IN THE SUPREME COURT OF OHIO

ACCELERATED SYSTEMSINTEGRATION, INC., et al.

Appellants

CASE NO.: 2007-1100

On Appeal from the Cuyahoga CountyCourt of Appeals, Eighth District

V.

HAUSSER + TAYLOR, LLP, et al.

Appellees

Court of Appeals No.: CA-06-88207

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APPELLEES' BRIEF IN OPPOSITION TO APPELLANTS'MEMORANDUM IN SUPPORT OF JURISDICTION

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RICHARD G. WITKOWSKI (0009839)NICHOLAS J. DERTOUZOS (0071018)Attorneys for AppelleesNICOLA, GUDBRANSON & COOPER, LLCRepublic Building, Suite 140025 West Prospect AvenueCleveland, Ohio 44115-1048Phone: (216) 621-7227

CHARLES LONGO (0029490)Attorney for Appellants25550 Chagrin Boulevard, Suite 320Beachwood, OH 44122Phone: (216) 514-1919

LYNN FISCHMAN UNIMANJOSEPH PATELLAAttorneys for Appellee American ExpressTax & Business450 Lexington AvenueNew York, NY 10017 RL[^D

JUL 17 2007

CLERK OF COURTSUPREME COURT OF OHIO

TABLE OF CONTENTS

Page

TABLE OF AUTHORITIES ........ ............................................................................ ii

APPELLEES H+T AND WIRTZ' POSITION ......................................................... 1

A. THE DISPUTE ................................................................................. 1

B. PROCEDURAL HISTORY .............................................................. 2

1. Joseph Litigation ......................................................................... 2

2. Accelerated I Litigation ............................................................. 3

3. The Present Appeal ..................................................................... 4

OPPOSITION TO APPELLANTS' PROPOSITION OF LAW ......................... 6

COUNTER PROPOSITION ... ......... ... ... ... ... .... ... .. ... .. ..... .. ... .. ... ... 6

A. INVESTORS REIT, GRANT THORNTON, ANDTHEIR PROGENY ........................................................................... 6

B. LIMITED EXCEPTIONS .:............................................................... 8

ARGUMENT . . .......................................................................................................... 10

CONCLUS ION ...............:......................................................................................... 12

CERTIFICATE OF SERVICE ................................................................................. 12

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TABLE OF AUTHORITIES

CASES pase

Aluminum Line Prod v. Brad Smith Roofing (1996),109 Ohio App. 3d 246 ............................................................................................. 7

Investors REIT v. Jacobs(1989), 1,5,6,746 Ohio St.3d 176 .................................................................................................. 8,9,10,11

Beechler v. Touche Ross (1992),81 Ohio App. 3d 354 ............................................................................................... 7

Fritz v. Brunner Cox (2001),142 Ohio App. 3d 664 (5`h District) ....................................................................... 8, 9, 10

Fronczak v. Arthur Anderson (1997),124 Ohio App. 3d 240 ............................................................................................. 7, 9

Grant Thornton v. Windsor House, Inc. (1991),57 Ohio St.3d 158 ................................................................................................... 1,5,6,7,9,10

Gray v. Estate of Barry (1995),101 Ohio App. 3d 764 ............................................................................................. 8, 10

Hater v. Gradison (1995),101 Ohio App. 3d 99 ............................................................................................... 7, 8

In re Enron Corporation Securities,456 F. Supp. 2d 687 (S.D. Tex 2006) .................................................................... 7

Jim Brown Chevrolet, Inc. v. S.R. Snodgrass, A. C. (2001),141 Ohio App.3d 583, at 586-587 ........................................................................... 7, 9

Riedel v. Houser (1992),79 Ohio App. 3d 546 ............................................................................................... 7

Sladky v. Lomax (1988),43 Ohio App. 3d 4 ................................................................................................... 10

TCN Behavioral Health Serv., Inc. v. Clark, Schaefer, Hackett & Co. (2005),unreported, 2005 WL 2979662 ............................................................................... 9, 10, 11

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STATUTES

R.C. 2305.09(D) ................... .................................................................................... 5 , 6, 7, 9

R.C. 2305.11(A) ........................ ...:........................................................................... 6

R.C. 2305.19) ........................................................................................................... 11

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I. APPELLEES H+T AND WIRTZ' POSITION

Appellants fail to raise a substantial constitutional question or show how the decision of

the Eighth District Court of Appeals is one of public or great general interest. Rather, the

underlying Eighth District decision follows the long and widely held precedent of this court set

forth in Investors REIT v. Jacobs (1989), 46 Ohio St.3d 176 and Grant Thornton v. Windsor

House, Inc. (1991), 57 Ohio St.3d 158. Those cases established a four year statute of limitations

for accounting malpractice claims and prohibit application of the discovery rule to extend the

statutory period for these cases. In this case, the appellate court affirmed the trial court's decision

which held that appellants failed to timely refile their claims after voluntary dismissal.

Appellants now seek to overturn the well established Investors RE'IT and Grant Thornton

precedent, due to their own dilatory mistake, by advocating a "delayed damages theory." There

is no dispute that the alleged malpractice was discovered in 2000. Appellants timely sued for the

malpractice in 2001. After dismissal by the court, appellants sued again in 2002 and then

voluntarily dismissed their claims in 2003. Appellants refiled their claims for a third time in

2005 almost two years after voluntary dismissal. Both the trial court and the court of appeals

held that appellants failed to timely refile their claims.

Appellants had ample time to prosecute their allegations and have no one to blame but

themselves for the failure to timely refile claims that were twice dismissed. This court should

not overturn widely followed precedent to provide appellants with a third bite at the apple.

A. THE DISPUTE

Appellees Hausser + Taylor, LLP and Carl Wirtz, CPA (collectively "Hausser") hereby

set forth their opposition to Ohio Supreme Court jurisdiction over this dispute. The appellants

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are Accelerated Systems Integration, Inc., Accelerated Systems Integration, Inc. ESBT and

Michael Joseph (collectively "ASI").

ASI's claims arise from services Hausser provided to non-party MRK Technologies, Ltd.

("MRK"), a partnership between appellant Joseph and non-parties Michael and Diane Kennedy

("Kennedys"). Hausser was MRK's financial statement auditor. In October 1999, Joseph and

the Kennedys ended their partnership and agreed to divide MRK's assets. On October 12, 1999,

Joseph and the Kennedys executed a separation agreement that provided for the division of

MRK's assets. As MRK's auditor, Hausser was engaged to perform a bonus calculation pursuant

to the separation agreement and based on the audited financial statements.

Hausser's bonus calculation was performed after its audit for MRK's 1999 year end was

completed in early 2000. Hausser's calculations indicated that MRK overpaid Joseph's 1999

bonus by approximately $1 million. Joseph immediately objected to Hausser's calculation

andthe dispute was referred to arbitration pursuant to the terms of the separation agreement.

Joseph and the Kennedys each retained third party "expert" accountants to perform independent

bonus calculations. Joseph hired Joseph Kirgesner, CPA ("Kirgesner"). The Kennedys hired

Robert Brlas, CPA. A third expert accountant was retained through Judge Nancy McDonnell to

ultimately resolve the bonus calculation dispute. Accordingly, Hausser's initial calculation had

no impact upon the final resolution of the claim.

B. PROCEDURAL HISTORY

1. Josenh Litigation

The present appeal arises from refiled claims. Michael Joseph first asserted these claims

against Hausser through a third-party complaint in the matter captioned American Express Travel

Related Services vs. Michael Joseph, et al., Cuyahoga Court of Common Pleas, Case No.

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425480, Judge Ann Mannen ("Joseph Litigation"). On December 18, 2000, while the arbitration

relating to the bonus calculation was pending, American Express Travel Related Services (the

credit card company) initiated a collection action against Joseph for an unpaid credit card bill.

On March 9, 2001, Joseph moved for leave to file a third-party complaint alleging accounting

malpractice, civil conspiracy, fraud, and tortious interference with business claims specifically

referencing Hausser's bonus calculation. Leave was granted on March 19, 2001. Appellant

Accelerated Systems Integration (Joseph's company) subsequently intervened in the action and

joined in Joseph's third-party complaint against Hausser. On July 3, 2002, Joseph and ASI's

third-party claims against Hausser were dismissed without prejudice on grounds they were not

proper third-party claims. The credit card litigation continued on and was voluntarily dismissed

on June 8, 2005.

2. Accelerated I Litigation

On April 16, 2002, Hausser filed suit against ASI for defamation in litigation captioned

Hausser + Taylor, LLP et al. vs. Accelerated Systems Integration, Inc. et al., Cuyahoga County

Court of Common Pleas, Case No. CV 02 468216 and assigned to Judge Nancy R. McDonnell

("Accelerated I"). MRK Technologies, Ltd. ("MRK") (a party to the present lawsuit) joined in

the defamation suit. However, MRK asserted claims to affirm the arbitration award.

With its answer, ASI asserted accounting malpractice counterclaims against Hausser that

were identical to those asserted in the Joseph Litigation. Thereafter, between May and October

of 2002, ASI submitted five amended answers and counterclaims with motions for leave to file.

On April 17, 2003, the trial court granted ASI leave to file the amended pleadings. ASI's

counterclaims alleged negligence and/or fraud by Hausser in connection with its audit of MRK

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and the related Michael Joseph bonus calculation. These counterclaims are the same claims as

are being asserted in this refiled litigation.

On April 23, 2003, ASI voluntarily dismissed all of its counterclaims against Hausser.

On November 17, 2003, Hausser dismissed its complaint against ASI. Hausser ceased to be a

party to Accelerated I on November 17, 2003. However, MRK continued to prosecute its claims

against Joseph regarding the arbitration of the separation dispute. After challenges to the

arbitration provision in the separation agreement and bonus calculation, the trial court appointed

a neutral accountant, Michael Nesser. Although Joseph originally agreed to Nesser's

engagement, Joseph subsequently objected to the engagement and Nesser withdrew. Joseph

eventually agreed to the appointment of Thomas Campbell of Meaden & Moore to serve as the

neutral accountant. Arbitration proceeded and, based upon Campbell's calculations, Joseph was

required to return to MRK approximately $800,000 of the $1 million in over distributed bonuses.

On April 30, 2004, the Accelerated I trial court affirmed the arbitration award in favor of

MRK/Kennedys, and denied all other claims and motions as moot. The court also found that

MRK/Kennedys were entitled to prejudgment interest. Joseph appealed, alleging errors in the

arbitration and in the appointment of the two neutral accounts. On appeal, the Eighth District

affirmed the trial court's decisions regarding the arbitration award but modified the accrual date

of the award of prejudgment interest. The Eighth District's opinion found that ASI waived its

right to dispute Hausser's report by consenting to the appointment of two subsequent

accountants. Hausser + Taylor v. Accelerated Systesm, 2005-Ohio-1017.

3. The Present Appeal

ASI initiated the present suit on September 27, 2005 ("Accelerated II"). The present suit

was filed almost two full years after ASI voluntarily dismissed Hausser in Accelerated I and over

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four years after it first filed suit against Hausser disputing the bonus calculation. Appellants'

present claims are identical to those previously asserted in the Joseph Litigation and Accelerated

1. The pleadings filed in those cases contain identical allegations arising from the exact same

transaction and occurrence-the dissolution of MRK in 1999 and the bonus calculation.

In Accelerated II, Hausser moved for judgment on the pleadings on grounds that ASI's

claims were barred by the applicable statute of limitations. The trial court granted judgment on

the pleadings in favor of Hausser. The Eighth District affirmed the trial court's decision that

ASI's claims were barred by the statute of limitations set forth in R.C. 2305.09(D) as interpreted

by this court in Investors REIT v. Jacobs (1989), 46 Ohio St.3d 176 and Grant Thornton v.

Windsor House, Inc. (1991), 57 Ohio St.3d 158. The court of appeals noted, however, that its

decision followed established precedent within the Eighth District but conflicted with a handful

of opinions from other districts.

Joseph and ASI now seek to overturn Investors REIT and Grant Thornton's well

established precedent based upon the conflict with other appellate districts. As set forth below,

the conflicting appellate court decisions are distinguishable from the present facts and ASI's

allegations. There is no conflict between any appellate districts in regard to the limitations

period for accountant malpractice where a plaintiff, such as ASI, becomes immediately aware of

the alleged negligence and damages, files suit, voluntarily dismisses, and fails to timely refile.

Because the case as presented fails to present a true conflict between judicial districts, this court

should decline to exercise jurisdiction.

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II. OPPOSITION TO APPELLANTS' PROPOSITION OF LAW

Counter Proposition: The court's decision upholding Investors REIT and GrantThornton and denying the delayed damages theory is proper.

A. INVESTORS REIT, GRANT THORNTON AND THEIR PROGENY

In Investors REIT v. Jacobs (1989), 46 Ohio St.3d 176 and Grant Thornton v. Windsor

House, Inc. (1991), 57 Ohio St.3d 158, this court clearly established that the statute of limitations

for accounting malpractice claims is four years from the date of the negligent act. In Investors

REIT, this court held that accountant malpractice claims are not covered by R.C. 2305.11(A), the

professional malpractice statute applicable to claims against attorneys and doctors. The syllabus

in the Investors REIT sets forth the applicable law:

1 Claims of accountant negligence are governed by the four-year statute oflimitations for general negligence claims found in R.C. 2305.09(D), not by thetwo-year period for bodily injury or injury to personal property set forth in R.C.2305.10, or by the one-year limitations period for professional malpractice claimsin R.C. 2305.11(A).

2.a The discovery rule is not available to claims of professional negligence broughtagainst accountants.

The Investors REIT holding was affirmed by this court two years later in Grant Thornton

v. Windsor House, Inc. (1991), 57 Ohio St. 3d 158. In Grant Thornton, the plaintiff sought to

assert claims relating to an audit completed more than four years prior to filing suit. The court

held:

Our decision in Investors governs Windsor's negligence and malpractice claims. Neitherparty disputes the applicability of Investors to the facts of this case; however, Windsorargues first that Investors is bad law and thus we should reverse it, or, in the alternative,that Investors alters vested substantive rights and thus we may not apply it retroactivelyto Windsor's cause of action. We choose not to reverse Investors, and further, we holdthat Investors poses no retroactivity problem.

In Investors, we held that the four-year statute of limitations in R.C. 2305.09 applied toaccountant negligence actions and that Ohio has no discovery rule to delay the running ofthe statute of limitations in accountant negligence actions.

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In Grant Thornton, this court chose not to reverse Investors REIT and there is nothing of public

or great general interest in the present dispute that warrants revisiting the issue here.

Despite ASI's argument to the contrary, the decisions in Investors REIT and Grant

Thornton have been widely relied upon and followed by both state and federal courts for over 15

years. See, e.g., Beechler v. Touche Ross (1992), 81 Ohio App. 3d 354; Riedel v. Houser (1992),

79 Ohio App. 3d 546; Hater v. Gradison (1995), 101 Ohio App. 3d 99; Aluminum Line Prod. v.

Brad Smith Roofing (1996), 109 Ohio App. 3d 246; Fronczak v. Arthur Anderson (1997), 124

Ohio App. 3d 240; In re Enron Corporation Securities, 456 F. Supp. 2d 687 (S.D. Tex 2006).

An electronic citation search reveals that Investors REIT and Grant Thornton have been

followed in well over one hundred cases. Many of those cases have considered and rejected the

delayed damages theory that ASI now advocates. For example, in.Iim Brown Chevrolet, Inc. v.

S.R. Snodgrass, A.C. (2001), 141 Ohio App.3d 583, at 586-587,1 the Eleventh District Court of

Appeals recently stated:

The Supreme Court further held that '[t]he discovery rule is not available to claims ofprofessional negligence brought against accountants.' Investors REIT, at paragraph two ofsyllabus. The Supreme Court reasoned that '[t]he General Assembly has not adopted adiscovery rule applicable to general negligence claims arising under R.C. 2305.09. Thiscourt will not interpret R.C. 2305.09 to include a discovery rule for professionalnegligence claims against accountants arising under R.C. 2305.09 absent legislativeaction on the matter.' Id. at 182, 546 N.E.2d at 212.

The decision in Investors REIT has been expanded to apply to other professions as well.

In Hater v. Gradison Div. of McDonald & Co. Securities, Inc. (1995), 101 Ohio App.3d 99, 110-

111, the First District Court of Appeals applied Investors REIT to claims for broker-dealer

negligence by investors. As with ASI, the plaintiff investors argued for a more lenient delayed

damages theory. The Hater court rejected the argument stating:

1 Discretionary appeal denied in.Iim Brown Chevrolet v. S.R. Snodgrass, A.C. (2001), 92 OhioSt.3d 1450 (TABLE, NO. 01-881).

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The controlling law on this issue is, we believe, set forth in REIT One. By holding thatthe statute of limitations began to run 'when the allegedly negligent act was committed,'the court in REIT One, in our view, meant exactly that: the date upon which the tortfeasorcommitted the tort, in other words, when the act or omission constituting the allegedprofessional malpractice occurred. Regardless of its validity or support in the commonlaw of torts, the delayed-damage theory cannot, we believe, be used to circumvent theclear holding of REIT One by resurrecting the discovery rule in a different analyticalguise.

B. LIMITED EXCEPTIONS

ASI attempts to correct its mistake in failing to timely refile by overturning widely held

precedent. ASI's cites only two cases that have distinguished this court's holding in Investors

REIT and Grant Thornton and applied the delayed damages analysis. The first is the Sixth

District's opinion in Gray v. Estate of Barry (1995), 101 Ohio App. 3d 764. In Gray, the

appellate court acknowledges the controlling nature of Investor REIT:

As an intermediate court, .we are bound to follow the pronouncements of the SupremeCourt of Ohio when that court has addressed an issue. In this instance, the SupremeCourt has held that, except for fraud or conversion, no discovery rule applies foraccountant malpractice cases. Investors REIT One v. Jacobs (1989), 46 Ohio St. 3d 176,546 N.E. 2d 206, paragraph two of the syllabus; Thornton v. Windsor House, Inc. (1991),57 Ohio St. 3d 158, 160, 566 N.E. 2d 1220, 1222-1223.

However, the court of appeals went on to espouse the delayed damages theory in favor of the

plaintiff. Gray involved claims that the accountant failed to file a requisite tax return form in

1988. The IRS levied its penalties in 1993 and the court held the statute ran from that date.

The second case relied upon by Joseph to establish a conflict is the decision by the Fifth

District in Fritz v. Brunner Cox (2001), 142 Ohio App. 3d 664 (5" District). As in Gray, Fritz

extended the four year statute of limitations applicable to accounting malpractice only for claims

for the negligent preparation of tax returns. The Fritz court reasoned that "neither the syllabus of

Investors REIT One nor the syllabus of Grant Thornton specifically address the applicability of

the "delayed-damages" theory advocated by appellants." Id.

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We are cognizant of the fact that other courts, in interpreting and applying Investors REITOne, would find that appellants' complaint against appellees for accountant negligencewas time-barred, since it was not filed within four years after the alleged negligent actwas committed, which, in this case, was the filing of appellants' 1994 federal income taxreturn on September 14, 1995. However, that interpretation of Investors REIT One wouldlead to an illogical and inequitable result, namely, that appellants' claims againstappellees would be time-barred before appellants' damages even manifested themselves.

***

Likewise, we find Investors REIT One distinguishable from the case sub judice, since theissue in this matter is when appellants' cause of action accrued, not the discovery ofappellants' injury. In short, we find that appellants' complaint was not barred by the four-year statute of limitations set forth in R.C. 2305.09(D), since appellants' cause of actionfor accountant negligence did not accrue until appellants suffered damages on August 13,1998.

The court of appeals decision in Fritz was appealed to this court on the same basis as ASI. This

court denied jurisdiction. Fritz v. Bruner Cox (2001), 93 Ohio St.3d 1418 (TABLE, NO. 01-

1183). Jurisdiction was also denied in Jim Brown Chevrolet, 92, Ohio St. 3d 1450, cited above.

ASI's assertion on pages 5 and 12 of its brief that "The Second, Sixth, and Ninth District

Courts have likewise held in accordance with the Fifth District Court of Appeals decision in

Fritz...and applied the delayed damages rule..." is mistaken. The Second District case, TCN

Behavioral Health Serv., Inc. v. Clark, Schaefer, Hackett & Co. (2005), unreported, 2005 WL

2979662, followed Investors REIT stating,

While the results of such a holding may seem harsh, especially in cases where damagesdo not manifest themselves until after the statute of limitations has run, neither theSupreme Court nor the legislature has altered the broad and explicit language of Investorsor Grant Thornton. Fronczak v. Arthur Andersen, L.L.Y. (1997), 124 Ohio App.3d 240,245, 705 N.E.2d 1283.

TCN involved claims of accountant malpractice arising from an audit. Plaintiff medical facility

(TCN) alleged defendant accounting firm failed to discover an overpayment by Medicaid from

1998. Medicaid sought reimbursement and TCN became aware of the malpractice in 2001.

However, TCN did not file suit until 2004. Following Investors, the appellate court found that

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the statutory period began to run from the date of the audit in 1999 and expired in 2003. The

court noted that the statute expired "well over a year from the time of the error's discovery." Id.

The Ninth District case, Sladky v. Lomax (1988), 43 Ohio App. 3d 4 predates and was

effectively rejected by the Investors REIT decision.

III. ARGUMENT

Appellants failure to timely refile their claims for a third time does not warrant

overturning 15 year old Ohio Supreme Court precedent. Regarding the certification of a conflict,

the application of the delayed damages theory by two courts to claims of accountant malpractice

in tax assessment cases does not warrant this court's review. As evidenced by the overwhelming

majority of decisions that follow Investors REIT and Grant Thornton, there is no constitutional

issue or public interest in the court of appeals here.

Although the Eighth District has certified a conflict among the two districts above, the

conflict being certified does not apply to this dispute. In this case, the Eighth District followed

its own precedent and that of Investors R.F.IT and Grant Thornton. The delayed damages theory

has never been recognized in the Eighth District. Moreover, the conflicting decisions in Gray

and Fritz arise from facts that are clearly distinguishable from the present dispute (which does

not involve a delay in the discovery of damages). These cases involve IRS tax assessments made

over four years after the accountant completed his work. The plaintiff taxpayers in those cases

were faced witb a statute of limitations that expired before they knew of their claim. This case

arises from the failure to timely refale known claims for a third time.

There is no dispute that ASI and Michael Joseph objected to Hausser's bonus calculation

when it was completed in 2000. Appellants claimed damages and first filed the present claims

asserting negligence and/or fraud by Hausser in the bonus calculation in the Joseph Litigation on

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March 9, 2001. ASI subsequently claimed damages and sued Hausser on identical claims in

Accelerated I and voluntarily dismissed that suit in 2003. The complaint in this litigation

(Accelerated II) was filed on September 27, 2005, over four years from the date ASI's claims

were first filed and almost two years after Hausser was voluntarily dismissed. Although ASI

could have refiled its Joseph Litigation/Accelerated I claims within one year of voluntary

dismissal pursuant to the savings statute (R.C. 2305.19), it missed its deadline by almost a year.

ASI's failure to refile is virtually identical to the decision in TCN Behavioral where the

damages were discovered well before the statute of limitations expired yet plaintiff failed to

timely file suit. In this case, as in TCN Behavioral, the courts were not sympathetic to plaintiff-

appellant's negligence in filing/refiling a claim. ASI had ample time to file and refile the present

claims. There is no basis in law, fact or equity to allow ASI additional time to refile claims

related to a 1999 bonus calculation completed in early 2000. The decision of the Eighth District

Court of Appeals upholding this court's decisions in Investors REIT and Grant Thornton is

entirely proper and does not warrant further review.

Finally, the facts presented by ASI and Joseph do not allow this court to fashion a

reasonable alternative to Investors REIT. If ASI and Joseph's delayed damages trigger to the

statute is accepted, it will eliminate statute of limitations applicable to accounting malpractice

claims entirely. A plaintiff will only have to allege that it has discovered some previously

unknown element of damages to the statutory time bar.

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IV. CONCLUSION

For the foregoing reasons, this court must decline to exercise jurisdiction.

Respectfully submitted,

RICHARD G. WITKOWSKI (0009839)NICHOLAS J. DERTOUZOS (0071018)Attorneys for H+T and WirtzNICOLA, GUDBRANSON & COOPER, LLCRepublic Building, Suite 140025 West Prospect AvenueCleveland, Ohio 44115-1048Phone: (216) 621-7227Fax: (216) 621-3999Email: witkowskiCcr^nicola.com

CERTIFICATE OF SERVICE

A copy of the foregoing was served via regular U.S. mail, postage prepaid, this -^to^

day of July, 2007, on the following:

Charles V. Longo25550 Chagrin BoulevardSuite 320Beachwood, OH 44122

Lynn Fischman UnimanJoseph A. PatellaAndrews & Kurth450 Lexington Avenue, 15°i FloorNew York, NY 10017

Attorney for Appellants

Attorneys for Appellee American Express

RICHARD G. WITKOWSKI (0009839)NICHOLAS J. DERTOUZOS (0071018)

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