Tate & Renner, attorneys at law
505 North Wooster Avenue   
P.O. Box 8   
Dover, Ohio  44622-0008   
(330) 364-9900   
FAX:  (330) 364-9901   
www.taterenner.com   
Email:  rrenner@igc.org   
Alfred L. Tate (1942-1995)
Richard R. Renner
Anthony Touschner (of counsel)

OSHA Docket Office, Docket No. OSHA-2007-0028
U.S. Department of Labor, Room N-2625
200 Constitution Avenue, NW.
Washington, DC 20210

By Facsimile:	(202) 693-1648

	Re:	Docket No. OSHA-2007-0028

Dear Madam or Sir:
A.  Introduction
Mr. Jason Zuckerman of Washington, DC, and myself submit these comments to the amended regulations at 29 CFR Part 24, 72 Fed. Reg. 44956, adopted on Aug. 10, 2007. Together, Mr. Zuckerman and I co-chair the Whistleblower Committee of the National Employment Lawyers Association. Mr. Renner has been a lawyer for 25 years, and has practiced before the US Department of Labor (DOL) since 1996. He has handled over 20 environmental, nuclear and other whistleblower cases before the DOL. Since 2002, he has also served as Secretary of the National Whistleblower Center. Mr. Zuckerman is now practicing primarily as Of Counsel at The Employment Law Group.
B.  The big picture.
We humbly submit that the amended regulations miss the big picture. The purpose of the employee protections is to afford protection for those who help to protect the environment, assist the government in obtaining compliance, and participate in other activities that promote the statutory objectives. Devereux v. Wyoming Association of Rural Water, 93-ERA-18 (Sec’y, October 1, 1993); Tyndall v. U.S. Environmental Protection Agency, 93-CAA-6, 95-CAA-5 (ARB, June 14, 1998). Employees can play an important role in protecting the public from environmental and nuclear safety dangers. They can keep managers and government officials honest by exposing attempts to cover up dangers. Discrimination against whistleblowers obviously deters such employee efforts on behalf of the public purposes. Accordingly, the federal statutes prohibit such discrimination. To achieve the ends of eliminating discrimination, and protecting complainants from retaliation, the law mandates that “employees must feel secure that any action they may take” furthering “Congressional policy and purpose, especially in the area of public health and safety, will not jeopardize either their current employment or future employment opportunities.”  Egenrieder v. Metropolitan Edison Co./GPU, 85-ERA-23, Order of Remand by SOL, pp. 7-8 (April 20, 1987). The whistleblower protection laws were passed in order to “encourage” employees to report safety violations and protect their reporting activity. English v. General Electric Co., 496 U.S. 72, 110 S.Ct. 2270, 2277 (1990); Wagoner v. Technical Products, Inc., 87-TSC-4, D&O of SOL, p. 6 (November 20, 1990)(the “paramount purpose” behind the whistleblower statutes is the “protection of employees”). Accord, Hill, et al. v. T.V.A., 87-ERA-23/24, D&O of Remand by SOL, pp. 4-5 (May 24, 1989). Consequently, there is a need for “broad construction” of the statutes in order to effectuate their purposes. DeFord v. Secretary of Labor, 700 F.2d 281,286 (6th Cir. 1983). In Passaic Valley Sewerage Comm. v. Department of Labor, 992 F.2d 474, 479 (3rd Cir. 1993), the Third Circuit stated:
. . . from the legislative history and the court and agency precedents . . . it is clear that Congress intended the ‘whistleblower’ statutes to be broadly interpreted to achieve the legislative purpose of encouraging employees to report hazards to the public and protect the environment by offering them protection in their employment.
The Energy Policy Act of 2005, Public Law 109-58, was enacted on August 8, 2005. Among other provisions, this new law amended the employee protection provisions for nuclear whistleblowers under Section 211 of the ERA, 42 U.S.C. 5851. The 2005 amendment added a provision for de novo review by a United States District Court in the event that the Secretary has not issued a final decision within one year after the filing of a complaint, and there is no showing that the delay is due to the bad faith of the complainant. Congress obviously wanted to expand the avenues of relief available to nuclear whistleblowers. The de novo process in district courts is available as an option for complainants, but is not required. As such, rules intend to accomplish the congressional purpose should respect the complainant’s options, and work in their favor, not to their detriment.
The interim final rule has altered Part 24 to deter complainants from seeking relief in district courts in a way that hampers all complainants in the preparation of their cases. We suggest that the Department would better serve the statutory goals by demonstrating that it is a superior forum for these specialized cases. The Department should compete on the quality of its determinations rather than sacrifice quality for the sake of speed.
C. ERA burdens should be described correctly.
The Department’s Summary and Discussion of Regulatory Provisions overgeneralizes when it states, “The burdens of proving a retaliation claim are the same as those of a standard discrimination claim.” In last year’s decision in Burlington Northern & Santa Fe Railway Co. v. White, 126 S. Ct. 2405 (June 22, 2006), the Supreme Court noted how the purpose of anti-retaliation laws goes beyond the purpose of anti-discrimination laws. Accordingly, the Court held that a broader range of adverse actions can be remedied with the anti-retaliation provision of Title VII than is addressed through its anti-discrimination provisions (which are limited to adverse employment actions). 
Also, Congress has specifically altered the burdens of proof in ERA cases. The Energy Reorganization Act (ERA), 42 U.S.C. § 5851(b)(3), provides:
(3)(A) The Secretary shall dismiss a complaint filed under paragraph (1), and shall not conduct the investigation required under paragraph (2), unless the complainant has made a prima facie showing that any behavior described in subparagraphs (A) through (F) of subsection (a)(1) of this section was a contributing factor in the unfavorable personnel action alleged in the complaint.
(B) Notwithstanding a finding by the Secretary that the complainant has made the showing required by subparagraph (A), no investigation required under paragraph (2) shall be conducted if the employer demonstrates, by clear and convincing evidence, that it would have taken the same unfavorable personnel action in the absence of such behavior.
(C) The Secretary may determine that a violation of subsection (a) of this section has occurred only if the complainant has demonstrated that any behavior described in subparagraphs (A) through (F) of subsection (a)(1) of this section was a contributing factor in the unfavorable personnel action alleged in the complaint.
(D) Relief may not be ordered under paragraph (2) if the employer demonstrates by clear and convincing evidence that it would have taken the same unfavorable personnel action in the absence of such behavior. [Emphasis added.]
The 1992 Amendments to the Energy Reorganization Act, Pub.L. 102-486, § 2902(d), added this par. (3), and was made effective by § 2902(i) to claims filed on or after October 24, 1992. This provision altered the burdens by requiring a complainant to show only that the protected activity was a “contributing factor.”  Thereafter, a respondent can defeat the claim only be showing “by clear and convincing evidence” that it would have taken the same unfavorable action even if complainant had not engaged in protected activity. The McDonnell Douglas framework no longer applies to ERA nuclear whistleblower claims because Congress provided an independent evidentiary framework for that statute in 1992. See Doyle v. U.S. Sec. Labor, 285 F.3d 243, 249-50 & n. 9 (3rd Cir. 2002), Williams v. Administrative Review Bd., 376 F.3d 471, 476 and n.3 (5th Cir. 2004), Trimmer v. U.S. Dep’t of Labor, 174 F.3d 1098, 1101 (10th Cir. 1999), and Stone & Webster Engineering Corp. v. Herman, 115 F.3d 1568, 1572 (11th Cir. 1997).
In Doyle, 285 F.3d at 249-50, the Court of Appeals for the Third Circuit reviewed the new evidentiary framework, noting: “[t]he Energy Policy Act of 1992, Pub.L. No. 102-486, 106 Stat. 2776, effective October 24, 1992, amended section 210 to incorporate a burden-shifting paradigm whereby the burden of persuasion falls first upon the complainant to demonstrate that retaliation for his protected activity was a ‘contributing factor’ in the unfavorable personnel decision.” “Clear and convincing” is an evidentiary standard that “requires a burden higher than ‘preponderance of the evidence’ but lower than ‘beyond a reasonable doubt.’” Getman v. Southwest Securities, Inc., 2003-SOX-8, at 10 (ALJ Feb. 2, 2004) (citing Yule v. Burns Int’l. Security Service, 1993-ERA-12 (Sec’y May 24, 1995)); see also Taylor v. Express One International, Inc., 2001-AIR-2 (ALJ Feb. 15, 2002). The ARB has relied on the Black’s Law Dictionary definition: “Clear and convincing evidence is ‘[e]vidence indicating that the thing to be proved is highly probable or reasonably certain.’” Peck v. Safe Air Int’l, Inc. d/b/a Island Express, ARB 02-028, 2001-AIR-3 (Jan. 30, 2004). 
There appears to be some confusion about the key elements of a whistleblower retaliation claim, which confusion results in investigators incorrectly assuming that a complainant must have “smoking gun” evidence of retaliation, that any reasonable explanation for an adverse action meets the “clear and convincing evidence” standard, and that an act of retaliation is actionable only where it has a tangible economic consequence. Accordingly, we suggest that the Department define the following terms:
An “unfavorable personnel action” includes any recommended, threatened, or actual discrimination, including, but not limited to, termination, demotion, suspension, or reprimand; involuntary transfer, reassignment, or detail;  referral for psychiatric or psychological counseling; investigation, provision of benefits; taking or failing to take any personnel action, including failure to promote or hire or take other favorable personnel action; engaging in any conduct that would dissuade a reasonable employee from engaging in activities protected by this statute; or retaliating in any other manner against an employee because that employee makes a protected disclosure or refuses to comply with an illegal order.
“Clear and convincing evidence” is evidence indicating that the thing to be proved is highly probable or reasonably certain and is a higher burden than preponderance of the evidence.
A “contributing factor” is any factor which, alone or in connection with other factors, tends to affect in any way the outcome of the decision.
The Department can assist all parties, and its own staff, by making clear that the burdens of proof for ERA cases are those set out in 42 U.S.C. § 5851(b)(3) and not the burdens of traditional discrimination claims.
D. Adoption of interim rule, and non-use of the liaison process.
We are disappointed that the Department has chosen to issue these changes as an interim final rule rather than affording all interested parties the normal opportunity to comment before adoption. Last year, we helped to initiate a liaison process with the Office of Administrative Law Judges (OALJ) and with OSHA. We did so on behalf of the Whistleblower Committee of the National Employment Lawyers Association (NELA). We had hoped that we would establish avenues of communication among policy makers, whistleblower groups and employer groups so that we could better understand each other’s interests and develop policy alternatives that are best suited to the statutory goals. The Department missed an opportunity to utilize this process to collect information and make decisions with a better understanding of the interests at stake.
E. Service of complaint and respondent’s response.
In Section 24.104(b), we suggest that it would be helpful if the regulation provided that OSHA serve the respondent’s response on the complainant’s representative. The practice among OSHA field offices is uneven on this point. Respondents are entitled to a copy of the complaint once it is filed. Complainants will have a right to the response once OSHA closes its investigation and the complainant submits a FOIA request. However, the complainant could assist OSHA in its investigation if the complainant has a copy of the respondent’s response. Also, respondents should know that their response will not be confidential so they are not caught by surprise when their response is used as an exhibit in the ALJ hearing.
In an effort to promptly complete investigations, some investigators are inclined to accept whatever justifications for an adverse action that are offered by the employer without probing whether such justifications are in fact credible. This approach cannot be considered an “investigation.”  To serve the critical objectives of these whistleblower protection statutes, OSHA investigators should provide a complainant with the respondent’s submissions and should not close the investigation until the complainant has had an opportunity to respond.
F. Permitting Witnesses to Meet Privately with OSHA Investigators.
Employees of respondents are often reluctant to speak candidly, if at all, to investigators for fear of reprisal. Accordingly, the presence of a respondent’s representative (typically an attorney) at an OSHA interview can have a chilling effect that prevents the investigator from discovering important evidence. Investigators should specifically inform witnesses of the opportunity to meet privately with an OSHA investigator or to speak with an OSHA investigator by phone.
G. Service of OSHA determinations on counsel of record.
In Section 24.105(b), we suggest that the rule should specifically require service on the attorney of record for each party (if the party has counsel). Mr. Renner has one case where OSHA sent the determination directly to a complainant with limited English proficiency, even though he signed and filed the original complaint. He did not learn about the determination until OSHA sent him a copy — more than a month later. Even though he filed the objection and request for hearing immediately upon his receipt of the determination, the ALJ dismissed the objection and request for hearing on grounds that it was not made within thirty days, counting from the original issuance directly to the complainant. This case is currently pending at the ARB (ARB Case No. 06-146). We could avoid these types of problems if the rule specifically required service on the attorney of record, or alternatively, if the rule allowed objections within thirty days of the last service when the party and his or her attorney are served at different times.
H. Appreciation for increased time to request a hearing.
Thank you for the provision in Section 24.105(c) expanding the time to file objections and requests for hearing. This change is long overdue to help parties get cases decided on the merits, instead of on technicalities. One of the remaining problems in the environmental whistleblower cases is the extremely short time limit (30 days) to file the original complaint with OSHA. It is so sad when we have to turn away prospective clients because they did not find an attorney with knowledge of or experience with this time limit until after it had expired. We appreciate the Department’s effort to expand the time limit and maximize the opportunities for decisions on the merits.
I. Imposing Undue Limitations on Discovery.
We particularly object, however, to the last sentence of Section 24.107(b) (“Administrative law judges have broad discretion to limit discovery in order to expedite the hearing.”). It had been well established that the time limits for adjudication can be extended or waived to allow for the completion of discovery. Timmons v. Mattingly Testing Services, 95-ERA-40, D&O of Remand by ARB, pp. 5-6 (June 21, 1996). An initial request to extend the time limits is routinely granted. Tracanna v. Arctic Slope Inspection Service, 97-WPC-1, ARB No. 97-123, D&O of Remand by ARB, at 5 (Nov. 6, 1997). Adequate time is absolutely necessary to accomplish proper discovery in a manner consistent with the Federal Rules of Civil Procedure. Accord, Malpass v. General Electric Co., 85-ERA-38/39, D&O of SOL, slip op. at 12 (March 1, 1994). The Secretary of Labor has stated that parties to DOL whistleblower proceedings have “all the discovery mechanisms of the Rule of Practice” available to them to assist in preparing for a hearing. Malpass v. General Electric Co., 85-ERA-38/39, D&O of SOL, slip op. at 12 (March 1, 1994). In Holub v. H. Nash Babcock, Babcock & King, Inc., 96-ERA-25, Discovery Order of ALJ (March 2, 1994), the ALJ ruled that “the law is well settled regarding the appropriateness of extensive discovery in employment discrimination cases. Further, the courts have held that liberal discovery in these cases is warranted.”  Id., slip op. at 6. Also see McDonnell Douglas Corp. v. Green, 411 U.S. 792, 804-05 (1073) (extensive discovery in employment discrimination cases is necessary and the refusal to adhere to the “liberal spirit” of discovery would be an abuse of discretion); Duke v. University of Texas at El Paso, 729 F.2d 994, 997 (5th Cr. 1984) (“procedural technicalities” to impede liberal discovery are improper). One member of the ARB explained:
In employment discrimination cases, the courts have held that discovery should be permitted “unless it is clear that the information sought can have no possible bearing upon the subject matter of the action.” Marshall v. Electric Hose & Rubber Co., 68 F.R.D. 287, 295 (D.Del. 1975) (citations omitted). “In such cases, the plaintiff must be given access to information that will assist the plaintiff in establishing the existence of the alleged discrimination.” Lyoch v. Anheuser-Busch Companies, Inc., 164 F.R.D. 62, 65 (E.D. Mo. 1995) (citations omitted). Accord Trevino v. Celanese Corp., 701 F.2d 397, 405 (5th Cir. 1983) (vacating protective order which limited discovery in part because, “imposition of unnecessary limitations on discovery is especially frowned upon in Title VII cases.”); Flanagan v. Travelers Insurance Co., 111 F.R.D. 42, 45 (W.D.N.Y. 1986) (same). Consistent with this body of case law, the Secretary of Labor and the ALJs have recognized the broad scope of discovery to be afforded parties in whistleblower cases. See, e.g., Malpass v. General Electric Co., Case Nos. 85-ERA-38/39, Sec’y Dec., Mar. 1, 1994, slip op. at 12; Holub v. Nash, Babcock, et al., Case No. 93-ERA-25, ALJ Disc. Ord., Mar. 2, 1994, slip op. at 6. See generally Timmons v. Mattingly Testing Services, Inc., ALJ Case No. 95-ERA-40, ARB Dec. & Ord. of Rem., June 21, 1996, slip op. at 4-6 (discussing the “full and fair presentation” of a whistleblower case by the parties). 
Khandelwal v. Southern California Edison, ARB No. 98-159, ALJ Nos. 1997-ERA-6 (ARB Nov. 30, 2000), concurring opinion of E. Cooper Brown.
It is ironic that Congress created the judicial bypass for ERA cases out of a perception that the DOL process was not adequate to protect whistleblower interests, and now the DOL is using the bypass provision as a basis to make its process even less suitable. We urge the Department to make its process better so that complainants are encouraged to bring their claims to the Department and allow the Department to complete its process. 
The 2005 amendment affects only ERA whistleblower complaints. However, the new Part 24 affects all the environmental whistleblower cases, even though the complainants there have no right of de novo review in district court. The current legislation provides no logical basis to restrict their rights of discovery in any way.
If the Department was intent on limited discovery for the sake of speed, it could make clear that ALJs can make an adverse inference of unlawful discrimination based on a respondent’s failure to make full and complete discovery responses. Accord, Malpass v. General Electric Co., 85-ERA-38/39, D&O of SOL, slip op. at 12 (March 1, 1994). The Department could add a requirement for initial disclosures (reference FRCP 26(a)(1)). The Department could expedite discovery by shortening the time to respond to interrogatories, requests for documents or admissions. 
We specifically suggest that the Department require parties to provide discovery responses in searchable electronic forms when a party has the responsive information in such forms. We have noticed numerous parties printing out emails, for example, and producing the hard copies to frustrate an opponent’s ability to save and search the responsive documents for key names or phrases. The companies go to extra effort to make their electronic records harder for complainants to use. The searchable electronic form is necessary to properly search and manage the documents. It is not fair that respondent can search the relevant emails, policy files, and other documents electronically while complainant and his counsel would have to read through all the of pages of paper to get the same information. We mention a searchable electronic form because some respondents’ counsels have been converting documents to PDF forms by scanning the hardcopy or otherwise making the PDF file non-searchable. That frustrates the purpose of electronic discovery. Courts that have considered the issue have held that production of electronic documents in their electronic form is proper. Armstrong v. Executive Office of the President, 1 F.3d 1274 (D.C. Cir. 1993), reversed on other grounds, 90 F.3d 553 (D.C.Cir. 1996). See also Anti-Monopoly, Inc. v. Hasbro, Inc., 1995 U.S. Dist. LEXIS 16355 (S.D.N.Y.) “Production of materials in hard copy form does not preclude a party from receiving the same information in electronic form.”; see also Cobell v. Norton, 2002 U.S. Dist. LEXIS 5291 (D.D.C.) (request for permission to produce emails on paper draws sanctions). Production electronically is easier for the producing party and more useful to the receiving party. It is the right thing to do. The ALJ erred in failing to compel respondent to produce its electronic versions of its documents.
The modern practice of maintaining electronic records means that businesses typically have more records than they did in times past. They will need the time to identify the location of all electronic data, to retrieve such data, and to prepare the data for production. Limiting the period for discovery prejudices complainants in that it will effectively deny them the opportunity to obtain the documents necessary to prove their claims. ALJs are generally reluctant to impose discovery sanctions. Limiting the period for discovery gives respondents a tremendous advantage in that they can spend months withholding documents and by the time the discovery motions are before an ALJ, the case will be going to trial and the complainant will not have had access to documents and information that can prove the claim. DOL precedent establishes that the reason for encouraging expeditious hearings is to benefit the complainant. Johnson v. Transco Prods., Inc., 85-ERA-7, slip. op. of ALJ at 2 (Mar. 5, 1985). The employee is likely to be out of a job or otherwise economically disadvantaged by the employer’s alleged retaliation. The time limits are not designed to provide the employer with a means of pressuring or harassing an employee who has “blown the whistle.” Bullock v. Rochester Gas & Electric Corp., 84-ERA-22 (ALJ June 8, 1984) (interim order) (Respondent had opposed continuance for Complainant to obtain an attorney). DOL appears to have lost sight of this precedent and appears to be more concerned with protecting respondents from the burden of discovery than in assuring a fair adjudication of a complaint. We urge the Department to remove the sentence that encourages ALJs to limit discovery, and instead specify that discovery should include initial disclosures, searchable electronic production of electronic records, and adverse inferences upon a showing of failure to make timely and complete responses.
J. Limiting federal court jurisdiction in ERA cases.
We propose directly stating that DOL’s effort to restrict a complainant’s ability to remove a case to federal court contravenes the plain meaning of the 2005 amendments to the ERA and is outside the scope of DOL’s authority. DOL simply lacks authority to rewrite the 2005 amendments to the ERA by striking the phrase de novo and restricting a complainant’s ability to remove a complaint to federal court. We suggest that DOL policy should respect the complainant’s legal right to seek relief elsewhere, but continue to strive to be a forum that draws parties in through its reputation for fair adjudications that accomplish the statutory purposes.
K. Role of DOL in enforcing whistleblower protection statutes.
The summary of changes to Section 24.108 states that “in most whistleblower cases, parties have been ably represented and the public interest has not required the Department’s participation.”  This statement is an unfortunate reflection of DOL’s stance on whistleblower protection laws. This orientation has grave consequences for public health and safety. Just last week, a hearing held by the House Committee on Education and Labor revealed that the six miners who died in a mine cave-in on August 6, 2007, had concerns about mine safety issues but were reluctant to raise them for fear of losing their jobs. Today, the Nuclear Regulatory Commission (NRC) is concluding that personnel at the Peach Bottom Atomic Power Station in Pennsylvania did not report concerns about the sleep inducing conditions for guards because of fear of retaliation. “If employees are coerced and intimidated into remaining silent when they should speak out, the result can be catastrophic.” Rose v. Secretary of Department of Labor (6th Cir. 1986), 800 F.2d 563, 565. Instead of focusing on limiting discovery in these cases, the Department should be focused on enforcing whistleblower protection laws that enable employees to raise concerns without fear of reprisal. Accordingly, the Department should consider intervening on behalf of complainants in these cases, especially where a complainant is pro se.
Ironically, it appears that under the current Administration, the Solicitor has intervened in whistleblower cases almost exclusively when there is an opportunity to narrow or undermine whistleblower protection laws. For example, Ambrose v. U.S. Foodservice, Inc., ARB Case No. 06-096, the Assistant Secretary submitted a brief proposing that the ARB construe coverage under the whistleblower provision of the Sarbanes-Oxley Act very narrowly. The brief proposed a standard that conflcts with the Department’s regulations implementing Section 806 of SOX and it disregarded the remedial purpose of Section 806 and Congressional intent. Simiarly, in Sasse v. Department of Labor, the Department submitted a brief to the Sixth Circuit arguing for a narrow construction of the range of adverse actions that are actionable under the environmental whistleblower laws. And in Ede v. Swatch Group, ARB No. 05-053, the Assistant Secretary again argued for a narrow construction of SOX. Hopefully, the Department will reverse this trend.
L. Deciding cases on the merits.
Finally, we suggest modifications to Section 24.110 that would further the goal of deciding cases on their merits. Specifically, the Department can allow a party to set out sufficient grounds for the ARB review, but then add additional grounds in the brief. The previous rule had allowed parties to make a simple request for review, and then set out the grounds in the brief. In appeals to the federal circuit courts, the process of writing the brief is when counsel is obligated to review the entire record to set out the assignments of error. To require that a party review the entire record to identify all the errors in less than ten business days (since the ten days run from the date of the decision, not the date counsel receives it) is unrealistic and unfair. We notice that in Section 24.105(c), the Department has expanded the time to file a simple objection and request for de novo review from five (5) days to thirty (30) days. We support this change in Section 24.105(c). However, it is uneven that parties are allowed thirty (30) days to file a simple request for hearing, but less than ten (10) days to review the entire record to identify all the assignments of error. From time to time, each of us might be in a hearing or take a vacation that is longer than ten (10) days. We suggest that thirty (30) days would be a better time limit for Section 24.110(a). To the extent that the ARB needs to determine that there are good issues present for briefing, this goal can be achieved without limiting a party to assign only those issues identified in the petition for review. The Department can require that a party file a petition that identifies good grounds for the review, and then permit the party to raise additional assignments of error in their brief. This later alternative would still allow the ARB to screen the petitions for meritorious issues for briefing, and preserve the fundamental goal of deciding cases on their merits instead of adding more technical grounds to defeat claims.
If Department personnel or other interested parties have any questions about our comments, they are welcome to call on us.
Very truly yours,

Richard R. Renner
Attorney at Law
Tate & Renner
505 N. Wooster Ave.
PO Box 8
Dover, OH 44622
330-364-9900
330-364-9901 fax
rrenner@igc.org
www.taterenner.com

Jason M. Zuckerman
Law Office of Jason M. Zuckerman, PLLC
888 17th Street, NW, Suite 900
Washington, D.C. 20006
Tel: 202.262.8959
Fax: 202.403.3222
jzuckerman@zuckermanlaw.com
www.zuckermanlaw.com