I * FOR THE NORTHERN DISTRICT OF GEORGIA /US j...
Transcript of I * FOR THE NORTHERN DISTRICT OF GEORGIA /US j...
FILED IN OPEN coa rIN TH5 UNITED STATES DISTRICT COWRT (j s p (! Ayjajlu
: #
'
I *
'
FOR THE NORTHERN DISTRICT OF GEORGIA /US j lj4
laaus N, 1 cjvrkATIANTA DIVISION g : lt. ; Dgput wk
UNSTED STATES OF AMERICA CRIMINAL INDICTMENT
4:2291*No . : 1 1
ROMIE RQLAND, M.D.AKTHONY LICATACRARLYN CARTERADRIAN SINGLETA'RY
DANTI CUMMINGSANTHONY FERGUSONDANNY THOMPSON
JOSHUA GADD
UNDER SEAL
THE GRAND JURY CHARGES THAT:
INTRODUCTIQN
At all times releyant to this' Indictment:
The Controlled Substances Act governed the manufacture,
distribution, and dispensing of controlled substances in the United
states. The Controlled Substanceà Act defines a ''controlled
substancel' as a drug or other substance that was included within
one of f ive ''schedules'' - Schedule I , 11 p 111, IV, or V - of Subchapter
1, Part B of the Act. 21 U.S.C. 5 802(6).
Various prescription drugs are defined as ccntrolled
substances under the Act. Drugs are placed into these schedules based
on their potential for abuse, aëong other things. Schedule I drugs
have a high potential for abuse, have no currently accepted medical
use, and lack accepted safe use. 21 U.S.C. 5 812(b)(1). Schedule
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 1 of 20
11 dyugs have a currently accepted medical use with severe
restrictions and have a high potential for abuse that can .lead to
severe psychological or physical dependence. 21 U.S.C. j 8l2(b) (2).
Schedule I5I drugs have a currently accepted medical use and have
a high potential för abuse, less than the drugs listed in Schedule
11 . 21 U .' S . C . j 8l2 (b) Schédule IV drugs have a currently accepted
medical 4se and have a low potential for abuse.relative to the drugs
in schedule 111. 21 U.S.C. j 8l2(b) (4).
3. Oxycodone, an opiate, a Schedule 11 controlled
substance. 21 C.F.R. 5 l308.12(b) (1). Oxycodone is Sold generically,
and the brand names Oxycontin, Roxicodone, and Percocet are
prescription drugs that contain Oxycodone. Percocet contains a
miyture of Oxycodone and Acetaminophen. Morphine Sulfate, a
painkilier, is a Schedule 11 controlled substance. 21 C.F.R. 5
1308.12 (b)(l). Morphine is sold generieally or under the brand name
MS Contin.
21,
controlled substances listed in Schedules 111, and IV can be
dispensed or distributed only by prescriptions by a licensed
practitioner. The Drug Enforcement Administration (DEA) as
authorized by the Act, issues registration numbers to qualifying
doctors and pharmacists that allow them to dispense or distribute
Schedule II, 111, and IV controlled substances. Accordingly, the
21, United States Code? Section 822(b), and TitleTitle
code of Federal Regulations, Section 290.1, provide that the
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 2 of 20
controlled substances described above can be dispensed only pursuant
to a valid prescription from a physician authorized to prescribe
controlled substances by the jurisdiction in which he is licensed
to practice his profession, and authorized by the DEA to prescribe
controllqd substances. C.F.R. 5 1306.03.
Title 21, Code of Federal Regulations, Section 1306.04,
provides that in order for a prescription for a controlled substance
to be valid, ''must be issued for a legitimate medical purpose
by an individual practitioner acting in the usual course of his
professional practice/' This section further provides that;
The responsibility for the proper prescribing anddispensing of controlled substances is upon theprescribing practitioner . . . An order purporting to
be a prescription issued not in the usual course ofprofessional treatmept or in legitimate and authorizedresearch is not a prescription within the meaning and
intent of section 309 of the Act (21 U.S.C. 5 829) andthe person knowingly filling such a purportedprescription, as well as the person issuing it, shall be
subject to the penalties provided for violations of theprovisions 6f law relating to controlled substances.
21 C.F.R. 1 1306.04.
An order purporting to be a prescriptipn that was issued
outside the ûsual course of professional treatment is not a
prescription within the meaning of the Controlled Sub/tances Act,
and the person who issues the prescription violates section 841(a)(l)
of Title of the United àtates Code.
CHIRON MEDICAL, ZXPRESS HEALTH, ATLANTA PAIN MANAGEMENT,
and KEY PAIN (hereinafter referred to collectively as the Mclinicar')
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 3 of 20
were ostensible pain clinics operating around Atlanta, Georgia.
8. ROMIE ROLAND, M.D. Was a doctor at the Clinics. ROLAND
was registered with the DEA under the provisions of the Controlled
substances Act as a practitioner and was assigned a DEA rqgistration
number that authorized him to write prescriptions for Schedule II,
and V controlled substances .
ANTHONY LICATA was the principal owner/operator of the
Clinics, and was directly involved in their operations. CHARLYN
CARTER was the Office Mlnager, which capacity she' ovevsaw the
Clinics' day-to-day operations, including scheduling appointments,
patient in-take, billing, and monitoring the doçtors/ work
activities. ADRIAN SINGLETARY was a security guard at the Clinics,
and he would also assist with patient triage. ANTHONY LICATA,
CHARLYN CARTER, and ADRIAN SINGLETARY? were not medical doctors
authorized to practice medicine.
10. DANTE CUMMINGS, ANTHONY FERGUSONZ DANNY THOMPSON, and
JOSHUA GADD ''sponsored'' a number of different patients' visits to
the clinics. Specifically, they would contact the Clinics and
schedule visits for multiple patients. These defendants would
supervise the visits, financing the costs of 50th seeing the doctor
as well as filling the prescriptions. The goal of this sponsorship
was to procure multiple prescriptions for ccntrolled substances;
these prescriptions were then filled, apd the narcotics sold for
a profit.
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 4 of 20
COUNT ONE
(2l U.S.C. j 846)(Conspiracy)
The allegations contained in paragraphs l through 10 are
hereby repeated, realleged? and incorporated by reference as if fully
set forth herein .
12. Beginning in or about February 2013 and continuing
until the present, within the Northern District 6f Georgia, the
defendants, ROMXE ROLAND? M.D.C ANTHONY LICATA, CHARLYN CARTER,
ADRIAN SINGLETARY , DANTE CUMMINGS , ANTHONY FERGUSON , DANNY THOMPSON ,
and JOSHUA GADD did knowingly combine,
and have a tacit understanding with
conspire, confederate, agree,
others known and unknown to the
Grand Jury, to knowingly and
outside the usual course of
intentionally distribute and dispense?
professionll medical practice and for
no legitimate medical.purpose, mixtures and substances containing
detectable amounts of various controlled substances, including, but
not limited to, Oxycodone (Schedule 11), Oxycodone and Acetamin6phen
(schedule 11), Morphins (Schedule 11), in violation of Tible 21,
ited states cpde, section 841(a)(1), (b)(l)(C) and tb) (2).Un
Purposes, Ways, Manner and Means of the Conspiracy
The purposes of the conspiracy included, but were not
limited to; the following:
To prescribe as many Oxycpdone, Oxycodone and
Acetaminophen, and Morphine pills, among other drugs, as possible,
irrespective of legitimate medical purpoée for presqribing them,
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 5 of 20
to generate profits. To accomplish this purpose, the defeniant, ROMIE
ROLAND, M .D., with the knowing involvement and participation of
ANTHONY LICATA , CHARLYN CARTER , and ADRIAN SINGLETARY , would
prescribe excessive amounts of Oxycodone, Oxycodone and
Acetaminophen, and Morphine, for other than a legitimate medical
purpose and not in the usual course of professional treatment, thus
causing, aiding, abetting, and facilitating the misuse, abuse, and
further distribution of the controlled substances.
It was part of the conspiracy that ROMIE ROLAND, M.D . would
prescribe Schedule 11 controlled substances, such as Oxycodone,
Oxycodone and Acetaminophen, and Morphine, at a patient's first
appointment without conducting a thorough medical examination, which
thus did not result in a legitimate diagnosis justifying the
prescriptionp of the controlled substances. Further, the defendant,
ROLAND, prescribed these drugs in amounts and dosage combinations
that exceeded that required for legitimate medical treàtment and
aroused suspicion from pharmacists. At later follow-up visits, the
defendant, ROLLND, wrote additional prescriptions with no or limited
further medical evaluation that was required to continue writing
préscriptions at the dosages indicated on the prescriptions. Further,
ROLAND prescribed i'throwaway'' prescriptions - prescriptions for
non-contrdlled substances that he knew would not always be filled
by patients - and developed other practices and procedures to avoid
being detected and targeted by law enforcement.
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 6 of 20
The défendants, ROMIE ROLAND, M.D., ANTHO;Y LICATA,
LYN CARTER, and ADRYAN SJNGLETARY, continued prescribingCHAR
controlled substanceà even after hearing patients talk about
diversion, ignoring obvious indications of misuse. The Clipics
serviced an inordinate amount of people, most having traveled from
out-of-state. LICATA nade it a practice of the Clinics to charge
out-of-state patients more for a visit than patients from Georgia.
It was futther part of the conspiracy that the defendants,
DANTE CUMMINGS, ANTHONY FERGUSQN, DANNY THOMPSON, and JOSHUA GADD,
w6uld sponsor other patients' visits to the Clinics.. CUMMINGS,
THOMPSON, FERGUSON, and GADD Would contact the Clinics, arrange for
multiple patients to be seen by the physician, apd often times pay
for each patient's visit. After these patients obtained
prescriptions for controlled substancqs, the prescripfions were
filled at pharmacies around the nation, and the narcotics were
distributed for a profit.
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 7 of 20
COUNT TWO
(21 U.S.C. 5 856)(Maint:ining Drug-lnvolved Premises)
The allegations contained in paragraphs 1 through 10 are
hereby repeated, realleged, and incorporated by reference as if fully
set forth herein.
Beginning on a date unknown, but at least by May 24, 2013,
and continuing until on or about December 3o, 2013, within the
Northeçn District of Georgia, the defendants, ROMIE ROLAND, M.D.,
ANTHONY LICATA, and CHARLYN CARTER, did knowingly and intentionally
open, lease, rent, use and maintain a place, namely a business
location operating as BExpress Health,'' located at 3149 E. Shadowlawn
Drive, in Atlanta (Fulton Couhty), Georgia? for the purpose of
distributing Schedule
of professional medical practice and for other than a legitimate
controlled substances? outside the course
medical purpose,
Sçctions 84l(a) (1) and (b) (i) (C), and 841(b) (2), all in violation.
'
of Title 2l, United States Code, Section 856(a) (1), and Title 18,
United Statés Code, Section
violation of Title United states Code,
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 8 of 20
COUNTS THREE - SIX
(21 U.S.C. j 841)(Distribution of a Controlled Substance)
19. The allegations contained in paragraphs 1 through 10 are
hereby repeated, realleged, and incorporated by reflrence as if fufly
set forth herein .
20. On or about October 2l, 2013, in the Northern District
of Georgia, the defendant, ROMIE ROLAND, M.D., a physician authorized
to prescribe controlled spbstances, did knowingly and intentionally
distribute guantities of Schedule 11 controlled subgtances, by
prescribing outside the scope of professional practice and not for
a legitimate medical purpose, the mixturqs and substances described
and designated below:
COUNT PATIENT DATE Rx PRESCRIBED
THREE Patient L.C. October 2l? 2013 56 MS Contin 30mg90 Roxicodone 30mg
FOUR Patient K.S. October 21, 2013 12O Percocet 10/325mg
FIVE Patient J.M. October 21, 2013 120 Percocet 10/32Smg
sIX Patient R.B. October 2l, 2013 12O Percocet 10/325mg
all in violation of Title 21, ' United States Code? Sections 84l (a) ( 1) ,
( b ) ( l ) ( C ) and (b) (2).
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 9 of 20
COUNTS SEVEN - EIGHT
(21 U.S.C. â 841)(Distribution of a Controlled Substance)
21. The allegations contained in paragraphs through 10 are
realleged, and incorporated by reference as if fullyhereby repeated,
set forth herein.
22. On or about November 18, 2013, in
of Georgia , the def endant , ROMIE ROT,AND , M .D . ;
the Northern District
a physician authorized
to prescribe controlled substances, did knowingly ànd intentionally
distribute quantities of Schedule 11 controlled substances, by
prescribing outside the scope of professional practice and not for
a legitimate medical purpose, the mixtures and substances described
and designated below:
COUNT PATIENT DATE DRUGS .
SEVEN Patient L.C. November 18, 2013 120 Oxycodone 30mg
EIGHT Patient J.M. November l8, 2013 90 Oxycodone 15mg
United States Code,sections 841(a) (1),
( b ) ( l ) ( C ) and (b) ( 2 ) .
10
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 10 of 20
COUNTS NINE - ELEVEN
(2l U.S.C. 5 841)(Distribution of a Controlled Substance)
The allegations contained in paragraphs 1 through 10 are
hereby repeated, realleged, and incorporated by reference as if fully
set .forth herein .
On or about December 18, 2013, in the Northern Diytrict
of Georgia, the defendant, ROMIE ROLAND, M.D., a physician authorized
to prescribe controlled substances, did knowingly and intentionally
distribute quantities of schedule 11 controlled substances, by
prescribing outside the scope of professional practiee and not for
a legitimate medical purpose, the mixtures and substances desctibed
and designated below:
' COUNT PATIENT DATE DRUGS
NINE Patient L.C. December 18, 2013 130 Oxycodone 30mg
.. '
TEN Patient R.B. December 18, 2013 130 Percocet 10/325mg
ELEVEN Patient K.S. December l8, 2013 l30 Percoeet 10/325mg
all in violation of Title 21, United States Code, Sections 84l(a) (1),
( 1) ( C) and (>) ( 2 ) .
11
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 11 of 20
COUNTS TWELVE - FOURTEEN
(21 U.S.C. 5 841)(Distribution of a Controlled Substance)
The allegations contained in paragraphs through 7 are
hereby repeated, realleged, and incorporated by reference as if fully
set forth herein.
On or about January 27, 2014, in the Ncrthern District
of Georgia, the defendant, ROMIE ROLAND, M,D., a physician authorized
to prescribe controlled substances, did knowingly and intentionally
distribute quantities of Schedule 11 controlled substances, by
jn - 'prescri ing outside the scope of prof essional practice and not f or
a legitimate medical purpose, the mixtures and substancés described
d designated below:an
couuT PATIENT bATE DRuGs
TWELVE Patient January 2014 l30 Oxycodone 30mg
THIRTEEN Patient R.B. Janùary 27, 2014 13Q Percocet 10/325mg
FOURTEEN Patient K.S. January 27, 2014 l30 Percocet 10/325mg
all in violation of Title 21 , United States Code , Sections 84l (a) (l) ,
(b) ( 1) ( C) and (b) (2 ) .
12
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 12 of 20
COUNTS FIFTEEN - SEVENTEEN
(2l U.S.C. j 841)(Distribution of a Controlled Substance)
The allegations contained ih paragraphs 1 through 10 are
hereby repeated, realleged,
set forth herein.
and incorporated by reference as if fully
28. On or about February 26, 2014, in the Northern District
of Georgia, the defendant, ROMIE ROLAND, M.D ., a physician authorized
to prescribe controlled substances, did knowingly and intentionally
distribute quantities of Schedule 11 controlled substances, by
prescribing outside the scope of professional practice and not for
a legitimate medical purpose, çhe mixtures and substances described
and designated below:
COUNT PATIENT DATE DRUGS
FIFTEEN Patient L.C. February 26, 2014 l30 Oxycodone 30mg
DIXTEEN Patient R.B. February 26, 2014 l20 Oxycodone 15mg
SEVENTEEN Patient K .S, February 26, 2014 90 Oxycodone 15mg
. '
a1l in violation of Title 21, United States Code, Sections 84l(a) (1),
(b) ( l ) ( C) and (b) ( 2 ) .
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 13 of 20
COUNTS EIGHTEEN ANn NINETEEN
(21 U.S.C. 5 841)(Distribution of a Cohtrblled Subbtance)
The allegations contained in paragraphs 1 through 10 are
hereby repeated, realleged, and incorporated by reference as if fully
set forth herein.
30. On or about March 26, 2014, in the Northern District of
Georgia, the defendant, ROMIE ROLAND, M .D., a physician authorized
to prescribe controlled substances, did knowingly and intentionally
distribute quantities of schedule 11 controlled substances, by
prescribing outside the scope of professional practice and not for
a legitimate medical purpose, the mixtures and substances described
and designated below:
COUNT PATIENT DATE DRUGS
, '
EIGHTEEN Patient L.C. March 26? 2014 130 Oxycodone 30ëg
NINETEZN Patient N.C, March 26, 2014 l20 Percocet 10/325m9
a1l in violation of Title 21 ,United States Code, Sectionj 841(a) (1)
(b) ( l ) ( C) ' and (b ) ( 2 )
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 14 of 20
COUNT TWENTY AHn TWENTY ONE
(21 U.S.C. j 841)(Distribution of a Controlled Substance)
31. The allegations contained in paragraphs 1 through 10 are
hereby repeated, realleged, and incorporated by reference as if fully
set forth herein .
32. On qr about April 23, 2014, the Northern District of
Georgia, the defendant, ROMIE ROLAND, M.D.? a physician authorized
to prescribe controlled substances, did knowingly and intentionally
distribute quantities of Schedule 11 controlled substances,
prescribing outside the scope of professional practice and not for
a legitimate medical purpose, the mixtures and substances described
and designated below;
COUNT PATIENT DATE DRUGS
TWENTY Patient L.C. April 23, 2014 130 Oxycodone 30mg
130 Oxycqdone 30mg
TWENTY ONE Patient N.C. April 23, 2014 120 Percocet 10/325mg 'l20 Percocet 10/325mg
al1 in violation ofTitle 21, United States Code, Sections 841(a)(1),
(b) ( 1) (C) and (b) ( 2 )
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 15 of 20
COUNT TWENTY TWO
(18 U.S.C. 5 1956)(Money Laundering Conspiracy)
Parag/aphs through 10 are realleged ànd incorporated
into Count Nine of this Indiçtment.
34. Beginning on a dlte unknown to the Grand Jury, but at least
by February 2013, and continuing pp to and including August 5, 2014,
in the Northern District of Georgia, and elsewhere, the defendants,
ROMIE ROLAND , M .D ., ANTHONY LICATA , CHARLYN CARTER, and DANTE
CUMMINGS, did unlawfully, willfully, and knowingly combine?
conspire, confederate, agree and have a tacit understanding with
each other and other persons known and unknown to the Grand Jury,
to commit violations of the law of the United States of America under
Title 18, United States Code, Section 1956, as follows:
(a) To conduct and atteppt to conduct financial transactions
affecting interstate and foreign commerce, which transactions
involved the proceeds of specified unlawful ac>ivity, that is, the
felonious selling and dealing in controlled substances, and knowing
that the property involved in such financial transactions represented
the proceeds of some form of unlawful activityr with the intent to
promote the carrying on of such specified unlawful activity, in
violation of Title 18, United States Code, Section 1956(a) (1), a1l
in violation of Title 18, United States Code, Section 1956(h).
16
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 16 of 20
Purposes, Ways, Manner and Means of the Conspiracy
35. The purposes of the money laundering conspiracy was to
acquire monies f rom the illegal prescription of controlled substances
to promote the continued operation of the Clinics' narcotics
distribution.
It was part of the conspiracy that the :ef endants and their
co-conspirators did distribute quantities of Schedule 11 controlled,
e
substances, by prescribing outside the scope of professional practice
and not for a legitimate medical purpose, controlled substances,
namely Oxycodone, Oxycodone and Acetaminophen, and Morphine.
The defendants generated significant proceeds from
illegally prescribing copious amounts of controlled substances for
no legitimate medical purpose.
38. The defendants and their co-conspirators uéed these
proceeds to operate the Clinics, to fund the salaries of the Clinics'
employees, purchase equipment used to issue presdriptions for
controlled substances, and to fund future trips for sponsored
patients to obtain prescriptions and, eventually, more controlled
substances.
17
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 17 of 20
FORFEITURE PROVISION
Upon conviction of any of the controlled substance offenses
alleged in Counts One through Twenty One of this Indictment, the
defendants, ROMIE ROLAND, M .D ., ANTHONY LICATA ? CHARLYN CARTER,
ADRIAN SINGLETARY, DANTE CUMMINGS, ANTHONY FERGUSON , DANNY THOMPSON,
and JOSHUA GADD, shall forfeit to the United States? pursuant to
Title 21, United States Code, Section 853(a), all property
constituting, or derived from, proceèds obtained, directly or
indirectly, aa a result of the said violations and a11 property used
or intended to be used, in any manner or part, to commit, or to
facilitate the commission of the said violatiops, including, bvt
not limited to, the following:
MONEY JUDGMENT; A sum of money in United States currency
equal to the amount of proceeds the defendants obtained as a result
of the offenses for which the defendant is conyicted. If more than
one defendant is convicted of an offense, the dekendants so convicted,
'
are jointly and severally liable for the amount involved in such
offense .
Additionally, upon conviction of one or more of the money
laundering offenées alleged in Count Twenty Two of this Indictment,
in violation of Title l8, United States Code, Section 1956, the
defendants, ROMIR ROLAND, M.D., ANTHONY LICATA, CHARLYN CARTER, and
18
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 18 of 20
DANTE CUMMINGS, shall forfeit to the United States any and all
property, real or personal, involved in such offénses and all property
traceable to such offenses, pursuant to Title 18, United States Code,
Section 982(1) (1), including but not limited to the fcllowing:
MONEY JUDGMENT: A sum of money in United States currency
equal to the total value of property involved in each offense for
which the defendants are liable. If more than one defendant is
convicted of an offense, the defendants so convicted are jointly
and severally liable for the amount involved in such offense.
If, as a result of any act or omission of the defehdant, any
property subject to forfeiture:
(1) cannot be located upon the exercise of due diligence;
has been transferred or sold to,
a third person;
or deposited with,
has been placed beyond the jurisdiction of the Court;
(4)'has been substantially diminished in value; or
(5) has been commingled with other property which cannot
be subdivided without difficulty ;
19
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 19 of 20
the United States intends, pursuant to Title 21, United States Code,
Section 853 (p) and Title l8, United States Code, Section 982(b)z
eek forfeiture of any other property of said defendant upto s
the value of the f orf eitable property or seek a m ney judgment against
said defendant for any amouht that would constitute the proceeds
of such violation.
FOR ERSON
SALLY QUILLIAN YATESUNITED STATES ATTORNEY
(C. OCK BROCKINGTONASSISTANT UNITED STATES ATTORNEY
6O0 U .S . Courthouse75 Spring Street SWAtlanta, Georgia 30303
(404) 581-6198Georgia Bar No. 775084
20
Case 0:14-mj-06285-BSS Document 1 Entered on FLSD Docket 08/07/2014 Page 20 of 20