PHL Variable Insurance Company v. Hudson Valley EPL LLC

Filing 30

REPORT AND RECOMMENDATION- DENYING 15 MOTION for Judgment on the Pleadings. Please note that when filing Objections pursuant to Federal Rule of Civil Procedure 72(b)(2), briefing consists solely of the Objections (no longer than ten (10) pages) and the Response to the Objections (no longer than ten (10) pages). No further briefing shall be permitted with respect to objections without leave of the Court. Objections to R&R due by 10/3/2014. Signed by Judge Sherry R. Fallon on 9/16/2014. (lih)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PHL VARIABLE INSURANCE
COMPANY,
Plaintiff,

v.
HUDSON VALLEY, EPL, LLC,
Defendant.

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Civil Action No. 13-1562-SLR-SRF

REPORT AND RECOMMENDATION
I.

INTRODUCTION
In this declaratory judgment action filed pursuant to 28 U.S.C. § 2201 and Rule 57 of the

Federal Rules of Civil Procedure, plaintiff PHL Variable Insurance Company ("Phoenix" or
"plaintiff') seeks to adjudicate its rights and obligations under a life insurance policy (the
"Policy") insuring the life of Phillip E. Skidmore ("Mr. Skidmore"). Specifically, Phoenix seeks
a declaration that the policy is null and void due to the lack of an insurable interest at the
Policy's inception. Presently pending before the court is a motion for judgment on the pleadings,
filed pursuant to Fed. R. Civ. P. 12(c) by defendant Hudson Valley EPL, LLC ("Hudson Valley"
or "defendant"). (D.I. 15) For the following reasons, I recommend that the court deny
defendant's motion.
II.

BACKGROUND
Plaintiff is a life insurance company incorporated and headquartered in Connecticut.

(D.I. 1 at~ 2) Defendant is a Delaware corporation. (Id.

at~

3)

The complaint alleges that stranger originated life insurance ("STOLI") policies have
emerged in recent years, and are comparable to unlawful wagering policies that lack an insurable

interest at inception. (Id.

at~~

8-9) The policies are not sought for legitimate insurance needs,

but rather are manufactured for the benefit of third parties in the secondary insurance market.
(Id. at~ 8) In a STOLI arrangement, speculators collaborate with an individual to obtain a life

insurance policy in the name of that individual, and then sell some or all of the death benefit
payable upon the death of the insured to stranger investors. (Id.

at~~

7-8) To maximize the

expected rate of return, STOLI speculators often target individuals who are elderly, and material
information concerning the insured is often inflated or otherwise misrepresented in order to
qualify for the most valuable policies with the highest death benefits at the lowest premiums.
(Id.

at~~

10-11) To conceal the nature of such policies, the insured often designates the policy

holder and/or beneficiary of the proceeds to be a shell third-party entity such as a trust, and then
transfers the beneficiary interest to a STOLI entity after obtaining the policy. (Id.

at~

12)

On October 16, 2007, the Phillip E. Skidmore Irrevocable Life Insurance Trust 2007-2
(the "Skidmore Trust"), by and through its trustee, U.S. Bank, N.A. ("U.S. Bank"), applied to
plaintiff (the "Application") for a life insurance policy (the "Policy") in the amount of four
million dollars for Mr. Skidmore. (D.I. 1 at~ 17) The Application represented that the
Skidmore Trust, which was created on July 13, 2007, would be the proposed owner and sole
beneficiary of the Policy. (Id.) The Application contained representations about Mr. Skidmore's
net worth and income, the financing of premiums, and the applicant's intent not to transfer a
beneficial interest to a third party. Plaintiff relied on such representations in determining
whether Mr. Skidmore was insurable and qualified for the insurance requested. (Id.

at~

18)

Specifically, the Application represented that Mr. Skidmore had a net worth of $4,500,000,
earned income of $200,000, and other income of $25,000. (Id.

at~

19) The Application also

represented that the Skidmore Trust did not intend to sell the Policy to a third party, the

2

premiums would not be financed, and the Skidmore Trust planned to pay $165,048 in first year
premiums. (Id.) Mr. Skidmore signed the Application in Florida and U.S. Bank, on behalf of the
Skidmore Trust, signed the Application in Minnesota. (Id. at ~ 21)
On December 3, 2007, Mr. Skidmore and the Skidmore Trust also executed a Statement
of Client Intent Form (the "SOCI"), which requested material information regarding the purpose
of the insurance, the source of funding for premiums, whether there was any understanding that a
third party would obtain an interest in the Policy and whether the insured or related parties would
receive inducements in connection with the purchase of the Policy. (Id.

at~

22) Mr. Skidmore

and the Skidmore Trust represented that premiums would not be financed, the funds used to pay
premiums would be contributed by Mr. Skidmore, the Policy was not being purchased in
connection with a program under which Mr. Skidmore had been advised of an opportunity to
transfer the Policy, that there was no intent that the Policy would be sold or transferred to a third
party, and that neither Mr. Skidmore nor the Skidmore Trust would receive cash or other
inducement in connection with the Application. (Id.)
Plaintiff offered the Policy to the Skidmore Trust with a planned first year premium of
$165 ,048 and a face amount of $4 million. (Id. at ~ 25) The offer was conditioned upon receipt
of an executed Policy Acceptance Form and premium payment. (Id.) On March 28, 2008, Mr.
Skidmore, U.S. Bank, and Mark Resnick, an insurance agent affiliated with R. Binday Plans &
Concepts, Ltd., executed an Acceptance of Resignation of Trustee and Appointment of
Successor Trustee Form ("Resignation Form"). (Id.

at~

26) Plaintiff subsequently received the

executed Policy Acceptance Form and received payment of the premium. (Id.

at~

27)

On April 2, 2010, plaintiff received a Designation of Ownership form designating Marcy
Trachtenberg, Resnick's sister-in-law, as the new owner of the Policy. (Id.

3

at~

28) On July 6,

2010, plaintiff received a second Designation of Ownership form designating defendant as the
new owner of the Policy. (Id. at i! 29) The Designation of Ownership form was executed by
Robert Schernwetter, in his capacity as president of Hudson Valley. (Id.) Mr. Schernwetter is
the father-in-law of Michael Binday, the vice president ofR. Binday Plans & Concepts Ltd. (Id.)
On February 15, 2012, Resnick and Binday were indicted on numerous counts of mail
and wire fraud, conspiracy, and obstruction of justice for orchestrating a $100 million STOLI
scam. 1 (Id. at i! 30) The indictment alleged that Binday and Resnick fraudulently induced
insurance companies to issue more than $100 million in life insurance coverage to straw buyers,
which they then sold on the secondary market prior to the issuance of the policies. (Id. at iii! 3032)
Mr. Skidmore passed away on March 6, 2012. (Id. at i! 34) Plaintiff grew concerned that
the Policy was procured in connection with a fraudulent STOLI scheme when it began
processing Mr. Skidmore's death claim. (Id. at i! 35) To verify that a valid insurable interest
was present at the time of the Policy's issuance, plaintiff requested certain information from
defendant regarding the application for the Policy and its subsequent transfer. (Id.) Defendant
refused to respond to plaintiffs request for information, and plaintiff did not make a decision on
the Skidmore death claim in the absence of that information. (Id.)
Plaintiff determined that Mr. Skidmore did not have any significant net worth or income
at the time he and the Skidmore Trust executed the Application, and Mr. Skidmore did not
contribute the funds used to pay the Policy premiums, which were instead funded by individuals
without an insurable interest in Mr. Skidmore's life. (Id. at iii! 37-38) Plaintiff further
determined that the Policy was procured by a third-party investor who lacked an insurable
1

Subsequently, on July 30, 2014, Resnick and Binday were found guilty on all charges and
sentenced to six years and twelve years in prison, respectively. (DJ. 18, Ex. A; DJ. 29, Exs. A
&B)

4

interest in Mr. Skidmore's life, and there was an understanding that a party other than the
Skidmore Trust would obtain a legal or equitable right, title, or interest in the Policy. (Id. at iii!
39-40) According to plaintiff, there was an understanding that Mr. Skidmore or a related party
would receive cash or other inducement in connection with the application for and purchase of
the Policy, and the Policy was purchased with the intent that a third-party investor without an
insurable interest would obtain an interest in and control over the Policy. (Id. at iii! 41-42)
III.

LEGAL STANDARD
In a diversity action, the court must first address the threshold issue of which law governs

the rights and liabilities of the parties before it. For substantive issues, the court looks to the
substantive law of the forum state in which it sits. Erie R.R. Co. v. Tompkins, 304 U.S. 64, 78
(193 8). The forum state's choice oflaw doctrine is included within its substantive law. Klaxon
Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487, 496-97 (1941 ); Kruzits v. Okuma Machine Tool,
Inc., 40 F.3d 52, 55 (3d Cir. 1994). Under Delaware law, the law of the place where an

insurance contract was made governs the obligations imposed by such contract. Wilmington
Trust Co. v. Mut. Life Ins. Co. ofNew York, 177 F.2d 404, 406 (3d Cir. 1949).

Defendant moves for judgment on the pleadings pursuant to Federal Rule of Civil
Procedure 12(c). Under Federal Rule of Civil Procedure 12(c), "[a]fter the pleadings are closed
- but early enough not to delay trial - a party may move for judgment on the pleadings." Fed. R.
Civ. P. 12(c). When deciding a Rule 12(c) motion for judgment on the pleadings based on an
allegation that the plaintiff has failed to state a claim, the motion "is analyzed under the same
standards that apply to a Rule 12(b)(6) motion." Revell v. Port Auth., 598 F.3d 128, 134 (3d Cir.
2010), cert. denied, 131 S. Ct. 995, 178 L. Ed. 2d 825 (Jan. 18, 2011 ).

5

To state a claim upon which relief can be granted pursuant to Rule 12(b)(6), a complaint
must contain a "short and plain statement of the claim showing that the pleader is entitled to
relief." Fed. R. Civ. P. 8(a)(2). Although detailed factual allegations are not required, the
complaint must set forth sufficient factual matter, accepted as true, to "state a claim for relief that
is plausible on its face." Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007); see also

Ashcroft v. Iqbal, 556 U.S. 662, 663 (2009). Under this standard, the court must accept all wellpleaded factual allegations as true, and must draw all reasonable inferences in favor of the nonmoving party. See Turbe v. Gov't of Virgin Islands, 938 F.2d 427, 428 (3d Cir. 1991). This
determination is a context-specific task requiring the court "to draw on its judicial experience
and common sense." Iqbal, 556 U.S. at 679.
IV.

DISCUSSION

Plaintiffs complaint seeks a declaration that the Policy is void ab initio for lack of any
insurable interest, and the remainder of plaintiffs claims for the retention of premiums are
contingent upon the ability to obtain that declaratory relief. (D.I. 1 at if 4 7) In its motion for
judgment on the pleadings, defendant argues that: (1) plaintiff is barred from asserting invalidity
of the Policy because the two-year contestability period has already expired; (2) even if
plaintiffs claim is not barred by the incontestability clause, plaintiff has failed to sufficiently
allege a lack of insurable interest; and (3) defendant is entitled to judgment on its counterclaims.
(D.I. 16at11, 17, 19)
A.

Applicable Law

Defendant argues that Florida law should apply to plaintiffs claims because the
Skidmore Policy was delivered and issued for delivery in Florida. (D.I. 16 at 9) According to
plaintiff, a choice of law analysis is unnecessary at this time because there is no inherent conflict

6

between Florida and Delaware law regarding insurance contracts. (D.I. 18 at 6) Even if such an
analysis were necessary, plaintiff contends that it is unclear which state's law would apply
because of the numerous conspirators who participated in the scheme. (Id at 7)
In general, Delaware courts apply the "most significant relationship" test to determine
which law to apply to contract claims. Travelers lndem. Co. v. Lake, 594 A.2d 38, 47 (Del.
1991 ). In the context of insurance contracts, Delaware courts have held that the most significant
relationship is the forum in which the contract was executed. Wilmington Trust Co. v. Mut. Life

Ins. Co. of New York, 177 F.2d 404, 406 (3d Cir. 1949). In the case presently before the court, it
is uncontested that the Policy was signed by Mr. Skidmore, issued for delivery, and delivered in
Florida, and the Policy Acceptance form was executed in Florida as well. See Am. General Life

Ins. v. Goldstein, 741 F. Supp. 2d 604, 611 (D. Del. 2010) ("Delaware courts have implicitly
recognized that, in the context of insurance contracts, the most significant relationship is the
forum in which the contract was executed."). Therefore, the court shall apply the law of
Florida.2

B.

Incontestability Clause

The Policy was issued on August 31, 2007, and Skidmore died on March 6, 2012.
Plaintiff filed the present action on September 17, 2013, contesting the validity of the Policy
despite its incontestability clause. Given the timing of the action, defendant asserts that the
incontestability clause is a legal bar to plaintiff's claims. (D.I. 16 at 11-17) Specifically,

2

Contrary to plaintiff's allegations, there are substantial conflicts between Delaware and Florida
case authorities regarding the topics at issue in this case. Compare Pruco Life Ins. Co. v. US.
Bank, C.A. No. 12-cv-24441, 2013 WL 4496506 (S.D. Fla. Aug. 20, 2013) with PHL Variable
Ins. Co. v. Price Dawe 2006 Ins. Trust, 28 A.3d 1059 (Del. 2011 ). Moreover, plaintiff does not
meaningfully contest the application of Florida law to the present case. (D.I. 18 at 6-8) Because
the facts clearly indicate that Florida bears the most significant relationship to the formation of
the Policy, there is no reason for the court to postpone a ruling on which state's law applies and
conduct the analysis under both Delaware and Florida law in the interim.
7

defendant contends that Florida statutory law contains no provision that renders a contract
unenforceable due to a lack of insurable interest, and that the Florida Supreme Court has
declined to read into the insurance statutes provisions that would render a policy void and
unenforceable unless such language is expressly contained within the statute. (Id. at 12)
Plaintiff responds that void contracts cannot be saved by their own contestability clauses under
Florida law. (D.I. 18 at 14-18)
In accordance with Florida law, the court concludes that Phoenix's complaint adequately
states allegations that, if proven, would render the Policy void from its inception for lack of an
insurable interest. The incontestability clause would not bar plaintiffs action as no contract
would exist if the Policy was void ab initio due to a lack of insurable interest. Section 627.455
provides that "[ e]very insurance contract shall provide that the policy shall be incontestable after
it has been in force during the lifetime of the insured for a period of 2 years ... " Fla. Stat. Ann.
§ 627.455 (emphasis added). Florida courts have interpreted this language to signify that the

statute regarding incontestability clauses applies only to a policy that is "in force," noting that
"the presence of an insurable interest is a fundamental prerequisite to the existence of an
insurance policy under Florida law, and public policy renders a policy procured without a valid
insurable interest void ab initio, i.e., from inception." TTSI Irrevocable Trust v. Reliastar Life
Ins. Co., 2010 WL 8721575, at *9 (Fla. Cir. Ct. Feb. 9, 2010); see also Atkinson v. Wal-Mart
Stores, Inc., 2009 WL 1458020, at *3 (M.D. Fla. May 26, 2009), aff'd 60 So.3d 1148 (Fla. Dist.

Ct. App. 2011) ("Florida courts have long held that insurable interest is necessary to the validity
of an insurance contract and, if it is lacking, the policy is considered a wagering contract and
void ab initio as against public policy."). Because the Policy in the present action lacks an

8

insurable interest for the reasons set forth in§ IV.C, infra, the Policy was never in force and the
incontestability period never began to run.
Defendant's interpretation of the relevant statutes contradicts the construction of those
statutes by Florida courts, and defendant fails to cite case authorities in support of its proposed
interpretations. Defendant's reliance on QBE Insurance Corp. v. Chalfonte Condominium

Apartment Association, Inc., 94 So.3d 541, 552 (Fla. 2012) and Lemy v. Direct General
Financial Co., 885 F. Supp. 2d 1265, 1272 (M.D. Fla. 2012) is misplaced because§ 627.455
expressly states that it applies only to policies that are "in force," and a policy that was void ab

initio cannot be presumed to be valid. Defendant also fails to appreciate the distinction between
void and voidable contracts recognized under Florida law:
"In general, the difference between void and voidable contracts is whether they
offend public policy. Contracts that offend an individual, such as those arising
from fraud, misrepresentation, or mistake, are voidable. Only contracts that
offend public policy or harm the public are void ab initio."

New Testament Baptist Church Inc. v. State, 993 So.2d 112, 116 (Fla. Dist. Ct. App. 2008)
(quoting Ockey v. Lehmer, 189 P.3d 51(Utah2008)); see also TTSI Irrevocable Trust, 2010 WL
8721575, at *9. Thus, while a contestability clause may bar a challenge based on fraud or
misrepresentation in an insurance application (DJ. 18, Ex. C at 6), a challenge based on a lack of
insurable interest is distinct because the policy itself never came into being, and the
incontestability provision never took effect in the first place, TTSI Irrevocable Trust, 2010 WL
8721575, at *9.
Defendant's reliance on Pruco Life Ins. Co. v. US Bank, 2013 WL 4496506 (S.D. Fla.
Aug. 20, 2013), a recent decision from the Southern District of Florida holding that an
incontestability clause applies equally to policies that are void ab initio, is also misplaced. The

9

court in US Bank compared a 2011 Florida case following the majority position3 with a 1989
New York case 4 following the minority position and applying New York law, 5 and determined
that the New York case was more closely aligned with Florida's public policy considerations.

Id. at *4. The US Bank court did not analyze or even mention the decision in TTSI Irrevocable
Trust, 2010 WL 8721575, nor did it consider a series of Florida Supreme Court cases declaring
that an insurance policy issued to a person without an insurable interest is void and does not even
come into being. See Meerdink v. Am. Ins. Co., 188 So. 764, 766 (Fla. 1939); Knott v. State ex

rel. Guaranty Income Life Ins. Co., 186 So. 788, 789-90 (Fla. 1939); see also Atkinson, 2009 WL
1458020, at *3. The US Bank court's analysis of Paul Revere Life Ins. Co. v. Damus, Ecker,

Rosenthal & Marshall, MD., 864 So.2d 442, 444 (Fla. Dist. Ct. App. 2003) is not compelling
because the case involved a challenge to misrepresentations, causing the contract to be voidable,
as opposed to void, in the context of a disability insurance case. In sum, the court's decision in

US Bank is non-binding as an unpublished District Court decision that is inconsistent with a
significant number of on-point Florida cases applying Florida law and public policy. This court
therefore rules in accordance with the weight of Florida case authorities.
C.

Insurable Interest

In support of its motion for judgment on the pleadings, defendant alleges that the Policy
was issued in accordance with Florida's statutory insurable interest law, and alternatively
because noncompliance with the statutory requirement does not render the life insurance policy
void ab initio. (D.I. 16 at 17) Specifically, defendant indicates that, at the time the Policy went
3

Pruco Life Ins. Co. v. Brasner, 2011 WL 134056 at n.5 (S.D. Fla. Jan. 7, 2011) (holding that
incontestability clauses have no effect where a policy is void ab initio for lack of insurable
interest).
4
New England Mut. Life Ins. Co. v. Caruso, 73 N. Y.2d 74 (1989).
5
Defendant fails to explain why the US Bank court's wholesale acceptance of a case based on
New York law is more persuasive than the numerous Florida cases upholding the majority
position. See n.2, supra.
10

into effect, the Policy's sole owner and beneficiary was a trust whose sole beneficiaries were Mr.
Skidmore's spouse and children, who had an insurable interest in Mr. Skidmore's life. (Id. at 18)
In response, plaintiff contends that Florida courts adopt a good faith standard when analyzing
whether an insurance policy possessed a valid insurable interest at issuance. (D.I. 18 at 18)
A 2008 amendment to § 627.404 provides that
[a]ny individual oflegal capacity may procure or effect an insurance contract on
his or her own life or body for the benefit of any person, but no person shall
procure or cause to be procured or effect an insurance contract on the life or body
of another individual unless the benefits under such policy are payable to the
individual insured or his or her personal representative, or to any person having,
at the time such contract was made, an insurable interest in the individual insured.
The insurable interest need not exist after the inception date of coverage under the
contract.
Fla. Stat. Ann. § 627.404(1). Florida courts have construed this provision to mean that "transfer
arrangements which pre-exist the inception of coverage violate the statute unless the transferee
has an insurable interest." John Hancock Life Ins. Co. v. Rubenstein, C.A. No. 09-cv-21721-UU,
D.I. 28 (S.D. Fla. Sept. 1, 2009); 6 see also AXA Equitable Life Ins. Co. v. Infinity Fin. Group,

LLC, 608 F. Supp. 2d 1349, 1356-57 (S.D. Fla. 2009) ("[T]he procurement and the assignment of
the policies was not done in good faith, but was part of a scheme devised by defendants to obtain
interests in insurance policies, not yet issued, that insured lives in which the defendants had no
insurable interest."); Sciaretta v. Lincoln Nat'l Life Ins. Co., 899 F. Supp. 2d 1318, 1324 (S.D.
Fla. 2012) ("I find that there is an implied covenant of good faith and fair dealing attached to Fla.
Stat. § 627.404' s requirement that there be an insurable interest at the inception of each
insurance policy. Therefore if the insurance policy at issue was procured with the intention that
6

Defendant alleges that the court in Rubenstein cited to Georgia law, not Florida law, and
therefore the case is inapposite. (D.I. 24 at 2) The court notes that the decision specifically
analyzes Florida Supreme Court authority, Florida Statute § 627.404, and Florida public policy.
Other than a tangential citation to one Eleventh Circuit decision applying Georgia law, which did
not provide the primary basis for the court's decision, this court fails to see how Rubenstein
involves anything other than an application of Florida law. (D.I. 18, Ex. C at 4-5)

11

it will be assigned or otherwise transferred to a person or entity with no insurable interest in the
life of the insured ... it is void ab initio. ")(internal quotations omitted)).
In the present case, the complaint alleges that
[t]he Policy was manufactured for the benefit of a third-party investor, which
lacked the requisite insurable interest in Mr. Skidmore's life at the time of the
Policy's issuance. Neither Mr. Skidmore nor any person with an insurable
interest in his life funded payment of the premiums on the Policy ... The
application for and purported ownership of the Policy by the Skidmore Trust was
merely a sham transaction intended to circumvent applicable insurable interest
laws and public policy.
(D.I. I at iJ 47) Accepting these allegations as true and viewing them in the light most favorable
to plaintiff, as the court must when considering a motion for judgment on the pleadings, the court
concludes that plaintiff has sufficiently stated a cause of action based upon allegations of the lack
of an insurable interest in the Policy.
D.

Counterclaims

Finally, defendant alleges that it is entitled to judgment on its counterclaims because
plaintiff breached the contract and violated the duty of good faith by failing to pay the Skidmore
death claim and delaying its decision on the claim. (D.I. I6 at 20) In response, plaintiff
contends that defendant cannot prevail on its counterclaims because it has failed to show the
existence of a valid and enforceable contract. (D.I. I 8 at 20)
Under Florida law, a cause of action for breach of contract has three elements: "(I) a
valid contract, (2) a material breach, and (3) damages." Havens v. Coast Florida, P.A., I I 7
So.3d I I 79, I I8I (Fla. Dist. Ct. App. 20I3) (citing Rollins, Inc. v. Butland, 95I So.2d 860, 876
(Fla. Dist. Ct. App. 2006)); see also Beck v. Lazard Freres & Co., LLC, I 75 F.3d 9I3, 9I4 (I I th
Cir. I 999). As previously stated, the court concludes that plaintiff has sufficiently pied a
challenge to the validity of the Policy in the present matter for purposes of Rule I 2( c). The court

I2

therefore cannot rule as a matter of law at this stage of the proceedings that defendant will
prevail on its counterclaim for breach of contract.

V.

CONCLUSION
For the reasons discussed above, I recommend that the court deny defendant's motion for

judgment on the pleadings. (D.I. 15)
This Report and Recommendation is filed pursuant to 28 U.S.C. § 636(b)(l)(B), Fed. R.
Civ. P. 72(b )(1 ), and D. Del. LR 72.1. The parties may serve and file specific written objections
within fourteen (14) days after being served with a copy of this Report and Recommendation.
Fed. R. Civ. P. 72(b). The failure of a party to object to legal conclusions may result in the loss
of the right to de novo review in the district court. See Henderson v. Carlson, 812 F.2d 874,
878-79 (3d Cir. 1987); Sincavage v. Barnhart, 171 F. App 'x 924, 925 n.l (3d Cir. 2006).
The parties are directed to the Court's Standing Order For Objections Filed Under Fed. R.
Civ. P. 72, dated October 9, 2013, a copy of which is available at
http://www.ded.uscourts.gov/court-info/local-rules-and-orders/general-orders.

Dated: September lk_, 2014
AGISTRATE JUDGE

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