DEPARTMENT OF HOMELAND SECURITY 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 
Application for the Correction of 
the Coast Guard Record of: 
 
                                                                                BCMR Docket No.  2012-036 
 
XXXXXXXXXXXXXXXX 
XXXXXXXXXXXXXXXX 

 

 

 
 

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 December 6, 2011, and subsequently prepared 
the final decision as required by 33 CFR § 52.61(c). 
 
 
appointed members who were designated to serve as the Board in this case. 
 

This  final  decision,  dated  October  25,  2012,  is  approved  and  signed  by  the  three  duly 

APPLICANT’S REQUEST  

 
 The applicant asked the Board to promote her to lieutenant commander (LCDR) on the 
 
inactive  duty  promotion  list  (IDPL)  retroactive  to  November  23,  2010,  the  date  on  which  she 
complied with the Coast Guard’s weight and body fat requirements, and to award her back pay 
and allowances.   
 

The applicant was in the Selected Reserve (an active status1 category of the Reserve) and 
was selected for promotion to LCDR in September 2009.  She was authorized promotion on July 
1, 2010, but the promotion was delayed because she was over her allowable weight and body fat 
limits and she was on weight probation.  The applicant was never promoted to LCDR as a result 
of her September 2009 selection because she was transferred from an active status to the inactive 
status  list  (ISL)2  immediately  prior  to  the  convening  of  the  LCDR  selection  board  in  August 

                                                 
1    Active  status  is  the  status  of  all  reservists,  except  those  on  an  inactive  status  list  or  in  the 
Retired  Reserve,  including  reservists  performing  extended  active  duty  and  long-term  ADSW.  
Article 7.A.2.a. of the Reserve Policy Manual.   
2    The  inactive  status  list,  Standby  Reserve,  is  a  Reserve  category  consisting  of  reservists  who 
may be ordered to active duty in time of war or national emergency if it is determined that not 
enough qualified reservists in an active status are available  in  the categories required.  Members 
on  the  inactive  status  list  may  not  train  for  pay  or  retirement  points,  are  not  eligible  for 

 

 

2010 because she did not meet the eligibility requirements for promotion (she was non-compliant 
with  the  Coast  Guard’s  Weight  and  Body  Fat  Standards  program).    On  August  13,  2010,  the 
applicant  acknowledged  a  page  7  advising  her  that  she  had  not  met  the  weight  standards  and 
body fat standards and would be transferred to the ISL.   
 

ALLEGATIONS 

 

An administrative remarks page (page 7) was entered into the applicant’s military record 
on April 10, 2010, advising her that she was on weight probation and that she was required to be 
weight-compliant by December 23, 2010.   If she failed to meet the weight requirements by the 
end of the probationary period, she would be transferred to the Individual Ready Reserve (IRR) 
or the Inactive Status List (ISL).3  She alleged that she was not told until early July 2010 that if 
she was not weight-compliant by the convening date of the next LCDR selection board, August 
16,  2010,  she  would  be  transferred  to  the  ISL  at  that  time.      She  did  not  meet  the  weight 
requirement on August 13, 2010, and was removed from an active status  and transferred to the 
ISL.     
 

Subsequent  to  her  transfer  to  the  ISL,  the  applicant  met  her  weight  requirement  on 
November  23,  2010.    On  December  13,  2010,  she  requested  to  be  transferred  back  into  the 
Selective Reserve (an active status), but was placed into the IRR (another active status) because 
the Coast Guard stated that the billet she held in the Selective Reserve no longer exited due to a 
reorganization.   
 

The  applicant  stated  that  under  14  U.S.C.  §  734  and  Article  7.A.12.b.  of  the  Reserve 
Policy Manual, her promotion was rightfully delayed in 2010 due to her non-compliance with the 
weight standards.  These provisions state that a reserve officer shall not be promoted to a higher 
grade unless the officer has been found to be physically qualified.  However, she argued that her 
transfer to the ISL on August 13, 2010 was improper because under Article 3.3.5 of the Weight 
and Body Fat Standards Program, she had until the end of her probationary period, December 23, 
2010, to become weight-compliant. 
 

The applicant argued that she was eligible for promotion on November 23, 2010, the date 
on  which  she  became  weight-compliant  because  her  name  was  never  removed  from  the 
promotion  list  and  because the list  was not  exhausted since the last person was promoted from 
that  list  on  July  1,  2011.    In  support  of  her  contention  that  she  was  eligible  for  promotion  on 
November  23,  2010,  she  cites  to  14  USC  §  729(h),  which  states,  “The  recommendations  of  a 
selection  board,  as  approved  by  the  President,  constitute  a  list  of  selectees  from  which  the 
promotions of Reserve officers shall be made.  An officer on a list of selectees remains thereon 
until promoted unless removed by the President under section 738 of this title.  If an existing list 
of  selectees  has  not  been  exhausted  by  the  time  a  later  list  has  been  approved,  all  officers 

                                                                                                                                                             
promotion,  and  do  not  accrue  credit  for  qualifying  years  of  service  for  retirement.    Article 
1.C.3.b. of the Reserve Policy Manual.   
3    The  page  7  states  that  the  applicant  was  34  pounds  overweight  and  that  she  exceeded  her  allowable 
body fat by 8%.   

 

 

remaining on the older list  shall be tendered appointments prior to  those on the later list.”  The 
applicant summed up her contentions as follows:    
 

I was still eligible for promotion from the PY 2010 LCDR list until it has been 
exhausted. 
The first person on the PY 2010 list was promoted on 1 April 2010 and the last 
person was promoted on 1 July 2011.   
The next convening LCDR board would be August 2011 after the PY 2010 list 
was exhausted, not August 2010 as I was told.   
I came into compliance with the weight standards on 23 November 2010 prior to 
the PY 2010 list being exhausted and therefore was eligible for promotion as of 
23 November 2010.   

 

VIEWS OF THE COAST GUARD 

 
 
On April 18,  2012  the Judge Advocate General  (JAG) of the Coast  Guard submitted an 
advisory opinion recommending that the Board deny relief in this case.  The JAG stated that the 
applicant’s  promotion  was  withheld  due  to  her  non-compliance  with  weight  requirements,  as 
required by regulation.  The JAG stated that weight compliance is an eligibility requirement for 
promotion.  In this regard, the JAG stated that the Reserve Policy Manual states, “if the officer 
fails  to  meet  promotion  requirements  prior  to  the  convening  date  of  the  next  promotion  board 
transfer  from  an  active  status  will  take  effect  on  the  day  prior  to  the  convening  date  of  the 
board.”   
 
 
The  JAG  stated  that  based  on  the  time  the  applicant  spent  in  the  ISL  (102  Days),  she 
“was assigned a new date of rank (27 August 2004) because service in an inactive status may not 
be counted in any computation of years in service in accordance with 10 U.S.C. § 12734(a).”   
 

The  JAG  submitted  a  memorandum  from  the  Commander,  Personnel  Service  Center, 
(PSC) and asked that it be accepted as a part of the advisory opinion.    PSC recommended that 
the application be denied and stated the following:  Although the applicant was selected during 
the PY 2010 IDPL LCDR promotion board, the applicant was not entitled to promotion because 
she  did  not  meet  the  weight-compliance  requirements.”    PSC  stated  that  the  applicant  was 
required  to  meet  all  requirements  for  promotion  by  the  convening  date  of  the  next  LCDR 
selection board or be transferred to the  ISL.  PSC stated that the Coast  Guard is presumptively 
correct, and the applicant has failed to substantiate any error or injustice in her record.   
 

APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 

 
 
In July 2012, the Board received the applicant’s response to the views of the Coast Guard 
and  she  disagreed  with  them.    She  restated  her  argument  that  she  should  have  been  promoted 
effective November 23, 2010 because the PY 2010 promotion list had not been exhausted as of 
that  date.    She  also  restated  her  argument  that  the  Coast  Guard  committed  an  error  by 
transferring her into the ISL before the end of her probationary period.   
 

 

 

The  applicant  stated  that  the  Coast  relied  on  a  provision  in  the  Reserve  Policy  Manual, 
 
which states that “If an officer fails to meet promotion requirements prior to the convening date 
of the next promotion board, transfer from an active status will take effect on the date prior to the 
convening  date  of  the  board”  to  transfer  her  to  the  ISL.  She  argued  that  transfer  to  the  active 
status list (ASL) of the Standby Reserve would have been more appropriate.  In this regard, she 
argued that according to the Reserve Policy Manual, the ASL is also an inactive status category 
of  the  Reserve  that  consists  of  reservists  who  have  been  transferred  from  the  Ready  Reserve 
because of a temporary hardship, disability or other cogent reasons and who intend to return to 
the Ready Reserve.  Members on the ASL may participate in reserve training activities without 
pay,  may  earn  retirement  points,  and  are  eligible  for  promotion,  whereas  members  on  the  ISL 
may  not  train  for  pay  or  retirement  points,  are  not  eligible  for  promotion,  and  do  not  accrue 
credit  for  qualifying  years  of  service  for  retirement.    Reservists  on  the  ISL  include  volunteers, 
with no requirement to remain in an active status and members who were eligible to be placed on 
the  ISL  in  order  to  prevent  an  inequity  with  regard  to  their  pay  and  promotion  or  retirement 
points.    
 
 
The applicant argued that the ASL is the more appropriate category for a member who is 
on  weight  probation  like  herself    because  overweight  condition  is  a  temporary  situation  where 
the  member  will  either  lose  the  weight  by  the  end  of  the  probationary  period  and  rejoin  the 
Ready Reserve or not lose the weight and be processed for separation.  She stated that if she had 
been transferred to the ASL she would have remained eligible for promotion.   
 
 
The  applicant  again  argued  that  since  the  President  never  removed  her  from  the  list  of 
selectees under 14 U.S.C. § 729(h) she should  have been transferred to the ASL  and  promoted 
once she became weight-compliant.   
 

APPLICABLE LAW AND REGUALTION 

 
Statutes 
 
14 U.S.C. § 276 states:  Officers who are not included on the active duty promotion list may be 
promoted under the regulations to be prescribed by the Secretary.   
 
14  U.S.C.  §  729(h)  states:  “The  recommendation  of  a  selection  board,  as  approved  by  the 
President,  constitute  a  list  of  selectees  from  which  the  promotions  of  Reserve  officers  shall  be 
made.   An  officer  on  a  list  of  selectees  remains  thereon  until  promoted  unless  removed  by  the 
President under section 738 of this title.  If an existing list of selectees has not been exhausted by 
the time a later list has been approved, all officers remaining on the older list shall be tendered 
appointments prior to those on the later list.”   
 
14 U.S.C. § 729(i) states:  “A Reserve officer whose name is on  a list of selectees for promotion 
shall, unless that officer’s promotion is lawfully withheld, be tendered an appointment in the next 
higher pay grade on the date a vacancy occurs, or as soon thereafter as practicable in the grade to 
which the officer was selected for promotion or, if promotion was determined in accordance with 
a  running  mate  system,  at  the  same  time,  or  as  soon  thereafter  as  practicable,  as  that  officer’s 
running mate is tendered a similar appointment.” 

 

 

 
14  U.S.C.  §  732  states,  “A  Reserve  officer  is  eligible  for  consideration  for  promotion  and  for 
promotion under this subchapter, if that officer is in an active status.” 
 
14 U.S.C. § 733 states, “A Reserve officer recommended for promotion by a selection board but 
not promoted because of removal from an active status shall be reconsidered by a selection board 
after  returning  to  an  active  status  and  if  selected  shall  be  placed  on  a  recommended  list  of 
selectees for promotion.  A Reserve officer to whom this section applies is not considered to have 
failed  of  selection  when  eliminated  from  a  list  of  selectees  for  promotion  solely  as  a  result  of 
being removed from an active status.”  
 
 14 USC § 734(a) states:  “A Reserve officer shall not be promoted to a higher grade unless the 
officer  has  been  found  to  be  physical  qualified  and  the  character  of  the  officer’s  service 
subsequent  to  the  convening  of  the  selection  board  which  recommended  the  officer  for 
promotion has been verified as satisfactory.” 
 
Regulations 
 
Reserve Policy Manual 
 
Article 7.A.12 (Delay of Promotion) of the Reserve Policy Manual states the following: 
 
“a.  Under  no  circumstances  will  an  appointment  to  a  higher  grade  be  tendered,  including  an 
appointment for an officer assigned to the IRR, until the following conditions have been met:   
 

(1) The reserve officer is found physically qualified by a current approved and documented 
physical  examination  and  the  officer’s  character  of  service  since  selection  has  been 
verified as satisfactory (14 USC 734).   

(2)  The  active  service  running  mate  has  been  promoted,  all  officers  of  the  same  grade  of 
higher  precedence  on  any  prior  promotion  list  have  been  tendered  an  appointment,  and 
the Secretary exercises promotion authority.   

 

“b. If an officer cannot meet the physical requirements or other criteria at the time the officer’s 
running mates is promoted, promotion will be withheld until he or she meets the requirements; 
the  command  shall  so  notify  the  Personnel  Command    (CGPC-rpm)  and  the  Personnel  Service 
Center prior to the authorized promotion date.   
 

(1) If the officer subsequently meets the requirements prior to the convening date of the 
next promotion board, CGPC-rpm will authorize promotion with a date of rank at the 
time  the  officer  would  have  been  promoted  had  the  promotion  not  been  delayed.  
However, pay and allowances accrue from the effective date of appointment, not the 
date of rank.   

(2) If the officer fails to meet promotion requirements prior to the convening date of the 
next promotion board, transfer from an active status will take effect on the day prior 
to the convening date of the board.   

 

 

(3) Once an officer in an inactive status becomes physically qualified or meets the other 
requirements for promotion, he or she may submit documentation to CGPC-rpm and 
request to be returned to an active status.  The officer shall then be reconsidered by a 
selection board and if selected shall be placed on the new promotion list.  A reserve 
officer is not considered to have previously failed of selection when eliminated from 
a  list  of  selectees  for  promotion  solely  as  a  result  of  being  removed  form  an  active 
status.” 

 
Weight and Body Fat Standards Program 
 
 
Article 3.2.1 states that members who exceed their maximum allowable body weight and 
body fat percentage will be placed on probation, during which time they are required to lose the 
necessary amount of weight and/or body fat to come into compliance.   
 
 
than eight months.   
 
 
Article  3.2.7  states  that  members  are  required  to  demonstrate  reasonable  and  consistent 
progress  throughout  their  probationary  period.    Progress  should  be  gauged  by  losing  weight 
and/or body fat at a rate of: 
 

Article 3.2.2 states that the probationary period cannot be greater than 35 weeks or more 

  one pound per week, and  
  one percent body fat per month 

 

Article  3.2.10  states  that  at  the  end  of  the  probationary  period  the  command  must  evaluate 
the  member  for  compliance  with  the  maximum  allowable  weight  and  allowable  body  fat 
standards.    This  provision  also  requires  the  command  to  prepare  the  necessary  administrative 
remarks page documenting the non-compliance and to process the member for separation, if the 
member is non-compliant with the regulation at the end of the probationary period,    
 

Article 3.3.5 states that the separation procedure for a non-compliant reservist is to transfer 
the member to the Standby Reserve, Inactive Status List (ISL) for up to one year.   If the reservist 
officer fails to meet the weight and body fat requirements, a mobilization and disposition board 
must screen the officer to recommend separation or retirement in accordance with section 8.A.7 
of the Reserve Policy Manual.   
 

FINDINGS AND CONCLUSIONS 

 

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

military record and submissions, the Coast Guard's submission and applicable law: 
 
 
 
of the United States Code.   The application was timely. 
 

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

 

 

2.   The  applicant  argued  that  under Article  3.3.5.  of  the Weight  and  Body  Fat  Program 
 
regulation,  she  had  until  December  23,  2010,  the  termination  date  of  her  weight  probationary 
period to lose the excess weight and body fat, and therefore, her transfer to the ISL on August 13, 
2010 was improper.  She further argued that even though she was in the ISL when she became 
weight-compliant  on  November  23,  2010,  she  was  still  eligible  for  promotion  on  that  date 
because the President never removed her name from the promotion list under 14 USC 729(h).    
 
3.    There  are  two  regulations  that  touch  upon  this  case.    1.  The  Weight  and  Body  Fat 
 
Program regulation that dictates standards for all Coast Guard members (active and Reserve) and 
the consequences for  non-compliance with  the regulation.   2.  The Reserve Policy Manual that 
dictates policy for Reservists, including the procedures for officer promotion.    
 
 
4.      Article  3.3.5  of  the  Weight  and  Body  Fat  Standards  governs  the  separation  of 
members from the service who fail to meet the weight and body fat standards.  The applicant is 
correct  that  under  the Weight  and  Body  Fat  regulation,  she  would  have  been  transferred  to  the 
ISL (removed from an active status) if she was not weight-compliant by December 23, 2010, the 
termination  date  of  her  probationary  period.      She  signed  an  administrative  remarks  page 
acknowledging that she was on weight probation and was required to lose the weight and body 
fat  by  December  23,  2010  or  she  would  be  transferred  to  the  ISL  or  the  IRR.    However,  the 
applicant had been selected for promotion to LCDR by the PY 2010 selection board in 2009 and 
was  on  a  promotion  list  awaiting  promotion  when  she  became  weight  non-compliant.    If  the 
applicant  had  not  been  on  the  promotion  list  for  LCDR,  the  only  date  she  would  have  been 
concerned with would have been the end date of her probationary period, December 23, 2010.    
  
 
5.    Since  the  applicant  was  on  the  promotion  list,  the  procedure  that  governed  her 
promotion to  LCDR was Article 7 of the Reserve Policy Manual and not  the Weight  and Body 
Fat regulation.  To be promoted (different from separation) the applicant was required to comply 
with the Reserve Policy Manual.  The applicant was authorized promotion on July 1, 2010.  Her 
promotion  was  properly  withheld  because  she  did  not  meet  the  eligibility  requirements  for 
promotion  due  to  non-compliance  with  the  Coast  Guard’s  weight  and  body  fat  requirements.  
Article  7.A.12.a.  of  the  Reserve  Policy  Manual,  requires  that  an  officer  be  physically  qualified 
for promotion or the promotion will be withheld until the requirement is met.  Article 7.A.12.b 
requires that the officer whose promotion is withheld meet the requirements for promotion prior 
to  the  convening  date  of  the  next  selection  board  and  if  the  officer  does  not  meet  the 
requirements  for  promotion  by  the  convening  date  of  the  next  board,  the  officer  is  transferred 
from an active status the day prior to the convening date of the selection board.   
 
 
6.  The applicant was not qualified for promotion on July 1, 2010, the date authorized for 
her promotion, because of her non-compliance with the Coast Guard’s weight requirement.  Nor 
was she qualified on August 13, 2010, prior to the convening of the next LCDR promotion board 
on August 16, 2010.  Therefore, as required by Reserve Policy Manual she was removed from an 
active status and transferred to the ISL. Once she was removed from an active status, she was no 
longer  eligible  for  promotion  from  the  PY  2010  promotion  list.    Section  732  of  title  14  of  the 
United States Code states that “A Reserve officer is eligible for consideration for promotion and 
for  promotion  .  .  .  if  that  officer  is  in  an  active  status.”    Section  733  of  title  14  of  the  United 
States Code states that “A Reserve officer recommended for promotion by a selection board but 

 

 

not promoted because of removal from an active status shall be reconsidered by a selection board 
after  returning  to  an  active  status  and  if  selected  shall  be  placed  on  a  recommended  list  of 
selectees for promotion.”  The last sentence of this provision makes it clear that a Reserve officer 
on a promotion list who is removed from active status loses the opportunity for promotion from 
that  list.    The  pertinent  portion  reads,  “A  reserve  officer  to  whom  this  section  applies  is  not 
considered  to  have  failed  of  selection  when  eliminated  from  a  list  of  selectees  for  promotion 
solely as a result of  being removed from an active status.  [Emphasis added.]   See also Article 
7.A.12.b.(3)  of  the  Reserve  Policy  Manual.    So,  even  though  the  applicant  became  weight-
compliant while in the ISL and prior to the end of her probationary period under the Weight and 
Body Fat Standards regulation, she could not be promoted from the PY 2010 list because under 
14 U.S.C. § 733 she lost the promotion when she was removed from an active status.  In order 
for  the  applicant  to  be  promoted  to  LCDR,  the  statute  requires  that  she  be  selected  again  for 
promotion  to  LCDR  by  a  subsequent  board.    (There  is  no  indication  in  the  record  whether  she 
has been considered by a subsequent selection board.)  
 
 
7.    The  applicant  is  correct  that  the  President  never  removed  her  name  from  the 
Promotion list under 14 U.S.C. § 738.  The law allows the President to remove an officer from 
the promotion list for cause.  Since there in no misconduct involved in the situation at hand this 
provision is inapplicable.  However, it is clear that Congress intended for Reserve officers to be 
in  an  active status for promotion.   See  14 U.S.C.  § 733.   Congress  also  gave the Secretary the 
authority  to  implement  regulations  for  the  promotion  of  Reserve  officers.    Under  those 
regulations,  the  Secretary  (Commandant)  determined  that  officers  would  be  removed  from  an 
active  status  if  they  do  not  meet  the  requirements  for  promotion  by  the  convening  date  of  the 
next selection board.  The applicant did not meet this requirement.   
 
8.    The  Coast  Guard  did  not  commit  an  error  when  it  removed  the  applicant  from  an 
 
active status and transferred her to the ISL on August 13, 2010, because it was permitted to do so 
under  Article  7.A.12.b.of  the  Reserve  Policy  Manual  which  specifically  governs  reservists 
promotion procedures.   The specific regulation with regard to Reserve officer promotions would 
govern over the more general Weight and Body Fat Standards regulation.    
 
 
9.  The applicant argued that she should have been transferred to the ASL instead of the 
ISL because her weight condition was temporary and she would have been eligible for promotion 
if on the ASL.  However, the regulation states that members in the applicant’s situation are to be 
transferred  from  an  active  status,  and  it  does  not  designate  where  such  members  should  be 
assigned.  The ASL is, by definition, an active status.  Therefore, placing the applicant in the ISL 
was within the discretion of the Commandant.    The Coast Guard did not commit an error by not 
transferring the applicant to the ISL.   
 
 
10.    The  harder  question  is  whether  the  Coast  Guard  committed  an  injustice  by  not 
explaining to the applicant in April 2010 that if she did not lose the weight prior to the date for 
the  convening  of  the  next  LCDR  selection  board  that  was  scheduled  for August  16,  2010,  she 
would be transferred to the ISL regardless of when her probationary was due to terminate under 
the  Weight  and  Body  Fat  regulation.    Injustice  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); see also BCMR No. 2001-043 (2001), Decision of Deputy General Counsel 

 

 

(applying the error and injustice standards in Reale to the BCMR). The page 7 only advised the 
applicant about the risk of separation from the Service if she were not weight-compliant by the 
end  of  her  probationary  period.    It  was  not  the  responsibility  of  personnel  responsible  for 
carrying  out  the  Weight  and  Body  Fat  regulation  to  advise  the  applicant  about  regulations 
governing Reserve promotion policy and procedures.  Reserve officer promotion regulations are 
published in the Reserve Policy Manual and the applicant could have reviewed them at any time.  
The  page  7  placing  the  applicant  on  weight  probation  could  have  possibly  led  the  applicant  to 
believe erroneously that she had until December 23,  2010 to become weight compliant without 
any consequences to her career.  However, for a matter as important as a promotion, the applicant 
should have consulted the Reserve Policy Manual or senior officers in her chain of command in 
April  2010  when  she  was  placed  on  weight  probation  about  the  particulars  regarding  her 
promotion.   
 
 
because the regulations were available to her for review.   
 
 
error or injustice in this case.   

11.  While the applicant’s situation is unfortunate, it does not shock our sense of justice, 

12.   Accordingly,  the  applicant  has  failed  to  prove  that  the  Coast  Guard  committed  an 

[ORDER AND SIGNATURES APPEAR ON NEXT PAGE] 

 

 

 

 
 
  

 
 
 

 

 

 

 

ORDER 

 

The application of XXXXXXXXXXXXXXXXX, for correction of her military record is 

  

 
 H. Quinton Lucie 

 

 

 
 James H. Martin 

 

 

 
 
 Paul B. Oman 

 

 

 

 

 

 

 

 

 

 

 

 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

denied.