HomeMy WebLinkAboutEVINGER AND ASSOCIATES, LLC. (3)INSURANCE NOT ON FILE N-2019-248
K MAY NOT PROCEED
a1_ CLERK OF COUNCIL
DATE: CITY OF SANTA ANA, CALIFORNIA
0: sAPP 0) NOV 14 2019 CONTRACT FOR THE PURCHASE OF SERVICES
�ta PREA Auditing Services —Police Department Jail Facility
his Contract is between SANTA ANA, CA ("City") acting by and through its Police Department
and EVINGER &•ASSOCIATES, LLC ("Contractor") and is made and entered into on this I It day
of November, 2019. This Contract is effective on this date and expires on July 31st, 2020, with
the option for the City to grant up an extension, exercisable by a writing by the City Manager and
the City Attorney, to cover a time period reflective of when all warranties have expired, or the date
Contractor has completed all Services in accordance with the requirements of this Contract, as
determined by the City.
BACKGROUND
All confinement facilities covered under the Prison Rape Elimination Act (PREA) standards must
be audited at least every three years to be considered compliant with the PREA standards, with
one third of each facility type operated by an agency, or private organization on behalf of an
agency, audited each year. These include adult prisons and jails, juvenile facilities, lockups
(housing detainees overnight), and community confinement facilities, whether operated by the
Department of Justice or unit of a state, local, corporate, or nonprofit authority.
This Contractor is familiar with the City's facility and is the auditor used in the City's first PREA
Audit in 2016. The new three-year Federal cycle for PREA Audits begins August 20, 2019. It is
recommended that agencies with one facility, conduct their audit within the first 12 months of each
Federal audit cycle.
The City has indicated a desire to have their on -site audit performed in 2019.
Evinger and Associates, LLC. PREA Auditor Contract Provisions
PREA Auditing Standards.
The Agency and the Auditor shall comply with the requirements set forth in the PREA auditing
standards (28 C.F.R. §§115.401-05). See Attachment 1.
11. Au i or
a) Designated Auditor. The Auditor may employ or partner with other auditors or staff.
However, there shall be one designated Auditor who shall be the responsible auditor for purposes
of this Contract and the PREA auditing standards. The Lead Auditor for this audit is Timothy M.
Evinger, US-DOJ Certified Auditor#P1374.
b) Auditor Staff. In addition to the Lead Auditors, the following individuals may be present
during the on -site portion of the audit to assist the auditor: Clerical/investigative staff of Evinger
& Associates, LLC.
CITY OF SANTA ANA PREA 2019 AGREEMENT WITH EVINGER AND ASSOCIATES
I
c) Auditor Exnenses, The City shall NOT bear any additional fees and expenses the Auditor
incurs in the conduct of the audit.
d) Auditor Fees. The Auditor's fees for the initial audit and any required corrective action process
site visit or travel is as follows: $6,722.. Payment in full within 15 days of the onsite audit.
Contractor will provide the City with an invoice.
Auditor Travel Expenses. The contractor is responsible for their own travel and related expenses.
e) Prohibition on Additional Compensation. The Auditor shall not accept any compensation for
the conduct of the audit not set forth in this Contract.
0 twx Parte Communication. The Auditor shall be permitted to initiate and receive ex parte
communications with the community stakeholders, the PREA Resource Center, the Department of
Justice, inmates, detainees, and residents, and other interested parties.
g) Auditor Responsibility and Authoritly., The Auditor shall have the responsibility and authority
to independently observe, assess, review, and report on the Agency's implementation and
compliance with the National Standards. In order to accurately assess compliance at the facility,
the Auditor shall: conduct an on -site inspection; observe programs and activities; interview
pertinent administrators, professional staff, correctional staff, and contractors; individually
interview a sample of inmates; review a sampling of videotapes from housing units; and conduct
detailed reviews of inmate records and other pertinent documents and reports. The Auditor shall
spend a sufficient amount of time at the facility in order to accurately assess day-to-day operations
and conditions. The Auditor shall be responsible for independently verifying representations from
the Agency regarding facility compliance.
h) Auditing Schedule. The Auditor shall provide the City with a tentative schedule of activities
during any on -site visits at least five days prior to arrival at the facility.
i) Maintenance. Storage, and Return or Destruction of Records. The Auditor shall take all
reasonable steps to safeguard City records and information retained pursuant to the audit. All
electronic files shall be securely password -protected or encrypted. All paper records shall be
maintained in a secure room or building, and within a locked case or cabinet. Upon conclusion of
the Auditor's document retention period, the Auditor shall securely burn, shred, or otherwise
destroy the retained records. The Auditor shall then notify the City, in writing, confirmation that
such documents have been destroyed.
j) Public Statements. Except as required or authorized by the PREA auditing standards; federal,
state, or local law; judicial order; this Contract; or as permitted by the City, the Auditor shall not
make any oral or written public statements — including, but not limited to, statements to the press,
conference presentations, lectures, or articles — with regard to: the status of the City's compliance
or noncompliance with the PREA Standards, or any act or omission of the City or its agents,
representatives or employees.
CITY OF SANTA ANA PREA 2019 AGREEMENT WITII EVINGER AND ASSOCIATES
k) Testimony. Except as required or authorized by the terms of this Contract, or by permission of
the City, the Auditor shall not testify in any litigation or proceeding with regard to the status of the
City's compliance or noncompliance with the National Standards; or any act or omission of the
City or its agents, representatives or employees, unless otherwise lawfully compelled to do so. if
the Auditor is lawfully compelled to provide such information, the Auditor shall promptly notify
the City.
1) Conflict of Interest. The Auditor shall not accept employment or provide consulting services
that would present a conflict of interest with his or her responsibilities under this Contract, with
the PREA auditing standards, or with auditor ethical guidance provided by the PREA Resource
Center or the Department of Justice, including, but not limited to, being employed or retained by
the City for purposes other than PREA auditing during the three-year period prior to the audit, or
during the three-year period subsequent to the audit.
m) Auditor Independence. Neither the City, nor any employee or agent of the City, shall have
any supervisory authority over the Auditor's activities, reports, findings, or recommendations.
n) Termination of the Auditor., The Auditor may be terminated if the City and the Department
of Justice agree and upon good cause shown. Good cause shall include, among other things, any
violation of the PREA Standards; or federal, state, or local law, which reasonably calls into
question the Auditor's fitness to continue serving as the Auditor. This Contract may be terminated
at any time, without cause, upon 30-day written notice by either party. Contractor shall retain a
prorated fee, commensurate with the work performed, prior to the notice.
o) Audit Report Delivers. The Auditor shall provide the audit report to the City head and the
facility superintendent within 30 calendar days of the conclusion of the auditor's on -site visit. If
there are no standards requiring corrective action, the audit report shall be considered final.
Exit Conference: An informal verbal report to City staff shall be given in person at the conclusion
of the Facility visit. This report shall include broad observations about the possible corrective
actions process and any necessary corrective actions that may or should be done immediately. It
is understood this verbal report is not exhaustive and a final preliminary report will be completed
within 30 days of facility visit.
p) Corrective Action Process. If the audit report indicates that corrective action is required, the
Auditor and the City shall work to promptly and jointly develop a corrective action plan toward
achieving compliance with all standards. The corrective action plan shall contain a timeline for
specific minimal remedial measures the City shall take to achieve compliance within a 180-day
corrective action period. The City shall deliver, and the auditor shall review and comment upon,
deliverables provided to the auditor pursuant to the corrective action timeline. The Auditor shall
issue his or her report at the conclusion of the 180-day corrective action period, or earlier if
compliance has been achieved before the end of the corrective action period. Under no
circumstances shall the final report be issued more than 180 days from the start of the CAP.
CITY OF SANTA ANA PREA 2019 AGREEMENT WITH EVINGER AND ASSOCIATES
The Cift
a) Tentative Audit Timeline. The Parties tentatively agree that the initial on -site visit for the
audit will occur during: December 2019.
b) Maintenance of Documentation and Information. Any and all of the documentation
(including electronic documentation) required by the National Standards shall be maintained and
secured by the City. The Auditor is authorized to request, review, and retain all such
documentation prior to, during, and after the on -site visit. Policy documents will be provided and
the applicable passages in policy will be marked, 30 days prior to the on -site visit.
c) Auditor Access. The City shall ensure that the Auditor have access to the facility,
documentation (including electronically -stored infbrmation), personnel, and inmates, consistent
with the auditing standards, until the issuance of the final report.
d) Posting of Auditor Contact Information. The City shall ensure that auditor contact
information, together with a statement of confidentiality, shall be conspicuously displayed in all
inmate housing units of the facility to be audited, for the six -week period prior to the on -site visit.
e) External Advocacy Organizations. The City shall work in good faith to identify and provide
the Auditor with contact information for community -based or victim advocates who may have
insight into relevant conditions in the facility, in order to permit the Auditor to fulfill his or her
obligations under 28 C.F.R. § 115.401(o).
I) Access to External Investigative Personnel., The City shall make best efforts to obtain and
provide information and personnel from external investigative entities relevant to compliance with
the National Standards to the Auditor.
g) Auditor Workspace and Electronics. During any on -site visit, the City shall provide the
auditor with reasonable workspace, and shall permit the auditor to maintain a laptop computer,
mobile telephones, and/or a tablet within that workspace.
h) Publication of Audit Renort. The City shall publish the final audit reports on the City website
within 14 days of receipt of the reports.
i) Retaliation Safeguards. The City agrees that it shall not retaliate against any person because
that person has provided any information or assistance to the Auditor, has tiled or will file a
complaint, or has participated in any other manner in the conduct of the Audit. The City agrees
that it shall timely and thoroughly investigate any allegations of retaliation in violation the National
Standards or this Contract and take corrective action identified through such investigations.
j) Mandatory and Discretionary Reporting Information. The City shall determine whether,
and to what extent, the Auditor is legally a mandatory or discretionary reporter of inmate abuse
in the relevant jurisdiction, and the City shall provide such information to the Auditor prior to the
on -site visit. The City shall also inform the Auditor contact information f'or the entity or entities
that may legally accept any discretionary or mandatory reporting.
CITY OF SANTA ANA PREA 2019 AGREEMENT WITH EVINGER AND ASSOCIATES
k) Primary Points of Contact. The City shall provide the Auditor with a list of primary points of
contact (PPC) with respect to staff of all relevant disciplines within the City and the facility (e.g.,
mental health care, investigations, and housing classification).
IV. Standard Contract Provisions
a) Conflict with PREA Standards. If any provision of this contract is found to be inconsistent
with the PREA auditing standards, the auditing standards shall prevail.
b) Any notice, tender, demand, delivery, or other communication pursuant to this Agreement
shall be in writing and shall be deemed to be properly given if delivered in person or mailed
by first class or certified mail, postage prepaid, or sent by fax or other telegraphic
communication in the manner provided in this Section, to the following persons:
To City: Clerk of the City Council
City of Santa Ana
20 Civic Center Plaza (M-30)
P.O. Box 1988
Santa Ana, CA 92702-1988
Fax 714-647-6956
With courtesy copies to:
Chief of Police
City of Santa Ana Police Department
60 Civic Center Plaza (M-96)
P.O. Box 1988
Santa Ana, California 92702
Fax 714-245-9007
To Consultant: Timothy M. Evinger
Managing Member - Evinger & Associates, LLC.
Post Office Box One
Klamath Falls, OR 9760 1 -0001
V. Insurance Requirements.
Prior to undertaking performance of work under this Agreement, Consultant shall maintain and
shall require its subcontractors, if any, to obtain and maintain insurance as described below:
a) Commercial General Liability Insurance. Consultant shall maintain commercial
general liability insurance naming the City, its officers, employees, agents, volunteers and
representatives as additional insured(s) and shall include, but not be limited to protection against
claims arising from bodily and personal injury, including death resulting therefrom and damage to
property, resulting from any act or occurrence arising out of Consultant's operations in the
performance of this Agreement, including, without limitation, acts involving vehicles. The
CITY OF SANTA ANA PREA 2019 AGREEMENT WITH EVINGER AND ASSOCIATES
amounts of insurance shall be not less than the following: single limit coverage applying to bodily
and personal injury, including death resulting therefrom, and property damage, in the total amount
of $1,000,000 per occurrence, with $2,000,000 in the aggregate. Consultant shall supply City with
a fully executed additional insured endorsement upon execution of this Agreement.
b) Business automobile liability insurance, or equivalent form, with a combined
single limit of not less than $1,000,000 per occurrence. Such insurance shall include coverage for
owned, hired and non -owned automobiles.
c) Worker's Compensation Insurance. In accordance with the provisions of Section
3700 of the Labor Code, Consultant, if Consultant has any employees, is required to be insured
against liability for worker's compensation or to undertake self-insurance. Prior to commencing
the performance of the work under this Agreement, Consultant agrees to obtain and maintain any
employer's liability insurance with limits not less than $500,000 per accident.
d) If Consultant is or employs a licensed professional such as an architect or engineer:
Professional liability (errors and omissions) insurance, with a combined single limit of not less
than $1,000,000 per claim with $2,000,000 in the aggregate.
e) The following requirements apply to the insurance to be provided by Consultant
pursuant to this section:
(i) Consultant shall maintain all insurance required above in full force and
effect for the entire period covered by this Agreement.
(ii) Certificates of insurance shall be furnished to the City upon execution of
this Agreement and shall be approved by the City.
(iii) Certificates and policies shall state that the policies shall not be
canceled or reduced in coverage or changed in any other material aspect without thirty (30) days
prior written notice to the City.
0 If Consultant fails or refuses to produce or maintain the insurance required by this
section or fails or refuses to furnish the City with required proof that insurance has been procured
and is in force and paid for, the City shall have the right, at the City's election, to forthwith
terminate this Agreement. Such termination shall not affect Consultant's right to be paid for its
time and materials expended prior to notification of termination. Consultant waives the right to
receive compensation and agrees to indemnify the City for any work performed prior to approval
of insurance by the City.
VI. Confidentiali!j
If Consultant receives from the City information which due to the nature of such information is
reasonably understood to be confidential and/or proprietary, Consultant agrees that it shall not use
or disclose such information except in the performance of this Agreement, and further agrees to
exercise the same degree of care it uses to protect its own information of like importance, but in
CITY OE SANTA ANA PREA 2019 AGREEMENT Wrrfi EVINGER AND ASSOCIATES
6
no event less than reasonable care. "Confidential Information" shall include all nonpublic
information. Confidential information includes not only written information, but also information
transferred orally, visually, electronically, or by other means. Confidential information disclosed
to either party -by any subsidiary and/or agent of the other party is covered by this Agreement. The
foregoing obligations of non-use and nondisclosure shall not apply to any information that (a) has
been disclosed in publicly available sources; (b) is, through no fault of the Consultant disclosed in
a publicly available source; (c) is in rightful possession of the Consultant without an obligation of
confidentiality; (d) is required to be disclosed by operation of law; or (e) is independently
developed by the Consultant without reference to information disclosed by the City.
VII. Venue; Consent to Jurisdiction.
Any claim, action, suit or proceeding (collectively, "Proceeding") between City and Contractor
that arises from or relates to this Contract shall be brought and conducted solely and exclusively
within Orange County, CA; provided, however, if a Proceeding must be brought in a federal forum,
then unless otherwise prohibited by law, it shall be brought and conducted solely and exclusively
within the United States District Court for the Central District of California. CONTRACTOR
HEREBY CONSENTS TO THE IN PERSONAM JURISDICTION OF THESE COURTS AND
WAIVES ANY OBJECTION TO VENUE IN THESE COURTS AND ANY CLAIM THAT THE
FORUM IS AN INCONVENIENT FORUM. Nothing in these provisions shall be construed as a
waiver of State's sovereign or governmental immunity, whether derived from the Eleventh
Amendment to the United States Constitution or otherwise, or a waiver of any defenses to
Proceedings orjurisdiction based thereon.
[signature page to follow]
CITY OF SANTA ANA PREA 2019 AGREEMENT WITH EVINGER AND ASSOCIATES
7
N-2019-248
ATTEST:
CITY OF SANTA ANA
AISY GOMEZ NE RIDGE
�Clcrk of the Council City Manager
APPROVED AS TO FORM:
SONIA R. CARVALHO
City Attorney
By:
*araBogosia6n---��
Assistant City Attorney
3
11/1112019
M. Evinger, Managing Member Date
RECOMMENDED FOR APPROVAL:
VALENTIN
Chief of Police
CITY OF SANTA ANA PREA 2019 AGREEMENT WITH EVINGER AND ASSOCIATES
N-2019-248
Attachment 1.
28 C.F.R. § 115.401 Frequency and scope of audits.
(a) During the three-year period starting on August 20, 2013, and during each three-year period
thereafter, the agency shall ensure that each facility operated by the agency, or by a private
organization on behalf of the agency, is audited at least once.
(b) During each one-year period starting on August 20, 2013, the agency shall ensure that at least
one-third of each facility type operated by the agency, or by a private organization on behalf of
the agency, is audited.
(c) The Department of Justice may send a recommendation to an agency for an expedited audit if
the Department has reason to believe that a particular facility may be experiencing problems
relating to sexual abuse. The recommendation may also include referrals to resources that may
assist the agency with PREA-related issues.
(d) The Department of Justice shall develop and issue an audit instrument that will provide
guidance on the conduct of and contents of the audit.
(e) The agency shall bear the burden of demonstrating compliance with the standards.
(i) The auditor shall review all relevant agency -wide policies, procedures, reports, internal and
external audits, and accreditations for each facility type.
(g) The audits shall review, at a minimum, a sampling of relevant documents and other records
and information for the most recent one-year period.
(h) The auditor shall have access to, and shall observe, all areas of the audited facilities.
(i) The auditor shall be permitted to request and receive copies of any relevant documents
(including electronically stored information).
0) The auditor shall retain and preserve all documentation (including, e.g., video tapes and
interview notes) relied upon in making audit determinations. Such documentation shall be
provided to the Department of Justice upon request.
(k) The auditor shall interview a representative sample of inmates, residents, and detainees, and
of staff, supervisors, and administrators.
(1) The auditor shall review a sampling of any available videotapes and other electronically
available data (e.g., Watchtour) that may be relevant to the provisions being audited.
(m) The auditor shall be permitted to conduct private interviews with inmates, residents, and
detainees.
CITY OF SANTA ANA PREA 2019 AGREEMENT WITH EVINGER AND ASSOCIATES
(n) Inmates, residents, and detainees shall be permitted to send confidential information or
correspondence to the auditor in the same manner as if they were communicating with legal
counsel.
(o) Auditors shall attempt to communicate with community -based or victim advocates who may
have insight into relevant conditions in the facility.
28 C.F.R. § 115.402 Auditor qualifications.
(a) An audit shall be conducted by:
(1) A member of a correctional monitoring body that is not part of, or under the authority of, the
agency (but may be part of, or authorized by, the relevant State or local government);
(2) A member of an auditing entity such as an inspector general's or ombudsperson's office that
is external to the agency; or
(3) Other outside individuals with relevant experience.
(b) All auditors shall be certified by the Department of Justice. The Department of Justice shall
develop and issue procedures regarding the certification process, which shall include training
requirements.
(c) No audit may be conducted by an auditor who has received financial compensation from the
agency being audited (except for compensation received for conducting prior PREA audits)
within the three years prior to.the agency's retention of the auditor.
(d) The agency shall not employ, contract with, or otherwise financially compensate the auditor
for three years subsequent to the agency's retention of the auditor, with the exception of
contracting for subsequent PREA audits.
28 C.F.R. § 115.403 Audit contents and findings.
(a) Each audit shall include a certification by the auditor that no conflict of interest exists with
respect to his or her ability to conduct an audit of the agency under review.
(b) Audit reports shall state whether agency -wide policies and procedures comply with relevant
PREA standards.
(c) For each PREA standard, the auditor shall determine whether the audited facility reaches one
of the following findings: Exceeds Standard (substantially exceeds requirement of standard);
Meets Standard (substantial compliance; complies in all material ways with the standard for the
relevant review period); Does Not Meet Standard (requires corrective action). The audit
summary shall indicate, among other things, the number of provisions the facility has achieved at
each grade level.
CITY OF SANTA ANA PREA 2019 AGREEMENT WITH EVINGER AND ASSOCIATES
10
(d) Audit reports shall describe the methodology, sampling sizes, and basis for the auditor's
conclusions with regard to each standard provision for each audited facility, and shall include
recommendations for any required corrective action.
(e) Auditors shall redact any personally identifiable inmate or staff information from their
reports, but shall provide such information to the agency upon request, and may provide such
information to the Department of Justice.
(f) The agency shall ensure that the auditor's final report is published on the agency's website if
it has one, or is otherwise made readily available to the public.
28 C.F.R. § 115.404 Audit corrective action plan.
(a) A finding of "Does Not Meet Standard" with one or more standards shall trigger a 180-day
corrective action period.
(b) The auditor and the agency shall jointly develop a corrective action plan to achieve
compliance.
(c) The auditor shall take necessary and appropriate steps to verify implementation of the
corrective action plan, such as reviewing updated policies and procedures or re -inspecting
portions of a facility.
(d) After the 180-day corrective action period ends, the auditor shall issue a final determination
as to whether the facility has achieved compliance with those standards requiring corrective
action.
(e) If the agency does not achieve compliance with each standard, it may (at its discretion and
cost) request a subsequent audit once it believes that is has achieved compliance.
28 C.F.R. § 115.405 Audit appeals.
(a) An agency may lodge an appeal with the Department of Justice regarding any specific audit
finding that it believes to be incorrect. Such appeal must be lodged within 90 days of the
auditor's final determination.
(b) If the Department determines that the agency has stated good cause for a re-evaluation, the
agency may commission a re -audit by an auditor mutually agreed upon by the Department and
the agency. The agency shall bear the costs of this re -audit.
(c) The findings of the re -audit shall be considered final
CITY OF SANTA ANA PREA 2019 AGREEMENT WITH EVINGER AND ASSOCIATES
II
TIMEV-1 OP ID: MM
A� R" CERTIFICATE OF LIABILITY INSURANCE
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THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER- THIS
CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES
BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED
REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.
IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. If SUBROGATION IS WAIVED, subject to
the terms and conditions of the policy, certain policies may require an endorsement A statement on this Certificate does not confer rights to the
certificate holder in lieu of such endomement(s).
PROWLER
Valley Regional Insurance Svcs
Fresno Office -Main Office
7576 N Ingram Ave Ste 102
Fresno, CA 93711----
CNM1�MTE CT Mary Thonesen
PHONE 1
1AIC. xg8 :559446.1398 NP • 669�46-0911
EE4tAIL
Mary Thonesen
INSURERS WrORaNO COVERAGE
NAICs
INSURER A: Maxtan Indemnity Ins. Co.
INSURED Evinger & Associates LLC
POBox1
Klamath Falls, OR 97601
INSURER B:
INSURER e
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INSURERD:
INSURER E:
INSURER F:
COVERAGES CERTIFICATE NUMBER: REVISION NUMBER:
THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD
INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS
CERTIFICATE MAY BE ISSUED OR MAY PERTAIN. THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS,
EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY RAVE BEEN REDUCED BY PAID CLAIMS.
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DESCRIPTION OF OPERATIONS ILOCATIONSIVEHICLES(ACORD 101, Addidolul Remadu SdpEW,,my M N1aclled If mon apace is re WL )
The City of Santa Ana, Its officers, em loyees , agents, volunteers and
representatives are additional insured in regards to general liability. See
attached form CG 2010 0413
City of Santa Ana 22019
Risk Management Divisio
20 Civic Center Plaza, 4
Santa Ana, CA 92702 AN A M. LAM
SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE
THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN
ACCORDANCE WITH THE POLICY PROVISIONS.
AUTHORQED REPRESENTATIVE
Mary Thonesen
C)1938-2014 ACORD CORPORATION. All rights reserved.
ACORD 25 (2014/01) The ACORD name and logo are registered marks of ACORD