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1 From: DORPTO Sent: Monday, February 09, :53 AM To: DORPTO Subject: Rule Development Workshop February 24, 2015 MEMORANDUM TO: Property Appraisers, Tax Collectors, Clerks of the Court, Value Adjustment Board Clerks, Boards of County Commissioners, Taxing Authorities and Interested Parties FROM: Property Tax Oversight SUBJECT: Rule Development Workshop February 24, 2015 DATE: February 9, 2015 The Department of Revenue announces that it will hold a rule development workshop on February 24, 2015, to discuss proposed new Rule 12D , F.A.C., proposed changes to rules in Rule Chapter 12D- 9, F.A.C., and proposed revisions to forms. The Florida Administrative Register (F.A.R.) gave notice of this public workshop on February 2, 2015 (Vol. 41, No. 21). These rules are: Proposed new Rule 12D , F.A.C. ( Transfer of Homestead Assessment Difference; Portability ; Sworn Statement Required; Denials; Late Applications). Amended Rule 12D-9.001, F.A.C. (Taxpayer Rights in Value Adjustment Board Proceedings). Amended Rule 12D-9.007, F.A.C. (Role of the Clerk of the Value Adjustment Board). Amended Rule 12D-9.015, F.A.C. (Petition; Form and Filing Fee). Amended Rule 12D-9.019, F.A.C. (Scheduling and Notice of a Hearing). Amended Rule 12D-9.020, F.A.C. (Exchange of Evidence) Amended Rule 12D-9.025, F.A.C. (Procedures for Conducting a Hearing; Presentation of Evidence; Testimony of Witnesses). Amended Rule 12D , F.A.C. (Index to Forms). These forms are: Form DR-501TS, Designation of Ownership Shares of Abandoned Homestead. Form DR-481, Value Adjustment Board Notice of Hearing. Form DR-486, Petition to the Value Adjustment Board Request for Hearing. Form DR-486PORT, Petition to the Value Adjustment Board Transfer of Homestead Assessment Difference Request for Hearing. The agenda for this workshop includes information for participating in this meeting through our teleconference system and is posted on the department s website at: Please forward any comments or questions to Public Comments 1

2 From: Coffey, Amanda S Sent: Wednesday, February 11, :33 PM To: DORPTO Cc: Dubov, Pamela; Moore, Erin Subject: RE: Rule Development Workshop February 24, 2015 Good afternoon, Thank you for the opportunity to provide feedback on the proposed rule changes to be discussed at the public workshop on February 24 th. Please consider the comments below as you deliberate the proposed changes. 1. In the proposed changes to FAC 12D-9.019(g), 12D-9.015(1)(e), 12D-9.015(2)(12), 12D (1)(d), and 12D-9.025(6)(c)(3), as well as on proposed Forms DR-486 and DR-486PORT, the following language is added in relation to a taxpayer s right to receive a property record card: [the Property Appraiser must provide a] property record card containing relevant information used in computing the current assessment... unless the property record card is available online from the property appraiser; (Note: the section following the ellipsis is not included in FAC 12D-9.020(1)(d) and 12D-9.025(6)(c)(3)). The language containing relevant information used in computing the current assessment is ambiguous and, to some degree, inaccurate. A property record card generally includes physical characteristics of a parcel, but may not include other information used in computing assessments, such as market data, comparable sales information, mass appraisal factors and calculations, etc.. A more appropriate statement would be:... containing relevant property data as reflected on the current tax roll, if requested, unless the property record card is available online from the property appraiser;. Other appraisal information, such as comparable sales data, is made available in other formats. Your consideration is appreciated. If you have any questions, please do not hesitate to contact me at the or phone number below. Sincerely, Amanda S. Coffey Assistant County Attorney representing the Pinellas County Property Appraiaser Pinellas County Attorney's Office 315 Court Street, 6th Floor Clearwater, FL Phone: (727) Fax: (727) All government correspondence is subject to the public records law. Public Comments 2

3 From: Cathy Mills Sent: Friday, February 13, :41 PM To: DORPTO Subject: February 24, 2015 Development Workshop I have two comments: 1. I am still confused by the wording on the evidence exchange time frame. "...count until the end of the next previous day" reads very strangely. If the holiday is Monday, that sentence is not going to solve the issue is it? How about, if the due date falls on a Saturday, Sunday or holiday, count back to the first prior work day? 2. Please consider the changes below to Part 2 of the information provided on page 2 of DR-486. Public Comments 3

4 Cathy A. Mills, Deputy Clerk Leon County Value Adjustment Board BOB INZER, Clerk of the Circuit Court and Comptroller (direct line) (Clerk Administration) (fax) Clerk Administration Division 301 S. Monroe Street, #100 Tallahassee, FL Refer to the Clerk's website for detailed information regarding the VAB process in Leon County. The Clerk welcomes your feedback. Share your comments on the service you received by clicking this link: Feedback from Website Under Florida law, s received by the Clerk's Office are public records. Both the message and the address it was sent from (except any information that is exempt from disclosure under State law) may be released in response to a public records request. Public Comments 4

5 From: Todd Jones Sent: Monday, February 16, :40 PM To: DORPTO Subject: Feb 24, PTO Rule Development Workshop The proposed language in 12D (10) requires additional verbiage, as underlined below: "Notification of the petitioner must be by first class mail with proof of delivery, commercial carrier, or by electronic means by following the steps described in Section , F.S." The DR-481 & DR-486 forms should: (1) In the heading, alert taxpayers that the Property Appraiser is an adverse party in these proceedings, and (2) provide a check box for communication delivery preference (i.e. swap placement of the and Phone boxes). Thank you, Todd Jones, President Florida Association of Property Tax Professionals Public Comments 5

6 From: SMA Sent: Tuesday, February 17, :50 AM To: DORPTO Cc: Sarah Wachman; April Warner; Subject: RE: PUBLIC RECORD ACT REQUEST RE: Rule Development Workshop February 24, 2015 Ms. Kemp what you do not understand is not clear. I d like to know who, if anyone, made a request for this rule development workshop. AND, I would like to add references to the new requirements related to compliance with the Ethics statutes as well as any sections in the Rules that related to that part of Module 2 which specifically includes the language related to VAB attorneys. In addition there is no description of public hearings anywhere in the Rules and there are several specific examples in various jurisdictions where either Hearings are not conducted in public facilities and therefore are hidden OR are behind closed doors in public facilities so that public observation is not possible. Since Chapter 192 see Due Process provides petitioners with the RIGHTS to public hearings, there is an obvious need to identify the physical characteristics that comply with that mandate. If you have any other questions, call me at SMA Public Comments 6

7 Public Comments 7

8 Public Comments 8

9 From: To: Subject: Date: Katherine Reardon DORPTO February 24, 2015 Development Workshop Tuesday, February 24, :36:29 AM 12d-p.025 is seems to contradict the changes taking the clerk out of the property record card loop. Katherine Reardon, CFE Investigation Manager Sarasota County Property Appraiser's Office (941) direct line Notice: If you should decide to communicate with us by , the Sarasota County Property Appraiser s office cannot guarantee the confidentiality of any information sent to us by . Florida has a very broad public records law. Most written communications to or from this office regarding business are public record and available to the public and media upon request. This and any response may therefore be subject to public disclosure unless reasons for nondisclosure are stated and referenced to applicable law. We recommend that you send confidential information to us by postal mail rather than . Public Comments 9

10 From: To: Subject: Date: Joy Hearn DORPTO February 24, 2015 Development Workshop Tuesday, February 24, :39:53 AM A property record card should be provided by the Property Appraiser. But who determines what is relevant. In my opinion this is open to all kinds of abuse primarily from tax agents. Joy Hearn Public Comments 10

11 From: Terri Pendarvis To: DORPTO Subject: Rule Development Workshop February 24, 2015 Date: Tuesday, February 24, :40:26 AM Good Morning, "My concern is on 12D-9.019(7)(b) states a petitioner has the right to inform the board clerk that he or she intends to leave, but need not exercise that right" My thoughts are the petitioner should be responsible for telling the clerk they are leaving. Otherwise they will remain on the sign-in sheet as being present, but when the hearing begins, it appears a no-show has occurred due to the petitioner leaving prior to the start of a hearing. Thank you. Terri Pendarvis Administrative Coordinator/Deputy Clerk Budget and Administrative Services and Value Adjustment Board 123 W. Indiana Avenue, Ste 304 Deland, FL Budget Office: (386) VAB Office: (386) Fax: (386) Public Comments 11

12 From: To: Subject: Date: Attachments: Beck, Wendy DORPTO RE: February 24, 2015 Public Rule Development Workshop Tuesday, February 24, :40:55 AM image001.png 12D in 12 I suggest implementing a time requirement for the property appraiser to send the card, I suggest 5 days from receipt of the petition. There was previously a time requirement for the clerk to send it, i.e. no later than time the notice of hearing is sent. Wendy Beck Wolansky, Esq. vcard Rennert Vogel Mandler & Rodriguez, P.A. 100 SE 2nd Street, Suite 2900, Miami, FL PHONE: , FAX: , DISCLAIMER From: Beck, Wendy Sent: Tuesday, February 24, :11 AM To: Subject: February 24, 2015 Public Rule Development Workshop I would like to make several comments verbally by phone. My name is Wendy Beck Wolansky and I am an attorney. The subject matter of the comment is: Comment to 12D (b)2--remove the words "and resided' in the 2nd line, as this is not the legal requirement for homestead. It must be the permanent residence of the owner, or his dependent. There are a number of requirements, and better drafting to just leave it with applied and received. So long as the person had the exemption, he or she is entitled to port the difference and allocate it according to this new provision. Comment to 3(a)-remove last sentence "Form DR-501T is submitted s an attachment to Form DR- 501, Original Application for Ad Valorem Tax Exemption, (incorporated by reference in Rule 12D , F.A.C.)--this does not make sense because one can apply for portability in years after he or she has already established a homestead, as such there should be no requirement to attach 501T to the original application. Wendy Beck Wolansky, Esq. vcard Rennert Vogel Mandler & Rodriguez, P.A. 100 SE 2nd Street, Suite 2900, Miami, FL PHONE: , FAX: , DISCLAIMER Public Comments 12

13 From: To: Subject: Date: Attachments: Beck, Wendy DORPTO RE: February 24, 2015 Public Rule Development Workshop Tuesday, February 24, :42:52 AM image001.png Comments on the forms: DR-481-must contain the words "within a reasonable time before the hearing" after the end of the last full paragraph (beginning You may not present, and the board or special magistrate may not consider,...and denied to the property appraiser ADD "WITHIN A REASONABLE TIME BEFORE THE HEARING." Same comment to page 2 on DR-487, end of first column "You may not present..." Same comment to page 2 on DR-486 PORT Wendy Beck Wolansky, Esq. vcard Rennert Vogel Mandler & Rodriguez, P.A. 100 SE 2nd Street, Suite 2900, Miami, FL PHONE: , FAX: , DISCLAIMER From: Beck, Wendy Sent: Tuesday, February 24, :11 AM To: Subject: February 24, 2015 Public Rule Development Workshop I would like to make several comments verbally by phone. My name is Wendy Beck Wolansky and I am an attorney. The subject matter of the comment is: Comment to 12D (b)2--remove the words "and resided' in the 2nd line, as this is not the legal requirement for homestead. It must be the permanent residence of the owner, or his dependent. There are a number of requirements, and better drafting to just leave it with applied and received. So long as the person had the exemption, he or she is entitled to port the difference and allocate it according to this new provision. Comment to 3(a)-remove last sentence "Form DR-501T is submitted s an attachment to Form DR- 501, Original Application for Ad Valorem Tax Exemption, (incorporated by reference in Rule 12D , F.A.C.)--this does not make sense because one can apply for portability in years after he or she has already established a homestead, as such there should be no requirement to attach 501T to the original application. Wendy Beck Wolansky, Esq. vcard Rennert Vogel Mandler & Rodriguez, P.A. Public Comments 13

14 100 SE 2nd Street, Suite 2900, Miami, FL PHONE: , FAX: , DISCLAIMER Public Comments 14

15 From: To: Subject: Date: Foglesong, Carol DORPTO 12D and multiple other sections Tuesday, February 24, :43:06 AM We have been asked by our petitioners to express their concern that the Property Appraiser s online property record card does not contain the same or sufficient information when compared to the physical property record cards. cf Carol Foglesong Assistant Comptroller, Records Administration Division Orange County Comptroller's Office PO Box 38 Orlando, FL (office phone) ( ) Public Comments 15

16 From: To: Subject: Date: Joy Hearn DORPTO February 24, 2015 Development Workshop Tuesday, February 24, :43:24 AM Two hour window rule The two hour window may not be enough if every body signs in late with a 2 hour window. How do you handle that when the rule says they have to be heard 2 hours from the beginning? Joy Hearn Public Comments 16

17 From: To: Subject: Date: Mitchell Taitano DORPTO A question Tuesday, February 24, :45:03 AM I thought I heard you mention that the property appraiser would be providing property record cards, so why then on the new proposed forms of the DR-486 and DR-481 is there a checkbox of: Send me a copy of the real property record card, on the DR-486 and the Enclosure of the Property record card on the DR-481. Tyler Gibson Pioneer Technology Group Software Support Specialist office: fax: toll free: Central Park Drive, Suite 100 Sanford, FL twitter.com/pioneertech Public Comments 17

18 From: Dixon, Sandra To: DORPTO Subject: RE: Rule Development Workshop February 24, 2015 Date: Tuesday, February 24, :50:40 AM Name: Sandi Dixon - VAB Clerk with Orange County VAB Comment 1: form DR-486 (section PART 2. Petition Information) denial for late filing of exemption or classification has been revised to read late filing of exemption or classification Does this mean it is no longer required for the petitioner to receive a denial letter from the property appraiser before they file a petition? Comment 2: form DR-486 (section PART 2. Petition information Additional information) The language used regarding joint petitions has been removed from the petition form and added to the instructions on page 2. The language has been revised, possibly leaving it open to interpretation. Currently reads: Attach a list of parcels with property appraiser s determination that parcels are substantially similar. Revised language: If available, include the property appraiser s determination that the parcels are substantially similar. Currently, for a petition to be considered a joint petition, the petitioner must include the PAO determination that the parcels are contiguous. With this revised language, if the petitioner does not provide that determination with the petition, does the VAB clerk issue a CN requesting that documentation be provided within 10 days of the notice? Public Comments 18

19 From: To: Subject: Date: Foglesong, Carol DORPTO 12D-9.007(10) and Forms Tuesday, February 24, :50:47 AM I call your attention to the following: The statute reads, On the form used to obtain the recipient's written consent, the sender must include a statement in substantially the following form and in a font equal to or greater than the font used for the text requesting the recipients' consent: NOTICE: Under Florida law, addresses are public records. By consenting to communicate with this office electronically, your address will be released in response to any applicable public records request. The revised petition form does not include the language shown above. I see the petition form as the form used to obtain the recipient s written consent. It seems that the language should be shown on the petition form. cf Carol Foglesong Assistant Comptroller, Records Administration Division Orange County Comptroller's Office PO Box 38 Orlando, FL (office phone) ( ) Public Comments 19

20 From: Terri Pendarvis To: DORPTO Subject: Rule Development Workshop February 24, 2015 Date: Tuesday, February 24, :56:36 AM Good Morning, Under 12D-9.020(2) If the board clerk reschedules for good cause under this rule - does this reschedule constitute a one-time reschedule, a good-cause reschedule, or neither. This is not mentioned on the suggested rule change and this leaves this area open for interpretation. This area mentions good cause reschedule; from experience this is confusing language. I think it would be best for this concern to be addressed with the rule change. Thank you. Terri Pendarvis Administrative Coordinator/Deputy Clerk Budget and Administrative Services and Value Adjustment Board 123 W. Indiana Avenue, Ste 304 Deland, FL Budget Office: (386) VAB Office: (386) Fax: (386) Public Comments 20

21 From: To: Subject: Date: Foglesong, Carol DORPTO 12D-9.019(3)4 and 12D-9.020(1)(a)2: Tuesday, February 24, :58:59 AM 1) 12D (3)4 : we suggest adding the following words shown in bold, The Notice of Hearing should include instructions just under the area providing contact information for a list of potential magistrates and for a copy of the VAB rules of procedure. 2) 12D (1)(a)2: We recommend the following language: A rescheduling under this paragraph is not considered to be a request to reschedule as provided in paragraph (4)(a). cf Carol Foglesong Assistant Comptroller, Records Administration Division Orange County Comptroller's Office PO Box 38 Orlando, FL (office phone) ( ) Public Comments 21

22 From: To: Subject: Date: Dena Pittman DORPTO February Development Workshop Tuesday, February 24, :54:47 AM Comment on Petitioner s need to provide adequate evidence as to why he/she believes the PA s assessment is incorrect: Reason for filing. It is very common for the petitioner to provide a print out from our Website that lists sales, including disqualified sales, and provide no work-up or break-down as to what the evidence is supposed to be representing. Nor are they required to prove that the PA information is incorrect. A petitioner can file a petition, and win with absolutely no evidence, while the PA has to provide a complete work-up, which takes many hours of research and preparation, while the petitioner is required to provide nothing. The Appraiser may make a statement we didn t consider that, lose presumption and the petitioner wins an on the spot appraisal done by a magistrate, who may not be at all familiar with the area, and get a bogus value, all the while doing nothing to prove the PA value was incorrect. Dena R Pittman Dena Pittman, CFE Chief Deputy Hendry County Property Appraiser Under Florida law, addresses are public records. If you do not want your address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in writing. SB 80/Chapter , Laws of Florida (Public Records Law Regarding ) Public Comments 22

23 Public Comments 23

24 Public Comments 24

25 From: SMA Sent: Wednesday, February 25, :38 PM To: DORPTO Cc: Subject: COMMENTS ON FEBRUARY 24 WORKSHOP 1. On the new DOR web site, the following sentence is NOT complete. It should include reference to the Chair of the Value Adjustment Board and/or the taxpayer s representative on the County Commission. Since property tax is administered locally, the best resources for assistance with property tax matters are the property appraiser and the tax collector in the property owner's county. 2. In the comments posted on line, there is a reference made by Todd Jones regarding proof of delivery in the evidence exchange. I prefer to have PA VAB evidence delivered via REGULAR US Mail because certified mail can lead to several days of delay in my receipt of mail, and that s not helpful because the mail is not delivered to the door rather across the road, never comes at the same time two days in a row, and substitute postal workers may not bring certified mail to the door of my office. Therefore, I suggest having a box or some check=off for whether a petitioner wants US Mail delivered regular or certified because notwithstanding all the variables it remains my preference to receive PA s evidence through US Mail and NOT certified. 3. There is a systemic need for at least two forms. One form should be a uniform application for VAB attorneys and VAB special magistrates and those forms should include detailed information about who has taught continuing education courses to the applicant, and whether any applicant has been an expert witness in litigation or an attorney in litigation involving any government entity with dates provided. In addition, the special magistrate applications should ask for disclosures related to service in other jurisdictions. And the applications should ask for state ethics training information who taught whatever course has been taken, when, and where to document compliance with recent changes to Chapter The other needed form is for Property Record Cards actually two different types covering real property and tangible personal property. Data needs to include, but should not be limited to, classification per DOR s classification list, qualified or unqualified transaction indicators, method used, and there are examples in a variety of jurisdictions covering cost related information and income related information which could be consolidated into one document if reviewed through a public process. See Miami-Dade for links to property record cards including much cost data BUT no income data while older property record cards from Orange County include, as applicable, income information but those records are not currently posted on line. There also are some concerns to be expressed related to TPP if those records are posted since valuable assets could proffer exposure therefore some discussion should be had to discuss the best ways to provide those records TIMELY to petitioners without creating unintended invitations to be robbed. SMA Public Comments 25

26 Sheila M. Anderson, Principal Commercial Property Services, Inc. Licensed Real Estate Broker / Profile: Public Comments 26

27 From: To: Subject: Date: Maria Suesz DORPTO Public Workshop 2/24/ additional comments Monday, March 02, :32:10 PM Hello, I am sending you my suggestions regarding the Form DOR-486, Petition to the Value Adjustment Board Request for Hearing. In the Information for the taxpayer, Part 2. Petition Information please eliminate the words if available. This language does not comply with F. S (e) and (f). I suggest you modify the language regarding Joint Petition to read: For a single petition for multiple parcels, attach a list of parcels along with the Property Appraiser s determination that the parcels are substantially similar etc. Thank you, Maria I. Suesz Maria I. Suesz Supervisor Clerk to the Board and Value Adjustment Board Indian River County Administration Buildingi A th Street Vero Beach, Florida Under Florida law, addresses are public records. If you do not want your address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in writing. Public Comments 27

28 From: Sara Cucchi Sent: Tuesday, March 10, :53 PM To: DORPTO; Marshall Stranburg; Andrea Moreland Cc: Vincent Aldridge; Danielle Scoggins; Steve Keller; Gary Moreland; Sarah Wachman; George Hamm Subject: Comments on 1/29/15 Draft Rules The Department of Revenue s 1/29/15 Draft Rules are an improvement over previous efforts which ignored legislative enactments. Below are comments to these Draft Rules. 1. [T]he Property Appraiser s online property record card does not contain the same or sufficient information when compared to the physical property record cards. I agree with this comment made by Orange County VAB Clerk staff on February 24, I previously informed the Department of this problem, and the Department has done nothing to address this taxpayer-hostile deficiency. In an dated October 15, 2014, Marshall Stranburg stated the Department was conducting some type of survey regarding the content of property record cards among counties. Please provide a copy of this survey, the results, and any related summaries, analyses, etc. 2. The Department s Draft Rule 12D-9.025(6)(c)3., does not make clear that the property record card is to be provided to the taxpayer by the property appraiser and not the VAB clerk. I agree with the comment on this issue made by the Sarasota property appraiser s office on February 24, The VAB clerk is responsible for sending the hearing notice, but under section (2)(a), F.S., (Ch , LOF) the property appraiser, not the clerk, is responsible for sending the property record card. 3. Previously, the taxpayer received the property record card at least 25 days before the hearing along with the hearing notice from the VAB clerk. Now, in Draft Rule 12D-9.020(2), the Department is moving the date the taxpayer receives the property record card to 7 days in advance of the hearing, which is taxpayer-hostile particularly since the property record card is a public record. I agree with the comment made by Wendy Beck on February 24, 2015, that the timing for the taxpayer getting the property record card needs improvement. 4. Taxpayers have a right to receive from the property appraiser, a copy of their property record card even if they don t they participate in the evidence exchange. The instructions on page 2 of Draft Forms DR-486 and DR 486 PORT do not inform taxpayers that a lack of participation in evidence exchange does not interfere with the taxpayer s right to obtain from the property appraiser a copy of the property record card containing relevant information used in computing the assessment. Please add text to these forms informing taxpayers Public Comments 28

29 that they have a right to obtain a property record card from the property appraiser regardless of whether the taxpayer initiates evidence exchange. Please note that it would have been transparent and helpful for the Department of Revenue to post on its website the transcript of the February 24, 2015 workshop, prior to concluding its public comment period. Thank you, Sara Cucchi Public Comments 29

30 From: To: Subject: Date: Terry Harmon DORPTO Public Comment - Proposed Rule and Form Amendments Tuesday, March 10, :55:44 PM Good afternoon: Our Firm serves as legal counsel to the Leon County Property Appraiser s Office ( LCPA ). On behalf of LCPA, I am submitting the following comments/questions with respect to the proposed new and amended rules and forms: 1. How will DOR handle the terms wife and husband in the various rules and forms in light of same-sex marriages? 2. Regarding Rule 12D-9.001(2)(g), 12D-9.015(1)(e) and (12), 12D-9.020(1)(d), as well as the corresponding forms, can DOR please define relevant information so as not to cause future litigation between taxpayers and property appraisers regarding what constitutes relevant information used in computing assessments? Is there justification for even needing to include this term? Thank you for your time and consideration of these comments and questions. Please feel free to contact me directly if you need clarification. Regards, Terry Terry J. Harmon, Esquire SNIFFEN & SPELLMAN, P.A. 123 North Monroe Street Tallahassee, Florida Telephone: (850) Facsimile: (850) Website: IMPORTANT NOTICE REGARDING COMMUNICATION: With changes in technology, the Firm is aware that is a common method of communication; however, please keep in mind the following: (1) clients should never use computers maintained or monitored by others (e.g., work; public computers) when communicating about sensitive or attorney-client matters; (2) incoming s may not be read immediately, because the intended recipient may be out of the office or otherwise unavailable; if your communication is time-sensitive, please call our office to ensure we are aware of your ; and (3) the Firm uses automated filters to block viruses and unwanted s. It is possible the Firm s network may not recognize your address and prevent your s from being properly delivered. Please call our office if we have not responded to your within a reasonable time or if the matter is time-sensitive. CONFIDENTIALITY NOTICE: Information in this may be protected from distribution by law, confidential, or protected from disclosure by the attorney-client privilege. It is intended only for the use of the disclosed individual or entity. If you are not the intended recipient of this communication, you are hereby notified that the law may restrict or prohibit the unintended use, copying or distribution of this communication. If you have received this Public Comments 30

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