Office of Detention and Removal Operations

US. Department of Homeland Security

425 I Street. NW
Washington, DC 20536

u.s. Immigration

and Customs
Enforcement

MEMORANDUM FOR:

Gloria Kee

~
Field Office Director
Los Angeles Field Office

~ Il

r~

i

FROM:

John P. Torres
Acting Director

SUBJECT:

Ventura County Detention Facility Annual Detention Review

The review of the Ventura County Detention Facility conducted on July 19-20,2005, in Ventura,
California, has been received. A fmal rating of Acceptable has been assigned and this review is
closed.
The rating was based on the Reviewer-In-Charge (RIC) Summary Memorandum and supporting
documentation. The Field Office Director must now initiate the following actions in accordance
with the Detention Management Control Program (DMCP):
1) The Field Office Director, Detention and Removal Operations, shall notify the facility within
five business days of receipt of this memorandum. Notification shall include copies of the
Form G-324A, Detention Facility Review Form, the G-324A Worksheet, RIC Summary
Memorandum, and a copy of this memorandum.
2) The Field Office Director shall schedule the next annual review before July 20, 2006.
Should you or your staffhave any questions regarding this matter, please contact
Deputy Assistant Director, Detention Management Division at (202) 732 b2 high
cc: Official File
b2 high, (b)(6), (b)(7)(C)

b6, b7c

Aepartment of Homeland Security

1!I!:'~lgtOI1, DC

20536

u.s. Immigration
and Customs
Enforcement

August 10,2005

MEMORANDUM FOR:

FROM:

John P. Torres
Director (Acting)
Office of Detention and Removal
b6, b7c

Reviewer In Charge
Los Angeles Field Office
SUBJECT:

b6, b7c

Ventura County Pre-Trial Detention Facility/Todd Road Facility
Annual Detention Review

The Los Angeles Field Office, Office of Detention and Removal conducted adetention review of
the Ventura County JailfTodd Road Facility on July 19 - 20, 2005. This review was conducted by
with additional team members,
and
The
b6, b7c
b6, b7c
b6, b7c
Ventura County Jail facility is used for detainees requiring housing less than 72 hours. It must be
noted that the Todd Road facility houses only sentences persons and are transferred there from the
main Ventura Jail. Detainees at the Todd Road facility are transported to the Ventura County Main
Jail by the Sheriffs Department, for release to ICE.
Type of Review:
This review is a scheduled Operational Review to determine general compliance with established
Immigration and Customs Enforcement (ICE) National Detention Standards. The last review of
these facilities was on August 17 - 18, 2004. All worksheets and working papers are maintained in
the appropriate ftle system and are available for review by the Review Authority.
Review Summary:
Both facilities operate under the guidelines of Title 15. In addition, they are accredited by the
Institute for Medical Quality (subsidiary ofthe California Medical Association). The current medical
accreditation expires May, 2006. The accreditation review is performed every three years.

Subject: Ventura Couare-Trial Detention Facility/Todd Road
Annual Detention Review
Page 2

Fa.

Review Findings:
The following information summarizes those standards not in compliance. Each standard is
identified and a short summary provided regarding standards or procedures not currently in
compliance.
Compliant
Deficient
At-Risk
Non-Applicable -

24
0
0
3

Standards Summary Findings:
The Ventura Pre-Trial Facility has improved their In-Take Processing to ensure no person is
detained in the holding ceUs for more then 3 to 4 hours, before being moved to a housing area. In
addition, both facilities have removed the disciplinary "meat loaf' meal and are no longer served.
All required ICE National Detention standards are being observed and there were no deficiencies
observed by any team member during this review.

The class action law suite filed in 2003 is currently still pending. The class action suite prevents
them from performing strip searches on any person booked into the facility or returning from outside
court hearings until there is a final decision in the case. The facility continues to conduct pat down
searches and a complete change of clothing to all inmates returning from court hearings. This
procedure is performed at both facilities and was observed by the male team members.
The Ventura Pre-Trial facility stated that the increased amount of Chemical Agents usage is due to
the fact that they have more inmates who are combative because of drug abuse. In some instances
one inmate has been sprayed more then one time in any day, while in SMU Administrative
Segregation. In addition, the increase of outside medical referrals is attributed to this same drug
abuse of the inmates booked into the facility.

RIC Observations:
BEST PRACTICE: The facilities have developed a computer system that enables them to view all
aspects of each inmate's time while incarcerated. This is why the team was only able to review the
medical records of some inmates that are located in the medical units. The computer system allows
for all Sheriffs personnel to access any inmates recorded stay including housing movements, meals,
medical attention including medicine dispensing, disciplinary and special management housing,
court hearing dates and time, etc. Within a few minutes it is possible to view every aspect of an
inmate.

Subject: Ventura c o .re-Trial Detention Facilityffodd Road F a a
Annual Detention Review
Page 3
STAFF: During the tour of each facility, all staff was pleasant and professional toward the team.
The staff exhibited working knowledge in their respective areas and answered all questions. They
were eager to demonstrate various procedures and ensured the team that they were in compliance
with not only their policies but ICE Detention Standards as well. Even though the Ventura Pre-Trial
facility is older, the team was informed that the current Commander demands cleanliness. It was
very obvious to the team that all areas including the kitchen maintained this very high standard. The
Todd Road facility as well practices this same high standard and is very well maintained.
COMMUNICATION: There are no significant concerns or issues as a result of this review. There is
continued communication with ICE personnel and the facilities on a weekly basis. Staff at the ICE
Ventura Sub-Office and the Ventura Pre-Trial Facility communicates via telephone and e-mail to
ensure daily operations are maintained.

RIC Issues and Concerns
At this review, there were no issues or concerns to report at either facility.
Recommended Rating and Justification:
It is the Reviewer in Charge recommendation that the facility receive a rating of "Acceptable". It is
the recommendation of the RIC that no plan of action is required and this review should be closed.

RIC Assurance Statement:
All fmdings of this review have been documented on Form G-324B and are supported by the written
documentation contained in the review file.

•

UARTERS EXECUTIVE REVIEW

Review Authority
The signature below constitutes review of this report and acceptance by the Review Authority. OIC/CEO will have 30 days from
receipt of this report to respond to all findings and recommendations.
HQDRO EXECUTIVE REVIEW: (Plcase Print Name)

John P. Torres
I itlc

Date

!\cti n Dir¢clur

Final Rating:

D Superior

o Good

~ Acceptable

o Deficient
D At-Risk

Comments:
The Review Authority (RA) concurs with the recommended rating of "Acceptable" made by the
Reviewer-In-Charge (RIC) as listed in the RIC Memorandum and G-324B Worksheets.

Form G-324A (Rev. 811/01) No Prior Version May Be Used Atler 12/31/0 I

•

.

"

•

Department Of Homeland Security
Immigration and Customs Enforcement

G. Accreditation Certificates

e of FacUi Reviewed
ICE Intergovernmental Service Agreement
ICE Staging Facility (12 to 72 bours)

List all State or National Accreditation[s] received:

C81

B. Current Facili~ Review
Type of Facility Review
[8J Field Office HQ Review
Date[s] of Facility
July 19 - 20, 2005

o
o

C. Previous/Most Recent Facrn~ Review
Date[s] of Last Facility Review
08/2004
Previous Rating
C8l Acceptable 0 Deficient 0 At-Risk
N amean d L oca t'Ion

0

Check box if facility has no accreditationls]

R. Problems / ComJ!laints JCopies must be attacbedl
The Facility is under Court Order or Class Action Finding
Court Order
Class Action Order
The Facility has Significant Litigation Pending
Major Litigation
Life/Safety Issues
E} Check ifl'U"ll,e.

0

D

o
o

F acilltlY Hi St o!y
Date Built
1981
Date Last Remodeled or Upgraded
112004
Date New Construction I Bedspace Added
N/A
Future Construction Planned
DYes [8J No Date:
Current Bedspace
Future Bedspace (# New Beds only)
966
Number: NI A Date:

I

r F acilItty

Name

VENTURA COUNTY PRE·TRIAL DETENTION FACILITY
Addresl (Street and Name)
800 S. VlCIORIA AVE.
City, State and Zip Code
VENTURA CA. 93009
County
VENTURA
Name and Title of Chief Executive Officer (WardeniOIClSuperintendent)
COMMANDER
b6, b7c
Telephone # (Include Area Code)
;05) 654 b6, b7c
ield Office I Sub-Ofl1ce (Ust Office with oversight responsibilities)
LOS ANGELES FIELD OFFICE
Distance from Field Office
60 miles

E ICE Information
Name of Reviewer In Charge (Last, Title and Duty Station)
b6, b7c
/ OIC I YEN
Name of Team Member I Title / Duty Location
b6, b7c 1 SDO I SPP
Name of Team Member I Title I Duty Location
b6, b7c o / DOS 1 LOS
Name of Team Member I Title 1 Duty Location
1
I

F CDFJlGSA I n ~ormation 0 Diy
I
Contract Number
Date of Contract or IGSA
10/0111998
12-99-0006
Basic Rates per Man-Day
$79.00
Other Charges: (If None, Indicate N/A)
$3.00 for medical charges;
;
,
Estimated Man-days Per Year

Detention Facility Inspection Form
Facilities Used Under 72 hours

I

J.

Total Facility Population
Total Facility Intake for previous 12 months
31 ,364
Total ICE Mandays for Previous 12 months

K. Classifi.cation Level jICE SPCs and CDFs Only)
,
.,',:" ....... ' " ,
L-l
L-2
L-3
I AdultMaIe
I Adult Female

...

L. Facility Ca ~acity

:... : Rated
Op_erational
Emergency
AdultMaIe
716
708
Adult Female
200
234
[] Facility holds Juvenile, Offenders 16 aDd older as Adults

I

USMS

Other

Support:
b2 high

b2 high

Form G-324B (Rev. 3117/05) No Prior Version May Be Used After 10/1 /04

•

Significant Incident Summary Worksheet

For ICE to complete its Review of your facility, the following information must be completed prior to the scheduled review
dates. The information on this form should contain data for the past twelve months in the boxes provided. The information on
this form is used in conjunction with the ICE detention standards in assessing your detention operations. This form should be
filled out by the facility prior to the start of any inspection. Failure to complete this section will result in a delay in processing
this report.

Assault:

Oll'cmdcn; on
Offcnden i

0

0

0

0

0

2
Assault:
Detainee 00

0

0

0

0

0

Stall'

Number of Forced Moves, incl.
Forced Cell moves l

0

0

0
41

40

16

0

2

0

\-M
0

0

0
0

0

0

0
0

0

0

0

Escapes
0
Grievances:

0

NOT
TRACKED
ALL

DECISIONS IN
COMPUTER
S

Deaths

0

# Psychiatric Cases referred for
Out.~ide

0

1,1

2

144

178

0

0

Care

Any attempted physical contact or physical contact that involves two or more offenders
Oral, anal or vaginal penetration or attempted penetration involving at least 2 parties, whetber it is consenting or nOTH:onsenting
Routine transportation of detainees/offenders is not considered "forced"
Any incident that involves four or more detainees/offenders, includes gang fights. organized multiple bunger strikes. work stoppages, hostage situations,
major fires. or other large scale incidents.

Fonn G-324B (Rev. 3/17/05) No Prior Version May Be Used After 12/1/04

•
Classification System
Detainee Handbook
Food Service
Funds and Personal Property
Detainee Grievance Procedures
Issuance and Exchange of Clothing, Bedding, and Towels
Practices

Detention Files
Disciplinary Policy
Emergency Plans
Environmental Health and Safety
Hold Rooms in Detention Facilities
Key and Lock Control
Population Counts
Security Inspections
Special Management Units (Administrative Segregation)
Special Management Units (Disciplinary Segregation)
Tool Control
Transportation (Land management)
Use of Force
Staff I Detainee Communication

Fonn G·324B (Rev. 3/17/05) No Prior Version May Be Used After 1211104

RIC Review Assurance Statement

By signing below, the Reviewer-In-Charge (RIC) certifies that all findings ofnoncornpliance with policy or inadequate controls
contained in the Inspection Report are supported by evidence that is sufficient and reliable. Furthermore, findings of
noteworthy accomplishments are supported by sufficient and reliable evidence. Within the scope of the review, the facility is
operating in accordance with applicable law and policy, and property and resources are efficiently used and adequately
safeguarded, except for the deficiencies noted in the report.

Reviewer-In.charge: (print Name)
b6, b7c

b6, b7c

b6, b7c

Title & Duty Location

Officer-In-Char eNEN

Print Name. Title, & Duty Location

Print Name. Title. & Duty Location
b6, b7c

, SDO/SPP

b6, b7c

Print Name, Title, & Duty Location

RIC Rating Recommendation:

Comments:

o, DOSILOS
& Duty L:x:alion

~ Acceptable

D Deficient
D At-Risk

See Attached Memorandum

Fonn G-324B (Rev. 3/17/05) No Prior Version May Be Used After 12/1/04

--

D~i'artmeDt of Homeland Security
Immigration and Customs Enforcement
Office of Detention and Removal

Condition of Confinement Review Worksheet
(This document must be attached to each G-324a Inspection Form)
This Form to be used for Inspections of alllGSA Facilities Used Under 72 Hours

Field Office Detention Review Worksheet
C8J

0

Local Jail- IGSA
State Facility - IGSA

Name
Ventura County Pre-Trial Detention Facility
Address (Street and Name)
800 South Victoria Avenue
City, State and Zip Code
Ventura CA. 93009
County
Ventura
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
b6, b7c
Commander
Name and title of Reviewer-in-Charge
b6, b7c
OIC/DRONEN
Date[sJ of Review
July 19-20,2005
Type of Review
DSpecial Assessment
Other
Headquarters I2SI Operational

rr

o

1
G-324B Detention Review Worksheet for IGSAs (Under 72 Hours) Rev: 10/18/04

o

[8J

ICE Staff enter all information on detainees admitted,
released, or transferred into the Deportable Alien Control

Deficient

o Deficient

Reviewer Signature

b6, b7c

o

o

o

0

0

[8J

0

0

l8J

0

0

l8J

0

0

l8J

0

[8J

Each shift
at least 5
female officers for female
searches.

No ICE staff on site/ICE
staff enters info. @ ICE
office

At-Risk

At-Risk

AUG ~ " ")('10;
Date:

0-324B Detention Review Worksheet for rOSA (Under 72 Hours) Rev: 10/18/04
2

~~G ~. (', ~ "'/'"

states in clear language basic
The detainee
detainee
The handbook identifies:
• Initial issue of clothing and bedding and
personal hygiene items.
• when a medical examination will be conducted .
• the telephone policy, debit card procedures,
direct and frees calls; Locations of telephones;
Policy when telephone demand is high; Policy
and procedures for emergency phone calls,
and the Detainee Message System.
facility search procedures and contraband
policy.
• facility visiting hours and schedule and visiting
rules and
lations

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

o

o

o

o

•

policy and procedures :
Including:
• Prohibited acts and severity scale sanctions.
• Time limits in the Disciplinary Process.
• Summary of Disciplinary Process.
• The detainee handbook describes the sick call
procedures for general population and
segregation.
• The handbook specifies the rights and
of all detainees.
Deficient

At-Risk

Knife cabinets close with an approved locking device
and the on-duty cook foreman maintains control of the
that locks the device.
All knives not in a secure cutting room are physically
secured to the workstation and staff directly supervises
detainees using knives at these workstations. Staff
monitor the condition of knives and
utensils

Reviewer Signatur

AUG 1 0 Z005

b6, b7c

Date:

G-324B Detention Review Worksheet for IGSAs (Under 72 Hours) Rev: 10/ 18/04

3

Detainees are served at least three meals daily. No
more than 14 hours elapse between the last meal
served and the first meal of the
A registered dietitian conducts a complete nutritional
analysis of every master-cycle menu planned.

~

0

0

~

0

0

~

0

0

~

0

0

o
Procedures include inspecting all incoming food
shipments for damage, contamination, and pest
infestation.

o Deficient

Reviewer Signature:

o

o

l8J

0

0

l8J

0

0

[gJ

0

0

[gJ

0

0

o At·Rlsk

Date: AUG 1 0 2005

b6, b7c

(Under 72 Hours) Rev: 10/18/04

G-324B Detention Review Worksheet for IG
4

•
Deficient

At-Risk

~ ~'~An'tAhl e

o Deficient

OAt-Risk

~ Acceptable

Deficient

At-Risk

Reviewer Signat

b6, b7c

o Repeat Find

Date: AUG 1

G-324B Detention Review Worksheet for IGSAs (Under 72 Hours) Rev: 10/18/04
5

0 2005

of privacy
Emergency phone call messages are immediately given
to detainees.
to return emergency phone calls
as soon as
Detainees are allowed phone calls to consula
officials.
Detainees in disciplinary segregation allowed phone
calls for family emergencies. Detainees in
administrative segregation and protective custody
afforded the same telephoning privileges as those in
on.
eneral
When detainee phone calls are monitored,
is posted by detainee telephones that phone calls made
by the detainees may be monitored. Special Access
calls are not monitored.

o Deficient

t8J

are
and identified according to
standard requirements.

t8J

e

Reviewer Signature:

Deficient

b6, b7c

181

0

0

181

0

0

181

0

0

181

0

0

r:8l

0

0

rzl

0

0

181

0

0

0

OAt-Risk

r:8l

0

0

r:8l

0

0

I8l

0

0

OAt-Risk

Flndl

D

MJG 102005

Date: _ _ _ __

G-324B Detention Review Worksheet for IGSAs (Under 72 Hours) Rev: 10/18/04
6

medication

The medical unit keeps written records
that is distributed.
to consent form
Detainees are
when medical

[8J

Deficient

~

0

0

~

0

0

~

0

0

[gl

0

0

[8J

0

0

r81

0

0

At-Risk

Every new
member receives suicide-prevention
training. Suicide-prevention training occurs during the
Drnn.n'"DQ orientation nrnnr!:lrn
Training prepares
to:
•
Recognize potentially suicidal behavior;
• Refer potentially suicidal detainees, following
facility procedures;
•
Understand and apply suicide-prevention

o Deficient

o o
o o
At-Risk

o

RAr~AA' .. . n , .,nn

AUG 1 0 Z005

b6, b7c

tI'~---- Date:

Reviewer Signature:
G-324B Detention R

7

The facility follows a written procedure
ndling
illegal contraband. Staff inventories, holds, and reports
it when necessary to the proper authority for
seizure.
Upon admittance, detainees receive notice of items they
can and cannot possess.

r8l Acceptable

Deficient

o

o

o

o

At-Risk

Written ru
i
the following sanctions:
• corporal punishment
• deviations from normal food service
• clothing deprivation
• bedding deprivation
• denial of personal hygiene items
• loss of correspondence privileges
exercise
of
•
The rules of conduct, sanctions, and procedures for
violations are defined in writing and communicated to all
detainees verbal and in
The
posted in
and
English or other dominate languages used in the facility:
• Rights and Responsibilities
• Prohibited Acts
• Disciplinary Severity Scale
• Sanctions
• If
acts occur,

Defici ent

Reviewer Signature:

o

0

0

1:2]

0

0

1:2]

0

0
Only in Handbook, & in
Video orientation.

0

(gJ

0

~

0

0

At-Risk

b6, b7c

Date:

AUG 1 fI 7.005

Under 72 Hours) Rev: 10/18/04

G-324B Detention R
8

ee or detainee groups
over other detainees.
Detainees are protected from:
•
Personal abuse I Corporal punishment
•
Personal injury
•
Disease
•
Property damage
•
Harassment from other detainees
The facility has written emergency plans that cover:
• Work/Food Strike
• Disturbances
• Escapes
• Bomb Threats
Adverse Weather
• Facility Evacuation
• Internal

o

o

o

o

•

o At·Rlsk

o Deficient

b6, b7c

G-324B Detention Review Worksheet for IGSAs (Under 72 Hours) Rev: 10/ 18/04
9

The facility has an approved
evacuation Ian.
The plan requires:
• Monthly fire inspections.
• Fire protection equipment strategically located
throughout the facility.
• Public posting of emergency plan with
accessible building/room floor plans.
• Exit signs and directional arrows.
exit diagram conspicuously
• An
area.
and disposal
Standard cleaning practices include:
• Using specified equipment; cleansers;
disinfectants and detergents.
An established schedule of cleaning and followins
A licensed/CertifiedfTrained pest-control professional
inspects for rodents, insects, and vermin.
• At least monthly.
• The pest-control program includes preventive
for

•

[8J Acceptable

D Deficient

D

[8J

0

0

[8J

0

0

[8J

D

0

l8l

D

0
Done every month or
more if needed.

~

D

0

At-Risk

AUG 1 0 2005
Reviewer Signature: -

b6, b7c

G-324B Detention Review Worksheet for IGSAs
10

'r----- Date:

72 Hours) Rev: 10/18/04

The hold rooms contain sufficient seating for the
number of detainees held.
The walls of the hold rooms escape
• The hold room ceilings are escape and tamper

f8l

0

0

f8l

0

0

Individ
are not held in hold rooms for more than 12
hours.
Ie and females are segregated from each other at

,ff

0

0

f8l

0

0

f8l

0

0

[8]

0

0

f8l

0

0

f8l

0

0

o Deficient

OAt-Risk

door locks to detainee living quarters, or
areas with an occupant load of 50 or more people,
conform to
•
Occupational Safety and Environmental Health
Manual, Chapter 3
•
National Fire Protection Association Life Safety
Code 1

f8l

o

o

Individual gun lockers are provided.
• They are located in an area that permits constant
officer observation .
•
In an area that does not allow detainee or public

f8l

o

o

o

o

Reviewer Signature

held at

b6, b7c

--4~----- Date:

AUG 1 0 2005
-----

G-324B Detention Review Worksheet for IGSAs (Under 72 Hours) Rev: 10/18/04
11

•

•

Issued keys are returned immediately in the
event an employee inadvertently carries a key
ring home.
Detainees are not permitted to handle keys
to staff.

o Deficient

x:

o
o

Written procedures cover informal and emergency
counts.
The control officer (or other designated position)
maintains an out -count record of all detainees
tern
leavi the

I:8J Acceptable

D9ficient

o 1<91:19al ..

OAt-Risk

,n ... nn

o
o
D KAnA:nFin

At-Risk

o
o

Reviewer Signature:

b6, b7c

0-...------

Date:

AIJG 1 0 Z005

G-324B Detention Review Worksheet for rGSAs (Under 72 Hours) Rev: 10118/04
12

o o
o o
o o
o DefIcient

OAt-RIsk

The Administrative Segregation unit provides
non-punitive protection from the general population and
individuals undergoing disciplinary segregation.
• Detainees are placed in the SMU
(administrative) in accordance with written
criteria .
may
inee in
In exigent circumstances,
ad
the SMU (administrative) before a written order has
been approved.
• A copy of the order given to the detainee within
24

181

0

0

~

0

0

~

0

0

181

0

0

condition.

nee maintains a normal level of personal
the SMU .
A health care professional visits every detainee at least
three times a week.

Reviewer Signature:

b6, b7c

o
--¥''''t------ Date:

AUG 1 0 Z005

G-324B Detention Review Worksheet for IGSAs (Under 72 Hours) Rev: 10/18/04
13

The SMU maintains a permanent log.
•
Detainee-related activity, e.g., meals served,
recreation visitors etc.
At a minimum staff record whether the detainee ate,
showered, exercised and took any medication during
every shift and records all pertinent information, e.g., a
medical condition suicidaVassaultive behavior

o Deficient

o

o

o

o

o
o

0

o

o

[8J

0

0

[8J

0

0

[8J

0

0

[8J

0

0

[8J

0

0

[8J

0

0

All records are
computerized

At-Risk

o

Monthly

AUG 1 0 2005
Reviewer Signature:

b6, b7c

Date:

G-324B Detention Review Worksheet for IGSAs (Under 72 Hours) Rev: 10/18/04
14

•
Deficient

OAt-Risk

The facility has a tool classification system. Tools are
class ified according to:
•
Restricted (dangerous/hazardous)
•

D

Maintenance unit and all
tools are located outside
of the secured facility.

o

Non Restricted (non-hazardous).
the

~Acce

•
•
•

tools to

o Deficient

D

o
o

OAt-Risk

Does not use force as punishment.
Attempts to gain the detainee's voluntary
cooperation before resorting to force
Uses only as much force as necessary to
control the detainee.

I:8l

o

o

o o
Reviewer Signature:

----~tk------ Date:

b6, b7c

fl..UG 102005

Under 72 Hours) Rev: 10/18/04

G-324B Detention R
15

•

Acceptable

Deficient

121

0

0

121

0

0

121

0

0

121

0

0

Deficle

Viewed written policy.

OAt-Risk

AUG 1 0 Z005

b6, b7c

Reviewer Signature

-t------

G-324B Detention

Date: _ _ _ __

r 72 Hours) Rev: 10/18/04
16