IN THE CIRCUIT COURT OF DUPAGE COUNTY, ILLINOIS
CIVIL DEPARTMENT, CHANCERY DIVISION
) 2015MR000580
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Case No.
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THE CHICAGO TRIBUNE,
Plaintiff,
v.
COLLEGE OF DUPAGE and
COLLEGE OF DUPAGE FOUNDATION,
Defendants.

TRANS# : 3675366
2015MR000580
FILEDATE : 04/29/2015

Date Submitted : 04/29/2015 03:37 PM
Date Accepted : 04/29/2015 04:00 PM

MARY SALEMI
STATUS 8/26/15 2007 9AM

COMPLAINT UNDER ILLINOIS FREEDOM OF INFORMATION ACT
FOR INJUNCTIVE AND DECLARATORY RELIEF
Plaintiff Chicago Tribune (the “Tribune”) brings this complaint under the Illinois
Freedom of Information Act against Defendants College of DuPage (“COD”) and College of
DuPage Foundation (the “Foundation”) for failure to disclose public records as required by law.
NATURE OF THE ACTION
1.

This is a complaint under the Illinois Freedom of Information Act (“FOIA”),

5 ILCS §140/1 et seq. In violation of FOIA, COD and the Foundation have refused to produce
certain public records, specifically subpoenas served on the Foundation and records related to the
Foundation’s Leadership Cultivation initiative that pays expenses for COD’s President, among
other things.
2.

The Tribune seeks: (a) a declaration that the Foundation is subject to the

requirements of FOIA as a public body, a subsidiary of a public body and/or a contractor
performing a government function under 5 ILCS §140/2(a) or §140/7(2); (b) in the alternative, a
declaration that, because of the complete overlap in personnel between COD and the Foundation,
records in possession of the Foundation or Foundation attorneys are under the control of COD
for purposes of 5 ILCS §140/2(c) and therefore subject to disclosure under FOIA; (c) an
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 injunction commanding COD and the Foundation to disclose the records requested in the
Tribune’s FOIA requests dated April 1, April 14 and April 16, 2015; and (d) an order awarding
the Tribune its attorneys’ fees and costs of bringing this lawsuit.
PARTIES
3.

The Tribune is a major daily newspaper and media outlet with the highest

circulation of any daily publication in the greater Chicago area, as well as national and
international readership. It is crucial to The Tribune’s mission that it receive timely information
regarding the operations of government to keep the public apprised of developments and
concerns in those areas.
4.

COD is a public community college located in Glen Ellyn, DuPage County,

Illinois. COD is a “public body” as that term is defined in 5 ILCS §140/2(a).
5.

The Foundation exists “to obtain contributions and donated assets in order to

expand opportunities for the College of DuPage Community,” according to its public tax filings.
The Foundation is a tax exempt organization under Section 501(c)(3) of the United States
Internal Revenue Code. It is the fundraising arm of COD that is housed on COD’s campus and
staffed and operated entirely by COD employees.
JURISDICTION AND VENUE
6.

Jurisdiction is granted to this Court under 5 §ILCS 140/11(a) of FOIA.

7.

Venue is proper in DuPage County under 5 §ILCS 140/11(c) of FOIA because

Defendants COD and the Foundation are located in DuPage County.
FACTUAL BACKGROUND
The Illinois FOIA
8.

In FOIA, the Illinois General Assembly declared that “all persons are entitled to

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 full and complete information regarding the affairs of government and the official acts and
policies of those who represent them.” 5 ILCS §140/1. FOIA specifically creates a presumption
that “[a]ll records in the custody or possession of a public body are presumed to be open to
inspection or copying.” Id. §140/1.2.
9.

“A ‘public body’ means all legislative, executive, administrative, or advisory

bodies of the State, state universities and colleges, counties, townships, cities, villages,
incorporated towns, school districts and all other municipal corporations, boards, bureaus,
committees, or commissions of this State, any subsidiary bodies of any of the foregoing ….” Id.
§140/2(a).
10.

“‘Public records’ means all records, reports, forms, writings, letters, memoranda,

books, papers, maps, photographs, microfilms, cards, tapes, recordings, electronic data
processing records, electronic communications, recorded information and all other documentary
materials pertaining to the transaction of public business, regardless of physical form or
characteristics, having been prepared by or for, or having been or being used by, received by, in
the possession of, or under the control of any public body.” Id. §140/2(c).
11.

“A public record that is not in the possession of a public body but is in the

possession of a party with whom the agency has contracted to perform a governmental function
on behalf of the public body, and that directly relates to the governmental function and is not
otherwise exempt under [FOIA], shall be considered a public record of the public body….” Id.
§140/7(2).
The Foundation
12.

The Foundation is an Illinois not-for-profit corporation incorporated on December

7, 1967. It is exempt from taxation under Section 501(c)(3) of the United States Internal

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 Revenue Code. Its purpose is to raise money for COD and its programs. Specifically, the
Foundation’s website states that its mission is “to obtain and steward contributions to expand
educational and cultural opportunities for the College of DuPage community.” The Foundation
is the fundraising arm of COD that is housed at COD’s campus and staffed and operated entirely
by COD employees. It operates as COD’s development office.
13.

Upon information and belief, the Foundation raises and contributes money

exclusively to COD for COD programs, scholarships for COD students, and COD initiatives, and
does not raise or donate funds for any purpose other than financially supporting COD.
14.

Among other programs, the Foundation has a “Leadership Cultivation” initiative

that funds certain expenses for COD’s leaders including COD President Robert Breuder
(“President Breuder”). As reported by the Tribune, the Foundation has reimbursed, for example,
meals and expensive bottles of wine for Brueder at COD’s on-campus restaurant, the Waterleaf.
The Foundation has or had a “House Account” at the Waterleaf to which Brueder billed charges.
15.

The Foundation is located at 425 Fawell Boulevard, Glen Ellyn, IL, which is a

building on COD’s campus. The Foundation does not pay rent, occupancy, utilities, or any other
amounts in return for the space it occupies on the COD campus. Rather, COD covers such
occupancy expenses for the Foundation.
16.

The website of the Foundation is hosted by COD at the web address

www.foundation.cod.edu. The email addresses for the Foundation’s employees are all at the
domain “@cod.edu,” which is the COD email server.
17.

The telephone exchange for the Foundation is the same as the telephone

exchange for COD.
18.

The Executive Director of the Foundation, Catherine Brod (“Brod”), is also the

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 Vice President of Development for COD. She is paid exclusively by COD. In fact, her position
with the Foundation is listed along with her COD position on COD’s website (“Catherine Brod
— Vice President, Development — Executive Director, College of DuPage Foundation.”).
19.

The Associate Executive Director of the Foundation, Karen Kuhn, is also the

Assistant Vice President of Development for COD. She is paid exclusively by COD. In fact, her
position with the Foundation is listed along with her COD position on COD’s website (“Karen
Kuhn — Assistant Vice President, Development — Associate Executive Director, College of
DuPage Foundation.”).
20.

On information and belief, COD does not have a separate development or

fundraising office other than the Foundation.
21.

The Foundation does not have any of its own employees. Each and every one of

the staff members who works for the Foundation is paid by COD and not by the Foundation.
22.

There are approximately eleven (11) staff members, including Brod and Kuhn,

who perform work for the Foundation as part of their duties for COD. The Foundation does not
pay these individuals but instead they are paid by COD.

As listed in its tax filings, the

Foundation incurred $0 for compensation, salaries and wages in each of tax years 2011, 2012
and 2013.

Upon information and belief, each and every individual who works for the

Foundation also obtains employee benefits, such as health insurance and pension benefits,
through plans that are available exclusively to COD employees.
23.

President Breuder is an ex-officio member of the Foundation’s Board of

Directors. Brod also is an ex-officio member of the Foundation’s Board of Directors.
24.

The administrators and/or trustees of COD in the past have been involved in

selecting board members of the Foundation.

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 25.

The Foundation is mostly or entirely under the control of COD. Employees and

administrators of COD, including but not limited to President Breuder, Brod and Kuhn, fully
direct and control the work of the Foundation. This includes decisions relating to raising and
spending funds by the Foundation exclusively for such purposes as requested or directed by
COD.
26.

Upon information and belief, COD has entered into a contract, either written or

oral, with the Foundation. Under this contract, the Foundation operates as a fundraising arm or
subsidiary of COD.
27.

Upon information and belief, the Foundation and COD closely coordinate

fundraising priorities, donor targets, and other affairs usually handled by a public college’s
development office.

Therefore the Foundation performs certain governmental functions –

including without limitation fundraising, donor development, grant making, and student
scholarships – for COD.
The April 1, 2015 FOIA Request for DuPage Grand Jury Subpoena
28.

The DuPage County State’s Attorney’s Office served a grand jury subpoena for

records on the Foundation (the “DuPage Grand Jury Subpoena”).
29.

Brod stated to Tribune reporter Jodi Cohen on March 29, 2015 that she had a copy

of the DuPage Grand Jury Subpoena. As previously alleged, Brod is an employee of COD as
well as the Foundation.
30.

On April 1, 2015, Tribune reporter Stacy St. Clair sent a FOIA request to COD by

email seeking “Any copies of grand jury subpoenas for the College of DuPage Foundation which
are in possession, physically or in electronic form, of the college, any of its administrators, senior
managers, president, board members, paid consultants, lobbyists or representatives.” (Ex. 1) (the

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 “April 1 Subpoena Request”).
31.

On April 8, 2015, Barbara Mitchell, the FOIA officer of COD, emailed a denial of

the April 1 Subpoena Request, stating, “The college does not have any documents responsive to
your request.” (Ex. 2).
32.

Upon further inquiry from the Tribune’s counsel, counsel for COD, Nanci Rogers,

stated in an email dated April 9, 2015: “Regarding the FOIA request for a Foundation grand jury
subpoena, our firm does not have a copy of a grand jury subpoena that was issued to the College
Foundation. We have checked with the Foundation Director [Brod] and the College and have
been advised that no College employee is in possession of such subpoena.” (Ex. 3).
33.

The Tribune’s counsel emailed Rogers again on April 9, 2015, stating that “the

Tribune has information that both Robert Breuder and Catherine Brod are or were in possession
of copies of the subpoena.” Id.
34.

Rogers responded: “[P]lease be advised that we have asked Dr. Breuder, Ms.

Brod as well as other College employees whether they have a copy of a grand jury subpoena
issued to the College Foundation and were told they did not. As I mentioned when we spoke
earlier today, we do not know who representing the Foundation may have an original grand jury
subpoena as we do not represent the College Foundation.” Id.
35.

After being informed on April 10, 2015 that Brod had stated to Cohen on March

29 that she was, in fact, in possession of a copy of the DuPage Grand Jury Subpoena, Rogers
finally admitted that Brod previously had a copy of the DuPage Grand Jury Subpoena, but since
then, the Foundation gave “the original and any copies of the grand jury subpoena” to another
outside attorney who was now representing the Foundation, and “[t]herefore the College has no
document responsive to your request.” Id.

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 36.

COD has never contended that the DuPage Grand Jury Subpoena is exempt from

FOIA. COD has admitted that the DuPage Grand Jury Subpoena was received by and formerly
in the possession of Brod, a COD employee. However, Brod later gave the DuPage Grand Jury
Subpoena to outside counsel for the Foundation (apparently the only representative of the
Foundation who is not also an employee of COD). Therefore, COD has used the Foundation –
and, specifically, separate outside counsel for the Foundation – as an artifice to circumvent the
mandates of FOIA and not disclose the DuPage Grand Jury Subpoena.
April 16, 2015 FOIA Request for Federal Grand Jury Subpoena
37.

On information and belief, the Foundation was served with at least one federal

grand jury subpoena on or around April 13, 2015 (the “Federal Grand Jury Subpoena”).
38.

On April 16, 2015, Tribune reporter St. Clair sent identical FOIA requests to each

of COD and the Foundation seeking “all state or federal subpoenas received by the College of
DuPage Foundation since April 1, 2015.” (Ex. 4 and 5) (the “April 16 Subpoena Request”).
39.

On April 23, 2015, a public relations spokesperson for the Foundation, Matt

Butterfield, informed St. Clair that the Foundation was denying the April 16 Subpoena Request.
(Ex. 6). Specifically, Butterfield wrote, “Counsel has instructed me that the Foundation is not
subject to FOIA as a non-governmental, not for profit corporation.” Id.
40.

On April 24, 2015, COD responded to the April 16 Subpoena Request by stating

that “The college does not have any documents responsive to your request.” (Ex. 7).
41.

COD has never disputed that the Federal Grand Jury Subpoena is a public record

that would be subject to disclosure under FOIA if it were received by, or in the possession or
control of, COD or the COD staff members who are also Foundation employees. In fact, since
approximately March 2015, COD has released to the Tribune copies of five (5) state or federal

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 subpoenas issued directly to COD in response to other FOIA requests from the Tribune.
42.

On information and belief, originals or copies of the Federal Grand Jury

Subpoena were, at one time, received by and in the possession of President Breuder, Brod,
and/or other COD employees.
43.

On information and belief, COD has taken the position that it does not have any

documents responsive to the April 16 Subpoena Request because Brod and/or other COD
employees who are also employed by the Foundation have now given any responsive documents
to outside counsel for the Foundation who is not an employee of COD.
44.

Thus COD is again using the Foundation – and, specifically, separate outside

counsel for the Foundation – as an artifice to circumvent the mandates of FOIA and not disclose
the Federal Grand Jury Subpoena.
April 14, 2015 FOIA Request for Leadership Cultivation Documents
45.

The Foundation has paid various expenses for President Breuder, including but

not limited to entertainment, meals and alcohol, via a “Leadership Cultivation” account or grant.
Specifically, the Foundation reported in its tax filings spending the following amounts for
“Leadership Cultivation:”
a. FY 2014: $27,276
b. FY 2013: $20,590
c. FY 2012: $39,481
d. FY 2011: $14,910
46.

Brod stated to the Tribune in a telephone interview on April 13, 2015, that these

“Leadership Cultivation” allocations covered the expenses of President Breuder.

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 47.

On April 14, 2015, Tribune reporter St. Clair sent identical FOIA requests to each

of the Foundation and COD seeking various documents, including but not limited to “receipts,
expense reports, and other documents showing payments made as part of the ‘Leadership
Cultivation Meetings’ or ‘Leadership Cultivation Account’ …” and “payments made as part of
the ‘Leadership Cultivation Grant….” (Ex. 8 and 9) (“The April 14 Leadership Cultivation
Request”). The April 14 Leadership Cultivation Request additionally sought “[c]opies of all
receipts, expense reports, and other related documents submitted by College of DuPage
administrators for reimbursement from the College of DuPage Foundation…” Id. (collectively,
the “Leadership Cultivation Documents”).
48.

On April 23, 2015, Butterfield informed St. Clair that the Foundation was denying

the April 14 Leadership Cultivation Request. (Ex. 6). Specifically, Butterfield wrote, “Counsel
has instructed me that the Foundation is not subject to FOIA as a non-governmental, not for
profit corporation.” Id.
49.

The Foundation has not claimed that the April 14 Leadership Cultivation

Documents are otherwise exempt from FOIA should the Court hold that the Foundation is
subject to FOIA.
50.

On April 29, 2015 (via a letter dated April 28, 2015), COD FOIA officer Mitchell

responded to the April 14 Leadership Cultivation Request as follows: “The college does not have
any documents responsive to your request.” (Ex. 10). Mitchell verbally informed the Tribune’s
reporters that COD was taking the position that the Leadership Cultivation Documents were not
in its possession or control because they were in the possession or control of the Foundation.
COD is taking this position despite the fact that the Foundation is staffed exclusively by COD
employees and therefore any documents in the possession of the Foundation’s staff members

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 necessarily are in the possession of COD as well. Moreover, many of the requested documents –
including but not limited to receipts from the Waterleaf, expense reports and reimbursement
request forms – were prepared by COD employees.
January 20, 2015 FOIA Request for Waterleaf Documents
51.

The denials of the April 1, 14 and 16 Requests are not the first occasions on

which COD has used the Foundation as an excuse to avoid FOIA’s mandates.
52.

COD owns and operates an on-campus restaurant called the Waterleaf, which

opened in late 2011.
53.

On January 20, 2015, Tribune reporter Cohen sent a FOIA request to COD

seeking, among other things, “Documents showing all House Accounts associated with the
Waterleaf” restaurant; and “Copies of all receipts charged to House Accounts associated with the
Waterleaf since 2011.” (Ex. 11, Nos. 7 and 8) (the “January 20 Waterleaf Request”).
54.

Over a period of time, COD provided certain documents responsive to the January

20 Waterleaf Request.

Specifically, COD provided receipts and other documents showing

charges to House Accounts 10 and 30, which were COD House Accounts at the Waterleaf.
55.

However, COD failed to provide documents responsive to the Waterleaf FOIA

related to Waterleaf House Account 20, which is or was a Foundation House Account.
56.

On February 24, 2015, Cohen sent an email to COD employee Joseph Moore

specifically asking, “[A]re there any House Accounts other than Accounts 10 and 30?” (Ex. 12).
57.

Rather than answering Cohen’s question, Moore responded by email on February

26, 2015, “The College will have no further comment at this time.” Id.
58.

On or about February 25, 2015, Cohen verbally asked COD’s FOIA officer,

Mitchell, whether there were documents for a Waterleaf House Account 20. Mitchell replied,

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 incorrectly, that there were no House Accounts other than House Accounts 10 and 30. She
further stated, incorrectly, that if Cohen and St. Clair had seen Waterleaf receipts designated for
House Account 20, that designation was an error.
59.

Finally, on or around April 13, 2015, Brod reluctantly admitted during a

telephone interview with Cohen that there existed a House Account 20 at the Waterleaf that was
the Foundation’s House Account. Specifically, Cohen asked Brod, “Does the Foundation have a
house Account [at the Waterleaf]?”

Brod said, “No.”

Then Cohen asked her, “Did the

Foundation ever have a house Account at the Waterleaf?” Broad hesitated and then said, “Yes.”
St. Clair then asked, “Was it House Account 20?” Brod claimed she did not know.
60.

On or about April 13, 2015, Cohen emailed counsel for COD, Kenneth Florey,

and requested that all documents relating to the Foundation’s House Account be disclosed
immediately pursuant to the January 20 Waterleaf Request. (Ex. 13)
61.

On or about April 17, 2015, FOIA Officer Mitchell forwarded certain responsive

documents to Cohen claiming that they were responsive to a “supplemental FOIA request
received via email dated April 13,” (Ex. 14) even though there was no April 13 FOIA request.
These documents revealed that there was a House Account 20, which was an account for the
Foundation.

These documents relating to Waterleaf House Account 20 should have been

disclosed in January pursuant to the January 20 Waterleaf Request.
62.

Thus COD only disclosed documents regarding the Foundation’s Waterleaf

House Account 20 after it was caught in a lie, and even then COD disclosed them four months
late. This is yet another example of the way in which COD – a public college – has been using
the existence of the Foundation as an excuse or a subterfuge to shield its financial records and
expenditures from public view, all in violation of FOIA.

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 COUNT I – DECLARATORY JUDGMENT
AGAINST THE COLLEGE OF DUPAGE FOUNDATION
UNDER ILLINOIS FREEDOM OF INFORMATION ACT
63.

The Tribune incorporates by reference paragraphs 1 through 62 of this Complaint.

64.

The Foundation is a “public body” or a “subsidiary” of a public body as those

terms are defined in 5 ILCS §140/2(a) because it operates functionally as a part of COD, being
staffed exclusively by COD employees who work in a COD building for the purpose of
financially supporting COD and its administrators, under the control of COD.
65.

Alternatively, the Foundation is contracted with a public body to perform one or

more governmental functions – including without limitation fundraising, donor development,
grant making, and student scholarships – on behalf of COD, as defined in 5 §ILCS 140/7(2).
66.

Therefore, the Foundation is subject to the requirements of FOIA.

67.

The Tribune is entitled to recover its reasonable attorneys’ fees pursuant to 5

ILCS §140/11(i).
WHEREFORE, the Tribune seeks (1) a declaratory judgment in its favor that the
Foundation is subject to FOIA, and that records in the possession or control of the Foundation
that are not otherwise exempt from FOIA are “public records” within the meaning of FOIA;
(2) an order allowing The Tribune expedited discovery regarding whether the Foundation is a
public body, a subsidiary to a public body, and/or contracted to perform governmental functions
for COD; (3) an order awarding the Tribune its attorneys’ fees and costs in prosecuting this
action; and (4) an order awarding the Tribune any other appropriate relief.

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 COUNT II – DECLARATORY JUDGMENT
AGAINST THE COLLEGE OF DUPAGE
UNDER ILLINOIS FREEDOM OF INFORMATION ACT
68.

The Tribune incorporates by reference paragraphs 1 through 62 of this Complaint.

69.

Alternatively to Count I—if the Foundation is deemed not to be subject to

FOIA—then the documents responsive to the April 1 Subpoena Request, the April 16 Subpoena
Request and the April 14 Leadership Cultivation Request are public documents in the possession
or control of COD within the meaning of 5 ILCS §140/2(c). Specifically, the DuPage Grand
Jury Subpoena, the Federal Grand Jury Subpoena, and the Leadership Cultivation Documents are
“public documents” by virtue of “ having been or being used by, received by, in the possession
of, or under the control of [COD as a] public body.”
70.

COD’s control over the operations of the Foundation is such that any document in

the physical possession of the Foundation or its agents is effectively in the control of COD
pursuant to 5 ILCS §140/2(c).
71.

The Tribune is entitled to recover its reasonable attorneys’ fees pursuant to 5

ILCS §140/11(i).
WHEREFORE, the Tribune seeks (1) a declaratory judgment in its favor that records not
otherwise exempt from FOIA in the physical possession of the Foundation or its agents remain in
the effective control of COD and therefore are “public records” within the meaning of FOIA,
which COD must produce under FOIA; (2) a declaratory judgment in its favor that records not
otherwise exempt from FOIA in the physical possession of the Foundation or its agents
previously prepared, received or possessed by COD are “public records” within the meaning of
FOIA that COD must produce under FOIA; (3) an order allowing The Tribune expedited
discovery regarding whether said documents are “public records” within the meaning of 5 ILCS

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 §140/2(c); (4) an order awarding the Tribune its attorneys’ fees and costs in prosecuting this
action; and (5) an order awarding the Tribune any other appropriate relief.

COUNT III – INJUNCTION
AGAINST COLLEGE OF DUPAGE AND COLLEGE OF DUPAGE FOUNDATION
UNDER ILLINOIS FREEDOM OF INFORMATION ACT
72.

The Tribune incorporates by reference paragraphs 1 through 62 of this Complaint.

73.

The Tribune seeks disclosure of:
a. The DuPage Grand Jury Subpoena as sought in the Tribune’s FOIA request dated
April 1, 2015 and defined in Paragraph 28 above;
b. The Federal Grand Jury Subpoena as sought in the Tribune’s FOIA requests dated
April 16, 2015 and defined in Paragraph 37 above; and
c. The Leadership Cultivation Documents as sought in the Tribune’s FOIA requests
dated April 14, 2015 and defined in Paragraph 47 above.

74.

The documents sought in the preceding paragraph are public documents within

the meaning of 5 ILCS §140/2(c) and subject to disclosure by COD and/or the Foundation under
FOIA. Neither the COD nor the Foundation has claimed that the documents are exempt under
Section 7 of FOIA for any reason. Thus the documents must be produced under FOIA.
75.

This court has jurisdiction “to enjoin [COD and the Foundation] from withholding

public records and to order the production of any public records improperly withheld from the
person seeking access.” 5 ILCS §140/11(d).
76.

The Tribune is entitled to recover its reasonable attorneys’ fees pursuant to 5

§ILCS 140/11(i).

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 WHEREFORE, The Tribune requests that this Court enter an injunction (1) ordering
COD and the Foundation to promptly produce (a) the DuPage Grand Jury Subpoena, (b) the
Federal Grand Jury Subpoena, and (c) the Leadership Cultivation Documents; (2) allowing The
Tribune expedited discovery regarding the documents sought; (3) awarding the Tribune its
attorneys’ fees and costs in prosecuting this action, and (4) awarding the Tribune any other
appropriate relief.
April 29, 2015

Respectfully submitted,
THE CHICAGO TRIBUNE

By:

/s/ Alexandra K. Block
One of its attorneys

Daniel M. Feeney
Alexandra K. Block
MILLER SHAKMAN & BEEM
180 North LaSalle Street
Suite 3600
Chicago, IL 60601
(312) 263-3700

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 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464

 Document received on 2015-04-29-15.37.07.0 Document accepted on 04/29/2015 16:01:18 # 3675366/17043361464