# Opposition Brief — Allemnore Community Hospital v. United States

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Opposition Brief
- **Published:** January 1, 1997
- **Citation:** 519 U.S. 1090

## Text

In the Supreme Court of the United States

OCTOBER TERM, 1996

ALLEMNORE COMMUNITY HospIrAL, INC., ET AL.,
PETITIONERS

VU.

UNITED STATES OF AMERICA

ON PETITION FOR A WRIT OF CERTIORARI
TO THE UNITED STATES COURT OF APPEALS
FOR THE FEDERAL CIRCUIT

BRIEF FOR THE UNITED STATES IN OPPOSITION

WALTER DELLINGER
Acting Solicitor General
FRANK W. HUNGER
Assistant Attorney General
ANTHONY J. STEINMEYER
BRIAN M. SIMKIN
Attorneys
Department of Justice
Washington, D.C. 20530-0001
(202) 514-2217

(ZUESTION PRESENTED

Whether the Tucker Act, 28 U.S.C. 1491, provides
for review of claims by providers of Medicare services
when 42 U.S.C. 139500 of the Medicare Act provides
for administrative and judicial review of such claims.

(I)

TABLE OF CONTENTS

Page
STII SHEUND cinue-cobensecndesubseabenbesnsenssesebvesunnennsebeineutenhes 1
i ce Lr eceenalanaetens 1
IID Qablabhntcilidbasuies sientenickslotatbebebenbectdbabibbbbsedrersiebiin 2
SIE bnenidcithetathakinntosndapeetistueterenietinvetinaniienaionetaetes 7
SUUIEIIDIIIET. Goahitcnsasighabetnpvcabueanvactpan gids dinasstaneniiniatesannicaunben ll
TABLE OF AUTHORITIES
Cases:
Alvarado Community Hosp. v. Shalala, No. CV
94-0972 (C.D. Cal. May 3, 1996), appeal pending,
I a il nchainloens 10
Bethesda Hosp. Ass’» v. Bowen, 485 U.S. 399
CUIUUIEE iaesthantubiinetennanntsdetabuindincasadidlintigiidienemaliceustvees 5, 6
Block v. Community Nutrition Inst., 467 U.S. 340
GEIIUD concienndiabbinibeersentanerarinnsenrsiisubinedeaiciagnteateiinesseis i)
Bowen v. Michigan Academy of Family Physicians,
eT anneeneale 7,8
Brown v. General Services Admin., 425 U.S. 820
UII . Gicancchiinadllniaaiabnandimmbivesnebaiitatabinaduapatdhereanamens 8)
Good Samaritan Hosp. v. Shalala, 508 U.S. 402
UIT dureibiepheath inhale tanith hciratanieanatibialtl nin nh masieebinacihbinitions 2
Heckler v. Ringer, 466 U.S. 602 (1984) ................08 11
Preiser v. Rodriguez, 411 U.S. 475 (1978) ............... i)
Preseault v. Interstate Commerce Comm’n,
ec i IEE . cnipeieenescdlch didn celeinigabablindviednatienemnanaeds )

Ruckelshaus v. Monsanto, 467 U.S. 986 (1984) .. 9 11
St. Vincent’s Med. Ctr. v. United States, 32 F.3d

ee es Ga: THEIPUEP nnuicradimicnidedthdunbidsonssbiandcsiasbidarbenes 6
Stonite Products Co. v. Melvin Lloyd Co., 315 U.S.

a a a al SR ty CE ET OO
United States v. Demko, 385 U.S. 149 (1966) .........
United States v. Erika, Inc., 456 U.S. 201 (1982) ..
United States v. Fausto, 484 U.S. 439 (1988) .........

oof ©

(IID

i

IV

Constitution, statutes and regulations: Page
U.S. Const. Amend. V (Just Compensation Clause) .. 9
Act of Oct. 26, 1974, Pub. L. No. 93-484, § 3(a),

Oe TE ED ancstaenistinisspieedsitishentedaiihienteneiesnitiin 8
Social Security Act, 42 U.S.C. 301 et segq.:
Tit. II, 42 U.S.C. 405(h) (§ 205(h)) ..........eeeeeeeeees 4, 7,8
Tit. XVIII (Medicare Act), 42 U.S.C. 1395 et seg. .. 2
SD UE ae SU seitnnienintbiesiivtiknniicah cingniosininasinatiaiatniain 4
OB ULL, TORO cessicnseocsnrememiviomncinnnnanes 7
Ge WE BE eerrricenpeninsetnamiviscineniinontepasiandiaien 4,7
GD URE BO Gintrncsvisnsitnrncdncevrins 5, 6, 7, 8, 9, 10, 11
GS SERA: ID etiivcistnitcieteitanticnithainsecinconicoatinl 10
42 U.S.C. 139500(a)(1)(A)() ..........ccccsecssreeesneeeeees 5
42 U.S.C. 139500(a)(1)(A)(ii) ...........ecceeessessseeseeees 5
GB CDK) TROD ticcstsccaveivintictithtiicianivens 5
GR Ua SED Strennnceerieniinnnnnia 5
© Ai RD ctiencotretiicintinaimnts 5
TED NE D tcectesescssasesccssanpnnicnedtatbiniee 8
Ge Uh ks SIGE EA. tekesictgntncnreGoitheiecseniariernns 5, 6, 10
Ge Ui SED teviinitiecenciensntsirneivitiinintainignn 5
Oe Fak: SINE Sethsitiitnbptinisnancdvernsahrnaimannnnnnnaicngs 2
42 U.S.C. 1895 ww(d)2)(E) ...........cccccoscssssccsssssene 3
42 U.S.C. 1895wWw(d)(3)(B) ............sscssccsscssseeseees 3
42 U.S.C. 1895ww(d)(5)(A) ........ccccccrcssccccccccsesees 2, 10
42 U.S.C. 1895Ww(d)(S)(A)GIV) .......eeeeeeceeeeeeeees 2, 10
Social Security Amendments of 1972, Pub. L. No.
92-603, § 243(a), 86 Stat. 1420 ..............ccccccsssceeeseeeees 8
Social Security Amendments of 1983, Pub. L. No.
SA BEF TUR. GB sae cscs iiistnnctecnsish incdinbbnis ceived 2
Tucker Act, 28 U.S.C. 1491(a)(1) ..............cceccsccsesceces 6
42 C.F.R.:

Section 405.1803
Section 405.1807
Section 405.1809(a)
Section 405.1809(b)(2)
Section 405.1841(b)
Section 413.20
Section 413.60

SPOS OSSHSE SESS OHHH ESTEE SE EEE HOH EEESEH ECE EES

SOHO SHESHSOSHEEHEH EERE SE OSER ESE RE SETS EEE EEE

SSOP SESH EEE E SEES EEEESE SES EEOEH SEEDER EEE O EES

SRST EES SEEHEEEEEHESESE TEETH EES E REE OOS

SPOTS E HE EEEH OSES TEE SHEE DESH OHO ERS

SOSH HEH SSSHESCHEE HEHE SESE HEHEHE ESE SET ESES

oO & OFT or or or or

SPER OH EES SHEETS ES ESE SESH ORE SEEOSESOES

Miscellaneous: Page

48 Fed. Reg. 39,776-39,777 (1983) ..........cccccccseeseseseeses 3
49 Fed. Reg. (1984):
ED, SED cncicecneginteseninapetnsitininossnnessseqnicamennevecenesens 3, 10

50 Fed. Reg. 35,708-35,710 (1985) ...........:cccccceeeeeeeeeees
51 Fed. Reg. 31,523-31,525 (1986) ...........cscccecsserereeees
52 Fed. Reg. 33,047-33,049 (1987) .............sssccceeseceeeees
53 Fed. Reg. 38,504-38,510 (1988) .............sesceseseeeeeeees
54 Fed. Reg. 36,498-36,500 (1989) ...........cccccsccceeeseeeees
55 Fed. Reg. 36,075-36,077 (1990) ..............csssessssesesees
OS Fie, Be, Gee GEE) scancnccccccsercccesrsesatorserccenesee
S. Rep. No. 1230, 92d Cong., 2d Sess. (1972) ..............

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Jn the Supreme Court of the United States

OCTOBER TERM, 1996

No. 96-578

ALLEMNORE COMMUNITY HospITAL, INC., ET AL.,
PETITIONERS

v.

UNITED STATES OF AMERICA

ON PETITION FOR A WRIT OF CERTIORARI
TO THE UNITED STATES COURT OF APPEALS
FOR THE FEDERAL CIRCUIT

BRIEF FOR THE UNITED STATES IN OPPOSITION

OPINIONS BELOW

The order of the court of appeals (Pet. App. 1-2) is
unpublished, but the decision is noted at 92 F.3d 1206
(Table). The opinion of the United States Court of
Federal Claims (Pet. App. 5-7, 9-10) is reported at 32
Fed. Cl. 608. The orders of the United States Court
of Federal Claims (Pet. App. 11-12) are unreported.

JURISDICTION

The judgment of the court of appeals was entered on
July 9, 1996. The petition for a writ of certiorari was
filed on October 7, 1996. The jurisdiction of this
Court is invoked under 28 U.S.C. 1254(1).

(1)

2

STATEMENT

1. Title XVIII of the Social Security Act estab-
lishes a federally funded health insurance program
for the elderly and disabled known as Medicare. See
42 U.S.C. 1395 et seg. (the Medicare Act). The Secre-
tary of Health and Human Services (the Secretary)
has delegated administrative responsibility for the
program to the administrator of the Health Care
Financing Administration (HCFA). The Social Secu-
rity Amendments of 1983 amended 42 U.S.C. 13895ww
and replaced the “reasonable cost” system of reim-
bursing provider hospitals with a Prospective Pay-
ment System, under which payment rates generally
are established without regard to a hospital’s actual
costs. See Good Samaritan Hosp. v. Shalala, 508
U.S. 402, 406 n.3 (1993).

Section 1395ww also provides for additional pay-
ments in “outlier” cases in which a patient’s hospital
stay is unusually lengthy or costly when compared to
most discharges classified within the same discharge
related group (DRG). 42 U.S.C. 1395ww(d)(5)(A). The
Secretary is required to establish payment crite-
ria applicable to all Medicare hospitals for outlier
cases prior to each federal fiscal year. bid. The total
amount of outlier payments made under Section
1395ww(d)(5)(A) for discharges in a fiscal year “may
not be less than 5 percent nor more than 6 percent of
the total payments projected or estimated to be made
based on DRG prospective payment rates for dis-
charges in that year.” 42 U.S.C. 1395ww(d)(5)(A)(iv).
For each fiscal year since 1984, the Secretary has
established prospective outlier payment criteria so

3

that nationwide outlier payments were expected to
equal between five and six percent of total PPS in-
patient services payments. See, e.g., 48 Fed. Reg.
39,776-39,777 (1983); 49 Fed. Reg. 264-266 (1984).’

In January 1984, the Secretary stated that outlier
criteria and payments for a fiscal year would not be
adjusted retroactively based on actual annual Medi-
care payment data for that fiscal year:

Using the data we had available, we set the
outlier criteria so that an estimated six percent of
total payments would be made for outliers. Nev-
ertheless, there is no necessary connection be-
tween the amount of estimated outlier payments

- and the actual payments made to hospitals for
eases that actually meet the outlier criteria.
While we expect that under these criteria outlier
payments will approximate six percent of total
payments, we will pay for any outlier that meets
the criteria, even if aggregate outlier payments
result in more than six percent of total payments.
Under such circumstances, we will continue to
make these payments for the remainder of the
Federal fiscal year without adjusting the DRG
rates to compensate for the additional payments.
Similarly, if we overestimate the amount of out-
lier payments, we will not adjust the DRG rates

1 To make outlier payments budget-neutral, Congress di-
rected the Secretary to reduce PPS rates to reflect the per-
centage of expected outlays for outlier payments. 42 U.S.C.
1395ww(d)(2)(E) and (3)(B).

4

to compensate hospitals for funds that were not
actually paid for outlier cases.

49 Fed. Reg. 265 (1984). The Secretary reiterated
that position in succeeding years.

2. Section 205(h) of the Social Security Act, 42
U.S.C. 405(h), which is made applicable to the Medi-
care Act by 42 U.S.C. 1395ii, provides:

The findings and decision of the [Secretary *]
after a hearing shall be binding upon all indi-
viduals who were parties to such hearing. No
findings of fact or decision of the [Secretary]
shall be reviewed by any person, tribunal, or
governmental agency except as herein provided.
No action against the United States, the [Sec-
etary], or any officer or employee thereof shall
be brought under section 1331 or 1346 of title
28 to recover on any claim arising under this
subchapter.”

42 U.S.C. 405(h) (emphasis added).

The Medicare Act allows provider hospitals to chal-
lenge their payments under the Medicare program.
Each fiscal year, hospitals submit to a fiscal inter-
mediary a cost report containing the hospital’s re-
quest for reimbursement. 42 U.S.C. 1395h; 42 C.F.R.
413.20. The fiscal intermediary audits the cost report
and issues a Notice of Program Reimbursement

2 See 50 Fed. Reg. 35,708-35,710 (1985); 51 Fed. Reg.
31,523-31,525 (1986); 52 Fed. Reg. 33,047-33,049 (1987); 53 Fed.
Reg. 38,504-38,510 (1988); 54 Fed. Reg. 36,498-36,500 (1989); 55
Fed. Reg. 36,075-36,077 (1990); 56 Fed. Reg. 43,227 (1991).

8 Section 1395ii provides that the reference to the
Commissioner of Social Security in Section 405(h) “shall be
considered a reference to the Secretary * * * of Health and
Human Services.” 42 U.S.C. 1396ii.

5

(NPR) reflecting the total program reimbursement
due the provider for items and services covered by the
Medicare Act. 42 C.F.R. 405.1803, 405.1807, 413.60; see
Bethesda Hosp. Ass'n v. Bowen, 485 U.S. 399, 401
(1988).

Under Section 139500, a provider that is “dis-
satisfied with a final determination of * * * its
fiscal intermediary * * * as to the amount of
total program reimbursement due the provider,” or
that is “dissatisfied with a final determination of the
Secretary as to the amount of the payment under
subsection * * * (d) of section 1395ww,” may request
a hearing before the Provider Reimbursement Re-
view Board (PRRB). 42 U.S.C. 189500(a)(1)(A)(i) and
(ii). The provider must request such a hearing
within 180 days of the fiscal intermediary’s final
determination, and the amount in controversy must
equal or exceed $10,000. 42 U.S.C. 139500(a)(2) and
(3). The Board may “affirm, modify, or reverse a final
determination of the fiscal intermediary.” 42 U.S.C.
139500(d). The Secretary further may either affirm,
reverse, or modify the Board’s decision. 42 U.S.C.
139500(f)(1). Following a final decision of the PRRB
(or any reversal, affirmance, or modification by the
Secretary), a provider may seek judicial review in the
United States District Court in the judicial district
where the provider is located or in the District of

* Under the Act, certain determinations (not relevant
here) are not reviewable. 42 U.S.C. 139500(g).

5 For “good cause,” the PRRB may waive the 180-day
limitation for up to a three-year period. 42 C.F.R. 405.1841(b).
The Secretary’s regulations also allow for a hearing before the
fiscal intermediary for amounts in controversy of at least
$1,000 but less than $10,000. 42 C.F.R. 405.1809(a) and (b)(2).

IE IIE ee

6 a

Columbia. Jbid. Section 139500 also provides for
expedited judicial review in district court whenever
the Board determines that it lacks authority over any
“question of law or regulations relevant to the mat-
ters in controversy.” IJbid.; see Bethesda Hosp. Ass’n,
485 U.S. at 401.

3. Petitioners are hospital providers which filed
suit in the United States Court of Federal Claims to
seek additional outlier payments for fiscal years 1985
and 1986 because the payments in those years al-
legedly “were less than the outlier payments due
them under 42 U.S.C. § 1395ww(d)(5)(A)(iv).” Pet. 5.
Petitioners contend that the court had jurisdiction
over their claims under the Tucker Act, 28 U.S.C.
1491(a)(1).° Petitioners did not seek administrative or
judicial review under Section 139500 within 180 days
after receipt of their NPR for the contested cost
years, because, they allege, they were not aware until
1992 of the total amount of outlier payments nation-
wide in 1985 and 1986. Pet. 4-6.

The government moved to dismiss petitioners’ re- |
spective complaints for lack of jurisdiction, claiming |
that the review procedures mandated by Section
139500 preclude jurisdiction under the Tucker Act.
During the pendency of the motion to dismiss, the
Federal Circuit decided St. Vincent’s Medical Center
v. United States, 32 F.3d 548 (1994) (Pet. App. 18-23),

6 In relevant part, 28 U.S.C. 1491(a)(1) provides:

The United States Court of Federal Claims shall have
jurisdiction to render judgment upon any claim against
the United States founded either upon the Constitution, or
any Act of Congress or any regulation of an executive
department, or upon any express or implied contract with
the United States.

7

which held that “[bJecause the Medicare Act contains
its own comprehensive administrative and judicial
review scheme, there is no Tucker Act jurisdiction
over Medicare reimbursement claims.” Pet. App. 16.
Citing St Vincent's, the Court of Federal Claims
granted the government’s motions to dismiss peti-
tioners’ suits. Jd. at 5-12. The cases were consoli-
dated on appeal, and the Federal Circuit affirmed
without opinion. /d. at 1-2.

ARGUMENT

The court of appeals’ decision is correct and does
not conflict with any decision of this Court or any
other court of appeals. Further review is not war-
ranted.

1. Section 205(h) of the Social Security Act, incor-
porated into the Medicare Act by 42 U.S.C. 1395ii,
provides that “[nJo * * * decision of the [Secretary]
shall be reviewed” by any “tribunal” except as pro-
vided by the Medicare Act. 42 U.S.C. 405(h). Because
petitioners did not avail themselves of the administra-
tive and judicial review procedures under Section
139500, the Federal Circuit correctly held that peti-
tioners’ claims must be dismissed.

Contrary to petitioners’ Suggestion (Pet. 8-12),
construing Section 205th) to limit judicial review
here does not conflict with Bowen v. Michigan
Academy of Family Physicians, 476 U.S. 667 (1986).
This Court held in Michigan Academy that 42 U.S.C.
405(h) and 1395ff(b)(1(C) do not foreclose review in
district court of the Secretary’s Medicare Part B
regulations establishing the method of determining
benefits. 476 U.S. at 675, 680. The Court was guided
by “the strong presumption that Congress intends
judicial review of administrative action” and the ab-

8

sence of any explicit provision in Part B (as it then
existed) for judicial review. Jd. at 670. In the present
case, however, petitioners seek under the Tucker Act
review of agency action precisely contemplated by
Section 139500, i.e., the amounts of their reimburse-
ments, including payments for outlier cases. Unlike
in Michigan Academy, application of Section 205(h)
to bar Tucker Act jurisdiction in the present case
would not deny providers a means to obtain judicial
review of their claims.

Prior to 1972, the Medicare Act did not permit
hospital providers to challenge their Medicare cost
determinations. S. Rep. No. 1230, 92d Cong., 2d Sess.
51 (1972). The Act was amended in 1972 and 1974 to
establish the PRRB and provide a comprehensive
scheme for review of payment disputes involving
amounts of $10,000 or more. Social Security Amend-
ments of 1972, Pub. L. No. 92-603, § 243(a), 86 Stat.
1420, 42 U.S.C. 139500; Act of Oct. 26, 1974, Pub. L.
No. 93-484, § 3(a), 88 Stat. 1459, 42 U.S.C. 139500(f).
Thus, the administrative and judicial review proce-
dures of Section 139500 are exclusive as to claims
covered by Section 139500.

This Court has held that when Congress enacts a
comprehensive administrative and judicial review
scheme for challenging agency action, the Tucker
Act does not provide an alternative basis for review.
See United States v. Fausto, 484 U.S. 489, 448-449
(1988) (review procedures in the Civil Service Reform
Act preclude judicial review under the Tucker Act);
United States v. Erika, Inc., 456 U.S. 201, 208 (1982)
(Medicare Act’s review provisions under Part B of the
Medicare program preclude judicial review under the

9

Tucker Act).’ Similarly, because Section 139500 sets
forth a precisely drawn and comprehensive scheme of
judicial review of payments to providers under the
Medicare program, the Tucker Act does not provide
the Court of Federal Claims with jurisdiction to hear
petitioners’ claims.®

Petitioners do not dispute that their claims are
covered by Section 139500’s review procedures. Pet.

* This rule is consistent with the principle that a remedy
furnished by a precisely drawn, detailed statute preempts a
more general, otherwise applicable remedy. See, e.g., Brown v.
General Services Admin., 425 U.S. 820 (1976) (Title VII of Civil
Rights Act of 1964 preempts preexisting employment discrimi-
nation remedies); Preiser v. Rodriguez, 411 U.S. 475 (1973)
(state prisoners may not seek redress under Civil Rights Act
because of comprehensive remedial scheme of habeas corpus);
United States v. Demko, 385 U.S. 149 (1966) (prison workers’
compensation system preempts Federal Tort Claims Act);
Stonite Products Co. v. Melvin Lloyd Co., 315 U.S. 561 (1942)
(specific venue statute for patent infringement cases is exclu-
sive law governing venue in such cases).

® Petitioners mistakenly rely (Pet. 12-16) on cases dis-
favoring implied repeal of Tucker Act jurisdiction. See, e.g.,
Preseault v. Interstate Commerce Comm'n, 494 U.S. 1 (1990);
Ruckelshaus v. Monsanto, 467 U.S. 986 (1984). Those cases
arose under the Just Compensation Clause and did not involve
the present situation in which Congress specifically has pro-
vided for review of the purported claims in another forum.
Similarly, petitioners’ contention (Pet. 24) that there is no
“Tejlear and convincing evidence’ of congressional intent to
bar all judicial review” is erroneous in light of Section 139500.
See also Block v. Community Nutrition Inst., 467 U.S. 340, 350-
351 (1984) (“This Court has * * * never applied the ‘clear and
convincing evidence’ standard in the strict evidentiary sense,”
but “has found the standard met, and the presumption favoring
judicial review overcome, whenever the congressional intent to
preclude judicial review is ‘fairly discernible in the statutory
scheme.’” (citation omitted)).

10

4-6. Indeed, hundreds of Medicare providers have
invoked Section 139500 to challenge the level of
their outlier reimbursement as not meeting the
five percent projection required by Section
1395ww(d)(5)(A)iv). See, e.g., Alvarado Community
Hosp. v. Shalala, No. CV 94-0972 (and consolidated
cases) (C.D. Cal. May 3, 1996), appeal pending, No.
96-55967 (9th Cir., filed June 19, 1996). Petitioners’
contention that they could not timely pursue review
under Section 139500 “through no fault of [their]
own” (Pet. i), even if true,® does not create juris-
diction under the Tucker Act. Because Congress
directed that providers dissatisfied with the program
payments, including outlier payments computed un-
der Section 13895ww/(d)(5)(A), must first seek review
before the PRRB, petitioners first must present
their claims, including any arguments that would
overcome the time limitations of Section 139500, to
the PRRB. If the PRRB determines that petitioners
are not entitled to relief for any reason, petitioners
must seek judicial review of the PRRB’s decision in
district court. 42 U.S.C. 139500(f)(1).”

® Petitioners argue (Pet. 4-5, 14) that, until 1992, they did
not receive the Secretary’s “final determination” of total ag-
gregate outlier payments. However, the Secretary is not re-
quired to publish actual Medicare payment data on a nation-
wide basis, and the Secretary first set forth the prospective
payment methodology for outlier payments in 1984. 49 Fed.
Reg. 264-266 (1984). Thus, the absence of national data on total
outlier payments did not prevent petitioners from making
their own claims under Section 139500(a) within 180 days after
receipt of their NPRs for any given cost year.

1 The fact that petitioners may seek judicial consideration
of their claims under Section 139500 also belies petitioners’ con-
tention (Pet. 23-24) that to preclude Tucker Act jurisdiction
over those same claims would raise constitutional questions.

1]

2. Judicial review is also precluded because peti-
tioners have not exhausted their administrative
remedies before the PRRB. Heckler v. Ringer, 466
U.S. 602 (1984) (exhaustion of administrative reme-
dies is mandatory in the Medicare program). Tucker
Act jurisdiction would not relieve petitioners of their
obligation to pursue administrative review before pre-
senting their claims to the courts. See Ruckelshaus
v. Monsanto Co., 467 U.S. 986, 1018 (1984) (requiring
exhaustion of administrative remedies before seeking
relief under Tucker Act). Because petitioners failed
to seek any review under Section 139500, the courts
below properly dismissed their claims.

CONCLUSION

The petition for a writ of certiorari should be
denied.

Respectfully submitted.

WALTER DELLINGER

Acting Solicitor General
FRANK W. HUNGER

Assistant Attorney General
ANTHONY J. STEINMEYER
BRIAN M. SIMKIN

Attorneys

DECEMBER 1996

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386004_1611%3A2. Public record. Not legal advice.