2020-10-08T16:59:51-05:00 2019-12-31 203746583 TAYLOR ROTH AND COMPANY 800 GRANT ST STE 205 DENVER CO 802032944 990 2019-01-01 464625504 TOWARDS JUSTICE OF COLORADO TOWA 9704035694 1410 HIGH STREET SUITE 300 DENVER CO 80218 BARRY BAER TREASURER 9704035694 2020-10-08 true DIANE K GRANGER P01388919 3038308109 2020-10-08 24.128.123.73 2020-10-08 16:59:51 CD P F510452ABB4A09DEF72ED4AF0FBBE4EEFED67493 F510452ABB4A09DEF72ED4AF0FBBE4EEFED67493 2019 2021-01-29 14:40:06Z TOWARDS JUSTICE DAVID SELIGMAN ESQ 1410 HIGH STREET SUITE 300 DENVER CO 80218 3999943 false X WWW.TOWARDSJUSTICE.ORG X 2014 CO TOWARDS JUSTICE IS A NONPROFIT LAW FIRM THAT SEEKS TO ADVANCE ECONOMIC JUSTICE THROUGH IMPACT LITIGATION, STRATEGIC POLICY ADVOCACY, AND COLLABORATION WITH ORGANIZERS AND PUBLIC AGENCIES. WE WERE FOUNDED IN RESPONSE TO THE HIGH VOLUME OF WAGE THEFT COMPLAINTS THAT WERE NOT BEING ADDRESSED IN COLORADO, BUT HAVE SINCE BROADENED OUR SCOPE TO TAKE ON CASES THAT DISMANTLE THE POWER IMBALANCES THAT UNDERMINE THE VALUE OF WORK AND DIMINISH WORKER RIGHTS. 6 5 11 2 0 563197 579934 5720 3404413 263 946 3907 9760 573087 3995053 0 0 464651 616775 0 7505 211738 158670 676389 775445 -103302 3219608 183053 3415883 13656 26878 169397 3389005 X TOWARDS JUSTICE IS A NONPROFIT LAW FIRM THAT SEEKS TO ADVANCE ECONOMIC JUSTICE THROUGH IMPACT LITIGATION, STRATEGIC POLICY ADVOCACY, AND COLLABORATION WITH ORGANIZERS AND PUBLIC AGENCIES. WE WERE FOUNDED IN RESPONSE TO THE HIGH VOLUME OF WAGE THEFT COMPLAINTS THAT WERE NOT BEING ADDRESSED IN COLORADO, BUT HAVE SINCE BROADENED OUR SCOPE TO TAKE ON CASES THAT DISMANTLE THE POWER IMBALANCES THAT UNDERMINE THE VALUE OF WORK AND DIMINISH WORKER RIGHTS. false false 696423 3404413 TOWARDS JUSTICE IS A NON-PROFIT LAW FIRM THAT ATTACKS ECONOMIC INEQUALITY WITH A FOCUS ON WORKPLACE ECONOMIC INJUSTICE. WE USE IMPACT LITIGATION TO ADVANCE HUMAN AND CIVIL RIGHTS SUPPLEMENTED WITH TARGETED AND STRATEGIC POLICY ADVOCACY AND COLLABORATION WITH WORKERS AND COMMUNITIES TO ATTACK SYSTEMIC INJUSTICES THAT UNDERMINE THE POWER OF WORKERS-IN PARTICULAR, IMMIGRANT WORKERS AND WORKERS OF COLOR-TO OBTAIN FAIR WAGES AND DECENT WORKING CONDITIONS. IN 2019, TOWARDS JUSTICE HAD SEVERAL SUBSTANTIAL ACCOMPLISHMENTS. MOST IMPORTANTLY, WE (1) OBTAINED A SUBSTANTIAL CLASS ACTION SETTLEMENT FOR AROUND 100,000 CHILDCARE WORKERS WORKING IN THE UNITED STATES ON J-1 AU PAIR VISAS, AND (2) WE CONVINCED THE COLORADO DEPARTMENT OF LABOR AND EMPLOYMENT TO MAKE MAJOR MODIFICATIONS TO WHAT HAD BEEN CALLED THE "COLORADO MINIMUM WAGE ORDER" THAT NOW PROVIDES ADDITIONAL PROTECTIONS FOR HUNDREDS OF THOUSANDS OF COLORADO WORKERS. OUR SETTLEMENT IN BELTRAN ET AL. V. INTEREXCHANGE ET AL., CAME AFTER YEARS OF LITIGATION THAT WE INITIATED IN 2014 TO ATTACK ALLEGED ABUSES OF THE CIVIL RIGHTS OF CHILDCARE WORKERS WORKING IN THE UNITED STATES ON J-1 AU PAIR VISAS. MOST IMPORTANTLY, WHILE THE J-1 VISA CONTEMPLATES THAT THESE WORKERS COME TO THE UNITED STATES ON A CULTURAL EXCHANGE, WORKERS COMPLAINED TO US THAT THEY WERE REALLY HERE PERFORMING DIFFICULT CHILDCARE RESPONSIBILITIES FOR MORE THAN 40 HOURS A WEEK AND YET WERE DENIED STATE AND FEDERAL MINIMUM WAGE. ADDITIONALLY, OUR INVESTIGATION FOUND THAT THESE WORKERS WERE SUBJECT TO A WAGE-FIXING SCHEME UNDER WHICH THE SPONSOR AGENCIES THAT EMPLOY THEM APPARENTLY AGREED TO SET THEIR WAGES AT A FIXED AMOUNT OF JUST UNDER 200 PER WEEK, MEANING THAT THESE WORKERS COULD NOT SHOP AROUND BETWEEN FAMILIES FOR HIGHER WAGES AND BETTER WORKING CONDITIONS. TOWARDS JUSTICE IS FIRMLY COMMITTED TO THE NOTION THAT ONE OF THE CORE CIVIL RIGHTS AFFECTING WORKERS IS THE RIGHT TO OBTAIN DIGNITY IN THE WORKPLACE THROUGH A COMPETITIVE LABOR MARKET. AFTER LITIGATING THIS CASE THROUGH MOTIONS TO DISMISS, CLASS CERTIFICATION, AND SUMMARY JUDGMENT, WE HELPED THE CLASS ACHIEVE A SUBSTANTIAL SETTLEMENT. THAT SETTLEMENT FORCED SIGNIFICANT CHANGES TO THE INDUSTRY. MOST IMPORTANTLY, SPONSOR AGENCIES NOW HAVE TO MAKE CLEAR TO WORKERS AND FAMILIES THAT WORKERS CAN SHOP ON AN OPEN MARKET WHERE FAMILIES CAN PAY THEM WHATEVER THEY PERCEIVE THE VALUE OF THEIR LABOR TO BE, SO LONG AS THEY ARE PAYING AT LEAST MINIMUM WAGE. WE HAVE HEARD ANECDOTALLY THAT THESE CHANGES HAVE ALREADY ALLOWED AU PAIRS TO REAP SUBSTANTIAL BENEFITS. FOR EXAMPLE, WE WILL FILE THIS FORM 990 IN THE MIDST OF A PANDEMIC WHERE CHILDCARE IS EXTRAORDINARILY VALUABLE TO FAMILIES AND AU PAIRS ARE IN HIGH DEMAND. BECAUSE OF OUR LITIGATION, AU PAIRS NOW KNOW THAT THEY CAN BARGAIN FOR HIGHER WAGES AND BETTER TREATMENT, AND IN MANY CASES, AU PAIR PAY HAS INCREASED DRAMATICALLY. ADDITIONALLY, STATES (MOST NOTABLY, MASSACHUSETTS) ARE RELYING ON PRECEDENT WE SET IN OUR CASE TO CONVINCE COURTS IN OTHER CIRCUITS THAT STATE MINIMUM WAGE LAWS APPLIED TO AU PAIRS ARE NOT PREEMPTED BY FEDERAL J-1 RULES. THE CORE MISSION OF TOWARDS JUSTICE'S LITIGATION PROGRAM IS TO ADVANCE THE RIGHTS OF WORKERS BEYOND THE CONTOURS OF A PARTICULAR CASE. THE BELTRAN LITIGATION IS A PERFECT ILLUSTRATION OF THE SUCCESS OF OUR LITIGATION WORK BECAUSE OF ITS BROAD AND BENEFICIAL IMPACT ON THE RIGHTS OF WORKERS IN THE AU PAIR MARKETPLACE. WHILE WE DO NOT OFTEN TAKE A LEADERSHIP ROLE IN POLICY DEBATES, IN 2019 WE LED A COALITION OF GROUPS ACROSS COLORADO IN ADVOCATING THAT THE COLORADO DEPARTMENT OF LABOR AND EMPLOYMENT USE ITS RULEMAKING AUTHORITY TO PROVIDE ADDITIONAL PROTECTIONS FOR WORKERS. THAT CAMPAIGN WAS POSSIBLE BECAUSE OF OUR LITIGATION CAPACITY. THE CREDIBLE THREAT OF LITIGATION UNDER THE ADMINISTRATIVE PROCEDURE ACT WAS WHAT SPURRED THE DEPARTMENT TO ENGAGE IN A CAREFUL RULEMAKING EFFORT AND TO EXAMINE WHETHER ITS PRIOR EXCLUSIONS OF CERTAIN WORKERS FROM PROTECTIONS WERE JUSTIFIED BY THE EVIDENCE. AFTER NEARLY A YEAR OF RULEMAKING ACTIVITY IN WHICH TOWARDS JUSTICE WAS DEEPLY INVOLVED, THE AGENCY PROMULGATED A NEW WAGE ORDER KNOWN AS THE "COMPS ORDER." THE COMPS ORDER PROVIDES SUBSTANTIAL ADDITIONAL PROTECTIONS FOR WORKERS. MOST IMPORTANTLY, IT COVERS OVERTIME EXEMPT WORKERS WITH A SUBSTANTIALLY INCREASED MINIMUM SALARY. IT ALSO EXTENDS REST AND MEAL BREAK PROTECTIONS TO TENS OF THOUSANDS OF WORKERS (INCLUDING CONSTRUCTION WORKERS) WHO HAD NOT PREVIOUSLY RECEIVED THOSE PROTECTIONS. IN ADDITION TO THESE SUCCESSES, IN 2019, TOWARDS JUSTICE FILED CIVIL RIGHTS LITIGATION ON BEHALF OF WORKERS AND CONSUMERS IN A VARIETY OF DIFFERENT AREAS, SUBMITTED AMICUS BRIEFS IN SUPPORT OF WORKERS, AND HELPED TO CHANGE THE CONVERSATION ABOUT WORK IN THIS COUNTRY. 696423 true true false true false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false true 4 0 true 11 true false false false false false false false false false false false false X 6 5 false false false false false false false true true false false false true true true true true true false true true X X DAVID SELIGMAN ESQ 9704035694 1410 HIGH STREET SUITE 300 DENVER CO 80218 JEFFREY WILLIAMS BOARD PRESID 2.00 X X 0 0 0 CAMILA SOSMAN PALMER SECRETARY 2.00 X X 0 0 0 BARRY BAER TREASURER 2.00 X X 0 0 0 NINA DISALVO ESQ BOARD MEMBER 1.00 X 26481 0 18 BRIAN GONZALES BOARD MEMBER 1.00 X 0 0 0 DAVID LOPEZ BOARD MEMBER 1.00 X 0 0 0 DAVID SELIGMAN ESQ EXECUTIVE DI 40.00 X 100000 0 25004 ALEXANDER HOOD ESQ ATTORNEY 40.00 X 102500 0 21301 JUNO TURNER ESQ LITIGATION D 40.00 X 102788 0 0 331769 46323 2 false false false 579934 579934 LEGAL FEE INCOME 541900 3404413 3404413 3404413 946 946 14650 4890 9760 9760 3995053 3404413 10706 125004 112504 11250 1250 410239 369215 36922 4102 41409 37268 3727 414 40123 36110 3611 402 7183 7183 628 390 190 48 24877 23266 1541 70 12756 10877 1159 720 27100 23577 3252 271 4355 4137 218 2093 1281 677 135 9257 8331 833 93 CLIENT COSTS 56418 56418 OUTREACH 7648 7648 PROFESSIONAL DEVELOPMENT 3818 2864 954 RESEARCH 2537 2537 775445 696423 71517 7505 80727 100326 3395312 8750 9821 2000 2000 183053 3415883 13656 26878 13656 26878 X 93529 3332430 75868 56575 169397 3389005 183053 3415883 3219608 X true X false true false X 282075 256285 307313 563197 579934 1988804 282075 256285 307313 563197 579934 1988804 115295 1873509 64 263 946 1273 8760 8760 13057 9905 3907 9760 36629 2035466 3721528 0.92040 0.87920 X PART II, LINE 10 NET SPECIAL EVENTS 35,323 ALL OTHER 1,306 RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 1050 1050 774395 775445 141317 35329 95158 102624 126458 141317 465557 698336 5000 5000 1720 1050 12770 23790 25656 31615 35329 116390 174585 FORM 990, PAGE 1, ITEM C TOWARDS JUSTICE FORM 990 - ORGANIZATION'S MISSION TOWARDS JUSTICE IS A NONPROFIT LAW FIRM THAT SEEKS TO ADVANCE ECONOMIC JUSTICE THROUGH IMPACT LITIGATION, STRATEGIC POLICY ADVOCACY, AND COLLABORATION WITH ORGANIZERS AND PUBLIC AGENCIES. WE WERE FOUNDED IN RESPONSE TO THE HIGH VOLUME OF WAGE THEFT COMPLAINTS THAT WERE NOT BEING ADDRESSED IN COLORADO, BUT HAVE SINCE BROADENED OUR SCOPE TO TAKE ON CASES THAT DISMANTLE THE POWER IMBALANCES THAT UNDERMINE THE VALUE OF WORK AND DIMINISH WORKER RIGHTS. FORM 990, PAGE 1, PART I, LINE 6 TOWARDS JUSTICE OF COLORADO RECEIVES SERVICES FROM A PRO BONO ATTORNEY WHO GENEROUSLY DONATED APPROXIMATELY 250 HOURS OF TIME TO THE ORGANIZATION IN 2019, VALUED AT 12,812 ON THE REVIEWED FINANCIAL STATEMENTS. FORM 990, PAGE 2, PART III, LINE 4A TOWARDS JUSTICE IS A NON-PROFIT LAW FIRM THAT ATTACKS ECONOMIC INEQUALITY WITH A FOCUS ON WORKPLACE ECONOMIC INJUSTICE. WE USE IMPACT LITIGATION TO ADVANCE HUMAN AND CIVIL RIGHTS SUPPLEMENTED WITH TARGETED AND STRATEGIC POLICY ADVOCACY AND COLLABORATION WITH WORKERS AND COMMUNITIES TO ATTACK SYSTEMIC INJUSTICES THAT UNDERMINE THE POWER OF WORKERS-IN PARTICULAR, IMMIGRANT WORKERS AND WORKERS OF COLOR-TO OBTAIN FAIR WAGES AND DECENT WORKING CONDITIONS. IN 2019, TOWARDS JUSTICE HAD SEVERAL SUBSTANTIAL ACCOMPLISHMENTS. MOST IMPORTANTLY, WE (1) OBTAINED A SUBSTANTIAL CLASS ACTION SETTLEMENT FOR AROUND 100,000 CHILDCARE WORKERS WORKING IN THE UNITED STATES ON J-1 AU PAIR VISAS, AND (2) WE CONVINCED THE COLORADO DEPARTMENT OF LABOR AND EMPLOYMENT TO MAKE MAJOR MODIFICATIONS TO WHAT HAD BEEN CALLED THE "COLORADO MINIMUM WAGE ORDER" THAT NOW PROVIDES ADDITIONAL PROTECTIONS FOR HUNDREDS OF THOUSANDS OF COLORADO WORKERS. OUR SETTLEMENT IN BELTRAN ET AL. V. INTEREXCHANGE ET AL., CAME AFTER YEARS OF LITIGATION THAT WE INITIATED IN 2014 TO ATTACK ALLEGED ABUSES OF THE CIVIL RIGHTS OF CHILDCARE WORKERS WORKING IN THE UNITED STATES ON J-1 AU PAIR VISAS. MOST IMPORTANTLY, WHILE THE J-1 VISA CONTEMPLATES THAT THESE WORKERS COME TO THE UNITED STATES ON A CULTURAL EXCHANGE, WORKERS COMPLAINED TO US THAT THEY WERE REALLY HERE PERFORMING DIFFICULT CHILDCARE RESPONSIBILITIES FOR MORE THAN 40 HOURS A WEEK AND YET WERE DENIED STATE AND FEDERAL MINIMUM WAGE. ADDITIONALLY, OUR INVESTIGATION FOUND THAT THESE WORKERS WERE SUBJECT TO A WAGE-FIXING SCHEME UNDER WHICH THE SPONSOR AGENCIES THAT EMPLOY THEM APPARENTLY AGREED TO SET THEIR WAGES AT A FIXED AMOUNT OF JUST UNDER 200 PER WEEK, MEANING THAT THESE WORKERS COULD NOT SHOP AROUND BETWEEN FAMILIES FOR HIGHER WAGES AND BETTER WORKING CONDITIONS. TOWARDS JUSTICE IS FIRMLY COMMITTED TO THE NOTION THAT ONE OF THE CORE CIVIL RIGHTS AFFECTING WORKERS IS THE RIGHT TO OBTAIN DIGNITY IN THE WORKPLACE THROUGH A COMPETITIVE LABOR MARKET. AFTER LITIGATING THIS CASE THROUGH MOTIONS TO DISMISS, CLASS CERTIFICATION, AND SUMMARY JUDGMENT, WE HELPED THE CLASS ACHIEVE A SUBSTANTIAL SETTLEMENT. THAT SETTLEMENT FORCED SIGNIFICANT CHANGES TO THE INDUSTRY. MOST IMPORTANTLY, SPONSOR AGENCIES NOW HAVE TO MAKE CLEAR TO WORKERS AND FAMILIES THAT WORKERS CAN SHOP ON AN OPEN MARKET WHERE FAMILIES CAN PAY THEM WHATEVER THEY PERCEIVE THE VALUE OF THEIR LABOR TO BE, SO LONG AS THEY ARE PAYING AT LEAST MINIMUM WAGE. WE HAVE HEARD ANECDOTALLY THAT THESE CHANGES HAVE ALREADY ALLOWED AU PAIRS TO REAP SUBSTANTIAL BENEFITS. FOR EXAMPLE, WE WILL FILE THIS FORM 990 IN THE MIDST OF A PANDEMIC WHERE CHILDCARE IS EXTRAORDINARILY VALUABLE TO FAMILIES AND AU PAIRS ARE IN HIGH DEMAND. BECAUSE OF OUR LITIGATION, AU PAIRS NOW KNOW THAT THEY CAN BARGAIN FOR HIGHER WAGES AND BETTER TREATMENT, AND IN MANY CASES, AU PAIR PAY HAS INCREASED DRAMATICALLY. ADDITIONALLY, STATES (MOST NOTABLY, MASSACHUSETTS) ARE RELYING ON PRECEDENT WE SET IN OUR CASE TO CONVINCE COURTS IN OTHER CIRCUITS THAT STATE MINIMUM WAGE LAWS APPLIED TO AU PAIRS ARE NOT PREEMPTED BY FEDERAL J-1 RULES. THE CORE MISSION OF TOWARDS JUSTICE'S LITIGATION PROGRAM IS TO ADVANCE THE RIGHTS OF WORKERS BEYOND THE CONTOURS OF A PARTICULAR CASE. THE BELTRAN LITIGATION IS A PERFECT ILLUSTRATION OF THE SUCCESS OF OUR LITIGATION WORK BECAUSE OF ITS BROAD AND BENEFICIAL IMPACT ON THE RIGHTS OF WORKERS IN THE AU PAIR MARKETPLACE. WHILE WE DO NOT OFTEN TAKE A LEADERSHIP ROLE IN POLICY DEBATES, IN 2019 WE LED A COALITION OF GROUPS ACROSS COLORADO IN ADVOCATING THAT THE COLORADO DEPARTMENT OF LABOR AND EMPLOYMENT USE ITS RULEMAKING AUTHORITY TO PROVIDE ADDITIONAL PROTECTIONS FOR WORKERS. THAT CAMPAIGN WAS POSSIBLE BECAUSE OF OUR LITIGATION CAPACITY. THE CREDIBLE THREAT OF LITIGATION UNDER THE ADMINISTRATIVE PROCEDURE ACT WAS WHAT SPURRED THE DEPARTMENT TO ENGAGE IN A CAREFUL RULEMAKING EFFORT AND TO EXAMINE WHETHER ITS PRIOR EXCLUSIONS OF CERTAIN WORKERS FROM PROTECTIONS WERE JUSTIFIED BY THE EVIDENCE. AFTER NEARLY A YEAR OF RULEMAKING ACTIVITY IN WHICH TOWARDS JUSTICE WAS DEEPLY INVOLVED, THE AGENCY PROMULGATED A NEW WAGE ORDER KNOWN AS THE "COMPS ORDER." THE COMPS ORDER PROVIDES SUBSTANTIAL ADDITIONAL PROTECTIONS FOR WORKERS. MOST IMPORTANTLY, IT COVERS OVERTIME EXEMPT WORKERS WITH A SUBSTANTIALLY INCREASED MINIMUM SALARY. IT ALSO EXTENDS REST AND MEAL BREAK PROTECTIONS TO TENS OF THOUSANDS OF WORKERS (INCLUDING CONSTRUCTION WORKERS) WHO HAD NOT PREVIOUSLY RECEIVED THOSE PROTECTIONS. IN ADDITION TO THESE SUCCESSES, IN 2019, TOWARDS JUSTICE FILED CIVIL RIGHTS LITIGATION ON BEHALF OF WORKERS AND CONSUMERS IN A VARIETY OF DIFFERENT AREAS, SUBMITTED AMICUS BRIEFS IN SUPPORT OF WORKERS, AND HELPED TO CHANGE THE CONVERSATION ABOUT WORK IN THIS COUNTRY. FORM 990, PAGE 6, PART VI, LINE 11B THE EXECUTIVE DIRECTOR AND A BOARD MEMBER, AS AVAILABLE, HAVE A MEETING WITH THE EXTERNAL CONSULTANT TO REVIEW THE FORM 990 AND ITS REQUIRED ATTACHMENTS AND SCHEDULES. DURING THIS MEETING, A REVIEW OF ALL FINANCIAL AND NARRATIVE INFORMATION IS UNDERTAKEN TO MAKE SURE ALL REPORTS AND SCHEDULES REFLECT THE ACTUAL OPERATING RESULTS OF THE AGENCY FOR THE MOST RECENTLY COMPLETED FISCAL YEAR. AFTER THIS PROCESS, THE EXECUTIVE DIRECTOR PRESENTS THE 990 TO THE FULL BOARD FOR REVIEW. FORM 990, PAGE 6, PART VI, LINE 12C THE BOARD ADOPED A CONFLICTS OF INTEREST POLICY IN OCTOBER OF 2014 AND THE BOARD EXECUTIVE COMMITTEE AND EXECUTIVE DIRECTOR WORK TOGETHER TO ENSURE COMPLIANCE WITH THAT POLICY THROUGHOUT THE YEAR. THE AGENCY MAINTAINS BOARD POLICIES AND PROCEDURES IN A CLOUD-BASED FORMAT ACCESSIBLE TO ALL BOARD MEMBERS. EACH BOARD MEMBER HAS ACCESS TO THE FOLDER AND THE ORIENTATION TO FULLY EXPLAIN THE ROLES AND RESPONSIBILITIES OF EACH MEMBER. FORM 990, PAGE 6, PART VI, LINE 15A THE BOARD OF DIRECTORS CONDUCTS AN ANNUAL PERFORMANCE AND COMPENSATION EVALUATION OF THE EXECUTIVE DIRECTOR, WHICH INVOLVES SURVEYING BOARD AND STAFF MEMBERS AND ANALYZING ORGANIZATIONAL PERFORMANCE RELATIVE BOTH TO MONETARY AND PROGRAMMATIC GOALS. THE BOARD THEN ANALYSES NONPROFIT SECTOR SALARY SURVEY DATA FOR EXECUTIVE PERSONNEL, INCLUDING COLORADO-SPECIFIC SURVEY INFORMATION COMPILED BY THE COLORADO NONPROFIT ASSOCIATION. SALARY IS SET BASED ON EXISTING SALARY STRUCTURE OF THE ORGANIZATION, EXECUTIVE DIRECTOR PERFORMANCE, AND RELEVANT NONPROFIT SECTOR TRENDS. FORM 990, PAGE 6, PART VI, LINE 19 GOVERNING AND PUBLIC FINANCIAL DOCUMENTS ARE AVAILABLE UPON WRITTEN REQUEST.