Charmaine Marie Green v. Belair Insurance Company Inc., 2014 ONFSCDRS 193

Financial Services Commission of Ontario

Neutral Citation: 2014 ONFSCDRS 193 FSCO A11-000765

BETWEEN:

CHARMAINE MARIE GREEN Applicant

and

BELAIR INSURANCE COMPANY INC. Insurer

REASONS FOR DECISION

Before: Lloyd (J. R.) Richards Heard: December 9, 10, 11, 2013, at the offices of the Financial Services Commission of Ontario in Toronto. Written submissions were received on January 17 and 31, 2014.

Appearances: Sophia Souffront for Ms. Green Thomas Hughes for Belair Insurance Company Inc.

Issues:

The Applicant, Charmaine Marie Green, was injured in a motor vehicle accident on September 20, 2009. She applied for and received statutory accident benefits from Belair Insurance Company Inc. (“Belair”), payable under the Schedule.¹ Belair subsequently terminated the benefits it had been paying to Ms. Green. The parties were unable to resolve their disputes through mediation, and Ms. Green applied for arbitration at the Financial Services Commission of Ontario under the Insurance Act, R.S.O. 1990, c.I.8, as amended.

The particular issues in this hearing are:

1. Is Ms. Green entitled to receive a medical benefit in the amount of $11,886.04 for services at Osler Rehabilitation Centre?
2. Is Ms. Green entitled to the cost of examinations at Assessment Direct in the amount of $1074.74 for a Follow-Up In-Home assessment, dated March 2, 2010?
3. Is Ms. Green entitled to attendant care benefits in the amount of $814.63 per month from September 20, 2009, to September 19, 2011, less the amounts Belair has already paid?
4. Is Ms. Green entitled to housekeeping and home maintenance benefits in the amount of $100.00 per week from September 20, 2009, to September 19, 2011, less the amounts Belair has already paid?
5. Is Belair liable to pay a special award because it unreasonably withheld or delayed payments to Ms. Green?
6. Is Ms. Green entitled to interest for the overdue payment of benefits?

Result:

1. Ms. Green is not entitled to receive a medical benefit in the amount of $11,886.04 for services at Osler Rehabilitation Centre.
2. Ms. Green is not entitled to the cost of examinations at Assessment Direct in the amount of $1074.74 for a Follow-Up In-Home assessment, dated March 2, 2010.
3. Ms. Green is not entitled to any further attendant care benefits.
4. Ms. Green is not entitled to any further housekeeping and home maintenance benefits.
5. Ms. Green is not entitled to a Special Award.

Background:

There is no issue that Ms. Green was involved in the motor vehicle accident on September 20, 2009. After the accident, Ms. Green claims that she had her impairments assessed by Assessment Direct and sought treatment for her injuries at Osler Rehabilitation Centre ("Osler"). She also claimed housekeeping and home maintenance benefits, as well as attendant care benefits, based on assessments at Osler and Assessment Direct. She states that she attended Osler for approximately one year and stopped attending only because Belair refused to pay for more treatment. She contends that Belair relied on faulty and self-serving insurer examination reports in terminating her benefits and in not approving treatment that she still requires. She also claims that a number of treatment plans that she submitted are “deemed approved” since Belair did not properly respond to them.

Belair contends that Ms. Green went directly to Osler after the motor vehicle accident and did not attend at her regular treating physician. In their view, Osler treated her claim as a commodity, rather than a plan to rehabilitate. Belair claims to have had difficulty adjusting Ms. Green’s claims because of the way Osler and Assessment Direct handled them, and that it paid almost $40,000.00 toward her claims in good faith. Belair claims to have stopped paying when it became apparent that the treatment was not being incurred and many of the assessments were not taking place. Belair’s view is that the medical treatment, housekeeping and attendant care expenses Ms. Green claims are not reasonable or necessary. Further, it should not be held liable for treatment or assessments that were approved, but later found not to be incurred or the result of abusive behaviour by the provider.

For the reasons that follow, I find that Ms. Green is not entitled to the benefits she claims.

EVIDENCE AND ANALYSIS:

Medical benefits in the amount of $11,886.04 for services at Osler

The Law

The Schedule states that an insurer shall pay a medical benefit to an insured person who sustains an impairment as a result of an accident. The medical benefit shall pay for all reasonable and necessary expenses incurred by or on behalf of the insured person as a result of the accident.

An insured person makes a claim for medical benefits by forwarding a treatment plan to an insurer. When the insurer receives the treatment plan, it is then obligated to notify the insured person of the goods and services for which it intends to pay. The Schedule further states that if the insurer fails to give this notice, then it shall pay for all goods and services provided under the treatment plan.

Ms. Green alleges that she accrued almost $12,000.00 in medical expenses at Osler for which Belair did not pay. Ms. Sheilagh Brown, an adjuster at Belair, gave evidence that 85 treatment and assessment plans were submitted to Belair in Ms. Green’s case (45 treatment plans and 40 requests for assessment). The 45 treatment plans were put into evidence at this hearing and range in date from October 9, 2009, to September 27, 2010.

Belair addressed the 45 treatment plans in the following manner:

• It paid for treatment, but neglected to pay for fees for form completion for the following plans: dated October 9, 2009; dated November 25, 2009; dated May 28, 2010; and dated July 5, 2010.
• It paid for treatment, but not for assessment fees and fees for form completion for the following plans: dated October 23, 2009; dated October 28, 2009; dated November 12, 2009; dated November 30, 2009; dated December 23, 2009; dated January 13, 2009; dated February 24, 2010; dated March 19, 2010; and dated April 30, 2010.
• It paid for assessment fees and fees for form completion, but not for the treatment itself in the following plans: dated May 10, 2010, and dated May 17, 2010.
• It denied the plan dated July 12, 2010, but provided no explanation of benefits.
• It denied the following treatment plans and provided explanations of benefits: dated August 3, 2010; dated August 11, 2010; dated August 20, 2010; dated August 30, 2010; dated September 8, 2010; dated September 17, 2010; and dated September 27, 2010.
• For the treatment plans dated August 3, 11, and 20, 2010, Belair paid what appear to be amounts for assessment fees. However, the explanation of benefits does not list the amounts.

Belair paid $37,098.21 in expenses to Osler in Ms. Green’s case within the first eight months after the motor vehicle accident.² Sometime in May 2010 Belair began refusing to pay for the treatment requested on Ms. Green’s behalf by Osler.

Credibility

In arbitration hearings an applicant’s credibility is vital, especially so when there are competing medical opinions. As stated in Faryna v. Chorny:³

“The credibility of interested witness [sic], particularly in cases of conflict of evidence, cannot be gauged solely by the test of whether the personal demeanour of the particular witness carried the conviction of the truth. The test must reasonably subject his story to an examination of its consistency with the probabilities that surround the currently existing conditions. In short, the real test of the truth of the story of a witness in such a case must be its harmony with the preponderance of the probabilities which a practical and informed person would readily recognize as reasonable in that place and in those conditions.”

I find that Ms. Green was not a credible witness at this hearing. Her claims regarding her need for treatment are not believable and lack consistency. I find that the medical treatments claimed on Ms. Green’s behalf by Osler were not reasonable and necessary.

Ms. Green had a history of high blood pressure, diabetes, anxiety, and panic disorders prior to the motor vehicle accident. She was a recipient of benefits from the Ontario Disability Support Plan prior to the accident and has been receiving the benefits since 1998. At the time of the accident she weighed 280 pounds and was considering undergoing gastric bypass surgery to aid in her weight loss goals.

She claims to have had a slip and fall accident earlier in 2009, but that the groin and leg impairments that she suffered in that accident had resolved. She claims to have had no impairments and felt generally fine at the time she was involved in the September 2009 motor vehicle accident.

Ms. Green was able to go home without the aid of an ambulance immediately after the motor vehicle accident in September 2009. Her evidence is that a tow truck operator towed her car away and that neither the police nor an ambulance attended at the scene. She claims that the morning after the accident she felt pain in her neck, and down her shoulders to her back. Her leg also hurt and she suffered headaches. She claims she could barely move her left arm. Any lifting hurt her and in the beginning she could not shower by herself and could not do dishes. She claims she could not drive for a while because she could not check her blind spot. In evidence, she stated that for four months after the accident she had to sit on a stool when showering.

She testified that after the motor vehicle accident, she went to see Dr. Choe, who had been her family doctor since 1993. She claims that he prescribed medications for pain and recommended physiotherapy. I reviewed Dr. Choe’s clinical notes and records⁴ and they indicate that prior to the September 2009 motor vehicle accident Ms. Green attended on June 23, 2009, because of a slip and fall accident. The first notation of Ms. Green’s visit to Dr. Choe after the motor vehicle accident is September 22, 2009. There is no mention of the motor vehicle accident in the notes, or of a prescription for pain medication, or any other indication that Dr. Choe knew of the accident that occurred two days earlier.

Ms. Green testified that in addition to seeing her family doctor on September 22, 2009, she also went to Osler. She did not know of Osler prior to the accident, yet she went to both her family doctor and Osler on the same day. At the hearing, Ms. Green stated that she could not remember who told her about Osler. However, in Dr. Doron’s insurer examination report,⁵ Ms. Green stated that she went to Osler on the advice of the tow truck operator who attended at the scene of the motor vehicle accident.

Dr. Choe’s notes reveal that Ms. Green went to see him again on October 1, 2009, for a blood test and again on November 16, 2009. In Dr. Choe's notes for these two visits, there is no mention of the motor vehicle accident. There is correspondence in Dr. Choe’s file addressed to Immigration Canada. The letter mentions diabetes, hypertension, asthma, sleep apnea, and morbid obesity, among Ms. Green’s impairments. The letter does not mention the motor vehicle accident or any impairments relating to it.

On December 9, 2009, Dr. Ashwani Choudhry assessed Ms. Green using an exercise Cardiolite stress test. Dr. Choudhry's notes for the visit indicate that Ms. Green was able to walk for four minutes on Bruce protocol achieving 97% of target heart rate. Ms. Green stopped the test due to fatigue. There is no mention in the notes that Ms. Green stopped because of impairments arising from the motor vehicle accident that she has described as particularly debilitating.

On December 23, 2009, Dr. Choe referred Ms. Green to Dr. Teosar Bhesania for a cardiac evaluation. Dr. Bhesania’s notes for the visit refer to Ms. Green’s then-current history as follows: "one month ago had history of chest pain and left arm pain. Went to emergency room and had investigations with Dr. Choudhry. Currently on disability for panic attacks." Dr. Bhesania’s consultation is three months after the motor vehicle accident, yet the notes do not mention the accident.

There are many entries in Dr. Choe’s file for Ms. Green where she was referred to specialists. The notes refer to bypass surgery, insomnia, foot issues, chest pain, and back pain after falling down stairs, among other issues. None of the notes mention that, because of a motor vehicle accident, Ms. Green suffered impairments that would require her to sit on a stool to shower. None of the notes mention the motor vehicle accident in any way.

Ms. Green did not call Dr. Choe to give evidence at this hearing. She did not call any medical witnesses.

I find that Ms. Green is not a credible witness and her story is not consistent with her claims for benefits. I find that she did not suffer impairments in the accident that would entitle her to the medical benefits she claims.

It is implausible that Ms. Green suffers from the impairments she alleges, yet she did not tell her regular treating physician about the motor vehicle accident during the entire period for which she claims benefits. It is implausible that Ms. Green underwent gastric bypass surgery in 2012, yet did not advise her medical practitioners about what she claims were significant impairments arising out of the motor vehicle accident. It is also implausible that Ms. Green still has back pain, shoulder pain, and arm pain, and claims that she has had injections for this pain, yet there is no mention in her medical records of this treatment.

Medical Evidence

In support of her claim for medical benefits, Ms. Green relies primarily on a Functional Abilities Examination by Dr. Larry Frydman,⁶ a chronic pain assessment by Drs. Shievitz and Grossi,⁷ and a follow-up in-home assessment by Dr. Shteynberg, dated August 16, 2010.⁸

Dr. Frydman’s report recommends that Ms. Green should continue participation in an appropriate rehabilitation program and that supportive care is necessary to prevent her regression. Dr. Frydman recommended assistive devices for Ms. Green.

Drs. Shievitz and Grossi diagnosed Ms. Green with chronic pain and observed that she had withdrawn socially and her physical capacity was insufficient to pursue work, family, or recreational needs. Their assessment declared that Ms. Green would not be able to return to her pre-accident function level. They recommended that she would benefit from a multi-disciplinary chronic pain program.

In August of 2010, Dr. Shteynberg noted only a 20% improvement in Ms. Green’s low back pain and neck pain. At eleven months after the motor vehicle accident, Dr. Shteynberg stated that Ms. Green suffered from pain chronicity and restricted range of motion in her lower back and cervical spine.

Belair ultimately terminated Ms. Green’s medical benefits on the strength of Dr. Thomas Doron’s assessments.⁹ Ms. Green asserts that Dr. Doron’s reports should carry little weight as they are self-serving and contradictory.

I prefer Dr. Doron’s reports over the reports Ms. Green submitted into evidence.

I prefer Dr. Doron’s evidence because he noted the inconsistency of Ms. Green’s presentation. That same inconsistency was evident at this hearing. Pain is subjective and medical practitioners rely on a patient’s subjective reports when completing assessments. Ms. Green’s subjective reports to Dr. Doron were of “almost complete limitations”. This was in contrast to objective testing which demonstrated no significant or pathological malady or structural deficiency.

In Dr. Doron’s view, Ms. Green had attended for treatment and had seen little improvement in her lower back and a worsening in some areas of pain including her headaches and anterior thighs. She had seen only modest improvement of one area, which was 20-25% subjective improvement in her neck condition. Dr. Doron stated that Ms. Green’s condition no longer resembled a resolving motor vehicle accident injury. She had chronic pain which was multi-focal and had failed to respond to the normal avenues of care directed towards recovery of motor vehicle accident injuries. He found that the treatment plans proposed for her were not reasonable and necessary because her condition had remained unchanged or with minimal improvement over nearly one year of the same form of treatment. He stated that she demonstrated almost complete limitations, including in her activities of daily living. He stated that clinical findings did not suggest a significant pathological malady or structural deficiency. He opined that a treatment that had been applied for eleven months without significant improvement should be discontinued while another approach or avenue is considered.

Ms. Green’s presentation to Dr. Doron is inconsistent with her presentation to medical practitioners who were not affiliated with Osler and Assessment Direct. She never advised her regular treating physicians about the motor vehicle accident. I find that the information Ms. Green presented to Dr. Doron when he assessed her was not credible.

I attach no weight to the evidence presented by the medical practitioners and assessors at Osler and Assessment Direct. Given her lack of credibility, I draw an adverse inference from the fact that Ms. Green called none of the medical practitioners from Osler and Assessment Direct to address her level of impairment. The reports submitted by the two clinics are not supported by the other evidence in this case.

Reasonable and Necessary Treatment?

Ms. Green claims that a number of the treatment plans that she submitted are “deemed approved” since Belair did not respond to them.

I find that the treatment proposed on behalf of Ms. Green in this case is not reasonable and necessary. No individual from Osler gave evidence to support Ms. Green’s claim for what appears to be an excessive amount of treatment. The only individual who testified at this hearing on Ms. Green’s behalf was Ms. Yan Sun, who has worked in the Assessment Direct collections department for three years and ten months. She had nothing to say about Osler and testified that she knew nothing of Ms. Green’s medical condition.

Ms. Green testified that her visits to Osler lasted 45 minutes to one hour. She did not need to make appointments and she could decide when she would attend. She does not remember how often she was assessed. She was assessed for acupuncture, yet her evidence was that she feared needles and acupuncture was never provided. Invoices list counseling sessions; however, her evidence is that she could not recall if she was ever counseled on the therapies. An accounting summary put into evidence¹⁰ lists four hours of services provided during one visit. In contrast Ms. Green states that she only attended Osler for one hour each visit. Further, the invoice lacks particularity and the author was not available to cross-examine.

In this case I find that Ms. Green has failed to provide evidence that Osler actually provided the services she claims. She presented a sign-in sheet from Osler with entries from September 2009 to September 2010.¹¹ The entries suggest that Ms. Green attended at Osler 167 times over the period. I am not persuaded that Ms. Green attended for this treatment. No medical practitioner gave evidence on her behalf that the treatment was necessary or that she attended for the treatment. There are inconsistencies in Ms. Green’s evidence about how much treatment was provided and when the assessments for the treatments occurred.

Given the lack of corroboration of her alleged impairments by any medical practitioners outside of Osler or Assessment Direct, I find that on a balance of probabilities, Ms. Green did not attend for this treatment. Accordingly, since Ms. Green has not proved that the services were provided, the amounts claimed under the treatment plans are not “deemed approved” and are not payable.

$1074.74 for an In-Home Follow-Up Assessment at Assessment Direct, dated March 2, 2010

An insurer is obligated to pay for the reasonable fees for an assessment or examination that is reasonably required in connection with a benefit.

Assessment Direct submitted an application for a Follow-Up In-Home assessment, dated March 2, 2010.¹² Belair never responded to the application. Dr. Mikhail Shteynberg completed the Follow-Up In-Home assessment report, dated August 18, 2010.¹³ Ms. Green asserts that since Belair did not respond to the application for the assessment, and the assessment was conducted, that the expense is “deemed approved” and therefore payable.

I find that this expense is not payable. Ms. Green has not persuaded me that the assessment was reasonable and necessary, or that Dr. Shteynberg actually conducted the assessment.

First, I find that the assessment was not reasonable or necessary because Ms. Green was not as impaired as she presented to assessors.

Second, in giving evidence, Ms. Green stated that two assessors went to her home. The reports of at least three assessors are in evidence, all of whom claim to have visited Ms. Green at home. The Osler invoice in evidence at this hearing¹⁴ also shows that Ms. Green received over two hours of treatment on the date this assessment ostensibly took place (even though Ms. Green gave evidence that she never attended for treatment for over one hour on any given day). Osler is located some distance away from Ms. Green’s residence. According to the evidence, Ms. Green would have had to leave her home, go to Osler for 2 1/2 hours of treatment, then go back home to have over 2 hours of assessments. Given the impairments Ms. Green claims, this is implausible. In addition, she has no clear memory of the assessment and she did not call the assessor to confirm that he actually conducted this assessment.

I find that Ms. Green has not proved that this assessment was reasonable, necessary or incurred.

Attendant Care benefits in the amount of $814.63 per month from September 20, 2009, to September 19, 2011

The Schedule states that an insurer shall pay an attendant care benefit to an insured person who sustains an impairment as a result of an accident. The benefit shall pay for all reasonable and necessary expenses incurred by or on behalf of the insured person for the services of an aide or attendant. The monthly amount of the benefit shall be determined in accordance with a Form 1.

I find that Ms. Green is not entitled to the attendant care benefits she claims.

Ms. Green bases her claim for attendant care benefits on Dr. Leon Kushnir’s Form 1, dated September 21, 2009.¹⁵ This is the day after the motor vehicle accident and indicates that Dr. Kushnir assessed Ms. Green on that day. When questioned about this at the hearing, Ms. Green stated that Dr. Kushnir did not see her on that date. She claims that he went to her house, but not on that date. Ms. Green did not call Dr. Kushnir as a witness to address the inconsistency.

Belair put into evidence Dr. Kushnir’s disciplinary decision from the College of Chiropractors of Ontario, dated April 19, 2012.¹⁶ In an agreed statement of facts in the decision, an applicant for motor vehicle accident benefits stated that Dr. Kushnir authored a report of an attendant care assessment that she knew nothing about. Dr. Kushnir was reprimanded by the College. I have already made findings about Ms. Green’s credibility. I also have concerns about the large number of treatment plan and assessment requests Osler and Assessment Direct submitted to Belair within the first year of her claim. Given this, I find that the College of Chiropractors report is relevant in Ms. Green’s case and is probative of Dr. Kushnir’s clinical practices. Ms. Green has also not persuaded me, on a balance of probabilities, that Dr. Kushnir assessed her on September 21, 2014, or on any other date. Since I am not persuaded that the assessment occurred, I assign no weight to Dr. Kushnir’s report and recommendations for attendant care.

Even if Dr. Kushnir’s assessment had taken place, the findings and recommendations in the report would have been based on Ms. Green’s subjective reports about her function. Ms. Green’s subjective reports are not supported by the evidence and are inconsistent with what she reported to her family doctor and the specialists to whom her family doctor referred her. For these reasons as well, I assign no weight to Dr. Kushnir’s report, or the other reports from Osler and Assessment Direct.

Ms. Green claims that after the accident her son provided a wide range of attendant care services to her for one year. I draw a negative inference from the fact Ms. Green did not call her son to give evidence on her behalf at this hearing.

I accept the evidence of Dr. Pritchett’s Form 1,¹⁷ which recommends no attendant care. His report also notes that in Ms. Green’s case, formal range of motion testing was not consistent with informal testing.

In considering the totality of the evidence, I find that Ms. Green's claim for attendant care benefits is not reasonable or necessary.

Housekeeping and Home maintenance benefits in the amount of $100.00 per week from September 20, 2009, to September 19, 2011

Ms. Green must satisfy three elements in order to prove entitlement to housekeeping and home maintenance benefits. She must have performed housekeeping and home maintenance activities before the accident. She must suffer a substantial inability to perform those housekeeping and home maintenance activities, as a result of an accident-related impairment. She must also have incurred additional expenses for someone else to perform those activities.

I find that Ms. Green is not entitled to this benefit. I find that she did not suffer a substantial inability to perform her pre-accident housekeeping and home maintenance activities as a result of impairments related to the accident.

Ms. Green submits that following the accident she was unable to do her housekeeping and home maintenance activities because of pain and limitations related to impairments she suffered in the motor vehicle accident. The reports and assessments that are used to address entitlement to benefits rely primarily on applicant self-reports about pain and function limitations. I have already addressed Ms. Green’s credibility. Again, I find that her claims of limitations related to her ability to perform her housekeeping and home maintenance activities are not supported by the evidence. I assign no weight to the assessments and disability certificates prepared by Osler and Assessment Direct. The forms all have long lists of impairments, with some inconsistencies between the assessments and the disability certificates. Some of the assessments Ms. Green submitted claim that she was progressing,¹⁸ while others remarked that she had not progressed.¹⁹ The impairments noted in the forms are not supported by the evidence and Ms. Green did not call any assessors to give evidence about the nature of the impairments she claims.

Most tellingly, Ms. Green claims that her son provided housekeeping and home maintenance services for her after the accident, yet she did not call him to give evidence at the hearing. I draw a negative inference from this fact.

I find that Ms. Green has not proved that she is entitled to housekeeping and home maintenance expenses.

Special Award

If an arbitrator finds that an insurer has unreasonably withheld or delayed payments , the arbitrator, in addition to awarding the benefits and interest to which an insured person is entitled under the Schedule, shall award a lump sum of up to 50% of the amount to which the person was entitled at the time of the award together with interest on all amounts then owing to the insured (including unpaid interest) at the rate of 2% per month, compounded monthly, from the time the benefits first became payable under the Schedule.

Ms. Green has not presented evidence to persuade me that Belair improperly terminated her benefits or did not properly assess her claims for benefits. Therefore, I find that a special award is not warranted in this case.

EXPENSES:

The parties made no submissions on expenses. They are encouraged to resolve the issue. If they are unable to do so, they may schedule an expense hearing before me according to the provisions of Rule 79 of the Dispute Resolution Practice Code.

December 18, 2014

Lloyd (J. R.) Richards Date Arbitrator

ARBITRATION ORDER

Under section 282 of the Insurance Act, R.S.O. 1990, c.I.8, as amended, it is ordered that:

1. Ms. Green is not entitled to a medical benefit in the amount of $11,886.04 for services at Osler Rehabilitation.
2. Ms. Green is not entitled to the cost of examinations at Assessment Direct in the amount of $1074.74 for a Follow-Up In-Home assessment, dated March 2, 2010.
3. Ms. Green is not entitled to attendant care benefits in the amount of $814.63 per month from September 20, 2009, to September 19, 2011, less the amounts Belair has already paid.
4. Ms. Green is not entitled to housekeeping and home maintenance benefits in the amount of $100.00 per week from September 20, 2009, to September 19, 2011, less the amounts Belair has already paid.
5. Ms. Green is not entitled to a Special Award.

December 18, 2014

Lloyd (J. R.) Richards Date Arbitrator

Footnotes

1. 1The Statutory Accident Benefits Schedule - Accidents on or after November 1, 1996, Ontario Regulation 403/96, as amended.
2. 2Exhibit 20, Osler Rehabilitation Accounting Summary
3. 31951 CanLII 252 (BC CA), [1952] 2 DLR 354 (B.C.CA)
4. 4Exhibit 19
5. 5Exhibit 30
6. 6Exhibit 11
7. 7Exhibit 16
8. 8Exhibit 17
9. 9Exhibit 30
10. 10Exhibit 20
11. 11Exhibit 3
12. 12Exhibit 24
13. 13Exhibit 17
14. 14Exhibit 20
15. 15Exhibit 6
16. 16Exhibit 27
17. 17Exhibit 29
18. 18Exhibits 8, 17
19. 19Ehibits 11, 12, 13,