IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT … · Hani Mirza. Texas Bar No. 24083512 ....
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1 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION JARROD STRINGER, et. al, Plaintiffs, v. ROLANDO PABLOS, IN HIS OFFICIAL CAPACITY AS THE TEXAS SECRETARY OF STATE and STEVEN C. McCRAW, IN HIS OFFICIAL CAPACITY AS THE DIRECTOR OF THE TEXAS DEPARTMENT OF PUBLIC SAFETY Defendants. § § § § § § § § § § § § § § Civil Action No. 5:16-cv-00257-OLG PLAINTIFFS’ NOTICE OF FILING PROPOSED FORM OF JUDGMENT Plaintiffs file this Notice along with their Proposed Form of Judgment, which is submitted as Exhibit A. The Court’s May 10, 2018 Order requires the Parties to submit a proposed form of judgment setting forth the necessary declaratory and injunctive relief, consistent with the Court's findings, on or before May 17, 2018. Order, Dkt. 105 at 60-61. On May 14, 2018, Plaintiffs’ counsel emailed their proposed form of judgment to Defendants’ counsel. See Ex. A; Ex. B. On May 15, 2018, Plaintiffs’ counsel requested a meeting with Defendants’ counsel to discuss the proposed form of judgment. See Ex. C. Defendants’ counsel agreed to confer via telephone call at 8:30 a.m. the next day. During the conference on May 16, 2018, Defendants’ counsel notified Plaintiffs’ counsel that they generally do not agree with the monitoring and public education provisions in Plaintiffs’ proposed form of judgment and recommended that the Parties submit separate filings in response to the Court’s May 10 th Order. During the call on May 16 th and in an email sent on the morning of May 17, 2018, Plaintiffs’ counsel requested that Defendants’ counsel send a draft of Defendants’ Case 5:16-cv-00257-OLG Document 106 Filed 05/17/18 Page 1 of 4
Transcript of IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT … · Hani Mirza. Texas Bar No. 24083512 ....
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IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION JARROD STRINGER, et. al,
Plaintiffs, v. ROLANDO PABLOS, IN HIS OFFICIAL CAPACITY AS THE TEXAS SECRETARY OF STATE and STEVEN C. McCRAW, IN HIS OFFICIAL CAPACITY AS THE DIRECTOR OF THE TEXAS DEPARTMENT OF PUBLIC SAFETY
Defendants.
§ § § § § § § § § § § § § §
Civil Action No. 5:16-cv-00257-OLG
PLAINTIFFS’ NOTICE OF FILING PROPOSED FORM OF JUDGMENT
Plaintiffs file this Notice along with their Proposed Form of Judgment, which is
submitted as Exhibit A. The Court’s May 10, 2018 Order requires the Parties to submit a
proposed form of judgment setting forth the necessary declaratory and injunctive relief,
consistent with the Court's findings, on or before May 17, 2018. Order, Dkt. 105 at 60-61.
On May 14, 2018, Plaintiffs’ counsel emailed their proposed form of judgment to
Defendants’ counsel. See Ex. A; Ex. B. On May 15, 2018, Plaintiffs’ counsel requested a
meeting with Defendants’ counsel to discuss the proposed form of judgment. See Ex. C.
Defendants’ counsel agreed to confer via telephone call at 8:30 a.m. the next day. During the
conference on May 16, 2018, Defendants’ counsel notified Plaintiffs’ counsel that they generally
do not agree with the monitoring and public education provisions in Plaintiffs’ proposed form of
judgment and recommended that the Parties submit separate filings in response to the Court’s
May 10th Order. During the call on May 16th and in an email sent on the morning of May 17,
2018, Plaintiffs’ counsel requested that Defendants’ counsel send a draft of Defendants’
Case 5:16-cv-00257-OLG Document 106 Filed 05/17/18 Page 1 of 4
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proposed form of judgment—or specify Defendants’ objections to Plaintiffs’ proposed form of
judgment and provide the details of Defendants’ proposal. See Ex. D. Defendants’ counsel did
not respond to this email with specific objections to Plaintiffs’ proposed form of judgment or
specific proposals from Defendants. Instead, Defendants’ counsel stated, in part, that Defendants
“were unable to reconcile [Plaintiffs’] proposal with the requirement that injunctive relief be
narrowly tailored to address the particular legal violation the Court found, as required by Rule
65.” See Ex. E.
As a result, if necessary, Plaintiffs request the Court allow them the opportunity to
respond to Defendants’ proposed form of judgment, any specific objections made by Defendants
to Plaintiffs’ proposed form of judgment, and/or any specific proposals from Defendants.
Dated: May 17, 2017 Respectfully submitted,
By: /s/ Hani Mirza Peter A. Kraus (pro hac vice) Texas Bar No. 11712980 [email protected] Charles S. Siegel Texas Bar No. 18341875 [email protected] Caitlyn E. Silhan Texas Bar No. 24072879 [email protected] Rachel A. Gross (pro hac vice) Texas Bar No. 24073608 [email protected] WATERS & KRAUS, LLP 3141 Hood Street, Suite 700 Dallas, Texas 75219 214-357-6244 (Telephone) 214-871-2263 (Facsimile)
Mimi M.D. Marziani Texas Bar No. 24091906 [email protected] Rebecca Harrison Stevens Texas Bar No. 24065381
Case 5:16-cv-00257-OLG Document 106 Filed 05/17/18 Page 2 of 4
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[email protected] Hani Mirza Texas Bar No. 24083512 [email protected]
TEXAS CIVIL RIGHTS PROJECT 1405 Montopolis Drive Austin, Texas 78741 512-474-5073 (Telephone) 512-474-0726 (Facsimile) ATTORNEYS FOR PLAINTIFFS
Case 5:16-cv-00257-OLG Document 106 Filed 05/17/18 Page 3 of 4
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CERTIFICATE OF SERVICE
I hereby certify that on May 17, 2018, a true and correct copy of this Notice and
Plaintiffs’ Proposed Form of Judgment was served upon counsel of record via the Court’s ECF
system.
/s/ Hani Mirza
CERTIFICATE OF CONFERENCE
I hereby certify that on May 16 and 17, 2018, Plaintiffs’ counsel conferred with
Defendants’ counsel, Anna Mackin and Esteban Soto, and Defendants’ counsel are opposed to
Plaintiffs’ Proposed Form of Judgment, which is submitted with this Notice as Exhibit A.
/s/ Hani Mirza
Case 5:16-cv-00257-OLG Document 106 Filed 05/17/18 Page 4 of 4
Exhibit A
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IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION JARROD STRINGER, et. al,
Plaintiffs, v. ROLANDO PABLOS, IN HIS OFFICIAL CAPACITY AS THE TEXAS SECRETARY OF STATE and STEVEN C. McCRAW, IN HIS OFFICIAL CAPACITY AS THE DIRECTOR OF THE TEXAS DEPARTMENT OF PUBLIC SAFETY
Defendants.
§ § § § § § § § § § § § § §
Civil Action No. 5:16-cv-00257-OLG
[PROPOSED FORM OF] JUDGMENT
The Court, having considered the parties’ motions for summary judgment and ordered
entry of judgment in favor of Plaintiffs (Dkt. 105), now therefore:
1. FINDS AND DECLARES, pursuant to 28 U.S.C. § 2201 and 52 U.S.C.
§ 20510(b)(2), that Defendants have violated the NVRA, 52 U.S.C. §§ 20503(a)(1), 20504(a),
(c), (d), and (e), and 20507(a)(1)(A), and the Equal Protection Clause, U.S. Const. amend. XIV,
§ 1, by failing to permit simultaneous voter registration with online driver’s license renewal and
change-of-address transactions;
2. PERMANENTLY ENJOINS Defendants, their agents and successors in office,
and all persons working in concert with them, from continuing to violate the NVRA and Equal
Protection Clause by:
(a) failing to establish procedures to register to vote in elections for Federal office for
driver’s license customers who renew or change their address online;
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(b) refusing to treat each online driver’s license renewal or change-of-address application
as an application for voter registration with respect to elections for Federal office;
(c) refusing to include a voter registration application form for elections for Federal
office as part of each online driver’s license renewal or change-of-address
application;
(d) requiring online driver’s license renewal and change-of-address customers who wish
to register to vote or update their voter registration to complete an entirely separate,
duplicative voter registration application with the Secretary of State’s office;
(e) refusing to make the voter registration portion of each online driver’s license renewal
or change-of-address application available to the Secretary of State’s office;
(f) refusing to treat the customer’s online driver’s license change-of-address application
as a notification of change of address for voter registration with respect to elections
for Federal office, unless the customer indicates that the change of address is not for
voter registration purposes;
(g) refusing to transmit voter registration information submitted in connection with
online driver’s license renewal and change-of-address transactions to the appropriate
State election official within the statutorily required timeframe, 52 U.S.C. § 20504(e);
(h) refusing, in the case of registration with an online driver’s license renewal or change-
of-address application, to ensure that any eligible online driver’s license customer is
registered to vote in an election, if the valid voter registration form of the customer is
submitted to the Department of Public Safety (DPS) not later than the lesser of 30
days, or the period provided by state law, before the date of the election;
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(i) refusing to accept and use online driver’s license customers’ previously-captured
electronic signatures for voter registration purposes; and
(j) failing to record and use an online driver’s license renewal or change-of-address
customer’s response to the voter registration portion of the application.
3. PERMANENTLY ENJOINS Defendants, their agents and successors in office,
and all persons working in concert with them, from implementing practices and procedures that
otherwise violate the NVRA;
4. DIRECTS Defendant DPS, no later than 45 days1 from the date of this Judgment,
to:
(a) permit simultaneous voter registration with online driver’s license renewal and
change-of-address transactions so that in order to register to vote or update voter
registration information, the online driver’s license renewal or change-of-address
customer only needs to respond to the following:
1. Would you like to register to vote? No additional information is required.
○ Yes, Register Me to Vote ○ No, Do Not Register Me to Vote
2. If you are already registered, this application will be used to update your voter registration address, unless you opt out. Would you like to opt out of updating your address for voter registration purposes?
○ Update My Voter Registration ○ Opt Out: DO NOT Update My Voter Registration (Your new address will not be submitted to the Texas Secretary of State’s office for voter registration purposes).
1 This shortened timeline compared to the initially requested relief of 90-day implementation is (1) justified considering the simplicity of implementation evidenced by the record, and (2) necessary because of the imminent election in November 2018.
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(hereinafter “the voter registration questions”);
(b) register to vote or update voter registration information for online driver’s license
customers who select “Yes” in response to the question, “Would you like to register
to vote?”
(c) register to vote or update voter registration information for online driver’s license
customers who select “Update My Voter Registration” in response to the question,
“Would you like to opt out of updating your address for voter registration purposes?”
(d) register to vote or update voter registration information for online driver’s license
customers who select both "No” in response to the question, “Would you like to
register to vote?” and “Update My Voter Registration” in response to the question,
“Would you like to opt out of updating your address for voter registration purposes?”
(e) track, record, and retain each online driver’s license renewal or change-of-address
customer’s response to the voter registration questions; and
(f) transmit the voter registration information for each online driver’s license renewal or
change-of-address customer to the Secretary of State’s office, including the
customer’s response to the voter registration questions and the customer’s electronic
signature file collected during the customer’s last in-person transaction;
5. DIRECTS Defendant the Secretary of State, upon receipt from DPS of each
online driver’s license renewal or change-of-address customer’s voter registration information
and signature file, to transmit this data in the normal course of business to local voter registrars
who are responsible for completing the voter registration process, in a manner substantially
similar to the process for transmitting voter registration information after an in-person
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transaction; and ensure that local voter registrars register to vote or update the voter registration
information of these customers;
6. DIRECTS Defendants, within 14 days from the date of this Judgment, to submit
to Plaintiffs’ counsel a broad-based public education plan for approval that details the use of all
media venues, including but not limited to television, radio, internet social media, Texas.gov,
and the Secretary of State’s website https://www.sos.state.tx.us, to inform and educate the public
on how this Judgment changes the voter registration process for online driver’s license renewal
and change-of-address applications; include in this public education plan steps to incorporate for
two years the promotion of voter registration through online driver’s license renewal and change-
of-address applications into the Texas.gov marketing program, the Texas.gov/driver marketing
campaign, and all DPS, Secretary of State, and their vendors’ marketing campaigns related to
online driver’s license renewal and change-of-address applications; and, once the public
education plan is approved by Plaintiffs, implement such plan no later than 45 days from the
date of this Judgment.2
7. DIRECTS Defendants to:
(a) submit to this Court notice of compliance with this Judgment no later than 45 days
from the date of this Judgment, with affidavits from the Director of DPS and the
Secretary of State attached confirming compliance with this Judgment;
(b) submit to Plaintiffs’ counsel on or before January 15th of every year for the next three
years through January 15, 2021, a report that includes, for the previous calendar year:
2 Should the Parties be incapable of agreeing on an appropriate public education plan, the Parties will submit their proposals to the Court no later than 25 days from the date of this Judgment, and the Court will order the implementation of a plan that takes reasonable steps to inform the public about this Judgment as described in Paragraph 6.
Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 6 of 8
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(i) a general summary of compliance efforts detailing all steps taken to implement
each of the provisions and requirements of this Judgment, including any
significant implementation problems, staff training needs, and recommendations
for improvement;
(ii) the number of online driver’s license renewal and change-of-address applications
and the number of voter registrations arising from these applications;
(iii)copies of all NVRA procedures and educational and training materials related to
online driver’s license renewal or change-of-address transactions both used in the
preceding year and expected to be used in the future;
(iv) any investigations or corrective actions at DPS or the Secretary of State’s office
related to voter registrations through online driver’s license renewal or change-of-
address applications;
(v) any implemented or revised policies or procedures at DPS or the Secretary of
State’s office related to voter registrations through online driver's license renewal
or change-of-address applications; and
(vi) all customer complaints related to voter registration through an online driver’s
license renewal or change-of-address application, and all subsequent
correspondence and action taken related to each customer complaint; and
(c) conduct monthly quality control tests until May 2019 to ensure that the online
driver’s license renewal and change-of-address process complies with this Judgment,
and report to Plaintiffs’ counsel every three months the results of completed quality
control tests;
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8. RETAINS jurisdiction over this action until two years after the date of this
Judgment to ensure that Defendants continue to comply with their obligations under the NVRA,
the Equal Protection Clause, and this Judgment, and, if Defendants fail to comply with this
Judgment at any time after the two-year deadline, permits Plaintiffs to initiate an enforcement
action against Defendants in this Court;
9. ORDERS that Defendants shall pay to Plaintiffs their reasonable attorney’s fees,
including litigation expenses, and costs as will be determined by the Court in a post-judgment
Order upon submission by the Plaintiffs.
SIGNED this ____ day of ________, 2018.
___________________________________ ORLANDO L. GARCIA CHIEF U.S. DISTRICT JUDGE
Case 5:16-cv-00257-OLG Document 106-1 Filed 05/17/18 Page 8 of 8
Exhibit B
Case 5:16-cv-00257-OLG Document 106-2 Filed 05/17/18 Page 1 of 3
5/17/2018 Texas Civil Rights Project Mail - Fwd: Stringer v. Pablos
https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=16361525f9daae16&search=inbox&siml
Hani Mirza <[email protected]>
Fwd: Stringer v. Pablos
Hani Mirza <[email protected]> Mon, May 14, 2018 at 8:02 PMTo: "Mackin, Anna" <[email protected]>Cc: Caitlyn Silhan <[email protected]>, Beth Stevens <[email protected]>,[email protected], [email protected], Mimi Marziani <[email protected]>, Ryan Cox<[email protected]>
Dear Counsel, Please see the attached word version of the Proposed Form of Judgment. Thank you, Hani Mirza ---------- Forwarded message ---------- From: Mackin, Anna <[email protected]> Date: Fri, May 11, 2018 at 1:32 PM Subject: Stringer v. Pablos To: Caitlyn Silhan <[email protected]>, "[email protected]" <[email protected]> Cc: "Taylor, Caroline" <[email protected]>, "Gall, Kelly" <[email protected]>
Dear Counsel,
In view of the Court’s order received today, do you have a proposal for what your desired injunction would looklike?
Thanks,
Anna
Anna Mackin | Assistant Attorney General
Texas Office of the Attorney General
512.475.4074 | [email protected]
-- Hani MirzaSenior AttorneyTexas Civil Rights ProjectO: (972) 333-9200 ext. 171
Case 5:16-cv-00257-OLG Document 106-2 Filed 05/17/18 Page 2 of 3
5/17/2018 Texas Civil Rights Project Mail - Fwd: Stringer v. Pablos
https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=16361525f9daae16&search=inbox&siml
www.texascivilrightsproject.org Facebook | Twitter | Instagram Donate Now! This email and any files attached are privileged and confidential, and is/are intended only for the individual named. If you are not the intended recipient orotherwise have reason to believe that you have received this message in error, please notify the sender by email and delete this message immediately from yourcomputer. Any other use, retention, dissemination, forwarding, printing, or copying of this message and any attachments is strictly prohibited.
Proposed Form of Judgment.docx 36K
Case 5:16-cv-00257-OLG Document 106-2 Filed 05/17/18 Page 3 of 3
Exhibit C
Case 5:16-cv-00257-OLG Document 106-3 Filed 05/17/18 Page 1 of 3
5/17/2018 Texas Civil Rights Project Mail - Fwd: Stringer v. Pablos
https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=16363ce60ab59891&search=inbox&dsq
Hani Mirza <[email protected]>
Fwd: Stringer v. Pablos
Caitlyn Silhan <[email protected]> Tue, May 15, 2018 at 7:37 AMTo: "Mackin, Anna" <[email protected]>Cc: Beth Stevens <[email protected]>, [email protected], [email protected], Hani Mirza<[email protected]>, Mimi Marziani <[email protected]>, Ryan Cox<[email protected]>
Anna, are you available to discuss this today at 3:30? Please let us know. Thanks. Caitlyn Silhan | AttorneyWaters & Kraus *sent from my iPhone, so please excuse any errors. On May 14, 2018, at 8:03 PM, Hani Mirza <[email protected]> wrote:
Dear Counsel, Please see the attached word version of the Proposed Form of Judgment. Thank you, Hani Mirza ---------- Forwarded message ---------- From: Mackin, Anna <[email protected]> Date: Fri, May 11, 2018 at 1:32 PM Subject: Stringer v. Pablos To: Caitlyn Silhan <[email protected]>, "[email protected]"<[email protected]> Cc: "Taylor, Caroline" <[email protected]>, "Gall, Kelly" <[email protected]>
Dear Counsel,
In view of the Court’s order received today, do you have a proposal for what your desired injunctionwould look like?
Thanks,
Anna
Anna Mackin | Assistant Attorney General
Texas Office of the Attorney General
512.475.4074 | [email protected]
Case 5:16-cv-00257-OLG Document 106-3 Filed 05/17/18 Page 2 of 3
5/17/2018 Texas Civil Rights Project Mail - Fwd: Stringer v. Pablos
https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=16363ce60ab59891&search=inbox&dsq
-- Hani MirzaSenior AttorneyTexas Civil Rights ProjectO: (972) 333-9200 ext. 171www.texascivilrightsproject.org Facebook | Twitter | Instagram Donate Now! This email and any files attached are privileged and confidential, and is/are intended only for the individual named. If you are not theintended recipient or otherwise have reason to believe that you have received this message in error, please notify the sender by email anddelete this message immediately from your computer. Any other use, retention, dissemination, forwarding, printing, or copying of thismessage and any attachments is strictly prohibited.
<Proposed Form of Judgment.docx>
This electronic message contains information from WATERS & KRAUS, LLP that may be privileged and confidentialattorney work product or attorney/client communication. The information is intended to be for the use of the addresseeonly. If you are not the addressee, note that any disclosure, copying, distribution or use of the contents of this message isprohibited. If you received this message in error, please notify the sender immediately.
Case 5:16-cv-00257-OLG Document 106-3 Filed 05/17/18 Page 3 of 3
Exhibit D
Case 5:16-cv-00257-OLG Document 106-4 Filed 05/17/18 Page 1 of 2
5/17/2018 Texas Civil Rights Project Mail - Fwd: Stringer v. Pablos
https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=1636e6c717421909&search=inbox&sim
Hani Mirza <[email protected]>
Fwd: Stringer v. Pablos
Caitlyn Silhan <[email protected]> Thu, May 17, 2018 at 9:06 AMTo: "Soto, Esteban" <[email protected]>, Anna Mackin <[email protected]>Cc: Beth Stevens <[email protected]>, "Taylor, Caroline" <[email protected]>, Hani Mirza<[email protected]>, "Gall, Kelly" <[email protected]>, "[email protected]"<[email protected]>, "[email protected]" <[email protected]>
Anna and Esteban, Following up on our call yesterday, we plan to file our proposed form of judgment by COB today, and would like theopportunity to review and potentially address any specific counter-proposals and objections you have to our draft beforefiling. To that end, and as we requested yesterday, would you please send us a draft of your proposed form of judgment—or specify your objections to our draft and provide the details of your proposal—by noon today? Thank you, Caitlyn Caitlyn Silhan | AttorneyWaters & Kraus *sent from a mobile device, so please excuse any errors. On May 15, 2018, at 1:26 PM, Soto, Esteban <[email protected]> wrote: [Quoted text hidden]
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<ATT00002.jpg>
This electronic message contains information from WATERS & KRAUS, LLP that may be privileged and confidentialattorney work product or attorney/client communication. The information is intended to be for the use of the addresseeonly. If you are not the addressee, note that any disclosure, copying, distribution or use of the contents of this message isprohibited. If you received this message in error, please notify the sender immediately.
Case 5:16-cv-00257-OLG Document 106-4 Filed 05/17/18 Page 2 of 2
Exhibit E
Case 5:16-cv-00257-OLG Document 106-5 Filed 05/17/18 Page 1 of 2
5/17/2018 Texas Civil Rights Project Mail - Today’s Submission
https://mail.google.com/mail/u/0/?ui=2&ik=fd92fad4ed&jsver=awrWbfDFcFs.en.&cbl=gmail_fe_180429.15_p3&view=pt&msg=1636f57dd59915d7&search=inbox&siml
Hani Mirza <[email protected]>
Today’s Submission
Mackin, Anna <[email protected]> Thu, May 17, 2018 at 1:23 PMTo: caitlyn silhan <[email protected]>, Beth Stevens <[email protected]>, Hani Mirza<[email protected]>, Mimi Marziani <[email protected]>, Ryan Cox<[email protected]>Cc: "Soto, Esteban" <[email protected]>, "Hendrix, Laura" <[email protected]>, "Taylor, Caroline"<[email protected]>, "Gall, Kelly" <[email protected]>
All, Thank you for providing us with a copy of the proposed judgment you intend to submit to the Court. As we indicated onthe call on Wednesday, we continue to dispute liability, and we also object to the scope of the relief you proposed. Thecourt found that Defendants’ current processing of online driver license renewals and changes of address violates theNVRA by failing “to permit a simultaneous voter registration application with every transaction[.]” Doc 105 at 60. TheCourt stated that “[a]sking motor voters whether they are interested in voter registration and sending them to SOS for anentirely separate application process is not enough [to comply with the NVRA’s motor voter requirements.]” Doc. 105 at60. We were unable to reconcile your proposal with the requirement that injunctive relief be narrowly tailored to addressthe particular legal violation the Court found, as required by Rule 65. We therefore object to its terms. Anna
Case 5:16-cv-00257-OLG Document 106-5 Filed 05/17/18 Page 2 of 2
