DEPARTMENT OF TRANSPORTATION 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 
Application for the Correction of 
the Coast Guard Record of: 
 
                                                                                BCMR Docket No. 1998-055 
 
 
   

 

 
 

FINAL DECISION 

 
ANDREWS, Attorney-Advisor: 
 
 
This  proceeding  was  conducted  under  the  provisions  of  section  1552  of 
title 10 and section 425 of title 14 of the United States Code.  It was commenced 
upon the BCMR’s receipt of the applicant’s application on February 6, 1998. The 
application  was  completed  and  docketed  on  June  9,  1998,  upon  receipt  of  the 
applicant’s military records.1  
 
 
appointed members who were designated to serve as the Board in this case. 
 

This  final  decision,  dated  June  15,  2000,  is  signed  by  the  three  duly 

APPLICANT’S ORIGINAL ALLEGATIONS AND REQUESTED RELIEF 

 
 
The applicant, a former xxxxxxxxxx, asked the Board to correct her record 
by changing the separation code (SPD code) and narrative reason for discharge 
in blocks 26 and 28, respectively, on the DD 214 discharge form issued upon her 
release from active duty.  At the time of her release, on October 1, 1993, she had 
served two years, two months, and three days on active duty.   
 

Initially,  the  applicant  alleged  that  the  LDM  separation  code  (which 
means involuntary early release under an authorized program or circumstance) 
and  the  narrative  reason  for  separation  (“convenience  of  the  government”) 
shown on her DD 214 are inaccurate and unjust.  She asked that they be changed 
to show that she was discharged pursuant to a reduction in force. 
                                                 
1  On April 29, 1999, the applicant waived her right to a decision within 10 months of the comple-
tion  of  her  application  under  14  U.S.C. §  425  in  order  to  reconsider  and  modify  her  requested 
relief. 

 
 
The applicant alleged that her veterans’ benefits have been “very limited” 
because of the inaccurate information on her DD 214.  In addition, she alleged the 
following:    “My  total  understanding  at  the  time  of  [her]  separation  from  the 
USCG was for the sole purpose of ‘Reduction in Force’ as an offer from my supe-
riors in the Coast Guard.  I should not lose my veterans benefits because of this 
discharge  and  if  I  had  been  explained  all  the  ramifications,  I  would  not  have 
given up all my benefits.”  She also alleged that “I was told after I accepted early 
release for a Reduction in Force that I was offered that my discharge was for the 
Government’s convenience.” 
 

The applicant alleged that she did not discover the errors until November 
20, 1997.  She stated that on that date, a “Veterans Service Officer informed me 
that I may have been given the wrong SPD code [at the] time of discharge.” 
 

VIEWS OF THE COAST GUARD 

 
Advisory Opinion of the Chief Counsel 
 
 
On February 25, 1999, the Chief Counsel of the Coast Guard submitted an 
advisory opinion, based on the applicant’s original application, in which he rec-
ommended that the Board grant relief. 
 
The Chief Counsel alleged that the Coast Guard had committed no errors 
 
with respect to the applicant’s SPD code.  He stated that, at the time of the appli-
cant’s discharge on October 1, 1993, LDM was the proper SPD code for members 
who were voluntarily discharged during a reduction in force.  The Chief Counsel 
explained that a few months after the applicant’s discharge, the SPD Handbook 
was revised and the LDM code was eliminated.  Under the new SPD Handbook 
issued in 1994, members being voluntarily discharged during a reduction in force 
receive an SPD code of KCC (voluntary discharge; reduction in force) and a nar-
rative reason for separation of “reduction in force.”  Therefore, the Chief Counsel 
stated  that  the  Coast  Guard  would  “not  contest  a  Board  decision  to  correct 
Applicant’s record to reflect a ‘KCC’ SPD in lieu of the ‘LDM’ SPD assigned.” 
 
 
The  Chief  Counsel  attached  to  his  advisory  opinion  a  memorandum  on 
the applicant’s case submitted by the Coast Guard Personnel Command (CGPC). 
  
Memorandum of the Coast Guard Personnel Command 
 
On February 9, 1999, the CGPC sent the Chief Counsel of the Coast Guard 
 
a memorandum advising him that no relief was warranted in the applicant’s case 
because no error had been made. 

 
 
The  CGPC  explained  that  the  SPD  code  LDM  (early  release  under  an 
authorized  program  or  circumstance)  was  correct  under  COMDTINST 
M1900.4C, which was issued on March 12, 1990.  On the date of the applicant’s 
discharge, October 1, 1993, LDM was the code “used for voluntary discharge in 
reduction in force discharge cases.” 
 

The  CGPC  opined  that  the  applicant  was  probably  confused  because  of 
the revised version of the SPD Handbook, which was issued on January 13, 1994, 
after the applicant’s discharge.  In this new handbook, SPD codes with the letters 
“DM” in the second and third positions signify discharges under holiday release 
programs.  The code LDM no longer exists in the new handbook.  Had the appli-
cant been discharged after the new handbook came into force, she would have 
received an SPD code of KCC (reduction in force). 
 

APPLICANT’S RESPONSE TO THE COAST GUARD’S VIEWS 

On February 25, 1999, the Chairman of the BCMR sent a copy of the views 

 
 
of the Coast Guard to the applicant and invited her to respond within 15 days.   
 

On April 8, 1999, the applicant called the BCMR and stated that she want-
ed to waive her entitlement to a decision within 10 months under 14 U.S.C. § 425 
because she was uncertain of the effect the KCC separation code proposed by the 
Chief Counsel would have on her entitlement to veterans’ benefits.  She stated 
that  she  needed  more  time  in  which  to  consult  the  Department  of  Veterans 
Affairs (DVA), which administrates MGIB benefits.  On May 5, 1999, the BCMR 
received written confirmation of the applicant’s waiver of the 10-month deadline. 
 

APPLICANT’S REVISED REQUEST 

 
On June 2, 1999, the applicant submitted a revised request for relief.  She 
 
asked  that  the  narrative  reason  for  separation  in  block  28  of  her  DD  214  be 
changed to “Involuntary REFRAD—Reduction in Strength.”  She also asked that 
the Block 25 be changed to reflect the part of the Personnel Manual that author-
ized the reduction in force.  She indicated that these changes should make her 
eligible for educational benefits under the Montgomery G.I. Bill (MGIB).2 
 

COAST GUARD’S RESPONSE TO THE REVISED REQUEST 

On June 9, 1999, the BCMR forwarded the applicant’s revised request for 

 
 
relief with a request to respond within 60 days.    
                                                 
2  38 U.S.C. § 3001. 

 
 
On May 23, 2000, the Chief Counsel responded to the applicant’s revised 
request.  He did not recommend granting the requested relief and reaffirmed his 
recommendation that the Board change her SPD code to KCC.  He indicated that 
the  applicant’s  revised  request,  if  granted,  would  make  her  eligible  for  MGIB 
benefits under 38 U.S.C. § 3011 (1993). 
 
 
The  Chief  Counsel  argued  that  the  applicant  voluntarily  applied  for 
release under the early release program authorized by ALCOAST 069/93.  Para-
graph  8  of  that  announcement,  he  alleged,  “specifically  addressed  Applicant’s 
situation and put her on notice that an early release might have an adverse effect 
on her MGIB eligibility.”  In addition, he stated, paragraph 11 of the announce-
ment  “clearly  indicated  that  this  early  release  program  is  strictly  voluntary.”  
Therefore,  he  argued,  she  “has  failed  to  prove  by  a  preponderance  of  the  evi-
dence that she was involuntarily separated under a reduction in force program.” 
 
 
The  Chief  Counsel  further  argued  that  when  the  applicant  enlisted  in 
1991, she signed a CG-3301I form acknowledging that she understood she would 
have to complete at least 48 months of active service before she would be eligible 
for MGIB benefits.  Therefore, he alleged, no injustice has been committed in this 
case. 
 

APPLICANT’S RESPONSE TO THE COAST GUARD’S VIEWS 

 
 
On May 24, 2000, the BCMR sent the applicant a copy of the Chief Coun-
sel’s supplemental recommendation and invited her to respond within 15 days.  
The applicant did not respond. 
 

SUMMARY OF THE RECORD 

 
On July 29, 1991, the applicant enlisted in the Coast Guard for a term of 
 
four years.  Prior to her enlistment, on July 16, 1991, the applicant signed a state-
ment  of  understanding  (form  CG-3301I)  concerning  MGIB  benefits.    Pertinent 
parts of the statement read as follows:   
 

I  am  automatically  enrolled  in  the  MGIB  and  my  basic  pay  will  be 

2. 
reduced by $100 per month for each of the first full 12 months of active duty. 
 
3. 
and there is NO REFUND of my monies under any circumstances. 
 
4. 

I cannot SUSPEND or STOP my monthly pay reduction under the MGIB, 

To be eligible for benefits, I must do the following:   
a. 

Complete 48 months of active duty.  

•  •  • 

I  can  make  a  one-time-only  election  to  disenroll  during  the  first  two 

8. 
weeks of active duty. 
 
I HAVE READ AND UNDERSTOOD EACH OF THE STATEMENTS ABOVE.  I 
UNDERSTAND THAT IF I DECIDE TO DISENROLL, IT MUST BE DONE DUR-
ING THE FIRST TWO WEEKS OF ACTIVE DUTY. 
 
On  August  15,  1991,  the  applicant  signed  another  statement  of  under-
standing regarding MGIB (form DD 2366) with somewhat different terms, which 
appear as follows: 

I  must  complete  three  years  of  active  duty  service  before  I  am 

 
2. 
entitled to $300 per month for 36 months. 

f. 

•  •  • 

h. 

 
I  must  complete  two  years  of  active  duty  and  join  the  Selected 
Reserve for a minimum four year service agreement before I am entitled to $300 
per month for 36 months. 
 
The DD 2366 also included a place for the applicant to sign if she wished 
to  disenroll  from  MGIB.    Because  the  applicant  did  not  sign  the  “Statement  of 
Disenrollment,”  she  was  automatically  enrolled  in  MGIB,  and  $100  was  with-
drawn from her monthly pay for each of her first 12 months on active duty. 

 
On  July  26,  1993,  the  Coast  Guard  issued  ALCOAST  069/93,  entitled 
“Voluntary  Early  Release  Program  for  Active  Duty  Enlisted  Personnel.”    It 
announced a program “to mitigate the negative effects of high retention rates,” 
by  permitting  enlisted  members  to  submit  requests  for  voluntary  early  release 
from active duty.  The deadline for submission was August 16, 1993.   

 
Paragraph  4  of  ALCOAST  069/93  stated  that  members  whose  requests 
were  approved  would  be  separated  by  reason  of  the  “convenience  of  the  gov-
ernment”  in  accordance  with  Article  12-B-12-A(6)  of  the  Personnel  Manual 
(COMDTINST M1000.6A).  These members would be released from active duty 
or discharged between October 1, 1993, and June 1, 1994. 
 
Paragraph  8  of  ALCOAST  069/93  stated  that  “[c]ommands  shall  ensure 
 
members  who  request  early  release  from  active  duty  under  this  program  are 
counseled [in accordance with COMDTINST 1760.9, the MGIB instruction] on the 
consequences their actions may have on MGIB eligibility.” 
 
 
Paragraph  10  stated  that  “separation  program  designator  ‘LDM’  for 
[members being released from active duty] and ‘JDM’ for [members being dis-
charged] shall be assigned.” 
 

Paragraph 11 stated that “[t]his early release program is strictly voluntary 

 
and will not be used in lieu of administrative separation processing.” 
 

On October 1, 1993, the applicant was released from active duty into the 
Coast Guard Reserve.  Her DD 214 indicates that the separation authority for her 
release was Article 12-B-12 of the Personnel Manual.  That article authorizes the 
Commandant  to  separate  members  for  the  “convenience  of  the  government” 
under various circumstances, including general demobilizations and reductions 
in authorized strength.  The DD 214 also shows a narrative reason for separation 
of  “convenience  of  the  government,”  an  SPD  code  of  LDM  (involuntary  early 
release under an authorized program or circumstance), and a reenlistment code 
of RE-1 (eligible to reenlist). 
 

APPLICABLE LAW 

 
Montgomery G.I. Bill 
 
 
Statutory  requirements  for  entitlement  to  MGIB  benefits  did  not  change 
from the time the applicant enlisted (38 U.S.C. § 1411 (1988 Supp. II)) until she 
was released (38 U.S.C. § 3011 (1988 Supp. IV)).  The statute read as follows: 
 

 

 

 

 

(1)  who— 
 

(A)    after  June  30,  1985,  first  becomes  a  member  of  the  Armed 

(a)  Except as provided in subsection (c) of this section, each individual – 
 
 
Forces or first enters on active duty as a member of the Armed Forces and – 
 
(i)    who  (I)  serves,  as  the  individual’s  initial  obligated 
period of active duty, at least three years of continuous active duty in the Armed 
Forces, … ; or 
(ii)  who serves in the Armed Forces and is discharged 
 
or released from active duty … ; (II) for the convenience of the Government, … in 
the case of an individual who completed not less than 30 months of continuous 
active duty if the initial obligated period of active duty of the individual was at 
least three years; or (III) involuntarily for the convenience of the government as a 
result  of  a  reduction  in  force,  as  determined  by  the  Secretary  of  the  military 
department  concerned  in  accordance  with  regulations  prescribed  by  the  Secre-
tary of Defense or by the  Secretary of Transportation with respect to the Coast 
Guard when it is not operating as a service in the Navy; … 
 
 
subsection— 

(2)  who [receives a high school diploma or the equivalent]; and 
(3)    who,  after  completion  of  the  service  described  in  clause  (1)  of  this 

•  •  • 

 

 
(D)  is released from active duty for further service in a reserve 
component of the Armed Forces after service on active duty characterized by the 
Secretary concerned as honorable service;  
 
is entitled to basic educational assistance under this chapter. 

 

Commandant Instruction M1900.4C 
 
 
On March 12, 1990, the Commandant issued revised instructions for filling 
out  the  DD  214.    This  instruction  was  in  force  until  September  28,  1993,  three 
days before the applicant’s release from active duty.  Chapter 1.C. of the instruc-
tion stated that the “Commandant (G-PE) will specify [the narrative reason for 
separation] entries to be made in [block 28] by pertinent letter or orders issued.” 
 

Chapter  2.C.  of  the  instruction  lists  the  following  various  possible  SPD 
codes, narrative reasons, and reenlistment codes that can be assigned to enlisted 
members who are discharged or released from active duty pursuant to a reduc-
tion in force: 
 
SPD 
 
Code 
Narrative Reason for Separation 
JCC  General demobilization/reduction in 

 
Authority 
12-B-12 

Reenlistment 
Code 
RE-R1, RE-1, or 
RE-4 
RE-R1, RE-1, or 
RE-4 
RE-R1 or RE-1 

12-B-12 

12-B-12 

RE-R1 or RE-1 

12-B-12 

RE-R1, RE-1, or 
RE-4 
RE-R1, RE-1, or 
RE-4 
RE-R1 or RE-1 

12-B-12 

12-B-12 

12-B-12 

RE-R1 or RE-1 

12-B-12 

 
Explanation 
Involuntary 
discharge 
Voluntary 
discharge 
Involuntary 
release 
Voluntary 
release 
Involuntary 
discharge 
Voluntary 
discharge 
Involuntary 
release 
Voluntary 
release 

KCC  General demobilization—Reduction in 

authorized strength 

authorized strength 

authorized strength 

LCC  General demobilization, reduction in 

MCC  General demobilization—Reduction in 

JDM 

authorized strength 
Early separation under an authorized 
program or circumstance 

KDM  Early separation under an authorized 

program or circumstance 

LDM  Early release under an authorized 

program or circumstance 

MDM  Early release under an authorized 

program or circumstance 

 

Commandant Instruction M1900.4D and the SPD Handbook 
 
 
On  September  28,  1993,  three  days  before  the  applicant’s  release  from 
active duty, the Commandant issued revised instructions for filling out the DD 
214  in  COMDTINST  M1900.4D.    Chapter  1.E.  provided  that  “the  appropriate 
separation  code  (SPD)  associated  with  a  particular  authority  and  reason  for 
separation  as  shown  in  the  SPD  Handbook  or  as  stated  by  the  [Military 
Personnel  Command]  in  the  message  granting  discharge  authority”  shall  be 
entered in block 26 of the DD 214.  In addition, the Military Personnel Command 
would specify the narrative reason for separation to be entered in block 28 “by 
pertinent letter or orders issued.”   
 

The provisions of former Chapter 2.C. were revised and issued in a sepa-
rate SPD Handbook.  The handbook was initially issued in draft form, and was 
issued in final form with minor revisions on January 13, 1994.  The handbook, in 
effect on October 1, 1993, does not contain an LDM separation code.  It includes 
the following: 
 
SPD 
Code 
JCC 

 
Narrative Reason for Separation 
Reduction in force 

Reenlistment 
Code 
RE-1 or RE-4 

 
Authority 
12-B-12 

KCC  Reduction in force 

LCC  Reduction in force 

MCC  Reduction in force 

MDM  Holiday Early Release Program 

RE-1 or RE-4 

12-B-12 

RE-1 or RE-4 

12-B-12 

RE-1 

RE-1 

12-B-12 

12-B-12 

 
Explanation 
Involuntary 
discharge  
Voluntary 
discharge 
Involuntary 
release  
Voluntary 
release 
Voluntary 
release 

 
Personnel Manual (COMDTINST M1000.6A) 
 
 
Article 12-B-12.a.(6) of the Personnel Manual, entitled “Convenience of the 
Government,” states that the Commandant may authorize or direct the separa-
tion of enlisted personnel “[t]o provide for early separation of personnel under 
various  authorized  programs  and  circumstances.”    Separations  for  “[g]eneral 
demobilization, reduction in authorized strength or by an order applicable to all 
members of a class of personnel specified in the order” are permitted under Arti-
cle 12-B-12.a.(1). 
 

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 submissions, 
and applicable law: 

 

The Board has jurisdiction concerning this matter pursuant to sec-

1. 

2. 

3. 

6. 

tion 1552 of title 10 of the United States Code. 
 

4. 

The applicant stated that she did not discover that the separation 
code on her DD Form 214, LDM, did not reflect the actual circumstances of her 
release  from  active  duty  until  November  20,  1997.    Therefore,  the  Board  finds 
that her application was timely. 
 
 
The  preponderance  of  the  evidence  indicates  that  the  applicant 
voluntarily sought to be released from active duty on October 1, 1993, pursuant 
to  the  provisions  of  ALCOAST  069/93,  issued  on  July  26,  19993.    ALCOAST 
069/93, seemingly anomalously, required applicant to be released with a separa-
tion code of LDM, which signified an involuntary release under an authorized 
program.  COMDTINST M1900.4C, Chapter 2.C.  By the time of the applicant’s 
release on October 1st, however, the separation code LDM had been discontin-
ued since COMDTINST M1900.4C was cancelled on September 28, 1993, and the 
new draft SPD Handbook did not include an LDM separation code. 
 
 
The Chief Counsel of the Coast Guard alleged that the LDM code 
was not in error but recommended that the Board grant relief by assigning the 
applicant  a  KCC  separation  code.    The Chief  Counsel  stated that  the  applicant 
would  have  received  a  KCC  separation  code  had  she  been  separated  after  the 
new  SPD  Handbook  was  issued.    However,  both  COMDTINST  M1900.4C  and 
the  new  SPD  Handbook  show  that  the  KCC  separation  code  should  be  used 
when a member is voluntarily discharged under a reduction in force.  Because 
the applicant was not discharged but instead released into the Reserve, the Board 
finds that the use of the KCC code would be inaccurate. 
 
 
Because  the  early  release  program  authorized  under  ALCOAST 
069/93  was  actually  voluntary,  it  should  have  required  the  applicant  to  be 
assigned the separation code MDM, not LDM, in accordance with the provisions 
of COMDTINST M1900.4C.  However, by the time members could be released 
under ALCOAST 069/93, COMDTINST M1900.4C and the LDM separation code 
had  been  cancelled,  and  the  meaning  of  the  MDM  separation  code  had  been 
modified to indicate an early release due to a holiday.  When the applicant was 
released on October 1, 1993, the separation code most closely describing the con-
ditions  of  her  release  under  the  new  SPD  Handbook  was  MCC,  which  means 
voluntary release due to a reduction in force. 
 

The  applicant  alleged  that  she  did  not  know  that  she  would  be 
giving  up  certain  veterans’  benefits  by  requesting  release  under  ALCOAST 
069/93.  A voluntary separation from military service is rendered involuntary if 

5. 

it results from misrepresentation or deception on the part of government officers. 
See Tippett v. United States, 185 F.3d 1250, 1255 (Fed. Cir. 1999); Scharf v. United 
States, 710 F.2d 1572, 1574 (Fed. Cir. 1983).  ALCOAST 069/93 clearly indicates 
that  members  requesting  release  under  its  terms  may  forgo  MGIB  benefits.  
Moreover,  it  required  that  such  members  be  counseled  concerning  the  MGIB 
educational  benefits  they  might  be  forgoing.    The  applicant  has  not  presented 
any evidence to overcome the presumption that her superior officers acted cor-
rectly,  lawfully,  and  in  good  faith  with  respect  to  counseling  her  under 
ALCOAST 069/93.  Arens v. United States, 969 F.2d 1034, 1037 (1992); Sanders v. 
United  States,  594  F.2d  804,  813  (Ct.  Cl.  1979).    Moreover,  when  she  enlisted  in 
1991, the applicant signed two documents describing the requirements for MGIB 
benefits.    Although  the  documents,  CG-3301I  and  DD  2366,  were  inconsistent 
with each other, under neither of them nor under the statute, 38 U.S.C. § 3011, 
would her two years, two months, and three days of active service have qualified 
her  for  MGIB  benefits.    Therefore,  the  Board  finds  that  the  applicant  has  not 
proved by a preponderance of the evidence that her release from active duty was 
rendered involuntary by any misrepresentation or deception on the part of the 
Coast Guard.  

 
7. 

8. 

 
Hoping  that  the  DVA  would  find  her  eligible  for  MGIB  benefits 
under 38 U.S.C. § 3011, the applicant asked that her SPD code, narrative reason 
for  separation,  and  authority  for  separation  be  changed  to  show  the  she  was 
involuntarily released from active duty during a reduction in force.  The Chief 
Counsel  indicated  that  the  program  devised  under  ALCOAST  069/93  was 
indeed a reduction in force.  However, the record proves that her release from 
active duty was voluntary. 
 
 
It  is  not  clear  from  the  record  whether  ALCOAST  069/93  (under 
which the applicant received the LDM separation code) was intended to overrule 
COMDTINST M1900.4C (under which she would have received an MDM sepa-
ration code) or COMDTINST M1900.4D (under which she should have received 
an MCC separation code).  Nothing in the text of the ALCOAST indicates such 
an  intent,  but  her  command  apparently  followed  its  dictates  regardless  of  the 
standing regulations in the COMDTINSTs.  The applicant has not proved by a 
preponderance of the evidence that her command committed an error or injustice 
in following the requirements of ALCOAST 069/93.  Moreover, if her command 
had followed the terms of COMDTINST M1900.4C or COMDTINST M1900.4D, 
she would have received a separation code indicating a voluntary release (MDM 
or  MCC),  rather  than  the  involuntary  code,  LDM,  she  now  has.    Voluntary 
releases during a reduction in force do not qualify a member for MGIB benefits 
under 38 U.S.C. § 3011.  Therefore, with respect to MGIB benefits, the applicant 
would  have  been  no  better  off  if  her  command  had  followed  the  terms  of  the 
COMDTINSTs rather than those of the ALCOAST. 

10. 

 
 
The applicant has not proved by a preponderance of the evidence 
that her DD 214 should reflect an involuntary release during a reduction in force.  
Furthermore, it is not apparent to the Board that she would benefit in any way by 
having her separation code changed to MDM or MCC.  
 
 
If the terms of paragraph 2.h. of the form DD 2366 signed by the 
applicant on August 15, 1991, are correct, she may be eligible for MGIB benefits 
upon  completion  of  four  years  in  the  Reserve  since  she  served  more  than  two 
years on active duty. 
 
 
11.  Accordingly, the Board should deny the requested relief.  However, 
if the applicant applies to the Board for reconsideration of her case, requesting 
that  her  separation  code  be  changed  to  MCC,  the  Board  shall  docket  her 
application. 

9. 

 

 
 

 

ORDER 

The  application  of  former  XXXXXXXXX,  USCG,  for  correction  of  her 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

military record is hereby denied. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 

 
 
Mark A. Holmstrup 

 

 

 
 
Thomas A. Phemister 

 

 

 
L. L. Sutter