UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT

PUBLIC CITIZEN, INC.

Appellee,

v.

UNITED STATES DEPARTMENT OF
HEALTH AND HUMAN SERVICES, et al.

Appellants.

No. 01-5294

CONSENT MOTION OF AMERICAN HOSPITAL ASSOCIATION,
AMERICAN MEDICAL ASSOCIATION AND FEDERATION OF
AMERICAN HOSPITALS FOR LEAVE TO FILE MEMORANDUM
AMICI CURIAE IN SUPPORT OF DEFENDANTS
AND THEIR MOTION FOR STAY PENDING APPEAL

Amici curiae hereby move for the entry of an Order allowing them to file a Memorandum Amici Curiae in Support of the Motion for Stay Pending Appeal of defendants United States Department of Health and Human Services and the Centers for Medicare and Medicaid Services ("CMS," formerly known as the Health Care Financing Administration) in the above-captioned case. The organizations joining in this motion are listed in the Statement of Interest section of the proposed Memorandum. Counsel for all parties have consented to the filing of this Memorandum. Finally, a copy of the proposed Memorandum is annexed hereto and made a part hereof as Exhibit A to this motion.

As set forth in the accompanying Memorandum of Points and Authorities, the motion should be granted because amici have a sufficient interest in the case, and because the proposed Memorandum is likely to assist the Court in resolving the fundamental issues at the core of this dispute.

Dated: August 29, 2001

 

Respectfully submitted,

HOGAN & HARTSON

By:
Darrel J. Grinstead, D.C. Bar No. 064022
Jeffrey Pariser, D.C. Bar # 462085
HOGAN & HARTSON L.L.P.
555 13th Street, N.W.
Washington, DC 20004
(202) 637-5600

Counsel for Amici Curiae

 



UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT

PUBLIC CITIZEN, INC.

Appellee,

v.

UNITED STATES DEPARTMENT OF
HEALTH AND HUMAN SERVICES, et al.

Appellants.

No. 01-5294

ORDER GRANTING MOTION FOR LEAVE TO FILE
MEMORANDUM AMICI CURIAE IN SUPPORT OF
DEFENDANTS' MOTION FOR STAY PENDING APPEAL

This matter came before the Court upon the Motion of American Hospital Association, American Medical Association and Federation of American Hospitals for Leave to File Memorandum Amici Curiae in Support of Defendants' Motion for Stay Pending Appeal filed August 24, 2001. Upon consideration of the motion, and the accompanying Memorandum of Points and Authorities, it is hereby ORDERED that the Motion for Leave to File a Memorandum in Support of Defendants' Motion for Stay Pending Appeal is GRANTED.

Dated this _______ day of _____________, 1999.

_________________________________
United States Circuit Judge

Copies to:

Roscoe C. Howard, Jr.
R. Craig Lawrence
G. Michael Harvey
United States Attorneys
Judiciary Center Building
555 Fourth Street, N.W.
Washington, DC 20001

Attorneys for Defendant


Alison M. Zieve
Public Citizen Litigation Group
1600 20th Street, N.W.
Washington, DC 20009

Robert W. Goodson
Carr Goodson
1667 K Street, N.W.
Suite 1100
Washington, DC 20006

Thomas W. Kirby
Jason P. Cronic
Wiley, Rein & Fielding LLP
1776 K Street, N.W.
Washington, DC 20006

Attorneys for Plaintiff


Darrel J. Grinstead
Jeffrey Pariser
HOGAN & HARTSON L.L.P.
555 13th Street, N.W.
Washington, DC 20004

Counsel for Amici Curiae



CERTIFICATE OF SERVICE

I certify that copies of the foregoing Motion of American Hospital Association, American Medical Association and Federation of American Hospitals Society for Leave to File Memorandum Amici Curiae in Support of Defendants Motion for Stay Pending Appeal was served by hand this 29th day of August, 2001 on the following counsel:

 

Roscoe C. Howard, Jr.
R. Craig Lawrence
G. Michael Harvey
United States Attorneys
Judiciary Center Building
555 Fourth Street, N.W.
Washington, DC 20001

Attorneys for Defendant

Alison M. Zieve
Public Citizen Litigation Group
1600 20th Street, N.W.
Washington, DC 20009

Robert W. Goodson
Carr Goodson
1667 K Street, N.W., Suite 1100
Washington, DC 20006

Thomas W. Kirby
Jason P. Cronic
Wiley, Rein & Fielding LLP
1776 K Street, N.W.
Washington, DC 20006

Attorneys for Plaintiff

________________________
Jeffrey Pariser

 



UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT

PUBLIC CITIZEN, INC.

Appellee,

v.

UNITED STATES DEPARTMENT OF
HEALTH AND HUMAN SERVICES, et al.

Appellants.

No. 01-5294

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
CONSENT MOTION OF AMERICAN HOSPITAL ASSOCIATION,
AMERICAN MEDICAL ASSOCIATION AND FEDERATION OF
AMERICAN HOSPITALS FOR LEAVE TO FILE MEMORANDUM
AMICI CURIAE IN SUPPORT OF DEFENDANTS
AND THEIR MOTION FOR STAY PENDING APPEAL

Amici curiae hereby move for leave to file the accompanying Memorandum in Support of Defendants' Motion for Stay Pending Appeal. Counsel for amici curiae sought the consent of the parties prior to the filing of this motion, and all parties consented to amici curiae filing the attached Memorandum (attached as Exhibit A to the accompanying Motion).

The instant motion for leave to file as amici should be granted because the amici have "a familiarity and knowledge of the issues raised . . . that could aid in the resolution of this case." Ellsworth Assocs., Inc. v. United States, 917 F. Supp. 841, 846 (D.D.C. 1996). As detailed in the Statement of Interest in the proposed Memorandum, amicus American Hospital Association ("AHA") is the largest national membership organization for hospitals in the United States. The AHA's mission is to promote high quality health care and health services through leadership and assistance to hospitals in meeting the health care needs of their communities. The AHA's membership includes approximately 5,000 hospitals, health systems, networks, and other providers of care, including hospitals and health systems throughout the United States.

Amicus American Medical Association ("AMA"), an Illinois non-profit corporation, is an association of approximately 275,000 physicians who practice throughout the United States. The AMA was founded in 1847 to promote the science and art of medicine and the betterment of public health, and these still remain its core purposes. Its members practice in all fields of medical specialization, and it is the largest medical society in the United States.

Amicus Federation of American Hospitals ("FAH") is a national trade association representing some 1,700 privately-owned and managed community hospitals and health systems providing health care across the acute and post-acute spectrum. FAH member hospitals provide care for patients in both urban and rural America. FAH's principal objective is to foster the public good through the creation and delivery of quality health care for all people. FAH's members include corporations or other organizations involved in the delivery of health care services that share a common philosophy of providing high quality, affordable health care, through free enterprise.

AHA, AMA, and FAH members have long been involved in peer review activities and in the delivery of health care services to patients on a daily basis. Amici are therefore in a unique position to speak to the important public interest served by maintaining the confidentiality of medical review proceedings. Amici contend both that the District Court's interpretation of federal law was incorrect, and that the Court's ruling, which effectively abrogates the peer-review privilege, will have an adverse effect on the interests Medicare and Medicaid beneficiaries, as well as on all citizens in the United States in the delivery of safe, quality health care. Amici respectfully maintain that the harm from the release of the peer-review records sought by plaintiffs would be irreparable and, in the event that the District Court's decision is overturned, cannot be undone. Conversely, the brief stay requested by defendants would prohibit the release of peer review records only until this Court can rule on the merits of this appeal, thus preventing the irreparable harm that would result if the Court were to deny the stay - allowing peer-review records to be released - and then to reverse the decision below. Moreover, if this Court were to affirm the District Court's ruling, the brief delay in the release of peer-review records occasioned by the stay would not prejudice plaintiff.

The interest of amici in this case is thus to protect the benefits of peer review for the general public. The participation of amici in developing peer review and their work in obtaining recognition for the importance of peer-review privilege, and the participation of the members of these organizations in actual peer review, give amici a unique breadth of experience and extensive specific knowledge on the questions at issue in defendants' motion.

Undersigned counsel therefore submit that the Court would benefit from the arguments of non-party amici. AHA, AMA, and FAH have particular expertise in the subject matter that is at the heart of this case, and are involved with peer-review privilege issues on a practical basis. Accordingly, they can provide an important perspective in these procedures, which will be of great assistance to the Court in its resolution of the technical issues relating to peer-review privilege which are an essential aspect of this case.

For these reasons, the proposed Memorandum fulfills the "classic role of [an] amicus curiae" - "assisting in a case of general public interest, supplementing the efforts of counsel," and drawing the Court's attention to matters that otherwise would not be considered. Miller-Wohl Co. v. Commissioner of Labor and Indus., 694 F.2d 203, 204 (9th Cir. 1982). The proposed Memorandum addresses only the factual issues regarding peer-review privilege and the consequences that could arise from the District Court's decision if it is not stayed. Nonetheless, the proposed Memorandum provides valuable and useful insights concerning those issues to assist the Court in the resolution of defendants' motion for stay pending appeal.



CONCLUSION

For the foregoing reasons, the Motion for Leave to File Memorandum Amici Curiae should be granted.


Dated: August 29, 2001

 

Respectfully submitted,

HOGAN & HARTSON L.L.P.


By:
Darrel J. Grinstead (D.C. Bar No. 064022)
Jeffrey Pariser (D.C. Bar No. 462085)
HOGAN & Hartson L.L.P.
555 13th Street, N.W.
Washington, DC 20004
(202) 637-5600

Counsel for Amici Curiae

 



CERTIFICATE OF SERVICE

I certify that copies of the foregoing Memorandum of Points and Authorities in Support of Consent Motion of American Hospital Association, American Medical Association and Federation of American Hospitals Society for Leave to File Memorandum Amici Curiae in Support of Defendants Motion for Stay Pending Appeal was served by hand this 29th day of August, 2001 on the following counsel:

 

Roscoe C. Howard, Jr.
R. Craig Lawrence
G. Michael Harvey
United States Attorneys
Judiciary Center Building
555 Fourth Street, N.W.
Washington, DC 20001

Attorneys for Defendant

Alison M. Zieve
Public Citizen Litigation Group
1600 20th Street, N.W.
Washington, DC 20009

Robert W. Goodson
Carr Goodson
1667 K Street, N.W., Suite 1100
Washington, DC 20006

Thomas W. Kirby
Jason P. Cronic
Wiley, Rein & Fielding LLP
1776 K Street, N.W.
Washington, DC 20006

Attorneys for Plaintiff


________________________
Jeffrey Pariser

 



UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT

PUBLIC CITIZEN, INC.

Appellee,

v.

UNITED STATES DEPARTMENT OF
HEALTH AND HUMAN SERVICES, et al.

Appellants.

No. 01-5294

RESPONSE OF AMICI CURIAE AMERICAN HOSPITAL
ASSOCIATION, AMERICAN MEDICAL ASSOCIATION AND
FEDERATION OF AMERICAN HOSPITALS IN SUPPORT
OF DEFENDANTS' MOTION FOR STAY PENDING APPEAL


Introduction

Amici curiae American Hospital Association ("AHA"), American Medical Association ("AMA"), and Federation of American Hospitals ("FAH") respectfully submit this Response in support of Defendants' Motion for Stay Pending Appeal. Defendants' motion seeks a brief delay of any release of peer-review documents in order to allow this Court first to decide whether the District Court erred in holding that such documents must be disclosed. Amici agree that the stay is warranted because release of peer-review documents will have an adverse effect on the ability to monitor and improve the delivery of care to patients throughout the U.S.

AHA, AMA, and FAH members are involved in the peer review process on a daily basis. Based on that extensive experience, amici submit that peer review is absolutely essential to ensuring and improving quality health care for patients. Peer review requires that physicians evaluate the competence of other practitioners. This process can only work, however, if physicians are willing to review each other and if the reviewing physicians can engage in completely frank and candid exchanges with respect to the physician under review. As explained below, such exchanges are only possible if confidentiality is maintained throughout the peer review process. Here, release of peer review documents ordered by the District Court would forever terminate any confidentiality of any documents disclosed; once disclosed, the confidentiality of these documents can never be restored. Consequently, a stay should be had maintaining the status quo - and the confidentiality of peer review documents - until this Court can rule on the merits of defendants' appeal.

Interest of the Amici Curiae

Amicus American Hospital Association ("AHA") is the largest national membership organization for hospitals in the United States. The AHA's mission is to promote high quality health care and health services through leadership and assistance to hospitals in meeting the health care needs of their communities. The AHA's membership includes approximately 5,000 hospitals, health systems, networks, and other providers of care, including hospitals and health systems throughout the United States.

Amicus American Medical Association ("AMA"), an Illinois non-profit corporation, is an association of approximately 275,000 physicians who practice throughout the United States. The AMA was founded in 1847 to promote the science and art of medicine and the betterment of public health, and these still remain its core purposes. Its members practice in all fields of medical specialization, and it is the largest medical society in the United States.

Amicus Federation of American Hospitals ("FAH") is a national trade association representing some 1,700 privately-owned and managed community hospitals and health systems providing health care across the acute and post-acute spectrum. FAH member hospitals provide care for patients in both urban and rural America. FAH's principal objective is to foster the public good through the creation and delivery of quality health care for all people. FAH's members include corporations or other organizations involved in the delivery of health care services that share a common philosophy of providing high quality, affordable health care, through free enterprise.

Amici AHA, AMA, and FAH members have long been involved in peer review activities and in the delivery of health care services to patients on a daily basis. Amici are therefore in a unique position to speak to the important public interest served by maintaining the confidentiality of medical review proceedings. Amici contend that the District Court's ruling, which effectively abrogates the peer-review privilege, will have a significant adverse effect on the delivery of safe, quality health care to Medicare and Medicaid beneficiaries as well as to patients throughout the United States.

The interest of amici in this case is thus to maintain the benefits of peer review for the general public. The participation of amici in developing peer review, their work in obtaining recognition for the importance of peer-review privilege, and the participation of various members of these organizations in actual peer review, give amici a unique breadth of experience and extensive specific knowledge on the questions at issue in defendants' motion.

Undersigned counsel therefore submit that amici AHA, AMA and FAH can provide an important factual perspective on peer review procedures, which will be of great assistance to the Court in its resolution of the technical issues relating to peer-review privilege which are an essential aspect of this case.

The amici have filed a motion seeking leave to file the instant memorandum, and all parties have consented to amici participation in the resolution of this motion.

ARGUMENT

The Court should grant the requested stay in order to prevent the irreparable harm that will result if peer-review records are released prior to a final determination on the merits of defendants' appeal. The release of such records cannot be "undone" because, once released, their confidentiality is forever destroyed. Thus, if this Court denies defendants' motion and requires the release of peer review records, harm will result even if this Court later determines that the law does not require such release. Such a result would be inequitable, to say the least.

Moreover, granting the stay will not prejudice plaintiffs. Rather, the stay will merely maintain the long-established status quo until this Court can review the ruling below.

I.

Irreparable Harm Will Result From the Release of
Peer Review Records Ordered by the District Court

A.  Peer Review Is Essential to Ensuring Quality Care

Medical peer review has been "universally accepted as the means by which a hospital and its medical staff scrutinize a physician's credentials and monitor the quality of care that is provided." Jeanne Darricades, Comment, Medical Peer Review: How is it Protected by the Health Care Quality Improvement Act of 1986?, 18 J. of Contemp. L. 263, 263 (1992) (hereinafter "Medical Peer Review"); see Christopher S. Morter, Note, The Health Care Quality Improvement Act of 1986: Will Physicians Find Peer Review More Inviting, 74 Va. L. Rev. 1115, 1117 (1988) (hereinafter "The Health Care Quality Improvement Act") (describing peer review as the process by which physicians can evaluate the quality of care offered by other practitioner, evaluate the qualifications of applicants seeking privileges or to renew privileges at hospitals, and effect disciplinary actions against medical staff members).

Peer review thus contributes to the "enhancement of quality of patient care through effective supervision of health care professionals [and] elimination from the health care system of those who should not practice." American Hospital Association, Immunity for Peer Review Participants in Hospitals 9 (1989). In other words, peer review makes the care of patients safer and more effective. As one commentator observed, "the effectiveness of [peer review] efforts is critical to the achievement of hospital quality." Paul L. Scribetta, Note, Restructuring Hospital-Physician Relations: Patient Care Quality Depends on the Health of Hospital Peer Review, 51 U. Pitt. L. Rev. 1025, 1032 (1990).

Indeed, the standards for hospital accreditation published by the Joint Commission on the Accreditation of Healthcare Organizations ("JCAHO") - the leading hospital accreditation body in the United States - require medical staff committees to participate in efforts to measure outcomes and processes, and to evaluate "individuals with clinical privileges whose performance is questioned as a result of the measurement and assessment activities." JCAHO, 2000 Hospital Accreditation Standards 303 (2000). Notably, the purpose of the JCAHO standards is "to improve the quality of care provided to the public." Id. at ii. Courts have also recognized that peer review is critical to the protection and improvement of patient care. See McCall v. Henry Med. Ctr. Inc., No. A01A0586, 2001 WL 737339, at *2 (Ga. Ct. App. July 2, 2001) ("The ultimate purpose of the peer review law is to improve the delivery of medical care to the patient."); Cameron v. New Hanover Mem'l Hosp., 293 S.E.2d 901, 922 (N.C. Ct. App.) (where "human lives are at stake . . . [t]he evaluation of professional proficiency of doctors is best left to the specialized expertise of their peers"), cert. denied, 297 S.E. 2d 399 (N.C. 1982); Limjoco v. Schenck, 486 N.W.2d 567, 569 (Wis. Ct. App. 1992) (the "clear purpose" of peer review laws "is to improve the quality of health care by encouraging persons to participate in the review of health care providers").

B. Effective Peer Review Requires Confidentiality

Although "medical peer review is recognized as essential to [the] providing of quality medical care, physicians are reluctant to actively participate in the process." Darricades, Medical Peer Review, supra, at 270. Many physicians "fear serving on peer review committees," Morter, The Health Care Quality Improvement Act, supra, at 1119, for several reasons, including the possibility of litigation by the reviewed physician and the fear that malpractice plaintiffs will obtain peer review materials, thereby making peer reviewers unwitting witnesses. See Charles David Creech, Comment, The Medical Review Privilege: A Jurisdictional Survey, 67 N.C. L. Rev. 179, 179 (1988).

Medical review thus can be effective only where the physicians engaged in reviewing are able to maintain a frank, candid exchange of ideas. Full and fair evaluation of the quality of care requires that the reviewing physicians have the ability freely to discuss and to criticize, if necessary, the actions taken by their colleagues. If committee members fail to candidly evaluate their colleagues, poor-quality care will go uncorrected, and incompetent or impaired physicians will be allowed to continue practicing.
In order to maximize physicians' abilities to engage in peer review with candor, state legislatures have enacted laws designed to protect the confidentiality of proceedings and encourage physicians to engage in peer review. See, e.g., N.C. Gen. Stat. § 131E-95 (protecting the confidentiality of medical review proceedings and granting immunity to medical review participants); Wis. Stat. § 146.37 (granting immunity to those who participate in peer reviews in good faith); 63 Pa. Code § 425.1, et seq.; Ky. Rev. Stat. Ann. § 311.377; Mass. Gen. Laws ch. 111 § 204; see also Charles D. Creech, The Medical Review Committee Privilege: A Jurisdictional Survey, 67 N.C. L. Rev. 179, 179 (1988) (noting that as of 1988, at least forty-six states had statutes to "protect the work of medical review committees"). Likewise, courts have repeatedly recognized that maintaining confidentiality in peer-review proceedings is critical to maintaining quality health care. E.g., Weekoty v. United States, 30 F. Supp. 1343, 1345 (D. N.M. 1998) ("the self-critical analysis privilege is particularly pertinent in the medical context as it promotes frank and honest discussions which protect lives and promote patient care"); Huether v. District Court, 4 P.3d 1193, 1195 (Mont. 2000) ("The goal [of peer review] is to promote continuous improvement in the quality of health care delivery through review of standardized health care operations and the performance of doctors and staff.");Virmani v. Presbyterian Health Servs. Corp., 515 S.E.2d 675, 694 (N.C. 1999) (noting that "open and honest communication in medical peer review proceedings helps to assure high quality public health care"), cert. denied, 529 U.S. 1033; Memorial Hosp.-The Woodlands v. McCown, 927 S.W.2d 1, 3 (Tex. 1996) (peer review laws are premised on the notion that "exacting critical analysis of the competence and performance of physicians and other health-care providers by their peers will result in improved standards of medical care").

If confidentiality of peer review proceedings is not maintained, physicians will either refuse to engage in peer review or will not be able to review their colleagues with the candor necessary to ensure that peer review works.

C. The Release of Peer Review Records
Will Cause Irreparable Harm

In light of the importance of peer review, and the need for confidentiality in order to ensure effective peer review, the harm that would be caused by the release of peer review records is significant. Once the courts hold that peer review records previously believed to be confidential can be made public, the community of physician reviewers will diminish rapidly, if not fade away entirely. Release of the peer review records sought in this case would discourage physicians from engaging in peer review and limit the effectiveness of any peer review that is conducted, because few, if any, physicians could engage in the candid evaluation of their colleagues necessary to useful review. The result would be that the ability to monitor and improve the delivery of health care would be diminished, creating a risk for all patients.

II.

The Requested Stay Would Not Harm Plaintiffs

Conversely, plaintiffs cannot seriously dispute that they will not suffer any harm from the brief delay in the release of peer-review records sought here. This Court will ultimately decide whether such records are releasable under federal law. If it holds that no release may be had, then plaintiffs will have lost nothing at all, since they never had the "right" to obtain the records in the first place. If, instead, the law is construed to allow the release of such records, then plaintiffs will obtain the access they requested. In light of the fact that the regulatory regime challenged here has been in place for well over a decade, plaintiffs can hardly complain about the brief delay sought here.

III.

Staying the District Court's Order Is In the Public Interest

Finally, the public interest lies in protecting the health of citizens throughout the United States. See Jaffee v. Redmond, 518 U.S. 1, 11 (1996) (noting that "[t]he mental health of our citizenry, no less than its physical health, is a public good of transcendent importance"). Peer review serves that interest by playing a critical role in ensuring the provision of quality health care to patients. Indeed, federal courts here and elsewhere have explicitly recognized that the public interest lies in encouraging and maintaining confidential peer review proceedings. E.g., United States v. Harris Methodist Forth Worth, 970 F.2d 94, 103 (5th Cir. 1992) ("Peer review materials are sensitive and confidential, and protecting that confidentiality serves an important public interest"); Weekoty, 30 F. Supp. 2d at 1348 ("Clearly the public good - saving lives and correcting life threatening errors by physicians resulting from preserving the confidentiality of [peer review] morbidity and mortality conference - outweighs the general preference for open discovery"); Laws v. Georgetown Univ. Hosp., 656 F. Supp. 824, 826 (D.D.C. 1987) ("This court recognizes an overwhelming public interest in promoting improvement in health care through the mechanism of staff peer review"); Bredice v. Doctors Hosp., Inc., 50 F.R.D. 249, 250-51 (D.D.C. 1970) (peer review "meetings are essential to the continued improvement in the care and treatment of patients. . . . There is an overwhelming public interest in having those staff meetings held on a confidential basis"), aff'd, 479 F.2d 920 (D.C. Cir. 1973).


CONCLUSION

For the foregoing reasons, as well as the reasons set forth in defendants' memorandum, defendants' Motion for Stay Pending Appeal should be granted.


Dated: August 29, 2001

 

Respectfully submitted,

HOGAN & HARTSON L.L.P.


By:
Darrel J. Grinstead (D.C. Bar No. 064022)
Jeffrey Pariser (D.C. Bar No. 462085)
555 13th Street, N.W.
Washington, DC 20004
(202) 637-5600

Counsel for Amici Curiae

 



CERTIFICATE OF SERVICE

I certify that copies of the foregoing Response of Amici Curiae American Hospital Association, American Medical Association and Federation of American Hospitals Society in Support of Defendants Motion for Stay Pending Appeal was served by hand this 29th day of August, 2001 on the following counsel:

 

Roscoe C. Howard, Jr.
R. Craig Lawrence
G. Michael Harvey
United States Attorneys
Judiciary Center Building
555 Fourth Street, N.W.
Washington, DC 20001

Attorneys for Defendant

Alison M. Zieve
Public Citizen Litigation Group
1600 20th Street, N.W.
Washington, DC 20009

Robert W. Goodson
Carr Goodson
1667 K Street, N.W., Suite 1100
Washington, DC 20006

Thomas W. Kirby
Jason P. Cronic
Wiley, Rein & Fielding LLP
1776 K Street, N.W.
Washington, DC 20006

Attorneys for Plaintiff


________________________
Jeffrey Pariser

 

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