Stephen Klapach v. Board of Education of the Borough of Fort Lee, Bergen County, 4/6/2021, (#79-21)

79-21
New Jersey Commissioner of Education
Decision
Stephen Klapach,
Petitioner,
v.
Board of Education of the Borough of
Fort Lee, Bergen County,
Respondent.
Synopsis
Petitioner, a science teacher in the respondent Board’s school district, appealed the Board’s decision to
affirm the results of a harassment, intimidation, and bullying (HIB) investigation into petitioner’s
conduct. The HIB investigation concluded that the petitioner committed an act of HIB against a student
when he read a confidential email from the student’s parent to pupils in another of his classes. The Board
affirmed the findings of the investigation, which stemmed from discipline the petitioner had threatened to
impose upon three students after they allegedly misbehaved during a lesson with a substitute teacher. The
parties filed cross motions for summary decision.
The ALJ found, inter alia, that: 	there are no material facts at issue here, and the matter is ripe for
summary decision; 	the issue for determination in this case is whether the petitioner’s reading of the
confidential email in front of a classroom of students was reasonably perceived as being motivated either
by any actual or perceived characteristic of student J.W.; Fort Lee’s HIB policy is substantially similar
to N.J.S.A. 18A:37-14; 	the Board’s letter to petitioner informing him that the HIB charge had been
sustained failed to state how his reading of L.C.’s email was motivated by an actual or perceived
characteristic of J.W.; and the Board’s argument that petitioner’s status as a teacher created an imbalance
of power which was the perceived characteristic is without merit. 	The ALJ concluded that power
imbalance is not a perceived or actual characteristic defined in Fort Lee’s HIB policy, nor in the relevant
statutes and regulations; the Board failed to establish that there was an act of HIB motivated by an actual
or perceived characteristic; and the Board’s sustaining of HIB charges against petitioner was therefore
arbitrary and unreasonable. 	Accordingly, the ALJ granted summary decision in favor of the petitioner
and denied the Board’s cross motion.
Upon comprehensive review, the Commissioner agreed with the ALJ findings and conclusion, affirmed the Initial
Decision of the OAL, reversed the Board’s determination that the petitioner committed an act of HIB, and directed
the Board to remove any reference to the HIB investigation and findings from the petitioner’s personnel file. In so
doing, the Commissioner noted that if the incident reported herein is included in petitioner’s personnel file for other
reasons, such as violations of Board policies other than its HIB policy, this decision does not extend to those
references, as the only issue presently before the Commissioner is the HIB finding. The Commissioner further noted
that she in no way condones petitioner’s conduct discussed herein. Teachers are placed in a position of trust by the
Board and the community. Petitioner in this matter demonstrated extremely poor judgment in singling out J.W. in
front of other students and sharing information from an email written by J.W.’s mother that should have remained
confidential.
This synopsis is not part of the Commissioner’s decision. It has been prepared for the convenience of the reader. It
has been neither reviewed nor approved by the Commissioner.
April 6, 2021

OAL Dkt. No. EDU 5069-20
Agency Dkt. No. 79-4/20
New Jersey Commissioner of Education
Decision
Stephen Klapach,
Petitioner,
v.
Board of Education of the Borough of
Fort Lee, Bergen County,
Respondent.
The record of this matter, the Initial Decision of the Office of Administrative Law
(OAL), the exceptions filed by both parties pursuant to N.J.A.C. 1:1-18.4, and petitioner’s reply to
respondent’s exceptions1 have been reviewed.
This matter concerns an alleged act of harassment, intimidation, and bullying
(HIB) by petitioner, a science teacher employed by the Fort Lee Board of Education (Board).
Following his absence from school on October 18, 2019, petitioner received a note from the
substitute teacher indicating that three students in his seventh period class had not behaved well.
On October 21, 2019, the next school day, petitioner informed these students that he might
decrease their class participation grades as a result. 	That night, J.W.’s mother, L.C., emailed
petitioner, stating that the substitute teacher was misinformed about J.W.’s behavior. 	The
following morning, petitioner read L.C.’s email aloud to his first period class, and one of the
students in that class informed J.W., who became nervous about going to class and asked her
mother to pick her up from school. 	J.W. was switched to another science class, and an HIB
1 Respondent did not file a reply to petitioner’s exceptions.

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investigation was opened against petitioner. 	The Board found that petitioner had committed an
act of HIB. Petitioner appealed, and the parties filed cross motions for summary decision. The
Administrative Law Judge concluded that the Board’s decision was arbitrary and unreasonable
because it did not establish an HIB act motivated by an actual or perceived characteristic. 	The
ALJ found that the power imbalance between a teacher and a student is not an actual or
perceived characteristic listed in the Board’s HIB policy, or the applicable statute or regulations.
In its exceptions, the Board argues that N.J.A.C. 6A:16-7.7(a)(2)(iii) provides that
bullying is 	“unwanted 	aggressive behavior that may involve a real 	or perceived power
imbalance,”2 and that the Board properly considered the power imbalance between a teacher and
a student – an imbalance that exists because of the very nature of the relationship – in reaching
its conclusion that petitioner committed an act of HIB. 	The Board cites to precedents
establishing that distinguishing characteristics are not limited to those enumerated in the statute,
which applies to a broad range of characteristics. According to the Board, the power differential
is a method of distinguishing the motivating characteristics of the aggressor, relative to a
perceived status of power – or lack thereof – of the victim. 	The Board contends that a teacher
abuses his power over students when he uses the imbalance to disrupt the student’s learning
environment. 	The Board argues that petitioner’s conduct was motivated by J.W.’s challenge to
his authority – an action that distinguished her.
In reply, petitioner argues that the regulatory addition of language indicating that
bullying may involve a power imbalance does not eliminate or replace the statutory requirement
that an act of HIB be motivated by a distinguishing characteristic of the student. 	Petitioner
2 Throughout its summary decision briefs and exceptions, the Board refers to this language as part of a 2018
amendment to the Anti-Bullying Bill of Rights Act. However, this language does not appear in the Act, but rather in
the Department of Education’s implementing regulations, in a provision outlining the required elements of district
HIB policies.

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therefore urges the Commissioner to accept the ALJ’s conclusion that the Board failed to set
forth any distinguishing characteristic, as required by the Act.
Petitioner also filed exceptions of his own, asking the Commissioner to not only
affirm the Initial Decision and reverse the Board’s decision, but also to rescind and expunge any
reference to the HIB investigation and decision from petitioner’s personnel file.
Initially, the Commissioner agrees with the ALJ that summary disposition is
appropriate. 	Upon review, the Commissioner also concurs with the ALJ that the Board’s
decision, finding that petitioner committed an act of HIB, was arbitrary, capricious, and
unreasonable because it did not establish any distinguishing characteristic of the alleged victim
that motivated, or could reasonably be perceived to have motivated, the petitioner’s conduct.3
The Anti-Bullying Bill of Rights Act (the Act) defines HIB as follows:
[A]ny gesture, any written, verbal or physical act, or any electronic
communication, whether it be a single incident or a series of
incidents, that is reasonably perceived as being motivated either by
any actual or perceived characteristic, such as race, color, religion,
ancestry, 	national 	origin, 	gender, 	sexual 	orientation, 	gender
identity and expression, or a mental, physical or sensory disability,
or by any other distinguishing characteristic, that takes place on
school property, at any school-sponsored function, on a school bus,
or off school grounds as provided for in section 16 of P.L. 2010,
c.122 (C.18A:37-15.3), that substantially disrupts or interferes with
the orderly operation of the school or the rights of other students
and that:
a. a reasonable person should know, under the circumstances,
will have the effect of physically or emotionally harming a student
or 	damaging 	the 	student's 	property, 	or 	placing 	a 	student 	in
reasonable fear of physical or emotional harm to his person or
damage to his property;
b. has the effect of insulting or demeaning any student or group
of students; or
3 Although the Commissioner concludes that the Board’s decision must be reversed, the Commissioner in no way
condones petitioner’s conduct, or minimizes J.W.’s feelings regarding the incident. 	Teachers are placed in a
position of trust by the Board and the community. Petitioner demonstrated extremely poor judgment in singling out
J.W. in front of other students and sharing information from an email written by her mother that should have
remained confidential.

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c. creates a hostile educational environment for the student by
interfering with a student's education or by severely or pervasively
causing physical or emotional harm to the student.
N.J.S.A. 18A:37-14.
Therefore, a finding of HIB requires three elements.4 	First, the conduct must be reasonably
perceived as being motivated by any actual or perceived enumerated characteristic or other
distinguishing characteristic and, second, the conduct must substantially disrupt or interfere with
the rights of other students or the orderly operation of the school. The third condition is that one
of the three criteria enumerated in the Act regarding the effect of the conduct must also be
satisfied. Wehbeh v. Bd. of Educ. of the Twp. of Verona, Essex County, Commissioner Decision
No. 51-20 (decided February 4, 2020).
Beginning with the first element required by the Act – that the conduct be
reasonably perceived as being motivated by a distinguishing characteristic – the Act “has not
limited ‘distinguishing characteristic’ to those specifically enumerated, but it has consistently
required such a perceived motivation.” K.L. v. Evesham Twp. Bd. of Educ., 423 N.J. Super. 337,
351 (App. Div. 2011). 	While HIB can be found based on a broad range of distinguishing
characteristics, the Commissioner finds that the power imbalance inherent in the relationship
between a teacher and a student cannot, by itself, be a distinguishing characteristic sufficient to
prove an act of HIB. Because only students can be the victims of HIB under the Act, status as a
student cannot be sufficient to substantiate an HIB finding, or there would be no reason to
include an additional requirement that the conduct be reasonably perceived as being motivated
by a distinguishing characteristic. See J.E. and R.E. v. Hunterdon Central Regional Bd. of Educ.,
OAL Dkt. No. EDU 188-14 (Initial Decision, Sept. 28, 2017), aff’d, Commissioner Decision No.
4 The statute also requires that the conduct take place on school property, at a school-sponsored function, on a school
bus, or off school grounds as provided for in N.J.S.A. 18A:37-15.3. The parties do not contest that this requirement
has been met in this matter.

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366-17 (decided Dec. 21, 2017) (finding, among other things, that a baseball coach’s comments
did not constitute HIB because the alleged target’s status as a student was not a sufficient
distinguishing characteristic to support such a finding).
When the Department of Education updated its HIB regulations in 2018, it added
a requirement that district HIB policies include a statement that “bullying is unwanted,
aggressive behavior that may involve a real or perceived power imbalance.” 	N.J.A.C. 6A:16-
7.7(a)(2)(iii). In response to public comments regarding the inclusion of power imbalance in the
rule, the Department stated, “The intent of the proposed rule is to assist school officials in
identifying HIB within the context and relative positions of the alleged aggressor and target,
rather than focusing solely on the real or perceived characteristics.” (emphasis added). 50 N.J.R.
155(b) (2018). The Department also noted that, for an incident to be deemed HIB, it must fulfill
the criteria at N.J.A.C. 6A:16-3, which mimics the criteria of the Act set forth above and includes
that the act be reasonably perceived as being motivated by a distinguishing characteristic. Ibid.
Notably, the Department further stated, “The mere existence of a real or perceived power
imbalance without fulfilment of the other criteria is insufficient to find an incident of HIB.” Ibid.
It is clear from the Department’s statements that a power imbalance can be a consideration in
HIB determinations, but it cannot be the sole basis for a finding of HIB, and all other criteria,
including the existence 	of 	a distinguishing characteristic of 	the alleged 	target, 	must 	be
established.
Nor does the Commissioner find that J.W.’s “challenge” to petitioner’s authority
distinguished her in the manner required by the Act. The series of events at issue here – alleged
misbehavior 	by 	J.W. 	with 	the 	substitute 	teacher, 	petitioner’s 	remarks 	about 	decreasing
participation grades, L.C.’s email in response, and petitioner’s in-class reading of and response
to that email – are in the nature of a conflict, not bullying. As the Appellate Division has noted,

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“harmful or demeaning conduct motivated only by another reason [other than a distinguishing
characteristic], for example, a dispute about relationships or personal belongings, or aggressive
conduct without identifiable motivation, does not come within the statutory definition of
bullying.” K.L. supra, 423 N.J. Super. at 351.
This matter is substantially similar to M.R., o/b/o minor child, M.R. v. Bd. of
Educ. of the Ramapo Indian Hills Regional High School District, Bergen Cty., Commissioner
Decision No. 426-16 (decided Dec. 21, 2016). In that case, M.R. texted her cheerleading coach
to inform him that she could not attend a basketball game due to other plans, and the coach
responded that she was off the team. During a game after M.R. returned to the team, the coach
told the team that he wanted his conversations with them kept private and not reported to parents.
M.R. felt that she was being targeted and that the team was a hostile environment. In that case,
the Board found, and the ALJ and Commissioner affirmed, that the coach did not commit an act
of HIB because his actions were not motivated by a distinguishing characteristic of M.R. While
the M.R. decision predates the addition of the “power imbalance” language to the Department’s
regulations, that language does not alter the requirements of the Act, for the reasons stated above,
and does not warrant a different outcome in this matter. 	Here, petitioner’s authority status was
similar to that of the coach in M.R., and he engaged in similar conduct, including imposing a
consequence for misbehavior and discussing the issue with other students. 	Here, too, there is no
evidence that petitioner’s conduct could reasonably be perceived as being motivated by a
distinguishing characteristic of J.W., and so he has not committed an act of HIB. 5
5 The Initial Decision, as well as the parties’ arguments, focused on whether petitioner’s conduct was actually
motivated by any distinguishing characteristic of J.W. 	However, the plain language of the statute requires an
analysis of how the actor’s motivation is perceived and whether that perception is reasonable. It does not require an
analysis of the actual motivation of the actor. Wehbeh, supra. Certainly, evidence that the actor was motivated by a
distinguishing characteristic would meet the standard of this section of the Act, but evidence that the actor was not
so motivated does not end the analysis. Here, because the Board failed to establish any distinguishing characteristic,
the Commissioner does not reach the issue of reasonable perception and raises it solely for the purposes of clarifying

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The Commissioner is mindful of the applicable standard of review, such that
when a local board of education acts within its discretionary authority, its decision is entitled to a
presumption of correctness and will not be disturbed unless there is an affirmative showing that
the decision was “patently arbitrary, without rational basis or induced by improper motives.”
Kopera v. W. Orange Bd. of Educ., 60 N.J. Super. 288, 294 (App. Div. 1960). However, because
the Board has not provided any evidence of a distinguishing characteristic of J.W, which is
required by the Act, the Commissioner concludes that the Board’s decision finding that petitioner
committed an act of HIB was arbitrary and unreasonable.
Accordingly, the Initial Decision is affirmed, and the Board’s determination that
petitioner committed an act of HIB is reversed. 	The Board shall remove any references to the
HIB investigation and findings from petitioner’s personnel file.6
IT IS SO ORDERED. 7
ACTING COMMISSIONER OF EDUCATION
Date of Decision: 	April 6, 2021
Date of Mailing: 	April 9, 2021
the criteria of the Act. Similarly, the Commissioner does not reach the issues of the second and third elements
required to prove an act of HIB.
6 However, if the incident is included in petitioner’s personnel file for other reasons, such as violations of Board
policies other than its HIB policy, this decision does not extend to those references, as the only issue before the
Commissioner is the HIB finding.
7 This decision may be appealed to the Appellate Division of the Superior Court pursuant to N.J.S.A. 18A:6-9.1.
Under N.J.Ct.R. 2:4-1(b), a notice of appeal must be filed with the Appellate Division within 45 days from the date
of mailing of this decision.

State of New Jersey
OFFICE OF ADMINISTRATIVE LAW
INITIAL DECISION
SUMMARY DECISION
OAL DKT. NO. EDU 5069-20
AGENCY DKT. NO. 79-4/20
STEPHEN KLAPACH,
Petitioner,
v.
FORT LEE BOARD OF EDUCATION,
Respondent.
__________________________________
Albert J. Leonardo, Esq. for Petitioner (Zazzali, Fagella, Nowack, Klienbaum
& Friedman, Attorneys)
Raina Pitts, Esq., for Respondent, (Methfessel & Werbel, Attorneys)
Record Closed: February 3, 2021 	Decided: February 19, 2021
BEFORE KIMBERLY A. MOSS, ALJ:
This mater having been opened to the Court by respondent, Fort Lee Board of
Education 	(Fort 	Lee) 	and 	petitioner 	Stephen 	Klapach 	(Klapach) 	on 	a 	motion 	for
summary decision on February 1, 2021. 	Respondent filed opposition to petitioner’s
motion on February 16, 2021. 	Petitioner filed a reply to the respondent’s motion on
February 16, 2021. 	By way of background, the petition was filed at the Office of
Administrative Law on June 2, 2020.

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FACTUAL DISCUSSION
Having reviewed submissions in support of and opposition to the within motion, I
FIND the following FACTS in this case.
Klapach is a science teacher at the Lewis F. Cole school in Fort Lee, New
Jersey. He was absent from school on October 18, 2019. A substitute teacher handled
his class on that day. 	Klapach was informed by the substitute teacher that his seventh
period class did not behave well. 	He was informed that three students including J.W.
were playing music from their computers during class, talking during class and ignoring
directives to turn off the music. 	On October 21, 2019, Klapach told the three students
that he was informed that they had misbehaved, and he may be decreasing their class
participation grade. 	That night J.W. informed her mother, L.C. about the decreased
class participation grade. 	L.C. emailed Klapach on October 21, 2019, stating that the
substitute teacher was misinformed about J.W.’s behavior.
On October 22, 2019, in Klapach’s first period class, he read the email L.C sent
him to the class. 	J.W. was not in that class. 	J.W. was informed by a student that
Klapach had read her mother’s email to the class. J.W. became nervous about going to
class and asked L.C. to pick her up. 	L.C. spoke to the vice principal Joseph Finizio
about the incident. J.W. was switched to a different science class.
On October 23, 2019 an HIB investigation was opened against Klapach. 	The
Board 	concluded 	that 	Klapach 	had 	committed 	the 	following 	act 	of 	harassment,
intimidation and bullying: “Student fearful to return to class, reading confidential email
aloud to other students.

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LEGAL ANALYSIS AND CONCLUSION
Respondent and petitioner seek to summary decision. 	The rules governing
motions for summary decision in an OAL matter are embodied N.J.A.C. 1:1-12.5.
These provisions mirror the language of Rule 4:46-2 and the New Jersey Supreme
Court’s decision in Judson v. Peoples Bank and Trust Company of Westfield, 17 N.J. 67
(1954). 	Under N.J.A.C. 1:1-12.5(b), the determination to grant summary judgment
should be based on the papers presented as well as any affidavits, which may have
been filed with the application. 	In order for the adverse, i.e., the non-moving party to
prevail in such an application, responding affidavits must be submitted showing that
there is indeed a genuine issue of fact, which can only be determined in an evidentiary
proceeding. 	The Court in Brill v. Guardian Life Insurance Company of America, 142
N.J. 520, 523 (1995), set the standard to be applied when deciding a motion for
summary judgment. Therein the Court stated:
The determination whether there exists a genuine issue with respect to a material
fact challenged requires the Motion Judge to consider whether the competent evidential
materials presented, when viewed in the light most favorable to the non-moving party . .
. are sufficient to permit a rational fact finder to resolve the alleged disputed issue in
favor of the non-moving party.
There is no genuine issue of material fact in this matter.
N.J.S.A. 18A 37-14 defined Harassment intimidation and bullying as:
Harassment, intimidation or bullying” means any gesture, any written,
verbal or physical act, or any electronic communication, whether it be a
single incident or a series of incidents, that is reasonably perceived as
being motivated either by any actual or perceived characteristic, such as
race, color, religion, ancestry, national origin, gender, sexual orientation,
gender identity and expression, or a mental, physical or sensory disability,
or by any other distinguishing characteristic, that takes place on school
property, at any school-sponsored function, on a school bus, or off school
grounds as provided for in section 16 of P.L.2010, c.122 (C.18A:37-15.3),

4
that substantially disrupts or interferes with the orderly operation of the
school or the rights of other students and that:
a. a reasonable person should know, under the circumstances, will have
the effect of physically or emotionally harming a student or damaging the
student’s property, or placing a student in reasonable fear of physical or
emotional harm to his person or damage to his property;
b. has the effect of insulting or demeaning any student or group of
students; or
c. creates a hostile educational environment for the student by interfering
with a student’s education or by severely or pervasively causing physical
or emotional harm to the student.
N.J.A.C. 6A; 16-7.7(a) (i) (ii) & (iii) provides
Each district board of education shall have control over the content of the
policy, except that the policy shall contain, at a minimum, the following
components:
i. A statement prohibiting harassment, intimidation or bullying of a student;
ii. A definition of harassment, intimidation or bullying no less inclusive than
that set forth in the definition at N.J.S.A. 18A:37-14 and N.J.A.C. 6A:16-
1.3;
iii. A statement that bullying is unwanted, aggressive behavior that may
involve a real or perceived power imbalance.
Fort Lee defines Harassment, Intimidation and bullying as:
Harassment, Intimidation and bullying means any unwanted aggressive
gesture, written, verbal or physical act or any electronic communication,
as defined in N.J.S.A. 18A: 37-14, whether it be a single incident or series
of incidents that may involve a real or perceived imbalance of power and:
1. 	Is reasonably perceived as being motivated either by any actual or
perceived characteristic, such as race, color, religion, ancestry, national
origin, gender, sexual orientation, gender identity and expression, or a
mental, physical or sensory disability, or by any other distinguishing
characteristic
2. 	Takes place on school property, at any school-sponsored function, on a
school bus, or off school grounds as provided for in N.J.S.A.18A:37-15.3,
3. 	Substantially disrupts or interferes with the orderly operation of the school
or the rights of other students and that:
a reasonable person should know, under the circumstances, will have the
effect of physically or emotionally harming a student or damaging the
student’s property, or placing a student in reasonable fear of physical or
emotional harm to his/her person or damage to his/her property;

5
b. Has the effect of insulting or demeaning any student or group of
students; or
c. creates a hostile educational environment for the student by interfering
with a student’s education or by severely or pervasively causing physical
or emotional harm to the student.
In this matter, the issue is whether Klapach reading the email of L.C. was
reasonably 	perceived 	as 	being 	motivated 	either 	by 	any 	actual 	or 	perceived
characteristic of J.W. 	The Fort Lee HIB policy is substantially similar to N.J.S.A. 18A
37-14. 	Respondent in its letter to Klapach to informing him that the HIB charges were
sustained did not state how Klapach’s conduct of reading the email of L.C. was
motivated by an actual or perceived characteristic of J.W. Fort Lee argues the fact that
Klapach was a teacher and therefore there was an imbalance of power is the perceived
characteristic. 	It bases this argument on the imbalance of power between teacher and
student. 	However, the Fort Lee policy, N.J.S.A. 18A:37-14 and N.J.A.C. 6A; 16-7.7( a)
(i) (ii) & (iii) do not include a power imbalance as an actual or perceived characteristic. It
is to be considered regarding the incident or series of incidents.
I CONCLUDE that power imbalance is not a perceived or actual characteristic as
defined in the Fort Lee policy, N.J.S.A. 18A:37-14 and N.J.A.C. 6A; 16-7.7(a) (i) (ii) &
(iii).
In order to establish an act of HIB there must be an incident motivated by an
actual or perceived characteristic. 	The reading of the letter was not motivated by a
perceived or actual characteristic. 	Fort Lee did not establish that there was an act of
HIB motivated by an actual or perceived characteristic.
I CONCLUDE that Fort Lee’s sustaining HIB charges against Klapach was
arbitrary and unreasonable because it did not establish an HIB act motivated by an
actual or perceived characteristic.
Based on the foregoing, the Board’s determination that Klapach had committed
acts of harassment, intimidation and bullying by reading a letter must be REVERSED.

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Accordingly, 	it 	is 	ORDERED 	that 	the 	Summary 	Decision 	motion 	of 	petitioner 	is
GRANTED, and the Summary Decision of respondent be and is hereby DENIED.
I 	hereby 	FILE 	this 	initial 	decision 	with 	the 	COMMISSIONER 	OF 	THE
DEPARTMENT OF EDUCATION for consideration.
This 	recommended 	decision 	may 	be 	adopted, 	modified 	or 	rejected 	by 	the
COMMISSIONER OF THE DEPARTMENT OF EDUCATION, who by law is authorized
to make a final decision in this matter. 	If the Commissioner of the Department of
Education does not adopt, modify or reject this decision within forty-five days and unless
such time limit is otherwise extended, this recommended decision shall become a final
decision in accordance with N.J.S.A. 52:14B-10.
Within thirteen days from the date on which this recommended decision was
mailed to the parties, any party may file written exceptions with the COMMISSIONER
OF THE DEPARTMENT OF EDUCATION, ATTN: 	BUREAU OF CONTROVERSIES
AND DISPUTES, 100 Riverview Plaza, 4th Floor, PO Box 500, Trenton, New Jersey
08625-0500, marked “Attention: Exceptions.” A copy of any exceptions must be sent to
the judge and to the other parties.
February 19, 2021
DATE 	KIMBERLY A. MOSS, ALJ
Date Received at Agency: 	February 19, 2021
Date Mailed to Parties: 	February 19, 2021
ljb