Attachment comments

This document pretains to SAT-AMD-20040826-00161 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2004082600161_404717

soar sarmo0ati Lora. cveerstar, ncme0 * Telsrar ie BEFORE Federal Communications Commission WASHINGTON, D.C. REeCElvEp In the Matter of NOV ~ 1 2094 FoderlCan Public Notice, Da. No. 04—3176 oneso grttConnintn (October 1, 2004) Grant of Application FilSkeqiaeat90—20011136° For Modification of Telstar 11R 00018 Authorization, NOV 0 2 z004 Call Sign $ 2357 Policy Branch Loral Orion, Inc. (Debtor—In—Possession) Intomnational Bureay Petition for Partial Reconsideration And Request for Waiver 0 2 2004 PETITION FOR PARTIAL RECONSIDERATION AND 0 R John P. Stem Deputy General Counsel Loral Space & Communications Ltd. (Debtor—In—Possession) 600 Third Avenue New York, New York 10016 (212) s3e—5228 November 1, 2004

TABLE OF CONTENTS SUMMARY.. BACKGROUND. 1. SECTION 25.165 OF THE COMMISSION‘S RULES BY ITS TERMS DOES NOT APPLY TO SATELLITE LICENSE MODIFICATIONS. ut THE COMMISSION‘S ORDER IMPOSING THE BOND SPECIFICALLY LIMITED APPLICATION OF THE BOND REQUIREMENT TO PENDING APPLICATIONS FOR NEW SATELLITE LICENSES.. 1¥ EVEN IF THE COMMISSION FAILS TO RESCIND THE BOND REQUIREMENT, IT SHOULD GRANT LORAL‘S REQUEST FOR A WAIVER OF SECTION 25.165(A) OF THE COMMISSION‘S RULES... CONCLUSION

SUMMARY Under a plain reading of 47 C.F.R. Section 25.163,a performance bond may only be imposed on "satellite licenses" fssued after teffective date ofthe rule and not on license modifications. The Bureau erred in applying the performance bond to Loral‘s request to modify a preexisting satellite replacement license. Moreover, the Commission‘s orders make clear that the bond rule was intended to have limited application to certain new satellite applications, not modification requests, pending at the time the bond rule became effective to avoid imposing a burden on existing licensees, pursuant to well established retroactivity criteria. In the altemative, should the Petition for Reconsideration be dismissed, Loral secks a waiver of the rule for good cause. Loral‘s Telstar satellites have provided critical capacity used for public safety services by agencies including the Federal Emergency Management Agency, the Department of Defense, and the Department of Homeland Security, and Telstar 11R would continue to provide capacity for such publi safety services. The Commission has specifically cited provision ofsuch public safety services as a factor weighing in favor ofa request for waiver ofthe bond requirement. Loral is also in a Chapter 11 reorganization process precipitated by significant financial hardship and can il afford the substantial costs associated with maintaining the bond. Waiver is also justified here because even if the Bureau‘s action could be upheld under the new bond rule, the retroactive financial burden on Loral, as an existing Hicensee,remains substantial. Finally, the nearly three—year pendency of Loral‘s modification request followed by almost immediate Bureau action following the effective date of a revised bond rule under which the Bureau seeks to impose the bond here presents an equitable reason for grant ofthe waiver.

BEFORE THE Federal Communications Commission WASHINGTON, D.C. In the Matter of ) ) Public Notice, Da. No. 04—3176 ) (October 1, 2004) Grant of Application ) File No. SAT—MOD—20011130— For Modification of Telstar 11R ) oo018 Authorization, ) Call Sign $ 2357 ) ) Loral Orion, Inc. (Debtor—In—Possession) ) ) ) Petition for Partial Reconsideration ) And Request for Waiver ) PETITION FO ERATION AND REQUEST FOR WAIVER Loral Orion, Inc. (Debtor—In—Possession) (‘Loral") submits this petition for partial reconsideration ofthe International Bureau‘s grant of Loral‘s Request for Modification of its Telstar 11R authorization. Specifically, Loral requests that the Bureau rescind or strike condition 2(e)in the attachment to the Telstar 11R Modification Grant, that required Loral to execute and file a $3 million dollar bond. Under a plain reading of the Commission‘s bond rule,and in light of the policies set forth in the Commission‘s underlying orders as well as established retroactivity law, the Bureau should not have retroactively imposed the bond requirement which took effect in 2004, on a replacement satellite liense that the Commission granted in 2001.

In the altemative, should the Commission determine that the imposition ofthe bond requirement was justified, Loral seeks a waiver ofthe rule. Loral satelites have provided critical eapacity used for public safety services by agencies including the Federal Emergency Management Agency (FEMA), the Department of Defense, and the Department of Homeland Security, and Telstar 1 1R would continue to provide capacity for such public safety services. The Commission has specifically cited provision of such public safety services as a factor weighing in favor ofa request for waiver ofthe bond requirement. Loral is also in a Chapter 11 reorganization process precipitated by significant financial hardship and can ill afford the substantial costs associated with maintaining the bond. In the interim, Loral posted the bond on October 28, 2004, to comply with the bond condition that is being challenged and to prevent possible automatic cancellation of its license. L BACKGROUND Telstar 11, a Ku—band satellite formerly known as Orion 1 and operated by Loral‘s predecessor in interest, Orion Atlantic, L.P. ("Orion"), has been operating at 37.5° W.L. since January 20, 1995. Telstar 11 is one ofthe series of Telstar FSS satellites that have provided a range ofservices to government and commercial users including critical public safety services provided to Americans via the Federal Emergency Management Agency and the Department of Defense. Orion filed an application to replace the satellite on May 8, 1998. On June 19, 2001 the Commission authorized Loral CyberStar, Inc. to

construct,launch and operate Telstar 1 TR as a Ku—band—only replacement for Telstar 11.\ Loral promptly requested that the Bureau adjust the construction milestonesThe 2001 Replacement Authorization had required completion ofconstruction by January 2003, a date that was reasonable when the application was fled in 1998 but could not have been met three years later when the Commission acted on the application, as it would have allowed just fourteen months in which to construct the satellte. Loral‘s milestone adjustment request was unopposed. Then, in November 2001, Loral filed an application for a modification of its authorization to use an additional 250 Mhz of spectrum in the extended Ku—band (2001 Modification Request)The 2001 Modification Request was also unopposed. On October 1, 2004, the Commission released a public notice containing the International Bureau‘s grant ofthe 2001 Modification Request.* The Bureau grant stamped the request and attached a set ofconditions, including new construction milestones and a requirement that Loral file a bond in the amount of$3 million by October 28, 2004." The Bureau dismissed Loral‘s request to adjust the milestones as moot, Loral executed a bond in that amount on Thursday, October 28, 2004 after ! Application ofLoral Space & Communications L. iva/ Orion Atlantc, L.P, fr Authoriy to Launch and Operate a Hybrid KibandChand Sateie System atthe37.5 W.L.OrbiLocation, File No. SAT« LOM—19980508—00043, DA—01—1427, Memerandr Opinion and Order, 16 ECC Red. 12,490 (2001) (©2001 Replacement Athorztion") * Leter fom John Stem, Deputy General Counse, oral Space & Communications L1d, to Thomas S Tyez, ChiStelite Division, InernationalBureau, FCG,dated July 19, 2001 ? saMop—20011130—00018 " Public Notee, D. No. 043176 (Octaber 1, 2004) Grant oApplieationfor Modificaion ofTelsar 1 TR Authorization, SAT—MOD—20011130.00018, CallSign S 2357 ("Telsar 11Modifcatin Gran). Loral Orin,Inc. (DebtorIn—Possession)is the entiy that currenl holdsthe authoriztionforTelsar 1 R. * Telsar 11R Modifiation Grant, Atachment, Condiion 2)@).

receiving approval to do so from Federal Bankruptey Court Judge Robert Drain. Loral timely filed a copy ofthe bond with the Commission the same day, to protect against automatic cancellation ofits Telstar 11R Modification Grant for failure to meet the bond condition 1t SECTION 25.165 OF THE COMMISSION‘S RULES BY ITS TERMS DOES NOT APPLY TO SATELLITE LICENSE MODIFICATIONS The FCC rule requiring the posting ofbonds, section 25.165, tatesin relevant part: (2) For all satelite licenses issued after September 20, 2004, other than DBS Hicenses, DARS licenses, and replacement satellite licenses as defined in paragraph (e), the licensee is required to post a bond within 30 days ofthe grant ofits license. Failure to post a bond will render the license null and void automatically. (1) NGSO licenseesare required to post a bond in the amount of $5 million (2) GSO licenseesare required to post a bond n the amount of $3 million sx++4 (€) A replacement satellite is one that is (1) authorized to be operated atthe same orbit location, in the same frequency bands, and with the same coverage area as one ofthe licensee‘s existing satelltes and (2)scheduled to be Iaunched so thatit will be brought into use at approximately the same time as, but no later than, the existing satellte is retired.® Loral contends that the Bureau improperly applied this rule retroactively upon the 2001 Replacement Authorization because the Commission did not ‘issue"a "satellite Hicense" when it grant stamped Loral‘s 2001 Modification Request. The Commission issued itsreplacement satelite license for Telstar 11R to Loral in 2001 (what the Bureau itself refers to as the ©2001 Replacement Authorization®), more than two years before the * Thisrule 47CR section 25.165, was modliffed (a quoted above)bythe Commissin in is Firt Order on Recansideration and Fih Reportand Order ("Fir Order on Reconsidention‘Y(IB Docket 02:34)(el. July7,2004 The first bond rul, imposed by the Commissionin the Frst Repor and Order, became efective on September 1, 2003.

first bond requirement took effect. The 2001 Replacement Authorization gave Loral final authority to construct,lunch and operate its replacement satellite, Telstar 1 1R, at 37.5° W.L. Thus, Loral already had its replacement satllite Kicense when it applied for a modification ofthat license to use additional Ku—band frequencies in November 2001 Indeed, Loral had already promptly executed a contract for construction for Telstar 11R in November 2001, in compliance with the original construction commencement milestone imposed by the Commission in its 2001 Replacement Authorization, at the time that it applied for its modification. By merely grant stamping Loral‘s unopposed 2001 modification request to add additional spectrum to Loral‘s 2001 Replacement Authorization, the International Bureau could not be deemmed to have issued a second replacement stellitelicense to Loral for the same orbital location. The Telstar 1 1R *satellite Kicense" had already been "issued" in 2001. It was the modification to that Hicense that was granted after the bond rule became effective, not the "satellte icense"" that isubject tothe bond requirement in section 25.165(@). The Commission has traditionally differentiated in its rules between space station Hicenses and space station license modifications. There are separate provisions in the Commission‘s rules for each." In the Commission‘s First Report and Order, in which it set out its new satellite licensing rules, including the bond requirement, it maintained this traditional distinction between "modifications", which it defined as "changes to a Hicensee‘s operating authority after itslicense has been granted" and "new satellite license 747 CR Sections 25.114and 25.117.

applications."*. Accordingly, under a plain reading of Section 25.165 ofthe Commission‘s rules, he Bureau erred in imposing the bond as a condition to the Telstar 11R Modification Grant. 111. THE COMMISSION‘S ORDER IMPOSING THE BOND SPECIFICALLY LIMITED APPLICATION OF THE BOND REQUIREMENT TO PENDING APPLICATIONS FOR NEW SATELLITE LICENSES The Commission‘s First Report and Order sets out its new satellite licensing rules, including the initial version ofthe bond requirement. That Order‘s detailed and specific discussion of which applications pending as ofthe effective date of the bond rule could be subject to that rule yields further support for Loral‘s argument that the bond requirement was not intended to apply retroactively to preexisting satellte licenses, such as Loral‘s 2001 Replacement Authorization, or to modifications of such preexisting authorizations. The Commission began its retroactivity discussion by stating that "we will apply the rules and proceduzes we adoptin this Order to pending applications, in cases where doing so will help further the goals ofthis proceeding to expedite service to the public and discourage speculation."" This statement makes clear that the Commission‘s new rules would apply to some but notall applications pending as ofthe effective date of the bond rule. The First Report and Order relied on established retroactivity law for the criteria it would use to make such determinations. The Commission articulated the following well established and limited circumstances for retroactive application of new rulesto pending applications: "The Commission can apply new procedures to pending applications if doing so does not impair the rights an applicant * Amendmentof the Commission‘s Space Station LicensingRulesand Polies,Frs Report and Ordeand Purther Natce ofProposed Rulemaking, 1B Docket No.02—34, 18 FCC Red 10760 (*Firt Report and Order)1 Mi—144. * Fist Report and Order, 4275

possessed when it filed ts application, increase an applicant‘s liability for past conduct, or impose new duties on applicants with respect to transactions already completed."" The Commission went on to conclude that application of the new rules tothe types of applications it specified in its First Report and Order would not have any ofthe prohibited effects." But that conclusion was based on the Commission‘s clarification that to satisfy the criteria for retroactive application ofnew rules to pending applications, only applications for new satellite lcenses would be subject its new satellite Kicensing rules, including the bond rule. Specifically, the Commission stated: «We emphasize that some ofthe rules we apply to pending applications do not apply to licenses granfed before this Order was adopted. Thus, licensees will not be required to post a bond for lcenses they have been granted in the past.""" And the Commission wrote: "We will apply this bond requirement to new satellte icensees only, not replacement satellites. Once a licensce has begun to provide service, we are confident that its replacement satellite application will be intended to continue service, and would not be filed for speculative purposes." As recently as July 6, 2004, the Commission reaffirmed this policy: "[WJe reiterate that the Commission did not adopt a bond requirement for replacement satellites.""" By effectively imposing the bond on a replacement satellte license that was granted before the bond rule became effective, the Interational Bureau acted in violation ofthese clear "* Bs Report and Order, 9276 and n. 686 (cting DirecTV, Ic.v. PCC, 110 F3d 816, 82526 (D.C.Cir. 1997);Landarat‘v. UST Film Producs, S11 U.S. 244, 280 (1994), ty © Fist Report and Order 283 (emphasis in origina " Fist Order on Reconsidertion, 1 55

directives in the First Report and Order, directives that are based on established retroactivity precedent. The Bureau‘s imposition ofthe bond, without discussion or analysis, in a grant stamped license modification in this case also clearly fails to satisty the substantive criteria for retroactive application ofnew rules set forth by the Commission because the bond does *impose new duties on applicants with respect totransactions already completed." In the First Report and Order the Commission concluded that application of the bond rule would not "impose new duties" on applicants for new satellite lienses "with respect to transactions already completed"because merely filing an application for a new satellite license could not be considered a completed transaction as such applicants have not yet been granted space station licenses. But here the Bureau did impose a new duty on Loral with respect to a "transaction already completed" by making Loral‘s 2001 Replacement Authorization subject to the bond requirement that became effective on September 20, 2004. Ttis indisputable that imposition of a multi million—dollar bond on existing licensees clearly imposes significant new duties and burdens on their licenses — the "transactions already completed." The Bureau‘s imposition ofthe bond on Loral‘s 2001 Replacement Authorization, has had an effect that the Commission specifically sought to avoid: an existing licensee, Loral,has been burdened with a requirement to spend considerable money on implementation of a $3 million dollar bond with respect to a license for a replacement satellite that the Commission granted long before the bond rule became effective. Had the Commission intended to apply the bond to existing satellite lcenseesor existing satellit replacement licenses with modification requests pending at the time that

the bond rule became effective, the Commission would have had to consider and justify the burden that the bond would impose on an existing licensce. That the Commission failed to even mention such a case, et alone analyze or justifyit, supports the proposition that the Commission carefullylimited retroactive application ofthe bond rule to pending applications for new satellites, he only type of pending applications that it specifically determined should be subject t the bond rule. Additional evidence of the Commission‘s intent to apply the bond only to new satellite applications can be found in its assumption that the only pending satellite applications to which its new rules would apply would be those filed in processing rounds in which the Commission‘s fungibility policy applied."* The Commission noted that such applicants for new satellite licenses could not have reasonably assumed they would be granted any authority if mutually exclusive applications were filed. Of course this assumption does not apply to the Bureau‘s application ofthe bond to a preexisting replacement authorization since the former fungibility policy and processing rounds applied only to new space station applications and not to a modification application to an existing authorization for a satelit intended to replace a licensee‘s operational satellte at a particular orbital slt. Had the Commission intended to apply the bond rule tolicense modification applications for existing replacement satellite lienses it would have to have considered this as an exception, not covered by the fungibility/processing round rationale discussed above. Unlike applicants thatfiled in processing rounds to which the fungibility policy applied, Loral reasonably had an expectation thatits modification request for its existing 2001 Replacement Authorization would be granted at 37.5° W.L., "* Fist Report and Order, $277.

as the application was not fled in the context ofa processing round and fungibility policy was not applicable. 1tis telling that te only specific applications that the Commission determined should be covered by the new licensing rules were new satellte applications filed in the V—band and Ka—NGSO processing rounds."" The Commission directed the International Bureau to review other pending applications consistent with the considerations discussed above."*. Inits grant—stamped Telstar 11R Modification the Bureau filed to even discuss, let alone justify, retroactive imposition ofthe bond or how such action could satisfy the Commission‘s retroactivity criteri in light ofthe obvious burden that the bond imposes on Loral‘s preexisting 2001 Replacement Authorization. Nor did the Bureau even attempt to explain how imposing the bond now would expedite service or discourage speculation with respect to a replacement satellte previously granted toa licensee already operating a satellite in the same orbital location. Moreover, the Bureau‘s action cannot be justified under the theory that in granting Loral‘s modification request it issued a new replacement lcense that included extended Ku—band. The Commission had already granted the 2001 Replacement License and its 2001 Modification Request was just that: a modification request and not a "new" replacement license. Further,that the bond imposed a new duty and onerous obligation on Loral‘s existing Telstar 1 TR license is clear, even if the Bureau‘s Telstar 1 1R Modification Grant could be deemed to be a new satellitelcense by virtue ofthe grant of authority to operate in the extended Ku—band. The Bureau‘s action stil has the " Fist Report and Order, 9 279—281. " Fit Report and Order, 4284 10

consequence of burdening the 2001 Replacement Authorization because both the Ku— band and extended Ku—band payloads will be on the same satellite. Thus, the retroactive effect ofthe bond on the 2001 Replacement Authorization is inescapable and the burden it imposes is not lessened and therefore should not bejustified even ifthe Telstar 11R Modification could be read as an additional or separate space station license pursuant to Section 25.165 and the revised definition ofreplacement satelites to exclude those with authorizations to operate in extended bands. In addition, in the First Order on Reconsideration, in which the Commission determined for the first time to apply the bond requirement to replacement satellits that are authorized to use extended bands,"" the briefdiscussion by which the Commission reaffirmed its decision to apply the bond rule to applications pending at the time that the bond rule became effective did not include any analysis of how imposing the bond on a pending modification request to an existing replacement authorization could satisty the established retronctivity erteria, discussed above."" The absence of any such discussion or analysis further supports Loral‘s position that the Commission did not intend for the Bureau to impose the bond requirement retroactively upon replacement satellte authorizations granted prior to September 20, 2004. Iv. EVEN IF THE COMMISSION FAILS TO RESCIND THE BOND REQUIREMENT, IT SHOULD GRANT LORAL‘S REQUEST FOR A WAIVER OF SECTION 25.165(A) OF THE COMMISSION‘S RULES In the event that the Commission determines to uphold the imposition of the bond requirement in this case, Section 25.165(a)of the Commission‘s rules, Loral requests a "‘ Fist Order on Reconsidenation, 54—59 " Fit Order on ReconsidentionY 71—72. 11

waiver ofthe requirement. The Commission‘s rules provide for waivers of any rule, provided that the petitioner shows good cause for the request." In the First Report and Order the Commission stated that it would consider requests for complete or partial waivers of the bond requirement for satelite operators proposing satelites that would provide public safety services."" Loral intends to provide public safety services on Telstar 1 TR as it has done for years on its Telstar satellites. Loral has consistently provided a range ofpublic safety services on Telstar 11 and other Telstar satellites on both a long and short term basis. Such public safety services have included provision ofdata and video capacity for the U.S. and state and local government entities t assis with air traffic control, disaster recovery services, and certain military operations. Telstar FSS capacity has been used to help FEMA provide communications services for forest fire fighting operations and for emergency reliefservices for victims of hurricanes and floods, and to help the Federal Aviation Administration to provide aviation safety. Telstar satelites provided capacity used extensively to provide public safety services in connection with the horrific attacks of September 11, 2001 and later for public safety services provided by the Department of Homeland Security. Telstar 11R is designed to continue to provide such public safety services, and Loral intends to provide these services on the satellite. Forthat reason, Loral requests a waiver ofthe bond requirement. Loral also remains in a Chapter 11 reorganization that began last year and seks waiver of the bond rule based on financial hardship as evidenced by its bankruptcy Pacras1s * Funst Reportand Order, § 169. 12

proceeding. On October 22, 2004, the Commission granted Loral a waiver for all of its 2004 regulatory fees based on the financial hardship that precipitated Loral‘s Chapter 11 filing."" In granting its waiver the Commission restated that "t will grant waivers of ts regulatory fees on a sufficient showing of financial hardship, and evidence of bankruptey or receivership is sufficient to establish financial hardship."" The Commission determined that Loral had submitted evidence establishing thatit had commenced Chapter 11 proceedings on July 15, 2003 and therefore the Commission granted the waiver request in full"". As Loral remains in Chapter 11, it requests a waiver of the rule based on ts continuing financial hardship. The costs ofmaintaining the bond are significant for Loral and waiver ofthe bond requirement will assist Loral in its plan to successfully emerge from Chapter 11 by reducing its costs. This will help Loral proceed more quickly to complete construction and launch Telstar 11R, expediting service tothe public including the crtical public safety services that have traditionally been provided using Loral‘s Telstar satellits. Loral also merits grant of a request for waiver in light ofthe unique circumstances in this case. Should the Commission refect Loral‘s Petition for Reconsideration and retain the bond requirement, this would be the first time that the bond was effectively imposed via a modification request by a licensee, Loral,that held its eplacement license long before the bond rule was even proposed, yet alone implemented. As discussed * Leter from Mark A. Reger o Phili L. Verveer(Oct. 22, 2004) Re: Request for Waive of cal Year (FY) 2004 Regulatary FeesforLoralSpaceCom Corpontion (Debror.In—Possesion), Lonl OrionInc (DcbtorIn—Rassession), and Lorl Senet Network Services, Inc.(DebtorIn—Possession)(Control No. co00r20G—04—050) "t1 "1 13

above,"" even ifthe Commission determines that the Bureau had authority to impose the bond because it deems the 2001 Modification Grant to be a new authorization for extended Ku—band under the revised bond rule that took effect on September 20, 2004, Loral‘s preexisting 2001 Replacement Authorization is inescapably and retronctively burdened with the costs ofthe bond. Finally, Loral‘s 2001 Modification Request to add extended Ku—band frequencies was filed on November 30, 2001. It was unopposed. Nevertheless,the Bureau did not grant the modification request until September 28, 2004, nearly three years later and only ight days following the effective date ofthe revised bond rule which the Bureau cites for authority to impose the bond. Even if the Commission were to reject Loral‘s arguments that the bond does not apply in this case, equity supports waiver ofthe bond given the unusually long time during which Loral‘s unopposed modification request was pending followed by almost immediate action following the effective date of the revised bond requirement. "* See discussion at pages 10—11 14

v. CONCLUSION Forall of the reasons discussed above, Loral requests that the Commission reconsider and rescind or delete ts imposition ofthe bond requirement attached as condition (2)(¢) to the Telstar 1 1R Modification Grant. In the alternative, Loral requests that the Commission grantits request for a waiver ofapplication of the bond requirement for good cause. Respectfully submitted, —PSlac John P. Stem Deputy General Counsel Loral Space & Communications Lid. (Debtor—In—Possession) 600 Third Avenve New York, New York 10016 (212) 338—5228 November 1, 2004 is

CERTIFICATE OF SERVICE 1, Dennette Manson, do hereby certify that on this 1st day of November 2004, copies of the foregoing Petition For Partial Reconsideration And Request For Waiver were delivered by hand, unless otherwise indicated, to the following parties: Marlene H. Dortch Thomas S. Tycz, Acting Chief Secretary Satellte and Radiocommunication Division Federal Communications Commission International Bureau 445 12th Street, SW Federal Communications Commission Washington, DC 20554 The Portals 445 12th Street, SW Washington, DC 20554 Femn J. Jarmulnek, Chief Robert Nelson, Chief Satellite Policy Branch Engineering Branch Satellite and Radiocommunication Division Intemational Burcau Federal Communications Commission Federal Communications Commission The Portals 445 12" Street, SW 445 12th Street, SW Washington, DC 20554 Washington, DC 20554 Steven Spacth, Legal Advisor Office ofthe Bureau Chief International Bureau Federal Communications Commission 445 12" Street, SW Washington, DC 20554 (AA n ))WW


Document Created: 2004-11-09 15:07:38
Document Modified: 2004-11-09 15:07:38
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