d stafford & associates--do not duplicate 1 2008 revisions of the heoa

D Stafford & Associates--Do NOTD Stafford & Associates--Do NOT Duplicate Duplicate

11

2008 Revisions of the 2008 Revisions of the HEOAHEOA


22

Published Annual ReportPublished Annual Report Statement of current policies concerning Statement of current policies concerning

campus law enforcement, including:campus law enforcement, including: The law enforcement authority of campus The law enforcement authority of campus

security personnelsecurity personnel The working relationship of campus security The working relationship of campus security

personnel with State and local law personnel with State and local law enforcement agenciesenforcement agencies• (NEW!) A written memoranda of understanding for (NEW!) A written memoranda of understanding for

the investigation of alleged criminal offensesthe investigation of alleged criminal offenses Policies which encourage accurate and Policies which encourage accurate and

prompt reporting of all crimes to the campus prompt reporting of all crimes to the campus police and the appropriate law enforcement police and the appropriate law enforcement agenciesagencies


33

Additional Hate Crime Data must Additional Hate Crime Data must be Collected and Reported be Collected and Reported

according to category of prejudice according to category of prejudice to include:to include:

Larceny-theftLarceny-theft Simple assaultSimple assault IntimidationIntimidation Destruction, damage, or vandalism of Destruction, damage, or vandalism of

propertyproperty


44

LarcenyLarceny: The unlawful taking, carrying, : The unlawful taking, carrying, leading, or riding away of property from leading, or riding away of property from the possession or constructive possession the possession or constructive possession of another.of another.


55

Simple AssaultSimple Assault: : An unlawful physical An unlawful physical attack by one person upon another where attack by one person upon another where neither the offender displays a weapon, neither the offender displays a weapon, nor the victim suffers obvious severe or nor the victim suffers obvious severe or aggravated bodily injury involving apparent aggravated bodily injury involving apparent broken bones, loss of teeth, possible broken bones, loss of teeth, possible internal injury, severe laceration or loss of internal injury, severe laceration or loss of consciousness.consciousness.


66

IntimidationIntimidation: : To unlawfully place another To unlawfully place another person in reasonable fear of bodily harm person in reasonable fear of bodily harm through the use of threatening words through the use of threatening words and/or other conduct, but without and/or other conduct, but without displaying a weapon or subjecting the displaying a weapon or subjecting the victim to actual physical attack.victim to actual physical attack.


77

Vandalism: Vandalism: To willfully or maliciously To willfully or maliciously destroy, injure, disfigure, or deface any destroy, injure, disfigure, or deface any public or private property, real or personal, public or private property, real or personal, without the consent of the owner or person without the consent of the owner or person having custody or control by cutting, having custody or control by cutting, tearing, breaking, marking, painting, tearing, breaking, marking, painting, drawing, covering with filth, or any other drawing, covering with filth, or any other such means as may be specified by local such means as may be specified by local law.law.


88

Discussions with FBIDiscussions with FBI

““Institution” can be the victim of the crime– Institution” can be the victim of the crime– i.e. graffiti in an elevator not directed i.e. graffiti in an elevator not directed toward a particular person or group.toward a particular person or group.

Investigation—only count it when there is Investigation—only count it when there is evidence that the perpetrator was evidence that the perpetrator was motivated to commit the crime based on motivated to commit the crime based on his/her bias…his/her bias…


99

Response from FBIResponse from FBI Vandalism should be reported as an offense Vandalism should be reported as an offense

whenever the police substantiate that vandalism whenever the police substantiate that vandalism took place. In the case of a vandalism involving took place. In the case of a vandalism involving hate graffiti, that fact alone does not make it a hate graffiti, that fact alone does not make it a hate crime. In Hate Crime Data Collection hate crime. In Hate Crime Data Collection Guidelines it states, "while no single fact may be Guidelines it states, "while no single fact may be conclusive, facts such as the following, conclusive, facts such as the following, particularly when combined, are supportive of a particularly when combined, are supportive of a finding of bias... 3. Bias related drawings, finding of bias... 3. Bias related drawings, markings, symbols, or graffiti were left at the markings, symbols, or graffiti were left at the scene. For example, a swastika was painted on scene. For example, a swastika was painted on the door of a synagogue."the door of a synagogue."


1010

Response from FBIResponse from FBI

Please note that this says supportive, not Please note that this says supportive, not conclusive. Also note that two facts are conclusive. Also note that two facts are present in the example - a swastika, and a present in the example - a swastika, and a Jewish synagogue. Hence, a swastika Jewish synagogue. Hence, a swastika painted on the wall of an elevator in a painted on the wall of an elevator in a college dorm does not necessarily equate college dorm does not necessarily equate to a hate crime. We would need more to a hate crime. We would need more facts, and they may never become known.facts, and they may never become known.


1111

Response from FBIResponse from FBI In our NIBRS system, we train that incidents that In our NIBRS system, we train that incidents that

involve ambiguous facts should be reported as involve ambiguous facts should be reported as an unknown bias. This allows for an an unknown bias. This allows for an investigation to be completed and be conclusive investigation to be completed and be conclusive either way. Should an agency code an incident either way. Should an agency code an incident as an unknown bias and never update with the as an unknown bias and never update with the final determination, our policy is to not count it as final determination, our policy is to not count it as hate crime for inclusion into our annual Hate hate crime for inclusion into our annual Hate Crime publication. In other words, we do not Crime publication. In other words, we do not want to count a hate crime until an agency's want to count a hate crime until an agency's investigation positively concludes that one investigation positively concludes that one occurred.occurred.


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Campus EmergencyCampus Emergency

Response &Response &

Evacuation ProceduresEvacuation Procedures


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A statement of current campus policies A statement of current campus policies regarding immediate emergency response regarding immediate emergency response and evacuation procedures, including the and evacuation procedures, including the use of electronic and cellular use of electronic and cellular communication (if appropriate), which communication (if appropriate), which policies shall include procedures to— policies shall include procedures to—


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Statement of Campus Emergency Statement of Campus Emergency Response & Evacuation Response & Evacuation

ProceduresProceduresImmediatelyImmediately notify the campus community upon notify the campus community upon

the confirmation of a significant emergency orthe confirmation of a significant emergency or

dangerous situation involving an immediate dangerous situation involving an immediate

threat to the health or safety of students or staffthreat to the health or safety of students or staff

occurring on the campus occurring on the campus

(campus, as defined by the Clery Act).(campus, as defined by the Clery Act).


1515

Emergency NotificationEmergency Notification

If there is an immediate threat to the health or If there is an immediate threat to the health or

safety of students or employees occurring on safety of students or employees occurring on

campus:campus:

-follow emergency notification procedures-follow emergency notification procedures

-must provide adequate follow-up -must provide adequate follow-up information to the community as needed. information to the community as needed.


1616

Immediate Notification vs. Timely WarningImmediate Notification vs. Timely Warning Emergency Notification (active shooter, Emergency Notification (active shooter,

tornado) is different than Timely Warning in the tornado) is different than Timely Warning in the Clery Act (crime). Clery Act (crime).

If there is an immediate threat to the health or If there is an immediate threat to the health or safety of students or employees occurring on safety of students or employees occurring on campus:campus: Campuses are not required to issue a timely Campuses are not required to issue a timely

warning based on the same circumstanceswarning based on the same circumstances

VS.


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Include a list of the titles of the person(s) or Include a list of the titles of the person(s) or

organization(s) responsible for carrying out the followingorganization(s) responsible for carrying out the following

actions and provide a description of the process theactions and provide a description of the process the

institution will use to:institution will use to: (i) Confirm that there is a significant emergency or (i) Confirm that there is a significant emergency or

dangerous situation as described in paragraph (g)(1) dangerous situation as described in paragraph (g)(1) of this section;of this section;

(ii) Determine the appropriate segment or segments of (ii) Determine the appropriate segment or segments of the campus community to receive a notification;the campus community to receive a notification;

(iii) Determine the content of the notification; and(iii) Determine the content of the notification; and (iv) Initiate the notification system.(iv) Initiate the notification system.


1818

Immediate NotificationImmediate NotificationA statement that the institution will, withoutA statement that the institution will, without

delay, and taking into account the safety of delay, and taking into account the safety of

the community, determine the content of the the community, determine the content of the

notification and initiate the notification notification and initiate the notification

system, unless issuing a notification will, in system, unless issuing a notification will, in

the professional judgment of responsible the professional judgment of responsible

authorities, compromise efforts to assist a victim or authorities, compromise efforts to assist a victim or

to contain, respond to, or otherwise mitigate theto contain, respond to, or otherwise mitigate the

emergency. emergency.


1919

Disseminating InformationDisseminating Information

Indicate procedures for disseminating emergency information to the larger community.


2020

What is a Test?What is a Test?

Test: Regularly scheduled drills, exercises, and appropriate follow-through activities, designed for assessment and evaluation of emergency plans and capabilities


2121

Documenting TestsDocumenting Tests An institution must document a description

of each exercise (test), including the date, time, and whether it was announced or unannounced.


2222

Policy Statements Regarding TestsPolicy Statements Regarding Tests

PublicizePublicize

emergency response and evacuation emergency response and evacuation procedures in conjunction with at least one procedures in conjunction with at least one test per calendar year. test per calendar year.

procedures to test emergency response and procedures to test emergency response and evacuation procedures on an annual basisevacuation procedures on an annual basis


2323

Annual Fire SafetyAnnual Fire Safety

Reporting on StudentReporting on Student

HousingHousing


2424

Annual Fire Safety Reporting on Annual Fire Safety Reporting on Student HousingStudent Housing

Each eligible institution participating in any Each eligible institution participating in any program under this title program under this title that maintains any that maintains any on-campus student housing facility muston-campus student housing facility must, , on an annual basis, publish a fire safety on an annual basis, publish a fire safety report, which shall contain information with report, which shall contain information with respect to the campus fire safety practices respect to the campus fire safety practices and standards of that institution, includingand standards of that institution, including——


2525

Annual Fire Safety Reporting on Annual Fire Safety Reporting on Student Housing Student Housing

On Campus Housing Facility– tentatively being On Campus Housing Facility– tentatively being defined as it is in the Clery Act.defined as it is in the Clery Act.• Housing built by “Foundations” Housing built by “Foundations”


2626

(1) A description of each on-campus (1) A description of each on-campus student housing facility fire safety student housing facility fire safety system. system.

(2) The number of fire drills held (2) The number of fire drills held during the previous calendar year.during the previous calendar year.


2727

1. Partial Sprinkler System is defined as having sprinklers in the common areas only.2. Full Sprinkler System is defined as having sprinklers in both the common areas and individual rooms.

Foggy Bottom

Residential

Facilities

Fire Alarm Monitoring Done On Site (by UPD)

Partial 1

Sprinkler System

Full 2 Sprinkler System

Smoke Detection

Fire Extinguisher

Devices

Evacuation Plans/

Placards

Number of evacuation (fire)

drills each calendar year

1959 E St. X X X X X 22109 F St. X X X X X 2Aston X X X X X 2Building JJ X X X X X 2City Hall X X X X X 4Crawford X X X X X 4Dakota X X X X X 2FSK X X X X X 2Fulbright X X X X X 2Guthridge X X X X X 2HOVA X X X X X 2International House X X X X X 2


2828

(3) The institution’s policies or rules (3) The institution’s policies or rules on portable electrical appliances, on portable electrical appliances, smoking, and open flames in a smoking, and open flames in a student housing facility. student housing facility.

(4) The institution’s procedures for (4) The institution’s procedures for student housing evacuation in student housing evacuation in case of a fire.case of a fire.


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(5) The policies regarding fire safety (5) The policies regarding fire safety education and training programs education and training programs provided to the students, and provided to the students, and employees. In these policies, the employees. In these policies, the institution must describe the institution must describe the procedures that students and procedures that students and employees should follow in the case employees should follow in the case of a fire.of a fire.


3030

(6) For purposes of including a fire in (6) For purposes of including a fire in the statistics in the annual fire the statistics in the annual fire safety report, a list of the titles of safety report, a list of the titles of each person or organization to each person or organization to which students and employees which students and employees should report that a fire occurred.should report that a fire occurred.

(7) Plans for future improvements in (7) Plans for future improvements in fire safety, if determined necessary fire safety, if determined necessary by the institution. by the institution.


3131

Annual Fire Safety Reporting on Annual Fire Safety Reporting on Student Housing Student Housing

Publish an Annual Fire Safety Report to Publish an Annual Fire Safety Report to include:include: Statistics for each on campus housing facility forStatistics for each on campus housing facility for

(3 most recent calendar years)(3 most recent calendar years)• Number of fires and the causes of each fireNumber of fires and the causes of each fire• Number of persons who received injuries that resulted Number of persons who received injuries that resulted

in treatment at a medical facility (including at an on in treatment at a medical facility (including at an on campus health center) campus health center)

• Number of deaths related to a fireNumber of deaths related to a fire• Value of property damage caused by a fireValue of property damage caused by a fire


3232

Foggy Bottom

Residential

Facilities

Total

Fires in

Each

Building

Fire

Number Date Time Cause of Fire

Number of

Injuries that

Required

Treatment at a

Medical Facility

Number of

Deaths

Related to a

Fire

Value of

Property

Damage

Caused by

Fire Case Number

1959 E St. 2 1 2/5/2009 2040 Stove fire 1 0 187.25 9010411 4/27/2009 1714 Stove fire 0 0 665.23 903988

2109 F St. 0 0 N/A N/A N/A N/A N/A N/A N/AAston 0 0 N/A N/A N/A N/A N/A N/A N/ABuilding JJ 0 0 N/A N/A N/A N/A N/A N/A N/ACity Hall 0 0 N/A N/A N/A N/A N/A N/A N/ACrawford 1 1 5/1/2009 1515 Fire in oven 0 0 500.00 905642Dakota 0 0 N/A N/A N/A N/A N/A N/A N/AFSK 0 0 N/A N/A N/A N/A N/A N/A N/A


3333

DefinitionsDefinitions

Fire: Any instance of open flame or other burning in a place not intended to contain the burning or in an uncontrolled manner.

Fire drill: A supervised practice of a mandatory evacuation of a building for a fire.


3434


Cause of Fire: The factor or factors that Cause of Fire: The factor or factors that give rise to a fire. The causal factor may give rise to a fire. The causal factor may be, but is not limited to, the result of an be, but is not limited to, the result of an intentional or unintentional action, intentional or unintentional action, mechanical failure or act of nature. mechanical failure or act of nature.


3535


Fire-related injury: Any instance in which a person is injured as a result of a fire, including an injury sustained from a natural or accidental cause while involved in fire control, attempting rescue, or escaping from the dangers of the fire. The term person may include students, employees, visitors, firefighters, or any other individuals.


3636


Fire-related death: Any instance in which a person is killed as a result of a fire, including death resulting from a natural or accidental cause while involved in fire control, attempting rescue, or escaping from the dangers of a fire. Dies within 1 year of injuries sustained as a result of the fire.


3737


Fire safety system: Any mechanism or system related to the detection of a fire, the warning resulting from a fire, or the control of a fire. This may include sprinkler systems or other fire extinguishing system, fire detection devices, stand-alone smoke alarms, devices that alert one to the presence of a fire, such as horns, bells, or strobe lights; smoke-control and reduction mechanisms; and fire doors and walls that reduce the spread of a fire.


3838


Value of Property Damage: The estimated value of the loss of the structure and contents, in terms of the cost of replacement in like kind and quantity. This estimate should include contents damaged by fire, and related damages caused by smoke, water, and overhaul; however, it does not include indirect loss, such as business interruption.


3939

Fire Safety Report LogFire Safety Report Log

(1) An institution that maintains on-campus (1) An institution that maintains on-campus student housing facilities must maintain a student housing facilities must maintain a written, easily understood fire log that written, easily understood fire log that records, by the date that the fire was records, by the date that the fire was reported, any fire that occurred in an on-reported, any fire that occurred in an on-campus student housing facility. This log campus student housing facility. This log must include the nature, date, time and must include the nature, date, time and general location of each fire. general location of each fire.


4040


(2) An institution must make an entry or an addition to an entry to the log within two business days of the receipt of the information.


4141


(3) An institution must make the fire log for the most recent 60-day period open to public inspection during normal business hours. The institution must make any portion of the log older than 60 days available within two business days of a request for public inspection.


4242

Annual ReportAnnual Report

An institution must make an annual report to the campus community on the fires recorded in the fire log. This requirement may be satisfied by the annual fire safety report that is published in the Annual Security/Fire Safety Report.


4343

MISSING STUDENTSMISSING STUDENTS


4444

Missing Student ProtocolsMissing Student Protocols

An institution that provides any on-campus An institution that provides any on-campus student housing facility must include a student housing facility must include a statement of policy regarding missing statement of policy regarding missing student notification procedures for student notification procedures for students who reside in on-campus housing students who reside in on-campus housing facilities in its annual security report. This facilities in its annual security report. This statement must -- statement must --


4545

Missing Student Notification Missing Student Notification Procedures, to include:Procedures, to include:

Indicate a list of titles of the persons or Indicate a list of titles of the persons or organizations to which students, organizations to which students, employees, or other individuals should employees, or other individuals should report that a student has been missing for report that a student has been missing for 24 hours; 24 hours;

Think about developing and publishing an Think about developing and publishing an institutional policy to support your policy institutional policy to support your policy statement.statement.


4646


Require that any official missing student Require that any official missing student report must be referred immediately to the report must be referred immediately to the institution’s police or campus security institution’s police or campus security department, or, in the absence of an department, or, in the absence of an institutional police or campus security institutional police or campus security department, to the local law enforcement department, to the local law enforcement agency that has jurisdiction in the area;agency that has jurisdiction in the area;


4747


Contain an option for each student living in an Contain an option for each student living in an on-campus student housing facility to identify a on-campus student housing facility to identify a contact person or persons whom the institution contact person or persons whom the institution shall notify within 24 hours of the determination shall notify within 24 hours of the determination that the student is missing, if the student is that the student is missing, if the student is determined missing by the institutional police or determined missing by the institutional police or campus security department, or the local law campus security department, or the local law enforcement agency. enforcement agency.

You need to develop a system to gather this You need to develop a system to gather this information…information…


4848


Advise students that their contact Advise students that their contact information will be registered information will be registered confidentially, and that this information will confidentially, and that this information will be accessible only to authorized campus be accessible only to authorized campus officials, and that it may not be disclosed, officials, and that it may not be disclosed, except to law enforcement personnel in except to law enforcement personnel in furtherance of a missing person furtherance of a missing person investigation.investigation.


4949


Advise students that if they are under 18 Advise students that if they are under 18 years of age and are not emancipated, the years of age and are not emancipated, the institution must notify a custodial parent or institution must notify a custodial parent or guardian within 24 hours of the guardian within 24 hours of the determination that the student is missing, determination that the student is missing, in addition to notifying any additional in addition to notifying any additional contact person designated by the student; contact person designated by the student; andand


5050


Advise students that, the institution will Advise students that, the institution will notify the local law enforcement agency notify the local law enforcement agency within 24 hours of determination that the within 24 hours of determination that the student is missing, unless the local law student is missing, unless the local law enforcement agency was the entity that enforcement agency was the entity that made the determination that a student is made the determination that a student is missing.missing.


5151


The procedures that the institution must follow The procedures that the institution must follow when a student who resides in an on-campus when a student who resides in an on-campus student housing facility is determined to have student housing facility is determined to have been missing for 24 hours include —-been missing for 24 hours include —-

(i) If the student has designated a contact (i) If the student has designated a contact person, notifying that contact person within 24 person, notifying that contact person within 24 hours;hours;

(ii) If the student is under 18 years of age and is (ii) If the student is under 18 years of age and is not emancipated, notifying the student’s not emancipated, notifying the student’s custodial parent or guardian and any other custodial parent or guardian and any other designated contact person within 24 hours; anddesignated contact person within 24 hours; and


5252


(iii) Regardless of whether the student has (iii) Regardless of whether the student has identified a contact person, is above the identified a contact person, is above the age of 18, or is an emancipated minor, age of 18, or is an emancipated minor, informing the local law enforcement informing the local law enforcement agency that has jurisdiction in the area agency that has jurisdiction in the area that the student is missing within 24 hours.that the student is missing within 24 hours.


5353

Compliance Statement:Compliance Statement:Missing Students Who Reside in On-Campus HousingMissing Students Who Reside in On-Campus Housing

If a member of the University community has reason to believe that a If a member of the University community has reason to believe that a student who resides in on-campus housing is missing, he or she student who resides in on-campus housing is missing, he or she should should immediatelyimmediately notify GWPD at (202) 994-6111. GWPD will notify GWPD at (202) 994-6111. GWPD will generate a missing person report and initiate an investigation. generate a missing person report and initiate an investigation.

After investigating the missing person report, should GWPD determine After investigating the missing person report, should GWPD determine that the student is missing and has been missing for more than 24 that the student is missing and has been missing for more than 24 hours, GW will notify the Metropolitan Police Department (MPD) and hours, GW will notify the Metropolitan Police Department (MPD) and the student’s emergency contact no later than 24 hours after the the student’s emergency contact no later than 24 hours after the student is determined to be missing. If the missing student is under student is determined to be missing. If the missing student is under the age of 18 and is not an emancipated individual, GW will notify the the age of 18 and is not an emancipated individual, GW will notify the student’s parent or legal guardian immediately after GWPD has student’s parent or legal guardian immediately after GWPD has determined that the student has been missing for more than 24 hours. determined that the student has been missing for more than 24 hours.

In addition to registering an emergency contact, students residing in In addition to registering an emergency contact, students residing in on-campus housing have the option to identify confidentially an on-campus housing have the option to identify confidentially an individual to be contacted by GW in the event the student is individual to be contacted by GW in the event the student is determined to be missing for more than 24 hours. If a student has determined to be missing for more than 24 hours. If a student has identified such an individual, GW will notify that individual no later than identified such an individual, GW will notify that individual no later than 24 hours after the student is determined to be missing. Students who 24 hours after the student is determined to be missing. Students who wish to identify a confidential contact can do so through the GW wish to identify a confidential contact can do so through the GW Housing web site. Housing web site.


5454

DISTRIBUTION OF DISTRIBUTION OF REPORTSREPORTS


5555

Distribution of ReportsDistribution of Reports

By October 1By October 1stst– distribute annual – distribute annual security report and, if the security report and, if the institution maintains on-campus institution maintains on-campus housing—distribute the annual fire housing—distribute the annual fire safety report to current students safety report to current students and employeesand employees


5656

Publication of ReportsPublication of Reports

An institution may publish the annual fire safety An institution may publish the annual fire safety report concurrently with the annual security report concurrently with the annual security report only if the title of the report clearly states report only if the title of the report clearly states that it contains the annual security report and that it contains the annual security report and the fire safety report.the fire safety report.

If the institution chooses to publish the annual If the institution chooses to publish the annual fire safety report separately from the annual fire safety report separately from the annual security report, both reports must contain security report, both reports must contain information about how to access the other information about how to access the other report. report.


5757

Distribution of Reports to Current Distribution of Reports to Current Students and EmployeesStudents and Employees

If the institution distributes either report to If the institution distributes either report to current students and employees using an current students and employees using an intranet or internet website, the institution intranet or internet website, the institution must distribute a notice that includes:must distribute a notice that includes: A statement of the report’s availabilityA statement of the report’s availability Exact electronic addressExact electronic address Brief description of contents of report(s)Brief description of contents of report(s)

• (best practice: don’t forget to update your (best practice: don’t forget to update your description to include fire safety)description to include fire safety)

Statement that institution will provide a hard Statement that institution will provide a hard copy upon request. copy upon request.


5858

Distribution of Reports to Prospective Distribution of Reports to Prospective Students and EmployeesStudents and Employees

The institution must provide a notice that The institution must provide a notice that includes:includes: A statement of the report’s availabilityA statement of the report’s availability Brief description of contents of report(s)Brief description of contents of report(s)

• (best practice: don’t forget to update your (best practice: don’t forget to update your description to include fire safety)description to include fire safety)

Statement that institution will provide a hard Statement that institution will provide a hard copy upon request.copy upon request.

If complying via website—must provide exact If complying via website—must provide exact electronic addresselectronic address


5959

Timeline for Compliance?Timeline for Compliance?


6060

D. Stafford & AssociatesD. Stafford & Associates

Dolores A. StaffordDolores A. Stafford

President & CEOPresident & CEO

P.O. Box 1121P.O. Box 1121

Rehoboth Beach, DE 19971Rehoboth Beach, DE 19971

(202) 438-5929(202) 438-5929

[email protected] [email protected]

d stafford & associates--do not duplicate 1 2008 revisions of the heoa

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