Thursday, September 20, 2012

Roberts Rules of Order and TFA

I just listened to the KUOW report (not yet available) on the vote of the TFA member to teach Special Ed at Franklin High.  What a mess and yet, interesting.  Here's what I understand happened.

They had six members in attendance (I believe Director Smith-Blum was missing).

Apparently the vote was 3 yeses (Martin-Morris, DeBell and Carr) and 3 abstained votes.  So the Board Manager said it did not pass.

DeBell corrected her and said abstaining votes don't count, they have a quorum and the majority of the quorum said yes.

THEN, Ron English, district counsel stepped up and said he wasn't sure.

Now, as a former PTA president who is supposed to know Robert's Rules of Order (but I don't know them well), I do know there are two issues.

One is what abstaining votes mean and the other is what constitutes a majority vote.

"...Abstentions do not count in tallying the vote; when members abstain, they are in effect only attending the meeting to aid in constituting a quorum..."

On the abstaining votes, DeBell is correct.  They do not count as votes at all.  (I have word out to the directors who did vote this way to ask why they voted this way.)

However, DeBell would seem to me to be wrong on what constitutes a majority.  

Robert's Rules seem to indicate that a majority of ALL ballots (including abstains) must vote Yes for a motion to pass.  They would have needed 4 yes votes to pass the measure and they did not have that.

What would be interesting is to ask Director Smith-Blum what her vote might have been.  Since it seems it did not pass, they may have to wait until she is there and see what that answer might be.

However, there are some differing statements in Robert's like this (and it may depend on which version you are reading):

...While it is the duty of every member who has an opinion on the question to express it by his vote, yet he cannot be compelled to do so. He may prefer to abstain from voting, though he knows the effect is the same as if he voted on the
prevailing side..."
This is NOT saying that the vote is counted as an affirmative (nor a negative), but that by abstaining, it is aiding the cause of the prevailing vote.
BUT

"...The basic requirement for adoption of a motion by any
assembly with a quorum is a Majority Vote, except for certain motions as listed below. A Majority is 'more than half' of the votes cast by persons legally entitled to vote, excluding blank votes and abstentions.
 
 
Majority does not mean 51%. In a situation with 1000 votes, Majority =501 votes; but 51% = 510 votes.
 

I will again say - NO one with 5 weeks of training should be teaching any Special Ed student.  I don't care how enthused or caring a person they are.  These are students with special needs (hence the "special" in education). TFA teachers have no training for these students and it is likely 
illegal and definitely wrong to put them in front of these students.  I have a 
special needs child and if they had tried this with me, I would have 
gotten my child out of that class and possibly sued the district.

46 comments:

Catherine said...

Melissa - did I interpret this posting correctly: DeBell was asserting that 3 of 6 votes is a majority (of quorum in attendance)? I've been on more than 10 boards over 20 years that used RRO as the standard and that's NEVER been how our groups have interpreted any of that standard.

Now - it may be that the SSB has some special rules in their charters or bylaws that say "tie goes the runner" but I don't see how since each side could say we got 3/6 votes which means our way goes.

I go back to one of the board meetings I attended when they were discussing math book selection and the then board president said "Most of us up here aren't that good at math, so....." I don't know what followed that assertion since my head was exploding.

mirmac1 said...

Yes, the board meeting was interesting. Like I said in another thread, I'm pleased three of our directors did not feel pressured to just hold their nose and vote yes, no matter how many research papers this undergrad provided data for.

The young man was there and, as is wont most TFA, talked about how uniquely talented he is and all enthused aboutl "passing on the joy of science" and all that.

I pointed out he was clearly just biding time before Med School, and that I was very concerned about the learning and social/emotional needs of his students that he would not address. I guess that's not a concern with our board; as long as he teaches a subset of the class, the rest can just drop out.

mirmac1 said...

WSSDA states majority present and voting. An abstention is not a vote.

In future, I say just vote no.

Anonymous said...

Does this mean the TFAer cannot teach in SPS until the vote is figured out?

SavvyVoter

Po3 said...

It is to bad the abstains did not simply vote No - would have been a clear tie.

I wonder what the abstain vote is about, usually you abstain if you have a conflict on interest.

Anonymous said...

Is the TFA candidate for Franklin being hired to teach Science, or SPED? Or is it to teach Science to students in SPED?
I'm confused.

-sps mom

Melissa Westbrook said...

I think until Mr. English sorts this out, no one is hired. They had a vote, their Legal counsel wasn't sure it was a valid vote and it would see they would error on the side of waiting to see the outcome.

They wanted to hire this candidate to teach Science but I believe there are Special Education students in the classroom.

mirmac1 said...

If this can be a thread about the meeting...?

What the heck was up with allowing former staffer Shannon MacMinnimee unlimited time to testify? Was it because of what she was testifying about? Not a peep out of DeBell as she easily exceeded four minutes at the podium.

So is that okay? If I'm talking about something DeBell likes (can't imagine that happening in this lifetime) I get unlimited time?

I think he noted our consternation because when a current staffer was speaking at the end, and abruptly cut off her testimony at the sound of the beep, he allowed her to finish her paragraph. I'm sure I would've gotten the hook.

mirmac1 said...

There are children with special learning needs, kids with social/emotional needs, and special needs students that are unidentified in EVERY classroom. Experienced teachers are more proficient at spotting these needs and how to address them, than a recent Chem major.

Carol Simmons said...

There are so many issues and concerns here. Robert's Rules is confusing but appears to state that an abstention is not a "no" vote. I assume the three Board members who abstained had their reasons for doing so and am anxious to learn what these reasons were. Another issue is the legality of a TFA recruit teaching classes where Special Education students are "mainstreamed." That is being researched by SPS General Counsel and we should know soon. The young TFA man appeared competent and caring but has not had the experience nor training to teach students let alone our Special Education students. I do not know of any administrator who has placed an untrained teacher in a classroom. Administrators were careful to never leave I.A.'s in classrooms without a certified teacher present, and the I.A.'s often had a great deal of experience. The TFA recruits do not. We could ask our Principals who are in central office positions now if they would have done so, or would do so now. Perhaps they would be willing to speak up and state why this is not only possibly illegal but professionally irresponsible and possibly very harmful to our students.

Anonymous said...

Smith-Blum has consistently voted to allow TFA. Imagine this means DeBell will simply bring the vote up again at the next meeting. Unless, from what I read here and The Times, he has so alienated Smith-Blum - or vise versa - that she also abstains. Someone should ask her her intentions, I guess.

EdVoter

Mary Griffin said...

I was at the meeting last night. The vote certainly was confusing. Prior to the vote Director Peaslee quizzed Paul Apostle and Ron English on whether a TFA applicant would be a "Highly Qualified" teacher under IDEA and whether they had any SpEd training in their five weeks of summer school. This line of questioning was based on the fact that he may have SpEd students in his science class, as SpEd students are to be included in the general curriculum. Mr. English responded by saying that Mr. Elroy An (the applicant) met all the criteria that a teacher would meet under a regular certificate, such as passing a WEST - B and a WEST - E, etc, and that he had suitable scholarly achievements, etc. Director Martin-Morris made the comment that regular teacher preparation curriculums vary widely and htat some do not include any informaiton on teaching SpEd. The vote was taken. Directors Peaslee, Patu and McLaren abstained. The vote was confusingly anticlimatic and I didn't stay until the end of the meeting to hear what Ron English said. There was very little discussion at the time, but my understanding is that an abstention counts as not voting, therefore the vote was 3-0. There was a quorum present, and a majority of those voting won. So the question in my mind is if the bylaws state a majority of those voting or a majority of those who were present and who were eligible to vote.



Mary Griffin said...

@mirmac1,

I believe the reason that Shannon MacMinnimee was allowed to testify that long was because she was testifying about Cheryl Chow.

I'm going to say something, and it isn't going to be popular, but all these people that have a problem with honoring Cheryl Chow are probably going to just have to back away from their keyboards for awhile. There is are legitimate times for jumping all over the school board and there is a time for keeping our mouth shut. And this is the time to keep our mouths shut.

Honoring a public servant in such a way is one of the good and decent things that society can do. So whether you agreed with Cheryl Chow or not, if you want to go all ballistic about not following the rules on testifying, this is not the time, because you will get no traction.

BTW, I went 7 seconds over when I was testifying and no one got out the gong on me. It was kind of fun, me being such a badass.

Anonymous said...

Help. I am confused. How do this TFA An's Special Education "credentials" differ from the "missing" TFA applicant that ended up being hired in Renton? Didn't Ron English say that SPS was unable to confirm the previous applicant's credentials related to Special Ed because there was no response to SPS messages? Or is the difference of situations related to the particular subject or classroom situation? Is this hire going to be teaching Special Education students? What was the actual wording of the motion? Does or does not this "hire" need training beyond that received through TFA in order to "legally" head the classroom?

Oompah

Mary Griffin said...

I believe there was confusion over which WEST tests the last candidate had passed, because the information supplied did not make sense, and when the Ron English attempted to contact the candidate over this, she did not return his calls. She was being hired to specifically teach Special Ed. This candidate is being hired to teach science. This candidate has taught in summer school in Chicago and has a bachelors in Biochemistry with a minor in Chemistry, and has co-authored scientific papers. He was one of the two-minute speakers in the public testimony. He made a good presentation for himself. Director Peaslee was fairly concerned about Special Ed kids in his classroom, and I am glad to see that. But people need to keep in mind that this vote was only whether the school board found that he fit the criteria to forward his application for a conditional certificate to the state, not a vote on whether TFA was a good idea or not. This may be one reason that there were some abstentions.

Melissa Westbrook said...

That Director Martin-Morris said he wanted to treat TFA teachers no differently from other teachers (this from the KUOW story) is ridiculous.

The district has a separate contract around hiring these teachers. They cost more money than new teachers. And so on.

They are NOT just a "new" teacher because if they were, we would not have a contract with TFA.

Louise said...

I am mystified how any board member justifies voting to have a TFA-er teach special ed. How can they do it? Did they state their reasons?

And on the other hand, why abstain instead of voting no? The whole situation stinks, honestly. Have a spine and vote no if that's what you believe.

Louise said...

Oh, now I see Mary's clarification - thanks Mary. It's a tiny bit clearer now.

Mary Griffin said...

To clarify what I said in my previous post, if a director thought that TFA was a bad idea, it might be a legitimate reason to abstain, rather than vote "no." I would be very interested in hearing why they abstained rather than voted "no." If there was a quorum present, and everyone had abstained and only one person voted "yes," and all that was needed was a majority of voters, than we might still have the same scenario--which would be an indictment of the process, in my opinion.

mirmac1 said...

Mary,

Notwithstanding the subject matter, the rules should be applied consistently. The current president has been more polite than Sundquist who, if he didn't like what you were saying, would interrupt sternly with "Conclude!"

Likewise, when directors would like to ask a question of a citizen who testified (like Chris Jackins), the current president squelches that. But if Holly Miller or Jonathan Knapp are in the audience, it's A-OK. Don't you think that is a double standard? Frankly, I'd rather hear what Chris has to say.

There would be a time or place for Ms McMinnimee's comments (who, BTW, is a former SPS counsel who beat down SpEd families. Good riddance). She could have arranged with a director for some time during his comment period.

Mary Griffin said...

@mirmac1

My point is that you need to fight these issues another day. Fight them when someone is not speaking of someone who is dying. Fight them when they are talking about TFA or Math or inequalities of BEX-IV or whether to roll the toilet paper over the top or under. When someone attacks on this point in this situation, it just makes them look bad.

Anonymous said...

To mirmac1,

It would seem to me that people like Holly Miller or Jonathan Knapp are called up to speak because their organizations are specific to the items being discussed, so it would make sense that this would be appropriate.

Two-cent Thursday

Anonymous said...

Out of curosity, I wanted the video online. Ms. McMinimee spoke for 2:59 seconds according my computer, and Ms. Chapman spoke for 2:42 seconds. Not sure what the big deal about a 17 second difference is.

Ms. McMinimee also identified herself as a resident of Seattle. Just because you used to work for SPS doesn't mean you shouldn't me allowed to execise your right to speak.

Sounds like some people have some serious sour grapes. Especially considerting the topic she.

-IMHO

mirmac1 said...

Note that the TFA staffers (who almost outnumbers the novice teachers) have taken a new tack. Last year it was "We're so Great and Enthusiastic!", then "We being treated so badly!", now it is "SPS, you're not holding up your end of the bargain!"

This was a bargain made in the backroom, in the shadows. The quals of their candidates are NOT being revealed even to the directors who are to vouch that they're "uniquely talented blah dee blah". No one guaranteed them spots. They do NOT conform to the minimum quals on the employment application. The only reason they are there is because MGJ and Susan Enfield said these folks will get treated special. Board policy says the Superintendent or his designee has final say. So Mr Banda is ulimately accountable for these unqualified people to teach in our most struggling schools. Period.

Anonymous said...

Out of curosity, I wanted the video online. Ms. McMinimee spoke for 2:59 seconds according my computer, and Ms. Chapman spoke for 2:42 seconds. Not sure what the big deal about a 17 second difference is.

Ms. McMinimee also identified herself as a resident of Seattle. Just because you used to work for SPS doesn't mean you shouldn't be allowed to execise your right to speak.

Sounds like some people have some serious sour grapes. Especially considerting the topic she was speaking to.

-IMHO

mirmac1 said...

IMHO,

Ms Chapman was allowed to complete her statement because DeBell had already allowed McMinnimee to continue and knew it would appear unfair. And actually, there were quite a few people in the room discomfited with McMinnimee's Free Mic night appearance. Are we all soured on grapes?

A director once wanted Mr Jackins to clarify an item he addressed and was on the agenda. He was not allowed to do so. Are only bureaucrats or former employees allowed free, uninterrupted speech?

Eric B said...

FWIW, I've usually seen DeBell let a speaker go on to about 15 seconds past time, then tell them to wrap up the comment. This has also generally not applied to Speaker #1, the official high school speaker. There were a few of those that went on for what seemed like hours, although were probably less than 5 minutes. Later high school student speakers (eg the groups from Nova talking about equitable funding) don't usually get the same leeway as Speaker #1.

Jack Whelan said...

I want to echo Mary Griffin. It's one thing to take on Wendy Kopp; it's another to take on the individual recruits. The fight over whether to let principals hire TFA recruits was lost last year. This particular candidate was hired by a principal, and while it's clear that he is very qualified in his area, we have to leave it to the principal to decide whether he can handle an inclusion classroom.

The question last night was simply focused on whether this candidate met the state legal requirement to manage a general science classroom with one or more special ed students in it. Apostle and English said it was legal. That may or may not be true. But the question before the board last night was whether to make this particular recruit a battleground about larger issues, and he probably does not deserve that.

So I interpreted the abstentions as saying: I don't like the position hiring TFA recruits puts the district in, but I can't really vote NO if that means this teacher is any less deserving of a conditional certification than any of the other TFA recruits.

This kid will probably do fine, I don't think the directors want to make these admirable young people scapegoats in a larger battle over ed reform. I think that's perfectly understandable. This kid will probably do fine. Anyway, that's what I was thinking as I watched the vote go down last night.


joanna said...

My understanding is that if the bylaws do not otherwise specify, Michael would be correct. However, if the rules of the organization require a majority of those present, then Ron is correct to call Michael's ruling into question. In this case it is not Robert's Rules that need to be examined, but the School Board's own rules.

Jan said...

I agree with Mary and Jack -- and I suspect that, given that Kay has previously voted to allow principals to hire TfA corps members, she would have voted yes here as well. As for the SPED students in the class, if they are being mainstreamed in to a class that would have otherwise not required that someone with a SPED certificate teach it -- well, that is what we signed up for here. And since the contract, that abominable contract, we entered into DID, in fact state that the Board would take the steps necessary to submit hired TfA folks for conditional certification -- I think they do unfortunately have a point when they say that declining them now is "failing to hold up our end of the deal."

I hate this deal. I think that inserting TfA into Seattle is a gross mangling of the original (laudible) purpose of the organization. I think it has been done because the organization is now intoxicated with growth and size, and has "manufactured" a bunch of bogus reasons to expand into areas that do NOT have shortages of qualified teachers. But -- we lost. The Board agreed to take this craven, dissembling group on board. Now, I think we have to live with what we agreed to do until the contract expires. At which point, I am hopeful that the Board will not renew it.

Unless the "deal" is that SPED kids cannot be mainstreamed into classes unless the teacher has SPED certification, the time to have thought about whether TfA folks, with 5 weeks of training, were going to have the chops to handle classes where a SPED kid or two might be mainstreamed into it was before -- when we were looking at whether to do this deal at all.

HMM and MdB are, in my opinion, total political hacks. But I cannot for the life of me fathom why a Boeing exec (Sherry) or a successful businesswoman (Kay) would have signed up for this circus!

Melissa Westbrook said...

So Director Peaslee said her vote was based on the fact that the candidate did meet the need that the school had and had some intellectual distinction in his area. She felt the answers she was given on whether the candidates was qualified to teach Special Ed were unclear. So she felt it necessary to abstain.

I have the answer from Ron English and I'll post it tomorrow but it would seem the vote will stand as affirmative.

I agree that it is not worth fighting over one candidate. I mean TFA is doing so poorly in the hiring in SPS (and I suspect in Federal Way given how the one TFAer fled in the first couple of weeks - not a great first impression).

You almost have to feel sorry for them in thinking this would be easy to just waltz in and expect open arms.

And you feel sorry for UW losing money on their program which is woefully underenrolled. Or rather, feel sorry that some other UW program is losing funding to the TFA program.

If charters don't pass, TFA will likely not last. Apparently, they aren't all that impressive to hiring teams through the Puget Sound region.

If charters do pass, well, then they are in like Flynn because those two things DO go together. Nothing like having a system of low-performing charters mostly populated by under-trained TFAers.

Anonymous said...

we have to leave it to the principal to decide whether he can handle an inclusion classroom.

Jack, what the heck are you talking about? ??? What's an "inclusion" classroom? As Mirmac notes, EVERY class... or nearly every class, in a high school has students with disabilities. As to "inclusion" classroom, what are you really talking about? Franklin has no "inclusion" program per se, that is, a class where a speciale educator manages special educatin students in general education. There's nothing that the sped central staff have designated as "inclusioN" programs at Franklin. So, that can't be it. There's no 1/2 and 1/2 type of thing... the so-called "blended programs" went the way of the do-do and only applied to kindergarten. ???? It sounds like you have the idea that students with disabilities are typically warehoused somewhere and allowed out every now and then for a special sort of thing called an "inclusion" classroom. Maybe there is such a thing, but it isnt' sanctioned by sped central staff... and none of the rest of us know about it.

The other question remains. What exactly was the TFAer hired for? Science? Or, special ed? There is no "science" disability, so no science class would ever be considered a special ed classroom - at least, not in any sane world. Not saying they don't have such things, but they are not defined anywhere.

-sped parent

mirmac1 said...

Likewise, sped parent there is no U.S. History disability, yet isn't that what the SAO said Ballard's principal spent restricted-use $$$ on?

I much prefer having caring, inquisitive board directors like McLaren, Patu and Peaslee, who strive to understand what the ramifications of placing a five-weeker in a HS in SE Seattle. Elroy An said he taught summer school in the Chicago Southside. Take a look at TFA's training. At most, these folks might actually get a full day or so, along with a passel of other trainees. Those poor kids are guinea pigs for this group.

I understand sped parent's consternation with Jack's comment. As I noted last night, the time is long gone when it should left up to principal prerogative whether our children are full members of a science classroom in their neighborhood school. ALL our kids deserve inclusion and great, fully qualified teachers.

Anonymous said...

Ceclia,

I have to say, your ever shifting logic does make this look like useless sour grapes. First your claim that Ms. McMinimee got well over four minutes, but when you watch the video it's clear her testimony was about three minutes. Then you claim that Ms. Chapman got "aburtely cut off," but if you watch the video you see that she stopped herself, then Director DeBell told her to continue (again for about three minutes). Ms. Chapman and Ms. McMinimee spoke for pretty much the same amount of time, give or take 15 seconds. Mary went after Ms. McMinimee and she went over her time too. No big deal. Now you seem to think that Ms. McMinimee shouldn't have a right to be a public speaker because she used to work for the district. Just because someone used to work for the district doesn't mean that they don't have a right to give public testimony. I get that you don't like the work she did, but it wasn't like she was there talking about special ed or teacher for american. She was there to speak in support of a proclamation for someone who is very clearly extremely ill. And from what it sounds like, she did so because of Charlie's post. Your fixation on this makes you look petty and small and that all you care about is insulting people with whom you disagree. It make you no better than the board members you dislike so much when you try to silence people who you don't agree with. It undermines your credibility on other things. And I say that as someone who has agreed with you in the past.

-IMHO

Anonymous said...

The main problem with Ballard HS (or any other school) using special education $$$ on general ed US History classes is not that there's no "US History disability". Special ed teachers have bargained for special ed student caseloads based on their ability to serve those students. Likewise, general educators have bargained for 150 general ed students across the day, based on their ability to serve them. Those caseloads are FULLTIME, all day long. Students have program types in their IEPs. That too is a negotiated, legal contract. When a program's special ed teacher is off doing other things (like teaching US History), then the student really is not in the program their IEP team agreed to. It is a breach of the IEP, breach of the union contract, and a subversion of funds. Other than all that, maybe it's a fine idea.

-sped parent

Michael H said...

Roberts Rules of Order don't trump state law. Check the law to determine what counts as a majority.

Anonymous said...

How are blended classes funded if they are include history? At Eckstein blended classes include LA, history & math.

By blended I mean 2 certificated teachers one of whom is sped certified. Some proportion of the class is sped students & some proportion is typically developing students.

Eckstein parent

Charlie Mas said...

Robert's Rules of Order is actually pretty clear. The motion passes if approved by the majority of votes cast. Abstentions do not count as votes cast. There were three votes cast and all three were in favor, so the motion was approved.

There are two problems here.

One is that the contract with Teach for America REQUIRES the Board to vote to approve the request for a conditional certificate for EVERY Teach for America candidate. It is an EXTRAORDINARILY BAD idea for the Board to contractually obligate themselves to vote a certain way on future matters. That represents a gross failure to provide good governance.

Second is the agreement in the contract to regard acceptance into Teach for America as the public award or recognition of special achievement required by law for candidates to qualify for a conditional certificate.

Those are both very, very bad things that the Board - and the District staff - allowed into the contract.

mirmac1 said...

I'm surprised Ron English said district policy calls for a majority of those present. I tried to find it in the board bylaws and policies, but could not.

Anonymous said...

There are times where it becomes very obvious that Ron English is a construction lawyer, not somebody who has the skill set that a general counsel normally has. Better that he acknowledged he didn't know the answer then to make something up. I suspect that what Melissa is going to report today is that he confirmed that the motion passed because the board follows Roberts rules of order where you are to go by the majority of votes cast with abstention not counting.

-ITK

Jack Whelan said...

@sped parent--

The TFA recruit was hired to teach science. He will, as you point out, have one or more special ed kids in his class as all teachers do. As I understand it, there will be no demands made on this teacher regarding sped students that are not made on any other classroom teacher.

I don't think it's a good idea to hire TFA recruits for a whole raft of reasons, but, as I said, that's a battle that was lost last year. The question before the board was a technical one concerning whether there was something about this particular recruit's qualification that made him ineligible for conditional certification. Apparently there was not.

So don't you agree that given the agreement we have with TFA, it's the principal's decision to make whether this candidate can handle a classroom? The principal may or may not have good judgement; the principal may or may not be politically motivated. But it's not the board's job to second guess the principal. What part of that am I getting wrong?

I do think it's the board's and the state's long-term responsibility to change the "principal culture", but that's another issue.

mirmac1 said...

That's the irony of Ballard's BS "inclusion" scheme. There ARE no demands placed on the other teachers. All the high-incidence sped students are concentrated in a few teachers' classrooms while the other teachers have zero. How are both regular ed kids and sped kids getting served in these regular ed classrooms, taught by teachers on the sped dime?

No Jack, it is not up to the principal. Washington's ESEA HQ Teacher plan calls for fewer out-of-field teachers, fewer conditional certs, and fewer inexperienced teachers in high poverty, high minority schools. Our superintendent could decide that THAT is the right thing to do. Board policy 5000 says "The Superintendent or his or her designee has the final authority for candidate selection."

Jack Whelan said...

@mirmac1 If principals are not following board policy, then, yes of course, they should be made to do so. Is that the case at Franklin where this TFA candidate is teaching? In other words will this TFAer be in a classroom stacked with sped kids, in one that will have none, or in one with the correct distribution?

But it seems to me that the issue regarding abuses of money that should be dedicated to sped students is different from whether this TFA kid should be certified to teach in the second or third types of classrooms. If he's going to wind up in the first, there are bigger issues than his conditional certification that need to be addressed. And dealing with that issue is beyond the scope of this particular board vote last week.

mirmac1 said...

Interesting, in Renton they dispense altogether with board approval for a conditional cert. To heck with WAC 181-79a-231(1)(e)...

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