Presentation on theme: "LEVEL TWO – ERASE STRATEGY"— Presentation transcript:
1 LEVEL TWO – ERASE STRATEGY BASICTHREAT & RISKASSESSMENTOVERVIEWLEVEL TWO – ERASE STRATEGY
2 ACKNOWLEDGEMENTSThe Canadian Centre For Threat Assessment & Trauma Response and Safer Schools Together is dedicated to ensuring safe and caring school communities and would like to acknowledge the BC Ministry of Education for its commitment in preventing bullying and ensuring safe and caring school communities by initiating the ERASE Bullying strategy (Expect Respect and a Safe Education).
3 HISTORICAL OVERVIEW OF THREAT ASSESSMENT IN CANADA THREAT ASSESSMENT TRAINING - DAY 14/6/2017HISTORICAL OVERVIEW OF THREAT ASSESSMENT IN CANADAThe Taber Response Project Photograph by: Calgary Herald ArchiveThe Taber School shooting occurred on April 28, 1999, just eight days after the Columbine School shooting in Colorado. Trauma response initiatives, headed by J. Kevin Cameron, Executive Director of CCTATR, led to the Alberta Government identifying the need to further examine incidents of this scope. Mr. Cameron was seconded by the Alberta Government and so began his investigation into not only trauma but eventually threat assessment.Consultations with U.S. sites that experienced school shootingsThe findings from these consultations shaped the field of Violence Threat/Risk Assessment and Trauma Response from that point forward.File Located on Safe Schools External Hard Drive
4 EVOLUTION/DEVELOPMENT OF VIOLENCE THREAT/RISK ASSESSMENT The field of Violence Threat/Risk Assessment is a relatively new field.As with any new field, there is an evolutionary process that it experiences.We are now in the 9th edition of the Protocol. The British Columbia Ministry of Education’s adaptation of the Level Two Training Guide has become the 5th edition of the training manual.
5 THREAT ASSESSMENT TRAINING - DAY 1 4/6/2017Threat Assessment has been referred to as the “missing link” in violence prevention. It is the process of deliberately trying to connect the dots or data that paints the picture that someone is moving on a pathway towards serious violence before the violent act occurs. All threats must be taken seriously and assessed in a timely manner.File Located on Safe Schools External Hard Drive
6 THREAT ASSESSMENT TRAINING - DAY 1 4/6/2017VTRA’s four basic steps include: Identifying worrisome or threatening behaviour.Using a multi-disciplinary team to conduct aviolence threat risk assessment.Determining if a threat maker actually poses a risk.Intervening appropriately.File Located on Safe Schools External Hard Drive
7 UNI-DIMENSIONAL ASSESSMENTS - are the plague of the violence threat/risk assessment world.They can occur when one person of any professional background such as mental health, policing, or school administration chooses to interview the individual in question without validating the interview data, and without investigating history regarding past violence, suicide attempts, or other factors.It is important to avoid uni-dimensional assessments because they do not provide an accurate and comprehensive understanding of the potential level of risk.
8 MULTI-DISCIPLINARY ASSESSMENTS - are required to determine accurate levels of riskand appropriate intervention.A multi-disciplinary assessment brings together groups of professionals from diverse disciplines to provide comprehensive assessment data and contextual variables. This allows you to determine an accurate level of risk and appropriate intervention strategy.
9 APPLICATION OF VTRA COMMITTEE AND TEAMS *Every school should have a Stage I VTRA team and every school district should have a district-wide team or personnel who can parachute in on school cases when extra support is required.*The district VTRA team leader (principal or designate) must be notified of all activations of the Stage I or II protocol.*The team is focused on collecting readily available data through a locker check, police check, and student file/record review that indicates the threat maker has “engaged in behaviour consistent with their threat.COMMITTEE AND TEAMSVTRA Committees and Protocol DevelopmentStep 1:A multi-disciplinary VTRA Committee must be developed to follow the guidelines set out in the district/regional protocol. VTRA Committees should be minimally represented by the following and/or their designate.Step 2: VTRA Team Development: a) Stage I VTRA Teams (sometimes referred to as the school/police team)b) School District/Division level VTRA teamc) Stage II VTRA teams
10 APPLICATION OF VTRA Stage I - VTRA Team Leadership and Team Activation Once the Stage I team is activated, leadership is shared and the team collaboratively decides initial steps that need to be taken for immediate data collection and any immediate risk-reducing interventions.School principals are responsible for disciplinary measures that may need to be taken to ensure the overall safety of students and staff.Police are responsible for determining if a parallel investigation focusing on the criminal aspect of the case will go forward while addressing public safety concerns.
11 Stage 1 - Data Collection and Immediate Risk-Reducing Intervention Stage I VTRA Teams must include the following three professionals and others as the team or committee deems appropriate on a continuous or case-by-case basis.School Principal and/or designateClinician (e.g. psychologist, counsellor, social worker)Police of JurisdictionStage II (consultation and/or information sharing phase)Other
12 THREAT ASSESSMENT TRAINING - DAY 1 4/6/2017LEVELS OF RISKLow categorization of risk does not imply no risk, but indicates the individual is at little risk for violence, and monitoring of the matter may be appropriate.Medium categorization of risk indicates the individual is at an elevated risk for violence, and the measures currently in place or further measures, including monitoring, are required in an effort to manage the individual’s future risk.High categorization of risk indicates the individual is at high or imminent risk for violence, and immediate intervention is required to prevent an act of violence from occurring.File Located on Safe Schools External Hard Drive
14 Stage II - Comprehensive Risk Evaluation Stage II involves a multi-disciplinary risk evaluation which often includes some or all of the following:police-based threat-assessment unitspsychology, psychiatry, mental health, child protection, youth probation, and othersStage II is focused on further data collection beyond the initial data set obtained by the Stage I Team and as such, the Stage II members are charged, in collaboration with the Stage I Team, with the formal risk assessment and evaluation which may include the use of tests and measures.
15 RISK ASSESSMENTNote:After the initial level of risk is assessed and immediate risk-reducing interventions have occurred, a further risk assessment may be required.Risk Assessment is the process of determining if an individual may pose a further risk to a known or unknown target or targets in an unknown period of time.a more comprehensive evaluation of all risk-reducing and risk-enhancing factors affecting the student. It determines long-term interventions and treatment goals.conducted by professionals who have completed advanced threat/risk assessments.
16 Stage III -Longer Term Treatment Planning Stage III requires reconvening all the Stage I and II team members who are involved in the case for the development and implementation of a comprehensive multi-disciplinary intervention, and to determine a follow-up date for case review.The agency that will take the lead at this point is the one that is the most appropriate at the time: every case on its own merit!In complex cases, one agency may take the initial lead, but after stabilization another may assume the leadership/coordinating role.
17 DETERMINING WHEN TO ACTIVATE A VIOLENCE THREAT/RISK ASSESSMENT IMMEDIATE RISK SITUATIONSThese situations include armed intruders inside the building or on the periphery who pose a risk to some target or targets, or active shooter and attacker scenarios.When immediate risk is identified, the principal will:contact the police and take steps to ensure the safety of all school members (e.g. perimeter lockdown, full-scale lockdown, and other protective measures).In these cases, a threat is posed and the matter is one of immediate police intervention and protective school response.
18 AUTOMATIC STAGE I VTRA ACTIVATION FOR: Serious violence or violence with intent to harm or killVerbal/written threats to kill others which are “clear, direct, and plausible”Internet website / threats to kill othersBullying - verbal, physical, cyber, and social via repeated patterns of behaviour and victimization
19 AUTOMATIC STAGE I VTRA ACTIVATION FOR: Possession of weapons including replicasBomb threats and making and/or detonating explosive devicesFire settingSexual intimidation or assaultGang-related intimidation and violence
20 Note: Criminal Charges In cases of violence or criminal acts, the police officer on the V-TRA team has “first call” as to whether charges will be laid.If the officer chooses not to proceed with criminal charges, Stage I will continue.If charges are laid, the officer of the V-TRA team often will refer it to another member so that they may stay on the team and participate in the Stage I process.An investigation does not prevent the remaining members from continuing the Stage I process.Collaboration will continue among the members, not withstanding each member has his/her own “jurisdiction”.
21 WORRISOME BEHAVIOURSThose that cause concern for members of the school community that may indicate a student is moving towards engaging in serious violent behaviour.This could include:drawing pictureswriting stories in classmaking vague statements that do not, of themselves, constitute “uttering threats” as defined by law, but are cause of concern for some members of the school community because of their violent content.The majority of high-risk behaviour, from Kindergarten to Grade 12, falls into this category.
22 When in Doubt Check It Out! WORRISOME BEHAVIOURSWhen in Doubt Check It Out!In many cases, following up on Worrisome Behaviours results in good early intervention measures. There are also cases where a little data leads to a lot and what seems like a minor case can quickly evolve to the formal activation of the VTRA team.
23 First Hypothesis in Threat Assessment: “It is a cry for help!” THREAT ASSESSMENT TRAINING - DAY 14/6/2017First Hypothesis in Threat Assessment: “It is a cry for help!”File Located on Safe Schools External Hard Drive
24 THREE PRIMARY HYPOTHESES IN VTRA One: Is it a conscious or unconscious “Cry for help”?Why would someone consciously or unconsciously give pre-incident signs or indicators?Two: Conspiracy of two or more! Who else knows about it? Who else is involved?Pairing Virtual Pairing Leakage
25 THREE PRIMARY HYPOTHESES IN VTRA Three: Is there any evidence of fluidity?Fluidity refers to the way a person can move from thoughts of homicide to thoughts of suicide and is also referred to as psychological shifting. Fluidity is important because the first hypothesis in a VTRA is that the threat is a cry for help.
26 IMPLICATIONS If we only assess in the homicidal domain, or fail to assess at all, because the threat maker is non-traditional, we miss an opportunity to intervene. In some cases we may run the risk of the student residing in the suicidal domain and completing a suicide.
27 SERIOUS VIOLENCE IS EVOLUTIONARY An individual who engages in serious violence does not spontaneously make the decision to harm someone. In some way, the individual’s thoughts, feelings, and behaviours moved them closer to the act before the act was committed.An individual who has never conceived of committing a serious violent act does not suddenly assault or kill someone. No one just snaps.There are signs that indicate that an individual is moving along a pathway to violence.
28 EVOLUTION OF VIOLENCE: KEY CONCEPTS Pathway to ViolenceThe pathway to serious violence is not a straight line. As an individual moves along a pathway to violence, that person is influenced by a large number of factors. The individual’s motivation will fluctuate, as will the emotional state. It is vital that the VTRA team be aware of these fluctuations and assesses the person’s behaviour over a period of time.
29 KEY POINTS REVIEWSerious violence is an evolutionary process no one just snaps. Everyone moves along a “Pathway of Justification”. Suspension of the student without TA often adds to the justification process. The biggest problem in the aftermath of high-profile violence is “under reaction” to often blatant indicators someone is moving on a pathway to serious violence. First hypothesis in threat assessment “It’s a cry for help”! The pathway to serious violence is not a straight line. “Good kid with no history of violence” is the quote that kills.
30 KEY FACTORS/CHARACTERISTICS TO BE CONSIDERED WHEN ASSESSING VIOLENCE: Dehumanization:the process that allows a person to emotionally, psychologically, and cognitively distance themselves from the nature of the act.Frequency/Intensity/Recency (FIR):the factors to be tracked when a change in baseline behaviour is noted.Empty Vessel:An individual who is not connected to a healthy mature adult will search for people or things to identify with. “What are they filling themselves up with?”
31 EMPTY VESSELS Do not allow yourself to be fooled by first looks. The individual is well liked, comes from a good family, is a good student, etc.Mere portrayal of these images does not indicate connectedness.There may be a much different story going on than what is being portrayed on the outside.If we can determine that there is a lack of connection, the next question we ask is “What are they filling themselves up with?”
32 THREAT ASSESSMENT TRAINING - DAY 1 4/6/2017Empty VesselsWhat are They Filling Themselves UpWith?KEY POINT: (Imitators vs. Innovators)Most threat makers are Imitators, not Innovators.If we do not give them anything to fill themselves up with, they will find it themselves.Is what they are filling themselves up with going to influence their violence potential?File Located on Safe Schools External Hard Drive
33 Our children will be what they fill themselves up with. MoviesMediaGamesWritingsDrawingsMusic
35 GIRL VIOLENCE “Violence and Bullying in girls can be subtle, but still requires response.”Girls are often overlooked as we believe most violence occurs with boys.Females seem to indulge more in emotional or social bullying. A girl who has significant power and influence in school or social settings can become a puppet master. While boys or girls can be puppet masters, the majority of puppet masters are female.
36 VTRA and Bullying Prevention The foundation of the VTRA model as relates to both violence prevention and bullying prevention is the emphasis on school dynamics.Naturally Open schools consistently work to be emotionally connected to each other in respectful ways that include healthy staff-to-staff relations, student-to-staff relations, and parent-school relations.When these exist there is an increased openness by concerned studentsand bystanders to report to adults when someone is in need.Naturally Closed schools or Traumatically Closed schools may be so emotionally disconnected that they see nothing until it is too late, or view their role in bullying prevention as insignificant or unnecessary as they state that, “bullying has been around for years and always will be.”The VTRA model assists schools in identifying and preventing the extreme acts of bullying that are becoming far too common in this generation.
37 CYBER-BULLYINGCyber-bullying is not limited to girls, but we see more girls engaging in cyber-bullying behaviour.increasing and becoming more concerning every yearonline attacks are increasingly clever and creativeThe simple way to define this behaviour would be to call it what it is: social assassination.
38 SOCIAL ASSASSINATIONUsing YouTube, Facebook, MySpace, Twitter, blogs, forums, and other such sites to attack the character and reputation of others. ( Hate Contracts )Technology (mobile devices including iPhones or other smart phones):can facilitate bullying, exclusion, and social isolationallow youth to access social networking sites anytime they wish and send picture and video messagesTechnology is a true gift for cowards who bully.They don’t have to look at their victims and they don’t have to deal with immediate, negative reactions from bystanders.
39 LOCKER AND BEDROOM DYNAMICS THREAT ASSESSMENT TRAINING - DAY 14/6/2017LOCKER AND BEDROOM DYNAMICSIn hundreds of cases in Canada we have found the evidence of planning in either the threat maker’s locker at school, their bedroom at home, or both.In some cases, such as the 1999 Taber School Shooting, the evidence was found too late, after the violence had occurred. But in most cases, the evidence has been uncovered during the formal violence threat/risk assessment (VTRA) and intervention process, and before violence or more serious violence could continue.File Located on Safe Schools External Hard Drive
40 THREAT ASSESSMENT TRAINING - DAY 1 4/6/2017File Located on Safe Schools External Hard Drive
41 HUMAN TARGET SELECTION Primary factors that influence the magnitude of school shootings and other traumatic events include:Human Target Selection:JustificationCurrent target or targetsHistory of violence/human target selectionIf we understand the threat maker’s history of violence and who that violence has been directed at, we can more easily determine if there is a “clear and discernible pattern of offending” and a higher likelihood to act out against a specific human target.
43 THREAT ASSESSMENT TRAINING - DAY 1 4/6/2017SITE SELECTIONSite Selection:conscious or unconscious belief that the site is the cause of all their pain, and therefore a justifiable targetbelief that they are less likely to get caughtsite of opportunitySite selection can be placed on a continuum - from psychological fusion to the site on one end, and site of opportunity on the other.File Located on Safe Schools External Hard Drive
44 Critical Periods: Ground Zero and Impact Zone Predictable time frames for increased threat-making andthreat-related behavioursCritical Period 1 – two weeks post incidentCritical Period 2 – 1 month prior to ChristmasCritical Period 3 – the anniversary of the incident within the impact zoneCritical Period 4 – when we are caught in the impact zone of another incident (parallel process)Critical Period 5 –unique to each school and community system
45 SYSTEMS THEORYviews trauma intervention as a complex and comprehensive process.requires schools and communities to address the trauma context by looking at:structurefunctionhistoryprovides insight into how different systems respond to trauma.assists multi-disciplinary VTRA teams to assess high-risk behaviour from both a behavioural and a systems perspective.
46 UNDERSTANDING THE SCHOOL AS A SYSTEM Respondrefers to the emotional/behavioural response to the crisis or traumatic eventSystemrefers to the relationship dynamics between the school administration, staff, students, parents and others within the formal organization
47 UNDERSTANDING THE SCHOOL AS A SYSTEM Not all school systems respond in the same way. Multiple schools exposed to identical traumatic stimuli can respond in dramatically different ways.Before attempting to provide support to a school, crisis responders should be acutely aware of the following:Trauma history of the schoolSchool’s pre-trauma functioningLeadership structure of the schoolInformation-sharing process between administration, staff, students, and parentsSchool’s attitude to the crisis response teamSchool’s beliefs and expectations about recovery
48 TES Model: Types of Systems Naturally Open School SystemsNaturally Closed School SystemsTraumatically Open School SystemsTraumatically Closed School Systems
50 FACTORS IN THREAT ASSESSMENT A team must have as many details as possible in order to effectively evaluate a threat. (Stage I Threat Assessment Report Form).If the threat is “clear, direct and plausible”, the Stage I protocol should be activated.Always work from the leading hypothesis that most threats are a cry for help.
51 FACTORS IN THREAT ASSESSMENT A threat that contains specific details about targets, weapons, locations, and motivation is much more likely to be carried out. The more detail contained in a threat, the more thought that has gone into the planning.Specific Plausible Details:Can identify target(s), weapon, method, time, location – higher riskMore detail and thought invested – higher riskMore plausible – higher riskLess specific data – lower riskSpecific but not plausible details – lower risk
52 THREAT ASSESSMENT VS RISK ASSESSMENT Threat assessment is the process of determining if a threat maker actually poses a risk to the target or targets threatened. Many individuals engage in threat-making behaviour but few actually do harm to others or themselves.Risk assessment is the process of determining if an individual may pose a further risk to a known or unknown target or targets in an unknown period of time.
53 DETERMINING WHEN TO ACTIVATE A VIOLENCE THREAT/RISK ASSESSMENT IMMEDIATE RISK SITUATIONSThese situations include armed intruders inside the building or on the periphery who pose a risk to some target or targets, or active shooter and attacker scenarios.When immediate risk is identified, the principal will:contact the police and take steps to ensure the safety of all school members (e.g. perimeter lockdown, full-scale lockdown, and other protective measures).In these cases, a threat is posed and the matter is one of immediate police intervention and protective school response.
54 AUTOMATIC STAGE I VTRA ACTIVATION FOR: Serious violence or violence with intent to harm or killVerbal/written threats to kill others which are “clear, direct, and plausible”Internet website / threats to kill others (refer to Appendix B for abbreviations commonly used on the Internet)Bullying - verbal, physical, cyber, and social via repeated patterns of behaviour and victimization
55 AUTOMATIC STAGE I VTRA ACTIVATION FOR: Domestic violencePossession of weapons including replicasBomb threats and making and/or detonating explosive devicesFire settingSexual intimidation or assaultGang-related intimidation and violence
56 Note: Criminal Charges In cases of violence or criminal acts, the police officer on the V-TRA team has “first call” as to whether charges will be laid.If the officer chooses not to proceed with criminal charges, Stage I will continue.If charges are laid, the officer of the V-TRA team often will refer it to another member so that they may stay on the team and participate in the Stage I process.An investigation does not prevent the remaining members from continuing the Stage I process.Collaboration will continue among the members, not withstanding each member has his/her own “jurisdiction”.
57 TYPES OF THREATSNote: Threats may be written, verbal, drawn, posted, or gestured only. Four Categories (as noted by the Federal Bureau of Investigation - FBI): Direct threat: identifies a specific act against a specific target and is delivered in a straightforward, clear and explicit manner. Indirect threat: tends to be vague, unclear and ambiguous. Veiled threat: is one that strongly implies, but does not explicitly threaten, violence. Conditional threat: warns that a violent act will happen unless certain demands or terms are met.
58 “clear and discernible pattern of offending” TYPES OF THREATSSome veiled and indirect threats may not meet the standard of law for criminal charges but do warrant assessment.Example:a target who is the subject of a gang-related hand sign that denotes “let’s get him” or “take him out”.a particular student of concern who has used a non-verbal but veiled throat cutting gesture prior to severely beating his targets.“clear and discernible pattern of offending”
59 VIOLENCE/BULLYINGWhen violence or bullying occurs, the following general guidelines can help administrators to determine if the case should be dealt with as a disciplinary matter only, or as a violence/threat risk assessment case.Consult with a VTRA member if:Lower baseline violence appears unprovokedClear victim and perpetrator dyad with power imbalance due to age, size, social power, or other factorsNo intent to harm presentIf the frequency, intensity, recency (FIR) of the violence denotes an increase in behavioural baseline of the perpetrator(s)
60 ACTIVATE VIOLENCE THREAT/RISK ASSESSMENT TEAM AND PROTOCOL IF: Serious violence occursThere is intent to seriously injure the target(s)When illegal weapons including knives, guns, replicas, machetes, and others are brandished or used in the commission of the offenceDirect, clear, and plausible threats to kill or seriously injure are communicated
61 WORRISOME BEHAVIOURSThose that cause concern for members of the school community that may indicate a student is moving towards engaging in serious violent behaviour.This could include:drawing pictureswriting stories in classmaking vague statements that do not, of themselves, constitute “uttering threats” as defined by law, but are cause of concern for some members of the school community because of their violent content.The majority of high-risk behaviour, from Kindergarten to Grade 12, falls into this category.
62 When in Doubt Check It Out! WORRISOME BEHAVIOURSWhen in Doubt Check It Out!In many cases, following up on Worrisome Behaviours results in good early intervention measures. There are also cases where a little data leads to a lot and what seems like a minor case can quickly evolve to the formal activation of the VTRA team.
63 ASSESSING VIOLENCE AND THREATS Data CollectionThe Interviewer“An investigative, skeptical, inquisitive mindset is critical to successful threat assessment.” (Fein, et. al. 2002)thoughtful probingviewing information with healthy skepticismpaying attention to key points regarding pre-attack behavior
64 ASSESSING VIOLENCE AND THREATS Data CollectionThe InterviewedThe following individuals should be interviewed when a formal threat assessment is activated:teachers and other school staffStudentstarget(s)threat maker(s)parents/caregiversothers
65 ASSESSING VIOLENCE AND THREATS Prior to conducting a series of interviews, beyond that of the reporter, the team should ask the following questions:“How much time do we have?”“Who will be interviewed?”“In what order will we interview them?”“Who will interview whom?”Depending on the severity of the case, one VTRA member may serve as the primary interviewer to ensure continuity of data collection and interviewing technique, i.e. criminal charges - police member ; health issues - clinical member.
66 ASSESSING THREATSThreat: an expression of intent to do harm or act out violently against someone or something. Can be spoken, written, or symbolic.Two Critical Principles:All threats and all threat makers are not equal.Most threat makers are unlikely to carry out their threats.BUT: All threats must be taken seriously and evaluated.
67 WORRISOME BEHAVIOURS: Majority of threat-related behaviour falls in this category.Worrisome behaviours are those that cause concern for members of the school system and may indicate that a student is moving toward a greater risk of violent behaviour:drawing pictures and writing stories in class (depicting violence)making vague statements that do not of themselves constitute “uttering threats” as defined by law.Identifying and following up on worrisome behaviours results in earlier interventions which produce better outcomes.
68 MOTIVATION AND EMOTIONAL STATE OF THREAT MAKER Key Concepts:Baseline Behavioursmethod used to formally determine baseline behaviour functioning.Motivationcannot always be known with complete certainty, but understanding the motivation of a threat maker is always key to evaluating a threat.
69 UNAUTHORED THREATS: ASSESSMENTS AND INTERVENTION Note:As of the writing of this protocol, there are no known casesin North America where an unauthored threat to kill was issuedand a homicide occurred on the day the threat statedThey are typically threats to commit a violent act against an individual(s), specific group, or site.They may be found written on walls or sidewalks, posted on the internet, letters left behind, etc.Although they may be credible in the world of terrorism, in the field of school-based threat assessment, the lack of ownership (Authorship) denotes lack of commitment.Never the less, there are steps that should be followed.
70 UNAUTHORED THREATS: ASSESSMENTS AND INTERVENTION 1) Assess the unauthored threat:In determining the initial level of risk, V-TRA teamsshould consider the language of commitment in theletter.Amount of detail in the letter or note (Location where violence is to occur, Target(s), Time, Date, Justifications, etc).Threatened to do what with what (Kill, Murder, Ruin your life, etc)Method of delivery of the threat (who found/received the threat, When did they receive it, how, who else knows, who did they tell, etc).Is the threat clear, direct, plausible, and consistent.
71 UNAUTHORED THREATS: ASSESSMENTS AND INTERVENTION 2) Identifying the Threat Maker:In many cases the author is never found, but steps can be taken toidentify who the author(s) are.Hand writing analysis.Word usage (phrases and expressions that may be unique).Spelling (errors, or modifications that may be unique).
72 END OF OVERVIEW THANK YOU! For additional information please contact Theresa Campbell at