198320375-12-23-2024-11-AS-SCIS-DD6U4C-20250122141454

Community Care Licensing

COMPLAINT INVESTIGATION REPORT

Facility Number: 198320375
Report Date: 06/21/2024
Date Signed: 12/23/2024 05:59:12 PM

Unsubstantiated

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

This is an official report of an unannounced visit/investigation of a complaint received in our office on
06/13/2024 and conducted by Evaluator David Espana

PUBLIC

COMPLAINT CONTROL NUMBER: 11-AS-20240613131841

FACILITY NAME:	CIELA		FACILITY NUMBER:	198320375
ADMINISTRATOR:	SHRAM, RONY		FACILITY TYPE:	740
ADDRESS:	17310 WEST VEREDA DELA MONTURA		TELEPHONE:	(917) 667-5303
CITY:	PACIFIC PALISADES	STATE: CA	ZIP CODE:	90272
CAPACITY:	100	CENSUS: 39	DATE:	06/21/2024
		UNANNOUNCED	TIME BEGAN:	08:00 AM
MET WITH:	Caudle, Wendy, Director of Wellness		TIME COMPLETED:	04:15 PM

ALLEGATION(S):

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Staff did not seek medical attention in a timely manner.
Facility is requiring staff to administer medication that should be given by an appropriately skilled professional.
Staff are not administering medication to residents in care.
Staff did not comply with Infection control requirements.
Facility is storing expired medication.
Facility did not ensure that staff are properly trained.

INVESTIGATION FINDINGS:

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** LPA Sparkle Day conducted a subsequent visit to the facility today to amend this report . However the findings remain the same. The Amendmenment is to soley remove duplicate information. It does not supersede the complaint investigation findings reflected on report created 06/21/24.** On 06/21/24, Licensing Program Analyst (LPA) David España made an unannounced visit to this facility and was greeted by Administrator #1 (A1) Rony Shram, Administrator. LPA explained the purpose of today’s Subsequent visit is to gather information for the allegations mentioned above.
The investigation consisted of the following: On 06/21/24 (LPA) David España was met by Rony Shram, Administrator #1 (A1). LPA requested, received, and reviewed copies of the following documents: Staff and Resident Rosters, resident files which contained, Resident Appraisal RCFE; Appraisal Need and Services Plan; Physician's Report for RCFE, including specifics from Resident Medical Assessment; Identification and Emergency Information; Current admission agreement with authorized signatures, Admission; Any Unusual Incident/Injury/Report; Death Report, Centrally Stored Medication and Destruction Record; and Register of Facility Clients/Residents. (Evaluation Report continues LIC 9099-C)

Unsubstantiated

Estimated Days of Completion:

SUPERVISORS NAME: Janae Hammond
LICENSING EVALUATOR NAME: Sparkle Day
LICENSING EVALUATOR SIGNATURE:	DATE: 12/04/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 12/04/2024

This report must be available at Child Care and Group Home facilities for public review for 3 years.

LIC9099 (FAS) - (06/04)

Page: 1 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE

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LPA interviews were conducted with 5 out of 5 residents, identified as R1, R2, R3, R4, and R5. LPA España reviewed records of resident 1-Resident5 (R1-R5). LPA España interviewed staff1-staff5 (S1-S5). LPA España reviewed records of 5 out of 5 Staff.

Investigation revealed the following:

Allegation: Staff did not seek medical attention in a timely manner.

On June 20, 2024, LPA España conducted interviews between 8:00 AM and 5:00 PM with staff members S1-S5, observation of an in-service training session, and review of facility records. LPA España interviewed staff (S1-S5) who denied the allegation. S1-S5 stated that medical attention is managed promptly. S1-S5 described detailed procedures for medical emergencies and medication administration. LPA España interviewed Administrator Rony Shram (A1) who provided documentation of strict adherence to protocols. A1 stated a temporary pharmacy account issue on June 18, 2024, but confirmed no critical medication was missed. LPA interviews were conducted with 5 out of 5 residents, identified as R1, R2, R3, R4, and R5, who stated satisfaction with staff attentiveness. 5 out of 5 residents confirmed timely medical responses. LPA España reviewed medical logs, eMAR, training files, infection control protocols, and medication inventories. LPA España found no evidence supporting the allegation of delayed medical attention.

(Evaluation Report continues LIC 9099-C)

SUPERVISORS NAME: Janae Hammond
LICENSING EVALUATOR NAME: Sparkle Day
LICENSING EVALUATOR SIGNATURE:	DATE: 12/04/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 12/04/2024

LIC9099 (FAS) - (06/04)

Page: 2 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE
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SUPERVISORS NAME: Janae Hammond
LICENSING EVALUATOR NAME: Sparkle Day
LICENSING EVALUATOR SIGNATURE:	DATE: 10/03/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 10/03/2024

LIC9099 (FAS) - (06/04)

Page: 3 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE

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Based on the information collected, an inspection of the facility, observation and interviews conducted, and an analysis of records reviewed, the Department found no evidence to support the allegation mentioned in this complaint. Although the allegation may have happened or is valid, there is not a preponderance of evidence to prove, “Staff did not seek medical attention in a timely manner.” did or did not occur, therefore the allegation is Unsubstantiated.

Allegation: Facility is requiring staff to administer medication that should be given by an appropriately skilled professional.

During the visit on June 20, 2024, LPA España observed an in-service training session focused on medication management, which provided insights into staff competency. LPA España interviewed 5 staff members (S1-S5), all of whom denied the allegation. S1-S5 stated that only trained and certified personnel administer medications, emphasizing adherence to regulations and the involvement of healthcare professionals for specialized medications. On June 21, 2024, LPA España interviewed Administrator Rony Shram (A1), who refuted the claim and reiterated the facility's commitment to regulatory compliance. A1 confirmed that policies ensure only qualified personnel handle medications requiring specialized skills. LPA interviews were conducted with 5 out of 5 residents, identified as R1, R2, R3, R4, and R5, who stated confidence in the facility's practices, noting that only trained nurses administered their medications. (Evaluation Report continues LIC 9099-C)

SUPERVISORS NAME: Janae Hammond
LICENSING EVALUATOR NAME: Sparkle Day
LICENSING EVALUATOR SIGNATURE:	DATE: 12/04/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 12/04/2024

LIC9099 (FAS) - (06/04)

Page: 4 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE

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LPA España conducted a thorough review of medical logs, electronic medication administration records (eMAR), training files, and protocols revealed no evidence supporting the allegation.

Based on the information collected, an inspection of the facility, observation and interviews conducted, and an analysis of records reviewed, the Department found no evidence to support the allegation mentioned in this complaint. Although the allegation may have happened or is valid, there is not a preponderance of evidence to prove, “Facility is requiring staff to administer medication that should be given by an appropriately skilled professional” did or did not occur, therefore the allegation is Unsubstantiated.

Allegation: Staff are not administering medication to residents in care.
On June 20, 2024, LPA España interviewed 5 staff members (S1-S5). S1-S5 unanimously denied the allegation, emphasizing that medication administration records confirm that all prescribed medications are administered as directed. S1-S5 highlighted a robust system of audits and checks that supports this claim.

On June 21, 2024, LPA España interviewed Rony Shram, the facility's administrator (A1). A1 refuted the allegation and underscored the meticulous nature of Medication Administration Records (eMARs), which undergo regular audits by both internal and external bodies to ensure high compliance.

(Evaluation Report continues LIC 9099-C)

SUPERVISORS NAME: Janae Hammond
LICENSING EVALUATOR NAME: Sparkle Day
LICENSING EVALUATOR SIGNATURE:	DATE: 12/04/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 12/04/2024

LIC9099 (FAS) - (06/04)

Page: 5 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE

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LPA interviews were conducted with 5 out of 5 residents, identified as R1, R2, R3, R4, and R5, who stated receiving their medications regularly and on time. 5 out of 5 residents praised the diligence of the staff in managing their medication needs. On June 20, 2024, LPA España reviewed records of relevant documentation, including medical logs and training files.

Based on the information collected, an inspection of the facility, observation and interviews conducted, and an analysis of records reviewed, the Department found no evidence to support the allegation mentioned in this complaint. Although the allegation may have happened or is valid, there is not a preponderance of evidence to prove, “Staff are not administering medication to residents in care” did or did not occur, therefore the allegation is Unsubstantiated.
Allegation: Staff did not comply with Infection control requirements.
On June 20, 2024, LPA España observed an in-service training session on infection control, which demonstrated staff competency in this area. LPA España conducted interviews with staff 1- staff 5 members (S1-S5). on June 20, 2024. S1-S5 unanimously denied the allegation, emphasizing the facility's strict infection control system, including regular checks and adherence to proper protocols. On June 21, 2024, LPA España interviewed Administrator Rony Shram (A1), who refuted the claim. A1 highlighted robust infection control protocols aligned with CDC guidelines and noted frequent training sessions and audits. A1 also reported that the facility's infection rates were below the national average. (Evaluation Report continues LIC 9099-C)

SUPERVISORS NAME: Janae Hammond
LICENSING EVALUATOR NAME: Sparkle Day
LICENSING EVALUATOR SIGNATURE:	DATE: 12/04/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 12/04/2024

LIC9099 (FAS) - (06/04)

Page: 6 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE

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LPA interviews were conducted with 5 out of 5 residents, identified as R1, R2, R3, R4, and R5, who supported the facility's practices. 5 out of 5 residents praised staff for maintaining cleanliness and infection prevention through consistent hand hygiene and use of protective gear. LPA España interviews were attempted with 6 residents; however, 1 out of 6 residents refused to participate. On June 20, 2024, LPA España conducted a thorough review of relevant documentation, including medical logs and infection control protocols. A Gastrointestinal Outbreak Notification Letter from February 12, 2024, indicated effective early intervention during an outbreak.

Based on the information collected, an inspection of the facility, observation and interviews conducted, and an analysis of records reviewed, the Department found no evidence to support the allegation mentioned in this complaint. Although the allegation may have happened or is valid, there is not a preponderance of evidence to prove, “Staff did not comply with Infection control requirements” did or did not occur, therefore the allegation is Unsubstantiated.
Allegation: Facility is storing expired medication.
On June 20, 2024, LPA España observed an in-service training session on medication management, underscoring staff competency in handling medications. LPA España interviewed staff 1-staff 5 (S1-S5) revealed unanimous denial of the allegation. S1-S5 emphasized a strict system for regularly checking expiration dates and disposing of expired medications promptly. (Evaluation Report continues LIC 9099-C)

SUPERVISORS NAME: Janae Hammond
LICENSING EVALUATOR NAME: Sparkle Day
LICENSING EVALUATOR SIGNATURE:	DATE: 12/04/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 12/04/2024

LIC9099 (FAS) - (06/04)

Page: 7 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE

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Administrator Rony Shram (A1) refuted the claim, highlighting weekly audits by a dedicated pharmacy team to ensure no expired medications are stored. On 6/20/2024, LPA interviews were conducted with 5 out of 5 residents, identified as R1, R2, R3, R4, and R5, who stated confidence in the facility's medication management, noting regular checks on expiration dates.

Based on the information collected, an inspection of the facility, observation and interviews conducted, and an analysis of records reviewed, the Department found no evidence to support the allegation mentioned in this complaint. Although the allegation may have happened or is valid, there is not a preponderance of evidence to prove, “Facility is storing expired medication” did or did not occur, therefore the allegation is Unsubstantiated.

Allegation: Facility did not ensure that staff are properly trained.
On June 20, 2024, LPA España observed an in-service training session on June 20, 2024, demonstrating the facility's commitment to staff education and competency. On June 20, 2024, LPA España interviewed staff 1- staff 5 (S1-S5) who revealed unanimous disagreement with the allegation. S1-S5 described a comprehensive training program that includes initial orientation, ongoing education, and regular skill assessments.

(Evaluation Report continues LIC 9099-C)

SUPERVISORS NAME: Janae Hammond
LICENSING EVALUATOR NAME: Sparkle Day
LICENSING EVALUATOR SIGNATURE:	DATE: 12/04/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 12/04/2024

LIC9099 (FAS) - (06/04)

Page: 8 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE

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LPA España interviewed Administrator Rony Shram (A1) refuted the allegation, stating that the training program exceeds state and federal requirements and is consistently praised by residents, families, and inspectors.

LPA interviews were conducted with 5 out of 5 residents, identified as R1, R2, R3, R4, and R5, stated confidence in staff training, noting their preparedness and professionalism. LPA España conducted record review of medical logs and training files, confirmed adherence to proper procedures. The review included a department-wide in-service sign-in sheet from February 15, 2024.

No deficiencies cited at the time of visit.

An exit interview was conducted with Rony Shram, Managing Principal and Allie David, VP of finance a copy of this report was provided.

SUPERVISORS NAME: Janae Hammond
LICENSING EVALUATOR NAME: Sparkle Day
LICENSING EVALUATOR SIGNATURE:	DATE: 12/04/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 12/04/2024

LIC9099 (FAS) - (06/04)

Page: 9 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32	Intentionally left blank

SUPERVISORS NAME: Stephanie Cifuentes
LICENSING EVALUATOR NAME: David Espana
LICENSING EVALUATOR SIGNATURE:	DATE: 06/21/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 06/21/2024

LIC9099 (FAS) - (06/04)

Page: 10 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32	Intentionally left blank

SUPERVISORS NAME: Stephanie Cifuentes
LICENSING EVALUATOR NAME: David Espana
LICENSING EVALUATOR SIGNATURE:	DATE: 06/21/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 06/21/2024

LIC9099 (FAS) - (06/04)

Page: 11 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32	Intentionally left blank

SUPERVISORS NAME: Stephanie Cifuentes
LICENSING EVALUATOR NAME: David Espana
LICENSING EVALUATOR SIGNATURE:	DATE: 06/21/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 06/21/2024

LIC9099 (FAS) - (06/04)

Page: 12 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32	Intentionally left blank

SUPERVISORS NAME: Stephanie Cifuentes
LICENSING EVALUATOR NAME: David Espana
LICENSING EVALUATOR SIGNATURE:	DATE: 06/21/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 06/21/2024

LIC9099 (FAS) - (06/04)

Page: 13 of 14

Control Number 11-AS-20240613131841

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
EL SEGUNDO ASC, 400 CONTINENTAL BLVD, STE 340
EL SEGUNDO, CA 90245

FACILITY NAME: CIELA	FACILITY NUMBER: 198320375
	VISIT DATE: 06/21/2024

NARRATIVE
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32	Intentionally left blank

SUPERVISORS NAME: Stephanie Cifuentes
LICENSING EVALUATOR NAME: David Espana
LICENSING EVALUATOR SIGNATURE:	DATE: 06/21/2024

I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.

FACILITY REPRESENTATIVE SIGNATURE:

DATE: 06/21/2024

LIC9099 (FAS) - (06/04)

Page: 14 of 14