State Tax Commission of Missouri

R & P REALTY / 440 FOREST PARK, )

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Complainant, )

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v. ) Appeal Numbers 05-20162 thru 05-20168

)

ED BUSHMEYER, ASSESSOR, )

ST. LOUIS CITY, MISSOURI, )

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Respondent. )

DECISION AND ORDER

HOLDING

Decision of the St. Louis City Board of Equalization is SET ASIDE. Hearing Officer finds presumptions of correct assessment rebutted. True value in money for the subject property for tax years 2005 and 2006 is set at $33,000,000, commercial assessed value of $10,560,000.

Complainant appeared by Counsel, Jerome Wallach, St. Louis, Missouri.

Respondent appeared by Counsel, Carl W. Yates, III, St. Louis, Missouri.

Case heard and decided by Hearing Officer Maureen Monaghan.

ISSUE

The Commission takes this appeal to determine the true value in money for the subject property on January 1, 2005.

SUMMARY

Complainant appeals, on the ground of overvaluation, the decision of the St. Louis City Board of Equalization. On or about August 15, 2005, Complainant filed their Review of Assessment alleging the following values:

Appeal Number	Parcel Number	Assessor’s Value	BOE Value	Complainant’s Value
05-20162	0905-00-0050-0 2028 Pine Street	$71,250	$71,250	$65,000
05-20163	0496-00-0010-0 1718 Pine Street	$3,500,000	$3,500,000	$2,500,000
05-20164	0895-00-0100-0 105 N. 18^th Street	$27,625,000	$27,625,000	$18,000,000
05-20165	0902-00-0020-0 1900 Pine Street	$2,519,000	$2,519,000	$1,800.000
05-20166	0905-00-0010-0 2008 Pine Street	$149,000	$149,000	$120,000
05-20167	0902-00-0030-0 1901 Chestnut	$383,700	$383,700	$300,000
05-20168	0905-00-0035-0 101 S. 20^th Street	$484,375	$484,375	$400,000
		$34,732,325	$34,732,325	$23,185,000

A hearing was conducted on September 7, 2007, at the St. Louis City Administration Building, St. Louis, Missouri. At the hearing, the Complainant opined the total value of the properties at $5,205,400 and the assessor’s office opined the total value at $33,000,000.

The Hearing Officer, having considered all of the competent evidence upon the whole record enters the following Decision and Order.

Complainant’s Evidence

Complainant submitted the following exhibits:

Exhibit A – Summary Appraisal Report of Ernest Demba, FASA, IFAS, PE, State Certified General Real Estate Appraiser

Exhibit B –Written Direct Testimony of Ernest Demba

Ernest Demba testified at the hearing.

All the exhibits were received into evidence.

Respondent’s Evidence

Respondent submitted the following exhibits:

Exhibit 1 – Appraisal Report of Marty Hilgeman, Missouri State Certified Residential Real Estate Appraiser and Thomas Curran, State Certified General Real Estate Appraiser
Exhibit 2 – Written Direct Testimony of Marty Hilgeman and Thomas Curran

Exhibit 3 – State of Missouri Department of Highway and Transportation Web Info

Exhibit 4 – Certificate of Values for Property filed in St. Louis City

Exhibit 5 – City Analysis

These exhibits were received into evidence.

Martin Hilgeman testified at the hearing.

FINDINGS OF FACT

1. Jurisdiction over this appeal is proper. Complainant timely appealed to the State Tax Commission from the decision of the St. Louis City Board of Equalization.

2. The subject property is located within Downtown City of St. Louis near Union Station and the main Post Office (Ex. A p. 22). The property has good and easy access to major transportation arteries, employment centers and commercial support services (Ex. A p. 22). Subject neighborhood is located within 25 minutes of the airport and is 10 minutes east of Clayton, the County Seat for St. Louis County (Ex. A, p. 22). The subject neighborhood is generally stable with paced growth/re-development throughout and considered to be one of the more desirable City locations (Ex. A, p. 26). The subject neighborhood is located very near Highway 40. Highway 40 is undergoing repairs and improvements (Ex A, p 26).

3. The property consists of a 357,697 square feet of land and is improved with three buildings. The buildings were built between 1884 and 1927 and have undergone renovations throughout their history. The properties are commonly known as the Union Station Plaza Building and Eastern Lot, Western Lot, Blue Cross Building and Garage, and the 18^th Street Garage.

4. The Blue Cross Building is an eight story, 450,000 square foot building built in 1947. The building has 425,000 square feet of net rentable area. The building underwent renovations in 1985 and 1993. The property is in average condition with no functional obsolescence.

5. The Union Station Plaza Building is a six story, 84,000 square foot office building with net rentable area of approximately 72,000 square feet. The improvement was originally built in 1886. It has undergone numerous renovations with the last renovation occurring in the 1980s.

6. The 18^th Street Garage is a four story parking garage built in 1924 with 600 parking spaces serving the Blue Cross Building.

7. There are two surface parking lots with approximately 480 parking spaces.

8. There was no evidence of new construction and improvement from January 1, 2005, to January 1, 2006.

9. The evidence on the whole record rebuts the presumptions of correct assessment and establishes true value in money (fair market value) of the subject property on January 1, 2005, was $33,000,000, assessed value of $10,560,000.

CONCLUSIONS OF LAW AND DECISION

Jurisdiction

The Commission has jurisdiction to hear this appeal and correct any assessment which is shown to be unlawful, unfair, arbitrary or capricious. Article X, section 14, Mo. Const. of 1945; Sections 138.430, 138.431, RSMo. The hearing officer shall issue a decision and order affirming, modifying or reversing the determination of the board of equalization, and correcting any assessment which is unlawful, unfair, improper, arbitrary, or capricious. Section 138.431.4, RSMo.

Presumptions in Appeal

There is a presumption of validity, good faith and correctness of assessment by the County Board of Equalization. Hermel, Inc. v. STC, 564 S.W.2d 888, 895 (Mo. banc 1978); Chicago, Burlington & Quincy Railroad Co. v. STC, 436 S.W.2d 650, 656 (Mo. 1968); May Department Stores Co. v. STC, 308 S.W.2d 748, 759 (Mo. 1958).

The presumption in favor of the Board is not evidence. A presumption simply accepts something as true without any substantial proof to the contrary. In an evidentiary hearing before the Commission, the valuation determined by the Board, even if simply to sustain the value made by the Assessor, is accepted as true only until and so long as there is no substantial evidence to the contrary.

Notwithstanding the provision of Section 138.431.3, RSMo – “There shall be no presumption that the assessor’s valuation is correct,” – the Supreme Court of Missouri has held, “A tax assessor’s valuation is presumed correct.” Snider v. Casino Aztar/Aztar Missouri Gaming Corp., 156 S.W.3d 341 (Mo. 2005). Citing to Hermel, supra; and Cupples Hesse Corp. v. State Tax Commission, 329 S.W.2d 696, 702 (Mo. 1959).

The presumption of correct assessment is rebutted when the taxpayer, or the assessor when presenting evidence of value different from that determined by the Board, presents substantial and persuasive evidence to establish that the assessor’s or Board’s valuation is erroneous and what the fair market value should have been placed on the property. Snider, Hermel & Cupples Hesse, supra.

Standard for Valuation

Section 137.115, RSMo, requires that property be assessed based upon its true value in money which is defined as the price a property would bring when offered for sale by one willing or desirous to sell and bought by one who is willing or desirous to purchase but who is not compelled to do so. St. Joe Minerals Corp. v. State Tax Commission, 854 S.W.2d 526, 529 (Mo. App. E.D. 1993); Missouri Baptist Children’s Home v. State Tax Commission, 867 S.W.2d 510, 512 (Mo. banc 1993). It is the fair market value of the subject property on the valuation date. Hermel, supra.

Market Value

Market value is the most probable price in terms of money which a property should bring in competitive and open market under all conditions requisite to a fair sale, the buyer and seller, each acting prudently, knowledgeable and assuming the price is not affected by undue stimulus.

Implicit in this definition is the consummation of a sale as of a specific date and the passing of title from seller to buyer under conditions whereby:

1. Buyer and seller are typically motivated.

2. Both parties are well informed and well advised, and each acting in what they consider their own best interests.

3. A reasonable time is allowed for exposure in the open market.

4. Payment is made in cash or its equivalent.

5. Financing, if any, is on terms generally available in the Community at the specified date and typical for the property type in its locale.

6. The price represents a normal consideration for the property sold unaffected by special financing amounts and/or terms, services, fees, costs, or credits incurred in the transaction.

Real Estate Appraisal Terminology, Society of Real Estate Appraisers, Revised Edition, 1984; See also, Real Estate Valuation in Litigation, J. D. Eaton, M.A.I., American Institute of Real Estate Appraisers, 1982, pp. 4-5; Property Appraisal and Assessment Administration, International Association of Assessing Officers, 1990, pp. 79-80; Uniform Standards of Professional Appraisal Practice, Glossary; Exhibit A, p. 11; Exhibit 1, p. 17.

Methods of Valuation

Proper methods of valuation and assessment of property are delegated to the Commission. It is within the purview of the Hearing Officer to determine the method of valuation to be adopted in a given case. See, Nance v. STC, 18 S.W.3d 611, at 615 (Mo. App. W.D. 2000); Hermel, supra; Xerox Corp. v. STC, 529 S.W.2d 413 (Mo. banc 1975). Missouri courts have approved the comparable sales or market approach, the cost approach and the income approach as recognized methods of arriving at fair market value. St. Joe Minerals Corp. v. STC, 854 S.W.2d 526, 529 (App. E.D. 1993); Aspenhof Corp. v. STC, 789 S.W.2d 867, 869 (App. E.D. 1990); Quincy Soybean Company, Inc., v. Lowe, 773 S.W.2d 503, 504 (App. E.D. 1989), citing Del-Mar Redevelopment Corp v. Associated Garages, Inc., 726 S.W.2d 866, 869 (App. E.D. 1987); and State ex rel. State Highway Comm’n v. Southern Dev. Co., 509 S.W.2d 18, 27 (Mo. Div. 2 1974).

Burden of Proof

In order to prevail, Complainant must present an opinion of market value and substantial and persuasive evidence that the proposed value is indicative of the market value of the subject property on January 1, 2005. Hermel, Inc. v. State Tax Commission, 564 S.W.2d 888, at 897. Respondent, when advocating a value different from that determined by the original valuation or a valuation made by the Board of Equalization, must meet the same burden of proof to present substantial and persuasive evidence of the value advocated as required of the Complainant under the principles established by case law.

Substantial evidence can be defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. See, Cupples-Hesse Corporation v. State Tax Commission, 329 S.W.2d 696, 702 (Mo. 1959). Persuasive evidence is that evidence which has sufficient weight and probative value to convince the trier of fact. The persuasiveness of evidence does not depend on the quantity or amount thereof but on its effect in inducing belief. Brooks v. General Motors Assembly Division, 527 S.W.2d 50, 53 (Mo. App. 1975). See also, Westwood Partnership v. Gogarty, 103 S.W.3d 152 (Mo. App. E.D. 2003); Daly v. P. D. George Co., 77 S.W.3d 645 (Mo. App. E.D. 2002); Reeves v. Snider, 115 S.W.3d 375 (Mo. App. S.D. 2003).

Complainant’s Evidence

The Complainant presented the testimony and appraisal report of Ernest Demba. The Complainant’s appraiser used the sales comparison approach and the income approach to determine value for the subject property.

Sales Comparable Approach

Complainant’s appraiser divided the properties into two sales: Union Plaza or Station with adjacent surface lots and the Blue Cross Building with its attached garage and the 18^th Street garage. The appraiser relied upon three sales of properties and used the same three sales for the Station Plaza properties and the Blue Cross properties. He found that the sales were “not necessarily comparable, they are just an indication of sales that have occurred in the past few years within the market area.” (Ex. A p. 57).

The gross building area of the comparables fell in a range from 72,796 to 475,212 square feet. The net rentable area for the properties was from 68,500 to 342,660 square feet. The improvements were from 25 to approximately 41 years in effective age. All of the comparables are located in or near the Central Business district within the market area in which the subject would compete if offered for sale. The sales occurred in a time frame from May 2003 to October 2004. The land areas ranged from .77 to 1.78 acres.

The adjusted per square foot sales prices of the three comparables when used with the Station Plaza properties were $12.20, $17.10, $27.15, with an average of $18.82. The appraiser concluded on a per square foot value of $18.63. The adjusted per square foot sales prices of the three comparables when used with the Blue Cross Building Plaza properties were $8.71, $9.77, $11.88, with an average of $10.12. The appraiser concluded on a per square foot value of $10.02. The resulting total value of the property would be $5,599,100.

The appraiser believed the subject properties are negatively influenced due to the nature of the properties and the construction in the area. The appraiser believed that the property value was negatively impacted by the construction on Highway 40 even though there are other highways and routes to the area including the Metro (Tr. 19-25). The property, according to the Complainant’s appraiser, would be difficult to market due to its “campus” properties believing that the properties would have to be sold to one purchaser as an entire unit rather than individual parcels. The appraiser did not find any excess land (Tr. 9, 15, 16, 17, 19, 38, 39-41, 52).

The appraiser, on cross-examination, would not speculate as to why the complainant paid $30,000,000 for most of the parcels and $2,500,000 for the garage in 1992 (Tr. 25).

Income Approach

The Complainant’s appraiser also valued the property using the income approach. The record, through the appraisal and the testimony, fails to provide the underlying information to establish the necessary data to develop an appropriate income approach. An Income approach before the Commission should include the following (12 CSR 30-3.065(B)1):

A. A complete reconstructed income and expense statement for the property under appeal showing economic or market values for the following elements:

(1) potential gross income;

(2) vacancy and collection loss;

(3) miscellaneous income;

(4) effective gross income;

(5) operating expenses; and

(6) net operating income;

B. The capitalization method and rate used including all calculations, a narrative explanation of why the capitalization method is appropriate and an explanation of each element of the selected method;

C. Sources of actual and market expenses, income and capitalization rate figures and verification for each;

D. Sources of actual and market expenses, income and capitalization rate figures and verification for each; and

E. The final indicate value derived from the income approach.

When the Complainant ignores the directives of the Commission rules with regard to a given approach to value it does so at its own risk. A taxpayer does not meet its burden if evidence on any essential element of the case leaves the Hearing Officer “in the nebulous twilight of speculation, conjecture and surmise.” See, Rossman v. G.G.C. Corp. of Missouri, 596 S.W.2d 469, 471 (Mo. App. 1980). Complainant’s exhibits in this appeal have left the Hearing Officer with nothing more than speculation, conjecture and surmise. Such a basis will not support a determination of fair market value as advocated by the Complainant.

The Complainant did not determine potential gross income stating that he would not estimate potential gross income “given current operating status of subject property.” The appraiser claimed that he would start with effective gross income based on actual rents of the property (Ex. A, page 70).

The appraiser used the actual rents of $17.00 for the non-owner rented areas. Appraiser used $10 square foot for the other areas (Tr. 55). The appraiser did not estimate or include income from the parking lots. The appraiser did not know why he did not include that information (Tr. 67-70).

The Complainant’s appraiser calculated a vacancy rate. The appraiser stated that as of January 1, 2005, the Station Plaza properties’ vacancy rate was 30%. In 2006, the rate increased to 70%. The subject’s dramatic increase in vacancy was not explained by the Complainant’s appraiser other than the age and the closing of Highway 40. The appraiser believes this property should be compared with class B and C properties and that the property’s location at the outer edge of the central business district and its close proximity to Highway 40 increases the vacancy potential. However, vacancy rates for similar buildings in 2002 was 16.4 % and was 20% percent last year (Tr. 52).

The appraiser used some market expenses determined from “sources” and some actual expenses. He stated that the expenses were around 70%. The appraiser conceded that owner occupied buildings have higher expense (Tr. 60-66).

In calculating the capitalization rate the appraiser stated that market indicates a range in overall rates from 10.1 to 14%. Appraiser used 14% claiming that the higher rate is warranted given the age and location of the property.

The appraiser used the discounted cash flow method. While the projections to get the subject to the vacancy rate determined by the appraiser may be based upon sound math covering the period from 2005 through 2011, that time period and the possible variance in rental rates and expenses is based too much on speculation and conjecture to be valid for the present appraisal problem. Further, Courts have seldom discussed the discounted cash flow analysis in the most positive of terms. In University Plaza Realty v. Hackensack, 12 N.J. Tax 354 (Tax 1992), aff’d 624 A.2d 1000 (App. Div.), the court stated: “The DCF method, as applied to tax valuation proceedings, is an amalgam of interdependent, attenuated assumptions of limited probative value.”

Using his methodology, the appraiser determined the value of the Station Plaza Building to be $833,228 (Ex. A, p. 84) and the Blue Cross building to be $4,960,364 for a total of $5,793,520 ($5,800,000).

Cost Approach

The appraiser did not use the cost approach stating that for this particular type of property the typical potential buyer would not consider this for an option to build an existing development (Ex. A, p. 87).

Reconciling the Values

Although the Complainant’s appraiser developed the sales approach, the appraiser relied solely on the income approach (Ex. A, p. 87).

In developing his approaches to value, the appraiser often stated that his opinion of certain items was arrived at by years in the market and speaking to people. This does not suffice as the evidence rebutting the presumption of correct assessment and establishing fair market value. The Hearing Officer cannot ignore the lack of essential supporting information in Complainant’s evidence with regard to the attempt to present an income approach to value. Drey v. State Tax Commission, 345 S.W.2d 228, 234-236 (Mo. 1961), Snider v. Casino Aztar/Aztar Missouri Gaming Corp., 156 S.W.3d 341, 348 (Mo. 2005). Tr. 16.

Respondent’s Evidence

The Respondent presented the testimony and appraisal report of Martin Hilgeman. The Respondent’s appraiser looked at all three approaches: the sales comparison approach, the income approach and the cost approach. The Respondent’s appraiser considered the cost approach but did not apply it stating that given the buildings ages and multiple renovations, the depreciation scale would be skewed thereby making the cost approach not reliable (Ex. 1, p. 42).

Excess Land

The Assessor’s office determined that the property has excess land which could be sold and developed. The land in located at 1901 Chestnut, 2008 Pine, 101N 20^th, 2028 Pine, and 2000 Pine and is approximately 144,251 square feet. The assessor used three sales for market comparison purposes and included the sale of the subject property in 1992. The dates of sale are from December 2001 to March 2005. The amount of land ranges from 51,275 square feet to 199,897 square feet. The prices range from 37.52 to 46.22 per square foot. After adjustments the prices range from $28.27 to $31.29. The assessor determined the value to be $27.73 per square foot or $4,000,000.

Income Approach

The Respondent’s appraiser valued the property using the income approach. The record, through the appraisal and the testimony, provided the underlying information to establish the necessary data to develop an appropriate income approach. The appraiser used the direct capitalization method.

Respondent’s appraiser relied upon nine properties for his rental analysis, including the subject property. The per square foot rent rate for these leases ranged from $13.39 to $17.18, including the current rent of $17.00 per square foot for the subject property. The appraiser concluded the appropriate rent to use was the average rent of $15.00 per square foot (Tr. 103). The properties have 497,000 square rentable feet for a potential gross income of $7,455,000. The assessor estimated the parking income (garage, surface parking and event parking) would be $657,600.

The Respondent’s appraiser stabilized the vacancy and collection loss at 20% of potential gross income or $1,491,000 based on subject’s location, depressed demand for class B space in this sub market or Downtown and downtown west. Using comparables, the assessor determined a 19% vacancy rate for the parking areas.

The appraiser also calculated operating expenses. The calculated operating expenses were then compared with BOMA and determined to be appropriate. The appraiser also included reserves for replacements.

The appraiser utilized a direct capitalization approach to using comparable sales in the market to determine the overall rate. The assessor found rates from 7.2% to 10.9%. The assessor also reviewed national investor surveys to estimate an overall rate for the subject property including Korpacz, who reported rates from 6-10%, the average 8.26%. The assessor settled on a rate of 9-10%.

The assessor also conducted a mortgage/equity technique to determine rate. The assessor surveyed local lenders for the loan to value ratios and the financing available. Developing a rate of 9.5%. The assessor concluded on an overall rate of 9.5% and combined it with an effective tax rate of 2.74%.

The appraiser concluded on a value of $28, 700,000 for the improved properties and added in the value of excess land of $4,000,000 resulting in a value of $32,700,000.

Sales Comparison Approach to Value

The assessor’s appraiser divided the properties into 4 sales: Blue Cross Building, Station Building, the excess land, and the 18^th Street Garage. Fifteen sale properties were used by the Respondent’s appraiser in his sales comparison approach with the Blue Cross Building properties. The sales occurred from February 2002 to January 2007. Gross building sizes were from 90,300 to 1,356,917 square feet. Net rentable areas were from 84,154 to 1,273,750. The age of improvements ranged from approximately 5 to 40 years.

The unadjusted price range was from $20.94 to $151.00 per square foot. Adjustments were made for conditions of sale, time, location and physical characteristics. The adjusted per square foot sales prices of the comparables were $41.42 $45.50, $45.90 $46.76, $46.98 47.97 $48.15 49.81 $49.89 $52.89, 53.80 $54.00, $54.74, $55.41, and $55.62. The average adjusted per square foot value was $49.92 and rounded by the assessor $50.00 per square foot.

Four sale properties were used by the Respondent’s appraiser in his sales comparison approach with the Station Plaza properties. The sales occurred from February 2005 to March 2006. Gross building sizes were from 63,000 to 335,723 square feet. The age of improvements ranged from approximately 20 to 40 years.

The unadjusted price range was from $29.79 to $48.30 per square foot. Adjustments were made for conditions of sale, time, location and physical characteristics. The adjusted per square foot sales prices of the comparables were $45.44 to $50.98. The average adjusted per square foot value was rounded by the assessor $48.00 per square foot.

Four sale properties were used by the Respondent’s appraiser in his sales comparison approach with the 18^th Street Garage property. The sales occurred from January 2002 to May 1, 2007. Gross building sizes were from 145,863 to 2,429,259 square feet. The total number of parking spaces ranged from 377 to 7,464. The age of improvements ranged from approximately 2 to 15 years.

The unadjusted price per parking space range was from $8,010 to $18,568. Adjustments were made for conditions of sale, time, location and physical characteristics. The adjusted per space sales prices of the comparables were $5730 to $7603. The mean average adjusted per space value was $6,500 per space. The total value $3,500,000 for the spaces considered (not included in the Blue Cross Building valuation) The property sold in 1993 for $3,500,000.

Total

Blue Cross Building $22,500,000

Plaza $ 4,000,000

Garage $ 3,500,000

Excess Land $ 4, 000,000

Reconciliation of Value

The appraiser concluded that the cost approach was not appropriate in valuating this property. The appraiser, in using the income approach, determined the value to be $32,700,000. The appraiser, in using the sales comparison approach, determined the value to be $34,000,000. The appraiser in reviewing the values concluded on a value of $33,000,000.

ORDER

The assessed valuation for the subject property as determined by the Board of Equalization for St. Louis City for the subject tax day is SET ASIDE. The true value in money of the property as of January 1, 2005, is set at $33,000,000, assessed value of $10,560,000.

A party may file with the Commission an application for review of this decision within thirty (30) days of the mailing of such decision. The application shall contain specific grounds upon which it is claimed the decision is erroneous. Failure to state specific facts or law upon which the appeal is based will result in summary denial. Section 138.432, RSMo 2000.

If an application for review of this decision is made to the Commission, any protested taxes presently in an escrow account in accordance with this appeal shall be held pending the final decision of the Commission. If no application for review is received by the Commission within thirty (30) days, this decision and order is deemed final and the Collector of St. Louis City, as well as the collectors of all affected political subdivisions therein, shall disburse the protested taxes presently in an escrow account, unless previously disbursed to the taxing jurisdictions pursuant to an order of the circuit court under Section 139.031(8), RSMo. If taxes have been disbursed under circuit court order, Complainant may apply to the circuit court having jurisdiction of the cause for disposition of the protested taxes held by the taxing authorities.

Any Finding of Fact which is a Conclusion of Law or Decision shall be so deemed. Any Decision which is a Finding of Fact or Conclusion of Law shall be so deemed.

SO ORDERED October 12, 2007.

STATE TAX COMMISSION OF MISSOURI

_____________________________________

Maureen Monaghan

Hearing Officer

Certificate of Service

I hereby certify that a copy of the foregoing has been mailed postage prepaid on this 12^th day of October, 2007, to: Jerome Wallach, Three City Place Drive, Suite 270, St. Louis, MO 63141, Attorney for Complainant; Carl W. Yates III, Associate City Counselor, 314 City Hall, St. Louis, MO 63103, Attorney for Respondent; Ed Bushmeyer, Assessor, 120 City Hall, St. Louis, MO 63103; Gregory Daly, Collector, 109 City Hall, St. Louis, MO 63103.

____________________________

Barbara Heller

Legal Coordinator