HomeMy WebLinkAbout20201875.tiffINVENTORY OF ITEMS FOR CONSIDERATION
Applicant EWS 12 LLC Case Number U R20-0007
Submitted or Prepared
Prior to At
Hearing Hearing
1
Thornton
SPO
Dingess,
Letter
in
prepared
P.C.,
opposition
Attorneys
by
dated
Austin
and
April
Hamre
Counselors
16,
with
2020,
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received
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April
of
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21,
the
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2020
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Response
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April
to
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City of Thornton
2020.
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EWS 12,
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City
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of
responses
Thornton
3
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Ostrander
of the
from
City
Steven
of
&
Thornton
Dingess,
Louis
with
P.C.,
Prescott,
questions
Attorneys
Special
during
and
Counsel
Counselors
public
comment
with
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Law
4
5
I hereby certify that the items identified herein were submitted to the Department of Planning Services at
or prior to the scheduled Ptanning Commissioners hearing.
Kim Ogle
Planner
John M. Dingess
Donald M.
Richard F. Rodriguez
Austin Havre
Anthony J. Basile
Lynn B. Obernyer -- 2003
ITA NI k RODRIGUEZ,
OSTRANDER& PINGESS,
RC.
Attorneys and Counselors at Law
3600 S. Yosemite Street, Suite 500
Denver, Colorado 80237-1829
Telephone: (3 03) 779-0200
Telefax: (303) 779-3662
nail@hrodlaw.eom
wwvv.hrodlawscom
April 16, 2020
Via Q.T.S. and Electronic Mail
Weld County Department of Planning Services
c/o Kim Ogle
1555 N. 17th Ave.
Greeley, CO 80631
kogle@weldgov.com
EXHIBIT
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Special Counsel
Paul C. Rufien, P.C.
Teri L. Petitt, LLC
Stephanie M. Ceccato, LLC
Joel M. Spector, LLC
Steven Louis -Prescott, P.C.
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Re: EWS ##I2 DJ Basin LLC Saltwater Disposal Site, Case No. U R O-0007
(the "Project")
Dear Mr. Ogle:
I submit this comment to the Project on behalf of the City of Thornton ("Thornton"). As
a nearby landowner and interested neighbor, Thornton desires to participate in the discussion
related to the location and feasibility of the Project.
The notice of hearing ("Notice") for the Project shows it will be located in the Ei2E/2 of
Section 30 in Township 8 North, Range 65 West, 6th P.I1 ., Weld County (the "Lands").
Thornton owns land immediately north, west, and south of the Lands, along with some mineral
rights.
Thornton has numerous questions and concerns related to the Project that it desires to
discuss with Expedited Water Solutions Colorado, LLC ("EWS") and the County Planning
Department, including but not limited to the following:
1. What is currently planned for the Project on the Lands? In the Pre -
Application meeting with the County, the proposed Project involved a Class II injection well
facility. See October 6, 2017 Memorandum ("Pre -Application Memo"). The Notice also
identifies the Project as a Class II Saltwater Disposal Facility. However, according to the Use
By p►ecial Review Questionnaire ("USR Questionnaire") submitted to the County, the Project is
described as a "Class IV salt water injection well facility." Class II and Class IV injection wells
are sufficiently different: Class II includes wells used to inject fluids associated with oil and gas
production and are subject to the jurisdiction of the Colorado Oil and Gas Conservation
Commission ("COGCC"); Class IV includes shallow wells used to dispose of radioactive or
Page 2
April 16, 2020
hazardous waste into or above freshwater aquifers, and are now banned by the EPA except where
used as part of groundwater cleanup. For purposes of this letter, Thornton presumes the Project
involves Class II injection wells,
2. Has DNS sought and/or obtained the requisite permits for the Project? Class
II injection wells are subject to COGCC permitting and location regulations, which regulations
are being substantially modified pursuant to Senate Bill 19-181 (COGCC Mission Change
Rulemaking). The Pre -Application Memo requests evidence of State permits. Has EWS applied
for and obtained the requisite COGCC permits? No permits for the Project are identified on the
COGCC website, If this is the case, the CO 's review of the Project will likely be subject to
the new, more stringent COGCC regulations. It is unclear that the Project will meet these
COGCC regulations, so as to receive requisite State permits, Additionally, Class 11 injection
wells require WOGLA permits. Thornton has not received notice or information related to such
an application with the County.
3. The new COGCC regulations will require numerous additional analyses
before the Project may be approved. Have they occurred? What were the results? These
include an alternative location analysis, seismicity evaluation, and disposal formation
hydrocarbon evaluation.
4. What are the sources of produced water (lease and location) to be injected as
part of the Project? This information is necessary for a COGCC permit, and should be shared
with the County and neighbors to the Project.
5. The new COGCC regulations will require an in-depth cumulative impacts
analysis related to risks to public health, safety, welfare, wildlife, and the environment. Has
this occurred? Specifically, EWS will be required to submit narratives related to risks to air,
water (surface and ground), wildlife, noise, dust, traffic, light, ecosystems, waste, and best
management practices employed in relation to each.
6, What steps will EWS take to protect its neighbors from nuisances associated
with the Project? According to the USR Questionnaire, there is no landscaping, screening, road
expansion, or fencing (in addition to existing barbed wire) planned for the Project. But
according to the EWS #12 Site USR19-OOXX Map and USR Questionnaire submitted with the
application documents, the Project is planned to have a detention pond, leach field, 35 tanks for
salt water processing, injection facilities and activities, oil recovery, a drum of biocide, a drum of
scale inhibitor, a septic system, 20 passenger vehicle trips per day, and as many 100 truck visits
per day. In addition, it plans to operate 24 hours per day, 365 days per year. The Project raises
serious nuisance concerns related to, among other things, noise, dust, light, air, odor, traffic, and
pests.
7. How will surface and groundwater resources be protected? There are dozens
of water wells, ditches, and canals on the Lands, Thornton's property, and other lands within a
one-half (1/2) mile of the Lands. Have the owners thereof received the Notice? How will EWS
ensure the protection of these valuable water resources?
Page 3
April 16, 2020
8. How has the County ensured compliance with its code requirements related
to the Project (in addition to WOGLA LA requirements, including those enacted August 5,
2019)? By way of example only, the County Code mandates:
(1) "Groundwater contamination must be prevented by following state
regulations that require cementation of wells (including injection wells) to
prevent commingling of water, oil and gas into other formations.";
(2) "E&P Waste, when transported off -site within Colorado for treatment or
disposal, shall be transported to facilities authorized by the COGCC
Director or permitted waste disposal facilities approved to receive E&P
Waste.";
(3)
"OG.Policy 1.1. The County should encourage cooperation, coordination
and communication between the surface owner and the mineral
owner/operators with respect to any developments of either the surface or
the mineral estate.";
(4) "OG.Policy 1.2. Oil and gas support facilities which do not rely on
geology for locations should locate in commercial and industrial areas,
when possible, and should be subject to review in accordance with the
appropriate sections of this Code.";
(5)
"o .Policy 2.5. The County should use its regulatory powers, to the
extent authorized by law, to minimize the impacts of oil, gas and other
mineral extractions to the land and land uses and ensure complete
restoration of the areas impacted, from start-up through termination of
production.";
(6) "OG.Policy 2.6. Promote the safety of all citizens and structures that are in
relatively close proximity to oil and gas facilities.";
(7) "OG.Policy 2.8. Oil- and gas -drilling activities should be planned to
accommodate current and future surface subdivision activities to the
extent such development can reasonably be anticipated.";
(8) "OG.Policy 2.9. Impose protective measures through available state,
County and federal regulations to ensure that the mineral operator
conducts operations in a manner that will minimize current and future
environmental impacts.";
(9)
"OG.Policy 2.10. Promote that well sites are reclaimed and closed by
techniques which address that the future use of the property is not
impaired because of environmental or safety problems[,]";
Page 4
April 16, 2020
(10) "OG Policy 3.1. Support regulations for cementing wells (including
injection wells) to prevent commingling of water, oil and gas into other
formations."; and
(11) "O .Policy 3.3. The extraction of oil and gas minerals should minimize
the impact on the quality and quantity of ground and surface water."
9. Has EWS anticipated additional surface development in the area? The Lands
are less than 2 miles from Pierce and the Project access is on County Road 90, which is paved
and subject to moderate traffic. Traffic will increase as Pierce expands, calling into question the
ability of County Road 90, as currently constructed, to handle 100 additional semi -truck trips to
and from the Lands each day.
10. What types of fluids and chemicals will be injected on the Lands? New
COGCC regulations will require disclosure of this information. It is important for the County
and neighbors to know what they risk exposure to if an accident occurs.
11. What formation(s) will the fluids and chemicals be injected into, what are its
geographic boundaries, what is its permeability, and will the fluids and chemicals flow into
pore space owned by the Thornton and other mineral owners? Thornton and other minerals
owners are entitled to compensation if their mineral pore space is being used by EWS.
12. What is the status of the potential pipeline to the Project? EWS stated in the
USR Questionnaire that a pipeline may be constructed to the Projectin two years to minimize
truck traffic. Who will construct the potential pipeline? Is the construction still planned given
the oil price crash? What is the likelihood of pipeline construction, timing of the construction,
and effect on truck traffic?
13. Is the Project necessary and financially viable at $2Olbbl oil? $30/bbl?
$40/bbl? Some experts do not expect oil prices to return to economic levels in 2020 or 2021.
Without economic prices, oil and gas companies will stop drilling new wells, meaning there will
not be a need to dispose of produced water. This must be a concern for a company preparing to
construct a multi -million dollar injection well facility. How do oil prices affect EWS 's
construction timing and plans?
14. What financial assurance has EWS provided? The remediation, restoration,
and reclamation associated with the Project after initial construction and when it is abandoned,
whether next year or in 50 years, will be substantial. Likewise, clean-up costs associated with
any accidental spill would be substantial. The COGCC's current regulations require de mini is
bonds which are not scheduled to be reviewed and revised this year. EWS will likely submit a
$50,000 injection well bond for the Project, and maintain its $60,000 blanket plugging bond for
its injection wells statewide. The collective COGCC bonding amounts would not be nearly
enough to complete satisfactory remediation, restoration, and reclamation of the Project. What
bonding is the County requiring to ensure its land and water are protected should an accident
Page
April 16, 2020
occur or should EWS dissolve or file for bankruptcy protection? Is the County concerned about
inheriting clean-up liability?
15. What measures are being taken to ensure public safety related to
earthquakes? Many recent studies show a causal effect between Class II injection wells and
earthquakes. The only reportable earthquakes in Weld County have been associated with such
injection wells. Thornton has concerns about owning land with residences and tenant farmers
above the potential epicenter of an earthquake. In the USR Questionnaire, EWS recognizes there
may be other single-family residences adjacent to the Lands.
Thornton requests the opportunity to (virtually) meet with EWS and the County Planning
D epartm ent to discuss these and other questions and concerns, and preserves its right to object to
the Project at the hearings.
Very1Tru3y Yours,
,Steven LouissPrescott, Esq.
poo]steven@brotlaw.com
cc: Joanne Herlihy, Senior Assistant Attorney, City of Thornton (email only)
Scott Twombl , Real Estate Manager, City of Thornton (email only)
EXHIBIT
u52ia—cterJ
Page 1
April 16,2 020
April 16, 2020
Via T.T.S. and. Electronic Mail
Weld County Department of Planning Services
do Kim Ogle
1555 N. 17th Ave.
Greeley, CO 80631 kogleaweldgov.com
Res EWS #12 DJ Basin LLC Saltwater Disposal Site, Case No. U R2 O-000 7 (the
" Proj ect" )
Dear Mr. Ogle:
I submit this comment to the Project on behalf of the City of Thornton ("Thornton"). As a nearby
landowner and interested neighbor, Thornton desires to participate in the discussion related to the
location and feasibility of the Project.
The notice of hearing ("Notice") for the Project shows it will be located in the Ei2E/2 of Section 30
in Township 8 North, Range 65 West, 6th P.M., Weld County (the "Lands"). Thornton owns land
immediately north, west, and south of the Lands, along with some mineral rights.
Thornton has numerous questions and concerns related to the Project that it desires to discuss with
Expedited Water Solutions Colorado, LLC ("EWS") and the County Planning Department,
including but not limited to the following:
1. What is currently planned for the Project on the Lands?
In the Pre- Application meeting with the County, the proposed Project involved a Class 1I
injection well facility. See October 6, 2017 Memorandum (" Pre -Application Memo"), The
Notice also identifies the Project as a Class II Saltwater Disposal Facility. However, according
to the Use By Special Review Questionnaire "U SR Questionnaire") submitted to the County,
the Project is described as a "Class IV salt water injection well facility." Class II and Class TV
injection wells are sufficiently different: Class II includes wells used to inject fluids associated
with oil and gas production and are subject to the jurisdiction of the Colorado oil and Gas
Conservation Commission ("COGCC"); Class IV includes shallow wells used to dispose of
radioactive or hazardous waste into or above freshwater aquifers, and are now banned by the EPA
except where used as part of groundwater cleanup. For purposes of this letter, Thorn ton presumes
the Project involves Class II injection wells.
It is a Class II injection well that is a typo on my part not EWS (by Eric femsran).
2.. Has EWS sought and/or obtained the requisite permits for the Project?
Class II injection wells are subject to COGCC permitting and location regulations, which
regulations are being substantially modified pursuant to Senate BM 19-181 (COGCC Mission
Change Rulemaking). The Pre -Application Memo requests evidence of State permits. Has
Page 2
April 16,2020
EWS applied for and obtained the requisite COGCC permits? No permits for the Project are
identified on the COGCC website. If this is the case, the COGCC' s review of the Project will
likely be subject to the new, more stringent COGCC regulations. It is unclear that the Project
will meet these COGCC regulations, so as to receive requisite State permits. Additionally,
Class II injection wells require WO LA permits. Thornton has not received notice or
information related to such an application with the County.
EWS will attain all necessary permits from Weld County and COGCC
3. The new COGCC regulations will require numerous additional analyses before the
Project may be approved. Have they occurred? What were the results?
These include an alternative location analysis, seismicity evaluation, and disposal formation
hydrocarbon evaluation.
EWS will attain all necessary permits from Weld County and COGCC
4. What are the sources of produced water (lease and location) to be injected as part of the
Project?
This information is necessary for a COGCC permit and should be shared with the County and
neighbors to the Project,
EWS will attain all necessary permits from Weld County and COGCC and provide information as
required to do so
5. The new COGCC regulations will require an in-depth cumulative impacts analysis
related to risks to public health, safety, welfare, wildlife, and the environment. Has this
occurred? Specifically, EWS will be required to submit narratives related to risks to air., water
(surface and ground), wildlife, noise, dust, traffic, light, ecosystems, waste, and best
management practices employed in relation to each.
EWS will attain all necessary permits from Weld County and COGCC
6. What steps will EWS take to protect its neighbors from nuisances associated with the
Project?
According to the USR Questionnaire, there is no landscaping, screening, road expansion, or
fencing (in addition to existing barbed wire) planned for the Project. But according to the
EWS 12 Site USR19.-00XX Map and US.USR Questionnaire submitted with the application
documents, the Project is planned to have a detention pond, leach field, 5 tanks for salt water
processing, injection facilities and activities, oil recovery, a drum of biocide, a drum of scale
inhibitor, a septic system, 20 passenger vehicle trips per day, and as many 100 truck visits per
day. In addition, it plans to operate 24 hours per day, 365 days per year. The Project raises
serious nuisance concerns related to, among other things, noise, dust, light, air, odor, traffic,
and pests.
The truck traffic that has been requested for the site has since been reduced to 50 trucks a day:
EWS will meet all of the requirements of Weld County for a U K
Page 3
April 16,2 020
7. How will surface and groundwater resources be protected?
There are dozens of water wells, ditches, and canals on the Lands, Thornton' s property, and
other lands within a one-half (1/2) mile of the Lands. Have the owners thereof received the
Notice? Howwill EWS ensure the protection of these valuable water resources?
The surface water from rain and snow will drain to an engineered detention pond that is
approved by the County. EWS cements 300' below the aquifer and alt the way back to surface.
8. How has the County ensured compliance with its code requirements related to the
Project (in addition to WO LA requirements, including those enacted August 5, MB)?
By way of example only, the County Code mandates:
(1)
"Groundwater contamination must be prevented by following state regulations that
require cementation of wells (including injection wells) to prevent commingling of
water, oil and gas into other formations. ";
(2) "E&P Waste, when transported off -site within Colorado for treatment or disposal, shall
be transported to facilities authorized by the COGCC Director or permitted waste
disposal facilities approved to receive E&P Wastes";
(3)
"OG.Policy U. The County should encourage cooperation, coordination and
communication between the surface owner and the mineral owner/operators with respect
to any developments of either the surface or the mineral estates";
(4) '"O .Policy 1.2. Oil and gas support facilities which do not rely on geology for locations
should locate in commercial and industrial areas, when possible, and should be subject
to review in accordance with the appropriate sections of this Code.„;
(5) "O .Policy 2.5. The County should use its regulatory powers, to the extent authorized
by law, to minimize the impacts of oil, gas and other mineral extractions to the land and
land uses and ensure complete restoration of the areas impacted, from start-up through
termination of production.";
(6) "OG.Policy 2.6. Promote the safety of all citizens and structures that are in relatively
close proximity to oil and gas facilities".;
(7) HOG.Policy 2.8. Oil- and gas -drilling activities should be planned to accommodate cun-
ent and future surface subdivision activities to the extent such development can
reasonably be anticipated.";
(8) "O .Policy 2.9 Impose protective measures through available state, County and federal
regulations to ensure that the mineral operator conducts operations in a manner that will
minimize current and future environmental impacts.";
(9) "OaPolicy 2.10. Promote that well sites are reclaimed and closed by techniques which
address that the future use of the property is not impaired because of environmental or
safety problem s[.]";
Page 4
April 16,2020
(10) '"o .Policy 3.1. Support regulations for cementing wells (including injection wells) to
prevent commingling of water, oil and gas into other formations. % and
(11) "OG Pol icy 3.3. The extraction of oil and gas minerals should minimize the impact on the
quality and quantity of ground and surface water."
EWS will attain all necessary permits from Weld County and COGCC
9. Has EWS anticipated additional surface development in the area?
The Lands are less than 2 miles from Pierce and the Project access is on County Road 90,
which is paved and subject to moderate traffic. Traffic will increase as Pierce expands, calling
into question the ability of County Road 9O as currently constructed, to handle 100 additional
semi -truck trips to and from the Lands each day.
The truck traffic that has been requested for the site has since been reduced to 50 trucks a day.
EWS will meet all of the requirements of Weld County for a U R,
10 What types of fluids and chemicals will be injected on the Lands?
New COGCC regulations will require disclosure of this information. It is important for the
County and neighbors to know what they risk exposure to if an accident occurs.
There will be no fluids or chemicals injected on the lands. We use 4 1/2" coated pipe to inject
the fluids to approximately 7,500' and below. Only chemicals we use on our location is
biocide and a scale inhibitor to keep our walls of our pipe free of scale.
11. What formation(s) will the fluids and chemicals be injected into, what are its geographic
boundaries, what is its permeability, and will the fluids and chemicals flow into pore
space owned by the Thornton and other mineral owners?
Thornton and other minerals owners are entitled to compensation if their mineral pore space
is being used by EW S.
The COGCC labels the zone as the "a1 Basin Injection Zone". Usually the top zone would be
the Lyons formation with approximately 5 to 7 more zones under the Lyons. It is my
understanding the mineral owners do not own the pore space they only own what is in the
space, in our case we will test the DJ Basin injection zones for potable water and
hydrocarbons. If there are 0 have never seen any) signs of hydrocarbons we would abort the
use of that zone. As for potable water the economics for bringing water up from that deep
does not make since from a economic stand point.
12. What is the status of the potential pipeline to the Project?
EWS stated in the USR R. u estion nai re that a pipeline may be constructed to the Project in two
years to minimize truck traffic. Who will construct the potential pipeline? Is the construction
still planned given the oil price crash? What is the likelihood of pipeline construction, timing
of the construction, and effect on truck. traffic?
Page 5
April 16,2020
The main reason for the new facility is to accommodate a client that is piping water. The pipeline
will be constructed to the facility at or very close to the time that the facility is expected to open.
EWS has agreed to limit trucks to 50 per day regardless of the completion of the pipeline or not.
13. Is the Project necessary and financially viable at $20/bbl oil? 30/bbl ' Soo/bbl ' Some
experts do not expect oil prices to return to economic levels in 2020 or 2021. Without
economic prices, oil and gas companies will stop drilling new wells, meaning there will not
be a need to dispose of produced water. This must be a concern for a company preparing
to construct a multi -million -dollar injection well facility. How do oil prices affect EWS's
construction timing and plans?
EWS thanks you for the concern but will continue to operate their business as EWS deems
necessary
14. What financial assurance has EWS provided?
The retned.iation, restoration, and reclamation associated with the Project after initial
construction and when it is abandoned, whether next year or in 50 years, will be substantial.
Likewise, clean-up costs associated with any accidental spill would be substantial. The
COGCC's current regulations require de minimis bonds which are not scheduled to be reviewed
and, revised this year. EWS will likely submit a $50,000 injection well bond for the Project, and
maintain its $60,000 blanket plugging bond for its injection wells statewide. The collective COGCC
bonding amounts would not be nearly enough to complete satisfactory remediation, restoration, and
reclamation of the Project. What bonding is the County requiring to ensure its land and water are
protected should an accident occur or should EWS dissolve or file for bankruptcy protection? Is
the County concerned about inheriting clean-up liability?
EWS will attain all necessary permits from Weld County and COGCC to construct the facility.
15. What measures are being taken to ensure public safety related to earthquakes? Many
recent studies show a causal effect between Class II injection wells and earthquakes. The only
reportable earthquakes in Weld County have been associated with such injection wells.
Thornton has concerns about owning land with residences and tenant farmers above the
potential epicenter of an earthquake. In the USR Questionnaire, EWS recognizes there may be
other single-family residences adjacent to the Lands.
There has not been any seismic activity at an EWS owned injection well. We currently have 11
wells in the DJ basin and each location has seismic equipment and are monitored 24/7/365 by an
independent company.
Thornton requests the opportunity to (virtually) meet with EWS and the County Planning Department
to discuss these and other questions and concerns, and preserves its right to object to the Project at
the hearings.
Page 6
April 16,2020
Very ,Truly Yours,
even Louis -Prescott, Es q.
poo 1 Steven@h od1a . cone
cc: Joanne Herlihy, Senior Assistant Attorney, City of Thornton (email only)
Scott T ornbly, Real Estate Manager, City of Thornton (email only)
Kristine Ranslem
From:
Sent:
To:
Subject:
Follow Up Flag:
Flag Status:
Steven Louis -Prescott <poolsteven@hrodlaw.com>
Tuesday, May 19, 2020 1:52 PM
PCTec hs
Public Comment by fly of Thornton in USR20-0007
Follow up
Flagged
Caution: This email originated from outside of Weld County Government Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Steven Louis -Prescott, counsel for the City of Thornton:
What is the status of COGCC permitting for this injection well location? What alternative site locations will be proposed
to the COGCC if an application is not approved prior to November 1, 2020?
When will a neighbor meeting be held, whether by Zoom or otherwise?
How was EWS able to cut the truck traffic in half, when the pipeline is now indefinitely on hold? Can the nearby injection
wells handle additional volume? Do they have requisite permitting to do so? Is EWS cutting its injection volumes in half
as well? Does this impact the project's economics?
BEST
LAW FIRMS
Ft o Il,F.,
Os'rR,N:c vrt Dl\c;iss P.C
Steven Louis -Prescott
Special Counsel
IINVIRE, RODRIGUEZ, OSTRANDER & DINGESS, P C-
3600 S_ Yosemite Street Suite 5D0
Denver, Colorado 80237-1829
(303) 779-0200
ocolsteven@hroIaw,cort
b Please consider the environment before printing this e-mail
2020
CONFIDENTIALITY NOTICE: This electronic mail message and any attachments may be confidential and/or subject to the attorney -client privilege and other
privileges This message is intended only for use by the person(s) or entity named above If you are not the fintcnded recipient(s) or a representative of the
intended recipients), then you are PROHIBITED from disclosing, copying, using, or disseminating any information in this message or its attachments. If you have
received this electronic message in error, please immediately contact Steven Louis -Prescott at (303) 779-0200 or by ernai! at poolsteven hrodlaw corn, and
destroy all electronic and hard copies of this
EXHIBIT
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