Anthony Guerriero and Maria Guerriero

1 printed pages contain little extracted OCR body text; searchable legal-body completeness has not been established for those pages.

OCR transcription for search; preserved printed pages are authoritative

Case 07-14648 Doc 34 _ Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page1of15

UNITED STATES BANKRUPTCY COURT
FOR THE
DISTRICT OF MASSACHUSETTS

OO OO OOOO OOO OOo a

Inre
ANTHONY GUERRIERO and Chapter 7
MARIA GUERRIERO, Case No. 07-14648-JNF

Debtors

OOO OOOO OI OOO I eee ene

MEMORANDUM

I. INTRODUCTION

The matter before the Court is the Motion of United States Trustee (“UST”) for
Order Dismissing Case under 11 U.S.C. § 707(b)(1) Based on Presumption of Abuse Arising
under 11 U.S.C. § 707(b)(2).. Anthony and Maria Guerriero (the “Debtors”) oppose the
Motion.

The Court conducted a hearing on the Motion and the Debtors’ opposition on
November 21, 2007 at which counsel to the parties represented that the facts were
undisputed. On December 6, 2007, the parties filed a “Stipulation of Facts.” The legal issue
presented is whether, in applying the means test and determining whether the
presumption of abuse arises, the Debtors are entitled to reduce their “current monthly

income” (“CMI”) by payments to their mortgagee pursuant to 11 U.S.C. § 707(b)(2)(A) (iii)

AUTHENTICATED
U.S. GOVERNMENT
INFORMATION

GPO

The Debtors pose the issue as follows: “Whether 11 U.S.C. § 707(b)(2)(A)(iii),1
providing for deduction of payments due to secured creditor from current monthly
income should be judicially rewritten to contain an implied condition that the payment
of the secured debt is being made at the time of the filing of the petition.”
2
where they have indicated their intention to surrender the real property subject to the
mortgage. 	The issue before the Court is not new 	and is representative of the1
interpretative challenges engendered by passage of the Bankruptcy Abuse Prevention and
Consumer Protection Act of 2005 (“BAPCPA”). See generally, Hon. Thomas F. Waldron and
Neil M. Berman, Principled Principles of Statutory Interpretation: A Judicial Perspective after
Two Years of BAPCPA, 81 Amer. Bankr. L. J. 195 (2007). Bankruptcy courts are divided on
the issue, and it remains unresolved. Within the First Circuit, two bankruptcy judges have
answered the question presented in the affirmative. See In re Hayes, 376 B.R. 55 (Bankr. D.
Mass. 2007), and In re Hartwick, 359 B.R. 16 (Bankr. D. N.H. 2007), but courts in other
jurisdictions have concluded that debtors may not deduct payments for secured debt if the
collateral securing the debt has been or will be surrendered. See, e.g., In re Skaggs, 349 B.R.
594 (Bankr. D. Mo. 2006).
II. STIPULATED FACTS
The Debtors, a married couple, filed a Chapter 7 petition on July 27, 2007. 	Mr.
Guerriero is a driver for Kamco Services, and Mrs. Guerriero is an office manager for
Burnham Associates. The Debtors’ CMI, the definition of which is set forth at 101 U.S.C.
§ 101(10A), exceeds the applicable median income for a household size of two in the
Commonwealth of Massachusetts. Moreover, the debts owed by the Debtors are primarily
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 2 of 15

The Debtors also indicated their intention to surrender the property on their2
“Chapter 7 Individual Debtor’s Statement of Intention.”
3
consumer obligations. Because the Debtors’ income is above the median income for their
family size and location, they were required to calculate and deduct their expenses
pursuant to 11 U.S.C. § 707(b)(2)(A)(i)-(iv) and to complete Part V of Form 22A.
The Debtors reside in an apartment located at 1304 Village Road East, Norwood,
Massachusetts. They moved there prior to filing their bankruptcy petition. At the time
they filed their Chapter 7 petition, the Debtors held an interest in residential real property
located at 25 Cross Street, Salem, Massachusetts (the Cross Street property”). On Schedule
A-Real Property, they listed the current value of the Cross Street property as $250,000,
subject to a secured claim in the sum of $358,706 held by Saxon Mortgage Services, Inc.
(“Saxon”). On Schedule A, they noted that the “property is being surrendered.” 2
The Debtors have two mortgages with Saxon which encumber the Cross Street
property. They testified at their section 341(a) meeting of creditors that they had not made
a mortgage payment on either the first or second mortgage since the Spring of 2007. In
their Statement of Financial Affairs, they disclosed that Saxon had commenced a
foreclosure proceeding.
The Debtors occupied the Cross Street property through June 15, 2007, at which time
they entered into a one-year residential lease for an apartment at Windsor Gardens and
moved to Norwood, Massachusetts. Their monthly rental expense, as listed on Schedule
J-Current Expenditures of Individual Debtor(s) is $1,510. On their Amended Official Form
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 3 of 15

Official Form 22A in effect at the time the Debtors filed their petition, at line 42,3
provides:
Future payments on secured claims. For each of your debts that is secured
by an interest in property that you own, list the name of the creditor,
identify the property securing the debt, and state the Average Monthly
Payment. The Average Monthly Payment is the total of all amounts
contractually due to each Secured Creditor in the 60 months following the
filing of the bankruptcy case, divided by 60. Mortgage debts should
include payments of taxes and insurance required by the mortgage. . . .
4
22A in Part V, “Calculation of Deduction allowed under § 707(b)(2),” Subpart C,
“Deductions for Debt Payments,” on line 42, the Debtors listed “[f]uture payments on
secured claims” totaling $2,442, although they have made no post-petition payments to
Saxon. They did not deduct any expense on line 20B under the IRS Local Standards for3
“housing and utilities; mortgage/rent expense.”
Saxon filed a Motion for Relief from the Automatic Stay on August 22, 2007 seeking
authority to foreclose its first mortgage on the Cross Street property. On September 5,
2007, in the absence of objections, this Court granted Saxon’s Motion. As of December 6,
2007, when the parties filed their Stipulation of Facts, Saxon had not conducted a
foreclosure sale and a mortgage discharge had not been recorded in the Essex County
Registry of Deeds.
The section 341(a) meeting of creditors was held on August 23, 2007 and continued
to September 19, 2007. 	On August 31, 2007, the UST filed a Statement that she was
currently unable to determine whether the Debtors’ case would be presumed to abusive.
On October 1, 2007, the UST filed the Motion to Dismiss now before the Court. 	See 11
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 4 of 15

5
U.S.C. § 704(b).
III. THE STATUTE
Section 707(b) provides in relevant part the following:
(b)(1) After notice and a hearing, the court, on its own motion or on a motion
by the United States trustee, trustee (or bankruptcy administrator, if any), or
any party in interest, may dismiss a case filed by an individual debtor under
this chapter whose debts are primarily consumer debts, or, with the debtor’s
consent, convert such a case to a case under chapter 11 or 13 of this title, if it
finds that the granting of relief would be an abuse of the provisions of this
chapter. In making a determination whether to dismiss a case under this
section, the court may not take into consideration whether a debtor has
made, or continues to make, charitable contributions (that meet the definition
of “charitable contribution” under section 548(d)(3)) to any qualified
religious or charitable entity or organization (as that term is defined in
section 548(d)(4)).
(2)(A)(i) In considering under paragraph (1) whether the granting of relief
would be an abuse of the provisions of this chapter, the court shall presume
abuse exists if the debtor’s current monthly income reduced by the amounts
determined under clauses (ii), (iii), and (iv), and multiplied by 60 is not less
than the lesser of--
(I) 25 percent of the debtor’s nonpriority unsecured
claims in the case, or $6,575, whichever is greater; or
(II) $10,950.
(ii)(I) The debtor’s monthly expenses shall be the
debtor’s applicable monthly expense amounts
specified under the National Standards and
Local Standards, and the debtor’s actual monthly
expenses for the categories specified as Other
Necessary 	Expenses 	issued 	by 	the 	Internal
Revenue Service for the area in which the debtor
resides, as in effect on the date of the order for
relief, for the debtor, the dependents of the
debtor, and the spouse of the debtor in a joint
case, if the spouse is not otherwise a dependent.
Such 	expenses 	shall 	include 	reasonably
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 5 of 15

6
necessary health insurance, disability insurance,
and health savings account expenses for the
debtor, 	the 	spouse 	of 	the 	debtor, 	or 	the
dependents of the debtor. Notwithstanding any
other provision of this 	clause, the monthly
expenses of the debtor shall not include any
payments for debts. . . .
(II) In addition, the debtor’s monthly expenses
may include, if applicable, the continuation of
actual expenses paid by the debtor that are
reasonable and necessary for care and support of
an elderly, chronically ill, or disabled household
member or member of the debtor’s immediate
family 	(including 	parents, 	grandparents,
siblings, children, and grandchildren of the
debtor, the dependents of the debtor, and the
spouse of the debtor in a joint case who is not a
dependent) and who is unable to pay for such
reasonable and necessary expenses.
(III) In addition, for a debtor eligible for chapter
13, the debtor’s monthly expenses may include
the 	actual 	administrative 	expenses 	of
administering a chapter 13 plan for the district in
which the debtor resides, up to an amount of 10
percent of the 	projected plan payments, as
determined 	under 	schedules 	issued 	by 	the
Executive Office for United States Trustees.
(IV) In addition, the debtor’s monthly expenses
may 	include 	the 	actual 	expenses 	for 	each
dependent child less than 18 years of age, not to
exceed $1,650 per year per child, to attend a
private or public elementary or secondary school
if the debtor provides documentation of such
expenses and a detailed explanation of why such
expenses are reasonable and necessary, and why
such expenses are not already accounted for in
the National Standards, Local Standards, or
Other 	Necessary 	Expenses 	referred 	to 	in
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 6 of 15

7
subclause (I).
(V) In addition, the debtor’s monthly expenses
may include an allowance for housing and
utilities, in excess of the allowance specified by
the Local Standards for housing and utilities
issued by the Internal Revenue Service, based on
the actual expenses for home energy costs if the
debtor provides documentation of such actual
expenses and demonstrates that such actual
expenses are reasonable and necessary.
(iii) The debtor’s average monthly payments on account of
secured debts shall be calculated as the sum of–
(I) the total of all amounts scheduled as contractually
due to secured creditors in each month of the 60
months following the date of the petition; and
(II) any additional payments to secured creditors
necessary for the debtor, in filing a plan under
chapter 13 of this title, to maintain possession of
the debtor’s primary residence, motor vehicle, or
other property necessary for the support of the
debtor and the debtor’s dependents, that serves
as collateral for secured debts;
divided by 60.
(iv) The debtor’s expenses for payment of all priority claims
(including priority child support and alimony claims) shall be
calculated as the total amount of debts entitled to priority,
divided by 60.
11 U.S.C.§ 707(b)(2)(A)(emphasis supplied).
The UST explains the mathematics governing when the presumption of abuse arises
under section 707(b):
[I]f after deducting all allowable expenses from a debtor’s current monthly
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 7 of 15

8
income, the debtor has less than $109.58 per month in monthly net income
(i.e., less than $6,575 to fund a 60 month plan), the filing is not presumed
abusive. If a debtor has monthly net income of $182.50 or more (i.e., at least
$10,950 to fund a 60 month plan), the filing is presumed abusive. Finally, if
a debtor’s monthly income is more than $109.58 but less than $182.50, the
case will be presumed abusive if that sum, when multiplied by 60 months
will pay 25% or mor of the debtor’s non-priority unsecured debts.
UST’s Motion to Dismiss at p.2, ¶ 4. See also In re Hayes, 376 B.R. at 58. Debtors may rebut
the presumption of abuse with reference to “special circumstances, such as a serious
medical condition or a call or order to active duty in the Armed Forces.” See 11 U.S.C. §
707(b)(2)(B). If the presumption of abuse does not arise, or is rebutted, the Court may still
dismiss a Chapter 7 case if the debtor filed the petition in bad faith or the totality of the
circumstances establishes abuse. See 11 U.S.C. 707(b)(3).
IV. POSITIONS OF THE PARTIES
A. The UST
Consistent with her duties, the UST reviewed all materials filed and provided by the
Debtors, including the Debtors’ Schedules, Statement of Financial Affairs, payment advices,
and amended Form 22A in order to determine whether granting them relief under Chapter
7 would be presumptively abusive. 	See 11 U.S.C. § 704(b)(1)(A). 	After reviewing the
documentation submitted by the Debtors, the UST concluded that the presumption of
abuse arose. To reach her conclusion, she recalculated the Debtors’ allowable expenses and
deductions and prepared an adjusted Form 22A. In sum, the UST increased the Debtors’
allowable deduction from $-0- to $1,225 for rental expenses on line 20B using the IRS Local
Standards for “housing and utilities; mortgage/rent expense” in Part V, Subpart A,
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 8 of 15

9
“Deductions under Standards of the Internal Revenue Service (IRS)” of Form 22A.
Additionally, she increased the Debtors’ allowable deductions from $393 to $782 on line
22 	using 	the 	IRS 	Local 	Standards 	for 	“transportation; 	vehicle 	operation/public
transportation expense.” 	Finally, she eliminated the Debtors’ $2,440 deduction for the
payment of secured debt (Saxon’s first and second mortgages) on line 42 of Subpart C. The
following chart summarizes the disparity in the treatment of the Debtors’ expenses and
deductions as set forth in the Debtors’ amended Form 22A and the adjusted Form 22A
created by the UST.
Part VI. DETERM INATION OF § 707(B)(2) PRESUM PTION 	Debtors 	UST
Current monthly income for § 707(b)(2) 	$6,458 	$6,458
Total of all deductions allowed under § 707(b)(2) 	$6,738 	$5,966.60
M onthly disposable income under § 707(b) 	($280) 	$491.40
60-month disposable income under § 707(b) 	($16,800) 	$29,484
The UST based her decision to recalculate the Debtors’ deductions based upon cases
such as In re Ray, 362 B.R. 680 (Bankr. D.S.C. 2007), In re Harris, 353 B.R. 304 (Bankr. E.D.
Okla. 2006), and In re Skaggs, 349 B.R. 594 (Bankr. E.D. Mo. 2006), which hold that debtors
who indicate their intention to surrender collateral are not entitled to take an expense
deduction for payments on secured debts pursuant to section 707(b)(2)(A)(iii). Because the
Debtors’ actual monthly disposable income based upon the UST’s adjusted Form 22A
shows disposable income of $491.40, an amount which exceeds the $182.50 threshold for
the presumption of abuse, the UST seeks dismissal of the Debtors’ bankruptcy case.
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 9 of 15

10
B. The Debtors
The Debtors rely upon the decisions in In re Hayes, 376 B.R. 55 (Bankr. D. Mass.
2007), and In re Hartwick, 359 B.R. 16 (Bankr. D. N.H. 2007), in support of their position
that the UST’s Motion to Dismiss lacks merits and must be denied. They emphasize use
of the term “shall” in section 707(b)(2)(A)(iii) and maintain that the Court lacks discretion
in interpreting the plain meaning of the statute.
V. DISCUSSION
In Hayes, Chief Judge Boroff ably articulated the different interpretations of section
707(b)(2)(A)(iii)(I), which governs the outcome of this case, specifically the meaning of the
phrase “scheduled as contractually due.” After the obligatory nod to the Supreme Court’s
command to enforce a statute according to its terms if the language is plain and does not
produce an absurd result, see United States v. Ron Pair Enter., Inc., 489 U.S. 235, 241 (1989),
Chief Judge Boroff discussed whether the word “scheduled” refers to the debtor’s
bankruptcy schedules, or whether it should be given its common, dictionary definition.
Compare In re Skaggs, 349 B.R. at 599 (“the Debtors’ schedules and statements form the
basis from which the Court should determine whether a debt is ‘scheduled as contractually
due.’”); In re Harris, 353 B.R. 304 (Bankr. E.D. Okla. 2006)(same) with In re Walker, No. 05-
15010-WHD, 2006 WL 1314125 at *4 (Bankr. N. D. Ga. May 1, 2006)(“[T]he plain language
of the statute permits a reduction from CMI for payments on secured debts that have not
been reaffirmed. Congress’ [sic] choice of the phrase, ‘scheduled as contractually due,’
suggests that, in determining which payments should be averaged for the deduction, the
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 10 of 15

A third line of cases hold that4
[T]he mere act of declaring an intent to surrender collateral on a Statement
of Intention does not extinguish the Debtors’ right to deduct those
payments under § 707(b)(2)(A)(iii). However, for purposes of a motion to
dismiss based on the presumption of abuse formula found in §
707(b)(2)(A) (Presumption of Abuse Motion), the relevant date on which
calculations should be based is the date of the filing of the motion, not the
date of the filing of the petition. Therefore, any events occurring
post-petition and up to the date of the filing of the motion must be taken
into account in applying the means test. Thus, if a debtor has carried
through with his intent to surrender the collateral and relief from stay has
been granted before the filing of the Presumption of Abuse Motion, the
payments on that debt would not be counted under § 707(b)(2)(A)(iii).
In re Ray, 362 B.R. at 683-84 (citing In re Singletary, 354 B.R. 455, 458 Bankr. D.Tex.
2006)). The court in In re Chang, No. 07-50484-ASW, 2007 WL 3034679 (Bankr. N.D.
Cal. Oct. 16, 2007), observed that the court in Singletary was constrained by Fifth Circuit
precedent, namely In re Cortez, 457 F.3d 448 (5th Cir. 2006). Noting that it was not
constrained by that precedent, the court in Chang concluded that “taking post-petition
events into account . . . contravenes the purpose of the means test as an objective
analysis, to be performed at the time the petition is filed. 2007 WL 3034679 at *3.
11
Court should determine how many payments are owed under the contract for each secured
debt at the time of filing.”) In re Longo, 364 B.R. 161 (Bankr. D. Conn. 2007)(same), In re
Randle, 358 B.R. 360 (Bankr. N.D. Ill. 2006), aff’d, Randle v. Neary (In re Randle), No.
07C631, 2007 WL 2668727 (N.D. Ill. July 20, 2007)(same); In re Sorrell, 359 B.R. 167 (Banrk.
S.D. Ohio 2007)(same); In re Hartwick, 359 B.R. 16 (Bankr. D. N.H. 2007); In re Nockerts,
357 B.R. 497 (Bankr. E.D. Wis. 2006)(same). 	As noted by the court in In re Chang, No. 07-4
50484, 2007 WL 3034679 (Bankr. N.D. Cal. Oct. 16, 2007), the majority of courts holds that
debtors are authorized to deduct monthly payments on secured debts where the debtor
intends to surrender the collateral securing the debt.
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 11 of 15

12
In Hayes, Chief Judge Boroff observed:
[E]ven if this Court were to conclude that the Trustee’s interpretation of the
statute is the appropriate one-i.e., that “scheduled as” refers to the debtor’s
bankruptcy 	schedules-this 	would 	“really 	be 	a 	distinction 	without 	a
difference.” In re Haar, 360 B.R. at 766; see also In re Randle, 358 B.R. at 365.
The “scheduling” of a secured debt on the debtor’s bankruptcy petition does
not change the fact that the payments are “contractually due.” In re Haar, 360
B.R. at 764, 765; In re Sorrell, 359 B.R. at 184; In re Randle, 358 B.R. at 365; In
re Singletary, 354 B.R. at 468. Nor does declaring an intention to ultimately
surrender 	property 	to 	the 	creditor 	abrogate 	a 	debtor’s 	contractual
obligations. In re Longo, 364 B.R. at 165-66; In re Haar, 360 B.R. at 764; In re
Sorrell, 359 B.R. at 184; In re Singletary, 354 B.R. at 467 n. 11, 468; In re
Walker, 2006 WL 1314123 at *4, 2006 Bankr.LEXIS 845 at *13-14.
Hayes, 376 B.R. at 62-63. Turning to the phrase, “in each of the 60 months following the
date of the petition,” the Hayes court further observed that “the term ‘following’ denotes
a look forward, specifically, a look sixty months into the debtor’ future.” Id. at 63. Chief
Judge Boroff concluded, however, that
[a]part from the obvious practical difficulties the Court would encounter in
trying to determine which debtors will actually make all payments required
under their contracts with secured creditors during each of the sixty months
following the petition, it is equally clear that the plain language of the statute
does not contemplate the Court assuming this kind of predictive role.
Id. Chief Judge Boroff added: “Nothing in the phrase ‘following the date of the petition’
suggests that the calculation must include only those payments actually made. Instead, the
phrase modifies the preceding portion of the statute which refers to those payments that
are ‘scheduled as contractually due.’” Id. at 64.
The court in Hayes also considered the legislative history of BAPCPA, although it
implied that reference to it was unnecessary because it found that the statute was not
ambiguous and did not produce an absurd result. Id. at 64-65. Recognizing that Congress
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 12 of 15

See Randle v. Neary (In re Randle), No. 07C631, 2007 WL 2668727 (N.D. Ill. July5
20, 2007); Fokkena v. Hartwick (In re Hartwick), 373 B.R. 645 (D. Minn. 2007), relying
on both the bankruptcy court and district court decisions in Randle and reaching the
same conclusion with respect to section 707(b)(2)(A)(iii).
13
may have intended to identify debtors capable of paying a percentage of their unsecured
debts in creating the means test under section 707(b)(2) and to deny them a discharge or
push them into Chapter 13, Chief Judge Boroff determined that Congress intended for the
means test to be mechanical and to reduce judicial discretion. Citing Randle, 358 B.R. at
364, one of only two pertinent decisions that appears to have been the subject of appellate
review, Chief Judge Boroff concluded:5
The deduction of secured payments due at the time of the petition filing-even
if the debtor intends to eventually surrender the property-is consistent with
the mechanical, discretion-void nature of the means test. See In re Kogler, 368
B.R. at 790-91; Walker, 2006 WL 1314123 at *6, 2006 Bankr.LEXIS 845 at
*18-19. To read into § 707(b)(2)(A)(iii)(I) a requirement that the court inquire
into possible future outcomes in each debtor’s case “is completely contrary
to Congress’ intent because it requires the kind of case-by-case adjustment
based on a debtor’s individual circumstances for the presumption of abuse
that Congress rejected.” In re Randle, 358 B.R. at 364.
Hayes, 376 B.R. at 65-66 (footnotes omitted).
VI. CONCLUSION
This Court has reviewed the decisions cited by the parties and by the court in Hayes.
Courts on all sides of the issue make valid points. The language of the statue, which is
simultaneously backward and forward looking, invites debate. This Court concludes that
decisions, such as Chief Judge Boroff’s decision in Hayes, and the cases upon which he
relied, are the better reasoned. In addition, adopting the holding in Hayes avoids
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 13 of 15

14
inconsistency within the district of Massachusetts, and, in view of Judge Deasy’s decision
in Hartwick, 359 B.R. 16 (Bankr. D. N.H. 2007), inconsistency within the circuit as well.
In view of the foregoing, the Court shall enter an order denying the UST’s Motion
to Dismiss without prejudice to the filing of a motion under 11 U.S.C. § 707(b)(3).
By the Court,
Joan N. Feeney
United States Bankruptcy Judge
Dated: February 4, 2008
cc: Paula R.C. Bachtell, Esq., Daniel Gindes, Esq.
Case 07-14648 Doc 34 Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 14 of 15

Case 07-14648 Doc 34 _ Filed 02/04/08 Entered 02/04/08 14:13:04 Desc Main
Document Page 15 of 15

15