Reply Brief — Indian River County, Florida, et al., Petitioners v. Department of Transportation, et al.

No. 19-1304

IN THE

Supreme Court of the United States

————

INDIAN RIVER COUNTY, FLORIDA; INDIAN RIVER

COUNTY EMERGENCY SERVICES DISTRICT,

Petitioners,

v.

UNITED STATES DEPARTMENT OF TRANSPORTATION;

ELAINE L. CHAO, IN HER OFFICIAL CAPACITY AS

SECRETARY OF TRANSPORTATION; UNDER SECRETARY

OF TRANSPORTATION FOR POLICY; FEDERAL

RAILROAD ADMINISTRATION; PAUL NISSENBAUM,

IN HIS OFFICIAL CAPACITY AS ASSOCIATE

ADMINISTRATOR OF THE FEDERAL RAILROAD

ADMINISTRATION; AAF HOLDINGS LLC,

Respondents.

————

On Petition for a Writ of Certiorari

to the United States Court of Appeals

for the District of Columbia Circuit

————

REPLY FOR PETITIONERS

————

DYLAN REINGOLD

County Attorney

INDIAN RIVER COUNTY

1801 27th St.

Vero Beach, FL 32960

J. MICHAEL LUTTIG*

728 West Lionshead Cir.

Vail, CO 81657

*

Admitted only in Virginia and

the District of Columbia

JEFFREY A. LAMKEN

Counsel of Record

JAMES A. BARTA

MOLOLAMKEN LLP

The Watergate, Suite 500

600 New Hampshire Ave., N.W.

Washington, D.C. 20037

(202) 556-2000

jlamken@mololamken.com

(Additional Counsel Listed on Inside Cover)

:,/621(3(635,17,1*&2,1&±  ±:$6+,1*721'&

LAUREN F. DAYTON

MOLOLAMKEN LLP

430 Park Ave., 6th Floor

New York, NY 10022

(212) 607-8160

ELIZABETH K. CLARKE

MOLOLAMKEN LLP

300 N. LaSalle St., Suite 5350

Chicago, IL 60654

(312) 450-6700

Counsel for Petitioners



TABLE OF CONTENTS

Page

I.

The Court of Appeals Deferred to an

Informal Agency Construction That

Contradicts the Statute’s Plain

Meaning ............................................................

II. The Decision Below Illustrates the

Continuing Disarray over Skidmore ............

III. This Case Is a Good Vehicle for

Resolving the Important Skidmore

Issue Presented ...............................................

Conclusion .....................................................................

(i)

2

8

10

12

iii

TABLE OF AUTHORITIES

Page(s)

CASES

Ammex, Inc. v. United States,

367 F.3d 530 (6th Cir. 2004) .............................. 10

Ass’n of Data Processing Serv. Orgs.,

Inc. v. Camp, 397 U.S. 150 (1970) .................... 11

Chevron, U.S.A., Inc. v. Nat. Res. Def.

Council, Inc., 467 U.S. 837 (1984) .............. 7, 8, 10

Clarke v. Secs. Industry Ass’n,

479 U.S. 388 (1987) ............................................. 11

Estrada-Rodriguez v. Lynch,

825 F.3d 397 (8th Cir. 2016) ............................

9

FDA v. Brown & Williamson Tobacco

Corp., 529 U.S. 120 (2000) .................................

5

Fed. Express Corp. v. Holowecki,

552 U.S. 389 (2008) .............................................

8

Gen. Dynamics Land Sys., Inc. v. Cline,

540 U.S. 581 (2004) ............................................. 7, 9

Kisor v. Wilkie, 139 S. Ct. 2400 (2019)........... 6, 9, 11

Kucana v. Holder, 558 U.S. 233 (2010) ................

5

Match-E-Be-Nash-She-Wish Band of

Pottawatomi Indians v. Patchak,

567 U.S. 209 (2012) ............................................. 11

Miller v. Clinton,

687 F.3d 1332 (D.C. Cir. 2012) ......................... 10

Univ. of Tex. Sw. Med. Ctr. v. Nassar,

570 U.S. 338 (2013) .............................................

7

Nat’l Cable & Telecomms. Ass’n

v. Brand X Internet Servs.,

545 U.S. 967 (2005) .............................................

9

iv

TABLE OF AUTHORITIES—Continued

Page(s)

SEC v. Chenery Corp.,

318 U.S. 80 (1943) ............................................... 4, 6

Skidmore v. Swift & Co.,

323 U.S. 134 (1944) ....................................... passim

Zivotofsky v. Clinton,

566 U.S. 189 (2012) ............................................. 11

STATUTES

23 U.S.C. § 101(a) (2006).........................................

5

23 U.S.C. § 130 (2006) .............................................

5

23 U.S.C. § 147(f ) (2006) ...................................... 11, 12

23 U.S.C. § 601(a)(8)(C) (2006) ..............................

5

23 U.S.C. § 602 (2006) .............................................

5

26 U.S.C. § 142(a) .................................................... 2, 4

26 U.S.C. § 142(a)(11)..............................................

5

26 U.S.C. §142(m) ............................................. passim

26 U.S.C. § 142(m)(1)(A) ......................................... 2, 4

IN THE

Supreme Court of the United States

————

NO. 19-1304

————

INDIAN RIVER COUNTY, FLORIDA; INDIAN RIVER

COUNTY EMERGENCY SERVICES DISTRICT,

Petitioners,

v.

UNITED STATES DEPARTMENT OF TRANSPORTATION;

ELAINE L. CHAO, IN HER OFFICIAL CAPACITY AS

SECRETARY OF TRANSPORTATION; UNDER SECRETARY

OF TRANSPORTATION FOR POLICY; FEDERAL

RAILROAD ADMINISTRATION; PAUL NISSENBAUM,

IN HIS OFFICIAL CAPACITY AS ASSOCIATE

ADMINISTRATOR OF THE FEDERAL RAILROAD

ADMINISTRATION; AAF HOLDINGS LLC,

Respondents.

————

On Petition for a Writ of Certiorari

to the United States Court of Appeals

for the District of Columbia Circuit

————

REPLY FOR PETITIONERS

————

Respondents do not—and cannot—defend the court of

appeals’ central holding that “DOT has reasonably interpreted” the phrase a “ ‘project which receives Federal

assistance under title 23’ ” to encompass projects that

merely “benefit[ ] from assistance” provided to others.

2

Pet. App. 26a (emphasis added). The court’s decision upholding a $1.15 billion bond allocation to a passenger-rail

facility that never received—and is not eligible to receive—Title 23 assistance rests on deference to an agency construction respondents no longer defend.

Respondents offer alternative rationales for the bond

allocation. But those rationalizations lack merit and cannot excuse the court of appeals’ failure to undertake the

required statutory analysis regardless. Nor can they

erase the need for review. As this case illustrates, courts

often fail to undertake a meaningful statutory analysis

before deferring to informal agency views. Review is

warranted to establish and enforce limits on Skidmore

deference.

I. THE COURT OF APPEALS DEFERRED TO AN INFORMAL AGENCY CONSTRUCTION THAT CONTRADICTS THE STATUTE’S PLAIN MEANING

A. The court of appeals’ atextual construction of the

statute is indefensible. Under § 142(m), tax-exempt

bonds must be used “to provide” a “surface transportation project which receives Federal assistance under title

23.” 26 U.S.C. § 142(a), (m)(1)(A). As the County explained (at 16-21), that requires the project to have

actually received federal dollars under Title 23. It is not

enough for a project to derive benefits from dollars spent

on something else. The court of appeals, however, upheld

the issuance of tax-exempt bonds to finance a passenger

rail line that did not receive—and is not eligible to receive—Title 23 dollars. It deferred to DOT’s atextual

view that “a project which—in whole or part—benefits

from assistance under Title 23” can be said to “ ‘receive[ ]

Federal assistance.’ ” Pet. App. 26a (emphasis added).

1. Respondents abandon any defense of the court’s

holding, and DOT’s view, that “receives” in § 142(m)

3

means “benefits from.” Respondents instead obfuscate.

The court’s statement that “receives” means “benefits

from,” respondents claim, is “shorthand” for the idea that

“the Florida Project received Title 23 assistance because

one of its component parts had received such assistance.”

Gov’t Br. in Opp. 20; see AAF Br. in Opp. 28. But the

court could not have been clearer: It understood “ ‘receives’ * * * to mean * * * benefits from.” Pet. App. 26a.

That understanding, moreover, reflects the construction DOT pressed below. Respondents repeatedly defended DOT’s bond allocation to AAF’s rail line on the

ground that “receives” means “benefits from”: “To benefit is to receive assistance,” they argued, “and vice versa.” Gov’t C.A. Br. 23-24; see AAF C.A. Br. 17, 27 (“statutory requirements are satisfied if the project for which

funding is sought has benefited or will benefit from * * *

Title 23 funds”) (emphasis added)). As the district court

observed, the “Department * * * interpret[s] the statute

to allow for PAB allocation[s] to projects based on direct

benefits from Title 23 spending.” Pet. App. 59a. DOT

even touted that it had allocated billions in tax-exempt

bonds to other facilities based on benefits derived from

Title 23 spending on “nearby” or “adjacent” projects.

Pet. 20; see Pet. App. 135a-136a; D. Ct. Dkt. 32-1 at 23-25

& n.10. Respondents do not deny that other allocations

were based on DOT’s view that “receives” means “benefits from.”1 Respondents’ effort to distance themselves

from that construction underscores how far it—and the

decision below—departs from the statute.

1

While AAF quibbles (at 32 n.5) over DOT’s rationale for one allocation, it cannot dispute that DOT allocated bonds to some facilities

(e.g., the Illinois logistics park) based on perceived benefits, Pet. 20.

The facts of this case are not “unique.” AAF Br. in Opp. 32 n.5.

4

2. Respondents’ (counterfactual) suggestion that

AAF’s rail line actually “received Title 23 assistance because certain components of the facility * * * received”

assistance is irrelevant and misleading. Gov’t Br. in Opp.

18; see id. at 16-17, 20-21; AAF Br. in Opp. 28-29. It is

irrelevant because the court below invoked Skidmore to

uphold DOT’s view that to “receive” means to “benefit

from.” It is wrong because, under § 142(m), bonds must

be used “to provide” the “surface transportation project

which receives Federal assistance.” 26 U.S.C. § 142(a),

(m)(1)(A). The bonds issued for AAF’s rail line were not

sought “to provide” the undertakings that received Title

23 assistance—highway-railway crossings. See Pet. 7-8,

17-18. To the contrary, AAF obtained bonds “for Phase

II” of its rail line, C.A. App. 4564, based on benefits from

funds already “invested in the * * * corridor,” id. at 4536.

While respondents claim that the crossing upgrades

are “part of a railroad ‘project,’ ” Gov’t Br. in Opp. 18;

AAF Br. in Opp. 29, the bonds were not used “to provide”

those upgrades. Nor did DOT’s approval letter find

those previously completed upgrades were part of the

yet-to-be-commenced Phase II. See C.A. App. 4564. It

would require an impermissible leap to assume that they

were. See SEC v. Chenery Corp., 318 U.S. 80, 94 (1943).

That is why respondents defended the bond allocation

below on the ground that “the Project received a direct

benefit” from “upgrade[d] crossings,” D. Ct. Dkt. 32-1 at

24; see p. 3, supra, not that Phase II itself “received”

Title 23 funding. Whether § 142(m) requires a “minimum

percentage” of bonds to be used on any portion of a

qualified facility is thus irrelevant. Gov’t Br. in Opp. 2223. The bonds here were not sought “to provide” the

crossings upgraded with Title 23 funds.

5

Attempting to label AAF’s new passenger rail line a

“project” that “receive[d]” assistance “under Title 23”

erases careful statutory distinctions. As the County explained (at 18-20), § 142(m) contemplates that the “project” must be eligible for federal dollars “under title 23.”

See 23 U.S.C. § 101(a) (2006). AAF’s rail line is not. It

was allocated bonds based on benefits from federal

dollars spent under 23 U.S.C. § 130 (2006), which authorizes upgrades to “railway-highway crossings.” It did not

receive Title 23 dollars under provisions addressing

“intercity * * * rail facilities.” 23 U.S.C. §§ 601(a)(8)(C),

602 (2006). Nor did it separately qualify for bonds as a

high-speed rail facility. See 26 U.S.C. § 142(a)(11). Congress understood “project” in § 142(m) to cover only

undertakings authorized to receive funds “under Title

23”; respondents seek to add undertakings that are not.

Respondents argue that the term “project” in § 142(m)

is broad enough to allow DOT to allocate bonds even to

facilities ineligible to receive Title 23 funds. Gov’t Br in

Opp. 21; AAF Br. in Opp. 21-22. But § 142(m) is clear,

and courts must respect statutory text and context alike.

See FDA v. Brown & Williamson Tobacco Corp., 529

U.S. 120, 133 (2000). The government disputes that facilities financed through § 142(m) must be eligible for Title

23 funds because “the term ‘project’ ” bears different

meanings in “different contexts.” Gov’t Br. in Opp. 21-22.

But that at most shows that “project” is a general term

that “ ‘must draw its meaning from its context.’ ” Kucana

v. Holder, 558 U.S. 233, 245 (2010). Within § 142(m),

“project” refers to facilities eligible for Title 23 assis-

6

tance. Congress required projects to receive assistance

“under title 23.” Pet. 19. AAF’s line never did.2

It is thus irrelevant whether § 142(m) requires a particular “applicant” to have “receive[d]” the Title 23 dollars spent on a project. Gov’t Br. in Opp. 19; see AAF Br.

in Opp. 31-32. Nothing about the County’s challenge

hinges on who obtained the Title 23 funds used to upgrade railway-highway crossings.

See Pet. 23-24.

Rather, the critical fact is that DOT allocated bonds to a

project that did not receive—and was not eligible to receive—federal assistance under Title 23. The court of

appeals deferred to an informal DOT construction that

rewrites the statute.

B. In deferring to that impermissible construction,

the court of appeals did not even analyze the applicable

statute. Respondents recite language from the decision

below declaring DOT’s view of § 142(m) to be “persuasive” and “consistent with the statutory framework.”

Gov’t Br. in Opp. 23-24; AAF Br. in Opp. 18-22. But it is

the courts’ duty to say what the law is; Skidmore does

not mean they can discharge that duty merely by quoting

statutory language and declaring, without any independent analysis, that an agency’s position is “persuasive” or

“consistent with the statutory framework.” Skidmore requires (or should require) courts to exercise their independent judgment about the best reading of a statute.

See Kisor v. Wilkie, 139 S. Ct. 2400, 2427, 2447 (2019)

(Gorsuch, J., concurring). Deference is appropriate “only

2

While the government asserts that AAF’s entire rail line is eligible

for funding under provisions of Title 23 that DOT did not invoke

below, compare Gov’t Br. in Opp. 21, with Pet. App. 24a, DOT’s

decision “cannot be sustained” under the government’s newly minted

rationale, Chenery, 318 U.S. at 95.

7

when the devices of judicial construction have been tried

and found to yield no clear sense of congressional intent.”

Gen. Dynamics Land Sys., Inc. v. Cline, 540 U.S. 581,

600 (2004).

Respondents’ oppositions highlight the court of appeals’ failure to employ those devices here. Unable to defend the court’s conflation of the statutory term “receives” with “benefits from,” respondents attempt to rewrite the decision below. But respondents cannot locate

meaningful analysis of their alternative rationales in the

decision. While respondents point to passages reciting

the Kussy letter or making conclusory assertions, see,

e.g., Gov’t Br. in Opp. 23-24 (citing Pet. App. 26a-27a), the

decision itself undertakes no independent analysis of

what terms like “project” mean or the statutory design.

The problem is not that the court “fail[ed] to use the

magic word ‘ambiguous’ ” before deferring to DOT. AAF

Br. in Opp. 20; see Gov’t Br. in Opp. 27. The problem is

that the court did not analyze the statute—its “language,” “structure,” and “design,” Univ. of Tex. Sw.

Med. Ctr. v. Nassar, 570 U.S. 338, 352-353 (2013)—in any

meaningful way before deferring to DOT’s countertextual view. The court abdicated the judicial role.

The government (at 25-26) tries to lay fault on the

County for that error. But the County always maintained that the statute’s plain language precluded any

deference. See County C.A. Br. 12-23; C.A. Reply 6-14.

It merely argued that DOT’s informal construction could

“at most” receive Skidmore (as opposed to Chevron) deference. County C.A. Br. 17. The court’s failure to give

effect to the statutory text is error under any standard.

8

II. THE DECISION BELOW ILLUSTRATES THE CONTINUING DISARRAY OVER SKIDMORE

The uncritical deference exhibited by the decision below exemplifies the widespread disarray over Skidmore.

For that reason, too, review is warranted.

A. This Court’s own decisions provide mixed guidance. Some suggest courts should search for the best

reading of a statute, exhausting all traditional tools of

construction, before considering an agency’s views;

others, such as Federal Express Corp. v. Holowecki, 552

U.S. 389, 402 (2008), are quicker to defer to informal

agency constructions that appear superficially reasonable. Pet. 25-28. The government does not deny there is

conflict over Skidmore’s proper application.

AAF disagrees (at 24) that decisions like Holowecki

can be read to permit a loose form of Skidmore deference, urging it “gave a full nod to the [statutory] text.”

But a decision does not have to “declare text irrelevant”

(ibid.) to provide a gloss on Skidmore that excuses use of

all the traditional tools of textual interpretation. In Holowecki, for example, the Court did not examine the ordinary meaning of the statutory term. See Pet. 26.

Rather, it deferred to an agency view upon pronouncing

it a “reasonable alternative that is consistent with the

statutory framework.” 552 U.S. at 402. As that decision

illustrates, merely giving a “nod” to the text is different

from exhausting the traditional tools of interpretation to

determine the text’s best meaning.

Citing a decision on Chevron deference, respondents

suggest it is irrelevant whether a court finds a statute

ambiguous before applying Skidmore. Gov’t Br. in Opp.

26; AAF Br. in Opp. 20, 24. But that elides a fundamental difference between the doctrines. Under Chevron, a

court must adopt any “permissible” agency construction

9

of the statute, even if it “differs” from the “best statutory

interpretation,” Nat’l Cable & Telecomms. Ass’n v.

Brand X Internet Servs., 545 U.S. 967, 980, 986 (2005).

Under Skidmore, by contrast, it remains the court’s job

to find the best reading of the statute—or at least it

should be. See Kisor, 139 S. Ct. at 2427, 2447 (Gorsuch,

J., concurring). An agency’s views should be considered

for their persuasive value “only when” statutory text

“yield[s] no clear sense of congressional intent.” Gen.

Dynamics, 540 U.S. at 600.

B. AAF insists that lower courts do not disagree

about what Skidmore entails because none actually state

that agency views can “override a ‘statute’s unambiguous

meaning.’ ” AAF Br. in Opp. 25. But the fact that courts

do not make such statements does not preclude them

from using deference doctrines to depart from clear

statutory commands—as this case illustrates. The mere

fact that the decision below began by “quoting the

relevant [statutory] language” (AAF Br. in Opp. 17, 21)

does not mean that the court employed all traditional

tools of interpretation before deferring. Respondents

cannot point to where the court actually undertook

independent statutory analysis in its opinion.

Nor is the decision below alone in reading Skidmore to

permit deference to agency constructions that fall far

short of the most plausible statutory understanding—or

even contradict statutory text. See Pet. 28-30. AAF declares (at 26 & n.4) that none of the cases cited in the

petition deferred to an agency reading that “contradicted

the plain text of the statute.” That cannot save AAF

here, even if it were true (which it is not). For none of

the cited decisions employed all the traditional tools of

statutory construction before deferring to informal agency views. In Estrada-Rodriguez v. Lynch, 825 F.3d 397

10

(8th Cir. 2016), for example, the only authorities the

court cited in construing the relevant statutory term

were prior agency decisions. See id. at 404-405. It did

not discuss the term’s ordinary meaning or the statute’s

structure. In Ammex, Inc. v. United States, 367 F.3d 530

(6th Cir. 2004), the court assumed the agency’s views

were “obviously” entitled to “deference,” and faulted the

challenger for failing to “identify an[ ] infirmity” with

them. Id. at 535. That is the opposite of a court seeking

to “ ‘decide for [itself ] the best reading’ ” of a statute.

Miller v. Clinton, 687 F.3d 1332, 1342 (D.C. Cir. 2012).3

III. THIS CASE IS A GOOD VEHICLE FOR RESOLVING

THE IMPORTANT SKIDMORE ISSUE PRESENTED

The court of appeals’ clear departure from the statutory text under the flag of Skidmore renders this case an

excellent vehicle for resolving the doctrinal disarray.

The government offers no reason for believing that the

court of appeals would have reached the “same result”

absent deference. Gov’t Br. in Opp. 28. Respondents’

abandonment of DOT’s view that a project “receives”

Title 23 funding if it merely “benefits from” that funding

demonstrates the court would not. See pp. 1-3, supra.

Regardless, respondents’ (erroneous) assertion that

there is a potential alternative ground for the same result

does not preclude review of an issue actually pressed and

3

AAF invokes an article acknowledging that courts purport to adhere to “ ‘unambiguous’ ” statutes, AAF Br. in Opp. 24, but the article further observes that courts disagree whether they must

exercise “ ‘independent judgment’ ” to determine a statute’s meaning

and “ ‘lack a coherent conception’ ” of Skidmore, Pet. 29 n.8 (quoting

article). Likewise, the fact that agencies prevail less under Skidmore than Chevron shows only that not all courts treat the doctrines

as equivalent. It does not disprove the palpable confusion.

11

passed upon below. See, e.g., Zivotofsky v. Clinton, 566

U.S. 189, 201-202 (2012). Nor does it prevent this Court

from providing much-needed direction about Skidmore.

Cf. Kisor, 139 S. Ct. at 2423-2424. The importance of this

particular case is not “exaggerate[d].” AAF Br. in Opp.

32. It concerns one of the most important issues before

the federal courts—when judicial deference to informal

agency interpretations of statutes is appropriate. Any

debate over the precise impact of § 142(m) cannot detract

from the importance of ensuring lower courts properly

discharge their responsibility of saying what the law is.

The government’s twice-rejected zone-of-interest

argument (at 29-30) fares no better. Both the district

court and the court of appeals rejected the argument—

and for good reason. See Pet. App. 17a-23a, 47a-52a.

The zone-of-interest test is not “especially demanding,”

Clarke v. Secs. Industry Ass’n, 479 U.S. 388, 399 (1987),

merely requiring a party to assert an interest “arguably

* * * protected or regulated by the statute,” Ass’n of

Data Processing Serv. Orgs., Inc. v. Camp, 397 U.S. 150,

153 (1970). A plaintiff cannot bring suit “only when [its]

‘interests are so marginally related to or inconsistent

with the purposes implicit in the statute that it cannot

reasonably be assumed that Congress intended to permit

the suit.’ ” Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak, 567 U.S. 209, 225 (2012).

The County—“a local government entity whose citizens will be directly affected by the AAF Project,” Pet.

App. 22a—easily satisfies that permissive standard here.

As the courts below explained, Congress arguably contemplated a role for local government input in § 142(m)

bond allocations. Pet. App. 23a, 52a. That provision has

an “integral relationship” to 26 U.S.C. § 147(f ), which requires public approval of bond issues by the relevant gov-

12

ernmental unit. Pet. App. 19a-20a, 22a. Although the

courts rejected a separate procedural challenge brought

under § 147(f ), Gov’t Br. in Opp. 31, that section shows

that Congress expected “State and local governments” to

have interests relevant to bond allocations made under

§ 142(m), Pet. App. 52a. The court of appeals also held

that the County had standing for another, independent

reason. Id. at 20a. “[T]here is no dispute,” the court

observed, the County’s “environmental and safety concerns are matters of the sort that DOT surely will have

‘in mind’ ” in allocating bonds. Ibid. The same is true of

the County’s concerns over a project’s authorization.

CONCLUSION

The petition should be granted.

Respectfully submitted.

DYLAN REINGOLD

County Attorney

INDIAN RIVER COUNTY

1801 27th St.

Vero Beach, FL 32960

J. MICHAEL LUTTIG*

728 West Lionshead Cir.

Vail, CO 81657

*

Admitted only in Virginia and

the District of Columbia

JEFFREY A. LAMKEN

Counsel of Record

JAMES A. BARTA

MOLOLAMKEN LLP

The Watergate, Suite 500

600 New Hampshire Ave., N.W.

Washington, D.C. 20037

(202) 556-2000

jlamken@mololamken.com

LAUREN F. DAYTON

MOLOLAMKEN LLP

430 Park Ave., 6th Floor

New York, NY 10022

(212) 607-8160

ELIZABETH K. CLARKE

MOLOLAMKEN LLP

300 N. LaSalle St., Suite 5350

Chicago, IL 60654

(312) 450-6700

Counsel for Petitioners

SEPTEMBER 2020