COMMONWEALTH OF KENTUCKY, BOARD OF DENTISTRY v. RALEIGH D. ANDREWS, D.D.S.
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RENDERED: August 25, 2000; 2:00 p.m.
NOT TO BE PUBLISHED
C ommonwealth O f K entucky
C ourt O f A ppeals
NOS.
1999-CA-000919-MR AND 1999-CA-000974-MR
COMMONWEALTH OF KENTUCKY,
BOARD OF DENTISTRY
v.
APPELLANT/CROSS-APPELLEE
APPEAL AND CROSS APPEAL FROM JEFFERSON CIRCUIT COURT
HONORABLE THOMAS J. KNOPF, JUDGE
ACTION NO. 98-CI-05090
RALEIGH D. ANDREWS, D.D.S.
APPELLEE/CROSS-APPELLANT
OPINION AFFIRMING IN PART, AND REVERSING AND REMANDING IN PART
* * * * * * * *
BEFORE:
GUDGEL, Chief Judge; GUIDUGLI and McANULTY, Judges.
GUDGEL, CHIEF JUDGE:
This is an appeal and cross appeal from an
order entered by the Jefferson Circuit Court affirming in part,
and reversing in part, an order of the appellant/cross-appellee,
Kentucky Board of Dentistry (board), imposing disciplinary action
against appellee/cross-appellant Raleigh D. Andrews, D.D.S.
The
board contends on direct appeal that the trial court erred by
finding that the board's conclusion, that Andrews refused to
comply with its subpoena directing him to produce records, is not
supported by substantial evidence.
Andrews contends on cross
appeal that the court erred by concluding that the board's
findings, that he used a single set of gloves while treating more
than one patient during the last week of June 1997, and that he
improperly delegated the task of taking dental x-rays to one or
more unqualified assistants, are supported by substantial
evidence.
For the reasons stated hereafter, we reverse and
remand on cross appeal as to the glove issue; otherwise, we
affirm.
Andrews purchased an existing dental practice in
Monticello and began practicing dentistry from that office.
He
continued to employ several of the prior dentist's employees,
including another dentist.
Disputes developed, and eventually
several complaints were filed with the board.
After a hearing,
the board found that Andrews had committed four violations
respecting KRS Chapter 313, which regulates the practice of
dentistry and dental specialties.
The board suspended Andrews'
license to practice dentistry for three years on each of the four
disciplinary counts, with the suspensions to run concurrently.
The board then probated all but thirty days of three of the
suspensions, and sixty days of the fourth suspension.
Andrews
appealed from the board's decision to the Jefferson Circuit
Court, which affirmed two of the suspensions and reversed the
remaining two.
This appeal and cross appeal followed.
The board contends on direct appeal that the trial
court erred by finding that its conclusion, that Andrews refused
to comply with the board's subpoena directing him to produce
records, is not supported by substantial evidence.
We disagree.
The board made the following relevant findings of fact:
16. On October 20, 1997, Board
Investigator Robert Thompson went to
Monticello with an agent of the Lake
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Cumberland Drug Task Force, and served Dr.
Andrews with a subpoena from the Board. That
subpoena directed Dr. Andrews to supply the
Board with the following:
1. Photocopy of appointment book from
and including September 15, 1997, to and
including October 20, 1997.
2. Original patient records, including
X-Rays, of all patients seen by Raleigh
D. Andrews, DDS, from September 15,
1997, to aid [sic] including October 20,
1997.
3. Original patient records of Douglas
Appleby (or Applebee).
When presented with the subpoena, Dr. Andrews
supplied his appointment book, which Thompson
copied. However, Dr. Andrews was concerned
about supplying original records to Thompson,
and repeatedly called his counsel about the
subpoena. After several calls to counsel and
a call between Dr. Andrews and the Executive
Director of the Board, Dr. Andrews agreed to
provide copies of a representative random
sampling of patient files for the relevant
period. Thompson picked out 20 to 25 files,
and went with Dr. Andrews to the local Police
Station to use a photocopy machine there to
make the agreed upon copies. By this time,
it was getting late in the day. Dr. Andrews
stayed at the Police Station with Thompson
while he copied, and had at least one more
telephone conversation with counsel. At
approximately 10:15 at night, Dr. Andrews
told Thompson that was enough, and left with
his files. Dr. Andrews testified that he had
to go because he had a charity function he
had to attend the next morning. Before Dr.
Andrews left with his files, Thompson gave
him a copy of KRS 313.220, informing him of
the Board's authority in this matter.
Thompson left that night with copies of only
11 files. (Citations to record omitted.)
The board concluded that Andrews' actions constituted a failure
and refusal to comply with its subpoena and lawful order.
Further, it concluded that his conduct constituted unprofessional
conduct and a material violation of the law.
-3-
The circuit court subsequently reviewed the record and
summarized the evidence as follows:
KRS 313.220(5) provides that any
licensee who fails or refuses to comply with
an order or direction of the Board shall be
reported to the Board for whatever
disciplinary action it deems appropriate,
"including revocation of any license if such
failure or refusal is deemed by the board to
be material." The hearing panel and Board
concluded that "Dr. Andrews failed and
refused to obey a lawful order of the Board"
and "this failure and refusal was a material
violation of the law and hampered the Board's
function under KRS Chapter 313, within the
meaning of KRS 313.220(5)." (Emphasis
added).
According to the testimony of Robert
Thompson, a Board investigator who served the
subpoena on Dr. Andrews on October 21, 1997,
Dr. Andrews did not have a copy machine so he
went to the circuit court clerk's office to
copy the appointment book of Dr. Andrews,
which was item one on the subpoena. When he
returned, he started to collect the original
patient charts outlined in the subpoena (item
two) with the help of one of Dr. Andrews'
dental assistants. Counsel for Dr. Andrews
telephoned to say that he could not in good
faith recommend that his client release
original patient charts and because it would
have been impossible to copy the large number
of charts requested (approximately 120),
Thompson testified that he contacted the
Board.
An agreement was reached between the
parties to allow Thompson to randomly select
a sample of 20 to 25 charts from the list
generated from the appointment book to copy.
It was approximately 6:00 p.m. or later when
Thompson started to randomly select the
samples to copy, and he and Dr. Andrews
traveled to the police station to make the
copies. During the photocopying, Dr. Andrews
was contacted by his attorney and after the
telephone call, Dr. Andrews said to stop as
that was enough. Thompson testified that he
could not remember the time this occurred,
but it was after dark and he did not believe
it was as late as 10:00 p.m. He had copied
eleven patient charts at that point.
-4-
Dr. Andrews' testimony on this issue
corresponds with Thompson's testimony, except
he testified that he stayed to help copy the
records until 10:15 p.m., and that he had
been doing it all day and had something
important to do the next day. He also
testified that he thought Thompson would come
back and finish the copying.
Thompson testified that he did not
recall Dr. Andrews saying "don't come back,"
and he was not given another subpoena or
directive by the Board to return to Dr.
Andrews' office to copy the rest of the
charts. (Citations to record omitted.)
On appeal, the board does not object in any way to the
court’s summary of the facts.
However, the board does object to
the court's conclusion that:
The undisputed evidence shows that Dr.
Andrews had been cooperating with Thompson
for a significant period of time; the parties
were able to reach a reasonable compromise
over chart selection; the hour was growing
late; and Dr. Andrews never told Thompson he
could not come back to copy the rest of the
selected charts. Given this evidence and the
circumstances of this case, the Board's
finding that Dr. Andrews not only failed but
refused to comply with the subpoena is
without support of substantial evidence on
the whole record.
Having carefully reviewed the entire record, we are
compelled to agree with the trial court that there is no
substantial evidence to support a finding that Andrews refused to
comply with the subpoena.
Indeed, Thompson described the
parties' conduct as cordial throughout the day the subpoena was
served, and it is clear from the evidence that the number of
charts to be copied was reduced by agreement of the parties, and
that any further limitations or delays in Andrews' compliance
were based on the advice of his attorney and the late hour.
-5-
Moreover, it is undisputed that the subpoena did not state a date
by which compliance was mandated, and there were no efforts to
obtain copies of records after the date on which the subpoena was
served and the first eleven records were copied.
Hence, it
follows both that the evidence did not support a conclusion that
Andrews refused to comply with the board's subpoena, and that the
court did not err by concluding that the board's finding in this
vein was not supported by substantial evidence.
Next, Andrews contends on cross appeal that the trial
court erred by concluding that the board's finding, that he used
a single set of gloves while treating more than one patient
during the last week of June 1997, was supported by substantial
evidence.
We agree.
Two of the charges against Andrews related to the use
of gloves.
Count I stated:
On at least one occasion on or about the
last week of June, 1997, Respondent treated
patients and used one set of gloves while
treating at least two or more patients that
day. Respondent did not dispose of the
gloves used while treating the prior patient
and did not use a new set of gloves for
treatment of the subsequent patient(s).
Count II stated:
On at least one occasion on or about a
Saturday or Saturdays in June, 1997,
Respondent treated patients and used one set
of gloves on all the patients seen by
Respondent that day. Respondent did not
dispose of the gloves used while treating the
prior patient and did not use a new set of
gloves for treatment of the subsequent
patient(s).
After the hearing, the board made the following
findings of fact relating to the use of gloves:
-6-
6. From January to February 1997, Dr.
Andrews employed Linda Phillips ("Phillips")
as a dental assistant in his office.
Phillips completed a course in dental
radiography approved by the Board and
thereafter took x-rays for Andrews. Phillips
acted as Dr. Andrews' assistant in the
operatory and had the opportunity the [sic]
observe him during his work day. One day
during her employment, Phillips witnessed Dr.
Andrews coming from one patient to another
without changing his gloves. She witnessed
him with his hands in the first patient's
mouth, and then coming directly to the next
patient without changing gloves. From that
time forward, Phillips would consistently
remind Dr. Andrews to change his gloves.
When she reminded him, Dr. Andrews did change
his gloves. . . .
. . . .
8. From the second week in June, 1997
to approximately July 4, 1997, Dr. Andrews
employed Pamela Jones ("Jones") as a dental
assistant in his office. Jones acted as
Andrews' assistant in the operatory and had
the opportunity to observe him during his
work day. Jones worked on weekends and
during one weekend in June, she was assisting
Dr. Andrews in the operatory treating
patients. On that day, she observed him work
on a patient without changing gloves from
working on a prior patient.
However, Phillips' allegation regarding the use of gloves was not
mentioned in the charges against Andrews, and the board
concluded:
7. . . . that on at least one occasion
on or about the last week of June, 1997, Dr.
Andrews used one set of gloves while treating
at least two or more patients that day, and
that he did not dispose of the gloves he was
wearing after treating one patient, and did
not use a new set of gloves for treatment of
a subsequent patient, as described by Ms.
Jones in her testimony. . . . The Panel
therefore concludes that Dr. Andrews violated
KRS 313.130 as charged in Count I of the
Amended Accusation.
-7-
8. . . . that the Board failed to meet
its burden to show that Dr. Andrews violated
the law as specifically charged in Count II
of the Amended Accusation. The Panel found
the testimony of Ms. Jones credible, but
there was not a preponderance of evidence in
the record upon which the Panel could find
that on the specific day referred to in Count
II, Dr. Andrews used the same set of gloves
on all patients. Therefore, the Panel
concludes that Dr. Andrews did not violate
KRS 313.130 as charged in Count II of the
Amended Accusation.
Thus, based on Jones' testimony, the board found that Andrews
failed to change gloves between patients on one or more occasions
in late June 1997.
However, the board concluded that the
evidence was insufficient to show that Andrews used a single set
of gloves while treating all patients on a Saturday during that
same month.
Relevant to the board's decisions are the following
portions of Jones' testimony regarding Andrews' use of gloves:
Q Now, how do you know he didn't change
gloves? Tell us what you saw.
A Like there was this one Saturday,
when the morning started, he got a pair of
gloves out of the clean box and he started
working on one patient, and I think we had
three that day, and then he would like, when
she got done, he would like walk back to the
back and then come back up and start working
on the other patients without going over and
getting a new pair of gloves.
Q Let me stop you right there and ask
you, where did Doctor Andrews usually get
clean gloves from when you were working with
him?
A
On the counter behind his chair.
. . . .
Q Where, again, was the box of clean
gloves that Doctor Andrews would get clean
-8-
gloves from when you saw him put on clean
gloves?
A
Right behind his chair where he sat.
Q
Is that within your sight?
A
Yes.
. . . .
Q Did you ever see dirty gloves
anywhere else other than in one of those
trash cans?
A
Yes.
Q
Where were they?
A On that Saturday, I think he pulled
them off like after the second patient, and
there's a drawer right beside his cabinet
like thing right beside his chair, right
beside the dental chair, and he would stick
them in there, and then like with our third
patient, he went to sit down and he opened
the drawer back up and he got them and put
them back on and worked with the third
patient.
Q Now, let me ask you, did you ever see
what was in that drawer?
A
Just one pair of gloves.
Q
Was it the same pair of gloves?
A
Yes.
Q Do you have any reason to believe
that there were [sic] a box of clean gloves
in that drawer?
A
No.
Q
Why do you not think that?
A Because when he opened the drawer, I
looked in there and there was nothing but
that one pair of gloves that he got out and
put on.
Q Now, how do you know that those
gloves were dirty gloves that you saw him
take out of that drawer and put on?
-9-
A
Because they were stained.
. . . .
Q Did you ever see Doctor Andrews start
to perform a procedure on a patient, leave
that patient, and go work on another patient
and not change gloves?
A
Yes, I did.
Q Was that on the Saturday in question
or was that on any other occasion?
A
It was on a different day.
. . . .
Q Now, let me see if I understand all
this correctly. You testified about the
Saturday when you worked with Doctor Andrews
alone in his office and you saw a handful of
patients that day. You also testified about
at least one other occasion where you were
concerned Doctor Andrews had reused the same
pair of gloves on different patients. Is all
that accurate?
A
Yes.
Q Is there any doubt in your mind, and
is it your opinion that you have seen Doctor
Andrews reuse gloves on different patients
that had already been used on other patients?
A
Yes, it is.
. . . .
Q First of all, ma'am, would you
disagree with the fact that you worked less
than 15 days for Doctor Andrews?
A
I worked about three weeks.
. . . .
Q Now, isn't it true, you believe the
clean gloves were only kept in one place in
Doctor Andrews' office?
A
Yes.
. . . .
-10-
Q And you believed the only place
anyone could get gloves, whether it be you,
other personal [sic], or Doctor Andrews, was
in that one place?
A
Yes.
Q And you could see that one place
where those clean gloves were, right?
A
Yes.
Q
Where was that place?
A
chair.
It was right behind Doctor Andrews'
Q All right. So if Doctor Andrews
walked out of an operatory with gloves on,
and came back with the same gloves on, if
there was only one place to get them, they
had to be the same gloves he left with,
right?
A
Yes.
Q Unless there were other places in the
office where he could pick up clean gloves,
which you didn't realize existed, correct?
A
Yes.
Q Now, the drawer you're talking about
where you saw Doctor Andrews reach and get
the same pair of gloves on this one occasion,
the drawer -- that drawer had gloves which
were not turned inside out, correct?
A
about?
Yes.
Which drawer are you talking
Q The drawer you were talking about
where he allegedly put a pair of dirty gloves
in and then went become [sic] and got that
same pair?
A
By his desk, by his chair, or in the
back.
Q No, in the cart by his chair. Not
the clean box that you thought existed only
in one place. I'm talking about the drawer
where you said you looked in and he pulled
out the same pair he had put in; is that
true?
-11-
A
Yes.
Q And I believe you testified do [sic]
this board in that drawer there was only one
pair?
A
Yes.
Q
Turn to page 29 of your deposition.
A
(WITNESS COMPLIES)
Q Now, the drawer in the back you
talked about, you said you only saw dirty
gloves in that drawer?
A
And papers.
Q
And papers.
A
Uh-huh.
Q And in the drawer next to his dental
chair, you only saw one pair of gloves?
A
Yes.
Q
Look at page 27 in your deposition.
Question: "Okay. And it's your
recollection that when he went to get gloves,
he didn't reach over to the box of new ones,
he went to another drawer somewhere?"
Answer: "I mean he would change every
now and then, but I'm saying that -- I mean,
like he -- he kept -- there's a little drawer
right there and he kept gloves in there."
I thought you said there was only one
pair.
A There was only one pair that I seen.
I'm sorry.
Q ". . . he kept gloves in there that
he would use on different patients and he
would just stick them in there and then he'd
just get them back out and use them."
"Where was this drawer?"
chair."
chair.
"It was right beside the dental
In the cabinet next to the dental
-12-
You just told this panel, you made
sure you looked in that drawer and there was
one pair, only one pair, the pair he had
taken off, and in your deposition, you said
there were gloves in there.
. . . .
Q And to your knowledge, the only box
of clean gloves in the entire office was
right behind his chair?
A
To my knowledge.
Q And I believe you testified that when
you take gloves off, they're pulled inside
out?
A
Yes.
Q And when you looked in the drawer and
saw a pair of gloves, they were not inside
out?
A
Yes.
Q
Yes, they were not inside out?
A
Yes, they weren't inside out.
. . . .
Q On page 32 of your deposition, line
20, my question was: "Okay. And just to
make sure I understand this, when you looked
in that drawer, you saw gloves that were not
inside out, they were laying there just ready
to be put on?
Answer:
"Yes."
You're still talking about one pair
of gloves or more than one pair of gloves?
A
One pair of gloves.
Q Now, Ms. Jones, isn't it true that
whenever Doctor Andrews left your sight, left
the operatory, you have no idea where he
went, what he did, or what he did with his
gloves?
A
Yes.
Q
That's true, correct?
-13-
A
Uh-huh.
Q So isn't it true, for all you know,
he changes gloves when you're not watching
and walks into the room with clean gloves on?
. . . .
HEARING OFFICER: I'll overrule the
objection. Is that the way it's phrased in
the deposition?
. . . .
Q . . . . "So, for all you know, he
changes gloves when you're not watching and
walks into the room with clean gloves on?"
Answer: "Well, he could, but I've
seen him use the same pair of gloves on the
same person."
A
Yes.
Q The same pair of gloves on the same
person?
A
I meant on different people.
HEARING OFFICER: Well, now I'm a
little confused. Do you know whether Doctor
Andrews changed his gloves when he was out of
the room?
THE WITNESS: I don't know that for
sure, no.
BY MR. RECKER:
Q Is it fair to say, Pam, that you
weren't watching him every second from the
time he got up from the patient?
A No, I wasn't watching him every
second.
Q On the one occasion you saw him do
this, go from one room to the other using the
same gloves, is it your testimony that on one
occasion, I'm looking at page 37 of your
deposition, ma'am, if you want to read along
with my question.
So is it your testimony that on that one
occasion, you walked with him from the moment
-14-
he left the mouth of the first patient until
entering the mouth of the second patient or
you don't know -- or don't you know?
Answer: "I mean he never left that
room."
Line 21. Question: "Is it fair to say,
Pam, that you weren't watching him every
second from the time he got up from the
patient?"
Answer: "No, I never watched him every
second."
Question: "Then how can you be sure on
this one occasion he went from one patient to
a second patient with the same gloves on?"
Answer: "I could be pretty sure."
Question: "Who was the patient?"
Answer: "I don't -- can't recall."
Question: "Now, if [sic] this the one
example where he used the same gloves on two
patients and you watched it, is that
correct?"
Answer:
"Yeah."
So other than the Saturday, this is
the one example you were talking about where
you saw him use it on two patients, correct?
A
Other than the Saturday?
Q
Yes.
A
Yes.
Q And on this one occasion, did you not
in your deposition state you couldn't be sure
if he changed gloves or not because you
weren't watching him every second?
A
True.
Q Isn't it true you never saw Doctor
Andrews, physically watch him go from one
mouth with gloves on them with something you
could identify, like blood on the gloves, and
then walk to the next patient with you into
-15-
the next mouth, you never saw anything like
that, did you?
A
No, I didn't.
Q If you
question, I'll
it's on. Page
let's start at
What are you asking?
want to know the specific
be happy to tell you what page
39 -- I'll tell you what,
page 38.
Question 10: Now, in the affidavit, you
go on to say, quote, including a Saturday
when Doctor Andrews used the same gloves
while seeing all the dental patients that
day, end quote.
Are you with me?
A
Uh-huh.
Q "So, I guess my question is, on that
one Saturday you're talking about, how is it
you, after what you just described, how is it
you saw him every second of the entire day go
from patient to patient?"
Answer: "I don't know. I was just
with him. I mean like if he worked on this
patient and like if he was numbing her, then
we'd go back to the little room and sit and
wait a few minutes and then go back and then
-- then he wouldn't discard his gloves and
he'd just get in another patient."
Question: "Pam, I'm not trying to be
difficult, I'm just trying to, you know,
physically see this. Isn't it fair to say
that even on that Saturday, you can't say
with certainty that you saw him every second
between one patient and the next patient?
Answer: "No."
Question: "That's not fair to say?"
Answer: "Well, I mean, I didn't watch
him every second."
Question: "Well, that's what I'm
asking. Isn't it fair to say that when
you're cleaning up an operatory or washing
your own hands or whatever, Doctor Andrews
could have discarded those gloves and the
next time you saw him he had new gloves on
which you thought were the same gloves?"
-16-
Answer: "I guess."
Question: "I'm just asking if that's
a fair portrayal of what could have
happened."
Answer: "Yeah."
Question: "Did you ever see him go,
physically watching him from one mouth with
gloves on them with something you could
identify like blood on the gloves --"
"Uh-huh."
"-- and then walk to the next patient
with you into the next mouth, you never saw
anything like that, did you?"
Answer: "No."
Line 11, page 40: "And then on that
one Saturday when there could have been two
or three patients, he could have done things
when you weren't watching -- when you weren't
watching as far as the gloves are concerned?"
Answer: "He could have."
. . . .
Q You've testified about Doctor Andrews
treating a patient, getting up, going
somewhere, and coming back, and you said you
don't know for certain what he did when he
was out of your sight; do you remember that?
A
Uh-huh.
. . . .
Q When he came back within your sight,
did you get a look at the gloves that he was
then wearing?
A
I don't remember.
Q And when he went away on these
occasions when you thought he had come back
with the same gloves on, did he go away for a
long period of time or was it a short period
of time?
A
It was a short period.
-17-
Q
How short?
. . . .
A
It was probably about --
Q Was it a couple of minutes or was it
tens of minutes?
A No, it was like three or four
minutes.
Given the foregoing testimony, it is clear Jones was of
the opinion that boxes of clean gloves were not available
anywhere in the dental office other than beside the dental chair,
and that she therefore would have noticed if Andrews obtained
clean gloves while she was seated nearby.
However, this evidence
must be viewed in light of the fact that Jones worked in the
dental office only on a part time basis for some three weeks.
More important, it is otherwise undisputed and the board found
that numerous boxes of clean gloves were located throughout the
dental office at all relevant times.
Moreover, the record
clearly shows that by the end of her testimony, Jones admitted
that she did not observe Andrews at all times between patients on
the dates in question, and that he may well have changed gloves
between patients if, as shown by the evidence and found by the
board, clean gloves were available in locations other than beside
the dental chair.
This being so, we are compelled to conclude
that the board's finding, that Andrews used a single set of
gloves while treating more than one patient "on at least one
occasion on or about the last week of June, 1997," is not
supported by substantial evidence.
Hence, the circuit court's
order must be reversed insofar as it affirms the board's findings
and disciplinary action respecting Count I.
-18-
Finally, Andrews contends on cross appeal that the
trial court erred by concluding that the Board's finding, that he
improperly delegated the task of taking dental x-rays to one or
more unqualified assistants, is supported by substantial
evidence.
We disagree.
Andrews adduced evidence below to show that he
delegated the responsibility for taking x-rays to a particular
qualified assistant, and that he did not delegate such
responsibility to any unqualified persons.
However, other
evidence showed not only that unqualified assistants regularly
took x-rays, but also that Andrews was aware of that fact and
sometimes specifically directed them to do so.
We are not
persuaded by Andrews' argument that since he designated a
specific qualified assistant to take x-rays, there was no
"delegation" of duties to unqualified persons.
Instead, the
evidence that Andrews encouraged or at least observed the taking
of x-rays by unqualified assistants, but took no steps to stop
them from doing so, was clearly sufficient to show that Andrews
permitted or authorized unqualified persons to take x-rays on his
behalf.
Thus, viewing the record as a whole, we are satisfied
that the board's finding, that Andrews improperly delegated the
task of taking x-rays to unqualified assistants, is supported by
substantial evidence, and we cannot say that the board erred by
making that finding.
For the reasons stated, the court's judgment is
affirmed in part, and reversed and remanded in part for further
proceedings consistent with our views.
ALL CONCUR.
-19-
BRIEF FOR APPELLANT/
CROSS-APPELLEE:
BRIEF FOR APPELLEE/
CROSS-APPELLANT:
A.B. Chandler III
Attorney General
Thomas A. Klausing
Louisville, KY
Mark Brengelman
Assistant Attorney General
Frankfort, KY
Frank R. Recker
Nancy A. Schell
Cincinnati, OH
-20-
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