Door County Tourism Zone Commission : Meeting Minutes

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DOOR COUNTY TOURISM ZONE COMMISSION
MINUTES OF JANUARY 21, 2010
The Landmark/Egg Harbor

ACTION ITEMS:
Tice moved and Weddig seconded to approve the agenda as submitted. Motion passed unanimously.

Nelson moved and Weddig seconded to accept the minutes of December 17, 2009, as submitted. Motion passed unanimously.

Nelson moved and Stayton seconded to approve Resolution No. 5-012110 to hold the Annual Meeting on a date to be determined by the Chairperson or by resolution of the Commission, as amended. Motion passed unanimously.

Nelson moved and Stayton seconded to hold back $75,000 from the DCVB for TZC cash flow needs, which will be paid back 75% in July and 25% in August. Motion passed unanimously.

Larson moved and Tice seconded to accept Payables and Reports as submitted. Motion passed unanimously.

Nelson moved and Larson seconded to convene into Closed Session pursuant to Wisconsin State Statutes, Section 19.85(1)(a)(f) or (g) to Consider Enforcement Action against Certain Businesses regarding the Room Tax Permitting, Late Payments and Reporting. Motion passed unanimously by roll call.

Stayton moved and Zacek seconded to reconvene into open session. Motion passed unanimously by roll call.

Larson moved and Weddig seconded to pursue compliance from Sand Bay Beach Resort and Suites, Ltd. (Nasewaupee); White Star Lodge (Gardner) and four others in a chronological order. Motion passed unanimously.

Larson moved and Nelson seconded to adjourn. Motion passed unanimously.

Committee Members Present by Roll Call: Robert Kufrin, Tom Benzshawel, Richard Briggs, Sandy D�Amico, Nancy Goss, Dave Holtz, Diane Jacobson, Deb Jeanquart, Jeff Larson, Little Bit LeClair, Bryan Nelson, Tom Olsen, Sarah Sawyer, Dick Skare, Carol Stayton (9:26), Chuck Tice, Bill Weddig, Nora Zacek

Excused: Andy Coulson, Mary Boston, Pauline Cyrus, Mike Johnson

Absent: Paul Flottman, Jennifer Laughlin

Also Present: Jack Moneypenny, Mary Denis, Sally Everhardus/DCVB; Dianne Lensert/Kerber Rose; Bill Vande Castle/Vande Castle, S.C.; Kathy Kirkland/Administrative Assistant

Audience: Myles Dannhausen/Peninsula Pulse; Frank Forkert/Supervisor, Liberty Grove

Call to Order
Chair Bob Kufrin called the meeting to order at 9:05 a.m.

Approval of the Agenda
Tice moved and Weddig seconded to approve the agenda as submitted. All ayes.

Acceptance of Minutes of December 17, 2009
Nelson moved and Weddig seconded to accept the minutes of December 17, 2009, as submitted. All ayes.

Administrative Assistant�s Report
Kirkland noted that several properties are closing earlier than they stated on their original applications, and some are stating they�ll open later (e.g., June instead of May). Four examples of estimated room tax owed were included in the packet: One for Maple Grove Motel for the two missing years (2007 and 2009), one for a Fish Creek condo that had not filed any reports in 2009, a large home in Gardner (currently unpermitted) renting for approximately $300/night, and a cottage in Baileys Harbor that has no reports filed in 2009. Kirkland used a combination of past performance, rates stated in ads, and local/countywide occupancy rates to extrapolate the estimates. The Fish Creek condo, after notices from the TZC office, did pay all of 2009 within the last week; using actual figures, Kirkland calculated late fees and penalties as of December 31, 2009 (the date of the other estimates) and found that she originally overestimated; the property didn�t do as well in 2009, but estimates are meant to be best-guesses that the permit holder can agree to or refute. Maple Grove�s estimate was vetted by Lensert and Kufrin and sent to Vande Castle along with the total legal fees accrued during compliance pursuit; the estimate will be used in the court proceedings.

Kirkland provided each Commissioner with a Removed Properties report with new entries highlighted in green (since 8/09 report), along with their own municipality�s Permitted Properties. Each municipality has full listings with the request that their Administrator/Clerks and Boards look them over for omissions or errors. Kufrin urged the Commissioners to do the same to look over the list of removed/permitted for omissions/commissions. Kirkland noted that some permit holders still have issues with the website and filing; some file twice, wrong month, etc., which is the reason for some payables this month (refunds to permit holders).

Kufrin pointed out the chart of units/types of properties by municipality. Roughly 75% are private owners and 25% would consider themselves a business. The number of units is the opposite, with 25% being 1s and 2s. Kufrin stated that it�s a good chart to use when we consider compliance and put into perspective whom we go after for compliance.

Report by the Door County Visitor Bureau on Marketing Efforts
Moneypenny stated he�ll take the TZC�s Removed list back to the Visitors Bureau to check against the Innline list, making sure they�re removed from the system. Moneypenny said the DCVB�s Finance Committee met yesterday to look at year-end, and they will carry forward what they estimated. Their Board sees it next month, and then he will bring unaudited year-end financials to the TZC, then audited when finalized in a few months.

The Visitor Guide has good reviews so far. A recent E-Tip sent out got 3,000 more requests. People like the new maps and the double indexes by category and municipality. CTA classes start on Monday, first one at Eagle Harbor Inn, Ephraim, with 20 people signed up. Coffee with Jack starts on Tuesday in Fish Creek and the next in Sturgeon Bay.

The staff is doing a walk-through of the lobby about winter projects such as moving a wall. (Stayton arrived 9:26 a.m.) They have readjusted the budget for cash flow to make the renovations. Once they identify a project and DCVB members who could fulfill them, they�ll send letters asking for members to take part in the bidding process. They�ll be careful that someone doesn�t join only so they can bid, which would result in a one-year membership.

Moneypenny has a year-end report for CMF; Kufrin suggested that commissioners read it for discussion next month. Moneypenny states that $24,900 out of the $234,000 is being carried over to 2010 for specific early-year projects. He reiterated cash flow with Hill: If a municipality wants something in first quarter and need $35,000, they can�t guarantee it; they should carry over their own money, just as the Visitor Bureau does when allocating for printing/promotions. There will be an open house once the lobby is done.

Mary Denis addressed December reporting. Kufrin noted that time per web visit was up the first 7 months and then down dramatically. Did something attribute to that? Denis said it dropped off in October, up in November and leveled out to 5.3 min in December. Page views correlate to those numbers, too. They looked back, internally and through eBrains, to see if last year�s calculations were wrong but they weren�t, so they have nothing specific that attributed to that. Kufrin asked if weather drives anything. It�s hard to judge. She noted that Door County will be featured on HGTV is February 6, and in USA Today, they�ll watch to see if there�s a bump in web visits. There has been correlation in the past such as an e-blast for the Visitor Guide. Open rates and click-thrus also dropped, Kufrin noticed. Denis feels it�s just seasonal. December over December was up 34% from 2008 Holly Days Holly Nights campaign. There was a 1.4% increase last year with unique visits.

They�re making Progress with group tour (i.e., over goal), have done a follow-up with Holiday Showcase/Chicago group, and approved the agency campaign on marketing and co-op for the first quarter. Jon wanted to point out that ROI is up almost 300% for Geiger in number of articles. He has schedule five journalist trips this year and worked with 14 journalists individually in December, There are 15 new articles for 2.6 million impressions. Denis said Jarosh was admitted to the Society of American Travel Writers, very prestigious.

Stayton wants details on HGTV. Moneypenny said the regular newsletter will have details. Moneypenny said the program, The Outdoor Room, features an Australian who travels around the world looking at ideas for d�cor. He�ll be visiting Woodwalk Galleries, Chanticleer, and other spaces. (Zacek arrived, 9:39). In writing about his d�cor, he�ll be talking about Door County as a destination, a good exposure.

Kufrin noted that the DCVB has been using this reporting format for three months. Does this work for everyone? Consensus is that it does. Next month, will the DCVB drop 2008 figures? Denis said they�d drop 2007. Stayton and Nelson argued to keep 2008, and Moneypenny felt three years is a trend rather than a comparison; he wants to keep 2008 all year.

Denise reported that the re-skin of website will have two photos, rotating Flash element. The Nature of Romance campaign kicks off in February. The redesign should be signed off by the end of March, go Beta in April, then live.

She talked about the ad campaign and passed around a mock-up. There were three scenarios and they liked the story campaign best, and it ties well into social media/networking. Personal stories add mystique and can be shared on Facebook, Twitter, etc. (DCVB is now partnered with three other DC sites to link). The concept is one powerful photo at the top of the page and advertorial copy as a ghosted image of a story fragment. The photo at bottom will rotate throughout the campaign to show a variety of images. They�ll encourage people to post stories, pictures/scrapbook online with subtitles to send to friends, perhaps using stories with permission. There�s a call to action at the bottom. The running catchphrase will be: �Your stories. Our setting. Like nowhere else.� Other municipalities can use the catchphrase with permission to broaden the message. Kufrin asked if the campaign runs all year. Denis said more than a year if it proves that it�s working.

Kufrin asked if there�s a separate phone number or Skype number, etc., to help quantify the ads� success. She replied that it would cost too much to track, and ads aren�t saturated enough to drive it significantly at this point. The agency will do quarterly tracking of campaigns but not specific ads. The agency is poised to react and readjust if something�s not working or there�s high response in X-campaign than in Y-campaign. Kufrin asked if the ad agency is responsive? Yes, they�re doing extra things, came up with a full crew. Its social networking guru is sending information, and they�re responsive to the fact that we need tracking. Moneypenny added that they�re sending four people up for CTA to go through the training to understand Door County�s history.

Consideration of Approving Resolution No. 5-012110 Amending the Bylaws to Change the Date of the Annual Meeting
Kufrin moved this up in the agenda to maintain a quorum. Currently, the Bylaws call for the Annual Meeting to take place in May. The Commission would like to change it to �be held on a date at such time and place, as shall be determined by the Chairperson or by resolution of the Commission.� It goes to the municipalities to sign off, which involves two-thirds approval. He asked commissioners to appear at their boards� meetings to approve with date of the boards� actions. The 2010 Annual Meeting will be held at the same time the regular June meeting in Sister Bay�s Fire Station (June 17), which coincides with election of officers, so it�s important to attend. LeClair noted a typo that will be fixed. Nelson moved and Stayton seconded to approve Resolution No. 5-012110 as amended. All ayes.

Discussion on the Current Comparatible Occupancy Numbers for 2009
Lensert referred to the comparative spreadsheet with the blue section. Overall, the room tax is down 0.7% from last year. We�re at year-end, and cutoff will be at the end of January for year-end reporting for auditors to come in. All the numbers will be re-run at that time, so all the columns will be �adjusted� at that time and will be in the February meeting packet. Moneypenny and Kufrin both expressed enthusiasm with the numbers. Lensert noted that some of the payments on Check Details are cleaning up overpayments on room tax so those figures aren�t carried over the larger overages to a new year. A separate line item has been added, �Retained,� based on the decision at the last meeting that starting with December 18, late fees/interest are to be retained by the TZC.

Consideration of Withholding a Certain Allocation of Funds from the DCVB for TZC Cash Flow Purposes in the Same Amount as in 2009
Kufrin asked Lensert about withholding an end-of-year allocation to the DCVB. Last year the TZC still had some initial money, and $75,000 had been retained. (Skare left at 10 a.m.) Lensert said with $75,000 held back, by the middle of February, the checking account showed $82,000; by March, the TZC would have been short if it hadn�t retained $75,000. She feels we need about $50,000 held back; it�s a given we�ll need to retain some while still incurring expenses before the season, so there�s no check for DCVB this meeting. What decision does the Commission want to make re: funds? Kufrin agreed that expenses such as an administrative assistant make it necessary. Moneypenny said the DCVB had set up and reanalyzed cash flow to allow for that retention. If we follow the trend last year and give the DCVB $50,000 in July and $25,000 in August, that would be fine, but he doesn�t want to get a line of credit. Weddig asked if the municipalities could not get a payment in December rather than DCVB have to do it all. Nelson asked if we should go for $50,000 or $75,000? Lensert said $50,000 would be tight; $75,000 would be better.

Kufrin said we can try to build up an excess so we�re not in a position to have to borrow from the DCVB to pay the bills. November�s monthly total is $23,000 which isn�t enough to make a difference; maybe we could do so in the summertime. Tice agreed that we should start a reserve fund and budget for it next year. Weddig asked if we could take a short-term loan and pay it back. Kufrin said the Bylaws provide for us to borrow money but that�s not something the TZA envisioned having to do. Tice said if our 4% is not enough, maybe we should increase the percentage. The late fees and penalties just even out the budget, don�t add to it enough. Kufrin said going from 4% to 5% is not sufficient�it would bring in only $15,000. The Finance Committee will meet in February and come back to the Commission in March to offer some solutions.

Nelson moved to hold back $75,000 from the DCVB for TZC cash flow needs, which will be paid back 75% in July and 25% in August. Stayton seconded. Moneypenny was fine with the arrangement. All ayes.

Larson moved to accept Payables and Reports as submitted; Tice seconded. All ayes.

Discussion of Specific Enforcement Actions before the Door County Circuit Court
Attorney Vande Castle is on hand to talk about specifics of court cases, then compliance. Kufrin had e-mailed Vande Castle�s letter on compliance enforcement suggestions.

Vande Castle said there are two cases pending. Beach Harbor/Jon Hansen had a summary Judgment assessed yesterday; Hansen did appear in court. Another case, Maple Grove Motel, is pending; the party won�t communicate at all and we had to use extraordinary measures of subpoena for the 2007 financial records. He hopes to be in court in mid-to-late February after putting together documentation to prove the amounts owed. Although those are the only two cases ever filed, he has had 68 files started over the last 18 months. In cases where we have little cooperation, we�ve had to use the measure in the statute to make a �best guess� estimate. He noted that the State makes an outrageous assessment to force compliance, and the property owner has to refute the amount. That similar arrangement is provided in our statute; we can ask court for judgment in that amount, which may force the person to give exact numbers. If not, the judgment will be for our best guess. You have to go through steps to convince the judge that it�s an appropriate amount for judgment; we have the laboring ore to demonstrate what we�re asking for. Vande Castle noted that there are no precedents for what we�re doing; while there are other Tourism Zones throughout the state, no cases have been filed. Other attorneys are asking for our paperwork, and even judges aren�t sure how to handle it, which is why Vande Castle has spent much time educating the court on the TZC�s authority. Judge Diltz now understands our rights to enforce municipality ordinances and our responsibility to follow through.

Vande Castle said court action is one part of the process, getting the judgment, but even then�as demonstrated in the Barbican case�we may not be able to collect. Collection from the State is indicative of that; he has talked to judges, and the courts have similar problems with traffic matters, outstanding warrants. How do you deal with it? As long as the person is in business, we should eventually be able to collect: establish communication, try to keep open line, and the office is doing a good job so that the permit holders come into meetings with a basic understanding of their responsibilities and exposure. Some have asked for a payment plan of some sort. The TZC will have to look at post-judgment actions; acts such as garnishment or seizure of assets are more difficult. The biggest leverage is that, with an ongoing business, once the judgment is docketed, it�ll impact their ability to get financing. Banks will require them to pay it or borrow as part of financing. Even if they try to sell, it becomes a special assessment in the municipality, and we can collect.

Kufrin asked if the permit issued by the Tourism Zone is similar to the privilege of a municipality granting a liquor license: if don�t have the license, they can�t operate. Technically, yes, Vande Castle said, but enforcement is difficult; do you lock or chain the door? Without a court order, you can�t; Olsen said the State comes in to do it in regard to liquor licenses. The DOR administers liquor licenses, so they have the authority to shut down. We don�t have the linkage with another authority. Vande Castle said it�s similar in concept but we have no enforcement to actually shut them down. Kufrin said we should pursue legislative change to transfer authority to the DOR to do that. Vande Castle said the State would have to do it, but the DOR is pretty hands-off despite missing the revenue from pursuing tax collection. Weddig wishes we could do it electronically; have the money go right into a bank account for taxes. Vande Castle�s experience is that there are ongoing problems in identifying the sales tax. You can ask for verification but don�t always get it. Weddig noted that credit card companies do a great job of online records.

Kufrin asked about court judgment; did judge include legal costs? Vande Castle said yes, he made an argument that the ordinance provides that cost of prosecution is included. The statute talks about forfeiture of 25% or $5,000, and he argued that could include legal costs/prosecution in trying to make TZC whole on its costs throughout the process. From a court cost standpoint, it does not specifically address attorney fees. Can we recover attorney fees? He argues that�s part of the process under enabling ordinance; there was no argument made against that.

A third case has gone through the letter-writing process; now we�ll start the court process. Vande Castle said if don�t get resolution by date certain, we�ll be filing.

Consider Approving Certain Alternative Short-Term Compliance Policies
It was felt that if we�re acting as agents for municipal ordinances, and it�s the municipality�s responsibility that has been assigned to us. Just as municipality could collect its costs, as their agent, we are also entitled to collect those costs and recover them. He suggests recovery through chargeback to the municipality on their 30%. If Municipality A has the delinquency, they pay the administrative costs; Kufrin felt that�s inherently unfair, because the cost of one compliance could be enormous in relation to that community�s collection. Vande Castle noted that when and if the expenses are recovered, the money would go back to the municipality. Without that agency assignment to us, we would just tell the municipality to enforce the ordinance and they would bear the costs. Vande Castle�s belief is that it�s a way to recover the costs and assign those costs to the municipality in which there�s a problem. Tice felt we�d wind up in worse shape; many municipalities would not find out who�s non-compliant; it�s a disincentive. However, we are a zone and the costs should be split amongst the entire group. Kufrin agrees; if there were 68 of these cases, the total of what we�ve done so far may equal the costs of the two that went to court, yet we didn�t charge that back to the municipalities. It seems less onerous if the costs are proportioned equally rather than to one municipality with one bad actor. It would be hard for municipalities to budget that way, and he�d worry someone would pull out at the end of five years because they didn�t want to engage in enforcement. Vande Castle stated that it�s up to the Commission to decide how to spread it, but because of the assignation, we can do it.

Tice asked why not take it off the top? Vande Castle says the statute doesn�t set it up that way; it states it�s a municipality expense; the 70% must be spent for tourism and development. It�s a specific definition that does not include collection; we can�t argue for the linkage. But we can make an argument for the 30% to be linked to collection costs under the statute. Weddig agrees. Nelson likes the idea of State legislative change, but it could take a while. With 68 names out there, can we take on some we haven�t begun for enforcement. It was suggested that if we believe someone is conducting business, we�ll whistle blow to the DOR, which will go after them for State filing and taxes. Vande Castle said of the 68, some have resolved already. Kufrin said it�s a combination of those who are permitted but noncompliant and then those who are not permitted. Vande Castle another option is small claims court. We�d offer the same types of argument and prove our case; it�s limited to $5,000 judgment, so we�d have to get at them quicker. Some entities use small claims even though the amounts owed are bigger but they know they can�t possibly collect anyway.

Weddig asked about the timeframe for small claims court. Vande Castle said we could look at starting separate actions each month to get under the $5,000 limit. The timeframe is dependent on the court calendar; from initial filing, it�s usually a month before it goes to court. Both sides show up, the court asks the defendant to admit or deny, then it has to go to trial if denied. The trial normally takes place within 30 days or goes into mediation (2-3 wks). So it�s basically a two-month turnaround time. The rules of evidence are the same but the atmosphere more relaxed. Attorneys are usually present. While there is some State discussion to raise it to $10,000; right now, it�s $5,000. Vande Castle said the housing authority files 100 at a time and collection agencies often file 50-60 at a time. That�s just the process. (Olsen left 11 a.m.)

Vande Castle said we�ve set that track record with the two cases. Now it�s a matter of processing them. Judge was ready for him yesterday. (Dannhausen and Forkert left 11 a.m.)

Stayton looked at the overall chart: There are 708 non-commercial business owners and only 159 commercial businesses. Is the court going to view private homeowner differently? She guesses that most don�t have state licenses or health inspections. Should every lodging owner have to meet requirements? Vande Castle said that specific argument hasn�t been directed to the court yet; there is no distinction in the statute under the definition. When Hanson stated, �I�m just a small business,� the judge said, �Here�s the statute; you�re responsible to comply. Your size doesn�t matter.� The courts are concerned with treating everyone the same. Stayton said the municipalities have backed off and don�t want to get involved in looking at individual properties.

Kufrin said the State does health inspections at the county level. Vande Castle said municipalities should state that if a business is delinquent on one thing, it prevents it from getting other permits. LeClair said if a liquor dealer is delinquent in bills, every June 30 the licenses are issued; postings are put in the paper, giving an opportunity for wholesalers to collect. If they can�t collect, licenses are not issued. Vande Castle said it�ll be ignored until the State goes after them; Tice noted that�s it�s a state requirement, not local.

Kufrin said if we rely on individual municipalities, it�ll be inconsistent. If all are treated the same, it has to come from us from the Commission. We have enforcement authority for room tax but not whether someone is permitted by the State.

Goss asked about Ephraim�s ordinance allowing up to 16 weeks up to transient rental in a year. The ordinance calls it �casual rental not advertised.� Kufrin said in Sister Bay, if renting more than 16 weeks, then you have to be zoned as a business; if less, you can retain residential zoning and be in compliance. It�s a zoning issue, not a permitting issue.

Benzshawel noted the restrictions on State permits: You have to have good water, smoke detectors, and a whole lot of things. Weddig noted that it�s a law to have a State permit; Tice reiterated that we should pressure the State to get involved. Kufrin said it took Steve Bell (health inspector) months to look at our list and said there were about 50 properties that he didn�t have on his state list. Kufrin felt that the more we move away from just collecting tax, we�ll be engaging our staff and taking on expenses on ancillary items such as health inspections, etc. Weddig said that on our permit, we could have a line for them to list the State health permit number. Stayton felt the ordinance should state that anyone renting has to have that. (Benzshawel left 11:10 a.m.)

Stayton asked if the owners in the court cases had counsel. No. She asked if they�d had counsel, would it have ended differently? Vande Castle said it�s more difficult to deal with an individual than an attorney; attorneys are on level playing ground and the defendant�s attorney can relay our authority back to the client. A large part of Vande Castle�s time is explaining to the individual.

Weddig said he�s surprised that other tourism zones don�t follow up on compliance; Sturgeon Bay never did. Vande Castle has been doing this for 30 years, and many municipalities have storm water management; they adopt a resolution, charge use tax, but there�s no enforcement. Stayton said there�s no case precedence yet the Dells area has had room tax so long. We�re setting precedent; why do we have nothing to refer to? Kufrin sand we�re working toward creating a policy to treat all the same and have documentation. Compliance policy needs written documentation to permit holders, attorney, and staff to make sure all understand the rules. Vande Castle had done an analysis between ours and municipality ordinances, noting that there are discrepancies about compliance and penalties. One issue that Vande Castle hasn�t yet faced is, how do you enforce compliance or collection from out-of-state owners?

Kirkland noted that while we focus on the formal businesses (hotel/resorts), the 1s and 2s are not always �moms and pops.� Some charge $200/night, $2,100 week, etc. They sleep up to 12 people. They have to be considered in the same category from room tax collection point of view.

Consider motion to convene into Closed Session pursuant to Wisconsin State Statutes, Section 19.85(1)(a)(f) or (g) to Consider Enforcement Action against Certain Businesses regarding the Room Tax Permitting, Late Payments and Reporting
Nelson moved to go into closed session pursuant to the named State Statutes; Larson seconded. Roll call �ayes� from: Robert Kufrin, Richard Briggs, Sandy D�Amico, Nancy Goss, Dave Holtz, Diane Jacobson, Deb Jeanquart, Jeff Larson, Little Bit LeClair, Bryan Nelson, Sarah Sawyer, Dick Skare, Carol Stayton, Chuck Tice, Bill Weddig, Nora Zacek. No �nays.�

CLOSED SESSION

Consider a Motion to Reconvene into Open Session
Stayton moved to reconvene into open session; Zacek seconded. Roll call �ayes� from: Robert Kufrin, Richard Briggs, Sandy D�Amico, Nancy Goss, Dave Holtz, Diane Jacobson, Deb Jeanquart, Jeff Larson, Little Bit LeClair, Bryan Nelson, Sarah Sawyer, Dick Skare, Carol Stayton, Chuck Tice, Bill Weddig, Nora Zacek. No �nays.�

Consider a Motion to Take Action, If Required
Larson moved to pursue compliance from Sand Bay Beach Resort and Suites, Ltd. (Nasewaupee); White Star Lodge (Gardner), and four others in a chronological order. Weddig seconded. All ayes.

Next Month�s Meeting
February 18th�s meeting is 9 a.m. at the Gibraltar/Fish Creek Fire Station, Cty F, three-fourths mile east of Highway 42.

Adjournment
Larson moved to adjourn; Nelson seconded. All ayes. Meeting adjourned at 12:15 p.m.

Respectfully submitted,

Kathy Kirkland
Administrative Assistant

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