Nevada Supreme Court Case 65960
Document 14-37394
Zandian’s Appeal of District Court’s Order to pay interest, costs, and attorney’s fees.
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IN THE SUPREME COURT OF THE STATE OF NEVADA
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REZA ZANDIAN A/K/A GOLAMREZA ZANDIANJAZI A/K/A GHOLAM REZA ZANDIAN A/K/A REZA JAZI A/K/A J. REZA JAZI A/K/A G. REZA JAZI A/K/A GHONOREZA ZANDIAN JAZI, AN INDIVIDUAL, Appellant,
VS.
JED MARGOLIN, AN INDIVIDUAL, Respondent.
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Nevada Supreme Court Case No. 65960
Electronically Filed Nov 13 2014 09:43 a.m. Tracie K. Lindeman Clerk of Supreme Court |
APPEAL
from the FIRST JUDICIAL DISTRICT
COURT OF THE STATE OF NEVADA
IN AND FOR CARSON CITY
THE HONORABLE JAMES T. RUSSELL, District Judge
APPELLANT'S OPENING BRIEF
JASON WOODBURY
Nevada Bar No. 6870
KAEMPFER CROWELL
510 West Fourth Street
Carson City, Nevada 89703
Telephone: (775) 884-8300
Attorneys for Appellant, Reza Zandian
TABLE OF CONTENTS
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TABLE OF AUTHORITIES |
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OPENING BRIEF |
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STATEMENT OF JURISDICTION |
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ISSUES PRESENTED |
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STATEMENT OF CASE |
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STATEMENT OF FACTS |
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SUMMARY OF THE ARGUMENT |
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ARGUMENT |
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I. STANDARD OF REVIEW |
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II. NRS 598.0999(2) DOES NOT PERMIT AN AWARD OF ATTORNEYS' FEES IN A PRIVATE CAUSE OF ACTION |
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III. THE DISTRICT COURT ABUSED ITS DISCRETION IN AUTHORIZING SPECIALIZED FEE RATES FOR ROUTINE LEGAL WORK |
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CONCLUSION |
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CERTIFICATE OF COMPLIANCE |
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CERTIFICATE OF SERVICE |
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TABLE OF AUTHORITIES
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CASES |
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Nevada Cases
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Albios v. Horizon Cmtys., Inc. 122 Nev. 409, 417, 132 P.3d 1022, 1027-28 (2006) |
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Banks v. Sunrise Hospital, 120 Nev. 822, 102 P.3d 52, 68 (2004) |
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Bergmann v. Boyce, 109 Nev. 670, 674, 856 P.2d 560,563 (1993) |
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Bobby Berosini, Ltd. v. People for the Ethical Treatment of Animals, 114 Nev. 1348, 1354, 971 P.2d 383, 386 (1998) |
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Brunzell v. Golden Gate Nat'l Bank, 85 Nev. 345,455 P.2d 31 (1969) |
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Butler v. State, 120 Nev. 879, 892-93, 102 P.3d 71 (2004) |
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Calloway v. City of Reno, 116 Nev. 250, 993 P.2d 1259 (2000) |
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Charlie Brown Constr. Co. v. Boulder City, 106 Nev. 497, 503, 797 P.2d 946 (1990) |
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Dearden v. Galli, 71 Nev. 199, 284 P.2d 384 (1955) |
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Dixon v. Second Judicial Dist. Ct., 44 Nev. 98,101, 190 P. 352, 353 (1920) |
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Gibellini v. Klindt, 110 Nev. 1201,1205, 885 P.2d 540, 543 (1994) |
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Horgan v. Felton, 123 Nev. 577, 581,1780 P.3d 982, 986 (2007) |
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Mooney v. Newton, 43 Nev. 441,187 P. 721 |
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Rowland v. Lepire, 99 Nev. 3o8, 315, 662 P.2d 1332, 1336 (1983) |
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Smith v. Crown Fin. Servs., 111 Nev. 277, 281, 890 P.2d 769, 771-72 |
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Nevada Cases cont'd |
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State, Dep't of Human Resources v. Fowler, 109 Nev. 782, 784, 858 P.2d 375,376 (1993)) |
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Sun Realty v. Dist. Ct., 91 Nev. 774, 776, 542 P.2d 1072, 1074 (1975) |
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Zandian v. Margolin, Nevada Supreme Court case number 65205 |
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Zandian v. Margolin, Nevada Supreme Court case no. 65960 |
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Other State Courts |
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Miller v. Kehoe, 107 Cal. 340, 40 P. 485 |
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NEVADA STATUTES
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NRS 482 (2001) |
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NRS 598.096 |
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NRS 598.0903 |
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NRS 598.0963 |
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NRS 598.0974 |
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NRS 598.0975 |
10, 11 |
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NRS 598.0983 |
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NRS 598.0985 |
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NRS 598.0999 |
passim |
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OTHER AUTHORITIES |
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1 Stuart M. Speiser, Attorneys' Fees §12:3 at 463-64 (1973) |
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OPENING BRIEF
COMES NOW, Appellant, REZA ZANDIAN ("ZANDIAN"), by and through his attorneys, KAEMPFER CROWELL, and hereby submits his Appellant's Opening Brief (“Opening Brief ”) and requests that this Court reverse the Order on Motion for Order Allowing Costs and Necessary Disbursements and Memorandum of Points and Authorities in Support Thereof issued May 19, 2014 by the District Court in this case below.
STATEMENT OF JURISDICTION
On May 19, 2014, the First Judicial District Court of the State of Nevada in and for Carson City, the Honorable James T. Russell presiding ("District Court") issued an Order on Motion for Order Allowing Costs and Necessary Disbursements and Memorandum of Points and Authorities in Support Thereof ("Order") in this case, which constitutes a "special order entered after final judgment." [1] On May 20, 2014, notice of entry of the Order was served by mail upon
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[1] See Joint App. at Vol. IV, 549-58 [hereinafter "J.A."]; NRAP 3A(b)(8).
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counsel for ZANDIAN.[2] And on June 23, 2014, ZANDIAN filed his timely Notice of Appeal of the Order.[3]
ISSUES PRESENTED
I. Whether the District Court incorrectly granted a motion ordering post-judgment costs and fees in favor of Respondent, Margolin and against, Appellant, ZANDIAN.
STATEMENT OF CASE
On December 11, 2009, Respondent, Jed Margolin ("MARGOLIN") filed a Complaint naming OPTIMA TECHOLOGY CORPORATION, a California corporation, OPTIMA TECHNOLOGY CORPORATION, a Nevada corporation, and ZANDIAN as Defendants.[4] MARGOLIN alleged several claims for relief in the original Complaint, all of which concerned ownership of four United States patents and allegations of conduct which damaged MARGOLIN's interest in the patents.[5] Subsequent to some initial proceedings between December, 2009 and August, 2011,[6]
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[2] See J.A. at Vol. IV, 559-70.
[3] See J.A. at Vol. IV, 581-99; NRAP 4(a)(1).
[4] See J.A. at Vol. I, 1-10.
[5] See J.A. at Vol. I, 1-10.
[6] The proceedings prior to the filing of the Amended Complaint are not pertinent to this appeal. For information as to those initial proceedings, see Docket Sheet at 9-10 (Nov. 5, 2014) (Zandian v. Margolin, Nevada Supreme Court case number 65960).
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MARGOLIN filed an Amended Complaint naming the same Defendants.[7] The Amended Complaint served as MARGOLIN's operative statement of claims for the remainder of the litigation. MAROGLIN's {sic} Amended Complaint included five claims for relief:
(1) "Conversion"; [8]
(2) "Tortious Interference With Contract";[9]
(3) "Intentional Interference with Prospective Economic Advantage"; [10]
(4) "Unjust Enrichment”;[11] and
(5) "Unfair and Deceptive Trade Practices."[12]
On June 24, 2013, MARGOLIN was granted a Default Judgment against ZANDIAN on all claims.[13]
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[7] See J.A. at Vol. I, 11-18.
[8] See J.A. at Vol. 1, 14-15.
[9] See J.A. at Vol. I, 15.
[10] See J.A. at Vol. I, 15.
[11] See J.A. at Vol. I, 16.
[12] See J.A. at Vol. I, 16.
[13] See J.A. at Vol. I, 35-37. The Default Judgment is the subject of another appeal pending with this Court. See Zandian v. Margolin, Nevada Supreme Court case number 65205.
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Subsequent to the Default Judgment, MARGOLIN filed a Motion for Order Allowing Costs and Necessary Disbursements and Memorandum of Points and Authorities in Support Thereof ("Motion").[14] Among other relief, the Motion requested that the District Court award MARGOLIN $34,632.50 in attorneys' fees incurred after entry of the Default Judgment, from October 18, 2013 through April 18, 2014.[15] In response to the Motion, ZANDIAN filed Defendants' Motion to Retax and Settle Costs[16] and an Opposition to Motion for Order Allowing Costs and Necessary Disbursements.[17] MARGOLIN filed a Reply in Support of Motion for Order Allowing Costs and Necessary Disbursements and Memorandum of Points and Authorities in Support Thereof [18] and the issue was submitted to the District Court.[19]
On May 19, 2014, the District Court ruled on the Motion and issued its Order on Motion for Order Allowing Costs and Necessary
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[14] See J.A. at Vol. III, 411-94.
[15] See J.A. at Vol. III, 415, 419-77.
[16] See J.A. at Vol. III, 495-505.
[17] See J.A. at Vol. IV, 537-45.
[18] See J.A. at Vol. IV, 506-33.
[19] See J.A. at Vol. IV, 546-48.
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Disbursements and Memorandum of Points and Authorities in Support Thereof.[20] The Order granted MARGOLIN's request for fees, determining that such an award was authorized by NRS 598.0999(2). [21] This appeal followed.[22]
STATEMENT OF FACTS
The issue presented in this appeal, whether the District Court properly awarded MARGOLIN attorney's fees under NRS 598.0999(2), is legal in nature and does not implicate any facts which are in dispute.
SUMMARY OF THE ARGUMENT
NRS 598.0999(2) does not authorize an award of fees in litigation between private parties. The District Court's Order - which relies exclusively on that provision in making such an award - should be reversed. Further, even if NRS 598.0999(2) did authorize a private attorneys' fee award, the District Court abused its discretion in authorizing a specialized fee rate for general and routine legal work.
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[20] See J.A. at Vol. IV, 549-58.
[21] See J.A. at Vol. IV, 551-52.
[22] See J.A. at Vol. IV, 581-640.
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ARGUMENT
I. STANDARD OF REVIEW
Usually, a trial court's decision as to an award of attorneys' fees is reviewed by this Court for an "abuse of discretion."[23] However, a court cannot "award attorney fees absent authority under a statute, rule, or contract."[24] And a trial court's interpretation of statute "presents a question of law, subject to de novo review."[25] Thus, when the issue is not whether the district court should have awarded fees but, rather, whether the court had statutory discretion at all to award attorneys' fees, the matter is subject to de novo review by this Court. That is the threshold question presented in this case.
II. NRS 598.0999(2) does not permit an award of attorneys' fees in a private action.
Nevada jurisprudence generally follows the "American Rule" which requires that litigants bear their own attorneys' fees incurred in
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[23] See Bobby Berosini, Ltd. v. People for the Ethical Treatment of Animals, 114 Nev. 1348, 1354, 971 P.2d. 383, 386 (1998) (citing Bergmann v. Boyce, 109 Nev. 670, 674, 856 P.2d 560, 563 (1993)).
[24] Albios v. Horizon Cmtys., Inc., 122 Nev. 409, 417, 132 P.3d 1022, 1027-28 (2006) (citing State, Dept of Human Resources v. Fowler, 109 Nev. 782, 784, 858 P.2d 375, 376 (1993)).
[25] Albios, 122 Nev. at 417,132 P.3d at 1028 (citing Banks v. Sunrise Hospital, 120 Nev. 822, 102 P.3d 52, 68 (2004)).
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the course of litigation.[26] The only exception to application of the American Rule in Nevada occurs when a contract, statute or court rule authorizes an award of attorneys' fees.[27] However, because these exceptions are in "derogation of common law," they are "strictly construed."[28] Thus, deviations from the American Rule are justified only by an "express"[29] statutory provision which establishes the exception in "plain terms."[30]
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[26] See Smith v. Crown Fin. Servs., 111 Nev. 277, 281, 890 P.2d 769, 771-72 ("`It has been a consistent rule throughout the United States that a litigant has no inherent right to have his attorneys' fees paid by his opponent or opponents. Such an item is not recoverable in the ordinary case as damages, nor as costs, and hence is held not allowable in the absence of some provision for its allowance either in a statute or rule of court, or some contractual provision or stipulation. This sweeping general rule has been applied in legions of cases to preclude recovery of attorneys' fees, whether by the plaintiff or by the defendant, from one's opponent in a civil action."' (quoting 1 Stuart M. Speiser, Attorneys" Fees§12:3 at 463-64 (1973)).
[27] See Horgan v. Felton, 123 Nev. 577, 583, 170 P.3d 982, 986 (2007) (citing Rowland v. Lepire, 99 Nev. 3o8, 315, 662 P.2d 1332, 1336 (1983)).
[28] Bobby Berosini, 114 Nev. at 1352, 971 P.2d at 385 (citing Gibellini v. Klindt, 110 Nev. 1201,1205, 885 P.2d 5402 543 (1994)).
[29] See Sun Realty v. Dist. Ct., 91 Nev. 774, 776, 542 P.2d 1072, 1074 (1975) (citing Dearden v. Galli, 71 Nev. 199, 284 P.2d 384 (1955)).
[30] Dixon v. Second Judicial Dist. Ct., 44 Nev. 98, 101, 190 P. 352, 353 (1920) ("The general rule is that counsel fees are not recoverable by a successful party either in an action at law or in equity except in the enumerated instances where they are expressly allowed by a statute.... And in the absence of a statute authorizing it in plain terms, no such fee can be taxed on appeal." (citing Mooney v. Newton, 43 Nev. 441, 187 P. 721; Miller v. Kehoe, 107 Cal. 340, 40 P. 485)).
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In this case, it is undisputed that there was no agreement and no rule which authorized an award of attorneys' fees. Rather, a single statutory provision, NRS 598.0999(2), was the basis for MARGOLIN's Motion and the District Court's Order. In pertinent part, that statute provides:
NRS 598.0999 Civil and criminal penalties for violations.
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2. Except as otherwise provided in NRS 598.0974, in any action brought pursuant to the provisions of NRS 598.0903 to 598.0999, inclusive, if the court finds that a person has willfully engaged in a deceptive trade practice, the district attorney of any county in this State or the Attorney General bringing the action may recover a civil penalty not to exceed $5,000 for each violation. The court in any such action may, in addition to any other relief or reimbursement, award reasonable attorney's fees and costs.[31]
This provision does not support the District Court's ruling awarding MARGOLIN post-judgment attorneys fees.
First, NRS 598.0999(2) is only triggered by actions "brought pursuant to NRS 598-0903-598.0999."[32] Those provisions of Nevada law authorize the commencement of actions by the Nevada Attorney
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[31] NRS 598.0999(2).
[32] Id.
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Genera1 [33] and Nevada's district attorneys [34] in regard to deceptive trade practices. They do not authorize a private right of action. Therefore, MARGOLIN's action was not "brought pursuant to NRS 598.0903-598.09" and the provision which the Motion and Order relied upon does not apply.
Second, even if NRS 598-0903-598.0999 is deemed to authorize private causes of action, subsection (2) of NRS 598.0999 restricts an award of attorneys' fees to only those actions brought by the Attorney General or a district attorney. The penultimate sentence establishes that the Attorney General or district attorney "may recover a civil penalty" up to $5,000 for a deceptive trade practice.[35] Then the final sentence of NRS 598.0999 goes on to state, "The court in any such action may, in addition to any other relief or reimbursement, award reasonable attorney's fees and costs."[36] The language "any such action" clearly refers to the preceding sentence which addresses the recovery of a civil penalty by the Attorney General or district attorney. To read the language otherwise renders
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[33] See NRS 598.096; NRS 598.0963.
[34] See NRS 598.0983; 598•0985.
[35] NRS 598.0999(2).
[36] See id. (emphasis added).
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the words "in any such action" superfluous and removes all meaning provided by the context. Nevada law rejects such an interpretation.[37]
This point - clear enough with even a cursory glance at the plain language - becomes unmistakable when the provision at issue is considered in conjunction with NRS 598.0975. That statute directs the disposition of "all fees, civil penalties and any other money collected pursuant to the provisions of NRS 598.0903 to 598.0999, inclusive."[38] Money collected in the course of an action initiated by the Attorney General goes to the State General Fund.[39] Money collected in the course of an action initiated by a district attorney goes to the county treasurer.[40] The only exceptions to the required disposition of funds collected pursuant to NRS 598.0999 are: (1)
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[37] Butler v. State, 120 Nev. 879, 892-93, 102 P.3d 71 (2004) ("Statutes should be given their plain meaning and 'must be construed as a whole and not be read in a way that would render words or phrases superfluous or make a provision nugatory. Further, every word, phrase, and provision of a statute is presumed to have meaning." (footnote omitted) (quoting Charlie Brown Constr. Co. v. Boulder City, 106 Nev. 497, 503, 797 P.2d 946 (1990); overruled on other grounds, Calloway v. City of Reno, 116 Nev. 250, 993 P.2d 1259 (2000)).
[38] NRS 598.0975(1) (emphasis added).
[39] See NRS 598.0975(1)(a).
[40] See NRS 598.0975(1)(b).
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criminal fines;[41] and (2) "restitution."[42] The first category, criminal fines, is not at issue in this appeal.
As to the second, NRS 598.0975 directs:
Money collected for restitution ordered in such an action must be deposited by the Attorney General and credited to the appropriate account of the Attorney General for distribution to the person for whom the restitution was ordered.[43]
NRS 598.0975 comprehensively addresses money collected pursuant to NRS 598.0999 and directs the disposition of that money. And there is no category of money which flows directly from a judgment debtor, such as ZANDIAN, to a judgment creditor, such as MARGOLIN. This conclusively establishes that NRS 598.0999 does not provide authorization for an award of attorneys' fees in a private cause of action.
Third, even if it was applicable to MARGOLIN's claim in general, the provision does not apply to post-judgment attorneys' fees which the Motion requested and the Order granted. Nothing in the language of the provision expresses or implies that it authorizes any
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[41] Presumably, such fines are disbursed in the same manner as other criminal fines.
[42] NRS 598-0975(3)(b).
[43] Id.
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award subsequent to a judicial adjudication that there has been a violation of Chapter 598 of Nevada Revised Statutes.
Fourth, the provision at issue has been the law in Nevada since July 1, 2001.[44] It has not previously been interpreted by this Court to authorize an award of attorneys' fees to a private litigant like MARGOLIN.
And, finally, even if the language of NRS 598.0999 could plausibly be stretched to allow for an award of attorneys' fees in private litigation, the award in this case is not consistent with the jurisprudence of this Court. This Court has consistently held that only an "express" authorization evident in the "plain language" of a statutory provision justifies deviation from the American Rule. At a minimum, the language of NRS 598.0999 is ambiguous enough that its application to this case is not "express" or "plain" and, for that reason, the extension of the language to private litigation should be rejected.
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[44] See 2001 Stat. of Nev. 482.
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III. The District Court abused its discretion in authorizing specialized fee rates for routine legal work.[45]
As noted hereinabove, the District Court enjoys discretion in determining the amount of a reasonable fee award when such an award is authorized by law. But that discretion is not without restraint. Brunzell v. Golden Gate Nat'l Bank [46] established the framework by which fees are to be evaluated. That Brunzell framework involves consideration of several factors in determining the reasonable value of legal services.[47] One factor, the most pertinent in this case, requires the District Court to consider "the character of the work to be done: its difficulty, its intricacy, its importance, time and skill required ...... [48]
Most of the legal work during the time frame addressed in the Motion was completed by two attorneys for MARGOLIN, both of whom charged at a rate of $300 per hour.[49] MARGOLIN claimed that
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[45] If the Court determines that NRS 598.0999 does not support the District Court's award in the Order, the issue addressed in this Section III is rendered moot and need not be reviewed.
[46] 85 Nev. 345, 455 P.2d 31 (1969).
[47] See Brunzell, 85 Nev. at 349-50, 455 P.2d at 33-34.
[48] Brunzell, 85 Nev. at 349, 455 at 33 (emphasis in original).
[49] See J.A. Vol. IV at 553 ("The amount of attorney's fees awarded only includes reasonable attorney's fees from October 18, 2013 to April 18, 2014, as follows: 11.4 hours of work performed by [Attorney 1] at $300 per-hour ($3,420.00); [and] 75.3 hours of work performed by [Attorney 2] at $300 per-hour ($22,590-00).")
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this elevated hourly rate was necessary due to counsels' experience and specialized skills in regard to "patent and deceptive trade practices litigation" which is a "niche practice that requires a high degree of legal skill and care in order to be performed properly and effectively."[50] Noting that "the customary fee charged by attorneys with our experience for similar patent and deceptive trade practices matters in Nevada ranges between $275-$450 per-hour," MARGOLIN's counsel argued that the $300 hourly fee was an appropriate rate for the work performed from October 18, 2013 through April 18, 2014.[51]
While it may very well be the case that an attorney experienced and specialized in patent and intellectual trade practice issues justifies a rate of $300 per hour, that rate is not consistent with the work at issue here. Subsequent to the Default Judgment, there was no need for a specialist as the work entailed only common and generalized legal issues. Specifically, the work of MARGOLIN's counsel from October 2013 to April 2014 involved collection efforts
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[50] J.A. at Vol. III, 416, 419-23.
[51] J.A. at Vol. III, 420.
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toward satisfaction of the Default Judgment and oppositions to ZANDIAN's efforts to set aside and stay the Default Judgment.[52] This work does not implicate any need for a legal specialist—and certainly not a specialist in such a highly technical field as patent and trade practice law. While MARGOLIN has every right to employ and to pay for the services of whomever he wishes to perform work related to his case, the work at issue in regard to the District Court's Order simply did not require that. As there is no question a more generalized practitioner with much less experience could have performed the function equally as well, the District Court should have reduced the rate to reflect the non-specialized rate of a general practitioner.
For this reason, the District Court abused its discretion in applying a rate of $300 per hour for the attorneys involved in this case, and the Order should be reversed and remanded on that basis.
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[52] See J.A. at Vol. I, 44 - Vol. IIII, 410; Docket Sheet at 3-4 (Nov. 5, 2014) (Zandian v. Margolin, Nevada Supreme Court case number 65960).
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CONCLUSION
ZANDIAN respectfully requests that this Court reverse the District Court's Order on Motion for Order Allowing Costs and Necessary Disbursements and Memorandum of Points and Authorities in Support Thereof, and remand this matter to the District Court for further proceedings consistent with its ruling.
DATED this 12th day of November, 2014.
KAEMPFER CROWELL
BY ______________________
JASON D. WOODBURY
Nevada Bar No. 6870
510 West Fourth Street
Carson City, Nevada 89703
Telephone: (775) 884-8300
Facsimile: (775) 882-0257
Attorneys for Appellant, REZA ZANDIAN
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CERTIFICATE OF COMPLIANCE
1. I hereby certify that this brief complies with the formatting requirements of NRAP 32(a)(4), the typeface requirements of NRAP 32(a)(5) and the type style requirements or NRAP 32(a)(6) because:
[X] This brief has been prepared in a proportionally spaced typeface using Microsoft Word 2003 in 14 point Georgia font;
or
This brief has been prepared in a monospaced typeface using [state name and version of word processing program] with [state number of characters per inch and name of type style].
2. I further certify that this brief complies with the page or type-volume limitations of NRAP 32(a)(7) because, excluding the pasts of the brief exempted by NRAP 32(a)(7)(c), it is either:
[X] Proportionally spaced, has a typeface of 14 points or more and contains 2,539 words; or
[ ] Monospaced, has 10.5 fewer characters per inch, and contains _____ words or _____ lines of text; or
[ ] Does not exceed _____ pages.
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3. Finally, I hereby certify that I have read this appellate brief, and to the best of my knowledge, information, and belief, it is not frivolous or interposed for any improper purpose. I further certify that this brief complies with all applicable Nevada Rules of Appellate Procedure, in particular NRAP 28(e)(1), which requires every assertion in the brief regarding matters in the record to be supported by a reference to the page and volume number, if any, of the transcript or appendix where the matter relied on is to be found. I understand that I may be subject to sanctions in the event that the accompanying brief is not in conformity with the requirements of the Nevada Rules of Appellate Procedure.
DATED this 12th day of November, 2014.
______________________________
JASON D. WOODBURY
Bar No. 6870
KAEMPFER CROWELL
510 West Fourth Street
Carson City, NV 89703
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CERTIFICATE OF SERVICE
Pursuant to NRAP 25(1), I declare that I am an employee of Kaempfer Crowell and on this 12th day of November, 2014, I served a copy of the foregoing Appellant's Opening Brief by Nevada Supreme Court CM/ECF Electronic Filing addressed to each of the following:
Adam P. McMillen
WATSON ROUNDS
5371 Kietzke Lane
Reno, NV 89511
DATED this 12th day of November, 2014.
__________________________
an employee of Kaempfer Crowell
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