A REGULAR MEETING OF THE VALUE ADJUSTMENT BOARD
january 13, 2012
The Lake County Value Adjustment Board met in regular session on Friday, January 13, 2012 at 2:00 p.m. in the Board of County Commissioners’ Meeting Room, Lake County Administration Building, Tavares, Florida. Present at the meeting were: Commr. Jimmy Conner, Chairman; Commr. Sean Parks; Jim Miller representing the Lake County School Board; and Will Walker and Ralph Smith as citizen members. Others present were: Alison Yurko, Counsel for the Value Adjustment Board; Kristy Mullane, Accounting Director, County Finance; Frank Royce, Chief Deputy, Property Appraiser’s Office; Peter Peebles, Senior Supervisor, Property Appraiser’s Office; Robbie Ross, Director of Tangible and Agricultural Properties, Property Appraiser’s Office; and Shannon Treen and Susan Boyajan, Deputy Clerks.
approval of minutes of meeting held august 29, 2011
On a motion by Mr. Walker, seconded by Mr. Miller, and carried unanimously by a 5-0 vote, the Board approved the Minutes of August 29, 2011 (Regular Meeting) as presented.
consideration of special magistrate recommendations
Commr. Conner explained what the Value Adjustment Board’s (VAB) authority was under the law, and he asked Ms. Alison Yurko, Special Counsel to the VAB, to further explain that to everyone present.
Ms. Yurko gave a brief overview of the process and noted that they have gotten a number of letters with correspondence and complaints, which they responded to and which were in the blue section of the notebook of backup materials that were provided to the VAB members. She explained that the Florida Administrative Code states in Section 12D-10.003 that the VAB has no power to grant relief either by an adjustment of the value of a property or by granting an exemption on the basis of hardship of a particular taxpayer. She also pointed out that the Florida Administrative Code and statutes were very clear that counties with a certain population can adopt a special magistrate procedure, which is what Lake County has done. She opined that the special magistrates who hear these cases are very experienced and knowledgeable, and the attorneys who hear the exemption cases understand the constitutional implications, case law, and statutes. She added that the special magistrates who hear the valuation cases are appraisers who understand the nuances of the cost approach and the sales comparison approach. She related that the role of the VAB was to make sure that there was no glaring error or oversight, and she opined that there were two cases out of the nine or ten letters she received that may meet that threshold. She noted that she was not an employee of Lake County, but was an employee of the Value Adjustment Board, which was a separate independent body.
Commr. Conner emphasized that this was not a rehearing of anyone’s case before the special magistrate, but to discuss whether the special magistrate made a glaring error, which was what he asked people who speak at this hearing to address.
Ms. Yurko continued to explain that under the rules, she was required to make a recommendation if there is a complaint or correspondence that goes beyond the realm of a routine request for reconsideration. She opined that most of the letters that have been received were basically a disagreement with the special magistrate’s decision and trying to get the evidence reconsidered. She stated that the things under the red category were correspondence that was received late, and after reviewing them she did not find any basis to change any of those recommendations.
Commr. Conner stated that they would hear from those that were present and have filled out a card indicating that they wished to speak.
Ms. Jean Pezzente, a resident of Deland and the Petitioner for Petition No. 2011-16, stated that this started when the Property Appraiser’s Office had the wrong address which was off by a few digits from her actual address, resulting in the card that was sent out being returned to that office and proceedings being filed to discontinue her homestead exemption. She explained that when she cleared up the mistaken address with the Property Appraiser’s Office, Ms. Casburn, an employee of that office, asked her why she had her tax bill sent to Connecticut, and she answered that was because she was not getting her tax bills at her Deland address since they were being sent to the wrong address. She also added that other reasons for denial were that she has property in Connecticut, how much time she spends time in Connecticut, and that she was not present for the hearing, and she did not think any of those things had any bearing on whether she should receive a homestead exemption.
Commr. Parks asked her how much time she spent in Connecticut.
Ms. Pezzente responded that she spends about 5 or 6 months a year there, as well as in Rhode Island at her sister’s home and at the beach, and she told Ms. Casburn that she tries to spend six months and one day in Florida.
Ms. Yurko pointed out that the standard that they would be looking at was that there was a presumption of correctness that the Property Appraiser has, and the Petitioner must refute that by a preponderance of the evidence. She related that she reviewed the file in this case, and the special magistrate pointed out that the Petitioner’s driver’s license, voter identification card, and vehicle registrations all reflected another address.
Ms. Alison Strange from the Law Office of Bret Jones PA, an attorney representing South Lake Crossings, the Petitioners for 2011-40 and 41, mentioned that they filed a memorandum which was included in the backup materials, and she requested that the VAB rule against the recommendation of the special magistrate. She explained that the issue arose because the property prior to her client’s ownership was a citrus grove which has become abandoned in recent years; however, all of the 333-acre property at issue was being used for a commercial cattle lease for 150 head of cattle. She stated that the only fact raised during the hearing which was relevant for the purposes of this board to consider is the fact that if the property had contained oak trees rather than citrus trees, her clients would have received their agricultural exemption, and the reason that the agricultural exemption for cattle has been denied is because the property qualifies for a voluntary program through the Department of Agriculture, which is the Citrus Health Program designed to help the citrus industry. She noted that the right for an agricultural exemption is not a right that is arbitrarily provided by the counties, but a constitutional right provided to owners by the state, and the County could only deny the right based on the current use of the property rather than the past or future use. She opined that the only possible scenarios that the Property Appraiser and special master could have used in this case was that the land was not being maintained and cared for sufficiently for purposes of cattle grazing, and the special magistrate looked at the capability of the soil and grass for livestock of each parcel. She pointed out that on page 2 of the special master’s ruling, the last sentence of her findings of fact states that the evidence showed that the petitioner understands that the dead or diseased trees should be removed and is in the process of getting bids and undertaking such removal. She explained that there are not so many cattle on this property that each piece of acreage must be used at all times, and evidence was provided during the hearing that the cattle move throughout the property and that the leaseholder is making those efforts to clear out where the cattle are moving. She opined that the evidence presented to the special master was sufficient for the VAB to disagree with her factual findings as to the use of all of the acreage, and the Petitioners should not be obligated to take part in the Citrus Health Program in order to obtain their agricultural exemption. She also pointed out that an expert brought in by the Petitioners testified that he had inspected the property and that the entire acreage was sufficient for cattle raising. She concluded that it is South Lake Crossings’ position that there was a legal error here, and she respectfully requested that the VAB give serious review of the facts in the transcript and memorandum of law that had been provided.
Mr. Frank Royce, Chief Deputy, Property Appraiser’s Office, indicated that their office included a response in the backup packet, and he noted that the property would not have been granted an exemption based on citrus and/or timber and was not denied solely because of the voluntary program that they did not sign up for. He pointed out that the District Court of Appeals in case after case has upheld agricultural cases based on use, and numerous visits from their office showed that there was no agricultural use on this property, with only one dead cow found on the property. He concluded that most of the property is abandoned citrus grove, and the condition and the non-agricultural use was the reason for the denial of the agricultural exemption.
Commr. Conner asked how many times they visited the property.
Mr. Peter Peebles, Senior Supervisor, Property Appraiser’s Office, stated that they visited the property five times, and he clarified that the property consisted of a total of 783 acres, 331of which was in dispute, which was fenced off from the rest of the property.
Mr. Smith asked whether it was denied in part because of not participating in the Citrus Health Program previously mentioned.
Mr. Royce answered that it was a contributing factor, but it would not have been denied if that was the only problem.
Ms. Strange asked the VAB to look at the aerials of the property that were provided, and she responded that the 331 acres at issue are over the entire parcel effectively along the outskirts of the piece. She stated that there were certain areas where there were old abandoned groves, but the cattle are free to roam everywhere.
Commr. Conner asked if she concurred that there were no cattle on the property.
She responded that she would be surprised if that were the case, because these are all adjacent and intermixed with open land, and the trees were cut off at the height that the cattle could reach.
Mr. Smith asked if there were any remains or evidence left to show that the cattle were there, such as cow patties or cow paths.
Ms. Strange noted that there was no indication that the cow was dead because of the land and that it could have been an old cow.
Mr. Peebles assured him that his office looks for that also, including the hairs in the barbed wire, trails, or cow patties.
Commr. Conner asked whether there is any support on the VAB to overturn the special magistrate’s decision in this case.
Commr. Parks asked what the difference would have been if it had been oak trees.
Mr. Peebles explained that they are looking at the normal care and maintenance of the property to bring it to any type of use, and nothing was done to this property to transition it into a pasture. He stated that the character of the property is an abandoned grove, and he pointed out that they were given an opportunity to file for a classification of the land as an abandoned grove, which would have given them a minimum two-year time frame to convert it into something else.
Commr. Conner noted that the central issue is whether they could find if the magistrate erred in determining that this was not an agricultural use, but he did not think there was legal criteria in this case to overturn the magistrate’s decision.
Mr. Smith asked if they had the authority to remand it back to the special magistrate.
Ms. Yurko noted that they could do that only in certain cases, and she reviewed the standard evidence sufficient to disagree with the special magistrate. She specified that the statute states the special magistrate process is for the purpose of taking testimony, and they may act upon that without further hearing. She commented that they have digressed into a very fact-specific discussion in this case, and she recommended that there was nothing that would suggest that they should send this back or have a rehearing.
On a motion by Mr. Walker, seconded by Commr. Parks and carried unanimously by a vote of 5-0, the VAB approved the special magistrate’s recommendations of the red category.
On a motion by Mr. Walker, seconded by Commr. Parks and carried unanimously by a vote of 5-0, the VAB approved the special magistrate’s recommendations of the yellow category.
On a motion by Mr. Walker, seconded by Commr. Parks and carried unanimously by a vote of 5-0, the VAB approved the special magistrate’s recommendations of the green category.
Ms. Yurko explained that the blue category consisted of a combination of cases where the petitioners submitted correspondence and/or complaints after the special magistrate hearings that required them under the rules to review the file and statutes. She specified that there were two cases out of those that she was recommending that the VAB might want to consider granting relief based on extraordinary circumstances and reverse the special magistrate’s determination, explaining that in Case No. 2011-353L, the special magistrate found that they were entitled to the church exemption, but they missed the March 1 filing deadline and did not present any evidence of extenuating circumstances. However, since that time they have provided a letter explaining that they had never gotten the notice, since they were just moving into the church.
On a motion by Mr. Walker, seconded by Mr. Smith and carried unanimously by a vote of 5-0, the VAB voted to overturn the special magistrate’s decision and grant relief in the form of the church exemption for Petition No. 2011-353L to the Epiphany Church due to extenuating circumstances.
On a motion by Mr. Miller, seconded by Mr. Walker and carried unanimously by a vote of 5-0, the VAB voted to overturn the special magistrate’s decision and grant relief in the case of Petition No. 2011-29 to Silvion Sedney, since the person previously believed to be a tenant in his household was actually his fiancée and is currently his wife.
Ms. Sandra Kurtz, Petitioner for Petition No. 2011-25, stated that she believed there was an error of mail not being delivered properly which resulted in the loss of her homestead exemption and mentioned that she has homesteaded there since 2005 and does not live anywhere else or rent the home out.
Commr. Conner asked if she had moved at all during that time.
Ms. Kurtz responded that she did not move, but she did work in Tampa and would go back and forth for about a week at a time.
Mr. Royce stated that the Property Appraiser and the special master both thought there was not enough evidence presented to show that she was a qualified resident of this Lake County home.
Ms. Kurtz stated that she had her address in Tampa, but did everything they asked her to do to prove that she was living in her home in Lake County.
Commr. Conner noted that they do not have the authority to overturn the facts of the case.
Ms. Yurko asked if this case was denied because she did not appear at the hearing or present evidence.
Ms. Kurtz responded that she presented evidence but was not at the hearing because she did not see that she had to be there, and people overlook things when they get older.
Ms. Yurko wanted to take a second look at this one.
Mr. Royce commented that it was not denied because she did not appear at the hearing, but was denied because she did not provide sufficient evidence that she lived there. He explained that when his office sends out a renewal homestead card and it come back to them, if the address has been changed or is out-of-town, it will automatically come back to them, and they will send a denial, which starts the process of that person proving residency to them.
Ms. Yurko explained that under the rule, petitioners who do not show up for the hearing or submit evidence are automatically denied, and she stated in her recommendation that the special magistrate did not create an error. She commented that the Petitioner is coming forward for the first time and submitting evidence, stating that she was confused and was not at the hearing.
Commr. Conner asked if they were going to tell everyone who fails to show up that they can present new evidence at this meeting and that the VAB would allow the petitioner to rehear the case. He asked what the VAB members wanted to do regarding this case.
Mr. Walker stated that the petitioner stated that she did provide evidence and whatever the Property Appraiser’s Office asked her to submit, and he asked her what she actually provided in the form of evidence to prove her position that she lived there.
Ms. Kurtz responded that they asked her to get a voters card here.
Commr. Conner asked her where she was registered to vote at the time she was denied the exemption.
Ms. Kurtz answered that she was registered to vote in Tampa as well as had her driver’s license from Tampa at that time, since she was working there.
Commr. Conner pointed out that people vote where they live, not where they work.
Mr. Miller stated that it was the law that she had to have a driver’s license from where she lived.
Mr. Walker stated that he believed that if her voter’s registration card and driver’s license were from Tampa, then her residence is not here. He advised her that if she wanted to get the exemption approved for next year, she had to be sure that she had those things at this address.
Ms. Pamela Lee, Petitioner for 2011-109, related that Florida Constitution Article 7, Section 4, Taxation and Assessments stated that the increase in assessments shall not exceed three percent or the consumer price index and that no assessment shall exceed just value. She related that she has lived on the same property and has had homestead for 20 years, and her assessed value which was $176,893 in 2010 jumped to $241,368 in 2011, which was far above the three percent or the consumer price index of 1.5 percent during that year. She opined that based on those numbers, the assessment should have been $179,546.
Mr. Royce responded that Florida law does limit the increase in homestead property to three percent, the consumer price index, or 100 percent of market value, except when the property owner makes changes to that property. He pointed out that there was some new construction done that was not previously brought on the tax roll, and they found the changes to the property when they next inspected it, resulting in a change in the assessment. He noted that it was also found that there was an apartment over the garage where Ms. Lee currently resides, and she rents out the house. As a result, she is now getting only a percentage of the homestead rather than the full homestead, since part of that property is rental and income property, and she could only get homestead on the portion she lives in.
Ms. Lee responded that her official record card contained information showing that the only two times that a permit was pulled for construction on the property was in 1991 for the original single-family residence and 2000 for the building Mr. Royce was describing, and she stated that those were the only times that anything was done to the properties. She opined that the record card was filled with lies and misinformation, including the fact that she has five acres of dry land.
Ms. Rosemary Webb, the Petitioner for Petition No. 2011-54, opined that she believed her homestead exemption was taken away from her due to an assumption and a lie, explaining that she has had homestead for 20 years here. She related that it started when no one answered the door when the Property Appraiser’s Office came to her home and that there were newspapers in the yard at that time, and the Property Appraiser’s Office had also indicated that her mail was going to Jensen Beach. She explained that she had remarried and spent some of the time at both her home and her husband’s home in 2009 and the first part of 2010, but after her husband died in 2010, she has been living in her house in Leesburg since January except for June, July, and August in Indiana. She clarified that even though it was indicated that she did not appear before the special magistrate, she actually was present for that hearing, and she believed that the record was changed to reflect that.
Commr. Conner noted that the special magistrate’s ruling indicates that the Petitioner has abandoned her Florida property and is actively trying to sell it, and he asked her whether she has abandoned it.
Ms. Webb responded that she has not abandoned the property, and that was one of the assumptions that she had alluded to. She clarified that she owns two houses, including one in Indiana, and she has both houses up for sale and is hoping the Indiana house sells first so that she could stay at her Florida home, since she cannot afford two houses. She also clarified that she did not have homestead in Indiana.
Commr. Conner noted that she is contradicting what the special magistrate concluded, and one of the criteria for overturning the case is that the special magistrate erred. He asked what the basis was for the special magistrate to conclude that she had abandoned her property and intended to sell it.
Mr. Royce related that they had received a phone call that no one was living there, and it looked like that was the case for the couple of visits that they made. He mentioned that the Petitioner had a husband at one time that lived in Jensen Beach and had a house there, and she had property in Indiana as well. He opined that the special master saw that there were several residences and made the determination that the permanent residence at that time was not shown to be Florida.
Ms. Webb pointed out that the Jensen Beach residence was owned by her husband who had died, and she asked why they took homestead for 2011 away from her, since she was only there in 2009 and 2010.
Commr. Conner commented that he was inclined to believe that there was evidence here that contradicts the first line in the last paragraph of the special magistrate’s ruling.
Mr. Royce asked if they could verify the address on her driver’s license and voter identification card.
Ms. Webb stated that both her driver’s license and voter registration currently have the address of the subject property.
On a motion by Mr. Smith, seconded by Mr. Miller and carried unanimously by a vote of 5-0, the VAB voted to overturn the special magistrate’s decision for Petition No. 2011-54.
Ms. Yurko wanted the record to reflect that abandonment is an issue that goes to subjective intent of the parties, and they did hear evidence today which the VAB felt compelling to indicate that the special magistrate erred on this very narrow issue, since they have a different interpretation of what the intent is.
Mr. Walker stated regarding Petition No. 2011-308 that after reading the response from the Petitioner, he did not feel that the figure they came up with is the fair market value, since the water system which was designed to serve 91 houses is serving one house, and there has been a utility adjustment of 55 percent in the value based on how much it is utilized, but the actual utilization is one percent instead of 45 percent. He related that the Petitioner had suggested a value of about $103,030 using a ten percent cap rate, and he would have been allowed to use a 15 percent cap rate under normal public utilities law. He found in his estimation that the $102,030 recommended by the Petitioner is much closer to the actual market value at this point in time. He pointed out that the Property Appraiser’s Office will get their chance to evaluate this each year as the number of users increases, and he indicated that the most current offer received by the owners during the course of trying to sell the property is $20,000 plus $2600 per connection over the next 20 years, which would increase the value as the connections increased.
Mr. Miller stated that he agreed with that based on income, using his background in real estate, since there was no income or hope of income, and he added that no one would pay $1 million for that building.
Ms. Yurko expressed concern that they were second-guessing the special magistrate’s determination, although they have a background in this area and may have come to a different conclusion. She commented that she was not an appraiser and did not understand the nuances of this issue, and she explained that the VAB would need to say that there was an error as a result of the wrong calculation. She suggested that an appeal would be the right place to reweigh that and have expert testimony given, since she believed there was a danger in setting that precedent.
Mr. Walker commented that he was contending that there was an error on the special magistrate’s part in the position that he took in regard to evaluating this property, so he believes they have the right to do that. Secondly, he was well aware what the cost would be to take a matter like this to circuit court, and he believed this board should be somewhat logical and fair to every petitioner.
Commr. Conner commented that he wanted to make sure that they could legally defend any action they take today and that the Property Appraiser could not challenge their decisions in circuit court.
Ms. Yurko responded that the Property Appraiser could challenge the VAB.
Mr. Miller stated that this was a very obvious error to him and Mr. Walker, and he thought they would be remiss if they did not do something regarding this particular case.
Mr. Robbie Ross from the Property Appraiser’s Office explained that this was a tangible personal property case, and it was determined by the courts several years ago that the income approach to tangible personal property is not a good idea, which was why it was not used, although it was considered. He commented that they did what they could to make an adjustment on that value, which was also reinforced by the special magistrate’s determination.
Mr. Miller stated that he thought that was real property.
Mr. Ross responded that it was considered tangible personal property and specialty property, and the owners filed a Public Service Commission report. He added that it was valued at what the plant could sell for and would also have to go under the Florida Public Service Commission guidelines for purchase and what their rate base would be if they did purchase it. He explained that the calculation is based off of what is reported on their annual report to the Public Service Commission, and the utility was calculated based off of the amount of water that was pumped and used by that one home.
Commr. Conner asked if the VAB had the legal authority to rule that the special magistrate erred because they disagree on the value of the property.
Ms. Yurko responded that Mr. Paul MacDermott, an appraiser, was the special magistrate for that case and that only appraisers hear those kinds of cases, because they are uniquely qualified to do that. She explained that there was a presumption of correctness that the Property Appraiser has, which must be refuted by a preponderance of the evidence. She expressed concern about reversing the decision in this case.
Commr. Conner commented that although he respects the commercial real estate knowledge and opinion of the people who are on this board and has an inclination to agree with them, he does not know if the legal test has been met to overturn the ruling. He asked, in fairness to the Petitioner and the VAB, if there was a motion to overturn that ruling.
There was a motion by Mr. Walker, which was seconded by Mr. Smith to overturn the special magistrate’s ruling in Petition No. 2011-308.
Commr. Parks commented that the evaluation is done by an expert.
Ms. Yurko reminded the board that the Statute states that the special magistrate process was for the purpose of taking testimony and making recommendations, which this board may act upon without further hearing. She also commented that something this complicated would be even harder to second-guess.
Mr. Walker pointed out that the area of expertise of this special magistrate was real property and not tangible property.
Commr. Conner noted that the number they recommend would have to be what the Petitioner asked for if they overturned this decision, and he emphasized that this board could not put a number on these properties.
Ms. Yurko stated that if they were inclined to do this, they should probably send it back to the special magistrate with the VAB’s guidance on what they thought the error was.
Mr. Walker withdrew his motion, and Mr. Smith withdrew the second.
Mr. Walker moved to remand the case back to the special magistrate, which was seconded by Mr. Smith.
Ms. Yurko recommended that the VAB not act on this, since she did not think there is a basis for that, and she asked for more time to look at this before advising them further.
Commr. Conner asked for her legal opinion on the motion and on what they could and could not do. He announced that they would take an eight-minute break.
Mr. Miller left the meeting at 3:27 p.m.
After reviewing the rule, Ms. Yurko explained that the rule to remand is very convoluted and complicated and was governed under 12D-9.029, which states that the board or magistrate shall remand a value assessment to the Property Appraiser when they have concluded that the Property Appraiser did not establish a presumption of correctness or has concluded that the Property Appraiser established a presumption of correctness that is overcome or the record does not contain competent, substantial evidence necessary to establish a revised value. She explained what the process for a remand would be if the VAB members thought they have sufficient evidence to make a determination on this issue.
Mr. Walker stated that based on what he just heard from counsel, he wanted to withdraw his motion, and he believed there was another alternative the Petitioner could seek in circuit court. He pointed out that they do not have the evidence presented at the hearing in front of them in order to make a determination.
Commr. Conner asked if anyone had any other cases under the blue category that they wanted to bring to the board’s attention.
Mr. Walker commented that the valuation should be based on fair market value on Petition No. 2011-309 brought by Raintree Utilities, mentioning that there was an accepted contract before the Public Service Commission for approval for $60,000, which he believed meets the definition of fair market value. He assumed that the Petitioner made it known that there was a $60,000 offer on the table that they had accepted and was waiting for approval on, and he did not know why the special magistrate did not take that into consideration.
Mr. Royce responded that the special magistrate has to make a determination of market value as of January 1, and any offer now or a closed deal will affect future years.
Mr. Walker stated that he did not have any further comment on that and that he had no further objections to anything in the blue section.
On a motion by Mr. Walker, seconded by Commr. Parks and carried unanimously by those present by a vote of 4-0, the VAB approved the special magistrate recommendations in the blue category, accepting the cases that the VAB already acted on.
On a motion by Mr. Walker, seconded by Commr. Parks and carried unanimously by those present by a vote of 4-0, the VAB approved the special magistrate recommendations in the orange category.
approval of special magistrate vendor invoices
Ms. Kristy Mullane, Accounting Director, County Finance, stated that they have included copies of checks as backup and the invoices that have been approved and paid by the Clerk’s Office, and they seek approval of those payments.
On a motion by Mr. Walker, seconded by Mr. Smith and carried unanimously by those present by a vote of 4-0, the VAB approved the invoices as submitted and paid.
report regarding review of order to dismiss mohit case
Ms. Yurko reported that there was a lawsuit filed a number of months ago by Dr. Benedict Mohit, a veterinarian in connection with the actions of the Value Adjustment Board, and the VAB was joined as a group and individually as a party. She related that fortunately the statute is very clear that the VAB was not an appropriate party to proceedings by a petitioner, and they were able to prevail in circuit court to get a dismissal with prejudice. She opined that they should seek solace in the fact that they are not a potential party for any of those petitioners, since this was a quasi-judicial function.
recertification of the 2011 tax roll
Mr. Royce stated that unfortunately because of one of the actions that the VAB took at this hearing which he did not account for, they would need to recalculate the homestead for Ms. Webb, Petition No. 2011-54, and come back at a later date for the VAB to certify the tax roll. He asked for them to have the Clerk set another hearing date so that they could do that.
There being no further business to be brought to the attention of the Board, the meeting was adjourned at 3:47 p.m.
JIMMY CONNER, CHAIRMAn
NEIL KELLY, CLERK