* Verduzco v. King County

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IN THE SUPREME COURT OF THE STATE OF WASHINGTON
REYNALDO S. VERDUZCO, 	) 	No. 103749-0
)
Petitioner, 	)
)
v. 	) 	EN BANC
)
KING COUNTY, WASHINGTON, 	)
) 	Filed: June 11, 2026
Respondent. 	)
______________________________ )
MONTOYA-LEWIS, J.—An employee sued an employer for employment
discrimination 	and 	retaliation 	in 	violation 	of 	the 	Washington 	Law 	Against
Discrimination (WLAD). RCW 49.60.030(1)(a), .210(1). Both claims require proof
the employer took an adverse employment action. Although neither the legislature
nor this court has defined an “adverse employment action,” the Washington Pattern
Jury Instructions (WPI) Committee offers pattern instructions defining the term for
each of those claims. In this case, the trial court issued a jury instruction that
combined both WPI definitions. The jury found the employer did not discriminate
but did retaliate against the employee, and the employer appealed.
The narrow question presented is whether the jury instruction was misleading.
FILE
IN CLERK’S OFFICE
SUPREME COURT, STATE OF WASHINGTON
JUNE 11, 2026
THIS OPINION WAS FILED
FOR RECORD AT 8 A.M. ON
JUNE 11, 2026
SARAH R. PENDLETON
SUPREME COURT CLERK
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We are not asked whether the WPI definitions state the correct legal standard; the
parties assume they do and dispute only whether the court erred by combining those
pattern definitions. While the instruction was misleading, the employer fails to
demonstrate reversible error because it did not prejudice the employer. We reverse
and remand to the Court of Appeals for further proceedings consistent with this
decision.
FACTUAL BACKGROUND
Reynaldo Verduzco has worked for King County Department of Natural
Resources and Parks (DNRP) since 1992. In 2018, he was promoted to program
manager for the DNRP hazardous waste management program. Verduzco is Latino,
and he uses hearing aids.1
The events relating to this retaliation claim began when Verduzco raised a
concern about bias in a hiring policy. According to Verduzco, his section manager
responded by yelling and berating him for delaying the hiring process. Verduzco
was stunned and embarrassed: he felt he was being treated like he was “dumb” and
1 	While 	the 	text 	of 	the 	WLAD 	references 	race 	discrimination, 	no 	one 	disputes
it 	also 	protects 	against 	discrimination 	based 	on 	ethnicity. 	See, 	e.g., 	State 	v. 	Zamora,
199 Wn.2d 698, 704 n.6, 512 P.3d 512 (2022) (recognizing that “while ‘Hispanic’ or ‘Latinx’
identifies a person’s ethnicity and not their race, the language of race when discussing
these 	principles 	[of 	discriminatory 	misconduct] 	includes 	Hispanic 	and 	Latinx 	persons”
(citing Peña-Rodriguez v. Colorado, 580 U.S. 206, 214, 137 S. Ct. 855, 197 L. Ed. 2d 107 (2017);
About 	the 	Hispanic 	Population 	and 	its 	Origin, 	U.S. 	C ENSUS 	B UREAU,
https://www.census.gov/topics/population/hispanic-origin/about.html 	[https://perma.cc/435J-
8PVB])). Verduzco described himself as Latino, Mexican, and a Person of Color. This opinion
uses the terms “race” and “ethnicity” to encompass those identities.
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“stupid” and his hiring decisions were not being taken seriously because he is
Mexican. 12 Verbatim Rep. of Proc. (VRP) at 1461-62.
Verduzco documented that interaction in several e-mails to human resources,
DNRP leadership, and members of the People of Color affinity group. He reported
that the section manager was retaliating against him for raising concerns about bias
and described her behavior as abusive and part of a pattern of racism at DNRP.
Human resources investigated this incident and concluded there had been no
discrimination directed at Verduzco because of his race or ethnicity. They told
Verduzco he should bring forward any concerns about discrimination or retaliation
but warned him about his approach and the tone and quantity of his e-mails.
Accordingly, Verduzco received a letter of expectations from his supervisor,
directing him to act professionally and follow workplace values of fairness and
respect. The letter also warned that continued behavior could lead to progressive
discipline up to and including termination.
Several tense meetings took place over the next few months. First, when
leading his team meeting, Verduzco shared news about a recent mass shooting in
El Paso, Texas. His hazardous waste management team worked closely with Latine-
owned businesses in King County, and Verduzco wanted his team to be aware of the
shooting—which targeted a Latine community, killing more than 20 people—and
how it may be affecting the community they serve. Verduzco noticed that some
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people left that meeting upset.
A colleague from a different team heard about those negative responses and
appeared at Verduzco’s next team meeting, wanting to attend. Verduzco was
surprised and upset by this because he expected that colleague to speak with him
directly before attending one of his team meetings. As a program manager, Verduzco
felt undermined in his professional role because he felt, as a Latino in a position of
authority, he was being monitored for having an emotional discussion about a racial
equity matter with his team. Verduzco brought these concerns to his supervisor,
Charles Wu. According to Wu, Verduzco became very angry and yelled. Verduzco
said that although the discussion was tense, he did not yell.
The 	next 	day, 	Verduzco 	and 	Wu 	attended 	a 	race 	equity 	conference
for government employees. When asked to discuss barriers to a successful antiracist
workplace, Verduzco said management was not supportive of addressing racism.
There 	was 	significant 	ambient 	noise 	in 	the 	room—an 	echoing 	gymnasium
with many people in groups speaking at once—and Verduzco spoke loudly.
He 	also 	used 	profanity. 	According 	to 	Wu, 	Verduzco 	yelled 	at 	him 	and
expressly 	named 	several 	DNRP 	leaders 	as 	holding 	back 	equity 	work 	and
perpetuating 	racism 	at 	their 	workplace. 	Verduzco 	said 	he 	never 	yelled 	or
directed his comments at anyone. When they returned from the conference,
Wu informed Verduzco there would be an investigation into his conduct, and,
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if 	his 	behavior 	continued, 	he 	would 	“be 	asked 	to 	leave 	the 	building.”
Clerk’s Papers (CP) at 2315.
Verduzco then received a parking ticket at the DNRP building parking lot.
He e-mailed Wu to report this because he felt he had been targeted for the ticket
due to his race and ethnicity. Wu issued Verduzco another letter of expectations
regarding 	his 	use 	of 	county 	e-mail 	to 	“accuse” 	the 	parking 	attendant 	of
racist behavior. 	Id. 	at 	2306-07. 	The 	letter 	directed 	Verduzco 	to 	address
personal issues via private e-mail and again warned that further incidents could lead
to discipline and termination.
Around the same time, Verduzco received a substandard performance review
for the first time. The performance review cited his “inappropriate use of county
e-mail.” 12 VRP at 1455.
The county placed Verduzco on administrative leave with no definite end date.
Verduzco was paid, but he was not permitted in the DNRP offices, the door codes
to access the building were changed, and investigations into his conduct and
complaints continued. This went on for five months. Ultimately, the county
decided to issue a five day suspension without pay as a consequence for Verduzco’s
“inappropriate” e-mails and behavior. CP at 1679.
After five months’ administrative leave and five days’ unpaid suspension,
Verduzco was permitted to return to work. He was placed in a different role
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at DNRP upon his return. Though his job classification and pay did not change, he
had less responsibility, and so the reassignment felt like a demotion. Together,
the 	investigations, 	administrative 	leave, 	suspension, 	and 	reassignment 	made
Verduzco feel humiliated, anxious, and silenced.
PROCEDURAL HISTORY
Verduzco sued the county, bringing claims of discrimination based on
race, ethnicity, and disability, and 	a claim of retaliation under the WLAD.
The parties proceeded to a jury trial where the jury was instructed as to all claims.
The 	WPI 	offers 	pattern 	jury 	instructions 	for 	both 	retaliation 	and
discrimination 	claims 	under 	the 	WLAD. 	The 	pattern 	instructions 	suggest
different definitions of an “adverse employment action” for each cause of action.
In the WPI “retaliation” section, the definitional instruction states:
The term “adverse” means unfavorable or disadvantageous. An
employment action is adverse if it is harmful to the point that it would
dissuade 	a 	reasonable 	employee 	from 	making 	a 	complaint 	of
[discrimination] 	[harassment] 	[and] 	[or] 	[retaliation]. 	Whether 	a
particular action is adverse is judged from the perspective of a
reasonable person in the plaintiff’s position.
6A WASHINGTON PRACTICE: WASHINGTON PATTERN J URY I NSTRUCTIONS: CIVIL
330.06, at 250 (7th ed. Supp. 2022) (alterations in original).
For a discrimination claim, the WPI suggests, “An adverse employment action
is one that materially affects the terms, conditions or privileges of employment.”
WPI 330.01.02, at 234.
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Verduzco proposed one instruction that recited both definitions from the WPI:
The term “adverse” means unfavorable or disadvantageous. An
employment action is adverse if it is harmful to the point that it would
dissuade 	a 	reasonable 	employee 	from 	making 	a 	complaint 	of
discrimination. Whether a particular action is adverse is judged from
the perspective of a reasonable person in the Mr. Verduzco’s position.
An adverse employment action is one that materially affects the terms,
conditions, or privileges of employment.
CP at 2542. The county opposed this instruction, arguing the jury “would be
confused 	by 	this 	[instruction] 	and 	apply 	it 	both 	to 	the 	discrimination 	and
retaliation cases.” 15 VRP at 1999. The court rejected this argument, concluding
Verduzco’s proposed instruction did not cause confusion or prevent the county
from 	arguing 	its 	case. 	The 	court 	accepted 	Verduzco’s 	proposed 	instruction
as instruction 8.
In closing arguments, Verduzco contended the county took numerous adverse
actions 	against 	him: 	multiple 	investigations, 	administrative 	leave, 	suspension
without pay, and effective demotion. The county, on the other hand, argued the only
adverse action was the unpaid suspension. 18 VRP at 2500. It asserted both the
discrimination claims and the retaliation claim should fail anyway because the
county suspended Verduzco for his “unprofessional conduct,” rather than his race,
ethnicity, disability, or reasonable opposition to discrimination. Id. at 2509-11.
The jury found the county did not discriminate against Verduzco based on his
race, ethnicity, or disability. But it found the county did retaliate against him.
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The 	county 	appealed, 	assigning 	error 	to 	instruction 	8 	and 	several
other independent issues. Specifically, it raised the issue of whether the instruction
was 	likely 	to 	confuse 	or 	mislead 	the 	jury 	regarding 	the 	retaliation 	claim.
Verduzco cross-appealed regarding the calculation of attorney fees.
The Court of Appeals reversed. Verduzco v. King County, No. 57052-1-II,
slip op. 	at 	1 	(Wash. 	Ct. 	App. 	July 	30, 	2024) 	(unpublished).2 It 	concluded
that instruction 8 was erroneous and reversed and remanded the retaliation claim
for a new trial. Id. at 27. The court declined to reach the remaining issues raised by
the parties on appeal. Id. at 1. We granted review. 4 Wn.3d 1015 (2025).
ANALYSIS
The 	WLAD 	recognizes 	a 	civil 	right 	to 	be 	free 	from 	discrimination.
RCW 49.60.030(1). 	This 	civil 	right 	encompasses 	the 	right 	to 	obtain 	and
hold employment without discrimination relating to protected statuses, such as race,
ethnicity, or disability. RCW 49.60.030(1)(a), .010. It also prohibits employers
from 	retaliating 	against 	someone 	who 	opposes 	acts 	of 	discrimination.
RCW 49.60.210(1).
Only Verduzco’s retaliation claim is at issue here. The WLAD’s retaliation
provision declares it an unfair practice for an employer “to discharge, expel, or
2 https://www.courts.wa.gov/opinions/pdf/D2%2057052-1-
II%20Unpublished%20Opinion.pdf
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Verduzco v. King County
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otherwise 	discriminate 	against 	any 	person 	because 	[they 	have] 	opposed
any practices forbidden by this chapter.” Id. A prima facie showing of retaliation
requires (1) the employee took a statutorily protected action, (2) they suffered
an adverse employment action, and (3) there is a causal link between their
protected activity and the adverse employment action. Cornwell v. Microsoft Corp.,
192 Wn.2d 403, 411, 430 P.3d 229 (2018) (citing Currier v. Northland Servs., Inc.,
182 Wn. App. 733, 742, 332 P.3d 1006 (2014); Wilmot v. Kaiser Alum. & Chem.
Corp., 118 Wn.2d 46, 68, 821 P.2d 18 (1991)).
The county conceded the suspension was an adverse action but argued
the other actions were not adverse. 18 VRP at 2500; Opening Br. of Appellant/
Cross-Resp’t King County at 44 (Wash. Ct. App. No 57052-1-II (2023)). The parties
do not dispute any other element of the retaliation claim. Nor do the parties ask this
court to define an adverse action under the WLAD as a matter of law.3 Our review
is limited to the sufficiency of the jury instruction that stated both pattern definitions.
3 The parties assume the WPI accurately states the law, but pattern jury instructions
“are not authoritative primary sources of the law” and “do not receive advance approval from
any court.” 6 WASHINGTON P RACTICE: WASHINGTON P ATTERN J URY INSTRUCTIONS : C IVIL 0.10, at
2-3 (7th ed. 	2019); State v. Carson, 184 Wn.2d 207, 224 n.11, 357 P.3d 1064 (2015).
In fact, the parties identify no authoritative source of Washington law defining “adverse
employment action” in this context. No provision of the WLAD defines an adverse employment
action; the term “adverse” does not appear in that statutory scheme at all. See RCW 49.60.210(1)
(“retaliation” means “to discharge, expel, or otherwise discriminate against”). WPI 330.06
is modeled after a U.S. Supreme Court decision interpreting federal antidiscrimination law.
WPI 330.06 cmt. (citing Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53, 67-68,
126 S. Ct. 2405, 165 L. Ed. 2d 345 (2006)). Although our Court of Appeals has found White
persuasive, this court has never considered whether White’s interpretation of federal law has any
application to the WLAD. Compare Boyd v. State, 187 Wn. App. 1, 15, 349 P.3d 864 (2015), with
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Jury instructions are reviewed de novo for errors of law; absent a legal error,
the specific language of instructions are matters of the trial court’s discretion.
Joyce v. 	Dep’t 	of 	Corr., 	155 	Wn.2d 	306, 	323, 	119 	P.3d 	825 	(2005);
Douglas v. Freeman, 117 Wn.2d 242, 256, 814 P.2d 1160 (1991). “Jury instructions
are 	sufficient 	when 	they 	allow 	counsel 	to 	argue 	their 	theory 	of 	the 	case,
are not misleading, and when read as a whole properly inform the trier of fact of the
applicable law.” Bodin v. City of Stanwood, 130 Wn.2d 726, 732, 927 P.2d 240
(1996). A jury instruction is erroneous if any of those elements are absent.
Anfinson v. FedEx Ground Package Sys., Inc., 174 Wn.2d 851, 860, 281 P.3d 289
(2012). 	“An 	erroneous 	instruction 	is 	reversible 	error 	only 	if 	it 	prejudices
a party. Prejudice is presumed if the instruction contains a clear misstatement of law;
prejudice must be demonstrated if the instruction is merely misleading.” 	Id.
(citation omitted) (citing Joyce, 155 Wn.2d at 323; Keller v. City of Spokane,
146 Wn.2d 237, 249-50, 44 P.3d 845 (2002)). The county challenged jury instruction
Jin Zhu v. N. Cent. Educ. Serv. Dist.—ESD 171, 189 Wn.2d 607, 613, 404 P.3d 504 (2017). While
Washington courts sometimes regard federal law as persuasive, federal case law is “not binding
on this court, which is ‘free to adopt those theories and rationale which best further the purposes
and mandates of our state statute.’” Kumar v. Gate Gourmet, Inc., 180 Wn.2d 481, 491, 325 P.3d
193 (2014) (quoting Grimwood v. Univ. of Puget Sound, Inc., 110 Wn.2d 355, 361-62, 753 P.2d
517 (1988)). In light of the WLAD’s command for liberal construction, RCW 49.60.020, “[w]here
this court has departed from federal antidiscrimination statute precedent, . . . it has almost always
ruled that the WLAD provides greater employee protections than its federal counterparts.” Id. We
have yet to consider the contours of a retaliatory action under Washington law. Given that the
parties here do not ask us to define an adverse action under the WLAD in order to resolve this
dispute, we will not reach that question at this time.
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8 	solely 	on 	the 	basis 	that 	it 	was 	misleading 	or 	confusing.
Opening Br. of Appellant/Cross-Resp’t King County, at 2, 39-40 (Wash. Ct. App.
No. 57052-1-II (2023)).
Instruction 8 listed both pattern definitions sequentially, as Verduzco raised
both types of claims. The WPI anticipates that a plaintiff might bring both types
of claims and recommends courts “combine” the two instructions “to differentiate”
the two claims. WPI 330.01.02 note on use, 330.06 note on use. The WPI offers
no further guidance on how to do so.4
Given 	that 	the 	instructions 	could 	have 	been 	read 	as 	alternatives 	or
as 	individually 	required 	elements, 	the 	instruction 	as 	given 	may 	have 	been
misleading. 	Assuming—without 	deciding—that 	the 	WPI’s 	construction
of the definitions accurately state the law, combining the two WPI definitions
into a single instruction, with no further direction, could have misled the jury.
As given, the instruction is ambiguous as to how the definition applied to each
of Verduzco’s claims.
Ambiguity 	in 	a 	jury 	instruction 	may 	be 	misleading. 	Anfinson,
174 	Wn.2d 	at 	874. 	For 	example, 	Anfinson 	involved 	a 	jury 	instruction 	on
representative 	evidence 	in 	a 	class 	action 	for 	violations 	of 	the 	Washington
4 Nothing prevents the WPI Committee from drafting additional pattern instructions for use
in trials where more than one type of claim is present. Further, trial courts could anticipate
confusion and clarify by specifying definitions or providing special verdict forms.
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Minimum Wage Act. The instruction stated that the jury should not consider
individual work experiences unless it finds “‘that they reflect policies, procedures,
or practices common to the class members during the class period.’” Id. (emphasis
added) (quoting the record). That instruction was “ambiguous because the term
‘common’ is subject to multiple definitions”—it could mean either shared by all
members of a group or a characteristic of a usual type. Id. at 874-75. The instruction
could be read to describe work experience that was true for most members of the
class or experiences shared by all members of the class. If the jury read “common”
to mean “all,” the instruction would effectively prohibit the use of representative
evidence otherwise permitted in class actions under wage and hour laws. Id. at 875.
Though the instruction did not necessarily state an incorrect legal standard,
it was ambiguous as to the legal standard and therefore misleading. See also
Lake Hills 	Invs., 	LLC 	v. 	Rushforth 	Constr. 	Co., 	198 	Wn.2d 	209, 	224,
494 P.3d 410 (2021) (jury instruction that “did not explicitly inform the jury that it
could calculate and attribute proportional liability” was potentially misleading).
Similarly here, the adverse employment action instruction was ambiguous
as to how it applied to each of Verduzco’s claims. The instruction listed both pattern
definitions 	of 	adverse 	actions 	for 	discrimination 	and 	retaliation 	claims, 	but
did 	not 	differentiate 	between 	the 	two 	claims, 	as 	the 	WPI 	recommends.
WPI 330.01.02 note on use, 330.06 note on use. Without differentiating between the
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discrimination and retaliation claims, each sentence in the instruction could be read
as 	alternative 	conceptions 	of 	“adverse” 	or 	as 	criteria
that must be satisfied comprehensively. This ambiguity was potentially misleading.
See Anfinson, 174 Wn.2d at 874-76; Lake Hills, 198 Wn.2d at 224.
However, the county fails to demonstrate it was prejudiced by this instruction.
The county argues that prejudice should be presumed. However, “[i]n order to be
reversible, a misleading jury instruction must also be prejudicial. Unlike a clear
misstatement of law, prejudice is not presumed.” Anfinson, 174 Wn.2d at 876
(citation omitted) (citing Keller, 146 Wn.2d at 249-50). As the challenging party,
the 	county 	bears 	the 	burden 	to 	establish 	prejudice. 	Griffin 	v. 	W. 	RS, 	Inc.,
143 Wn.2d 81, 91, 18 P.3d 558 (2001); Lake Hills, 198 Wn.2d at 225-26.
Verduzco alleged the county both discriminated and retaliated against him;
under the WLAD, discriminating against a person who has opposed an act
of discrimination is a type of retaliation. RCW 49.60.210(1). The evidence presented
to the jury suggested a pattern of Verduzco complaining and the county responding:
Verduzco 	viewed 	the 	county’s 	responses 	as 	discriminatory 	and 	retaliatory
while the county characterized its actions as justified and disciplinary. Although
the WPI definitions may differ qualitatively in order to address different harms—
treating an employee adversely because of their status or treating them adversely
because of their complaint—in practical terms, many actions by employers could
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fall under both categories. E.g., Jin Zhu v. N. Cent. Educ. Serv. Dist.—ESD 171,
189 Wn.2d 607, 615, 404 P.3d 504 (2017) (failure to hire may constitute both
discrimination 	and 	retaliation). 	Compare 	Alonso 	v. 	Qwest 	Commc’ns 	Co.,
178 Wn. App. 734, 747, 315 P.3d 610 (2013) (for a discrimination claim,
reassignment with loss of benefits may constitute an adverse action), with Tyner v.
Dep’t of Soc. & Health Servs., 137 Wn. App. 545, 564-65, 154 P.3d 920 (2007) (for
a retaliation claim, reassignment with loss of benefits may constitute an adverse
action).
Indeed, some of the same conduct by the county in this case could be relevant
to both pattern definitions. Verduzco produced evidence of several actions that might
be sufficiently unfavorable or disadvantageous to dissuade a reasonable employee
from complaining: DNRP leadership wrote letters in his personnel file, gave him a
poor performance review, put him on leave, revoked his access to the building, and
suspended him without pay. Those actions individually or collectively might
dissuade a reasonable employee in Verduzco’s position from complaining, under the
WPI 	definition 	for 	a 	retaliatory 	adverse 	action. 	WPI 	330.06; 	see 	Boyd 	v.
State, 	187 	Wn. 	App. 	1, 	14, 	349 	P.3d 	864 	(2015)
(finding substantial evidence of adverse actions in a retaliation claim when employer
issued a written reprimand, reported employee to the police, and suspended
employee without pay). Some of those actions may also satisfy the WPI definition
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for a discriminatory adverse action. For example, revoking Verduzco’s access to the
building where he worked affected the terms or conditions of his employment.
WPI 330.01.02. Even if not all the actions affected the terms or conditions of
Verduzco’s employment, the county does not dispute that the unpaid suspension did,
given that Verduzco was not permitted to work and was not compensated.5
The county fails to explain how it was prejudiced by this instruction. Instead,
the county contends the jury might have read instruction 8 to find some conduct
materially affected the terms or conditions of employment without considering
whether it could 	also 	dissuade a reasonable employee from complaining of
discrimination. But the county cannot explain why unpaid suspension could not
dissuade a reasonable employee in Verduzco’s circumstances from complaining.
If anything, combining the two WPI definitions narrowed the scope of actions
the jury could consider to only those that satisfied both definitions. Reducing the
range of actions to consider did not lower Verduzco’s burden; it made it easier for
the county to negate the adverse action of the retaliation claim (and harder for
Verduzco to prove that element) than the pattern instructions call for. Rather than
prejudicing the county, instruction 8 seems to have benefited it. The instruction
5 The county argued no other conduct but the unpaid suspension could constitute
“discipline” because a union representative testified that some actions, such as administrative
leave, would not be subject to a grievance procedure under the collective bargaining agreement.
But the county cites no authority for the proposition that the negotiated terms of a contract between
a union and an employer control the meaning of a retaliatory or discriminatory act deemed an
unfair practice by the legislature.
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Verduzco v. King County
No. 103749-0
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allowed the county to argue its theory of the case: that the unpaid suspension was
the only adverse action it took and that doing so was justified, not retaliatory.
The county fails to demonstrate prejudice. See Lake Hills, 198 Wn.2d at 225-26.
CONCLUSION
The narrow question presented is whether a jury instruction that combined
two WPI definitions of a term—which has never been defined by the legislature or
examined 	by 	this 	court—was 	misleading 	to 	a 	jury 	tasked 	with 	determining
both retaliation and discrimination claims. While instruction 8 was ambiguous
to the extent it combined pattern definitions without direction on how to apply them
to each of the claims, the county has failed to demonstrate reversible error.
This instruction did not prejudice the county. Id. at 227 (no reversible error
when potentially misleading instruction did not prejudice the challenging party).
Given 	that 	other 	appellate 	issues 	remain, 	we 	reverse 	and 	remand 	to 	the
Court of Appeals to decide the additional issues raised on appeal and decline
to assess attorney fees at this time. RAP 13.7(b); RAP 18.1.
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Verduzco v. King County
No. 103749-0
17
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WE CONCUR:
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Yu, J.P.T.
Madsen, J.P.T.
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