Supreme Court
No. 2024-287-Appeal. (KC 23-192)
The Providence Community Health : Centers, Inc.
v. :
Neal Dupuis, in his capacity as Tax : Assessor for the City of Warwick.
NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court
Neal Dupuis, in his capacity as Tax : Assessor for the City of Warwick.
Present: Suttell, C.J., Goldberg, Robinson, and Lynch Prata, JJ.
OPINION
Chief Justice Suttell, for the Court. The plaintiff, The Providence
Community Health Centers, Inc. (PCHC or plaintiff), appeals from a Superior Court
judgment entered in favor of the defendant, Neal Dupuis, in his capacity as Tax
Assessor for the City of Warwick (the tax assessor or defendant), following the grant
of the defendant’s motion for summary judgment. This case came before the
Supreme Court pursuant to an order directing the parties to appear and show cause
why the issues raised in this appeal should not be summarily decided. After
considering the parties’ written and oral submissions and reviewing the record, we
conclude that cause has not been shown and that this case may be decided without
further briefing or argument. For the reasons set forth herein, we affirm the
judgment of the Superior Court.
-1- I
Facts and Travel1
PCHC is a nonprofit healthcare organization operating in Providence, Rhode
Island. It is the only federally qualified health center in Providence. PCHC was
established in 1968 and treats patients without regard to their ability to pay for its
healthcare services, including medical, dental, mental health, substance abuse, vision
and enabling services. As of 2022, PCHC treated 62,489 patients, approximately 78
percent of whom were either uninsured or provided with public insurance. The vast
majority of its patients qualify for Medicaid, which suggests that it predominantly
serves those who are beneath or just above the federal poverty level. However,
PCHC admitted that it is not always able to collect every patient’s financial
information and that one patient self-reported a household annual income of
$350,000.
PCHC owns twenty-five properties in Providence, which allows it to provide
its services to a large number of people in the community. At issue in this appeal,
however, is PCHC’s sole property in the City of Warwick, located at 1 Coastway
Boulevard (the property), which it acquired on July 28, 2020. The property is
utilized by PCHC for “Patient Case Management, Clinical Administrative Staff,
1 We glean the facts primarily from the affidavits of Merrill R. Thomas, the President and Chief Executive Officer of PCHC, and Neal Dupuis, the Tax Assessor for the City of Warwick.
-2- Medical Records, Billing, Coding, Accounting/Payroll, Human Resources and
Executive Leadership.” Additionally, healthcare providers within the case
management division of PCHC meet with patients virtually from the property to
provide those patients with healthcare services.
On March 25, 2021, the Providence City Council passed a resolution favoring
the passage of legislation that would grant PCHC an exemption from property taxes.
Thereafter, the General Assembly provided PCHC with a specific property tax
exemption, which went into effect on June 1, 2021. See G.L. 1956 § 44-3-3(a)(70).
The language of that exemption provides: “The following property is exempt from
taxation * * * [r]eal and tangible personal property of The Providence Community
Health Centers, Inc., a Rhode Island domestic nonprofit corporation, located in
Providence, Rhode Island.” Id.
On September 10, 2021, PCHC applied for a tax exemption from the tax
assessor for the City of Warwick. On December 31, 2021, while that application
was under consideration, the tax assessor assessed the property as being worth
$5,541,500 for the tax year 2022. In January 2022, the tax assessor requested
information from PCHC pertaining to how its operations benefit Warwick and for
any communications it may have had with the city or its legislative representatives.
PCHC responded by informing the tax assessor that it employed thirty-nine Warwick
residents and that it had treated a minimum of 843 Warwick residents over the course
-3- of 2021. Additionally, PCHC noted that it did not have any discussions about a tax
exemption “with the City of Warwick,” but that it had received support from a
Warwick representative in considering § 44-3-3(a)(70). It further provided letters
from sponsors of § 44-3-3(a)(70), stating that it was the General Assembly’s intent
to provide PCHC with a statewide property tax exemption. Based on “the fact that
the Providence City Council and Providence [General Assembly] delegation were
the only ones involved in the passage of § 44-3-3(a)(70),” the tax assessor concluded
that the statute “is a Providence-specific exemption * * *.” Accordingly, PCHC’s
request for an exemption was denied.2
PCHC was then liable to Warwick for $155,716.15 in taxes on the property.
It appealed its tax liability to the tax assessor, arguing that the § 44-3-3(a)(70)
exemption applied to the property even though the property is situated in Warwick
and not Providence. That appeal was denied on November 22, 2022. PCHC next
appealed from that decision to the Tax Board of Review for the City of Warwick
(tax board), arguing once again that the plain language of § 44-3-3(a)(70) provided
it with an exemption, and, once again, that appeal was denied on or about February
14, 2023.
2 The affidavit of Merrill R. Thomas notes that this denial occurred on “June 27, 2020.” However, the request for the exemption first came in September 2021 and based on the other events that occurred in the interim, the date of denial was likely June 27, 2022.
-4- PCHC then filed an appeal from the decision of the tax board to the Superior
Court, pursuant to G.L. 1956 § 44-5-26(j), on March 16, 2023. In its original
petition, PCHC argued that it was exempt from paying taxes on the property due to
§ 44-3-3(a)(70); however, on November 24, 2023, it amended its petition to include
the contention that it was alternatively exempt from paying such taxes under
§ 44-3-3(a)(12).3
After answering the amended petition, the tax assessor moved for summary
judgment arguing that the court was required to construe the statutes strictly against
PCHC because it was seeking an exemption. He then argued that PCHC’s reading
of § 44-3-3(a)(70) was incorrect because (1) the grammar and punctuation of the
statute plainly supports the determination that only PCHC’s Providence properties
are exempted from taxation, (2) the plain language of the statute expressly exempts
only PCHC’s Providence properties, (3) PCHC’s interpretation contains surplusage,
and (4) public records surrounding the enactment of § 44-3-3(a)(70) suggest that the
General Assembly intended to exempt only PCHC’s Providence properties. He
3 General Laws 1956 § 44-3-3(a)(12) provides a tax exemption for
“[p]roperty, real and personal, held for, or by, an incorporated library, society, or any free public library, or any free public library society, so far as the property is held exclusively for library purposes, or for the aid or support of the aged poor, or poor friendless children, or the poor generally, or for a nonprofit hospital for the sick or disabled[.]”
-5- further argued that PCHC failed to meet the requirements for the exemption set forth
in § 44-3-3(a)(12) because (1) it is not an actor contemplated by the statute to receive
an exemption, (2) the original drafters of the statute would not have considered it to
be applicable to PCHC, (3) even if the statute were applicable, PCHC does not serve
the poor “exclusively” as the statute requires, and, (4) if § 44-3-3(a)(12) were found
to be applicable, then the specific exemption located in § 44-3-3(a)(70) would be
superfluous.
PCHC responded with its own cross-motion for summary judgment. It first
argued that the plain language of § 44-3-3(a)(70) unambiguously exempts its
property—wherever it may be located in the state—from taxation. It next claimed
that § 44-3-3(a)(12) applies to it, because the plain language of that statute does not
require it to serve the poor exclusively. PCHC further contended that, even if the
language of that statute were ambiguous, it could not be interpreted to require an
organization to serve the poor exclusively due to the “proviso canon” and, to hold
otherwise, would lead to an absurd result.
The hearing justice heard arguments on the cross-motions on June 24, 2024,
and delivered a bench decision concluding that PCHC was not exempt from taxes
on the property. The hearing justice first determined that there were no genuine
issues of material fact and that the matter turned on the statutory interpretations of
§§ 44-3-3(a)(70) and 44-3-3(a)(12). Relying on a previous decision from the
-6- Superior Court, the hearing justice held that the language of § 44-3-3(a)(12) was
ambiguous. See PACE Organization of Rhode Island v. Frew, No. PC-2023-01202,
2024 WL 1135970 (R.I. Super. Mar. 6, 2024). He also determined that PCHC’s
argument concerning the “proviso canon” was unavailing because this Court
previously determined that the statute requires that a party seeking an exemption
must serve the poor exclusively. See Lifespan Corporation v. City of Providence,
776 A.2d 1061, 1062 (R.I. 2001) (mem.) (“Section 44-3-3(12) exempts from
taxation real and personal property that is held ‘exclusively * * * for a hospital for
the sick or disabled[.]’”). Because an ambiguous statute granting a tax exemption is
to be resolved in favor of the taxing authority, see Polseno Properties Management,
LLC v. Keeble, 288 A.3d 988, 992 (R.I. 2023), and because PCHC admitted that it
does not exclusively serve the poor, the hearing justice found that § 44-3-3(a)(12)
does not grant PCHC a tax exemption on the property.
The hearing justice then analyzed whether § 44-3-3(a)(70) provided PCHC
with an exemption for the property tax. He determined that the subsection is not
ambiguous and that its inclusion of the phrase “located in Providence, Rhode
Island[]” limits PCHC’s exempted property to only those properties it owns in
Providence. Therefore, he concluded that, because the property is located in
Warwick, § 44-3-3(a)(70) did not grant PCHC an exemption.
-7- The hearing justice went on to state that, even if the statute were to be deemed
ambiguous, reading the statute as a whole did not help in determining whether the
exemption only applied to PCHC’s Providence properties because “there is no
uniformity in the language used * * *.” He also determined that interpreting “located
in Providence, Rhode Island[]” as merely describing the location of PCHC’s
headquarters would make that language surplusage—because it does not identify
which property is exempt—and that interpretation would create issues in the event
that PCHC changed the location of its headquarters. The hearing justice noted that
his interpretation of the statute is bolstered by the fact that the statute begins with
the phrase “the following property is exempt from taxation.” Finally, although he
recognized that grammar and punctuation should not be the sole basis of statutory
construction, he agreed with the tax assessor that “the placement of the comma after
the word ‘corporation’ supports the argument that ‘located in Providence, Rhode
Island’ relates back to the word ‘property.’”
As a result, the Superior Court granted the tax assessor’s motion for summary
judgment and denied PCHC’s cross-motion for summary judgment. PCHC timely
filed its notice of appeal on July 12, 2024.
-8- II
Standard of Review
“This Court reviews de novo a decision of the Superior Court to grant
summary judgment, applying the same rules and standards as those employed by the
justice below.” Riccitelli v. Town of North Providence by and through Vallee, 308
A.3d 977, 981-82 (R.I. 2024) (quoting Benaski v. Weinberg, 899 A.2d 499, 502 (R.I.
2006)). “We will affirm a trial court’s decision only if, after reviewing the
admissible evidence in the light most favorable to the nonmoving party, we conclude
that no genuine issue of material fact exists and that the moving party is entitled to
judgment as a matter of law.” Bayview Loan Servicing, LLC v. Providence Business
Loan Fund, Inc., 200 A.3d 153, 156 (R.I. 2019) (brackets omitted) (quoting Cancel
v. City of Providence, 187 A.3d 347, 350 (R.I. 2018)).
“[W]hen presented with questions of statutory interpretation, this Court
engages in a de novo review.” Bayview Loan Servicing, LLC, 200 A.3d at 156-57
(quoting In re Tetreault, 11 A.3d 635, 639 (R.I. 2011)).
III
Discussion
On appeal, PCHC argues that the hearing justice erred by misinterpreting both
§§ 44-3-3(a)(70) and 44-3-3(a)(12). We will analyze each of those statutes in turn.
-9- Section 44-3-3(a)(70)
We begin our discussion by examining the entire text of § 44-3-3(a)(70):
“The following property is exempt from taxation: * * * Real and tangible personal property of the Providence Community Health Centers, Inc., a Rhode Island domestic nonprofit corporation, located in Providence, Rhode Island[.]”
The parties disagree as to which antecedent “located in Providence, Rhode Island”
modifies. PCHC contends that it modifies “a Rhode Island nonprofit corporation,”
thus, “located in Providence, Rhode Island” merely adds a description of where
PCHC is primarily located. PCHC argues that this is clear from the plain language
of the statute when viewed as a whole, because other sections of § 44-3-3(a) include
a street address, plat or lot numbers, or map and block numbers to define specific
properties that are to be exempted, which is not included in § 44-3-3(a)(70).
The tax assessor, on the other hand, contends that it modifies “[r]eal and
tangible personal property of The Providence Community Health Centers, Inc.” and,
therefore, limits the scope of PCHC’s property tax exemption to property PCHC
owns in Providence. He notes that, although other sections of the statute are more
specific when limiting a corporation’s properties that are to be exempted, PCHC
owns twenty-five properties throughout Providence and listing each one would be
impractical. The tax assessor suggests that the lack of any specific property
- 10 - identification, combined with the specification of Providence, is evidence that the
General Assembly only intended to exempt PCHC’s Providence properties.
To enhance that argument, the tax assessor points to § 44-3-3(a)(40), which
provides for the following tax exemption:
“Real and personal property located within the city of East Providence of the Trustees of Methodist Health and Welfare service a/k/a United Methodist Elder Care, a Rhode Island nonprofit corporation[.]”
Both parties agree that this section provides the Trustees of Methodist Health and
Welfare service a property tax exemption limited to property it owns in East
Providence, despite the fact that there is no specific property identification contained
in it. PCHC argues that § 44-3-3(a)(40) differs from § 44-3-3(a)(70), because
subsection (40) uses the phrase “located within” prior to naming the organization,
whereas subsection (70) uses the phrase “located in” after naming PCHC. It further
notes that “in” and “within” have different dictionary definitions.
“It is well settled that when the language of a statute is clear and unambiguous,
this Court must interpret the statute literally and must give the words of the statute
their plain and ordinary meanings.” Berman v. Sitrin, 991 A.2d 1038, 1043 (R.I.
2010) (quoting Accent Store Design, Inc. v. Marathon House, Inc., 674 A.2d 1223,
1226 (R.I. 1996)). “This is particularly true where the Legislature has not defined
or qualified the words used within the statute.” D’Amico v. Johnston Partners, 866
A.2d 1222, 1224 (R.I. 2005) (quoting Markham v. Allstate Insurance Co., 116 R.I.
- 11 - 152, 156, 352 A.2d 651, 654 (1976)). “In matters of statutory interpretation our
ultimate goal is to give effect to the purpose of the act as intended by the
Legislature.” Id. (quoting Webster v. Perrotta, 774 A.2d 68, 75 (R.I. 2001)).
“It is an equally fundamental maxim of statutory construction that statutory
language should not be viewed in isolation.” Rhode Island Truck Center, LLC v.
Daimler Trucks North America, LLC, 338 A.3d 1056, 1060 (R.I. 2025) (quoting In
re Brown, 903 A.2d 147, 149 (R.I. 2006)). “When performing its duty of statutory
interpretation, this Court considers the entire statute as a whole; individual sections
must be considered in the context of the entire statutory scheme, not as if each
section were independent of all other sections.” Id. at 1060-61 (brackets omitted)
(quoting In re Brown, 903 A.2d at 149). “If a statute is ambiguous—that is,
‘susceptible of more than one construction’—the Court will ‘adopt the construction
that comports with constitutional imperatives.’” Id. at 1061 (quoting In re Kyle S.,
692 A.2d 329, 334 (R.I. 1997)). “It is only if the statutory language is ambiguous
that we will turn to our well-established maxims of statutory construction in an effort
to glean the intent of the Legislature.” Id. (quoting Johnson v. Johnson, 264 A.3d
835, 838 (R.I. 2021)).
This Court is required to read the terms of the statute in their plain and
ordinary meaning, and not in a hypertechnical fashion. See In re Proposed Town of
New Shoreham Project, 25 A.3d 482, 505 n.30 (R.I. 2011) (providing that, in
- 12 - determining if an ambiguity exists in a statute, “the question is not whether there is
an ambiguity in the metaphysical sense, but whether the language has only one
reasonable meaning when construed, not in a hypertechnical fashion, but in an
ordinary, common sense manner” (quoting Lazarus v. Sherman, 10 A.3d 456, 464
(R.I. 2011))). The terms “in” and “within” are commonly used interchangeably in
everyday parlance and thesauruses have the two listed as synonyms. See Roget’s
International Thesaurus § 207.10 at 158 (5th ed. 1992). Thus, the Court draws no
distinction between the terms “in” and “within” as they are employed in § 44-3-3(a).4
Despite those terms being indistinguishable, we must still address the fact that
§ 44-3-3(a)(40) utilizes the phrase “located within” prior to naming the Trustees of
Methodist Health and Welfare service as the owner of the exempted
property—which makes it clear that the property to be exempt is that which is
physically in East Providence—whereas § 44-3-3(a)(70) provides “located in” after
it names PCHC. PCHC argues this distinction shows that the phrase “located in”
merely describes the location of its headquarters. Yet, this Court has held that, when
interpreting a statute, it “is bound, if it be possible, to give effect to all its several
4 Dictionaries also include definitions for the two terms which are virtually indistinguishable, often using one term to define the other. “In” is commonly defined as “[w]ithin the limits, bounds, or area of” or “[f]rom the outside to a point within[.]” The American Heritage Dictionary of the English Language 885 (5th ed. 2011) (emphasis added). “Within” is defined as “[i]n or into the inner part[.]” Id. at 1990 (emphasis added).
- 13 - parts. No sentence, clause or word should be construed as unmeaning and
surplusage, if a construction can be legitimately found which will give force to and
preserve all the words of the statute.” St. Clare Home v. Donnelly, 117 R.I. 464, 470,
368 A.2d 1214, 1217-18 (1977). If the Court were to accept PCHC’s interpretation
of § 44-3-3(a)(70), then the phrase “located in Providence, Rhode Island” would
have no effect or force and would serve as mere background information for the
reader about PCHC’s principal place of business.
Had the General Assembly intended such an interpretation it could have used
the phrase “headquartered in Providence, Rhode Island.” See In re Proposed Town
of New Shoreham Project, 25 A.3d at 526 (“[A]ny other interpretation by this Court
would impermissibly read purposefully unwritten words into the statute’s meaning
and subvert the Legislature’s clear intention * * *.”).
Rather, interpreting “located in Providence, Rhode Island” as limiting the
scope of PCHC’s exemption to its Providence properties gives effect to the plain and
ordinary meaning of the words of the statute, while also limiting the amount of
surplusage and avoiding unwritten terms from being read therein. Further, “[t]his
Court has held that our duty is to ‘strictly construe statutory tax exemptions in favor
of the taxing authority.’” Polseno Properties Management, 288 A.3d at 992 (quoting
Delta Airlines, Inc. v. Neary, 785 A.2d 1123, 1126 (R.I. 2001)). “We have noted
that ‘the rule of strict construction is not to be applied so as to defeat a clear
- 14 - legislative intent to grant a particular exemption.’” Id. (quoting Preservation Society
of Newport County v. Assessor of Taxes of City of Newport, 104 R.I. 559, 565, 247
A.2d 430, 434 (1968)). “Nevertheless, ‘the party claiming the tax exemption bears
the burden of demonstrating that the statute reveals such an intent.’” Id. (quoting
Delta Airlines, Inc., 785 A.2d at 1126).
PCHC has not persuaded this Court that any such intent can be detected in the
statute itself. While it has introduced letters from both the state senator and state
representative who sponsored the bills which eventually became § 44-3-3(a)(70),
letters from individual legislators do not assist this Court in discerning the intent of
the entire General Assembly. See LaPlante v. Honda North America, Inc., 697 A.2d
625, 628-29 (R.I. 1997) (“[P]ost hoc affidavits offered as ‘recollections’ of the intent
of legislators are not true legislative histories and should be given no weight. They
hold no place within the canons of statutory construction.”). Additionally, those
letters are extrinsic to the text of the statute itself, to which this Court is limited in
interpreting a statute absent ambiguity. See Berman, 991 A.2d at 1043 (“It is well
settled that when the language of a statute is clear and unambiguous, this Court must
interpret the statute literally and must give the words of the statute their plain and
ordinary meanings.”) (quoting Accent Store Design, Inc., 674 A.2d at 1226).
- 15 - Finally, PCHC submits that three other organizations5 have been granted tax
exemptions that are worded similarly to § 44-3-3(a)(70) and that the Superior
Court’s interpretation would strip those organizations of their exemptions outside of
their respective locations, leading to an absurd result. However, PCHC has provided
no evidence in the record showing that those organizations are receiving tax
exemptions outside of their statutorily defined areas; even if they had provided such
evidence, it would not be an appropriate replacement for the plain text of the statute.
See Berman, 991 A.2d at 1043.
Thus, for the reasons provided above, we hold that § 44-3-3(a)(70) does not
grant PCHC a tax exemption in the property.
Section 44-3-3(a)(12)
Turning to the next statute at issue, the text of § 44-3-3(a)(12), in its entirety,
provides:
“The following property is exempt from taxation: * * * Property, real and personal, held for, or by, an incorporated library, society, or any free public library, or any free public library society, so far as the property is held exclusively for library purposes, or for the aid or support of the aged poor, or poor friendless children, or the poor generally, or for a nonprofit hospital for the sick or disabled[.]”
5 Those three entities are Steere House in Providence (§ 44-3-3(a)(54)), Habitat for Humanity—Greater Providence in Providence (§ 44-3-3(a)(58)), and the Manissean Tribal Council in New Shoreham (§ 44-3-3(a)(77)).
- 16 - In determining that § 44-3-3(a)(12) does not apply to the property, the hearing justice
held: (1) that the statute is ambiguous; (2) that PCHC is not the type of entity covered
by the statute; and (3) that, even if PCHC were an entity covered by the statute, it
failed to serve the poor “exclusively” as required by this Court’s prior precedent. See
Lifespan Corporation, 776 A.2d at 1062. In concluding that § 44-3-3(a)(12) is
ambiguous, the hearing justice relied on an earlier opinion of the Superior Court,
where it was determined that the statute could reasonably be interpreted in different
ways. See Frew, 2024 WL 1135970, at *4.
The appeal in that case, PACE Organization of Rhode Island v. Frew, 355
A.3d 44 (R.I. 2026), was recently argued before this Court, and, for reasons already
sufficiently explained in its respective opinion, we determined that § 44-3-3(a)(12)
was ambiguous as it applied to the specific factual circumstances of PACE
Organization of Rhode Island’s application for a tax exemption. Frew, 355 A.3d at
50-51. While that holding was limited, the arguments presented here by PCHC as
to why the statute is unambiguous and its interpretation of it are identical—almost
verbatim—to the arguments that were presented by PACE Organization of Rhode
Island.6 See id. at 47. For that reason, we extend our holding that § 44-3-3(a)(12) is
6 We note that PCHC does present an additional argument not found in PACE Organization of Rhode Island v. Frew, 355 A.3d 44 (R.I. 2026), which addresses how any ambiguity should be resolved in the statute. PCHC argues that “even assuming arguendo that [§ 44-3-3(a)(12)] is ambiguous, the proviso canon both resolves that ambiguity and clarifies that the ‘exclusivity’ requirement cannot apply
- 17 - ambiguous to the instant matter.7 “[I]f a doubt or ambiguity exist[s] in a statute
granting an exemption, such doubt must be resolved in favor of taxation.” City of
Providence v. Killoran, 447 A.2d 369, 371 (R.I. 1982). Therefore, PCHC is not
entitled to a tax exemption under § 44-3-3(a)(12).
IV
Conclusion
For the reasons set forth herein, the judgment of the Superior Court is
affirmed, and the record of this case shall be returned thereto.
Justice Long did not participate.
Justice Goldberg participated in the decision but retired prior to its
publication.
to PCHC’s use of the [p]roperty.” As noted, “if a doubt or ambiguity exist[s] in a statute granting an exemption, such doubt must be resolved in favor of taxation.” City of Providence v. Killoran, 447 A.2d 369, 371 (R.I. 1982). Therefore, we need not consider that argument because this Court is not tasked with resolving any such ambiguity. See id. 7 Once more, we limit that finding of ambiguity only as applied to the facts of this case.
- 18 - STATE OF RHODE ISLAND SUPREME COURT – CLERK’S OFFICE Licht Judicial Complex 250 Benefit Street Providence, RI 02903
OPINION COVER SHEET
The Providence Community Health Centers, Inc. v. Title of Case Neal Dupuis, in his capacity as Tax Assessor for the City of Warwick. No. 2024-287-Appeal. Case Number (KC 23-192)
Date Opinion Filed June 5, 2026
Justices Suttell, C.J., Goldberg, Robinson, and Lynch Prata, JJ.
Written By Chief Justice Paul A. Suttell
Source of Appeal Kent County Superior Court
Judicial Officer from Lower Court Associate Justice Richard A. Licht
For Plaintiff:
M. Hamza Chaudary, Esq. Attorney(s) on Appeal For Defendant:
Peter F. Skwirz, Esq.
SU-CMS-02A (revised November 2022)