FINAL DECISION 

 
 
This proceeding was conducted according to the provisions of section 1552 of title 10 and 
section  425  of  title  14  of  the  United  States  Code.    The  Chair  docketed  the  application  upon 
receipt of the applicant’s completed application on July 21, 2010, and subsequently prepared the 
final decision as required by 33 CFR § 52.61(c).  Although the applicant labeled her brief as a 
request for reconsideration of BCMR Docket No. 2009-155, the Chair docketed the application 
as a new case because the relief sought is different from that in BCMR Docket No. 2009-155.   
 
 
appointed members who were designated to serve as the Board in this case.  
 
 

This  final  decision,  dated  April  28,  2011,  is  approved  and  signed  by  the  three  duly 

APPLICANT’S REQUEST 

 

DEPARTMENT OF HOMELAND SECURITY 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 
Application for the Correction of 
the Coast Guard Record of: 
 
                                                                                BCMR Docket No.  2010-213 
XXXXXXXXXXXXX 
XXXXXXXXXXXXX 
   

 
The applicant asked the Board to correct her record to show that she advanced to YNCM 
(master  chief  yeoman;  pay  grade  E-9)  on  September  1,  2008.   The  applicant  alleged  that  she 
would  have  been  advanced  on  this  date  were  it  not  for  the  erroneous  and  unjust  enlisted 
employee review (EER) that the Board ordered removed from her record in BCMR Docket No. 
2009-155.   
 

BACKGROUND 

In an earlier proceeding, BCMR Docket No. 2009-155, the applicant asked the Board to 
correct her record to show that she was advanced to YNCM (E-9) from the 2007 advancement 
list retroactive to December 1, 2007.  She alleged in that application that her then-commanding 
officer (CO) committed an error and/or injustice against her by withdrawing her recommendation 
for the applicant’s advancement and by removing her name from the 2007 advancement  list five 
days before the applicant was due to be advanced.  The applicant argued that the CO took this 
action without giving the applicant any prior notice or counseling that the CO was displeased 
with her performance.  Nor did the CO inform the applicant’s then-rating chain of her concerns 

about  the  applicant’s  performance.  Therefore,  the  applicant  argued  that  she  did  not  have  an 
opportunity to correct the alleged performance and leadership deficiencies noted by the CO.   

 
The  CO  was  dissatisfied  with  the  applicant’s  performance  as  chief  of  the  Servicing 
Personnel Office (SPO). However, according to the applicant’s rating chain supervisor, she was 
assigned  to  full-time  duty  as  the  command  senior  chief  and  he  had  assigned  someone  else  as 
chief of the SPO.  Prior to filing an application with the Board, the applicant filed an Article 138 
complaint against the CO seeking advancement to E-9.  The reviewing authority (RA) for the 
Article 138 sided with the CO, but made the following pertinent statement with regard to the 
applicant’s performance: 

 
[The applicant’s performance was clouded by the] ineffectiveness of the [CO] and 
other members of your chain of command to communicate performance concerns 
to you in clear and understandable terms and in a timely fashion.  These actions 
were inconsistent with my strategic direction to all MLC CO’s to communicate 
and  manage  expectations  of  performance  regularly  with  our  people  in  order  to 
minimize surprises.  These actions were also inconsistent with your [CO’s] motto 
for ISC Alameda of “compassion, courage, and commitment.”  The poor timing 
of the [CO’s] decision to not recommend you for advancement was very hurtful to 
you.  The situation leaves open the question whether  you could have overcome 
your [CO’s] performance concerns if given sufficient time to correct them before 
the  projected  advancement  date.    Regarding  this  issue,  I  must  remind  you  that 
there is no entitlement to advancement.  Neither the Coast Guard nor the member 
is  well  served  if  the  member  is  advanced,  particularly  to  the  highest  enlisted 
grade, where a [CO] does not judge the member to be ready for advancement.  I 
extend  this  assertion  to  cases  where  a  [CO’s]  judgment  is  not  shared  with  the 
member  in  sufficient  time  to  allow  that  member  an  opportunity  to  correct  the 
deficiency before the end of a marking period or a projected advancement date.  
When our leaders correctly utilize our performance review process, the process 
should give our people time to correct performance deficiencies.  This is a crucial 
leadership issue to our service and one that is also very important to me.  Though 
in  your  case,  the  process  did  not  work  optimally,  this  does  not  compel  me  to 
change my position on the central issue.   
 
Simultaneously  with  the  removal  of  her  name  from  the  2007  advancement  list,  the 
applicant was due an enlisted employee review (EER) for the period ending November 30, 2007.  
She was not recommended for advancement on that EER and received two below-average grades 
of 3 for respecting others and monitoring work.1  Nor was she recommended for advancement on 
her transfer evaluation which ended on June 28, 2008, but she received a letter of commendation 
from the CO for certain accomplishments at the unit.    

 
Although the JAG stated in the advisory opinion in BCMR Docket No. 2009-155 that he 
recommended relief if the Board found that the applicant suffered an injustice regarding the CO’s 
decision to remove the applicant’s name from the 2007 advancement list, the Board denied the 

                                                 
1  Performance marks range from a low of 1 to a high of 7. 

applicant’s  request  for  advancement.  The  Board  found  that  the  CO’s  decision  to  remove  the 
applicant’s  name  from  the  E-9  advancement  list  5  days  prior  to  her  scheduled  advancement 
constituted neither error nor injustice.   However, the Board granted the applicant’s request for 
removal of the November 30, 2007 EER and the June 28, 2008 EER.  In this regard, the Board 
stated the following: 

 
The  record  is  .  .  .    replete  with  evidence  of  an  improper  performance  review.  
While the applicant had no right to be promoted, she does have a right to a fair 
EER.  She is entitled to proper counseling during the period of observation.  The 
EER job performance observations differ from promotion recommendation in that 
job performance evaluations must be based upon true facts of past history rather 
than projections of future performance.  

 

  # 

# 

# 

 
[T]he Board finds that the CO did not commit an injustice against the applicant by 
withdrawing her recommendation for advancement.  The Board finds that the CO 
failed in her leadership responsibility to the applicant and the applicant’s rating 
chain by not communicating her dissatisfaction with the applicant’s performance 
to her rating chain. 

The applicant’s request that she be promoted should be denied.  The applicant’s 
record  should  be  corrected  to  remove  the  EERs  dated  November  30,  2007  and 
June 26, 2008.  Both EERs are products of injustice and they contain erroneous 
marks and comments.  All of the applicant’s allegations have been considered and 
those not discussed within the findings and conclusions are not considered to be 
dispositive of the issue in this case.    

 

In light of the above findings, the Board ordered in BCMR Docket No. 2009-155 that the 

 
 
applicant’s record be corrected as follows: 
 

a.  Remove the EER performance marks dated November 30, 2007, plus counseling 

receipt and any other associated documents that may be in the military record. 
 

b.  Remove  the  EER  performance  marks  dated  June  26,  2008,  plus  the  counseling 

receipt and any other associated documents that may be in the military record.   
 

APPLICANT’S CURRENT REQUEST AND ALLEGATION 

(BCMR 2010-213) 

 
 
In the instant case, the applicant asked the Board to correct her record to show that she 
was  advanced  to  master  chief  petty  officer  (YNCM;  E-9)  from  the  2008  advancement  list 
retroactive to September 1, 2008, the date on which she alleged she would have been promoted 
but for the erroneous and unjust 2008 EER.   The applicant stated that she has learned that her 
name was on the 2008 advancement list and that she would have been advanced except for the 

erroneous  and  unjust  EERs  that  were  subsequently  ordered  removed  from  her  record.        The 
applicant further stated the following: 
 

[The  applicant’s]  name  appeared  on  the  2008  advancement  list.    She  could  not 
advance because of the 2008 EER issued by her [CO], which the Board removed 
from her record.  [The applicant’s] EER for 2009 is excellent and recommends 
advancement.  Thus, even if [the CO’s] concerns were legitimate and sufficient to 
warrant  withdrawal  of  [her]  advancement  recommendation  in  November  2007, 
those concerns no longer existed for the period covered by her 2009 EER, which 
was from July 2008   . . . through November 30, 2009.   
 
The BCMR accepted the concerns of [the CO] as sufficient to justify  her 2007 
advancement withdrawal decision . . . 
 
The  BCMR  directed  the  removal  of  the  EER  closing  June  26,  2008  because  it 
contained erroneous marks and comments and therefore was unjust.  Because of 
the  2008  EER,  [the  applicant]  was  ineligible  for  advancement  in  2008  and 
ineligible to take the service wide examination for advancement to E-9 in 2009. . . 
The  2008  EER,  however,  contained  no  “Below  Standard”  marks,  and  [the 
applicant’s] performance on the two measures for which she received such marks 
in 2007 improved to “Above average”.  Her overall scores also improved notably.   
 
The erroneous and unjust 2008 EER had the effect of precluding [the applicant’s] 
advancement for two  years despite the  fact that  her performance marks  did not 
support a non-recommendation for advancement.  It is . . . unclear why [the CO] 
continued to believe that [the applicant] was not ready for advancement as of June 
26, 2008 at the latest, when the second EER closed.  She did not directly inform 
[the applicant] of the reasons for her non-recommendation. . . . [The applicant] 
had  enjoyed  ample  time  to  improve  her  performance  in  the  areas  [the  CO] 
considered deficient, and in fact did improve her performance in those areas, as 
the EER reflects.   
 
The  issue,  then,  is  whether  [the  CO’s]  concerns  about  [the  applicant’s]  duty 
performance were sufficient to justify depriving [the applicant] of fair and timely 
opportunities  for  advancement  after  2007.    They  were  not.    Not  only  were  the 
concerns not effectively communicated to [the applicant] as the BCMR . . . found, 
they  were  comparatively  minor  and  did  not  persist  into  the  2009  evaluation 
period.  Those consequences, certainly when viewed in the light of the Board’s 
reasons for removing the 2008 EER, were excessive, unfair, and highly unjust.  

 
  
The  applicant  stated  that  the  Board’s  removal  of  the  two  EERs  had  one  of  two  legal 
effects  on  her  promotion  eligibility:    1)  the  voidance  of  the  EERs  removed  the  CO’s  non-
recommendations  for  advancement  making  the  applicant  eligible  for  advancement  or  2)  their 
voidance removed the non-recommendation for advancement, but did not render the applicant 
eligible for advancement because of the absence of positive recommendation for advancement.  
The  applicant  argued  that  the  two  unjust  EERs prejudiced  her  advancement  opportunities  and 

that the relief granted by the Board in BCMR Docket No. 2009-155 corrected one injustice while 
giving rise to a second—her inability to compete for advancement for three years. 
  
 
The applicant also alleged that the Board did not adequately address her discrimination 
complaint.    However,  on  page  2  in  BCMR  Docket  No.  2009-155,  the  Board  summarized  the 
applicant’s discrimination allegation, as follows: 
 

 The applicant asserted that her race was a determining and improper factor in [the 
CO’s] decision to withdraw her recommendation for the applicant’s advancement 
to master chief.  The applicant stated that it is well-established in the professional 
literature  that  racial  bias  exists  in  the  workplace,  including  the  uniformed 
services.    The  applicant  stated  that  literature  and  research  have  concluded  that 
racial and other forms of discrimination occur in the absence of overtly racist acts 
or  attitudes  and  that  modern  racial  discrimination  is  better  characterized  as  a 
biased  cognitive  process  founded  on  stereotypical  attitudes  and  beliefs  about 
minority group members rather than consciously held racist views.  The applicant 
asserted that because overtly discriminatory acts and statements are less common 
today  than  in  decades  prior,  the  courts  routinely  look  at  statistics  detailing  the 
demographic composition of a work force in determining whether race played a 
role in a personnel decision. With respect to African-American representation in 
the highest enlisted ranks of the Coast Guard, the applicant offered that she was 
one of six African-Americans serving in the Coast Guard in the grade of E-8 and 
there was only one African-American female serving in grade E-9, while African-
Americans  comprised  over  10%  of  the  total  Coast  Guard  military  force.    The 
applicant stated that she should have been the second African-American female 
serving in pay grade E-9.  The applicant contended that “[a]lthough [the CO’s] 
discrimination  may  have  been  unconscious  nevertheless  she  intentionally 
withheld information that has negatively impacted my career.”      

 
 
The Board noted in footnote 9 of the findings and conclusions that “the applicant alleges 
discrimination  but  offers  no  specific  facts  relating  to  her  case.    Moreover,  the  unrebutted 
conclusion of the reviewing authority [RA] for her Article 138 complaint against the [CO] is on 
record.”   In her current application the applicant disagreed that she had not rebutted the RA’s 
determination of no discrimination.  In this regard, the applicant stated that she had no right or 
opportunity to rebut the RA’s findings directly.  She also argued that she in fact did rebut the 
RA’s  determination  by  citing  the  deficiencies  in  his  inquiry  and  by  providing  the  statistical 
analyses  and  supporting  evidence.    She  argued  that  her  discrimination  allegation  was  not 
frivolous because the statistical evidence developed and published by the Coast Guard supported 
drawing an inference that race was a determinative factor in her CO’s decision to withdraw her 
advancement recommendation.    
 

VIEWS OF THE COAST GUARD 

 

 

On December 17, 2010, the Board received an advisory opinion from the Judge Advocate 

General (JAG) of the Coast Guard who made the following recommendation: 

Based  on  the  unique  set  of  facts  and  circumstances  of  this  particular  case,  the 
BCMR’s Final Decision in 2009-155 . . . , and  the input provided by CG-PSC 
[Commander, Personnel Service Center], the Coast Guard does not object to the 
applicant’s retroactive advancement to Master Chief Petty Officer (E-9) effective 
December 1, 2007.  This advisory is based solely on the issues presented in this 
case;  therefore,  it  should  not  be  viewed  as  a  shift  in  policy  or  relied  upon  as 
precedent [with respect to] PERSMAN [Personnel Manual] sects 5.C.4.b., 5.C.e.4 
& 5.C.25.d.2   

 

The  JAG  stated  that  the  BCMR  may  correct  errors  and  remove  injustices  in  a 
serviceman’s records pursuant to 10 USC § 1552(a).  Error can be defined as either legal or 
factual.    In  the  instant  case,  the  CO  withdrew  her  recommendation  for  the  applicant’s 
advancement in accordance with Article 5.C.25.d. of the Personnel Manual which states that 
the  only  review  of  the  CO’s  decision  to  withdraw  an  advancement  recommendation  is  a 
complaint  under  Article  138  of  the  Uniform  Code  of  Military  Justice  (UCMJ).    Therefore, 
from  a  policy  standpoint,  the  applicant’s  CO  acted  within  her  discretion  regarding  the 
withdrawal  of  the  applicant’s  advancement  recommendation.  However,  “‘[i]njustice’,  when 
not also ‘error’, is treatment by the military authorities, that shocks the sense of justice, but is 
not technically illegal.” Reale v. United States, 208 Ct. Cl. 1010, 1011 (1976) (unpublished) 
(citing  Yee  v.  United  States,  206  Ct.  Cl.  388  (1975)).    The  JAG  stated  that  viewed  in  its 
entirety  from  a  totality  of  the  circumstances,  coupled  with  the  Board’s  findings  and 
conclusions in BCMR Docket No. 2009-155, and PSC’s current input, the evidence suggests 
the  applicant  suffered  a  manifest  injustice  regarding  her  CO’s  decision  to  withdraw  her 
advancement recommendation.  The injustice against the applicant has not been cured by the 
Board’s Final Decision in BCMR Docket No. 2009-155.    

 
The JAG noted the Board’s finding in the earlier case that the CO failed in her duties 
and committed an injustice against the applicant, as well as the applicant’s rating chain, by not 
informing them of her concerns about the applicant’s alleged leadership deficit and lackluster 
performance.  This apparent failure to communicate performance concerns was also articulated 
by the RA in the Applicant’s Article 138 complaint response.  The Coast Guard agreed with 
the  Board  that  the  applicant’s  CO  committed  an  error  in  evaluating  the  applicant’s 
performance as indicated on her 2007 and 2008 EERs.  The JAG further stated: 
 

When  viewing  the  applicant’s  case  from  a  “totality  of  circumstances” 
perspective,  the  command’s  failure  in  leadership  with  regard  to  the  applicant 
resulted  in  the  extremely  negative  consequence  faced  by  the  applicant.  
Moreover, the applicant was led to believe her performance was above standards 
by  receiving  favorable  endorsements  and  recommendations  for  positions  of 
greater  responsibility.    (e.g.  favorable  endorsement  from  the  CO  for  the 
applicant to attend the Command Master Chief course; favorable endorsement 
from  CO  on  Applicant’s  application  for  membership  on  the  Command’s 

                                                 
2      These  two  provisions  allow  for  withholding  or  canceling  an  advancement  when  the  member  loses 
eligibility  because,  among  other  reasons,  the  CO  has  withdrawn  the  member’s  advancement 
recommendation.    

Diversity Advisory Council; favorable endorsement for special assignment to a 
Command Master Chief position, selection for a 2008 Command Master Chief 
assignment;  etc.)    The  mixed  messages  sent  by  the  applicant’s  command, 
coupled with the apparent failure to communicate performance expectations is 
inconsistent  with  CG  policy  as  it  pertains  to  performance  evaluations  and  the 
advancement program’s intended purpose.   
 
The JAG noted that COs are “charged with ensuring all enlisted member under their 

command receive accurate, fair, objective, and timely evaluations.”  (Emphasis in original.)   
The JAG concluded by stating that it is the Coast Guard’s position that the applicant suffered a 
manifest  injustice  that  was  not  adequately  addressed  by  the  removal  of  her  2007  &  2008 
EERs.    
 
 
The JAG included a memorandum from the Commander, Personnel Service Center (PSC) 
with  the  advisory  opinion.    PSC  did  not  recommend  relief,  but  recognized  that  the  applicant 
would have been advanced on September 1, 2008 if she had remained eligible (by not having the 
mark of not recommended on the EERs).  PSC stated to the JAG that “while voiding the EERs 
removed the CO’s non-recommendation for advancement, we cannot presume that a command 
endorsement then exists.”   
 

APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 

 
 
On  September  8,  2010,  the  Board  sent  a  copy  of  the  views  of  the  Coast  Guard  to  the 
applicant.  The  Board received the  applicant’s reply through the U.S. mail on April 25, 2011. 
(Although the applicant indicated that her reply was also faxed to the Board, it was not received.)  
The applicant stated in her reply that she agreed with the JAG’s comments and disagreed with 
PSC’s comments.   

FINDINGS AND CONCLUSIONS 

 

 

The Board makes the following findings and conclusions on the basis of the applicant's 

1. The Board has jurisdiction concerning this matter pursuant to section 1552 of title 10 

military record and submissions, the Coast Guard's submission and applicable law: 
 
 
of the United States Code.  The application was timely. 
    
2.    The  applicant  has  established  error  in  her  record  by  virtue  of  the  Board’s  order  in 
 
BCMR Docket No. 2009-155 removing the two ERRs for the periods ending November 30, 2007 
and June 28, 2008 from her record because they  were erroneous  and/or unjust.  The question  
before the Board in this case is whether the erroneous and unjust EERs were prejudicial to the 
applicant’s failure to be advanced from the 2008 list i.e., was there a causal connection between 
her failure to be advanced from the 2008 eligibility list and the errors.   
 
3.    The  Board  finds  that  the  two  erroneous  and  unjust  EERs  were  prejudicial  to  the 
 
applicant’s  failure  to  be  advanced  from  the  2008  eligibility  advancement  list  because  both 
contained a mark of not recommended for advancement.   In this regard, Article 5.C.4.b.2. of the 

Personnel  Manual  states  that  the  CO’s  recommendation  is  required  to  be  eligible  for 
advancement, and Article 5.C.4.e.4. states that the CO’s recommendation for advancement is the 
most  important  eligibility  requirement  in  the  Coast  Guard  advancement  system.    Therefore, 
because the erroneous EERs did not recommend the applicant for advancement she could not be 
advanced  from  the  2008  list.    However,  because  both  EERs  were  the  product  of  error  and/or 
injustice as determined by the Board in BCMR Docket No. 2009-155, they could not and should 
not have been the basis for not advancing the applicant in 2008.  As PSC stated, the applicant 
would have been authorized advancement on September 1, 2008, had she remained eligible for 
advancement. The only reason she was not eligible for advancement was because of the mark of 
not recommended on the erroneous EERS.   
 

4.  To remedy the error and injustice suffered by the applicant, the Board finds that her 
record should be corrected to show that she was advanced to E-9 retroactively to September 1, 
2008, which would have occurred if the erroneous EERs had not been in her record.  To do less 
would perpetuate the significant injustice suffered by this applicant at the hand of her prior CO.  
The Board is aware of no other method by which to cure the error and injustice that would make 
the applicant whole.   Under 10 U.S.C. § 1552,  an applicant is entitled to “nothing more than 
placement in the same position he would have been had no error been made.” Denton v. United 
States, 204 Ct. Cl. 188, 199-200 (1974), cert. denied, 421 U.S. 963 (1975); see also Kimmel v. 
United States, 196 Ct. Cl. 579, 591 (1971) (“The injustice was removed by placing plaintiff in 
the same position he would have been had no error been made. This was all that plaintiff was 
entitled to receive.”); Bliss v. Johnson, 279 F. Supp. 2d 29, 35 (D.D.C. 2003).   Moreover, the 
applicant has demonstrated that she has the time in service, knowledge, and skill to serve in pay 
grade E-9 by her placement on the 2008 and 2011 eligibility lists.  Erroneous and unjust EERs 
should not serve as a basis for not advancing her from the 2008 advancement list.   
 

5.  In the advisory opinion for the Coast Guard, the JAG recommended granting relief,3 
and,  as  discussed  above,  the  Board  agrees.    Although  the  JAG  recommended  retroactive 
advancement  to  December  1,  2007,  the  Board  finds  that  the  applicant  should  have  relief 
retroactive to September 1, 2008, the date she would have advanced from the 2008 list, which is 
the  relief  she  requested  in  the  current  application.      Apparently,  the  JAG  treated  the  current 
application as a reconsideration of BCMR Docket No. 2009-155 for retroactive advancement to 
December  1,  2007.    That  approach  is  understandable  since  the  allegations  of  error  in  both 
applications grew out of the same set of unfortunate circumstances.  However, more important 
than this procedural issue is the fact that, for the second time, the JAG has recommended relief 
for this applicant.  Although the JAG’s recommendation for relief in the earlier case could have 
been stronger, he makes it very clear in this current case that the Coast Guard believes that the 
applicant has suffered a significant and continuing injustice at the hands of her then-CO that can 
be remedied only by advancing her to E-9 with a retroactive effective date.  In this regard, the 
JAG stated that the injustice suffered by the applicant due to the failed leadership of the then-CO 
was not cured by the final decision in BMCR No. 2009-155.   The Board notes that because of 
                                                 
3 PSC, in its memorandum to the JAG, argued that “with EERs containing the non-advancement recommendation 
removed  from  the  applicant’s  record,  it  cannot  be  presumed  that  a  command  endorsement  for  her  advancement 
exists.”    The  Board  notes  that  the  regulation  requires  a  command  endorsement  for  advancement.    However,  10 
U.S.C. 1552 gives the Secretary or her delegate the authority to correct and remove any error or injustice from a 
military record.       

the erroneous EERs, the applicant’s name was removed from the 2008 E-9 advancement list and 
those  same  EERs  prevented  her  from  competing  for  advancement  from  May  2008  until  May 
2010.  As already stated, not retroactively advancing the applicant to E-9 effective September 1, 
2008, perpetuates the error and injustice suffered by the applicant because of the two erroneous 
EERs that were ordered removed from her record by the BCMR.   
 

6.    The  Board  was  not  persuaded  by  the  applicant’s  complaint  of  discrimination  in 
BCMR Docket No. 2009-155, and as stated in that case “issues not discussed within the findings 
and conclusions [of that case] were not considered to be not dispositive of the issues in the case.”  
The applicant presented no new evidence in this case that would dictate a reconsideration of the 
discrimination issue.    

 
7.    Accordingly,  the  applicant’s  record  should  be  corrected  to  show  that  she  was 

advanced to YNCM (E-9) retroactive to September 1, 2008, with back pay and allowances.  

  

 

[ORDER AND SIGNATURES APPEAR ON NEXT PAGE] 

ORDER 

 

 

 
 
 

 
 
 

The application of XXXXXXXXXXXXXXXX, for correction of her military record is 
granted.    Her  record  shall  be  corrected  to  show  that  she  was  advanced  to  YNCM  (E-9)  on 
September 1, 2008.  The applicant shall receive all back pay and allowances.   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
 
Anthony C. DeFelice 

 

 
Peter G. Hartman 

 
 
 

 
 
 

 
 

 
 
 

 
 

 
 

 

 

 

 

 

 

 

 

 

 

 

 

 
 

 
 

 
 

 

 
Vicki J. Ray