(B) Statement of Points and Authorities in Diersen v. Walker (GAO)

Case 16:  (B) Statement of Points and Authorites in Diersen v. Walker (GAO)

David J. Diersen,
for himself and all others
similarly situated,

v.

COMES NOW, the Plaintiff, David J. Diersen (Diersen), for himself and all others similarly situated, and submits the following statement of points and authorities in support of his motion to alter or amend the judgment pursuant to F.R.Civ.P. 59(e). A motion under F.R.Civ.P. 59(e) may be filed within 10 business days of entry of an Order of final disposition. Entry of the final Order in this action was on September 3, 1999, and therefore, Diersen’s motion to alter or amend judgment is timely filed.

1. Defendant, United States General Accounting Office (GAO), in support of its allegation that all Diersen’s claims before this Court should be dismissed, made statements in its October 20, 1998 and December 24, 1998 filings to persuade this Court that the District of Colombia (DC) was not the proper venue, that Diersen had not met the requirements of Local Rule 203, and that Diersen’s amended complaints did not comply with F.R.Civ.P. 8(A). Those statements were factually false, wrong and misleading.

2. This Court erred in relying on those false and incorrect statements, apparently following the by now quite obviously inapplicable presumption that GAO and its Department of Justice (DOJ) attorneys do not plead or testify falsely to the Court. To the contrary, as proven by their direct quotes following, statements made by GAO and its attorneys statements are false. It follows as night follows day, that GAO officials violated their duty to this Court to be truthful as to factual issues for which they have unique access, especially concerning GAO regulations and policies, and that GAO’s attorneys violated their duty to this Court under the standards set out by the United States Supreme Court in Black v. Romano, 471 U.S. 606, 621-22 & n. 18 (1985).

3. It also follows that GAO’s allegations regarding the facts supporting lack of venue are unproven and mere unsupported and false arguments unless this Court holds a hearing on the factual statements that Diersen disputes and determines that they are true. Without such a hearing, the rules governing due process of law under the Federal Rules of Civil Procedure, and indeed our whole system of Federal Law, means nothing.

4. For this most important reason, which Diersen submits beings into question the very integrity of the federal government and the integrity of its officers, which most assuredly can not be presumed to be always truthful, and the effects of misapplication of that presumption which go far beyond the boundaries of this case, Diersen’s motion to alter or amend the judgment and his motion for leave to file third amended complaint must be granted. In addition, Diersen’s claims must remain before this Court or he will be constructively barred from having legal representation concerning those claims thereby denying him his constitutional right of due process of law.

5. This Court’s judgment to dismiss Diersen’s claims was quite simply based on false and erroneous factual allegations and misleading statements made by GAO and its attorneys. This Court erred in basing its judgment on such allegations and statements without holding a hearing to resolve the important material factual conflicts involved in this case, especially those which involve venue and Diersen’s class action claims. There is simply no reasonable basis for this Court’s complete reliance on the assumption that GAO and its attorneys always tell the truth. In fact, as demonstrated below, in this instance they did not. Therefore, it is respectfully submitted that this Court should alter or amend its judgment as Diersen has requested. In addition, this Court should set a hearing to determine the disputed facts relating to venue and Diersen’s class action claims based on the simplified statement of facts contained in the new "third amended complaint."

Allegations That Are False:

6. As set forth below, this Court’s judgment concerning venue was based on GAO statements and allegations which were accepted as being the gospel truth. However, those statements and allegations are in fact demonstrably false and misleading. The correct facts are that GAO’s principal office is in DC and all of the unlawful employment policies and practices Diersen complains of were established and implemented in that office. Diersen pled those facts in his original complaint, in all subsequent pleadings, and in his proposed amended complaints. Additional correct facts include that at all relevant times, Diersen’s official personnel file was maintained and administered in DC and never in Chicago and that the bulk of the witnesses to the claims of both Diersen and the class he seeks to represent are located in DC. Diersen pled those facts in his first amended complaint and in all subsequent pleadings. In Diersen’s third amended complaint, filed contemporaneously herewith, he shortened and clarified his individual claims. There can be no doubt that venue is properly in DC and it is plain error for this Honorable Court to hold otherwise.

7. Judgment Concerning Venue and The Nature Of Diersen’s Claims Was Based On GAO Statements That Are Wrong: GAO stated at page 9 of its October 20, 1998 memorandum in support of its motion to dismiss that "Plaintiff’s allegations pertaining to employment discrimination all arose in Chicago, Illinois." Based on that incorrect statement, this Court made the following factually incorrect statement at page 3 of its September 3, 1999 Memorandum in support of its Order:

8. GAO’s statement is simply untrue. Diersen alleged that the root cause of the actions taken against him all arose in DC because of employment policies and practices there. This Court erred in relying on GAO’s false statement and compounded the error by then stating incorrectly that Diersen made no allegations of employment discrimination in DC.

Compare, Diersen’s statements in his original complaint:

QUOTES FROM ORIGINAL COMPLAINT:

Also compare, Diersen’s statement of his second amended complaint:

GAO’s principal office is located in DC and all of the policy decisions that violate federal law and underlie this lawsuit affecting Diersen’s individual claims and the class he seeks to represent were established and implemented there. (Page 2)

9. Diersen also stated with particularity that all of the personnel actions taken against him personally, and those taken against the class were the direct result of the implementation of the GAO’s nation-wide policies to disfavor older employees. He alleged that all of the individual acts taken against him were the result of the policies and practices created, implemented, and enforced not in Chicago, but rather, in DC.

10. Compare Diersen’s complaint allegations which allege that the discriminatory employment actions GAO took against him were driven by GAO’s agency-wide policy of giving preferential treatment to its younger employees and especially to those who are minority and/or female as follows:

THE FOLLOWING QUOTES ARE FROM THE SECOND AMENDED COMPLAINT, HOWEVER, THE THEORY OF THE CASE IS EVIDENT IN THE ORIGINAL COMPLAINT AND EACH SUBSEQUENT AMENDMENT:

Diersen’s claims and those of each member of the class include that for over 15 years, on a continuing basis, GAO maintained and continues to maintain a practice of favoritism for its younger Evaluators, especially those who are female and/or minority, in matters involving hiring, work assignments, performance expectations, performance appraisals, bonuses, merit pay increases, promotions, transfers, and separation from service. The result of that practice, which has been observed by Diersen and many others with whom he has maintained contact and which he avers in fact exists, includes the following: (a) Equally or better qualified persons who are older, male, and/or white are not hired, are denied work assignments, are given unrealistic performance expectations, are given unfair performance appraisals, are denied bonuses, are denied merit pay increases, are denied promotions, and/or are given actual or defacto adverse transfers, demotions, or discharge; (b) Since 1989, GAO has abused the flexibility in its broadbanding and pay-for-performance (PFP) systems to achieve the results in (a) above; (c) Virtually all promotions to Band II and to Band III in virtually all GAO’s divisions and offices during the class period were given to persons under the "magic age" of 43, an age younger than Diersen, and an age at which virtually all promotions stop. Virtually all exceptions to this rule of which Diersen is aware were females, minorities, and/or persons who have agreed to give preferential treatment to those groups; (d) This practice has been universal, in all divisions and offices and for all grade levels of employment involved, for the entire class period. (Pages 10 and 11)

This is a suit by a former federal employee who was constructively discharged after an 18 year period of employment with GAO during which he experienced at every turn a constant and continuing pattern of discrimination because of GAO’s policy and practice to favor younger persons who were typically females and minorities targeted for promotion and retention over older better qualified employees. (Page 15)

(Diersen’s) managers actively discriminated against him in violation of federal law by removing him from audits of IRS and other existing high profile work assignments, denying him leadership roles on audits of IRS and other high profile work assignments, and substituting lower skill and lower profile work assignments, with the intent to deny him promotion to which he was entitled as the most qualified and to force him out of the federal service, which actually happened. The final events in the series which led to Diersen's complaint of discrimination occurred on September 30, 1997 and in the forty five days preceding that date. Those events included giving him an unfair performance appraisal and forcing him to accept either a constructive demotion or forced transfer. (Page 18)

Diersen, by virtue of his qualifications and expertise, was at least equally qualified for each work assignment, bonus, merit pay increase, and promotion that he did not receive. GAO employees who were either younger than Diersen, female, and/or minority and less qualified received higher profile assignments, bonuses, larger merit pay increases, and promotions. But for the discrimination complained of herein, Diersen would have received the assignments, bonuses, merit pay increases, and almost all of the promotions. (Page 19)

Diersen alleges that a prima facie case exists as well as a continuing pattern of action exists of age discrimination, reverse discrimination, and retaliation. That pattern resulted in his constructive discharge. Pursuant to GAO’s illegal policy and practice of giving preferential treatment to younger employees, GAO discriminated against Diersen because of his age since he became 40 years old on September 29, 1988. Adverse employment actions GAO took against Diersen because of his age include denying him job assignments, denying him leadership roles, giving him unrealistic expectations, giving him unfair performance appraisals, denying him bonuses and merit pay increases, discouraging him from applying for promotions, assigning him as subordinates problem employees, and encouraging the making of and making false extremely negative statements about him both before and after his constructive discharge. (Page 20)

After his constructive discharge, GAO continued to retaliate against him. His superiors filed false and extremely negative affidavits for the investigation of his discrimination complaint. GAO refused to properly investigate his discrimination complaint. GAO continues to sabotage his efforts to find professional work. On at least five occasions since September 30, 1997, as documented by disinterested third parties, GAO willfully and repeatedly failed to follow its own procedures, including GAO Order 2294.3, for handling inquiries about former employees. GAO failed to respond to inquiries about Diersen’s GAO employment. GAO refused to acknowledge that Diersen was eligible to be rehired by GAO. GAO failed to keep its agreement with Diersen to give him a strong letter of recommendation and to respond to inquiries about his GAO employment in a manner that is consistent with that letter of recommendation. (Page 22)

Diersen’s retirement was a direct result of the adverse employment actions that GAO took against him because of his age, gender, and race as described above; GAO’s retaliation against him for complaining about discrimination as described above; and the additional adverse employment actions that GAO took against him during September of 1997. Those adverse employment actions included giving him an extremely unfair performance appraisal and forcing him to accept either a constructive demotion or adverse transfer. He was told that for the rest of his GAO career, he would likely have to work for junior members of that group. Those members, were uniformly younger, female, and/or minority and were less qualified than Diersen for leadership roles in terms of relevant experience, education, and professional certifications. The justifications that GAO have given for the preferential treatment it gave others and for the adverse employment actions it took against Diersen, including allegations that he could not be objective on IRS audits and that he had serious performance problems, are false, demonstrably so, and a mere pretext for GAO's discriminatory actions in accordance with its agenda of giving preference to younger females and minorities. GAO's investigation of Diersen's EEO complaint and the alleged facts that GAO relied on to take its adverse employment actions against Diersen was itself biased and a pretext, thereby denying Diersen the benefit of due process in the administrative processing of his complaint. (Pages 22 and 23)

GAO managers refused to give Diersen leadership roles even though he was better qualified for such roles in terms of his education, professional certifications, experience, and demonstrated performance; many younger employees, females, and minorities were routinely given such roles. (Pages 29 and 30)

GAO managers expected Diersen to meet unrealistic expectations that younger employees, females, and minorities were not expected to meet. (Page 30)

GAO managers discouraged Diersen from applying for promotions and routinely gave promotions to younger employees, females, and minorities who were less qualified in terms of education, professional certifications, experience, and demonstrated performance. (Page 33)

THE REPRISALS AROSE IN DC ALSO:

11. Evidence of the causal link between his protected activities and GAO’s retaliatory actions include five reports issued by three disinterested third parties that document that on five occasions between July 2, 1998 and July 14, 1999, GAO willfully and repeatedly failed to follow its own national policy procedures and failed to keep promises it had made to Diersen when, after his constructive discharge, GAO failed to respond to inquiries about Diersen’s GAO employment, when it failed to respond to such inquiries in a timely manner, when it refused to acknowledge that Diersen was eligible to be rehired by GAO, and when it did not respond to inquiries about his GAO employment in a way that is consistent with its letter of recommendation.

12. The following cases on this point show that GAO’s factually wrong statements furnish an insufficient basis for this Court’s determination of improper venue. Thus, but for the falsities accepted by the Court as true, the transfer of venue request should have been denied.

13. In Hayes v. RCA Service Co, 546 F Supp 661 (1982, DC Dist Col), this Court found that it is proper to look to the place where the decisions were made (Here The District of Columbia) when determining venue for Title VII actions. According to the Court in Hoffman v. United Telecommunications, Inc., 575 F Supp 1463 (DC Kan 1983), venue is proper in the judicial district where the defendant has its principal office if the unlawful employment practices are claimed to have been established and implemented in that office rather than in the office in which the plaintiff was employed. This is exactly what Diersen claims and has pled.

14. The Court’s decision in Stebbins v. State Farm Mutual Automobile Insurance Company, 413 F.2d 1100 (D.C. Cir.), cert. denied 396 U.S. 895 (1969), does not support GAO’s motion for change of venue (as GAO argued) because Stebbins did not claim that any unlawful employment practices were established by or implemented by officials in the defendant’s principal office and he did not claim that any discriminatory personnel decisions that affected him were made there. See Haynes and Hoffman, supra.

15. In Turberville v. Casey, 525 F. Supp. 1070 (D.D.C. 1981), relied upon by GAO, the Court found that proper venue was where the employer’s principal office was located. The Court rejected Turberville’s allegation that another judicial district had proper venue because the head of her employing agency maintained an office there.

16. In summary, all Diersen’s Title VII claims have proper venue in this Court and this Court’s judgment concerning the nature of Diersen’s claims, and therefore, which Court has proper venue, is wrong because it is based on a GAO statement that is factually wrong. A correct decision by this Court regarding venue requires a finding that this Court has proper venue for Diersen’s Title VII claims because all the unlawful employment policies and practices Diersen complains of were established and implemented in GAO’s principal office in DC. Each and every GAO employee is well aware of that fact, and any allegation to the contrary is simply an attempt to mislead this Court with falsities.

17. Moreover, GAO acknowledged at page 10 of its October 20, 1998 memorandum in support of its motion to dismiss that this Court may have proper venue for Diersen’s ADEA claims. Therefore, all Diersen’s claims, including his inextricably connected age class action and individual ADEA and reverse discrimination Title VII claims, have proper venue in this Court. All of his claims, and all of the actions against him arose from the same root cause, GAO’s quota system favoring certain employees based upon age, gender and to a much lessor extent, race at the expense of older employees like Diersen.

18. Judgment Concerning The Maintenance And Administration Of GAO’s Official Personnel Files Was Based On A GAO Statement That Is Misleading If Not Factually Wrong: GAO stated at page 9 of its October 20, 1998 memorandum in support of its motion to dismiss that "Plaintiff’s employment records are maintained and administered in St. Louis, Missouri." Based on that statement, this Court made the following statement at page 3 of its September 3, 1999 Memorandum in support of its Order: "The employment records of plaintiff are neither maintained nor administered in the District of Columbia." [emphasis added to both].

19. The foregoing statement is true NOW, but was untrue for the entire time frame of this case.

Compare: Page 2 of Diersen’s second amended complaint: "The official personnel files for Diersen and for each member of the class he seeks to represent were at all relevant times maintained and administered in DC."

20. In addition, St. Louis, Missouri, where closed files are stored, is not the venue where GAO has requested this Court to transfer Diersen’s individual claims and to which the Court ordered the transfer of venue.

21. Therefore, this Court’s judgment concerning the maintenance and administration of GAO’s official personnel files for Diersen and the members of the class he seeks to represent is simply factually wrong and baseless.

22. Judgment Concerning Judicial Economy And Convenience Of The Parties And Witnesses And The Interest Of Justice Was Based On GAO Statements Are Factually Wrong: GAO stated at page 10 of its October 20, 1998 memorandum in support of its motion to dismiss that "Plaintiff’s Title VII claims must be brought or transferred to the Northern District of Illinois and plaintiff’s age discrimination claims arise from the same operative facts" and "Most potential witnesses likely live and work in or near Chicago" and "While, pursuant to (28 U.S.C. § 1391(e)), the District of Columbia may be a proper venue under ADEA, considerations of judicial economy, convenience of the parties and witnesses, and the interests of justice demonstrate that venue, in fact, is more appropriate in the District Court in Illinois."

23. Based on those most presumptive statements, which require the Court to accept GAO’s assertion of where Diersen’s witnesses will come from and reside, this Court made the following statement at page 3 of its September 3, 1999 Memorandum in support of it Order: "Considerations of judicial economy and convenience of the parties and witnesses and the interest of justice require that the ADEA claim be transferred along with the Title VII claim."

24. GAO’s statements on this issue, relied upon by the Court without hearing or the opportunity to challenge as basic fact, are misleading and wrong. This Court acknowledged at page 3 of its September 3, 1999 Memorandum, that proper venue for Diersen’s Title VII class action claims is being "challenged as a matter of fact" and that it involves a "factual dispute." Further, as Diersen stated at page 2 of his second amended complaint: "the largest single concentration of members of the class Diersen seeks to represent lives and works in or around the DC" and "the bulk of the witnesses to the claims of both Diersen and the class he seeks to represent are located there."

25. Therefore, this Court’s judgment concerning the convenience of witnesses was based on GAO statements that are factually wrong when Diersen’s pleadings are taken as true as is the proper standard at this stage of the case. Further, if all Diersen’s claims are transferred to the Court in Chicago and that Court reinstates his class action claims, in all likelihood, all Diersen’s claims would be transferred back to this Court, and judicial economy will not have been served by the hiatus in the interim. Of course, that is exactly what GAO wants in this case where the basic facts of its discrimination are so blatant, well known, publicized, and provable. In other words, GAO’s only defense is to attempt to influence this Honorable Court to deny access to justice by delay and transfer. This is not the judicial system that is supposed to be in effect in America.

26. Venue must remain with this Court in the interests of justice, because if this Court grants the alternative relief that GAO seeks and transfers Diersen’s claims to Chicago, he will also be constructively barred from having adequate legal representation. Diersen’s counsel resides in Annapolis, Maryland and has represented Diersen and many other GAO employees in matters involving age discrimination, reverse discrimination, and retaliation at GAO since the late 1980s. He is very familiar with GAO’s policies and procedures and he is more familiar with Diersen’s claims than any other counsel. However, while counsel for both parties maintain offices in DC, Diersen’s counsel does not have an office in Chicago. In addition, Diersen has no counsel in Chicago, let alone counsel who is familiar with GAO and his claims. If Diersen’s counsel were to attempt to continue to represent Diersen in Chicago, the adequacy of representation that Diersen could receive would be severely impaired. Therefore, in the interest of justice, venue should remain with this Court.

Judgment Concerning Diersen’s Provided Local Rule 203 Information Was Based On A GAO Statement That Is Factually Wrong

27. GAO stated at page 8 of its October 20, 1998 memorandum in support of its motion to dismiss that "Plaintiff’s Complaint does not state any of the information required by Local Rule 203." Diersen had the right to amend his pleadings. He did that in a timely fashion. It can not be argued that his amended complaints, filed before any responsive pleading did not meet the requirements of Local Rule 203.

28. In its December 24, 1998 opposition to Diersen’s motion for leave to file amended complaint, GAO did not allege that Diersen had not provided all information required by Local Rule 203 in his first amended complaint, but instead, argued at page 18 that

"Plaintiff’s purported class allegations, however, should be dismissed due to the plaintiff’s failure to exhaust administrative remedies regarding, or provide adequate notice of, his purported class action allegations" ....

"Consequently, any proposed amendment to the Complaint in this regard will be futile and will not save plaintiff’s complaint from dismissal."

29. Based on GAO’s statements, this Court made the following statement at page 2 of its September 3, 1999 Memorandum in support of its Order: "Plaintiff’s class action allegations will be dismissed because plaintiff has failed to satisfy the pleadings requirements for class actions established by Rule 203 of the Rules of this Court."

30. However, GAO’s statements are factually wrong and this Court erred in relying on them because as required by Local Rule 203(a), now LCvR 23.1(a), Diersen’s second amended complaint contains at page 4 a separate heading styled "Basis For Certifying Class" and under that heading, in a short and plain way, Diersen referenced the portions of F.R.Civ.P. 23 under which he claims his suit is maintainable as a class action; he provided the approximate size and definition of the class; he provided the basis upon which he claims to be an adequate representative of the class; he provided the commonality and typicality questions of law and fact common to the class; and he provided findings required by F.R.Civ.P. 23(b)(3). The following case on this point shows that GAO’s factually wrong statement, which was the only basis for this Court’s factually wrong judgment, is inadequate to support the Order in this case..

31. In its motion to dismiss, GAO likened Diersen’s actions to those of the plaintiff in Abney v. District of Columbia, 1989 WL 17750 (D.D.C. 1989). However, Abney never filed an amended complaint to satisfy Local Rule 203 requirements, and further, his motion for class certification did not satisfy Local Rule 203 requirements either. In Abney, the Court clearly indicated that class action claims should not be dismissed for Local Rule 203 deficiencies unless the plaintiff fails to correct those deficiencies in an amended complaint or in a motion for class certification. Diersen did correct his Local Rule 203 deficiencies when he filed his first amended complaint.

32. This Court’s judgment concerning Diersen’s providing Local Rule 203 information, and therefore, its dismissal of Diersen’s class action claims, is wrong because it is based on a statement made by GAO that is factually wrong. Diersen’s class action claims should not be dismissed because of Local Rule 203 deficiencies because he corrected those deficiencies in his amended complaint and because this Court’s conclusion to the contrary is factually wrong.

Judgment Concerning Diersen’s Compliance With F.R.Civ.P. 8(a) Was Based On GAO Statements That Are Factually Wrong

33. GAO stated at page 18 of its December 24, 1998 opposition to Diersen’s motion for leave to amend that: "Plaintiff’s proposed Amended Complaint merely eliminates certain claims and modifies plaintiff’s allegations regarding his purported class action claims." Apparently based on that statement, this Court stated at page 2 of its September 3, 1999 Memorandum in support of its Order: "If the case were not to be transferred, leave to amend would be denied in any event because the proposed amended complaint is not the "short and plain statement of [plaintiff’s] claim" required by F.R.Civ.P. 8(a) but a long amalgamation of factual assertions and arguments. It more of a brief than a complaint."

34. However, GAO’s statement is factually wrong and this Court erred in relying on it because an objective review of Diersen’s amended complaints shows that they are not unreasonably long or complicated and that they contain, pursuant to F.R.Civ.P. 8(a), a short and plain statement of the grounds upon which this court’s jurisdiction depends, statements of Diersen’s class action and individual claims that are not unreasonably long or complex and show that he and the class he seeks to represent are entitled to relief, and a demand for judgment for relief sought. The admittedly long recitation of facts demonstrates only that many, many instances of blatant discrimination took place. GAO’s misdeeds over that long period of time may be subject to summarization, as Diersen has done in his accompanying Third Amended Complaint. But it can not be said as to each allegation that it standing alone is not a short and plain statement of the facts upon which relief could be granted. In fact, the problem in drafting is that while individual instances of discrimination and retaliation are each simple, there are just a lot of them, causing the complaint as drafted to be very long.

35. The format of Diersen’s complaints is not the one used for briefs and his complaints do not contain amalgamations of factual assertions and arguments and even if they did, F.R.Civ.P. (8)(a) does not require plaintiffs to present their factual assertions under one heading and their arguments under another.

36. Diersen’s complaints can only be shortened by providing less detail on his individual claims. Therefore, Diersen’s amended complaints comply with F.R.Civ.P. 8(a).

37. Nevertheless, contemporaneously with his motion to alter or amend judgment, Diersen has filed a third motion for leave to amend his complaint. It is an attempt to comply with GAO’s and this Court’s admonition that the first and second amended complains were too long and complex.

38. Diersen’s third amended complaint contains far less detail concerning his individual claims and is therefore only 28 pages long instead of 54. It is respectfully submitted that this third amended complaint complies with F.R.Civ.P. 8(a) and that along with the arguments contained in this statement of points and authorities, all the technical format and presentation issues cited at page 2 of this Court’s September 3, 1999 Memorandum in support of its Order have been addressed and solved.

Diersen Has a Right to Amend His Complaint

39. Under F.R.Civ.P. 15(a), plaintiffs may amend their complaint once as a matter of right at any time before the defendant files a responsive pleading.

40. A motion to dismiss is not a responsive pleading. Duda v. Franklin Park Pub. Sch. Dist. 84, 133 F.3d 1054, 1056-1057 n.2 (7^th Cir. 1998) and Barbara v. New York Stock Exch., Inc., 99 F.3d 49 (2d Cir. 1996) and Brever v. Rockwell Int’l Corp., 40 F.3d 1119 (10^th Cir. 1994).

41. Therefore, because GAO has not yet filed a responsive pleading, Diersen has a right to amend his original complaint.

Respectfully submitted,

Walter T. Charlton
D.C. Bar No. 186940
230 Kirkley Road
Annapolis, Maryland, 21401
Phone: 410-571-8764
Fax: 410-897-0471
Email:
charltonwt@aol.com

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