Florida Employment Law Blog : Florida Employment Lawyer & Attorney : Epstein Becker Green Law Firm : Immigration, Discrimination, Labor, FLSA : Serving Miami, Fort Lauderdale, Florida

A plaintiff who alleges that his employer terminated his employment in retaliation for filing a workers’ compensation claim is entitled to proceed to trial, according to a recent decision by the Third District Court of Appeals, Ortega v. Engineering Systems Technology, Inc. (Fla. 3d DCA, January 20, 2010).  The Ortega case provides a good opportunity to explore the contours of section 440.205, Florida’s workers’ compensation retaliation statute.

The plaintiff in the case, Ricardo Ortega, fell off a ladder on October 31, 2006 while working for his employer, Engineering Systems Technology, Inc. Ortega broke his wrist, and the employer’s workers’ compensation carrier was notified. Ortega was put in a “no work” status while he received therapy. Three months after his accident, on February 1, 2007, Ortega’s doctor authorized him to engage in the “limited use of [his] injured hand” with a twenty pound weight restriction. On the same day, Ortega asked his boss, Enrique Borja, if he could return to work. Borja told Ortega the company had no light duty for him and to come back when he had no limitations. On April 12, 2007, Ortega’s doctor released him to work without restrictions. Four days, later, Borja told him, “I don’t have work for you… I removed you from my staff two months ago.” But around the same time, Borja also stated that he would take Ortega back when he was sufficiently recovered.

Borja sued Engineering Systems under section 440.205, Florida Statutes, which provides:

Coercion of employees.--No employer shall discharge, threaten to discharge, intimidate, or coerce any employee by reason of such employee's valid claim for compensation or attempt to claim compensation under the Workers' Compensation Law.

The trial court granted summary judgment to Engineering Systems, and Ortega appealed.

On appeal, the Third DCA ruled that there were genuine disputes of fact as to whether Ortega was fired, or whether he failed to request a return to duty; and whether, if Ortega was fired, it was in retaliation for his pursuit of workers’ compensation benefits. The court rejected the employer’s argument that Ortega’s failure to provide his employer with a Division of Workers’ Compensation Form DWC-4, releasing him to return to work, provides a complete defense to a retaliation claim under section 440.205.

So what can Florida employers learn from the Ortega decision? Perhaps the most important lesson is to do what Engineering Systems and Borja apparently did not do:  adopt a clear policy authorizing the termination of employees who are unable to work for a period of time (e.g. three months), and apply the policy decisively and consistently.  (For employers covered by the FMLA, make sure the policy is compliant with this statute.)  It seems likely that Engineering Systems did not have a clear policy governing such situations. It is clear that Borja was not decisive in terminating Ortega or in consistently delivering his message to Ortega.

Suppose, however, that Borja had told Ortega on February 1, 2007 that in accordance with company policy, his employment was terminated because he had been unable to perform his job for three months. In Pericich v. Climatrol, Inc., 523 So. 2d 684, 685 (Fla. 3d DCA 1988), the Third District Court of Appeals held that section 440.205:

only prohibits the retaliatory discharge of an employee “by reason of” the filing of a workers’ compensation claim. The statute cannot be interpreted to prohibit the discharge of an employee for any reason once the employee has filed or pursued a workers' compensation claim. Employers still retain their traditional right to terminate employees for legitimate business reasons, such as unsatisfactory job performance or excessive absenteeism.

And in Edwards. v. Niles Sales & Service, Inc., 439 F. Supp. 2d 1202, 1230 (S.D. Fla. 2002), a federal court, citing Pericich, held that “[w]ithout question, firing an employee because the employee has been unable to work for approximately three months constitutes a legitimate business decision[.]

So, Borja could have lawfully terminated Ortega on February 1, 2007. If the company’s policy provided for termination after a three-month period of incapacity, and Borja terminated Ortega decisively in accordance with this policy, it is likely that the Third DCA would have upheld the trial court’s summary judgment order. 

The point here is that section 440.205 does not give an employee a right to be restored to his job when he returns from leave from a work-related injury. Nor does it give an employee a right to work in a light-duty capacity.  The statute only gives an employee a right to be free from retaliation because he has filed a workers' compensation claim. These issues can become blurred, as they were in Ortega. But by adopting a clear policy stating that an employee will be terminated after a period of inability to work (for any reason), and applying that policy decisively, employers can avoid costly litigation under section 440.205.            

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A non-disabled applicant for employment can proceed to trial under the Americans with Disabilities Act based on a company’s unlawful pre-employment medical inquiry, according to a recent decision by the Eleventh Circuit Court of Appeals, Harrison v. Benchmark Electronics Huntsville, Inc. (11^th Cir. January 11, 2010). 

The case arose when John Harrison was working as a temporary employee for Aerotek, which assigned Harrison to work at Benchmark Electronics Huntsville, Inc. (BEHI). Harrison has epilepsy and takes barbiturates to control his condition. Harrison applied for permanent employment at BEHI and consented to a drug test.  When his drug test came back positive, his supervisor learned about it and was in the room when Harrison explained his epileptic condition to the medical review officer (MRO). Soon thereafter, his supervisor decided not to extend an offer to Harrison and asked Aerotek not to return Harrison to BEHI. 

Harrison filed a charge with the EEOC, which determined that Harrison was not disabled. Harrison then sued BEHI under the ADA, claiming that BEHI engaged in an unlawful pre-employment medical inquiry under the ADA. The district court granted summary judgment to BEHI. The court ruled that, even assuming Harrison had a right to sue based on a pre-employment medical inquiry, BEHI was entitled to ask whether he had a legitimate use for such medication.

A panel of the Eleventh Circuit Court of Appeals reversed the district court’s decision. At the pre-offer stage, the court noted, an employer may not conduct a medical examination or make inquiries of a job applicant as to whether the applicant is an individual with a disability, or as to the nature or severity of such disability. An employer may only inquire into the ability of an applicant to perform job-related functions. Joining several other circuit courts of appeal, the court held that this prohibition is not limited to disabled applicants. “Allowing non-disabled applicants to sue will enhance and enforce Congress’s prohibition,” the court reasoned. “Moreover, a contrary reading would vitiate [the Act’s] effectiveness.” Quoting an earlier Tenth Circuit decision, the court wrote that “[i]t makes little sense to require an [applicant] to demonstrate that he has a disability to prevent his [potential] employer from inquiring as to whether or not he has [one].”

The court then addressed the merits of Harrison’s claim. First, the court noted that the ADA recognizes an exemption to the pre-employment inquiry rule for drug tests. Not only are drug tests permissible at the pre-offer stage, but so are follow-up questions in response to a positive drug test, such as: “What medications have you taken that might have resulted in this positive test result?” However, disability-related questions are still prohibited. 

The court ruled that under the circumstances, i.e. because Harrison’s supervisor told him that his drug test was positive, because Harrison disclosed his prescription, and because the supervisor was present in the room when Harrison explained his medical condition to the MRO, “a reasonable jury could infer that [the supervisor’s] presence in the room was an intentional attempt likely to elicit information about a disability in violation of the ADA’s prohibition against pre-employment medical inquiries.” The court also ruled that a reasonable jury could infer that the supervisor based his decision not to hire Harrison on information gleaned from an improper medical inquiry.

For employers in the Eleventh Circuit, the Harrison case offers a couple of valuable lessons. First, employers must not make prohibited pre-employment medical inquiries of any applicant, including applicants that are apparently or obviously not disabled. Harrison makes clear that any applicant is a potential plaintiff under the ADA. 

Second, employers must be extremely careful with the handling of information obtained from drug tests. As Harrison illustrates, there is a fine and arguably fuzzy line between permissible follow-up questions following a positive drug test, and impermissible disability-related questions. To avoid crossing this line, employers may wish to consider administering drug tests only after making a conditional offer of employment to applicants. Once a conditional job offer is made, the employer may ask disability-related questions as long as this is done for all entering employees in that job category.   

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The Florida Civil Rights Act prohibits marital status discrimination in employment. i.e. discrimination based on the state of being married, single, divorced or separated.  What it does not do is prohibit discrimination based on the identity or actions of one's spouse. 

That's a pretty simple concept, and it's been the clearly established law in Florida since 2000, when the Florida Supreme Court issued its opinion in Donato v. Am. Tel. & Tel. Co., 767 So.2d 1146, 1155 (Fla. 2000). 

But that didn't prevent the Miami-Dade County Equal Opportunity Board recently from ruling in favor of Hilda Fish, whose employment with Industrial Affiliates, Ltd. was terminated because she married Mr. Fish, one of the operating partners of the business. The MDEOB ruled in favor of Ms. Fish even though the employer had replaced her with another married woman, which seemingly proves that it had no problem with the fact that Ms. Fish was married.

Fortunately for the employer, the Third District Court of Appeals corrected the error, holding that the MDEOB's decision "represents a clear departure from the essential requirements of the law resulting in a miscarriage of justice and is therefore quashed."  In a terse decision, the court noted that the lower court, an appellate panel from the Miami-Dade Circuit Court, had denied review "for reasons unknown."  It makes you wonder, did the MDEOB and the circuit court panel read Donato? 

In any event, the lesson of the Fish decision for Florida employers is clear.  It is perfectly legal to have an anti-nepotism policy that prohibits the employment of relatives or spouses of employees, and to take action against spouses whose employment runs afoul of this policy.  As Donato makes clear, discriminating against an employee because of the actions or identity of the employee's spouse is legal. It is only the state of being married, single, divorced or separated that Florida's ban on marital status discrimination protects against.

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In Florida, absent an employment contract specifying that an employee will be employed for a certain period of time, the employment relationship is "at-will."  This means, generally speaking, that the employee can be fired, or can resign, at any time, for any reason. The employer does not have to have "good cause" to terminate an at-will employee. 

There are numerous statutory exceptions to this general rule.  It  is unlawful to terminate an employee because of the employee's race, national origin, sex, religion, disability, age, or other discriminatory reasons specifically prohibited by statute.  It is also unlawful to terminate an employee because the employee has engaged in protected activity.  Under federal law, this includes engaging in concerted activity with other employees, or complaining about violations of the Fair Labor Standards Act (which governs minimum wage and overtime pay).  Under Florida law, protected activity includes an employee's objection to, or refusal to participate in, a violation of a law, rule or regulation by the employer, or the employee's filing a valid worker's compensation claim. There are other statutory exceptions to the at-will employment rule. This blog post is not intended to cover them all.  Suffice it to say that absent one of these statutory exceptions, employers in Florida are free to terminate at-will employees without having their decisions second-guessed by a court of law. 

But what about compensation, commissions and other benefits that the at-will employee earned prior to termination? Can an employer refuse to pay the terminated employee on the grounds that the employment relationship was at-will? 

The answer is no, and a recent decision by the Second District Court of Appeals illustrates this point. In Patwary v. Evana Petroleum Corp., the plaintiff, Shaifur Patwary, sold a hotel to Evana Petroleum Corporation and its owners ("EPC"), but reached an agreement under which Patwary would manage the hotel for EPC in exchange for a fifty percent share of the hotel's net profits through the pendency of the agreement, and a fifty percent share of the hotel's net proceeds in the event of a sale. When EPC sold the hotel, it terminated Patwary without notice and refused to pay him the proceeds and profits he accrued under the agreement. Patwary sued for breach of contract.

At the trial court level, EPC filed a motion for summary judgment, arguing Patwary's claim was barred because it concerned a breach of contract action brought under an agreement without a definite duration. The trial court agreed and dismissed Patwary's claim.

On appeal, the Second DCA reversed the trial court's decision, holding that "[a]n employer's right to terminate an at-will contract does not entitle the employer to renounce compensation or other benefits that vest while the contract is in force. Quoting the Fourth DCA's decision in J.R.D. Mgmt. Corp. v. Dulin, 883 So. 2d 314, 317 (Fla. 4th DCA 2004), the court noted that it is "only an action for breach of employment that is barred when the contract of employment is terminable at will; other contractual provisions may not be affected by the at-will employment rule."

For Florida employers, the lesson of Patwary is clear:  Despite the fact an employee was employed on at-will basis, the employer must still pay the employee the compensation and other benefits that he earned prior to his termination.  Now, what "earned" means in the case of an employee who gets paid, in whole or in part, by bonuses or commissions, is another issue. But that's the subject of a future post....

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A trial court's decision to admit into evidence a Broward County Civil Rights Division "no reasonable cause" determination was an abuse of discretion and constituted reversible error, according to a recent decision by the Fourth District Court of Appeals. 

The plaintiff in the case, Cameshia Byrd, alleged that her employer, BT Foods, Inc., a Wendy's franchisee, terminated her employment because she was HIV positive. She alleged violations of the Florida Omnibus AIDS Act, section 760.50(3)(b), Florida Statutes, and the Florida Civil Rights
Act, section 760.10(1)(a).  BT Foods asserted that it took Byrd off the work schedule because she failed to produce a doctor's note following an absence from work, and that Byrd never produced a doctor's note and never returned to work. 

At trial, over the objection of Byrd's attorney, the trial court admitted into evidence a "no reasonable cause" determination that had been issued by the Broward County Civil Rights Division.  The BCCRD had determined that BT foods "discharged the Charging Party because she did not produce a note from from her doctor's office or hospital and not because of her medical condition."  Defense counsel highlighted this fact during closing argument, and the jury returned a verdict for BT Foods.

On appeal, the Fourth DCA noted that although the federal public records exception to the hearsay rule included factual findings resulting from an investigation, Florida's public records exception was narrower.  On this basis alone, the determination letter might have been inadmissible.  But Byrd's attorney did not assert hearsay as the basis for his objection at trial.

Instead, Byrd's attorney argued that the probative value of the letters was substantially outweighed by the danger of unfair prejudice.  Rejecting a per se rule on this point, the court held that the admissibility of reasonable cause determinations is an issue best left to the discretion of the trial judge.  Nevertheless, in this instance, the Fourth DCA ruled that the trial court abused its discretion in admitting the determination letter "because the conclusory nature of the BCCRD’s determination letter left it with little probative value when compared to the substantial prejudicial effect it may have had on the jury’s ultimate assessment of Byrd’s credibility and the pivotal determination as to whether Byrd had indeed provided a doctor’s note to her employer."

The Byrd decision highlights the relatively unimportant role that agency determinations typically play at trial.  Whether an agency rules there is "reasonable cause" or "no reasonable cause" (or, in the EEOC's case, that it is "unable to conclude" there was a violation of the statutes), the determination is likely to be inadmissible anyway.  Most courts seem to realize that agency investigations of discrimination complaints are often cursory and their determinations unreliable.  The limited probative value of these determinations is likely to be outweighed by their prejudicial effect on jurors, who tend to assume, erroneously, that an agency has conducted a thorough investigation before issuing its determination.  Lawyers and judges usually know better.  And in all fairness to the agencies, given the number of discrimination charges filed every year, a thorough investigation of every charge is simply not possible. 

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Please join us for this informative seminar. Details below.

Quicksand for Employers:  Labor, Employment and Immigration Law Developments in the First Year of the Obama Administration   WHEN Friday, December 4, 2009 Registration: 8:00 AM Program 8:30 AM - 10:30 AM WHERE Miami City Club Wachovia Financial Center  200 South Biscayne Blvd., 55th Floor Miami, Florida         Presented by: Hector A. Chichoni, Esq., EpsteinBeckerGreen Kevin E. Vance, Esq., EpsteinBeckerGreen Mark J. Beutler, Esq., EpsteinBeckerGreen Join us for a panel discussion by immigration attorney Hector A. Chichoni and labor and employment attorneys Kevin E. Vance and Mark J. Beutler, all of EpsteinBeckerGreen's Miami office.  These panelists will discuss developments in immigration law and labor and employment law during the first year of the Obama Administration. Part I: Immigration law   A new administration and downturn in the economy have contributed to an ever-    changing and challenging year in immigration.   Mr. Chichoni will discuss the following immigration topics: The Obama Administration's immigration initiatives and programs The latest on the Department of Labor's strategy in PERM cases in this economy The trends in U.S. Citizenship and Immigration Services adjudication An H-1B cap analysis and Strategies for Fiscal Year 2011 Recent federal court cases and administrative decisions Responses to U.S. Citizenship and Immigration Services audits and Immigration and Customs Enforcement investigations The impact of continued state legislation Prospects for immigration legislation in the coming year Global immigration trends Part II: Labor and Employment Law Since the Obama Administration came into power, we have seen Congress introduce several employment bills that, if passed, would have a significant effect on business nationwide.  Also, the Department of Labor and the EEOC have already become more active under the Obama Administration.   Additionally, unions heavily supported Barack Obama in his presidential bid, and much of their support hinged on his backing of union-friendly initiatives, most especially the controversial Employee Free Choice Act (EFCA).  A political tug-of-war has left the National Labor Relations Board (NLRB) - the agency that referees labor disputes - deadlocked and unable to resolve some of the thorniest clashes between unions and management.  Since January 2008, the NLRB has had three vacancies and just two members - one from each party.  As a consequence, the Board has spent nearly two years putting off dozens of cases.  President Obama recently appointed three new members who, when confirmed, are expected to forge a new labor policy more hostile to the interests of employers.  Messrs. Vance and Beutler will discuss the following labor and employment law topics: The Lilly Ledbetter Fair Pay Act, which has already been passed and which will breathe new life into previously time-barred employment discrimination claims The Employment nondiscrimination Act, which seeks to include sexual orientation in the federal anti-discrimination law The Balancing Act of 2009 and similar bills that would mandate various forms of paid leave Increased activity and shifting priorities within the Department of Labor in several areas including workplace ergonomics and other employee health and safety initiatives, wage and hour enforcement, and whistleblower protections New appointments to the NLRB and their potential impact on the NLRB's agenda The potential reversal of employer-friendly NLRB decisions The EFCA, including the current political stand-off and the likelihood of a compromise; card check, fast-track union campaigns; mandatory arbitration of employer-union impasse on first contracts; and more stringent penalty provisions Recent pro-union executive orders affecting federal contractors There will be a short question and answer session following the discussion.  View Event Summary and Biographies     Register for Event   If you have any questions, please contact Anneliese Garcia at  305-579-3200 or email agarcia@ebglaw.com   About EBG: Founded in 1973, EpsteinBeckerGreen is a law firm with approximately 350 lawyers practicing in offices in Atlanta, Boston, Chicago, Houston, Los Angeles, Miami, New York, Newark, San Francisco, Stamford and Washington D.C. The Firm’s size, diversity, and as a founding member of the International Lawyers Network (ILN), allow its attorneys to address the needs of both small entrepreneurial ventures and large multinational corporations on a worldwide basis. EpsteinBeckerGreen continues to build and expand its capabilities as a law firm focused on five core practices: Business Law, Health Care and Life Sciences, Labor and Employment, Litigation and Real Estate. For more information on EpsteinBeckerGreen, please visit www.ebglaw.com. For more than three decades, the EpsteinBeckerGreen seminar series has introduced senior executives, general counsel and human resources professionals to cutting-edge issues in nearly every area of business touched by law.

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U.S. Citizenship and Immigration Services (USCIS) today posted an

informational video on its Web site that provides an overview of the agency’s Systematic Alien Verification for Entitlements (SAVE) program. The new video describes the immigration status verification process and explains how federal, state, and local benefit-granting agencies can apply to participate in the program. USCIS encourages agencies to view the video to determine if the SAVE program is appropriate for their immigration status verification needs. The SAVE program is an intergovernmental initiative that assists benefit-granting agencies in determining an applicant’s immigration status. The program ensures that only entitled applicants receive federal, state or local public benefits and licenses. Additionally, SAVE offers eligible agencies an efficient, secure and cost-effective method of immigration status verification. Specifically, the program checks the applicant’s information against millions of federal database records. Currently, more than 300 agencies are enrolled in the SAVE program. The video, along with additional information about the SAVE program, is available at www.uscis.gov/SAVE or by submitting a request to SAVE.help@dhs.gov (write “SAVE Informational Video” in the subject line.

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On October 6, 2009, the Department of Homeland Security (DHS) announced that it will issue a final rule, to be published in the Federal Register on October 7, 2009, rescinding the embattled “No-Match” regulation.  As we have previously reported, DHS is of the opinion that the receipt of a “No-Match” letter provided constructive knowledge to an employer that an employee may not be authorized to work. This rule would have created a “safe-harbor” procedure for employers to respond to “No-Match” letters, thus clearing employers from any knowing hire liability for that worker. 

DHS first announced its intention to rescind the “No-Match” rule on August 19, 2009, through the publication of a proposed rule. This action was the culmination of months-long federal litigation concerning whether or not the rule had been lawfully promulgated and whether or not it was constitutional.

In taking this step, effectively abandoning the litigation, DHS stated as follows: “After further review, DHS has determined to focus its enforcement efforts relating to the employment of aliens not authorized to work in the United States on increased compliance through improved verification, including participation in E-Verify, ICE Mutual Agreement Between Government and Employers (IMAGE), and other programs.”

Employers beware, upon publication of the rule we fully expect the Social Security Administration to begin issuing new “No-Match” letters and DHS will still consider the receipt of a “No-Match” letter as an indicator of unauthorized employment.  Although there will be no “safe-harbor,” employers should have a plan and procedure in place to address the receipt of a “No-Match” letter. Having a proper plan in place not only helps an employer maintain the integrity of its workforce from an immigration perspective, but also assists an employer in meeting its W-4 reporting requirements with respect to Social Security withholdings.

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This should be a great seminar.  Looking forward to seeing you there.

California Employment Law for  Florida Employers   Monday, November 2, 2009 Lunch & Program 12:00PM - 2:00 PM

Miami City Club Wachovia Financial Center 200 South Biscayne Boulevard 55th Floor Miami, FL 33131 ___________________________________________ Presented by:  Angel Gomez, III, Esq., EpsteinBeckerGreen California is home to one of the largest economies in the world, and to one of the world's best-educated and most productive workforces.  Many employers find California to be an essential part of their strategic plan, but are not aware of the specifics of the state's evolving employment laws and policies.   We would like to invite you to a special seminar with Angel Gomez, Esq., a member of Epstein Becker & Green situated in the Firm’s Los Angeles office, concentrating in employment law.  Mr. Gomez will provide tips for preventing and minimizing liability for companies with employees in California.   The average jury verdict in employment cases is nearly $1.4 million It is illegal to require female employees to wear skirts It is illegal to have a "use it or lose it" vacation plan Terminated employees must be paid in full on their last day Transvestites are a "protected class" in some cities Overtime must be paid after 8 hours of work in a day Pregnant employees may take up to seven months of protected leave Releases must contain California-specific language Employees may use one-half of their sick time for family illnesses California’s new disability discrimination law is broader than the ADA Co-workers can be personally liable for unlawful harassment Group insurance premiums may need to be paid indefinitely by the company for someone on workers’ compensation leave Termination of an employee on workers’ compensation leave is risky and complex – even if the employee has been out for a year or more There are important exceptions to many of the above  This lunch session is intended for senior personnel management, as well as in-house counsel, whose advice is sought concerning their California operations.  We will review the specifics of California employment law that may not be well known outside of California, as well as discuss strategic and long-range issues. For example, Mr. Gomez will also discuss: How California juries assess employer termination decisions How to structure terminations to increase your chance of success in California courts What is required before a California court will enforce an arbitration agreement How to avoid having that lawsuit against you decided by a jury ___________________________________________ Mr. Gomez is a graduate of Harvard Law School, and the University of California at Berkeley. He is an experienced speaker and author, including being the management co-author of California Employment Litigation, a widely read treatise on the subject, published by Bancroft-Whitney. He has spoken before such organizations as the National Employment Law Institute, Personnel and Industrial Relations Association, National Employment Law Council, among many others. In an ever-changing California legal environment, increased knowledge can help you to protect against potentially significant liability and improve your company's overall productivity. Please contact Anneliese Garcia 305.579.3200 or agarcia@ebglaw.com with any questions. FEE $30 Please RSVP no later than  Thursday, October 29, 2009 Please respond by clicking one of the buttons below   About Epstein Becker & Green, P.C. Founded in 1973, EpsteinBeckerGreen is a law firm with approximately 350 lawyers practicing in offices in Atlanta, Boston, Chicago, Houston, Los Angeles, Miami, New York, Newark, San Francisco, Stamford and Washington D.C. The Firm’s size, diversity, and global affiliations allow its attorneys to address the needs of both small entrepreneurial ventures and large multinational corporations on a worldwide basis. EpsteinBeckerGreen continues to build and expand its capabilities as a law firm focused on five core practices: Business Law, Health Care and Life Sciences, Labor and Employment, Litigation and Real Estate. For more information on EpsteinBeckerGreen, please visit www.ebglaw.com.  For more than three decades, the EpsteinBeckerGree seminar series has introduced senior executives, general counsel and human resources professionals to cutitng-edge issues in nearly every area of business touched by law.      Having trouble with the link? Simply copy and paste the entire address listed below into your web browser: http://guest.cvent.com/i.aspx?1Q,P1,100FB60D-5EB1-4201-A277-62ACC6E130B5 If you do not wish to receive future emails from Anneliese Garcia please click the link below. Click here

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