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STATE OF RHODE ISLAND SUPERIOR COURT

WASHINGTON, SC

IN RE:

ESTATE OF JOYCE C. WILLNER, C.A. NO: WP13-0400

by and through her

GUARDIAN

APPELLANTS’ PRETRIAL MEMORANDUM

INTRODUCTION

This matter addresses important issues concerning the rights of wards, especially those

with dementia, such as Alzheimer’s, petitioners, and guardians under Rhode Island’s

Guardianship Statute and the due process clause of the US and RI Constitutions. At the heart of

this case are the rights and wishes of an 88-year-old holocaust survivor with moderate

Alzheimer’s who wants to return home from a nursing home in which she no longer wishes to

reside. There was no objection to the initial placement, but once she has sufficiently recuperated

from her life-threatening battle with pneumonia, she wanted to return to her home, and to have

her son serve as her Guardian. In opposition to her wishes are her husband and daughter who are

aligned with each other and seek to keep her isolated in a nursing home because they believe she

is safer there. The Disability Law Center has been permitted to intervene on behalf of the ward,

Joyce Willner. In addition, an amicus brief has been or will be submitted on her behalf by the

Rhode island Chapter of the American Civil Liberties Union.

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STATEMENT OF THE CASE

Joyce Willner has had a difficult and challenging life. Born in Eastern Europe in 1925,

she was persecuted by the Nazis because of her Jewish faith, imprisoned and nearly starved to

death at the infamous Bergen Belsen Concentration Camp, after which Joyce emigrated to Israel

and later to the United States. She has been married to her husband Kurt since 1948 and is the

devoted mother of her daughter, Yaffa, and her son, Michael, and the doting grandmother of

Michael’s two children now young adults. She and her husband purchased their home on the

shore of Indian Lake in South Kingstown, Rhode Island, in 1968. Her life has revolved around

her family, friends, and neighbors.

Joyce was diagnosed with dementia in 2006 but continued to live with her husband, who

is being treated for bipolar disorder, in their Indian Lake home. Part-time home care aides were

employed for approximately nine hours a day, six days a week, from 2006 to 2010. By 2011,

however, their long-term healthcare insurance was depleted. Their son, Michael, began spending

up to two weeks every month living with and assisting in the care of both of his parents,

commuting from his home is in Virginia. Yaffa would visit on Sundays from her home in

Boston, Massachusetts. Since 1990, Kurt’s and Joyce’s next-door neighbors and friends,

Marshall Feldman and Karla Steele have shared religious holidays as well as family celebrations

and social events with the Willners.

In April of 2012, Joyce contracted the flu which required hospitalization. She developed

pneumonia and was placed in intensive care, where she fought for her life for seven days. Even

after she had recovered from her pneumonia and had been discharged from the ICU, it was

feared that she was near death, and the hospital placed her in hospice care. A morphine drip was

administered to her which her son Michael believed was going to result in her death. Michael’s

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advocacy for the discontinuation of the morphine drip led to a family rift when Kurt and Yaffa

argued for continuation of the morphine drip and end of life hospice care. Ultimately, the

hospital relented, discontinuing the morphine drip, and Joyce quickly recovered. She was

discharged from the hospital on May 9, 2012, was temporarily placed at Roberts Health Centre, a

nursing home in North Kingstown, Rhode Island, for rehabilitation. This placement was

followed by intra-family debate over whether Joyce should be in hospice care at the nursing

home as advocated by Kurt and Yaffa but opposed by Joyce and Michael. By June of 2012 she

was determined to be too healthy to be eligible for hospice care. Kurt continued to try to have

her placed in hospice, but to no avail.

By September of 2012, Kurt Willner retained counsel and pursuant to a 1993 Power of

Attorney, though he knew Joyce had granted Michael her Power of Attorney in 2004, transferred

his and Joyce’s ownership interest in their home to himself, as sole owner, and declared that

Joyce could not return home. Kurt also applied for Medicaid on behalf of Joyce, falsely claiming

that she had chosen not to live in her home. Son Michael sought legal counsel and filed a

Guardianship petition to protect his mother and to help her in her efforts to be discharged from

the nursing home and to return home. The South Kingstown Probate court, the Honorable

Stephen R. White, presiding, appointed Michael as temporary guardian, over Kurt’s objection,

and George Bauerle, III, Esq., as a Guardian Ad Litem (GAL). A geriatric psychiatrist, Andrew

Rosenzweig, MD, completed a full DMAT which indicated that Joyce needed a guardian to help

her with medical, financial, and residential issues but only limited help with associational issues.

He opined that she did not require a nursing home level of care.

An evidentiary hearing for the appointment of Michael as permanent guardian was held

in the South Kingstown Probate Court in November 2012, at which the GAL and Dr.

Rosenzweig testified in person and by and through the GAL Report and the doctor’s two

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DMATs and his deposition testimony1. Kurt opposed the Permanent Guardianship Petition, but

Joyce’s attending physician at the nursing home did not testify in opposition to Dr. Rosenzweig’s

diagnosis. The Court granted the Petition and appointed Michael as Permanent Guardian of the

Person and Estate of his mother. No appeal of the December 14, 2012, Order was taken and

thus, it became the law of this case.

In January of 2013, Michael and Kurt met with Joyce and discussed her living

arrangements. Joyce said she wanted to move back to her home, and Kurt agreed to allow her to

return. Michael and his father reached an agreement on the terms of Joyce’s return home and an

agreement concerning how to finance Joyce’s home care needs. However, in February of 2013,

Yaffa convinced Kurt to retain new counsel to attempt to block any efforts by Michael to get

court approval for Joyce’s home care plan and to get access to Joyce’s assets and income to help

pay for Joyce’s care and legal expenses. Also, in February of 2013, Kurt inappropriately

transferred title to the family home to his daughter ,Yaffa, retaining a life estate only for

himself.

Michael began taking Joyce out for excursions to eat, to visit her friends and neighbors,

and for scenic rides. Kurt, however, would not let Michael bring Joyce to the marital home for a

visit. (Previously, when the nursing home had recognized Kurt as Joyce’s decision-maker, Kurt

had prohibited Michael from taking Joyce anywhere, yet Kurt despite having a driver, had never

taken Joyce out of the nursing home.)

By April of 2013, the battle lines were drawn. Joyce and Michael continued to attempt to

get approval for Joyce’s return home or at least back to her community, since her friends and

neighbors offered to open their home for her to live there with appropriate round-the-clock

supervision. Kurt filed on April 25, 2013, a Petition for Removal of the Guardian, arguing that

1 The hearing took place on November 29, 2012, and the Order was entered on

December 14, 2012.

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“Michael fails to act in the best interests of the ward.” Michael filed an objection, and a hearing

date of July 18, 2013, was requested.

In May Michael filed a Pro Se Entry of Appearance, but Kurt’s attorney filed an

objection, claiming that Michael was attempting to practice law as an unlicensed Rhode Island

attorney.

In July, the newly appointed South Kingstown Probate Court Judge, the Honorable

Merlyn O’Keefe, Esq., (Judge White had resigned) issued the following Orders, without

holding an evidentiary hearing:

1. Denied Michael A. Willner’s Motion to Entry Appearance Pro Se (7/16/13);

2. Struck all of the motions and pleadings filed by Michael A. Willner;

3. Denied H. Jefferson Melish, Esq.’s Entry of Appearance on behalf of the Estate of

Joyce C. Willner (7/16/13);

4. Overruled Michael Willner’s objection to Kurt Willner’s proposed Order

(7/25/13);

5. Denied the Guardian’s Motion for Approval of home health care plan (7/25/13);

and

6. Denied the Guardian’s Motion for Access to Ward’s Income and Assets (7/25/13).

The removal petition and objection thereto were rescheduled for September 19, 2013.

On July 31, 2013, Appellants filed a Claim of Appeal and Joyce with the assistance of her

Guardian son and her attorney filed for divorce from Kurt seeking an equitable distribution of

marital assets including title to the marital domicile and other relief. She also sought a

Temporary Order of relief seeking a return to her home and access to her assets and income. The

Divorce Summons, Complaint, and Motion for a Temporary Order were served on Kurt Willner

on August 12th

, with a hearing in the Washington County Family Court scheduled for September

27th

. On August 14th

, Kurt Willner filed a Miscellaneous Petition in Probate Court seeking to

schedule the Removal Petition for August 22nd

.

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On August 14th

, the Probate Court Judge, sua sponte, scheduled an “emergency” hearing

to take place on the following morning with email notice to the offices of H. Jefferson Melish

and R.J. Connelly and with no notice to the ward or the guardian. A hearing took place

telephonically on the 15th

over the objection of Attorney Melish (who was out-of-state on

vacation) – a hearing without proper notice to counsel, the guardian, or the ward and without an

evidentiary hearing. The Probate Court Judge removed the Guardian and appointed Yaffa

Willner as the Successor Guardian. Thereafter, Attorney Melish returned to Rhode Island to file

an Amended Claim of Appeal on August 20th

challenging the August 15th

removal order.

On September 27th

the Family Court dismissed Joyce’s divorce complaint without

prejudice pursuant to the Successor Guardian’s request.

By letter dated September 13, 2013, to the Administrator of the Roberts Health Centre,

the Successor Guardian, through counsel, ordered the following:

1. Michael A. Willner is allowed visitation with his mother, Joyce C. Willner, but

that those visits are to be limited to regular business hours and are to be in the

common areas only.

2. Mrs. Willner is not to be removed from the facility by anyone except Kurt Willner

or Yaffa Willner except in a medical emergency or for a scheduled doctor’s

appointment(s).

3. Marshall Feldman and Clara [sic] Steele are not to be permitted any visitation at

all.

Thus, Joyce is currently not allowed to leave the nursing home for rides with Michael or

to visit her friends and neighbors. Kurt and Yaffa have not taken Joyce out of the nursing home

since Yaffa was appointed Successor Guardian.

On January 25, 2014, the Successor Guardian filed a status report indicating that the

ward’s medical condition is stable and that there are no perceived changes in the ward’s decision-

making capacity.

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Appellant’s Motion to Assign and Accelerate Trial was granted. A Scheduling Order

required the parties to complete discovery by February 21, 2014. A date certain for trial was set

for April 14, 2014.

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ISSUES PRESENTED

While it is settled that Joyce Willner needs a permanent Guardian and Michael Willner

was appointed her Guardian with her consent after appropriate DMATS and a GAL report were

received and after an evidentiary hearing that was not appealed, there remain the following legal

issues that need to be decided:

A. Whether the Probate Court met procedural and substantive statutory requirements

when it removed Michael Willner as Guardian of his mother.

The burden of proof on this issue should be on the husband who filed both the

removal petition and the miscellaneous petition. Clear and convincing evidence is

required. RIGL § 33-15-5.

B. Whether the Probate Court erred in denying the ward’s rights to participate in

making decisions concerning who her guardian should be, and whether she has the

right to reside in her own home with 24-hour supervision rather than being

institutionalized in a nursing home against her will.

C. Whether the Probate Court erred in denying the Guardian access to the ward’s

estate and income.

D. Whether the Probate Court erred in denying the Guardian’s Motion to represent

himself pro se.

E. Whether the Probate Court erred in prohibiting the Estate Attorney from

representing both the ward and the Guardian when their interests were the same.

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ARGUMENT

A. The Probate Court failed to meet the procedural and substantive requirements of the

Guardianship Statute RIGL Chapter 33-15-1 et seq., when it removed Michael Willner as

guardian of his mother.

The Probate Court violated the notice requirement under the Guardianship Statute when

he rescheduled, sua sponte, a hearing on the Removal Petition the day after the Miscellaneous

Petition seeking to speed up that hearing was filed, with no notice to the Ward and less than one

day’s email notice to both attorneys. (Attorney Melish, out-of-state on vacation and with no staff

in his office that day, was alerted to it by his staff by phone on the morning of the hearing.) The

Removal Petition had been filed on April 25, 2013, originally scheduled for hearing on July 19,

2013, and then rescheduled for September 19, 2013; the Miscellaneous Petition had been filed on

August 14, 2013, the day before the actual hearing, with a requested hearing date (that also would

have provided insufficient notice) of August 22, 2013, before being abruptly rescheduled for the

following day.

RIGL § 33-15-17.1 requires 14 day notice to the respondent at the commencement of a

case and 10 day notice thereafter. RIGL Title 33 Chapter 15 sets forth Probate Court practice

requirements”: RIGL 33-22-7 requires notice by the court before proceedings in “any complaint

for the removal of an executor, administrator, conservator, or guardian.” RIGL § 33-22-11

requires notice by advertisement “once a week for at least two (2) weeks. The first advertisement

to be published at least fourteen (14) days before the first of any hearing dates contained in such

notice ….” §33-22-14 also requires findings by the Court that notice has been provided. In this

case, neither attorney received adequate notice, the ward received no notice at all, and the

Probate Court provided no findings that adequate notice had been provided during the August 15,

2013 hearing. See transcript of 8/15/13 hearing. Jt. Exhibit #23.

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The substantive requirements of the removal section of the Guardianship Statute were not

followed or met either. See RIGL §33-15-18. The removal statute lists the following specific

grounds for the removal of a Guardian:

1. That he/she has not fulfilled or is no longer able to fulfill the duties of the

Guardianship Order or Guardianship Law, or

2. That the ward no longer needs a guardian based on a DMAT, or

3. That the Guardian resigns.

One of the above conditions must be found by the court to be applicable. None of the grounds

apply to the facts and circumstances of this case. The ward did not request the removal of her

son. Her husband was not her guardian and was not filing the Miscellaneous Petition on her

behalf as he clearly was in direct conflict with her by refusing to support her desire to return

home or even to reside in her next-door-neighbor’s home. Furthermore, there is no evidence of

breach of duty, neglect, or misconduct on the part of the guardian to justify the filing of a

removal petition or any court findings to warrant the removal of Michael Willner as Guardian of

his mother against her wishes.

The arbitrary appointment of Yaffa Willner as Successor Guardian by the Probate Court

at the “emergency” August 15, 2013 hearing is totally against the wishes of Joyce Willner. RIGL

33-15-6 requires that the Court consider the “wishes expressed by the individual found to be

incapacited as to preferences among individuals eligible to serve as limited guardian or

guardian.” Yaffa Willner clearly refuses to carry out the wishes of her mother and thus cannot

meet the individual needs and desires of her mother. Yaffa Willner also has a direct conflict of

interest as a consequence of the (possibly illegal) appropriation of the jointly owned marital

domicile South Kingstown by Kurt Willner and his transfer of its ownership to his daughter.

Yaffa has directly aligned herself with her father in thwarting Joyce Willner’s desire to return to

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her home. To date, her role as Successor Guardian has been to further isolate Joyce from her

son by restricting his visiting time, preventing him from taking her out of the nursing home, and

denying her access to her good friends and neighbors, Marshall Feldman and Karla Steele. See

Jt Exhibit #27. When this issue is tried de novo in Superior Court, the moving party, Kurt

Willner, who filed the removal and miscellaneous petitions, will have the burden of proof and

must meet the “clear and convincing evidence” standard of RIGL § 35-15-5

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B. The Probate Court erred in denying the ward’s rights to participate in decisions

concerning who her Guardian should be, and whether she has the right to reside in her home with

24/7 supervision rather than be institutionalized in a nursing home against her will.

The legislative intent is set forth in § 35-15-1 as follows:

The legislature finds that adjudicating a person totally

incapacitated and in need of a guardian deprives that person of all

his or her civil and legal rights and that this deprivation may be

unnecessary. The legislature further finds that it is desirable to

make available, the least restrictive form of guardianship to assist

persons who are only partially incapable of caring for their needs.

Recognizing that every individual has unique needs and differing

abilities, the legislature declares that it is the purpose of this act to

promote the public welfare by establishing a system that permits

incapacitated persons to participate as fully as possible in all

decisions affecting them; that assists such persons in meeting the

essential requirements for their physical health and safety, in

protecting their rights, in managing their financial resources, and

developing or regaining their abilities to the maximum extent

possible; and that accomplishes these objectives through providing,

in each case, the form of assistance that least interferes with the

legal capacity of a person to act in his or her own behalf. This

chapter shall be liberally construed to accomplish this purpose.

Throughout the Guardianship statute there are protections for the rights of respondents.

The law sets forth notice requirements, the appointment of a guardian ad litem, the requirement

of DMATs (a decision making assessment tool), the appointment of counsel, and the right to a

hearing to “strike a delicate balance between providing the protection and support necessary to

assist the individual and preserving, to the largest extent possible, the liberty, property, and

privacy interests of the individual.” RIGL § 33-15-4. The respondent’s rights are also set forth

in §33-15-5:

No limited guardian or guardian shall be appointed until after a

hearing on the petition. The hearing shall be before a judge of the

probate court of the city or town where the petition was filed.

(1) The respondent shall have the right to be present at the hearing

and all other stages of the proceedings.

(2) The respondent shall be allowed to:

(i) Compel the attendance of witnesses;

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(ii) Present evidence; and

(iii) Confront and cross examine witnesses.

(3) The standard of proof shall be clear and convincing evidence.

(4) The Rhode Island rules of evidence shall apply.

(5) Any professional whose training and experience aid in the

assessment of decision making ability and who has so assessed the

respondent may be permitted to provide expert testimony regarding

the decision making assessment of the respondent.

The guardian ad litem provisions, RIGL § 35-15-7, outline additional protections to

ensure that the respondent has the right to choose or object to the appointment of a guardian, the

right to counsel, and the right to participate in all decisions affecting her. Michael Willner has

consistently sought to advocate for his mother on these matters and to follow her clearly

articulated wishes concerning living in her home (or, at least, in her community) and her choice

of guardian and attorney. This Court has the opportunity to afford to Joyce Willner all of the

rights and protections she deserves and to hear her voice in determining where she lives, who

should be her guardian and who should be her attorney at a full evidentiary hearing.

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C. The Probate Court erred in denying the guardian access to the ward’s estate and

income.

The Court in November of 2012 after an evidentiary hearing and after receiving a GAL

report and an expert’s testimony concerning Joyce Willner’s decision-making ability found that

she needed a guardian and that her son was qualified to be so appointed. The Probate Court

initially limited the responsibilities of the Guardian “to a review of financial assets and an

investigation of same.” The Probate Court Judge also kept Joyce Willner’s residency “status

quo until Michael Willner submits a proposed plan for her care to be approved by this Court.” Id.

Because there was a family rift between wife/son and husband/daughter, the Court was urging

mediation to help resolve the financial issues and competing interests that were self-evident. See

12/14/12 order Jt. Exhibit No 8.

The competing interests were temporarily resolved in January of 2013 when father and

son agreed to honor Joyce’s desire to return home and worked out an accommodation concerning

Joyce’s and Kurt’s income streams and the payment of expenses. Unfortunately, in February

Kurt changed his mind, deeded title to the marital home from himself to his daughter (retaining a

life estate only for himself), and hired new attorneys to block Joyce’s efforts to return home.

The Probate Court erred by not empowering the guardian to have access to Joyce’s assets

and income so that he could fulfill his duty to help her return home. Joyce’s assets and income

were completely controlled by her husband and not the Guardian. She was not only held against

her will in the nursing home, but also stripped of her home and annuities as well as the income

from her Social Security, German Reparations, and annuities. Thus, her liberty and property

interests were stripped away from her as her husband and daughter successfully blocked her

wishes by convincing the Probate Court to deny Michael Willner access to his mother’s estate.

The Probate Court failed to protect Joyce Willner’s person and estate by denying her, through her

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son/advocate, access to her assets and income to pay for her home care and legal fees.

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D. The Probate Court erred by denying Michael Willner’s Motion to represent himself.

Appellant Michael Willner has the right to represent himself pro se. He retained Attorney

Melish to represent the interests of his mother and her estate. He wished to assert the right to

represent himself as Guardian. The Probate Court denied him that right. The Court also refused

to allow Attorney Melish to represent either the Estate or the ward, allowing him only to

represent the Guardian.

RIGL §33-15-2 states in relevant part that “[a]ny person may file a verified petition for

the appointment of a guardian,” which Appellant filed with the Probate Court. In Rhode Island,

it also settled law that “[a] pro se litigant, like any litigant, is guaranteed a meaningful

opportunity to be heard.” O’Brien v. Sherman, 2009 R.I. Super. LEXIS 15 (R.I.Super.Ct. 2009),

citing Logan v. Zimmermann Brush Co., 455 U.S. 422, 437, 102 S.Ct. 1148, 1158, 71 L.Ed .2d

365 (1982). Thus, Appellant, as Petitioner, had a right to be heard by the Probate Court as a pro

se litigant. The Rhode Island Judiciary’s website, which is maintained by the Rhode Island

Administrative Office of State Courts, states in relevant part that, “You may represent yourself in

a lawsuit … In criminal matters, you have a constitutional right to represent yourself. In civil

matters, there is no such right but it is a choice made by you.”

Thus, Appellant, as Petitioner, had a right to be heard by the Probate Court as a pro se

litigant.

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E. The Probate Court erred when it prohibited the Estate Attorney from representing the

ward and the guardian when their interests were the same.

Based on the GAL report and Dr. Rosenzweig’s DMAT and testimony, it is abundantly

clear that Michael Willner and Joyce Willner have no conflict of interest. Joyce Willner wants

Attorney Melish to represent her interests which are identical to those of her son, who is her

strongest advocate. Attorney Melish was retained by Michael Willner to represent his mother

and her estate. As long as there is no conflict of interest between mother and son there is no

justification for denying Joyce’s wishes to have Attorney Melish and the Rhode Island Disability

Law Center advocate on her behalf.

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AUTHORITIES

The appellants rely on the following cases and standards which are submitted as

attachments hereto:

1. In RE: Laurette Borduas Eifrig

Superior Court Slip Decision filed June 22, 2007, setting forth the standard of review

for probate appeals.

2. Olmstead, Commissioner, Georgia Department of Human Resources, et v. L.C. et al

Concerning the rights of the disabled to live in the most appropriate integrated setting

appropriate to her needs. 527 U.S. 581 at 597-603 (1999).

3. National Guardianships Association Standards of Practice Fourth Edition 2013

Especially citing Standards regarding Informed Consent(6)

Standards for Decision-Making (7)

Least Restrictive Alternative (8)

Duties re Pers (12)

Medical Treatment (14)

4. Jacob Winkelman, a minor, by and through his parents and legal guardians, Jeff and

Sandee Winkelman, et al v. Parma City School District, 550 U.S. 516 (2007)

Concerning the rights to pro se representation

The appellants also rely on the legal arguments and statutory and case law submitted by

the Rhode Island Disability Law Center and the Rhode Island Chapter of the American Civil

Liberties Union on behalf of the ward.

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ANTICIPATED TESTIMONY

The appellants expect to call Marshall Feldman and Michael Willner as their primary

witnesses. They reserve the right to call Kurt Willner and Yaffa Willner as adverse witnesses.

They may utilize photographs and videos to assist Joyce Willner in expressing her wishes

concerning where she wants to live and who she wants to be her Guardian. Finally, the

appellants may use their expert, Dr. Andrew Rosenzweig, to testify and reserve the right to call

him as a rebuttal witness if deemed necessary.

It is expected that Marshall Feldman’s testimony will be consistent with the affidavits he

has submitted in these proceedings both by himself and jointly with his wife, Karla Steele.

Michael Willner’s testimony will deal with all disputed issues of this case and

supplement the record concerning his mother’s life and her desire to live in the community and

participate in family life as a respected and valued member and not be isolated in an institution

separated from her friends and neighbors.

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CONCLUSION

At the conclusion of this Trial, the appellants will seek the following relief:

1. That the July 16th

and 25th

and August 15th

rulings of the Probate Court be reversed

and that the Superior Court order that Michael Willner be the Guardian of the Person and Estate

of Joyce C. Willner with all of the rights and responsibilities as set forth in RIGL § 33-15-1 et

seq.;

2. That Joyce C. Willner be permitted to live either in her own home or in her neighbors’

home at the discretion of the Guardian with input from the ward;

3. That the Guardian have full access to and authority over the property and income of

the ward to assist in paying her home care and legal expenses;

4. That the Court declare that Michael Willner has the right to represent himself pro se at

his discretion;

5. That the Court declare that Attorney Melish may represent the Estate including the

ward and guardian as long as they do not have a conflict with each other and each wishes to be

represented by him.

In addition, appellants request that this Court retain jurisdiction over this matter to ensure

compliance with its orders.

RESPECTFULLY SUBMITTED

On behalf of the Appellants,

__________________________

H. JEFFERSON MELISH, #3100

74 Main Street

Wakefield, RI 02879

(401) 783-6840

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CERTIFICATION

I herby certify that on the __ day of April, 2014, I emailed and mailed a copy of the

foregoing document to the following:

R.J. Connelly, III, Esq./Alan Barnes, Esq.

CONNELLY LAW OFFICES

372 Broadway

Pawtucket, RI 02860

Anne M. Mulready, Esq.

Rhode Island Disability Law Center, Inc.

275 Westminster Street, Suite 401

Providence, RI 02903

Michael Willner

11521 Potomac Road

Lorton, VA 22079-4264

____________________