U.S. Department of Agriculture: Resolution of Discrimination
Complaints Involving Farm Credit and Payment Programs (12-APR-01,
GAO-01-521R).
Discrimination complaints by minority farmers who were denied
benefits under the Department of Agriculture's (USDA) farm
assistance programs have been a long-standing issue. In 1997, a
group of African-American farmers consolidated their claims of
racial discrimination in farm lending and benefit programs into
one class action suit against USDA. In April 1999, a federal
district court approved a consent decree between the parties for
settling the suit that included a framework for resolving the
individual claims. This correspondence examines (1) the status of
claims under the class action settlement and (2) the results of
the Department's efforts to resolve discrimination complaints by
minority farmers through its administrative processes. GAO found
that the consent decree provides for various parties outside the
federal government to make decisions on the individual claims on
the basis of information submitted by the claimants and USDA.
Although USDA participates in the process, it does not make
decisions on the individual claims. As of January 17, 2001, more
than 25,000 people had filed claims under the consent decree. At
the same time, however, more than 3,600 claimants were rejected
as not being eligible class members, and more than 7,900 who met
the class eligibility criteria were found not to be entitled to a
payment. Many of these people appealed these decisions to a
court-appointed party. Furthermore, the court extended the
deadline for filing a claim, and more than 57,000 individuals
have submitted written requests to file late claims. The
resolution of discrimination complaints through USDA's
administrative process differs significantly from the resolution
of the class action. In particular, for cases handled under
USDA's administrative process, USDA makes decisions on the
discrimination complaints. Its Office of Civil Rights (OCR)
investigates allegations of discrimination, decides if there is
evidence of discrimination, and negotiates settlements with
complainants when OCR finds that discrimination has occurred.
USDA's Office of General Counsel reviews the cases in which OCR
found evidence of discrimination to determine the legal propriety
of the finding and of the proposed award. Finally, The Farm
Service Agency (FSA) implements settlement agreements in which
discrimination was found to have occurred in the programs that
the agency operates.The payments in settling these complaints
were made from FSA's farm loan program accounts.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-01-521R
ACCNO: A00835
TITLE: U.S. Department of Agriculture: Resolution of
Discrimination Complaints Involving Farm Credit and Payment
Programs
DATE: 04/12/2001
SUBJECT: Farm credit
Racial discrimination
Administrative remedies
Litigation
Claims settlement
Farm Credit System
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GAO-01-521R
GAO- 01- 521R Resolving Discrimination Complaints United States General
Accounting Office
Washington, DC 20548
April 12, 2001 The Honorable Larry Combest Chairman, Committee on
Agriculture House of Representatives
Subject: U. S. Department of Agriculture: Resolution of Discrimination
Complaints Involving Farm Credit and Payment Programs
Dear Mr. Chairman: Discrimination complaints by minority farmers- including
African- Americans, Hispanics, and American Indians- who were denied
benefits under the U. S. Department of Agriculture?s (USDA) farm assistance
programs 1 have been a longstanding issue. Compounding this concern has been
USDA?s inability to address discrimination complaints through its
administrative processes in a timely manner. These issues came to a head in
1997 when a group of African- American farmers consolidated their claims of
racial discrimination in farm lending and benefit programs into one class
action suit against USDA- Pigford v. Glickman. On April 14, 1999, a federal
District Court approved a consent decree between the parties for settling
the suit that included a framework for resolving the individual claims. USDA
continues to operate its internal administrative process for resolving
discrimination complaints that are outside the class action settlement.
Concerned about certain aspects of the class action settlement and about
USDA?s administrative process for resolving program- related discrimination
complaints, you asked us to examine (1) the status of claims under the class
action settlement and (2) the results of the Department?s efforts to resolve
discrimination complaints by minority farmers through its administrative
processes. 2 As requested, in addressing the second objective, we focused on
minority farmers? discrimination complaints involving USDA?s farm credit and
payment programs, which are operated by USDA?s
1 A program complaint might allege, for example, that a USDA official
discriminated against a minority farmer on the basis of race by failing to
process a loan application. 2 There have also been long- standing concerns
about USDA?s treatment of minority employees. As requested, however, this
report focuses on program- related discrimination complaints and not on
employees? discrimination complaints. In U. S. Department of Agriculture:
Problems Continue to Hinder the Timely Processing of Discrimination
Complaints (GAO/ RCED- 99- 38, Jan. 29, 1999), we
reported on the problems in processing discrimination complaints by both
program participants and employees.
GAO- 01- 521R Resolving Discrimination Complaints Page 2 Farm Service Agency
(FSA). This report summarizes the information we provided
during a March 2, 2001, briefing of the Committee?s staff. In summary, we
found the following:
With regard to the class action settlement, the consent decree approved in
April 1999 provides for various parties outside the federal government to
make decisions on the individual claims on the basis of information
submitted by the claimants and USDA. Although USDA participates in the
process, it does not make decisions on the individual claims. As of January
17, 2001, more than 25,000 people had filed claims under the consent decree;
of these, more than 10, 300 received settlement payments totaling
approximately $520 million. Many claims are still being processed, which
will likely result in substantially more payments to resolve this class
action. At the same time, however, more than 3,600 claimants (about 15
percent of those who filed claims) were rejected as not being eligible class
members, and more than 7, 900 who met the class eligibility criteria were
found not to be entitled to a payment. As provided in the consent decree,
many of these people appealed these decisions to a court- appointed party.
Furthermore, the court extended the deadline for filing a claim, and more
than 57,000 individuals have submitted written requests to file late claims.
While most of the costs of settling the class action are paid from a fund
maintained by the Department of the Treasury for paying judgments against
the federal government, some are made from USDA?s funding accounts,
including FSA?s salaries and expense account.
The resolution of discrimination complaints through USDA?s administrative
process differs significantly from the resolution of the class action. In
particular, for cases handled under USDA?s administrative process, USDA
makes decisions on the discrimination complaints. Its Office of Civil Rights
(OCR) investigates allegations of discrimination, decides if there is
evidence of discrimination, and negotiates settlements with complainants
when it finds that discrimination has occurred. USDA?s Office of the General
Counsel reviews the cases in which OCR found evidence of discrimination to
determine the legal propriety of the finding and of the proposed award.
Finally, FSA implements settlement agreements in which discrimination was
found to have occurred in the programs that the agency operates. From fiscal
year 1999 through January 31, 2001, FSA made settlement payments to 28
complainants that totaled $3. 2 million; 25 of these payments were made in
fiscal year 1999. The payments in settling these complaints were made from
FSA?s farm loan program accounts. In addition, 11 of these 28 complainants
received debt relief on existing farm loans totaling $2.6 million.
Process for Settling and Status of Discrimination Cases Under the Class
Action Consent Decree
Process Established Under the Consent Decree The following material
summarizes four key aspects of the class action consent decree, which was
approved by the U. S. District Court for the District of Columbia on
GAO- 01- 521R Resolving Discrimination Complaints Page 3 April 14, 1999, 3
as well as the status of the claims filed and payments made under the
decree as of January 17, 2001. 1. Class eligibility criteria: In summary, to
be eligible for the class, a farmer must be African- American and have
farmed or attempted to farm between January 1, 1981, and December 31, 1996;
applied to USDA during that time period for a farm loan (credit) or a farm
payment (noncredit benefit) but did not receive what he or she had
requested; and
filed a racial discrimination complaint by July 1, 1997, regarding USDA?s
consideration of the application.
Also, the consent decree provided claimants the opportunity to opt out of
the class action resolution procedure and continue their individual cases
through administrative or judicial avenues. Claimants had until August 12,
1999, to exercise this option.
2. Court- appointed parties in the decision process: Four parties- a
facilitator, adjudicator, arbitrator, and monitor- are involved in the
decision- making process under the decree on the basis of information that
they received from the claimants and USDA. The first three parties were
designated by the court in the consent decree; the court appointed the
monitor in January 2000. While USDA provides information that it has on the
claimants, it does not make decisions on the individual claims. The
following summarizes the functions of the four parties.
Facilitator- the Poorman- Douglas Corporation- processes claims and decides
if a person is eligible to be in the class.
Adjudicator- JAMS- Endispute, Inc., with some assistance from the
PoormanDouglas Corporation- decides if claimants who select the resolution
of their claims under one procedure, referred to as Track A and described
below, are entitled to receive a payment.
Arbitrator- Michael K. Lewis of ADR Associates- decides if claimants who
select the resolution of their claims under an alternative procedure,
referred to as Track B and described below, are entitled to receive a
payment and, if so, the award amount.
Monitor- Randi Ilyse Roth, Executive Director of the Farmers Legal Action
Group, Inc.- reviews appeals of eligibility or award decisions. The monitor
can direct the other parties to reexamine a claim when the monitor
determines that a significant error occurred in the decision. The monitor is
also to report on the implementation of the decree to, among others, the
court and USDA.
3 A complete copy of the court- approved consent decree and the court?s
opinion paper can be found at http:// www. dcd. uscourts. gov/ district-
court- 1999. html.
GAO- 01- 521R Resolving Discrimination Complaints Page 4 To support that a
discrimination complaint was filed, the decree states that the
claimant must provide the facilitator with one of the following: (1) a copy
of either the complaint filed with USDA or a USDA document that references
the complaint; (2) a copy of correspondence to a Member of Congress, the
White House, or some other government official stating that the claimant had
been discriminated against; (3) a declaration by a nonfamily member stating
that he or she has first- hand knowledge that the claimant filed a complaint
with USDA and describing the manner in which the complaint was filed; or (4)
a declaration by a nonfamily member stating that he or she has first- hand
knowledge that a USDA official told the claimant that the claimant?s oral
discrimination complaint would be investigated.
3. Resolution procedures: Claimants who meet class eligibility requirements
select one of the following two tracks for processing their claims.
Track A- Under this procedure, an adjudicator reviews the claim and
information submitted by USDA regarding the claim. Specifically, to support
a claim of discrimination involving farm credit, the person must show the
adjudicator that (1) he or she owned, leased, or attempted to own or lease
farmland; (2) he or she applied for a farm loan or loan servicing during the
1981 through 1996 period; (3) his or her loan or servicing application was
not approved as requested and such treatment was less favorable than the
treatment that specifically identified, similarly situated, white farmers
received; and (4) USDA?s treatment of the application led to economic damage
to the person. To support a claim of discrimination involving a farm payment
program, the person must show the adjudicator that (1) he or she applied for
the program payment during the 1981 through 1996 period and (2) his or her
application was not approved as requested and such treatment was different
from the treatment received by specifically identified, similarly situated,
white farmers.
Under this track, claimants who provide substantial evidence of
discrimination involving farm loans are entitled to receive, among other
things, a payment of $50,000. Claimants who provide substantial evidence of
discrimination involving farm payments are entitled to receive a payment of
$3,000. (The $3, 000 payment amount was approved by court order dated Feb.
7, 2001.) The consent decree defines ?substantial evidence? as relevant
evidence that a reasonable person might accept as adequate to support a
conclusion after considering other evidence that detracts from the
conclusion.
Track B- This alternative procedure offers claimants who believe they have
suffered extreme damages a more detailed review through an arbitration
hearing. This track has a higher standard of proof than the evidence
required in Track A and provides for a tailored award based on the
individual?s proof of damages. Specifically, a preponderance of evidence is
required, which the consent decree defines as relevant evidence necessary to
prove that something is more likely true than not true.
4. Time frame for entering the class: The consent decree states that a
claimant must have submitted a completed claim to the facilitator within 180
days of the decree (that is, by Oct. 12, 1999). Should that deadline be
missed, a person could ask the
GAO- 01- 521R Resolving Discrimination Complaints Page 5 court for
permission to file late but must show that his or her untimely submission
was due to extraordinary circumstances beyond his or her control. The court
ruled on July 14, 2000, that timely, but defective, claims that were
corrected and resubmitted to the facilitator after October 12, 1999, are to
be treated as though they had been properly filed. Also, since many people
either filed late claims or requested claim forms after the filing deadline,
the court delegated to the arbitrator the authority to approve or deny
petitions for late filings. The July 14 th order also required that late
claims had to be submitted to the facilitator by September 15, 2000.
Status of Claims Filed Under the Class Action Consent Decree As table 1
shows, more than 25,000 people had filed claims with the facilitator under
the consent decree as of January 17, 2001; the facilitator accepted 85.5
percent of these claims for processing by the adjudicator or the arbitrator
and rejected 14. 5 percent on eligibility grounds.
Table 1: Status of Claims Filed Under the Class Action Consent Decree, as of
January 17, 2001 Status category Number of claims
Claims accepted for processing Under Track A 21,202 Under Track B 198 Total
claims accepted for processing 21,400 Claims rejected for processing
(claimant not an eligible class member) 3, 636
Total claims filed under the consent decree 25,036
Source: USDA.
On the Track A claims that were accepted for processing, the adjudicator
ruled in favor of 12,076 claimants and against 7, 919. Through mid- January
2001, as table 2 shows, more than 10, 300 claimants who prevailed on Track A
farm loan claims received payments, which totaled more than $517 million.
The amount of money to be paid on the remaining Track A claims will likely
be substantial, since the adjudicator ruled that 1, 529 claimants are
eligible for a $50, 000 farm loan award and 204 claimants are eligible for a
$3, 000 farm payment award. Also, 1,207 cases are still under consideration
by the adjudicator. In addition to receiving payments, 130 claimants have
also received debt relief on existing farm loans that totaled $8.3 million.
GAO- 01- 521R Resolving Discrimination Complaints Page 6
Table 2: Status of Claims Accepted for Processing Under Track A, as of
January 17, 2001 Status of claims Number of claimants
Adjudicator?s decision In favor of claimant 12,076 (57 percent) Against
claimant 7,919 (37 percent) Total completed decisions 19,995 (94 percent)
Adjudicator?s decision not completed 1, 207 (6 percent)
Total Track A claimants 21,202 (100 percent)
Track A farm loan claims Claimants who received a $50, 000 payment 10,343 a
Claimants ruled eligible by the adjudicator to receive a payment 1,529
Total found eligible for a $50,000 payment 11,872
Track A farm payment claims b Claimants who received a payment 0 Claimants
ruled eligible by the adjudicator to receive a payment 204
a The payments to these claimants totaled $517. 2 million. b A February 7,
2001, court order provides that the payment on approved Track A farm payment
claims is to be $3,000 per claimant.
Source: USDA.
Also, through mid- January 2001, according to the arbitrator, there had been
rulings in favor of seven Track B claimants with award payments totaling $3.
6 million; two other Track B claimants settled their discrimination
complaints late in 2000 before an arbitration hearing was held- their award
payments totaled about $150, 000. 4 In addition, the number of remaining
Track B claimants has been reduced for several reasons: For example, some
switched their claims to Track A; some had their complaints dismissed by the
arbitrator; and after going to hearings, some had arbitration rulings
against them. According to the arbitrator, in early April 2001, about 100
Track B cases still needed to be resolved.
As stated above, the consent decree authorizes the monitor to review the
appeals of eligibility or award decisions and to direct the other court-
appointed parties to reexamine a claim when the monitor determines that a
significant error has occurred in the decision. Many of the people who the
facilitator ruled were not eligible to be admitted to the class or who the
adjudicator ruled were not entitled to a payment award have appealed those
decisions. According to USDA, more than 5, 500 claimants have requested
reviews by the monitor. Also, USDA appealed some decisions that were in
favor of claimants. Specifically, an attorney in USDA's Office of the
General Counsel told us that USDA has almost 500 requests for reviews by the
monitor. In commenting on a draft of this report, the USDA attorney told us
that the monitor issued four decisions during March 2001- two directing the
adjudicator to reexamine decisions and two ruling that the decisions did not
need to be reexamined.
4 The arbitrator told us in early April 2001 that 25 additional Track B
cases with award payments totaling about $3. 5 million were resolved through
settlement agreements negotiated by the Department of Justice in February
2001.
GAO- 01- 521R Resolving Discrimination Complaints Page 7 Furthermore, many
late requests to participate in the resolution process still need to
be processed. According to USDA, the facilitator has received more than
57,000 late claim petitions, which the arbitrator needs to review to decide
if the people will be allowed to file late claims.
Table 3 shows the various funding sources that are used to make payments to
the claimants, their counsel, and the other parties involved in this matter.
Table 3: Sources of Funds for Payments Under the Class Action Consent Decree
Party to receive payment Funding account for payments
Track A claimants with approved farm loan claims Judgment Fund a Track A
claimants with approved farm payment claims USDA?s noncredit program funding
account or FSA?s
salaries and expense (S& E) account if noncredit program account funds are
not available Track B claimants with favorable rulings Judgment Fund Class
counsel and related attorney?s fees Judgment Fund b Facilitator,
adjudicator, arbitrator, and monitor FSA?s S& E account c Other d FSA?s S& E
account d
a The Judgment Fund is a Treasury account that is generally available for
payment of most court judgments and Department of Justice compromise
settlements of actual or imminent lawsuits against the federal government. b
According to Justice officials, a total of $8 million had been paid through
mid- February 2001. c A total of about $17. 7 million was obligated in
fiscal years 1999 and 2000; FSA estimates that obligations will total more
than $13 million in fiscal year 2001. d Two contractors are providing
administrative assistance with the class settlement. Also, FSA is
reimbursing Justice and USDA?s Office of the General Counsel for certain
class- related expenses. FSA?s obligations totaled $4.5 million in fiscal
years 1999 and 2000; FSA estimates that obligations will total $2. 5 million
in fiscal year 2001.
Source: Information obtained from USDA and Justice.
Information on Claimants Who Opted Out of the Class Settlement The consent
decree allowed claimants who met the class eligibility criteria to opt out
of the resolution procedure and to continue their cases through
administrative or judicial avenues. According to USDA, more than 200
claimants have exercised this option. Two of these cases have been resolved
through settlement agreements negotiated by Justice; one through an
arbitration ruling; and five through USDA?s administrative process. The
payment awards for these eight claimants totaled about $3.1 million. The
payments in the cases settled by Justice came from the Judgment Fund. The
payments in the arbitration case and in the cases settled by USDA were from
FSA?s farm loan program accounts, which, as discussed below, are accounts
for paying the costs associated with the agency?s loans. In addition, two of
these claimants received debt relief totaling slightly over $350, 000.
Settlement of Discrimination Cases Under USDA?s Administrative Processes
Unlike the class settlement procedure in which reviews and decisions are
made by court- appointed parties, the process for resolving discrimination
complaints administratively resides within USDA. Specifically, USDA?s Office
of Civil Rights investigates allegations of discrimination, decides if the
evidence supports the
GAO- 01- 521R Resolving Discrimination Complaints Page 8 allegations, and
reaches settlement agreements with complainants when
discrimination is found to have occurred. USDA?s Office of the General
Counsel reviews discrimination cases and agreements to ensure the legal
propriety of the finding and the proposed award. FSA implements the
agreements by making compensatory damage payments to the complainants and,
if provided for, by writing off existing loans and paying complainants?
legal expenses.
In making payments, FSA uses funds in its farm loan program accounts. FSA
uses these accounts on the basis of guidance that USDA received from the
Office of Management and Budget (OMB) in the early part of fiscal year 1998.
Specifically, if the complaint involves fiscal year 1991 or earlier loans,
funds in the liquidating account (a funding account to pay costs associated
with such loans) are used to make the payment; if the complaint involves
fiscal year 1992 or later loans, funds in the financing account (a funding
account to pay the costs of post- fiscal year 1991 loans) are used. However,
GAO issued a legal opinion in October 1999 concluding that the farm credit
program?s financing and liquidating accounts, which are the subsidy accounts
for the farm loans, are not available for paying compensatory damages in
settling discrimination claims against USDA. 5 Notwithstanding GAO?s
position, FSA continues to follow OMB?s guidance and use these accounts for
making settlement payments.
From the start of fiscal year 1999 through January 31, 2001, FSA made
payments totaling $3. 2 million on 28 administratively settled
discrimination complaints.
Settlement payments totaling $2.8 million were made to 25 complainants in
fiscal year 1999. Payments totaling about $400,000 were made to two
complainants in fiscal year 2000 and to one complainant in the first 4
months of fiscal year 2001.
The payments for administratively settled complaints were made from FSA?s
subsidy accounts that support the farm loan programs. Of the $3. 2 million,
28 percent ($ 900,000) was paid from the financing account and 72 percent ($
2.3 million) from the liquidating account.
Payments totaling approximately $110, 000 were made to attorneys for 13 of
the 28 complainants. These payments were also made from the loan subsidy
accounts- about $40, 000 from the financing account and $70,000 from the
liquidating account.
Eleven of the 28 complainants received debt relief on existing farm loans
totaling $2.6 million.
The bases of the discrimination complaints by these 28 complainants varied
considerably. Some complained that they had been discriminated against
because of their race or gender; others cited more than one reason for their
complaint. For example, six African- Americans and two Native Americans
filed racial discrimination complaints; one other Native American complained
of race and age discrimination; seven females filed complaints of sexual
discrimination; and six other females
5 See GAO opinion letter B- 280396. 2 (Oct. 28, 1999).
GAO- 01- 521R Resolving Discrimination Complaints Page 9 complained of being
discriminated against because of their gender and other factors,
such as marital status (for example, divorced or widowed) or age. USDA spent
considerable time resolving the cases in which OCR found that discrimination
had occurred. On average, 3. 5 years elapsed from the date of the
discrimination complaint to the payment date for the 28 complainants who
received payments. The quickest payment was made in 20 months; the slowest
took over 7 years.
Agency Comments
We provided USDA with a draft of this report for review and comment. We met
with USDA officials, including OCR?s acting Director and FSA?s Deputy
Administrator for Farm Loan Programs. The Department?s officials agreed with
the material contained in the report. They also provided suggestions for
clarifying the report, which we incorporated as appropriate.
Furthermore, we provided officials in the Civil Division of the Department
of Justice with a draft of this report for review. Justice?s officials
suggested various technical corrections and clarifications, which we made as
appropriate.
Scope and Methodology
In conducting this review, we interviewed, among others, OCR?s former
Director and Deputy Director, who is currently the acting Director; FSA?s
farm credit program officials, including the Director of the Loan Making
Division and the Director and Deputy Director of the Loan Servicing and
Property Management Division; an attorney in USDA?s Office of the General
Counsel; and officials in Justice?s Civil Division who are directly involved
in the class action settlement. Also, to compile information on the
resolution of claims under the class action settlement, we reviewed, among
other things, the court- approved April 1999 consent decree and other
related documents, including the court?s opinion paper on the decree and the
orders and stipulations that the court has issued since then. We reviewed
USDA?s reports on the status of settlements, including payments; the most
recent report at the time of our review was as of January 17, 2001. We
obtained from Treasury?s Financial Management Service selected information
on payments from the Judgment Fund and obtained from FSA?s Budget Division
information on payments to the various outside parties that are involved in
the class action settlement. The payment information obtained included the
funding accounts used for paying the claimants, their attorneys, and the
outside parties. We also obtained from the offices of the arbitrator
information on complaint cases settled through arbitration and settled
before an arbitration hearing was held.
In addition, to compile information on USDA?s efforts to resolve
discrimination complaints by minority farmers through its administrative
process, we reviewed, among other things, OCR?s guidance manual for
reviewing and settling complaints and its case files for most of the
complaints settled administratively from fiscal year 1999 through the first
4 months of 2001. We obtained from FSA?s Financial Management Division
information on, among other things, payments and debt relief
GAO- 01- 521R Resolving Discrimination Complaints Page 10 for each
complainant whose case was resolved during this period by OCR. The
payment information obtained included the funding accounts used for the
settlements.
We performed our work from December 2000 through March 2001 in accordance
with generally accepted government auditing standards. We did not verify the
accuracy of the information contained in USDA?s status reports or in the
various financial reports that we were provided.
- - - - As agreed with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this letter until 30
days after the date of this letter. At that time, we will send copies to the
appropriate House and Senate committees; interested Members of Congress; the
Honorable Ann M. Veneman, Secretary of Agriculture; the Honorable John
Ashcroft, Attorney General; the Honorable Mitchell E. Daniels, Jr.,
Director, Office of Management and Budget; and other interested parties. The
letter will also be available on GAO?s homepage at http:// www. gao. gov.
Please call me at (202) 512- 3841 if you or your staff have any questions
about this letter. Key contributors to this letter are listed in enclosure
I.
Sincerely yours, Lawrence J. Dyckman Director, Natural Resources and
Environment Enclosure
GAO- 01- 521R Resolving Discrimination Complaints Page 11 Enclosure
GAO Contacts and Staff Acknowledgments GAO Contacts Lawrence J. Dyckman,
(202) 512- 3841
Jerilynn B. Hoy, (202) 512- 9837
Staff Acknowledgments In addition to those named above, Jacqueline A. Cook,
Robert G. Crystal, Richard B. Shargots, and Patrick J. Sweeney made key
contributions to this letter.
(360034)
*** End of document. ***