidence of

its contents.

51. The allegations contained in Paragraph 51 are vague and Defendants therefore

deny same. To the extent Plaintiffs refer to the Corps’ September 9, 2009, letter or any other


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document those documents speak for themselves and are the best evidence of their contents.


allegation in Paragraph 52 that the Corps “should have known” states a legal conclusion to

which no response is required.

53. Defendants admit that the language quoted in Paragraph 53 is found in a

document which Plaintiffs’ furnished to the Corps for the first time by letter dated March 3,

2010, and which purports to be a transcript of a meeting between certain Tribal representatives

and certain Corps representatives, including Steven Naylor, which occurred on July 31, 2009.

The Corps was not informed, either prior to or during the meeting, that any transcript was being

made of the meeting, the Corps did not consent to any recording of the meeting, and the Corps

was not provided with a timely opportunity to review the transcript for purposes of ensuring its

accuracy or correcting errors in transcription.

54. Defendants admit that the language quoted in Paragraph 54 is found in a

document which Plaintiffs’ furnished to the Corps for the first time by letter dated March 3,

2010, and which purports to be a transcript of a meeting between certain Tribal representatives

and certain Corps representatives, including Steven Naylor, which occurred on July 31, 2009.

The Corps was not informed, either prior to or during the meeting, that any transcript was being

made of the meeting, the Corps did not consent to any recording of the meeting, and the Corps

was not provided with a timely opportunity to review the transcript for purposes of ensuring its

accuracy or correcting errors in transcription.

55. Defendants admit that a document provided to the Corps by a third party contains

a representation that the United States Department of Agriculture does not possess any files


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pertaining to a grazing plan for Merlyn Drake’s lakeshore property at Enemy Swim Lake and

aver that the document speaks for itself and is the best evidence of its contents.


57. Defendants admit that the Corps informed the Tribe that Merlyn Drake leased the

north side of the property to a local farmer. Defendants are without knowledge or information

sufficient to form a belief as to the truth of the remaining allegations contained in Paragraph 57

and therefore deny same.

58. Defendants deny the allegation contained in Paragraph 58.



61. The allegations contained in Paragraph 61 state legal conclusions to which no

response is required and are also argumentative. To the extent any additional response may be

deemed to be required to the allegations contained in Paragraph 61 Defendants deny same.


63. Defendants deny the allegations contained in Paragraph 63, which are also

argumentative.

64. Defendants deny the allegations contained in Paragraph 64 and those allegations

are vague.

65. Defendants are without sufficient information to form a belief as to the truth of

the allegations contained in Paragraph 65 and therefore deny same.


extent any additional response may be deemed to be required to the allegations contained in


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Paragraph 66 Defendants deny same.

67. Defendants admit that the Corps has received from Plaintiffs, by letter dated

March 3, 2010, copies of written statements from the individuals identified in Paragraph 67,

which statements speak for themselves and are the best evidence of their contents. Defendants

deny any remaining allegations contained in Paragraph 67.

68. Defendants deny the allegations contained in Paragraph 68. To the extent

Plaintiffs refer to the statements referenced in Paragraph 67, those statements speak for

themselves and are the best evidence of their contents.

69. Defendants incorporate their responses to Paragraphs 67 and 68 herein.

Defendants otherwise deny the allegations contained in Paragraph 69.

70. Defendants admit that Plaintiff provided the Corps, by letter dated March 3, 2010,

with photographs and videos. Defendants deny the remaining allegations contained in Paragraph

70, and deny the allegation that the Tribe obtained all the photographs in 2009 because

Defendants are without sufficient information to form a belief as to the truth of that allegation.





73. Defendants admit that Corps representatives met with representatives of the Tribe

on July 31, 2009. Defendants deny the remaining allegations contained in Paragraph 73.


75. Defendants admit that in 2009 the Corps inadvertently provided the Tribe with the


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referenced document which speaks for itself and is the best evidence of its contents. Defendants

deny the remaining allegations in Paragraph 75.

76. Defendants admit that certain public records were provided to the Corps by letter

dated March 3, 2010, which records speak for themselves and are the best evidence of their

contents. Defendants deny any remaining allegations contained in Paragraph 76


78. The Corps admits that the Tribe has stated its belief to the Corps as to the truth of

the factual allegations contained in Paragraph 78, however, Defendants are without knowledge

or information sufficient to form a belief as to the truth of those allegations and therefore deny

same.

79. The referenced letter speaks for itself and is the best evidence of its contents.


80. The referenced correspondence speaks for itself and is the best evidence of its

contents. Defendants otherwise deny the allegations contained in Paragraph 80.

81. The referenced communication speaks for itself and is the best evidence of its

contents. Defendants otherwise deny the allegations contained in Paragraph 81.

82. The quoted document speaks for itself and is the best evidence of its contents.


83. The referenced report speaks for itself and is the best evidence of its contents.



85. Defendants admit that the Tribe stated its belief as reflected in Paragraph 85 but


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Defendants do not agree with the Tribe’s belief and therefore deny any remaining factual

allegations in Paragraph 85, which are also argumentative.



allegations in Paragraph 86, which are also argumentative. In addition, to the extent the

allegations contained in Paragraph 86 state legal conclusions, no response is required.



allegations in Paragraph 87, which are also argumentative. In addition, to the extent the

allegations contained in Paragraph 87 state legal conclusions, no response is required.


89. Defendants admit that the Tribe has stated Drake has not implemented a fenced

buffer zone between his grazing land and the lake.

90. Defendants admit that the Tribe has so stated its belief to the Corps as referenced

in Paragraph 90, but Defendants do not agree with the Tribe’s belief and therefore deny any

remaining factual allegations contained in Paragraph 90.

91. Defendants admit that the Tribe has so stated its belief to the Corps as referenced

in Paragraph 91, but Defendants do not agree with the Tribe’s belief and therefore deny any

remaining factual allegations contained in Paragraph 91.


93. Defendants are aware that David R. German has prepared a report and other

materials which speak for themselves and are the best evidence of their contents. The Tribe’s


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letter also speaks for itself and is the best evidence of its contents. To the extent any additional

response may be deemed to be required to the allegations contained in Paragraph 93 Defendants

deny same.





deny same.





deny same.





deny same.






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deny same.

98. Paragraph 98 states conclusions of law to which no response is required. To the






102. Defendants deny the allegations contained in Paragraph 102, which are vague.




106. Paragraph 106 contains legal conclusions to which no response is required. To

the extent a further response may be deemed to be required to the allegations contained in


107. Paragraph 107 contains legal conclusions to which no response is required. To the



108. Paragraph 108 contains legal conclusions to which no response is required. To the



109. Defendants admit that they have received written communications from the Tribe

and certain individuals expressing opinions which speak for themselves and are the best


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evidence of their contents.


the truth of when the Tribe came to the belief it states in Paragraph 110 and therefore deny same.

The substance of the Tribe’s belief states a legal conclusion to which no response is required.


112. Paragraph 112 contains legal conclusions to which no response is required.

113. Defendants admit that the Corps did not provide public notice of Mr. Drake’s

activities, however, the Corps participated in a public meeting on January 25, 2005, attended by

a Tribal official, at which the Corps informed those in attendance of the Corps’ decisions

regarding Drake’s activities as of that time.


115. Defendants admit that the Corps has prepared no environmental assessment or

environmental impact statement under the National Environmental Policy Act (“NEPA”) for any

activity specifically proposed by Mr. Drake, but aver that Corps undertakes whatever

environmental analysis is appropriate under NEPA when the Corps issues its Nationwide Permit

Regulations.


the extent any further response may be deemed to be required to the allegations in Paragraph 116

Defendants deny same.

117. The Corps admits that it was informed of the Tribe’s opinion. With respect to the

substance of the Tribe’s opinion, Paragraph 117 contains legal conclusions to which no response

is required. With respect to any factual allegations forming the substance of the Tribes’ opinion,


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Defendants are without knowledge or information sufficient to form a belief as to the truth of

those allegations and therefore deny same.

118. The Corps admits that the Tribe stated this opinion to the Corps, but Defendants

deny the underlying factual allegations forming the Tribes’ opinion.







125. Defendants deny the allegations contained in Paragraph 125, which also calls for

speculation as to a fish’s state of mind.


127. The referenced report speaks for itself and is the best evidence of its contents.



130. Paragraph 130 states a conclusion of law to which no response is required.

131. The referenced document speaks for itself and is the best evidence of is contents.


133. The June 17, 2005, letter, a copy of which was provided to the Corps, speaks for

itself and is the best evidence of its contents.



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the truth of the allegation of when the Tribe first formed its opinion as stated in Paragraph 134

and therefore deny same. The underlying opinion states legal conclusions to which no response

would be required if it were alleged as such.



137. Paragraph 137 states a legal conclusion to which no response is required and is

also argumentative. To the extent a further response may be deemed to be required to the

allegations contained in Paragraph 137, Defendants are without knowledge or information

sufficient to form a belief as to the truth of those allegations and therefore deny same.









the extent any further response may be deemed to be required to the allegations contained in


143. The allegations contained in Paragraph 143 regarding the length of the road are

repetitive of the allegation contained in Paragraph 14 and Defendants have already responded to

those allegations. Defendants deny the allegations contained in the remainder of Paragraph 143.


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144. The referenced letter speaks for itself and is the best evidence of its contents.

145. The November 4, 2005, permit application quoted in part in Paragraph 145 speaks

for itself and is the best evidence of its contents.

146. The referenced application speaks for itself and is the best evidence of its

contents.

147. Defendants admit the allegations contained in Paragraph 147.

148. The referenced application speaks for itself and is the best evidence of its

contents.



extent any further response may be deemed to be required to the allegations contained in













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159. Defendants admit that the Corps did not notify the Tribe’s Historic Preservation

Office but deny that the alleged activities constitute undertakings.

160. Defendants admit that the Corps did not notify the SHPO but deny that the

alleged activities constitute undertakings.









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the truth of the allegation contained in Paragraph 166 and therefore deny same.


the truth of the allegation contained in Paragraph 167 regarding the matters Mr. Fletcher worked

on while employed by EPA and therefore deny same. Defendants deny that Mr. Fletcher has

submitted numerous written filings with the Corps.


To the extent any further response may be deemed to be required to the allegations contained in



the allegation of when the Tribe first formed its opinion as stated in Paragraph 169 and therefore

deny same. To the extent any further response may be deemed to be required to the allegations

contained in Paragraph 169, Defendants deny same.



172. The Tribe’s letter speaks for itself and is the best evidence of its contents.


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173. The August 30, 2010, letter speaks for itself and is the best evidence of its

contents. Defendants deny that the letter constituted a “final decision” as that term appears to be

used by the Tribe.

174. Defendants repeat their responses to Paragraphs 1-174.




176. Defendants deny the allegations contained in Paragraph 176, which are also

vague.



179. Defendants admit that Plaintiffs have asserted the stated opinion to the Corps but

deny the remaining allegations contained in Paragraph 179.

180. Defendants admit that certain members of the public and the Tribe have expressed

the stated opinion but deny the remaining allegations contained in Paragraph 180.








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185. Defendants deny the allegations contained in Paragraph 185, which are vague.

186. Paragraph 186 states legal conclusions to which no response is required, except

Defendants deny that any decisions referred to were preliminary.

187. Paragraph 187 states legal conclusions to which no response is required, except

that Defendants deny that any final decision was made in 2010.

188. Defendants have moved to dismiss Count 2 of Plaintiffs’ Amended Complaint

and therefore do not respond further to the allegations contained therein.

















23
























24
























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219. Defendants repeat their responses to Paragraphs 1 through 219.




Paragraph 221, Defendants deny same. However, Defendants admit that whenever the Corps

determined that a proposed activity to be undertaken by Mr. Drake was authorized by a

nationwide permit, the Corps found that he activity had independent utility.

222. Defendants admit that the activities to be undertaken by Mr. Drake were all

within approximately a one mile radius. Defendants deny all remaining allegations in Paragraph

222. 223. Paragraph 223 states legal conclusions to which no response is required. To the





Paragraph 224 Defendants deny same, and specifically deny that the Corps made any final

decision in 2010.







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Paragraph 230 Defendants deny same. Defendants specifically deny that the Corps made any

final decision in 2010.




To the extent any further response may be deemed to be required to the allegations contained in




Paragraph 234 Defendants deny same. Defendants specifically deny that the Corps made any

final decision in 2010.



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237. The referenced document speaks for itself and is the best evidence of its contents.



239. Defendants admit that Mr. Fletcher contacted the Corps, but deny that he was

ignored. Paragraph 239 is also argumentative.









244. The referenced document speaks for itself and is the best evidence of its contents.

Defendants are without knowledge or information sufficient to form a belief as to what Mr.

Fletcher left out of the document and therefore deny that portion of the allegation.




246. Paragraph 246 states legal conclusions and a prayer for relief to which no

response is required. To the extent any further response may be deemed to be required to the


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allegations contained in Paragraph 246 Defendants deny same.

247. Paragraph 247 states legal conclusions and a prayer for relief to which no

response is required. To the extent any further response may be deemed to be required to the

allegations contained in Paragraph 247 Defendants deny same.

248. To the extent any factual allegation of Plaintiffs’ Amended Complaint has not

been specifically admitted, Defendants deny such allegation.

The remainder of Plaintiffs’ Amended Complaint states its prayer for relief to which no

response is required.

DEFENSES

1. This Court lacks subject matter jurisdiction over Plaintiffs’ Amended Complaint

to the extent Plaintiffs challenge any Corps action that occurred more than six years prior to the

filing of Plaintiffs’ Complaint or Amended Complaint and to the extent Plaintiffs challenge any

exercise of the Corps’ enforcement discretion.

2. The Corps’ August 30, 2010, letter to the Tribe does not constitute final agency

action for purposes of judicial review and the Court lacks jurisdiction over Plaintiff’s Amended

Complaint to the extent Plaintiffs challenge the Corps’ August 30, 2010, letter. The letter was a

response to the Tribe’s letter and it merely informs the Tribe of previous actions the Corps had

already taken, the majority of which Plaintiffs failed to challenge within the applicable statute of

limitations, and of the Corps’ exercise of enforcement discretion, which is not justiciable.

3. Plaintiffs’ Amended Complaint fails to state claims for which relief can be

granted.

4. Plaintiffs’ Amended Complaint is barred in whole or in part by laches.


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5. Injunctive relief should not be awarded against the Corps for equitable reasons.

6. Because review of the merits of Plaintiffs’ claims is required to be based solely

upon the Corps’ administrative record, and under well-established standards of judicial review,

to the extent the Court has jurisdiction over those claims, neither Plaintiffs’ Amended Complaint

nor the Corp’s Answer may be used to establish any question of fact or law on the merits.

7. Even if Plaintiffs were to prevail on any of their claims, the only available remedy

is a remand to the Corps. The Court may not direct the Corps to take any particular action on

remand.

8. Plaintiffs’ 247-paragraph Amended Complaint in this record review case violates

the requirement of Fed. R. Civ. P. 8(a)(2) that the Amended Complaint must contain a short and

plain statement of the claim.

9. An award of costs and fees against the Corps is inappropriate.

WHEREFORE, the Corps prays that:

A. the Court dismiss Plaintiffs’ Amended Complaint against it;

B. the Court award the Corps its costs and disbursements in this action; and

C. the Court award such other relief as is just and appropriate.


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Respectfully submitted,

IGNACIA S. MORENO,Assistant Attorney General

s/David A. Carson DAVID A. CARSONUnited States Department of JusticeEnvironment and Natural Resources Division999 18th StreetSouth Terrace, Suite 370Denver, Colorado 80202(303) [email protected]

s/Jody H. Schwarz Jody H. Schwarz (DC Bar #493998)U.S. Department of JusticeEnvironment & Natural Resources DivisionNatural Resources SectionP.O. Box 7611Washington, D.C. 20044(202) 305-0245 (tel.)(202) 305-0506 (fax)[email protected]

Dated: March 9, 2012

CERTIFICATE OF SERVICE

It is hereby certified that on March 9, 2012, the undersigned caused the foregoing

Defendants’ Partial Answer to Plaintiffs’ Amended Complaint to be served electronically on

counsel in this case who are registered with the Court’s ECF system by filing it electronically

with the Court. Any counsel not registered for ECF service will be served by first class mail.

/s/David A. Carson David A. Carson


corps answer

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