Date: 20090129
Docket: T-1239-08
Citation: 2009 FC 99
Vancouver, British
Columbia,
January 29, 2009
PRESENT: The Honourable Justice Johanne Gauthier
BETWEEN:
THE
MINISTER OF NATIONAL REVENUE
Applicant
and
CORY STANCHFIELD
Respondent
REASONS FOR ORDER AND ORDER
[1]
In the
present application, the Minister of National Revenue (the Minister) seeks a
compliance order against Cory Stanchfield pursuant to section 231.7 of the Income
Tax Act, R.S.C. 1985, c. 1 (5th Supp.) (the Act) to provide the
information and documentation listed in the Minister’s request for information
(RFI) sent to Mr. Stanchfield on February 19, 2008.
[2]
Mr.
Stanchfield argues that he did in fact comply with the RFI. He explains that
the alleged inadequacies (referred to in the affidavit of Tove Mills) of the
response of Cory Stanchfield, the taxpayer and respondent in this application
are caused by the Minister’s confusion in attributing to him assets, income and
activities of another, distinct entity whom he characterizes as “Cory Stanchfield,
in his capacity as a natural person acting in his own capacity and for his own
private benefit”. Because this is not the first time similar arguments have
been made by Cory Stanchfield as well as other taxpayers in the Vancouver area, it is worth reviewing
in some detail the arguments presented by the respondent.
[3]
In his respondent
record, Mr. Stanchfield included two affidavits. The first is entitled
“Affidavit of Cory Stanchfield (the Respondent)” while the second one is
entitled “Affidavit of Cory Stanchfield, in his capacity as a natural person
(the Witness)”. In that second affidavit, the affiant states: “Given our
similar names, the same date of birth of March 17, 1971; signature, and mailing
address. It is my intent to clarify this confusion as to the true ownership of
any property and/or activities that are mistakenly assumed to be the
Respondent’s.” Also, at paragraph 7 of the said affidavit, the affiant
indicates that when the Canada Revenue Agency (CRA) agents came to his residence
to serve the respondent, “I answered the door and advised them that I was not
the person they were looking for. And at both times, documents were
dropped before me or were thrown into my private residence before agents walked
away. In both instances, I forwarded these legal documents to the
Respondent” (emphasis added). At the direction of the Court, the signatories
of each affidavit were to be present at the hearing. It quickly became apparent
that there was only one human being involved and that Cory Stanchfield who
appeared and argued the case before me had signed both affidavits himself.
[4]
Having
established that the Cory Stanchfield referred to in the respondent’s record,
the affidavits and the oral arguments under various terms like “natural
person,” “natural person acting in its own capacity and for its own benefit,”
“the taxpayer,” “the Respondent,” etc, has but one body, one mouth, one brain,
one set of hands, and thus is one single human being, one must now review the
argument presented by the said Cory Stanchfield to explain his response to the
Minister’s RFI, in light of the fact that in his affidavit “in his capacity as
a natural person (the Witness)”, he clearly indicates: (1) that he does have a
residence and an address in British Columbia; (2) that he has held a variety of
positions including for example but not limited to president, secretary and
treasurer of several Nevada corporations created by him; (3) that he received
remuneration among other things from Mr. Plotnikoff for what he describes as
“education regarding the teachings of human rights”; and, (4)
that payments received from Mr. Plotnikoff would reference “natural person
compensation and/or consulting in the memo line.”
[5]
At
paragraph 37 of his written submissions, Mr. Stanchfield says that he knows
that he is a person as defined by the Act and that at no point did he argue
that he was not, contrary to what, according to him, is asserted in paragraph 6
of the Minister’s memorandum of fact and law. On that basis, he indicates that
the case law submitted by the Minister that deals with the issue of not being a
person or examining whether the respondent is a natural person or not is
immaterial and irrelevant for this is not his position here in this case.
Rather, he explains in paragraph 38 of his memorandum of fact and law that when
one reviews the correspondence between him and the Minister’s representative,
the question being asked was which person in the definition of “person”
in the Act was the RFI issued to.
[6]
As stated
above, this is far from the first time that persons have attempted to argue
that “natural persons” are not covered within the scope of application of the
Act. In fact this underlying notion has been specifically and thoroughly
canvassed in a number of decisions, to the extent where it can be said today
that such a notion is wholly without merit. Despite this, the respondent
attempts to distinguish each and every one of these cases.
[7]
In Kennedy
v. Canada Customs and Revenue Agency, [2000] 4 C.T.C. 186 (Kennedy),
Justice G. Gordon Sedwick of the Ontario Superior Court of Justice held that “A
“person” in its ordinary meaning includes a human being or a natural person as
well as an artificial person such as a corporation. The primary sense of the
word is a natural person; the secondary sense, an artificial person such as a
corporation” (para. 17). Thus, the Court found that, “the word “person” in a
statute includes both natural persons and corporations” (para. 19) and “a
“person” as defined in s. 248(1) of the Income Tax Act includes both a
natural person and an artificial person.” (para. 21).
[8]
The respondent
attempts to distinguish this seemingly clear determination by arguing that in
that particular case, Mr. Kennedy was arguing he was not a person subject to
the Act because he was a natural person, while here the respondent submits that
he is not a natural person and accepts that he is subject to the Act. The respondent
further submits that Justice Sedwick’s comments could not apply to the case at
bar because they were made in the context of a party advancing an argument on
the exemption of natural persons from the Act while not being, in the eyes of
the respondent, a natural person because of the fact that “he was under a
contract of service and that he was in pensionable employment” (transcript of
hearing, p. 23, line 19-21).
[9]
In M.N.R.
v. Camplin, 2007 FC 183, [2007] 2 C.T.C. 205 (Camplin), Justice
François Lemieux found the respondent, Mr. Camplin, guilty of contempt of Court
for having failed to comply with a compliance order issued by Justice Konrad
Von Finckenstein, in relation with an RFI. Mr. Camplin seemed to argue that he
held two distinct capacities, one which coined in the terms of “legal
representative of the taxpayer” and the other as his “private capacity as a
“natural person” for my own benefit”. Justice Lemieux reiterated the view of
Justice Von Finckenstein to the effect that such a distinction is “meaningless
and without difference” (para. 28) and that the compliance order required Mr.
Camplin to provide information in response to the RFI on all his assets as a
human being. Mr. Camplin’s insistent refusal to provide such information in
relation to what he felt was his private capacity as a natural person resulted
in him being in breach of this compliance order. The respondent here argues
that this case is equally irrelevant as he is not asserting that he is the
legal representative of the taxpayer, he accepts that he is the taxpayer.
[10]
This issue
was also canvassed, this time by the British Columbia Court of Appeal, in R.
v. Lindsay, 2006 BCCA 150, [2006] 3 C.T.C. 146 (Lindsay). Justice
Mary V. Newbury, speaking for the Court, dealt with the submission of Mr.
Lindsay in that case that he was not a “person” under the meaning of this term
under the Act by explaining that:
the ordinary meaning of “person” is a
natural person (including, I would have thought, a “free will, full liability
flesh and blood living man”) and that the purpose of statutory definition is to
extend the meaning to include other specified legal entities as well.
Mr. Lindsay’s position that he is not a “person” for purposes of the Income
Tax Act is simply not tenable.” [emphasis in original, para. 3]
Again, the respondent submits that Mr. Lindsay’s position is
different than his own, in the sense that, again, he does not deny that he is a
person for the purposes of the Act.
[11]
Finally,
the respondent himself attempted to argue before this Court in the course of
another application for a compliance order brought against him by the
Applicant, that he, as a natural person, was not a “person” for the purposes of
the Excise Tax Act, R.S.C. 1985, c. E-15 (M.N.R. v. Stanchfield
(September 26, 2007), Vancouver T-1179-07). Justice Frederick E. Gibson rejects
this proposition, on the basis that “the Respondent is clearly a “person”
within the scope of the definitions “person” and “individual” in section 123 of
the Excise Tax Act” (p. 4). The respondent seeks to distinguish the
result of his very own “first kick at the can” by arguing that he agrees with
the determination of Justice Gibson as he now realizes that he was in fact
before him in his capacity as a taxpayer. He claims that it was counsel for the
applicant that led the Court to believe that he was before the Court in his
capacity as a natural person and it is for this reason that he argued in this
fashion before Justice Gibson.
[12]
It is of
interest to note that, in a decision rendered after the date of the hearing of
the present matter, the respondent was found guilty of contempt of the
above-mentioned Court order. In M.N.R. v. Stanchfield, 2009 FC 72,
Justice Yves de Montigny found that “The distinction drawn by Mr. Stanchfield
between his capacity as a natural person and his capacity to act in some other
way is entirely of his own doing, and is devoid of any support in the case
law.” (para. 27).
[13]
At
paragraph 39 of his memorandum of fact and law, Mr. Stanchfield states:
For greater certainty, the Respondent
does not believe that he is a ‘natural person’ nor does the Respondent believe
that he has some existential capacity. The Respondent believes that he is a “taxpayer”
as defined in the Income Tax Act, and is subject to the Act, and the RFI that
was served upon him via registered mail.
Finally, at paragraph 42, Mr. Stanchfield states that “[t]he
Respondent takes the position that there are reasonable grounds to conclude
that” what he characterises as the Witness and the Respondent are
distinctly separate, namely;
a) Under the Canadian Bill
of Rights, the right of the individual extends to natural persons only, as
verifiable with reference to page 129 in the Canadian Law Dictionary, 4th
Ed., by John. A. Yohis Q.C. and with reference to R. v. Colgate-Palmolive
Ltd. (1972), 8 C.C.C. (2d) 40 (Ont.Co.Ct.).
b) Section 2 of the Canadian
Bill of Rights provides in effect that every enactment, either by
Parliament or a subordinate authority, shall, in the absence of a declaration
to the contrary, be so construed and applied as not to abrogate, abridge or
infringe any of the natural person’s rights and freedoms recognized and
declared in Section .1
c) Section 2 of the Canadian
Bill of Rights renders any statute inconsistent with this fundamental law,
inoperative unless it mentions that it will operate notwithstanding the Canadian
Bill of Rights.
d) If there is a conflict
between the Canadian Bill of Rights and another statute, such as the Income
Tax Act (R.S.C. 1985, c. 1 (5th Supp.)), the Canadian Bill of
Rights must in all cases prevail over the conflicting statute, as
verifiable with reference to page 244 in Elmer A. Driedger’s book, Construction
of Statutes, 2nd Ed., 1983
e) The Income Tax Act
is void of any declaration in a prescribed form required by section 2 of the Canadian
Bill of Rights to operate notwithstanding the Canadian Bill of Rights.
f) The Income Tax Act
(R.S.C. 1985, c. 1 (5th Supp.)) shall be so construed and
applied as not to deprive a natural person of their private property without
due process of law, as verifiable with reference to section 1 and 2 of the Canadian
Bill of Rights.
Mr. Stanchfield concluded his submissions
before the Court by submitting that the fundamental question of law that needs
to be answered by the Court before issuing the requested compliance order is as
follows:
Is a natural
person, as defined in the Canadian Law Dictionary, 4th Ed., by John
A. Yogis, Q.C., acting in their own private capacity for their own private
benefit, directly included within the definition of the word
“person” as defined in subsection 248(1) of the Income Tax Act of Canada?
If yes, then how
does the Court deal with section 2 the Canadian Bill of Rights, where it
clearly expresses, “Every law of Canada shall, unless it is expressly declared
by an Act of the Parliament of Canada that it shall operate notwithstanding the
Canadian Bill of Rights, be so construed and applied as not to abrogate,
abridge or infringe or to authorize the abrogation, abridgment or infringement
of any of the rights or freedoms herein recognized and declared…”, when there
is no notwithstanding clause in the Income Tax Act of Canada? [emphasis in
original]
[14] In short, yes,
a natural person, acting in their own private capacity for their own private
benefit, is directly included within the definition of the word “person” at subsection
248(1) of the Act. This conclusion is not in contradiction with the Canadian
Bill of Rights, S.C. 1960, c. 44 (the Bill of Rights) despite the absence
of a notwithstanding clause or declaration within the Act because there is no
evidence that this act deprives an “individual”, to whom the Bill of Rights
applies, of his or her right to the enjoyment of property without due process
of law.
[15] Further, the respondent’s
attempts to distinguish the case law which has, in the view of the Court,
already fully canvassed this issue must fail. With regards to Kennedy, Justice Sedwick
fundamentally decided that “natural persons” are not excluded from the ambit of
the Act. The distinction that the Respondent attempts to draw in the present
case is a futile one. The difference in the argument presented by Mr. Kennedy
in the above-mentioned case in comparison to the one presented by the respondent
here is that the respondent attempts to convince the Court of the existence of
two separate persons within the same body, one subject to the Act
(characterised here as the “Respondent” or the “taxpayer”) and another exempt
(characterised here as the “Witness” or the “natural person” or “natural person
acting for his own benefit”).
[16] In ruling that Mr. Kennedy was not exempt from the
application of the Act, Justice Sedwick specifically decided that “natural
persons” were directly included in the definition of the term “person”
contained at subsection 248(1) of the Act. Thus, the distinction advanced by
the respondent is immaterial. As will be further explained below, he does not
have two distinct capacities. Further, Justice Sedwick’s determination that
natural persons are included within the definition of the term “person”
contained at subsection 248(1) of the Act is determinative of the argument put
forward by the respondent that “Cory Stanchfield, in his capacity as a natural
person (the Witness)” cannot be subject to the provisions of the Act. In light
of Kennedy, this argument must fail.
[17] Camplin is equally applicable to the case
at bar. The fact that the respondent attempts to distinguish this case by
submitting that he has not argued that he is the legal representative of the
taxpayer but rather has accepted that he is a taxpayer is nothing more than
change in vocabulary that has no legal significance. Mr. Camplin in the
above-mentioned case seems to have argued, in the same fashion as the respondent,
that he had two capacities, one which he characterised as being his “private
capacity as a “natural person” for my own benefit” and the other as his
capacity as “legal representative of the taxpayer”. Here, the respondent
characterises his purported capacities as being (1) as a natural person, and
(2) as a taxpayer. The deletion of the words “legal representative” from the latter
purported capacity does not render this case distinguishable from the one at
bar. The whole notion of their being a second capacity distinct from the one of
a natural person or human being is a pure fiction, one which is not sanctioned
by law. One can describe nothing in any terms one wishes; it still remains
nothing.
[18] As for Lindsay, it is clear that the
reasoning of the British Columbia Court of Appeal equally applies to the case
at bar. Again, the respondent’s argument that his position is fundamentally
different from the one presented to the British Columbia Court of Appeal is
flawed. The fact that the respondent recognizes that one of his purported
capacities is subject to the application of the Act does not alter his argument
that the other, “natural person” capacity is not. The findings of the British
Columbia Court of Appeal on the question of whether or not the Act applies to
“natural persons” are material to the question of whether or not the Act
applies to this second purported capacity of the respondent, the capacity as a
“natural person”. The tweaking of the respondent’s argument to add a capacity
which is, in his view, subject to the Act does not alter the validity of the
Court’s reasoning in Lindsay.
[19] Finally, the attempt by the respondent to convince
this Court that a distinction can be made between the present case and the
findings of Justice Gibson in M.N.R. v. Stanchfield, above, is equally
without merit. This argument hinges on what the respondent says was his own
error as to what capacity he was before Justice Gibson. This argument
inevitably fails because there is no such question as to capacity. One cannot
be in error as to which capacity one is before a Court of law when one has but
one single capacity. As Justice de Montigny held in his decision on the
application for Mr. Stanchfield to be found in contempt, M.N.R. v.
Stanchfield, above, accepting such an argument would be tantamount to
accepting that Mr. Stanchfield has the ability to choose “in what capacity he
acts; this is obviously an untenable proposition, and one that runs afoul of
any tenable interpretation of the Act.” (para. 27). While the act which Justice
de Montigny references here is the Excise Tax Act, above, this comment
readily applies to the Act which is at issue here.
[20] Despite this
Court’s conclusion that the Courts have already provided a clear answer to the
question submitted by the respondent, above, I shall nonetheless provide, in an
abundance of caution, a few additional comments on this matter. The Barron’s
Canadian Law Dictionary,
cited by the respondent in his question, above, defines the term “natural
person” as “a human being that has the capacity for rights and duties”. This
definition is derived from a case of the Manitoba King’s Bench, Hague v.
Cancer Relief & Research Institute, [1939] 4 D.L.R. 191 (Hague).
[21] In this case,
Justice Dysart had to deal with a considerable obstacle facing the plaintiff,
the apparent possibility that the defendant from which it sought to obtain
relief had no legal existence. In the course of his reasoning on the issue,
Justice Dysart explains that:
Persons are of two
classes only – natural persons and legal persons. A natural person is a human
being that has the capacity for rights or duties [thus the definition proposed
by Professor Yogis]. A legal person is anything to which the law gives a legal
or fictitious existence and personality, with capacity for rights and duties.
[para. 12]
[22] The term
“natural person” is but a term, among others, that is descriptive of a tangible
reality, described in a more tangible fashion by the term “human being”. The Dictionary
of Canadian Law
defines the term “natural person” with nothing more than the words “a human
being”. Indeed, nothing more is required to adequately define the notion. As
accurately characterised by Justice Dysart in Hague, a person can be
either natural or legal. When a person is natural, it is a human being.
Therefore, every human being is a natural person.
[23] When one uses
simply the term “person”, one necessarily includes the notion of the human
being, as it is the very essence of the reality represented by this term. This
explains why, in the Act, subsection 248(1) does not specifically mention the
term “human being” in its definition of the term “person”. This is not
necessary given that, as explained by professors Duff, Alarie, Brooks and
Philipps in Canadian Income Tax Law,
“this definition merely expands on the ordinary meaning of the word
“person”” (emphasis added). This is entirely consistent with the approach of
the British Columbia Court of Appeal in Lindsay (see above at para. 10).
There is thus absolutely no doubt that a natural person is directly included
within the definition of the word “person” at subsection 248(1) of the Act.
[24] The question
submitted to the Court by the respondent contains a qualification to the term
“natural person”, in that it asks not only if the definition of “person” within
the Act includes “natural persons” per say but rather natural persons, “acting
in their own private capacity for their own private benefit”. Thus the question
which at the hearing the respondent qualified as being the fundamental
underpinning of this case, that is the question of capacity. Fundamentally,
each individual human being, or natural person, has a legal capacity. As the Black’s
Law Dictionary
makes clear, an “individual” is something which is “[e]xisting as an indivisible
entity” (emphasis added). Cory Stanchfield, the human being or natural person
before this Court, is an individual whose entity is indivisible. He has a legal
capacity but it too is indivisible. He may act in other capacities than that of
his individual capacity but only in such capacities which are recognised by
law.
[25] Hague illustrates
the extent to which one must go to create another such capacity that is
recognised by law. In that instance, the legislature of Manitoba had adopted a Cancer Relief Act, S.M. 1930, c. 1
where at section 2 it was provided that:
There is hereby
created a corporation to be called “The Cancer Relief and Research Institute”
(hereinafter called “the institute”). The Institute shall be a body corporate
and politic, and have perpetual succession, with a corporate seal, and may sue
and be sued, plead and be impleaded in all Court whatsoever.
At first blush, it seems
evident that such an entity has a capacity recognised by law. Justice Dysart,
however, found that it did not.
[26] Despite a
highly convincing use of terms, by the legislature of a province no less, some
of the legal requirements for the creation of a corporation had not been met in
that instance and the institute which had purportedly been created by the
Manitoba legislature and which was now being sued in an action was found to be,
in fact, nothing. In the words of Justice Dysart, the legislature:
can exercise its
creative powers only upon material out of which corporations can be made.
Without such material it cannot create a corporation. It may, like the poet,
“give to airy nothing a local habitation and a name,” but it cannot give to
nothingness a corporate personality with corporate powers. It cannot do the
impossible. The purported creation of the Institute is merely an attempt at the
impossible. [para. 16]
[27] If this is
true for a corporation, purportedly created by a legislature, it even more so
for a natural person. Cory Stanchfield’s attempt to argue before this Court
that his body comprises two persons which act in different capacities is of one
of two things: (1) an inadmissible division of his indivisible entity, or (2)
an attempted creation of a second entity in a fashion which is not recognized
by law, the result of which amounts to nothing in the eyes of the law. It is an
attempt at the impossible and the respondent cannot do the impossible.
Therefore, “Cory Stanchfield (the Respondent)” and “Cory Stanchfield, in his
capacity as a natural person (the Witness)” is but one person, with one single
capacity, whom is directly included in the definition of “person” contained at
subsection 248(1) of the Act.
[28] Thus, natural
persons, whether described as acting in their own private capacity for their
own private benefit or not, are directly included in the definition of “person”
contained at subsection 248(1) of the Act. This is because the qualifying terms
“own private capacity” and “own private benefit” are of absolutely no relevance
in the eyes of the law.
[29] This in no way conflicts with the
provisions of the Bill of Rights. Individuals in Canada are afforded human rights and fundamental freedoms by the Bill of Rights,
one of which is the right to the enjoyment of property. However, this right is
not unconditional, as individuals may be deprived of this right by due process
of law. A notwithstanding clause or declaration would indeed be required in an
Act of the Parliament of Canada by virtue of section 2 of the Bill of Rights if
such Act would “abrogate, abridge or infringe or authorize the abrogation,
abridgement or infringement” the right of an individual to the enjoyment of
property without due process of law. The Act represents the due process of law.
In Kennedy, Justice Sedgwick also explains that:
The rule of law
refers to the supremacy of law over the exercise of arbitrary power […] The Income
Tax Act is a law of general application enacted by an elected legislature.
It does not represent an exercise of arbitrary power. [para. 23]
[30] As such, the Act validly applies to all
persons residing in Canada for any part of a taxation year, regardless of
whether these persons are afforded the protections of the Bill of Rights, or
not. The absence of a notwithstanding clause or declaration in the Act does not
affect the validity and the legality of this situation, which cannot be
described in any other way than representing the “due process of law”.
[31] That said, has Cory
Stanchfield complied with the terms of the RFI sent to him by the Minister on
February 19, 2008? In light of the evidence presented to the Court by Mr.
Stanchfield (see above at para. 4), it is abundantly clear that he has not.
This evidence contains blatant discrepancies with the information provided to
the Minister in response to the RFI. The Court is satisfied that the respondent
was required under section 231.2 of the Act to provide the information
requested in the RFI and that he did not fully comply with this requirement.
The Court is equally satisfied that the information requested is not protected
by solicitor-client privilege. The Court will thus issue the compliance order
requested by the Minister, pursuant to section 231.7 of the Act.
[32] The Minister is seeking
his costs on this application which are quantified at $936. Mr. Stanchfield,
again relying on his untenable legal position, argued that the Court should
take into consideration the fact that he is unemployed. As noted, this is not
the first time that Mr. Stanchfield is involved in proceedings of this nature.
Justice Gibson ordered him to pay the Minister’s costs in his order. There are
no valid reasons for not granting the applicant his costs in this matter. I fix
them at a lump sum of $900.
ORDER
THIS COURT ORDERS that:
1. Cory Stanchfield shall comply with the RFI he received
from the Minister and provide to the CRA officer, acting under the authority
conferred by the Act or other person designated, within thirty (30) days
of the date of this Order the following information:
a) Civic address where Cory Stanchfield currently
resides;
b) Name of all employers for Cory Stanchfield from
January 1, 2005 to the present which is to include all relations where
wages or contract fees were paid as well as where work was done under a
“barter” style agreement;
c) A complete list, including source names,
address and amounts of all other income, gifts, loans or other sources of
income for Cory Stanchfield for the period January 1, 2005 to the present;
d) A complete list of all bank accounts and
investment accounts which is to include any U.S.
domiciled or offshore bank accounts for which Cory Stanchfield has signing
authority for the period January 1, 2005 to the present;
2. The
Applicant is awarded costs against Mr. Stanchfield in the amount of $900.
“Johanne
Gauthier”
FEDERAL COURT
NAME OF COUNSEL AND SOLICITORS OF RECORD
DOCKET: T-1239-08
STYLE OF CAUSE: THE
MINISTER OF NATIONAL REVENUE V. CORY STANCHFIELD
PLACE OF
HEARING: Vancouver, British
Columbia
DATE OF
HEARING: January
12, 2009
REASONS FOR ORDER
AND ORDER: GAUTHIER J.
DATED: January
29, 2009
APPEARANCES:
Ms. Amanda
Lord
|
FOR THE
APPLICANT
Minister of
National Revenue
|
Mr. Cory
Stanchfield
|
FOR THE
RESPONDENT
Self-Represented
|
SOLICITORS
OF RECORD:
Department of
Justice
900-840 Howe
Street
Vancouver,
British Columbia
V6Z 2S9
Fax: (604) 666
-1462
|
FOR THE
APPLICANT
Minister of
National Revenue
|
Cory
Stanchfield
c/o Unit 584
185-911 Yates
Street
Victoria, British Columbia
V8V 4Y9
Fax: (708)
842-9362
|
FOR THE
RESPONDENT
Self-Represented
|