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It might appear at first blush that cases involving noncitizens with pre-1988 convictions would be rare today, and should therefore be of only passing interest to overworked immigration attorneys. However, cases involving long term lawful permanent residents with old criminal convictions will continue to arise as the INS works to clear its backlog of naturalization applications, and as these individuals apply for renewal of their Resident Alien Cards. A clear, though not commonly known, rule once existed whereby noncitizens who were convicted of an aggravated felony other than murder prior to November 18, 1988 were not deportable based on the offense being defined as an aggravated felony.

On November 5, 1998, the Board of Immigration Appeals, en banc, decided Matter of Lettman, Interim Decision No. 3370 (BIA 1998). The Lettman decision was based on a new interpretation of two old statutes, the Anti Drug Abuse Act of 1988 (ADAA),1 which created the aggravated felony ground of deportation now condified as Immigration and Nationality Act (INA) § 237(a)(2)(A)(iii),2 and the Immigration Act of 1990 (IMMACT90) § 602(c).3 ADAA § 7344(b) clearly specified that the aggravated felony ground of deportability would apply only to convictions entered on or after November 18, 1988, the date of enactment of the ADAA, and the BIA and the Immigration and Natural-ization Service have until now follow-ed that effective date restriction when deciding in specific cases whether a pre-ADAA conviction rendered an alien deportable for having been convicted of an aggravated felony.4 Thus, for the past ten years a pre-November 18, 1988 conviction for an aggravated felony did not make an alien deportable under INA § 237(a)(2)(A)(iii) or its historical predecessors.

IMMACT90 reorganized the various grounds of deportability into a single section of the Immigration and Nationality Act, and modified some of them in the process. In Lettman, supra, the BIA reexamined IMMACT90 § 602(c), and interpreted language in that paragraph to mean that IMMACT90's reorganization of the grounds of deportability into a new section of the Immigration and Nationality Act effectively eliminated the effective date restriction imposed by ADAA § 7344(b). Apparently, this elimination of ADAA § 7344(b) in 1991 went unnoticed by the BIA and the INS, who have continued to recognize and enforce it in deportation proceedings and related regulations.5 It also went unnoticed by several federal circuit courts of appeal that have upheld the BIA’s previous interpretation of the continuing validity of ADAA § 7344(b).6

This article summarizes the law as it existed before November 5, 1998, reviews the new interpretation put forth by the BIA in Lettman, and discusses the larger issues created by Lettman in the context of the expanded definition of aggravated felony adopted by Congress in the Illegal Reform and Immigrant Responsibility Act of 1996 (IIRAIRA).7 Lettman appears to remove the last vestige of an era when concepts of "notice," "fair warning" and "due process" were thought to be necessary prerequisites to the proper administration of laws. Lettman may also form an important stepping stone toward complete retroactive removal of long term lawful permanent residents with old criminal convictions regardless of how long ago they occurred and regardless of any equities the individuals may have acquired since. Cases involving noncitizens with old convictions will continue to arise, and if Lettman is upheld by federal courts, will involve immense hardship and dislocation for individuals and families who were until now under the impression that their debt to American society had been paid.


In Matter of A-A-, 20 I. & N. Dec. 492 (BIA 1992), the BIA struggled to reconcile the definition of aggravated felony created by ADAA § 7342 and codified in INA § 101(a)(43), which was silent regarding its temporal reach, with the specific consequences or disabilities that flow from a conviction for a crime defined as an aggravated felony (such as deportability or ineligibility for various forms of relief from deportation) to which Congress had assigned clear effective dates. The BIA resolved the ambiguity by creating a two step analysis.

The two-step analysis is summarized as follows: First, determine whether the crime is defined as an aggravated felony; second, if the crime is defined as an aggravated felony, determine whether the conviction applies to a provision that attaches specific immigration consequences or disabilities to individuals convicted of aggravated felonies.

The two step test makes the definition of a crime as an aggravated felony merely a threshold matter in determining whether a particular immigration consequence or disability, such as deportability, should attach to an alien convicted of such a crime. The issue of whether a specific consequence, e.g., deportability under INA § 237(a)(2)(A)(iii) or ineligibility for specific forms of relief from deportation, should result from a crime being defined as an aggravated felony must be evaluated independently from the definition. Thus, a conviction satisfying the aggravated felony definition set forth in INA § 101(a)(43) does not automatically imply deportability under INA § 237(a)(2)(A)(iii). The prospective limit created by ADAA § 7344(b) established that a pre-November 18, 1988 conviction was not an aggravated felony as that term is defined in the Immigration and Nationality Act.

The two step analysis was reaffirmed by the BIA in Matter of Reyes, 20 I. & N. Dec. 789 (BIA 1994)(holding that the aggravated felony bar to a finding of good moral character contained in INA § 101(f)(8) does not apply to convictions predating November 29, 1990, the date of adoption of IMMACT90), has been upheld by numerous federal appellate court decisions ,8 and exceptions based on the application of this test have for years been incorporated in federal immigration regulations enforced by the INS.9

The BIA decided Matter of A-A- after Congress adopted IMMACT90, and had evaluated the effect of IMMACT90 on its treatment of aggravated felonies as part of that same decision.......the 1990 Act explicitly provides that the newly added crimes–money laundering, nonpolitical crimes of violence, and certain crimes in violation of foreign law . . . are aggravated felonies only if 'committed on or after the date of the enactment of [the 1990] Act.' Section 501(b) of the Immigration Act of 1990, 104 Stat. at 5048. Matter of A-A-, supra, at 499.

Thus, in Matter of A-A-, the BIA was not only aware of the existence of IMMACT90 when it put forth its two step analysis, it analyzed portions of IMMACT90 to support its statutory interpretation.


In a stunning reversal of established precedent, the BIA en banc found that “an alien convicted of an aggravated felony is subject to deportation regardless of the date of conviction when the alien is placed in deportation proceedings on or after March 1, 1991, and the crime falls within the aggravated felony definition." Matter of Lettman, Interim Decision No. 3370 (BIA, Nov. 5, 1998).

This departure from established case law is remarkable for several reasons that will be elaborated below. First, the BIA’s new interpretation of a seven year old statute constitutes a repeal by implication based on admittedly ambiguous language; second, under applicable Supreme Court precedent, the new interpretation of IMMACT90 § 602(c) impermissibly creates new legal consequences for actions already completed; third, the BIA reversed its longstanding interpretation of statutes that have been repeatedly tested over the past several years without acknowledging that it was doing so, and without providing any rationale for the change; and fourth, the BIA had previously affirmed the Immigration Judge’s finding that the Respondent was deportable under IIRAIRA's amended definition of aggravated felony, but retreated from that position in favor of its new interpretation of IMMACT90 § 602(c).

The withdrawal of its prior affirmation of the immigration judge's decision in favor of a questionable rationale based on IMMACT90 suggests that the BIA may doubt the legal sufficiency of retroactive language contained in INA § 101(a)(43) (as amended by IIRAIRA §§ 321(b) and (c))10 to support a finding of deportability for an alien convicted prior to November 18, 1988 of an aggravated felony. This doubt supports an argument against deportability for a retroactively defined aggravated felony described in a previous article.11

Repeal by Implication: IMMACT90 § 602(c) does not cite ADAA § 7344(b) or make any reference to the temporal reach of the aggravated felony ground of deportation now codified as INA § 237(a)(2)(A)(iii).12 Therefore, if it indeed effectuated the repeal of ADAA § 7344(b), such an interpretation must be construed as a repeal by implication of ADAA § 7344(b). The BIA majority acknowledged that IMMACT90 § 602(c) is ambiguous and capable of different readings: “We acknowledge from the outset that the second sentence of section 602(c) is difficult to decipher, even after considerable examination. In the end, we find it to be an ambiguous provision, which is capable of different readings, and we principally derive its meaning by looking for guidance beyond its literal language." Lettman, supra, at 9.

A cardinal rule of statutory interpretation is that repeals by implication are not favored, and federal courts will require a clear statement of congressional intent before finding that such repeal has in fact occurred.13

A corollary principle is that when two statutes are in conflict, a specific statute closely applicable to the substance of the controversy at hand controls over a more generalized provision. Farmer v. Employment Sec. Com's of North Carolina, 4 F.3d 1274, 1283-84 (4th Cir. 1993).

The Supreme Court has firmly articulated this principle as follows: It is a basic principle of statutory construction that a statute dealing with a narrow, precise, and specific subject is not submerged by a later enacted statute covering a more generalized spectrum. Where there is no clear intention otherwise, a specific statute will not be controlled or nullified by a general one, regardless of the priority of enactment. The reason and philosophy of the rule is, that when the mind of the legislator has been turned to the details of a subject, and he has acted upon it, a subsequent statute in general terms, or treating the subject in a general manner, and not expressly contradicting the original act, shall not be considered as intended to affect the more particular or positive previous provisions, unless it is absolutely necessary to give the latter act such a construction, in order that its words shall have any meaning at all.

Radzanower v. Touche Ross & Co., 426 U.S. 148, 153 (1976)(quoting Morton v. Mancari, 417 U.S. 535, 550-51 (1974) (emphasis added).14

In U.S. ex rel. Kwong Hai Chew v. Colding, 192 F.2d 1009, 1011 (2d Cir. 1951), the Second Circuit articulated tests for upholding a repeal by implication as follows: “The 1950 statute makes no reference to the 1918 act, as amended . . . nor to the Presidential Proclamations promul-gated thereunder, nor to the Regulations which implement the Proclamations. It is elementary that repeals by implication are not favored. We see no such repugnancy between the prior law and the 1950 statute as would justify holding that the Proclamations and their implementing Regulations have been impliedly repealed.” In Lettman, the respondent and the dissenting members of the BIA identified alternative interpretations of IMMACT90 § 602(c) that would avoid any implied repeal of ADAA § 7344(b), thus demonstrating that ADAA § 7344(b) must be held to survive IMMACT90 § 602(c).

Lettman arose in the Eleventh Circuit, and the Lettman majority relied heavily on the Eleventh Circuit decision in Lopez-Amaro v. INS, 25 F.3d 986 (11th Cir. 1994), cert. denied, 513 U.S. 1146 (1995) (interpreting the temporal reach of the firearms ground of deportation). But the Eleventh Circuit also abhors repeals by implication." Amendments by implication are disfavored. Only when Congress' intent to repeal or amend is clear and manifest will we conclude that a later act impliedly repeals or amends an earlier one." Ardestani v. U.S. Dept. of Justice, INS, 904 F.2d 1505, 1513-14 (11th Cir. 1990) (citing Patel v. Quality Inn South, 846 F.2d 700, 704 (11th Cir. 1988)). Thus, even in the Eleventh Circuit, which provided precedents relied upon by fourteen of the fifteen members of the BIA to control the outcome of Lettman, the issue is not resolved.

In enacting IMMACT90 § 602, Congress' only apparent intent with respect to the aggravated felony ground of deportation was “the consolidation of related grounds in order to make the law more rational and easy to understand.” Lettman, supra, at 8 (citing H.R. Conf. Rep. No. 101-955, at 119, 128 (1990)). Given the patently ambiguous language of IMMACT90 § 602(c), and the complete absence of any legislative history demonstrating a congressional intent to repeal ADAA § 7344(b), the clearly prospective operation of the aggravated felony ground of deportation cannot have been repealed by implication by IMMACT90 § 602(c), as held by the BIA in Lettman.

The strength of federal court precedents against finding a repeal by implication is thus manifest. Although the issue was clearly briefed by respondent,15 the BIA majority chose not to acknowledge the issue, and dismissed respondent’s arguments collectively with a single sentence: "We have not found the respondent’s argument in this area to be persuasive." Lettman, supra, at 8. Landgraf and the creation of new legal consequences.

The line of Supreme Court cases culminating in Landgraf v. USI Film Products, 511 U.S. 244 (1994) and recently reaffirmed in Hughes Aircraft Company v. United States ex rel. Schumer, 117 S.Ct. 1871 (1997), stands for the proposition that in order to interpret a statute as attaching new legal consequences to events completed before its enactment, Congress must clearly express its intent that the statute be retroactively applied to such situations. The aggravated felony ground of deportation now codified as INA § 237(a)(2)(A)(iii) established a mandatory, purely legal ground of deportability. If IMMACT90 § 602(c) is now interpreted to have stripped ADAA § 7344(b) from the books such that convictions that were once explicitly exempt from the aggravated felony definition at the time § 237(a)(2)(A)(iii) was created are no longer exempt, this interpretation would clearly attach new legal consequences to events completed before enactment of IMMACT90 § 602(c). Indeed, the respondent in Lettman is a clear example of an individual to whom new legal consequences have been attached by the BIA's revised interpretation of the admittedly ambiguous language of IMMACT90 § 602(c). Therefore, Landgraf principles apply, and the statutory language that purports to create the retroactive effect must be evaluated against the Landgraf standard.

Accordingly, since IMMACT90 § 602(c) is susceptible to more than one interpretation as acknowledged by the BIA, Landgraf bars any interpretation that results in an impermissible retroactive effect. Lettman is the quintessential impermissible retroactive effect prohibited by Landgraf.

Reversal of established statutory interpretation

Of the fifteen Board Members, three disagreed with the new interpretation of IMMACT90 § 602(c), and only one raised the issue of the implicit reversal of established statutory interpretation created by Lettman.

As Board Member Rosenberg pointed out, The majority now proposes to read an ambiguous savings clause provision of an 8-year-old legislative enactment in a way that is diametrically opposed to the interpretation that has been followed regularly, without providing any substantial reason for such a change. Lettman, supra, at 24 (Rosenberg, dissenting).

Having established and consistently followed a longstanding policy for interpreting the effect of an aggravated felony conviction in a specific case, the BIA is not free to reverse that policy as a matter of administrative discretion. The deference due an administrative decision depends on a number of factors, including: (1) the thoroughness of its consideration; (2) the validity of its reasoning; and (3) the consistency with earlier and later pronouncements. See, e.g., Detsel v. Sullivan, 895 F.2d 58, 65 (2d Cir. 1990). Patently inconsistent application of agency standards to similar situations lacks rationality and is arbitrary. See, e.g., Vargas v. INS, 938 F.2d 358, 362 (2d Cir. 1991). The U.S. Supreme Court concurs with this reasoning: "Though the agency’s discretion is unfettered at the outset, if it announces and follows–by rule or by settled course of adjudication–a general policy by which its exercise of discretion will be governed, an irrational departure from that policy (as opposed to an avowed alteration of it) could constitute action that must be overturned as 'arbitrary, capricious, [or] an abuse of discretion' within the meaning of the Administrative Procedure Act, 5 U.S.C. § 706(2)(A). See Yang v. INS, 117 S.Ct. 350, 353 (1996).

Thus, even if the BIA position in Lettman is a permissible interpretation of IMMACT90 § 602(c), the BIA is not free to arbitrarily reverse a previously established interpretation. Considering that the BIA has acknowledged the inherent ambiguity of § 602(c), Lettman is an arbitrary reversal of an established interpretation of law that should be reviewable in federal court as an abuse of administrative discretion.

Retreat from IIRAIRA

Lettman carries implications beyond the issue of pre-ADAA aggravated felonies. The explicitly prospective language of ADAA § 7344(b) supports a more far reaching argument against deportation based on a retroactively defined aggravated felony.16 In essence, the continued existence of an entire class of individuals shielded by ADAA § 7344(b) would represent a direct contradiction of the broadly implied retroactive language of IIRAIRA §§ 321(b) and (c), and would constitute further evidence that IIRAIRA §§ 321(b) and (c) do not provide sufficient authority to retroactively apply the now expanded definition of aggravated felonies to render noncitizens deportable for old convictions. However, if ADAA § 7344(b) was repealed by IMMACT90 § 602(c) as held by the BIA in Lettman, then that argument is correspondingly weakened. Careful examination of Lettman with respect to this issue reveals that Lettman raises more questions than it answers.

Lettman is the BIA's response to the respondent’s Motion to Reconsider a prior decision by the BIA in the case.17 The immigration judge had found the respondent deportable based on the retroactive language contained in IIRAIRA's amendments to the INA § 101(a)(43) definition of aggravated felonies. Respondent appealed the immigration judge’s finding of deportability based on the prospective language of ADAA § 7344(b), and citing applicable BIA precedent, especially Matter of A-A-, supra. In its response brief, the Immigration and Naturalization Service argued that the immigration judge's decision basing deportability on the retroactive language of IIRAIRA §§ 321(b) and (c) was correct. On its own initiative, the BIA then requested special briefing from the parties and from amici on the issue of the effect of IMMACT90 § 602(c) on ADAA § 7344(b).

In Lettman, the BIA concluded: On review, the Board agrees with the respondent that our previous decision should be reconsidered in light of additional legal arguments. Therefore, the motion to reconsider will be granted. Lettman, supra, at 4.

Thus, the BIA appears to have concluded that the apparently retroactive language contained in the aggravated felony definition (INA § 101(a)(43) as modified by IIRAIRA §§ 321(b) and (c)) is not sufficient to support a finding of deportability under INA § 237(a)(2)(A)(iii) for a pre-ADAA aggravated felony conviction. This is consistent with Matter of A-A-, supra. Indeed, in a separate footnote the BIA reaffirmed its holding in Matter of A-A-, as follows: The immigration judge appeared to base his deportability finding on the aforementioned IIRIRA provisions.However, these provisions are limited to the definition, and the specific deportation ground involved needed to be further examined before deportability could be upheld. Lettman, supra, n.14.

Thus, Lettman states that ADAA § 7344(b) was repealed, but the two step process remains valid. The two step process isolates the analysis of consequences or disabilities from the definition of an aggravated felony. It therefore renders IIRAIRA §§ 321(b) and (c), which apply only to the definition of an aggravated felony, insufficient to confer a retroactive effect on INA § 237(a)(2)(A)(iii). This is consistent with the BIA's decision in Lettman to grant the motion to reopen.

Lettman may therefore be read to provide substantial indirect support for the broader argument against deportability based on a retroactively defined aggravated felony. Whether that result was intended by the BIA is unclear. By way of another footnote, the BIA stated that it has not expressed an opinion concerning the interaction between the retroactive language contained in the aggravated felony definition of INA § 101(a)(43) and the prospective language of ADAA § 7344(b): Our decision today involves a crime which fell within the original definition of an aggravated felony. We therefore have not addressed the interaction between the prospective limitations which once existed in section 101(a)(43) of the Act, and the most recent changes to the aggravated felony definition. Lettman, supra, n.4.

By structuring its position in this way, the BIA may simply be reserving the option of finding in the future that in the absence of the prospective limitation previously provided by ADAA § 7344(b), the retroactive language of IIRAIRA §§ 321(b) and (c) is now sufficient to create the statutory authority to deport individuals for having been convicted of a retroactively defined aggravated felony. However, by abstaining from making such a finding here, the BIA has tacitly encouraged further litigation of the issue in other cases.

Judicial review of Lettman

The issue of whether Lettman is reviewable in federal court remains to be litigated, particularly in light of the Eleventh Circuit’s recent decision in Richardson v. Reno, No. 98-4230, December 9, 1998. However, the issue in Lettman is whether the respondent is deportable under INA § 237(a)(2)(A) (iii). Under INA § 242(a)(2)(C), "no court shall have jurisdiction to review any final order of removal against an alien who is removable by reason of having committed a criminal offense covered in section . . . 237(a)(2)(A)(iii) . . . ." Since the issue in Lettman (and in any analogous case) is whether the respondent is removable under 237(a)(2)(A)(iii), a reviewing court must address the substantive issue presented by Lettman in order to decide whether it has jurisdiction. Moreover, the determination of deportability under INA § 237(a)(2)(A)(iii) is a nondiscretionary, pure interpretation of law. Judicial review of such a determination is not precluded by INA § 242(a)(2)(B) (Denials of discretionary relief). Accordingly, judicial review should not be precluded by INA § 242(a)(2).


In Lettman, the BIA ruled that the explicitly prospective language contained in ADAA § 7344(b) was eliminated in its entirety as a result of the recodification of the grounds of deportability accomplished by the Immigration Act of 1990. The resulting repeal by implication of ADAA § 7344(b) and the abdication sub silencio of long established BIA precedent supported by numerous federal court decisions and federal regulations beg for review in federal court. Moreover, the startling interpretation of law adopted by an overwhelming majority of the BIA in this decision relies on an interpretation of an admittedly ambiguous statute that would clearly attach new legal consequences to acts already completed, an impermissible result under established Supreme Court precedent.

As of this writing, Lettman was undergoing initial review by the Eleventh Circuit on jurisdictional grounds alone. Regardless of the outcome there, any subsequent BIA decisions relying on Lettman should be contested other federal circuits. Even if Lettman survives federal court review, the two step test dividing the definition of an aggravated felony from the specific consequences or disabilities that may flow from that definition (e.g., application of the bar to good moral character under INA § 101(f)(8)) remains intact, but with substantially reduced effect.


1. Pub. L. No. 100-690, 102 Stat. 4470-71.

2. See 8 U.S.C. § 1227(a)(2)(A)(iii).

3. Pub. L. No. 101-649, 10

4. Stat. 4978. 4. See Matter of A-A-, 20 I. & N. Dec. 492, 497 (BIA 1992)("Congress explicitly stated that this deportation ground would only be prospectively applied to an alien ‘convicted, on or after the date of enactment of [the 1988] Act, of an aggravated felony.'"); see also INS Genco Opinion 91-25, "Aggravated Felony: Applicability to Convictions," Feb. 22, 1991.

5. See Note 9, supra.

6. See Note 8, supra.

7. Pub. L. No. 104-208, 110 Stat. 3009 (1996).

8. See, e.g., Asencio v. INS, 37 F.3d 614 (11th Cir. 1994); Campos v. INS, 16 F.3d 118 (6th Cir. 1994); De Osorio v. INS, 10 F.3d 1034 (4th Cir. 1993); Barreiro v. INS, 989 F.2d 52 (1st Cir. 1993).

9. See 8 C.F.R. § 240.56 (restricting the aggravated felony bar to eligibility for voluntary departure to convictions entered on or after November 18, 1988, consistent with Matter of A-A-, supra); see also 8 C.F.R. § 316.10(b)(2) (precluding a naturali-zation applicant from demonstrating good moral character only if he has been convicted of an aggravated felony on or after November 29, 1990, consis-tent with Matter of Reyes, supra).

10. IIRAIRA § 321(b) added the following language to the aggravated felony definition contained in INA § 101(a)(43): "Nothwithstanding any other provision of law (including any effective date), the term applies regardless of whether the conviction was entered before, on, or after the date of enactment of this paragraph." IIRAIRA § 321(c) stated that "the amendments made by this section shall apply to actions taken on or after the date of the enactment of this Act, regardless of when the conviction occurred . . . ."

11. See Ron Wada, An Argument Against Deportability Based on a Retroactively Defined Aggravated Felony, 3 Bender's Immigration Bulletin 1035 (Oct. 15, 1998).

12. IMMACT90 § 602(c) states, in relevant part, "Except as otherwise specifically provided in such section and subsection (d), the provisions of such section, as amended by this section, shall apply to all aliens described in subsection (a) thereof notwithstanding that (1) any such alien entered the United States before the date of the enactment of this Act, or (2) the facts, by reason of which an alien is described in such subsection, occurred before the date of the enactment of this Act."

13. See, e.g., Takao Ozawa v. U.S., 260 U.S. 178, 192 (1922) ("There is nothing in section 2169 which is repugnant to anything in the act of 1906. Both may stand and be given effect. It is clear, therefore, that there is no repeal by implication."); Girouard v. U.S., 328 U.S. 61, 79 (1946) ("There is no necessary inconsistency . . . between the 1940 Act and the 1942 amendments. Without it repeal by implication is not favored."); Kaku Nagano v. McGrath, 187 F.2d 759, 766-67 (7th Cir. 1951) ("We need no citation of authority to support the proposition that repeals by implication are never favored and that the clearest case possible must be made before an inference may properly be drawn that a later act by implication repeals an earlier one."); U.S. v. Joya-Martinez, 947 F.2d 1141, 1144 (4th Cir. 1991) ("An implied amendment or partial repeal of a statute will not be recognized by the courts, unless it clearly appears the legislature so intended.").

14. The Supreme Court provided further guidance on this issue in Touche Ross, supra, quoting from Posadas v. National City Bank, 296 U.S. 497, 503 ("the intention of the legislature to repeal must be clear and manifest"), and Morton v. Mancari, supra ("when two statutes are capable of co-existence, it is the duty of the courts . . . to regard each as effective").

15. See Memorandum of Law in Support of Motion to Re-Consider, In the Matter of Robert Lettman, A17-599-144, January 1998, submitted by Joan Friedland, Florida Immigrant Advocacy Center.

16. See Note 11, supra.

17. See Lettman, supra, at 3-4; see also Motion to Re-Consider, submitted to the Board of Immigration Appeals in the Matter of Robert Lettman, A17-599-144, July 31, 1997.

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