Reducing Liability Uncertainty When Redeveloping...

Reducing Liability Uncertainty When Redeveloping

Environmentally Challenged Property: Federal vs. State

Liability Protections, Defenses, and Due Care Obligations

During Property Acquisitions

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THURSDAY, AUGUST 8, 2019

Presenting a live 90-minute webinar with interactive Q&A

Charles B. Howland, Partner, Curtis Mallet-Prevost Colt & Mosle, New York

Megan M. Roberts-Satinsky, Attorney, Linowes and Blocher, Annapolis, Md.

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Reducing Liability Uncertainty When Redeveloping

Environmentally Challenged Property

Charles Howland, Curtis, Mallet-Prevost & Mosle LLP

Megan Roberts-Satinsky, Linowes and Blocher LLP

❖ CERCLA and RCRA Corrective Action overview❖ Latest developments from EPA’s Superfund Task

Force reform and RCRA reuse/redevelopment efforts

❖ State “mini superfunds” and voluntary cleanup programs overview

❖ Similarities and differences across the programs❖ Strategic and practical considerations for moving a

site forward under particular programs

Overview of today’s program

6

❖ Fear of unknown, potentially unlimited liability❖ Similarities & differences re “certainty’ under

federal, state cleanup programs❖ How recent developments in law, government

guidance, and government practice signal agencies’ renewed willingness to address these issues

Overarching issues

7

❖ Assumptions➢ New buyer/lessee is acquiring an interest in potentially

contaminated land➢ A governmental agency may already be (or once have been)

involved w/ site, or not.➢ Not all buyers have same goals/risk tolerance.

❖ Your goals➢ Minimize & quantify potential cleanup liabilities➢ Maximize the likelihood of a reuse scenario that is acceptable

to all stakeholders■ Financial backers■ Environmental regulatory agencies■ Local planning/zoning agency■ Neighbors

What is “certainty”?

8

❖ “Certainty’ v/v liability➢ Self-executing ‘safe harbor’, or negotiated w/

government/3d party?

❖ “Certainty” v/v business interruption➢ If new construction, will the project get financed & built? ➢ Once built, will your business be interfered with?

❖ Today’s focus is on certainty regarding environmental liabilities, but the issue feeds how other forms of uncertainty are handled.

What is “certainty”?

9

❖ Where in the arc of site response is the property?➢ Identification » investigation » remedy selection »

remediation » 'completion'?

❖ What does “cleanup” actually mean?➢ What assumptions re final exposure?➢ Remedy:

■ Actual removal?■ In situ treatment?■ Cap w/ institutional controls?■ Other?

❖ How long will the investigation & cleanup take?

Useful questions & issues re “certainty”

10

❖ Distinguish government as:➢ Controller of remedy process➢ Imposer/protector re cleanup liability➢ Controller of land use

❖ What government agency (if any) will control how these questions & issues are addressed?➢ Federal?➢ State?➢ Local only (via zoning, land use controls)?

❖ What are your levers of influence w/ agencies re these issues, and when, where, & how do your exercise them?

Useful questions & issues re “certainty”

11

CERCLA “Brownfield,”“Eligible Response Site”

❖ Key terms for several aspects of “certainty” discussed below❖ Per § 101(39), “Brownfield:”

➢ “real property, the expansion, redevelopment, or reuse of which may be complicated” by the presence of a HS, pollutant, or contaminant.”

➢ Adds in: petroleum, “controlled substances,” mine scarred lands➢ Excludes sites:

■ Current/future CERCLA Removal action■ NPL sites, proposed or final■ Federal facilities■ Facility subject to an order issued under CERCLA, RCRA, CWA,

TSCA PCB cleanup order, or SDWA

❖ Per § 101(41), ERS = “Brownfield,” further excluding:➢ CERCLA NPL/HRS scored, unless EPA determines that “no further

Federal action will be taken” (NOFA)➢ Site of spcl. consideration (i.e.threat to a sole-source drinking water

aquifer or sensitive ecosystem12

SDWA 1431 Orders

~ 7,000 RCRA permit closure sites

40,000 SEMS (née CERCLIS) sites ~1,340 CERCLA

remedial (NPL) sites

~ 11,000 CERCLA Removal sites

3,779 RCRA Corrective Action sites

(‘2020 Universe’)

Whose cleanup jurisdiction: Fed. or State?

TSCA PCB Cleanup orders

13

SDWA 1431 Orders


450,000+ CERCLA “Brownfields” (“Eligible Response Sites” ±), cleanups overseen by states, under Voluntary Cleanup Programs or ‘mini Superfunds’ CERCLA 128(a) assessment & cleanup funding

may be available CERCLA 128(b) enf. bar on EPA 106 & 107

actions at ERSs

100,000-200,000 RCRA LUSTs

(abandoned), Fed. prog. implemented

by states








14

SDWA 1431 Orders




actions at ERSs

100,000-200,000 RCRA LUSTs

(abandoned) Fed. prog. Implemented

by states








• CERCLA 101(41)(B)(ii) ‘deferral’ of non S’fund fed. sites back to state

• [EPA/State MOAs?]• If state program protective, & • To promote economic development, or help

create/preserve green space.

15

SDWA 1431 Orders




actions at ERSs

100,000-200,000 RCRA LUSTs

(abandoned) Fed. prog. Implemented

by states








• CERCLA 101(41)(B)(ii) ‘deferral’ of non S’fund fed. sites back to state

• [EPA/State MOAs?]• If state program protective, & • To promote economic development, or help

create/preserve green space.• Defer/Delist NPL sites back to states

midstream? (Not per current EPA guidance; no 128(b) enf. bar.)

16

❖ 1970s: Inadequacy of RCRA apparent➢ Love Canal, “Valley of the Drums”

❖ CERCLA passed 1980❖ Broad response authorities to deal with contaminated sites

➢ initially financed with several taxes on chemical and petroleum industries, lapsed in 1985

❖ Amendments re “certainty”➢ Superfund Amendments and Reauthorization Act of 1986➢ Asset conservation, Lender Liability, And Deposit Insurance

Protection Act Of 1996➢ Small Business Liability Relief And Brownfields Revitalization Act

Of 2002 (‘Brownfields Amendments’)➢ Brownfields Utilization, Investment And Local Development Act

of 2018 (‘BUILD Act’)

CERCLA Overview

17

❖ CERCLA = Federal program only➢ Cannot be delegated to the states➢ States do carry out statutorily-defined support functions

❖ Exec. Orders 12580 & 13016 re who is the “President”❖ Regulations 40 CFR Parts 300 - 374. Key here:

➢ National Contingency Plan➢ All Appropriate Inquiries for BFPP defense

❖ Policy and guidance documents❖ Site-specific remedy selection, enforcement documents

➢ Action Memoranda (Removal Actions)➢ Records of Decisions (Remedial Actions)➢ Settlements in CDs and administrative settlements

❖ Watch for the fruits of EPA’s Superfund Task Force’s work

CERCLA Overview

18

❖ Applies to uncontrolled releases/threatened releases of hazardous substances, pollutants and contaminants

❖ Which “may present an imminent and substantial risk” to “public health and welfare”

❖ Excludes➢ Petroleum, crude oil, synth./nat.lgas➢ Fed. permitted releases➢ Certain recycling transactions➢ CERCLA §104(a)(3) (i.e. asbestos in buildings)

❖ Authorities include➢ Response authorities (§ 104), applicable to pot. releases of hazardous

substances, pollutants and contaminants➢ Enforcement authorities (§ 106 & 107) authorities, applicable only to

pot. releases of hazardous substances

CERCLA Overview

19

CERCLA Cleanup process

❖ Removals (at any time)❖ Identification❖ Preliminary Assessment❖ Site Investigation❖ Remedial Action

➢ NPL listing➢ Remedial Investigation/Feasibility

Study➢ Proposed plan➢ Record of Decision➢ Remedial Design➢ Remedial Action➢ Operations & Maintenance➢ Delisting

❖ Who carries out Removals & Remedial Action?➢ EPA at private, fund

lead ➢ Fed. gov’t. at fed.

facilities➢ PRPs via enforcement

20

CERCLA NPL Cleanup process

❖ Pre-listing, options exist for choosing regulator➢ Per § 105(h), at state request, EPA can

“defer” an ERS to a state program if cleanup will be CERCLA protective.

❖ Post-listing, EPA can designate a state to be “lead” at a PRP-funded CERCLA action

❖ Once on the NPL train, you’re generally on until the final stop➢ NCP: “Releases may be deleted from or

recategorized on the NPL where no further response is appropriate”

➢ But see 1995 NPL Deletion Policy, allowed deferral of listed, still dirty, sites to RCRA CA; sim. for nuc. sites/NRC

➢ Last word?

21

CERCLA Remedy Selection: For NPL Sites, 9 criteria:

❖ Threshold criteria➢ Overall protection of human health and the environment➢ Compliance with ARARs

❖ Balancing criteria➢ Long-term effectiveness and permanence➢ Reduction of toxicity, mobility, or volume through treatment➢ Short-term effectiveness➢ Implementability➢ Cost

❖ Modifying criteria➢ State (support agency) acceptance➢ Community acceptance

22

Overall protection of human health and the environment

❖ Established in Remedial Action Objectives (RAOs) based on site-specific risk assessment, which considers: sources, routes, & receptors

❖ IDs acceptable exposure levels across various scenarios➢ Re carcinogens, levels corresponding to excess lifetime cancer risk

between 10-4 and 10-6➢ Re systemic toxicants: levels that do not cause adverse effects (HI > 1)

❖ Current and expected future land use is relevant to soil RAOs; not (by itself) relevant to expected future use of ground water➢ CERCLA’s/EPA’s expectation is to return groundwater to beneficial

use, throughout the plume, regardless of whether currently used➢ Various off ramps to expectation do exist

❖ Ecological risk also assessed.23

❖ Distinguish “applicable”, “relevant and appropriate”❖ CERCLA cleanups must comply w/ the substantive federal and

more stringent state environmental law cleanup standards ➢ Chemical-specific➢ Action-specific➢ Location-specific

❖ Compliance w/ administrative procedures (i.e. permits) not required

❖ State is required to identify its ARARs to EPA➢ Must be discrete, formally adopted➢ Consistently applied statewide

❖ CERCLA allows EPA to waive an ARAR, incl. inter alia:➢ Interim remedy; Technical impracticability; Fund balancing

Applicable, or Relevant and Appropriate Requirements

24

CERCLA Liability

Potentially Responsible Parties

❖ Per 107(a), 4 classes of PRPs:➢ Current owners or operators➢ Owners or operators at the

time of disposal➢ Generators and parties that

arrange or arranged for disposal

➢ Transporters that select or selected disposal sites

❖ PRPs may perform work and/or reimburse EPA.

❖ PRP-conducted response actions subject to EPA oversight

Standards of Liability

❖ Only for haz. substances❖ 107(a) Direct claim

➢ Strict➢ Joint & several

❖ 113 Contribution claim among liable parties; i.e. ‘Gore amendment’ equitable factors:➢ Distinguishable contribution to the

release➢ Amount of hazardous substance

involved➢ Degree of toxicity➢ Degree of involvement of the person

in the handling of the HSs➢ Degree of cooperation w/ gov’t

25

* Innocent Landowner

* Contiguous Landowner

* Bona Fide Prospective Purchaser

* Section 107(b)(3) defenses

* act of God

* act of War

* act or omission of a third party

Statutory Liability Protection

26

* Recent development – BFPP historically applied to purchasers but this protection was extended to prospective lessees in the BUILD Act, part of the Consolidated Appropriations Act of 2018

* Uncertainty – BFPP is self-executing – you will not know whether you have met the elements until you assert the defense* For NPL sites, prospective purchaser agreement is

possible

Bona Fide Prospective Purchaser

27

* All disposal must have occurred prior to acquisition (or lease)

* All appropriate inquiry

* AAI regulation/ASTM E1527-13

* Issues with ASTM standard

* Data gaps, data failure

* Emerging contaminants (PFOS/PFOAs)

* Lawyers’ role in review Phase I and II reports

BFPP Elements

28

* Must exercise “appropriate care” and take “reasonable steps” to:

* Stop any contaminant releases

* Prevent any threatened future release

* Prevent or limit human, environmental or natural resource exposure to any previously released hazardous substance

* Unlike AAI, no EPA regulations

* Ashey II

BFPP Elements

29

* Reasonable steps* Your due diligence will inform you as to the nature and

extent of contamination* You may be able to receive a comfort letter outlining

reasonable steps at a specific site

BFPP Elements

30

* No connection through family or “contractual, corporate or financial relationship”

* Lender protection

* Foreclosure issues

* EPA’s 2011 enforcement discretion guidance regarding affiliation issues

* Exceptions

* Generally exempt relationships

BFPP Elements

31

* Cooperation with agency authorized to conduct response

* Comply with land use restrictions and institutional controls

* Comply with information requests or administrative subpoenas

* Especially Section 104(e) information requests

BFPP Elements

32

* Ashley II of Charleston v. PCS Nitrogen, Inc., 791 F. Supp. 2d 431 (D. S.C. 2001), aff’d, 714 F.3d 161 (4th Cir. 2013)

* 3000 E. Imperial, LLC v. Robertshaw Controls Co., No. CV 08-3985 PA (Ex.), 2010 WL 5464296 (C.D. Cal. Dec. 29, 2010).

* SPS Limited Partnership LLLP v. Sparrows Point, LLC, No. VC JFM-14-589, 2017 WL 3917153 (D. Md. Sept. 6, 2017).

BFPP In Practice

33

❖ Distinguish➢ Removal Ks, can be in

AOCs■ PRP cleanup■ BFPP ‘Doing work’

➢ Remedial Ks, must be in CDs■ PRP cleanup

❖ Scope of the liability release (work to be performed v. site-wide)

❖ Contribution protection

CERCLA Negotiated Settlements w/ EPA

❖ Key definitions➢ ‘Work to be performed’➢ Covenants➢ “Matters addressed"➢ “Site”➢ CERCLA--required ropeners for

‘new information’ for site-wide remedial action covenants

❖ Renewed prospects for Prospective Purchaser Agreements for BFPPs?

❖ Model agreements online34

❖ CERCLA § 128(b)(1)(A) bars EPA from bringing a 106 or 107 enforcement action against a person who is➢ Conducting or has completed a response action regarding a

release at an “eligible response site” ➢ in compliance with a state cleanup program

❖ Exceptions to the enforcement bar, if ➢ State requests that EPA take/keeps site➢ Contamination crossing state line➢ EPA finds imminent & substantial endangerment➢ Information unknown at time is revealed

❖ Note:➢ Built-in political constraints on EPA invoking exception ➢ Opportunity for use at non-CERCLA fed.-lead sites? (See below)

CERCLA Section 128(b) “Safe Harbor” for state-led cleanups at ERSs

35

❖ Called for by then EPA Admin. Scott Pruitt➢ Developed by EPA career staffers➢ Issued 7/17

❖ 42 Recommendations, over 5 goals➢ 1: Expediting Cleanup and Remediation➢ 2:Re-invigorating Responsible Party Cleanup and

Reuse➢ 3: Encouraging Private Investment➢ 4: Promoting Redevelopment and Community

Revitalization➢ 5: Engaging Partners and Stakeholders

EPA Superfund Task Force

36

❖ Summaries of and links to other relevant EPA guidance, sometimes with further 'gloss.'

❖ AAI, & steps to satisfying it.❖ Several 'disposal after acquisition' issues

➢ ‘Passive migration'➢ Types of physical, site preparation activities that developers

can undertake without losing protections.

❖ 2011 Affiliation guidance, including re buyer/seller indemnifications & other agreements.

❖ "Reasonable steps" that the Agency would likely accept❖ Institutional controls and other land use restrictions❖ Is enforcement discretion for EPA only, courts ultimately

decide scope of CERCLA liability.❖ Relevant to private contribution actions?

7/29/19 Revised Common Elements Guidance

37

* Generally applies to release of hazardous waste from a solid waste management unit at a RCRA facility* Facilities – hazardous waste treatment, storage or

disposal

* “Interim status” facilities

* Authority can be delegated to states – not all have taken it

* Once CA is triggered, assessment and potential cleanup is required for entire facility

RCRA Corrective Action

38

* Release/threated release

* Determine whether interim measures are required

* RCRA facility assessment

* Corrective Measures Study

* Alternatives


39

* EPA issues Statement of Basis

* Public participation

* EPA issues a Final Decision and Response to Comments

* Implement Corrective Measures

* Through terms of RCRA permit or a 3008(h) order

* COC

* Ongoing maintenance


40

* Mini superfunds

* Often similar provisions to CERCLA

* Typically exclude NPL sites or sites under RCRA Corrective Action

* Authority for emergency response actions and long term remediation

* Establishment of cleanup funds or financing mechanisms

State “superfund” Programs

41

❖Public participation provisions

❖Prospective purchaser protections

➢Some states

❖Innocent landowner

➢Most states

❖ Comfort letters (site status, NFA)

State “superfund” Programs

42

❖Established to facilitate investigation and cleanup of contaminated sites➢ Protection from liability

➢ Tax credits and other financial incentives

❖Available to both RPs and innocent purchasers

➢Different sign-off and certainty

➢Determine your status before you become an owner

❖What sites are generally eligible?

➢ Not NPL sites or those under enforcement action

➢ How dirty does the site need to be?

State Voluntary Cleanup Programs

43

❖Application

➢ Requires background information (Phase I/II) and proposed development plan

➢ Relatively high application fees

➢ Sometimes a bond is required for the proposed work

❖ Participant must prepare and have approved a detailed CAP or RAP

➢Lawyer’s role in reviewing plan

➢Public participation


44

❖Multiple pathways to determining cleanup levels

➢Background

➢Site-specific risk assessment

■ Who/what are the receptors?

➢ State-wide tables for different media

❖ Institutional and engineering controls and other closure requirements

➢ Based on the use of the property - choose this carefully

➢ Environmental covenants as well

➢ Some are negotiable, others not at all


45

❖ Sign-off

➢NFA/NFRD

➢ COC

❖ What is your liability protection under a VCP?

➢ What contaminants?

➢ Contribution actions

❖ Issues of timing

❖ Think creatively - possibility of using VCP alongside other State program to add certainty


46

❖ Think creatively - possibility of using VCP alongside other State program to add certainty

❖ Some jurisdictions will allow you to withdraw from the VCP, conduct the cleanup under a different program, and then re-enroll to get a new sign-off

❖ Be aware of changing policies over time


47

❖ Remedy selection➢ Distinguish different remedy selection processes ➢ Practical differences regarding contaminated

groundwater➢ RCRA has no NCP; program implemented through

guidance

❖ Liability➢ RCRA does not have any statutory liability “safe

harbors”

❖ CERCLA amendments, guidance and policies historically more focused on encouraging reuse of sites – this may be changing

Key Differences Between CERCLA and RCRA

48

❖State programs (generally)➢ Greater focus on prompt

cleanup and encouraging reuse

➢ Process for achieving regulatory sign-off more predictable

➢ Agency reopeners vary ➢ Contribution protection (state

liability)➢ Tax credits

Key, crosscutting issue: how much public comment/participation?

Federal v. StateProgram Differences

❖ Benefits - CERCLA➢ EPA can waive ARARs ➢ Removes administrative federal &

state administrative permit requirements

➢ Statutory reopeners➢ Contribution

■ Stronger case for NCP-compliant contribution action against others

■ Contribution protection for yourself

❖Benefits – RCRA CA❖Sometimes greater flexibility❖Required if active, & subject to

TSD permit❖~ 44 states implement

49

❖ Consider pros & cons of each➢ What will final cleanup Remedial Action Objectives be?➢ How long to final cleanup decision?➢ How ‘iron clad’ will the covenants, contribution protection be?➢ Can redevelopment begin during, or even be incorporated into, remedy

implementation❖ Reinvigorate 105(h) pre-NPL deferral to state programs?❖ Revisit sending NPL sites to the states post-listing?

➢ See 1996 delisting of the 29th and Mead/“North Industrial Corridor” site, Wichita, Kansas

❖ For non-CERCLA Fed. sites (RCRA CA, SDWA, etc.), invoke CERCLA 101(41)(B)(ii) ‘deferral’ of non S’fund fed. sites back to state, where state program protective, would promote economic development, or help create/preserve green space?

Current/Future Issues re Choosing the Regulator

50

* PFAS (Per- and Polyfluoroalkyl Substances)* CERCLA

* Not currently a hazardous substance* EPA can’t list a site on NPL with only PFAS but they can be

a secondary contaminant* EPA can conduct removal activities* No cost recovery under section 107

* RCRA - EPA has used its Section 7003 authority to address PFAS

* State authorities

Emerging Contaminants

51

❖ 1887 – 2003➢ 3,100 acre facility➢ 1916, Bethlehem Steel purchases,

expands steelmaking, begins shipbuilding

➢ 1950s, world’s largest steel works (sintering plant, blast furnace for iron production, basic oxygen furnaces, continuous strip castor, hot strip mills, cold reduction mills and tin mills)

❖ 1991 - Coking operations cease

Sparrows Point Case Study

52

❖ 1997➢ EPA, MDE & BSC enter into RCRA Corrective

Action (3008(h)) consent decree, requiring RCRA RFI, CMS, Interim Measures

❖ 2003 BSC bankruptcy❖ 2005 – 2012

➢ Succession of steel companies & bankruptcies (Intern. Steel Group, Arcelor Mittal, Severstal N.A., RG Steel)

❖ 2010➢ Chesapeake Bay Foundation & Blue Water

Baltimore file RCRA citizen suit against current & former steel mill operators


53

❖ 2011 Fed. Ct. Decision re scope of 1997 CD, CBF/BWB litigation➢ Current owner not responsible for pre-2005 offshore

contamination

❖ 2012 bankruptcy sale➢ SPLLC acquires facility for redevelopment➢ To resolve objections of EPA & MDE re satisfying 1997 CD, SPLLC

agrees to sign on to 1997 RCRA CD, $500k put in trust to complete offshore investigation by EPA

❖ 7/14 ‘carve out’ from 1997 CD➢ EPA acknowledges that no further work required under the CD at ~

2,400 acres of Site➢ Acknowledges that ultimately EPA will issue RCRA Corrective

Action decision documents (SBs & FDRTCs) for entire site

❖ 2/15 Offshore sediments deferred to CERCLA


54

❖ 9/14, Sparrows Point Terminal (now Tradepoint Atlantic) agreed to separate, coordinated prospective purchaser agreements w/ EPA & MDE to address cleanup:

❖ EPA PPA➢ TPA to accomplish all onshore work RCRA Corrective Action work,

including completion of➢ Final Site Wide Investigation➢ Interim Measures➢ Preparation and implementation of Corrective Measures Studies & Corrective

Measures Implementation.

➢ TPA pays $3M to address offshore investigation & cleanup (EPA RCRA program deferred offshore sediments to CERCLA program), & certain oversight costs

➢ EPA covenants under CERCLA & RCRA for “existing contamination”➢ TPA asserted BFPP status; confirmed by fed. ct. in SPS Limited Partnership

LLLP v. Sparrows Point, LLC (D. Md. Sept. 6, 2017).


55

❖ MDE Administrative Consent Order➢ Required assessment and cleanup under

Maryland’s Voluntary Cleanup Program, ➢ TPA deemed an “inculpable party” under

state statute, thus making TPA and other parcel purchasers eligible for Brownfield tax credits

➢ $48M financial assurance, increased as necessary

➢ Stipulated penalties for non-compliance


56

❖ Recognize site-specific legal & operational history, technical context

❖ Challenge of an ‘orphan’ RCRA Corrective Action site

❖ Offshore sediments, w/ multiple sources of contamination

❖ Site not a CERCLA “Brownfield” b/c of RCRA CA❖ Re EPA covenants: what is the “site”? What is

“existing contamination”?❖ Interplay between EPA CA authorities & state

cleanup authorities (including ‘mini Superfunds’ as well as VCPs)

❖ EPA’s willingness to let state take the lead for land cleanup, under its VCP, while EPA simultaneously meets its RCRA Corrective Action obligations, based on common deliverables from current owner

Sparrows Point Case Study -Lessons learned

57

Curtis, Mallet-Prevost, Colt & Mosle LLP

“They are all extremely high quality. That is what is different to other firms.”

Chambers USA 2018

About Curtis, Mallet-Prevost, Colt & Mosle, LLP

Founded in 1830, Curtis is one of the world’s longest established international law firms. Headquarters in New York City

~ 300 lawyers operating out of 16 offices located across the globe.

For nearly 200 years Curtis has been advising clients on their most significant and strategic matters. The firm has a history of ‘firsts.’ One of the first U.S. firms to open in Mexico

Offices in Europe, China, & Central Asia

The only U.S.-headquartered law firm licensed to practice in Oman.

Diverse domestic and international client baseGovernments and state-owned entities

Multinational companies

Financial institutions

Public and private businesses

Entrepreneurs

High-net-worth individuals. 58

Thank You

Charles Howland, CurtisMallet-Prevost & Mosle [email protected]

Megan Roberts-Satinsky

Linowes and Blocher LLP

[email protected]

59

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