DEPARTMENT OF HOMELAND SECURITY 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 
Application for the Correction of 
the Coast Guard Record of: 
 
                                                                                BCMR Docket No.  2011-215 
XXXXXXXXXXXXXXXXX 
XXXXXXXXXXXXXXXXX 
 

 

 

 
 

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 28, 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  June  21,  2012,  is  approved  and  signed  by  the  three  duly 

APPLICANT’S REQUEST AND ALLEGATIONS 

 
 
 The  applicant  asked  the  Board  to  correct  his  record  by  promoting  him  to  commander 
(CDR) with the date of rank he would have had if he had been selected for promotion year (PY) 
by  the  PY  2011  selection  board.    In  the  alternative,  he  asked  that  his  record  be  corrected  by 
removing  his  two  non-selections  for  promotion  to  commander  CDR  before  the  PY  2011  and 
2012 CDR selection boards.1,2  He also requested that if selected by the first selection board to 
consider  him  with  a  corrected  record  that  his  CDR  date  of  rank  be  backdated  to  the  date  he 
would have received if selected by the PY 2011 selection board.   
 
 
The  applicant  alleged  that  he  had  an  incomplete  record  before  the  PY  2011  CDR 
selection board.  In this regard, the evidence shows that his record of professional development 
(CG-4082) covering courses and training that he completed from approximately June 9, 2005 to 
August  14,  2009  (approximately  22  courses)  was  not  in  his  record.    In  addition,  the  applicant 
stated that the evaluation summary sheet in “Direct Access” showed his job classification as that 
of  a  LT  when  he  was  a  LCDR  filling  a  LCDR’s  job.    One  of  the  documents  submitted  by  the 
applicant entitled “My Employee Review” has two entries.  One entry shows that from June 29, 
                                                 
1  At the time he submitted his application, the applicant had only one failure of selection for promotion 
to CDR.  While  his application  was pending before the  BCMR he  encountered his second  non-selection 
before the PY 2012 CDR selection board.   

2   The terms non-selection, failure of selection, and passovers are used interchangeably in this decision.   

 

 

2005 to April 30, 2006, his job and position codes were that of a lieutenant.”  The more recent 
entry shows that from May 1, 2006 to April 30, 2007, his job and position codes were that of a 
LCDR.  His LCDR date of rank is March 1, 2006.   
 
 
The applicant submitted evidence showing that he made every effort to have a corrected 
record before the PY 2011 CDR selection board.  He submitted several documents including the 
record of professional development to PSC for inclusion in his record prior to convening of the 
PY 2011 selection board.  However, the last two pages of the professional  development  record 
were not in his record before the PY 2011 selection board.   
 
 
alleged incorrect LT job classification occurred after the PY 2011 non-selection.   
 

It  appears  from  the  record  that  the  discovery  of  the  alleged  error  with  respect  to  the 

VIEWS OF THE COAST GUARD 

 
 
On October 20, 2011, the Judge Advocate General (JAG) of the Coast Guard submitted 
an  advisory  opinion  recommending  that  the  Board  grant  relief  in  accordance  with  a 
memorandum submitted by the Commander, Personnel Service Center (PSC). 
 
 
PSC  stated  that  “despite  the  applicant’s  attempts  to  rectify  the  situation  with  respect  to 
errors in his record, not all items were added to his record or corrected in time for the [PY 2011] 
promotion  board  and  thus  an  injustice  has  been  substantiated.”  PSC  added  that  the  omitted 
documents  could  have  had  an  impact  on  the  selection  board’s  determination  not  to  select  the 
applicant because the applicant had a 5-year gap in his professional development history.   
 
However,  PSC  affirmed  that  the  applicant’s  record  was  corrected  in  time for  evaluation 
 
by the PY 2012 CDR selection board, but the applicant was not selected for promotion to CDR 
by that board with a corrected record.  Therefore, PSC argued that the non-selection before the 
PY 2012 selection should not be removed from the applicant’s record.   
 
 
In  light  of  the  above,  PSC  recommended  the  removal  of  the  applicant’s  PY  2011  non-
selection for promotion to CDR, but PSC did not recommend the removal of the applicant’s PY 
2012 non-selection and stated that the PY 2012 failure should count as the applicant’s first failure 
of  selection.    PSC  recommended  that  the  applicant’s  record  be  reviewed  by  the  PY  2013  CDR 
selection board, and if selected by the PY 2013 selection board that his date of rank be corrected 
to the date he would have received if he had been selected by the PY 2012 selection board.   
  

APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 

 
 
On  January  24  2012,  the  Board  received  the  applicant’s  response  to  the  views  of  the 
Coast Guard.  He agreed with them, except that he disagreed that his PY 2012 failure of selection 
should not be removed.   
 
The applicant argued that the Coast Guard’s contention that he did not suffer an injustice 
 
before the PY 2012 selection board is incorrect and that the remedy recommended by the Coast 
Guard is inadequate.  The applicant argued that the appropriate remedy in this case would be  a 

 

 

special  selection  board,  as  authorized  by  10  U.S.C.  §  628(b),  where  an  officer’s  record  is 
compared  with  a  sampling  of  other  officer’s  records  who  were  selected  and  the  special  board 
renders a determination as to whether that non-selected officer would have been selected with a 
corrected record. 3 
 
 
In  the  alternative,  the  applicant  argued  that  the  Coast  Guard  should  remove  both  of  his 
non-selections for promotion from his record.  The applicant argued that in determining whether 
a  failure  of  selection  should  be  removed,  the  Board  must  consider  (1)  whether  the  error  was 
prejudicial to the applicant’s record in the sense that it made the applicant’s record appear worse 
than it would have without the errors, and (2) whether it is unlikely that the applicant would have 
been promoted in any event.  BCMR No. 2007-022, citing Engels v. United States, 678 F.2d 173, 
177 (Ct. Cl. 1982).  The applicant argued that he is not required to prove that the error changed 
the  result  of  the  selection  board,  just  that  the  error  prejudiced  his  record.   The  applicant  stated 
that  in  assessing  whether  an  error  prejudiced  his  record,  “the  fundamental  principal  is  whether 
[the applicant’s] record before the selection boards still portrayed his service career on a fair and 
equitable  basis.”    Hary  v.  United  States,  618  F.2d  704,  708  (Ct.  Cl.  1980).   The  end  burden  of 
demonstrating the harmlessness of the error falls on the government.  Engels, 678 F.2d at 176. 
 
The  applicant  argued  that  his  non-selection  by  the  PY  2011  selection  board  had  lasting 
 
negative impacts that prejudiced his record before the PY 2012 selection board.  He argued that 
his  record  before  the  PY  2012  selection  board  was  prejudiced  by  indicators  that  he  had  been 
previously passed over for promotion.  He stated that the Federal Court of Claims has recognized 
“the inherently detrimental nature of the presence of passovers in a serviceman’s record . . .”  See 
Riley  v.  United  States,  608  F.2d  441,  444  (Ct.  Cl.  1979).    With  regard  to  the  Riley  case,  the 
applicant offered the following: 
 

[T]he court invalidated a second nonselection for promotion on the basis that an 
earlier  nonselection  was  prejudicial  to  the  serviceman’s  record.    In  Riley,  a 
serviceman  was  passed  over  for  promotion  for  the  first  time  after  the  selection 
board  viewed  a  record  that  contained  two  erroneous  OERs.    Id.  at  442.    The 
erroneous  OERs  were  removed  from  [the  applicant’s]  record  and  [the  applicant] 
applied to have the passover removed from his record. Id.   While the application 
was pending, the applicant was passed over a second time.  Id.  The record before 
the  second  selection  board  did  not  contain  the  erroneous  OERs,  but  did  indicate 
that [the applicant] was previously passed over for promotion. Id.  The court held 
that  inclusion  of  the  first  nonselection  in  the  serviceman’s  record  before  the 
second selection board was prejudicial error.  Id at 444.  “[T]he parties and even 
the  Correction  Board  acknowledged  that  previous  passovers  may  detrimentally 
affect  promotion  opportunities.”    Id.    As  the  first  nonselection  was  based  on 
material  error that prejudiced the serviceman’s record and the nonselection itself 
was prejudicial, both the first and second nonselections were equally invalid even 
though  the  erroneous  OERs  had  been  removed  from  the  serviceman’s  record  by 
the time the second selection board considered him for promotion.  Id.  The court 

                                                 
3   The  Coast  Guard  does  not  have  the  authority  to  convene  special  selection  boards.    See  Memorandum  from  the 
Office of the Judge Advocate General, General Law Division (January 26, 2001).   

 

 

ordered a nonprejudicial explanation be put in the serviceman’s record addressing 
the gaps caused by the nonselections.  Id at 445.   

 
The applicant stated that the Coast Guard lists the in-zone and above-zone4 candidates for 
 
promotion in a combined list to avoid disclosing candidates who are above-zone to the selection 
board.  According to ALCGOFF 093/11, the Coast Guard listed members to be considered by the 
PY 2012 selection board alphabetically.  The only other information about the members on that 
list was their employee identification numbers.  Out of 261 candidates, the applicant’s name was 
listed  as  number  149.    The  applicant  stated  that  this  procedure  of  listing  members  failed  to 
remove  all  indicators  from  the  record  of  a  candidate  who  has  been  previously  passed  over  for 
promotion.   The applicant  argued that his  date of rank and the fact  that  he had one more OER 
than other candidates indicated to the CDR selection board that he had a previous non-selection.  
The  applicant  stated  that  based  on  promotion  statistics  in  the  announcement  of  the  selection 
board  results  for  PY  2012  there  was  a  74%  (125/170)  opportunity  of  selection  for  in-zone 
officers  and  a  20%  (18/90)  opportunity  of  selection  for  above-zone  officers.    The  applicant 
argued  that  by  virtue  of  his  date  of  rank  he  would  have  been  associated  with  the  above-zone 
officers at the PY 2012 CDR board.   
 
The applicant argued that his record was further prejudiced before the PY 2012 selection 
 
board  because  due  to  his  non-selection  before  the  PY  2011  selection  board,  he  was  unable  to 
pursue career enhancing assignments that would have made him a stronger candidate before the 
PY 2012 board.  In addition, the applicant stated that the employee summary sheet that showed 
his rank as lieutenant was not corrected until November 9, 2011 after the PY 2012 CDR selection 
board met on July 26, 2011.  The  applicant  argued that the selection board would have had no 
way of knowing that the rank error on his employee summary sheet was an administrative error, 
and that it would have been logical for the selection board to conclude that the error was simply 
an indication of the applicant’s carelessness in checking his record for accuracy prior to the CDR 
board.  The applicant also stated the following: 
 

The PY11 non-select basically foreclosed all opportunity for applicant to comply 
with the Commandant’s guidance to the PY 12 board that “[o]fficers should aspire 
.  .  .  to  assignments  that  provide  them  with  successively  greater  levels  of 
responsibility,  authority  and  accountability.”      .  .  .  The  lack  of  an  end  of  tour 
award,  applicant’s  inability  to  seek  career  enhancing  assignments,  the  continued 
presence of errors in the record, and the indicators to the board that applicant had 
a  previous  non-select  on  his  record  made  applicant’s  record  at  the  PY12  [CDR] 
board  weaker  than  it  would  have  been  had  it  not  been  for  the  Coast  Guard’s 
failure to correct substantial errors in applicant’s record for the PY11 board.  It is 
impossible  to  know  whether  these  errors  in  fact  caused  the  PY  [CDR]  board  to 
non-select  applicant.    However,  applicant  must  only  show  the  record  appeared 
worse than it would have without the errors.  Other than the non-selects in PY11 
and PY 12, applicant had had a stellar career in the Coast Guard.  There is nothing 
in his record to indicate that applicant would not have been selected for promotion 
even if his record had not been correct.   

                                                 
4   Above-zone refers to an officer who has been passed over for promotion.   

 

 

   
 

FINDINGS AND CONCLUSIONS 

 

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

3. 

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 was not selected by the PY 2011 selection board for promotion to CDR.  
After  learning  of  his  non-selection,  he  reviewed  his  record  and  discovered  two  pages  were 
missing  from  his  Professional  Development  Record.    He  filed  an  application  with  the  Board 
seeking a direct promotion because of the error and failure.   In the alternative, he requested the 
removal of his failure of selection before the PY 2011 selection board, and that if selected by the 
PY 2012 board, that his date of rank be backdated to what it would have been if selected by the 
PY 2011 board.   
 
  While  his  application  was  pending  before  the  BCMR,  the  Coast  Guard 
 
administratively  corrected  the  applicant’s  record  by  including  a  complete  copy  of  his 
Professional  Development  Record.    His  corrected  record  was  then  placed  before  the  PY  2012 
CDR selection board.  However, even with the corrected record,  the applicant was not selected 
for promotion by the PY 2012 CDR selection board. After the applicant’s failure before the PY 
2012 board, the Coast Guard issued an advisory opinion in this case recommending removal of 
the  PY  2011  failure  of  selection,  but  not  the  PY  2012  failure.    In  his  reply  to  the  advisory 
opinion, the applicant  renewed his  request for  a  special board.   In the alternative, he requested 
removal of his PY 2011 and PY 2012 failures of selection, and that if he is selected by the PY 
2013 selection board that  his  date of  rank be adjusted to  the date he  would  have had if he had 
been selected by the PY 2011 selection board.    
 
 
4.  With respect to the applicant’s request for a special selection board, the Board has no 
such authority.  The General Law Division of the office of the JAG stated in a January 26, 2001 
memorandum  that  10  U.S.C.  §  628  does  not  authorize  the  Coast  Guard  to  convene  special 
selection boards. .  Nor is it the Board’s policy to promote an officer who has not been selected 
by  a duly  convened selection board.   In  similar  cases, the  Board has  denied requests for direct 
promotions, including BCMR Nos. 1998-065, 2008-024, and 2010-038.  As the Board explained 
in BCMR 2008-024 (finding 14) for not directly promoting an officer: 
 

The  applicant  requested  that  upon  a  finding  of  error  or  injustice  that  the  Board 
order  his  promotion  to  the  grade  of  LCDR,  as  well  as  direct  the  removal  of  his 
two  failures  of  selection  of  promotion  to  LCDR.   The  Board  does  not  normally 
promote  but  instead  removes  failures  of  selection  for  promotion  that  allows  the 
applicant  another  opportunity(s)  to  be  considered  for  promotion  by  a  duly 
constituted  selection  board  with  a  corrected  record.  .  .  .  Moreover,  decisions  on 
promotions  are  better  left  to  the  Service  which  has  a  selection  board  process  in 
place to determine who is best qualified for service in the next higher grade.    

 

 

 
Therefore,  the  Board  will  consider  the  applicant’s  request  for  alternative  relief,  which  is  the 
removal of his PY 2011 and 2012 failures of selection and backdating of his CDR date of rank to 
the PY 2011 board if he is selected for CDR by the PY 2013 selection board.   
 
 
 
5.  With regard to the PY 2011 selection board, the Board finds that the applicant’s record 
before that board contained a prejudicial error.  The Coast Guard admitted, and the Board finds, 
that the applicant’s record before the PY 2011 CDR selection board was inaccurate because it did 
not  include  the  applicant’s  complete  Professional  Development  Record.  Therefore,  the  Coast 
Guard  recommended,  and  the  Board  agrees,  that  as  a  result  of  this  prejudicial  error,  the 
applicant’s  PY  2011  failure  of  selection  for  promotion  to  CDR  should  be  removed  from  his 
record.   
   
 
6.  With regard to the PY 2012 selection board, the Coast Guard stated that the applicant 
had a  correct  record before that board and still was not  selected for promotion.  Therefore, the 
Coast Guard argued that his PY 2012 failure should not be removed.   In contrast, the applicant 
argued that his PY 2012 failure of selection for promotion to CDR should be removed because, 
even though the error had been corrected and even though the Coast Guard does not distinguish 
between in-zone and above-zone officers before selection boards, he  was prejudiced  before the 
2012 board by the fact that the selection board knew that he was above-zone based on his LCDR 
date  of  rank  and  due  to  his  having  one  more  OER  than  other  in-zone  officers.      However 
ALCGOFF  093/11  issued  on  June  15,  2011  published  the  selection  board  list  for  the  PY  2012 
CDR board and listed officers alphabetically by last name with no other information on that list 
except for their employee identification numbers.  By listing the officers alphabetically there was 
no indication on that list who was more senior or who was in or above-zone.   Of the 261 officers 
on  the  selection  board  list,  the  applicant  was  listed  as  number  149.    Therefore,  with  just  the 
names listed alphabetically and no other information about the officer on that list,  the selection 
board  could  not  tell  from  that  list  which  officers  were  above-zone.  The  applicant  has  not 
provided an explanation  why  the selection board  would be  curious  about  his  date of rank such 
that  it  would  review  and  compare  dates  of  ranks  for  all  261  officers.    The  applicant  has  not 
presented  sufficient  evidence  that  it  was  apparent  to  the  PY  2012  selection  board  that  he  was 
above-zone due to his date of rank.  Nor has he presented sufficient evidence that the selection 
board was aware that he was above-zone because he had one more OER than other members on 
the  list.  Except  for  his  statement,  he  presented  no  concrete  evidence  in  this  regard.      The 
applicant has failed to establish an error in his record before the PY 2012 board and without the 
establishment of an error there is no basis on which to discuss removing a failure of selection due 
to  prejudice  or  any  other  reason.    See  Engels  v.  United  States,  678  F.2d  173,  175  (“officers 
claiming    .  .  .  to  have  been  improperly  selected  out,  after  passovers,  must  first  show  that  the 
service committed a legal error.”)  The court further stated in  Engels that as to the existence of 
the error, the burden of going forward and of persuasion lies squarely with the claimant.  In this 
case, the applicant speculates as to errors but offers insufficient proof that any error occurred in 
his record before the PY 2012 selection board.   
 
7.    Even  if  the  selection  board  was  aware  of  the  applicant’s  date  of  rank,  it  would  not 
 
prove that the applicant was above-zone.  In this regard, the officers may have different dates of 
rank  for  different  reasons.    For  instance,  officers  on  the  list  could  have  had  date  of  rank 

 

 

adjustments  through  BCMR  action.    Therefore,  it  cannot  be  automatically  assumed,  as  the 
applicant has done, that what appears to be an earlier date of rank means that an officer is above-
zone.   
 
 
8.    The applicant next alleged that the rank history entry on his employee summary sheet 
indicating  that  he  held  a  LT’s  position  immediately  after  his  promotion  to  LCDR  was  not 
corrected until after the PY 2012 board dismissed. The Coast Guard indicated that the applicant 
had a correct record before the PY 2012 selection board.  Except for his statement, the applicant 
did not present any evidence showing when this correction was actually made.  He suggested that 
this error may have led the selection board to believe that he was not concerned enough about his 
record  to  review  and  correct  it  prior  to  the  selection  board  meeting.    However,  even  if  the 
employee summary sheet indicated that he held a LT’s position as a LCDR immediately after his 
promotion to LCDR, it was clearly obvious that the applicant was a LCDR, since the following 
entry on the employee summary sheet showed that he was a LCDR and since he was competing 
for promotion to CDR before the PY 2012 selection board.  He would not have been competing 
for promotion to CDR as a LT.  Moreover, all of his LCDR OERs showed his rank as LCDR, as 
did  his  Record  of  Professional  Development.      In  addition,  the  applicant’s  suggestion  that  an 
incorrect  rank  on  an  employee  summary  sheet,  which  was  an  obvious  administrative  error  and 
was  refuted  by  accurate  reflections  of  his  rank  and  the  other  overwhelming  evidence  in  the  
record, would have influenced the selection board or  outweighed an otherwise strong record of 
performance is not persuasive to the Board.   The Board is not persuaded that this administrative 
error constituted a legal error that was prejudicial to the applicant before the PY 2012 selection 
board because it did not make his overall record appear worse.  See Engels at 176.5   
 
 
9.    In  light  of  the  above  finding,  the  Board  agrees  with  the  advisory  opinion  that  the 
applicant’s  PY  2011  failure  should  be  removed  from  his  record  and  treated  as  if  it  never 
occurred. The PY 2012 failure should not  be removed  because he had a  substantially  complete 
and fair record when he was considered for promotion by PY 2012 selection board.  In Hary v. 
United  States,  618  F.2d  704,  709  (1980),  the  court  stated  that  an  officer  is  entitled  to  a  record 
before a selection board that is “substantially complete and fair,” which the applicant had before 
the PY 2012 selection board.     Therefore, his PY 2012 failure should be treated as first failure, 
as recommended in the advisory opinion.  The applicant’s record should be placed before the PY 
2013 selection board and if selected by that board, his date of rank should be adjusted to that he 
would have received if selected by the PY 2012 board.     
 
 
10.    The  Coast  Guard  recommended  relief  that  is  more  generous  than  Board  precedent 
supports.   In such past situations, the Board has ordered the Coast Guard to correct the error and 
to  remove  the  applicant’s  failure  of  selection  for  promotion.    The  Board’s  order  would  have 
further directed that if the applicant is selected for promotion by the first board to consider him 
with a corrected record, his date of rank should be backdated.  (If the applicant is not selected by 
the  first  board  to  consider  him  with  a  corrected  record,  he  is  usually  not  backdated  by  the 
BCMR.)  See ordering language in BCMR Nos. 2008-024 and 2010-038.  

                                                 
5  In Engels, the United States Court of Claims established two "separate but interrelated standards" to determine the 
issue of nexus.  The standards are as follows:  "First, was the claimant's record prejudiced by the errors in the sense 
that  the  record  appears  worse  than  it  would  in  the  absence  of  the  errors?    Second,  even  if  there  was  some  such 
prejudice, is it unlikely that he would have been promoted in any event?”  Id. at 176. 

 

 

 

 
The Coast Guard recommended relief in the applicant’s case similar to that that an officer 
would  be  entitled  to  whose  record  was  not  considered  by  a  selection  board  due  to  an 
administrative error. Under 14 U.S.C. § 262(b) an officer shall not be considered to have failed 
of selection if he was not considered by a selection board because of administrative error.  The 
law further states that “[i]f he is selected by the next succeeding selection board and promoted, 
he shall be given the date of rank and position on the active duty promotion list in the grade to 
which promoted that he would have held had he been recommended by the first selection board.”  
In cases of administrative error, it is as if the administrative error never occurred. In this case, by 
treating the applicant’s PY 2012 failure as his first, it is as if the FY 2011 failure never occurred.   
Even though under Board precedent, the applicant would not be entitled to backdating if selected 
by  the  PY  2013  board  because  he  failed  before  the  PY  2012  selection  board  with  a  corrected 
record, this Board will grant the relief recommended by the Coast Guard under this particular set 
of circumstances.   
 
 
11.  Accordingly, the  applicant  should have the  partial relief  recommended by the JAG, 
which  includes  the  removal  of  his  PY  2011  failure  of  selection  for  promotion  to  CDR  as  if  it 
never  occurred.    His  PY  2012  failure  of  selection  for  promotion  should  not  be  removed  and  it 
should  be  considered  his  first  failure  of  selection  for  promotion  to  CDR.    If  he  is  selected  for 
promotion by the PY 2013 selection board he should have the date of rank he would have had, if 
he had been selected by the PY 2012 selection board, with back pay and allowances.     
  
 
 

[ORDER AND SIGNATURES APPEAR ON NEXT PAGE] 

 

 

 

 

ORDER 

 

The  application  of  XXXXXXXXXXXXX,  for  correction  of  his  military  record  is 

granted, in part, as follows: 
 

The Coast Guard shall correct his record by removing his PY 2011 failure of selection for 
promotion to CDR.  His PY 2012 failure of selection for promotion to CDR shall not be removed 
from his record and shall be considered his first failure of selection for promotion to CDR.  If he 
is  selected  for  promotion  to  CDR  by  the  PY  2013  selection  board,  his  date  of  rank  shall  be 
backdated  to  what  it  would  have  been  had  he  been  selected  for  promotion  by  the  PY  2012 
selection board and he shall receive corresponding back pay and allowances. 

  
No other relief is granted.   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 

 
 Philip B. Busch 

 

 

 
 Lynda K. Pilgrim 

 

 

 
 Vicki J. Ray