New South Wales Police Force v Cursley
[2010] NSWWCCPD 66
•16 June 2010
| WORKERS COMPENSATION COMMISSION | ||||||
| DETERMINATION OF APPEAL AGAINST A DECISION OF THE COMMISSION CONSTITUTED BY AN ARBITRATOR | ||||||
| CITATION: | New South Wales Police Force v Cursley [2010] NSWWCCPD 66 | |||||
| APPELLANT: | New South Wales Police Force | |||||
| RESPONDENT: | Jason Cursley | |||||
| INSURER: | Allianz Australia Insurance Ltd | |||||
| FILE NUMBER: | A1-8080/09 | |||||
| ARBITRATOR: | Ms A Simpson | |||||
| DATE OF ARBITRATOR’S DECISION: | 10 March 2010 | |||||
| DATE OF APPEAL DECISION: | 16 June 2010 | |||||
| SUBJECT MATTER OF DECISION: | Compensation for pain and suffering resulting from impairment; section 67 of the Workers Compensation Act 1987; back injury | |||||
| PRESIDENTIAL MEMBER: | Deputy President Bill Roche | |||||
| HEARING: | On the papers | |||||
| REPRESENTATION: | Appellant: | SMK Lawyers | ||||
| Respondent: | WG McNally Jones Staff | |||||
| ORDERS MADE ON APPEAL: | The Arbitrator’s determination dated 10 March 2010 is confirmed. | |||||
| The appellant employer is to pay the respondent worker’s costs of the appeal, as agreed or assessed. | ||||||
BACKGROUND
The respondent worker, Jason Cursley, started work as a general duties police officer with the appellant employer, the New South Wales Police Force, in about 1996. In 2004, he joined the water police diving unit. On 22 October 2007, he injured his lower back while lifting a 100 kg cylinder from a trailer. He reported his injury and claimed compensation. Liability was admitted and weekly compensation paid voluntarily.
In an Application to Resolve a Dispute (‘the Application’) registered in the Commission on 6 October 2009, Mr Cursley sought lump sum compensation in respect of a 15 per cent whole person impairment together with $25,000.00 for pain and suffering.
The Commission referred the claim for whole person impairment to Dr Rosenthal, Approved Medical Specialist (‘AMS’), for assessment. In a Medical Assessment Certificate (‘MAC’) issued on 4 December 2009, Dr Rosenthal certified Mr Cursley to have a 12 per cent whole person impairment as a result of the injury to his lumbar spine.
By consent, the appellant employer agreed to pay compensation under section 66 of the Workers Compensation Act 1987 (‘the 1987 Act’) in the sum of $17,902.50 in respect of the 12 per cent impairment certified by Dr Rosenthal. The Commission listed the claim for compensation for pain and suffering for conciliation and arbitration on 10 February 2010. That claim could not be resolved and proceeded to arbitration. The Arbitrator heard submissions from each of the parties, but took no oral evidence.
In a reserved decision delivered on 10 March 2010, the Arbitrator made the following determination:
“The Commission determines:
1.That the Respondent pay the Applicant s67 Workers Compensation Act 1987 compensation for pain and suffering in the amount of $20,000 being 40% of a most extreme case.
2.That the Respondent pay the Applicant’s costs as agreed or assessed.”
In an appeal filed in the Commission on 6 April 2010, the appellant employer seeks leave to challenge the Arbitrator’s decision with respect to the worker’s entitlement to compensation for pain and suffering.
LEAVE TO APPEAL
Monetary threshold
Before proceeding to deal with an appeal, the Commission must determine whether the application meets the requirements of section 352 of the Workplace Injury Management and Workers Compensation Act 1998 (‘the 1998 Act’).
As the appellant employer has challenged the entirety of the award of compensation for pain and suffering, I am satisfied that the monetary thresholds in section 352(2) are satisfied.
Time
The appeal was lodged within 28 days of the Arbitrator’s decision in compliance with section 352(4) of the 1998 Act.
I grant leave to appeal.
ON THE PAPERS
Section 354(6) of the 1998 Act provides:
“(6)If the Commission is satisfied that sufficient information has been supplied to it in connection with proceedings, the Commission may exercise functions under this Act without holding any conference or formal hearing.”
Having regard to Practice Directions Numbers 1 and 6, the documents that are before me, and the submissions by the parties that the appeal can proceed to be determined on the basis of these documents, I am satisfied that I have sufficient information to proceed ‘on the papers’, without holding any conference or formal hearing, and that this is the appropriate course in the circumstances.
EVIDENCE
Mr Cursley relied on evidence from Dr Millons in a report dated 30 June 2009. Dr Millons took a history of the work injury and that Mr Cursley sought treatment from his general practitioner at a medical centre at Caringbah. CT and MRI scans revealed a large lumbar sacral disc prolapse towards the left side with displacement of the left S1 nerve root. His symptoms did not resolve and an opinion was sought from Dr Rosenberg, orthopaedic surgeon, who felt that surgery was needed.
Mr Cursley sought a second opinion from Dr Pell, neurosurgeon, who agreed that surgery was required. Dr Pell operated on Mr Cursley on 25 July 2008 at St Vincent’s Private Hospital. Leading up to that operation, Mr Cursley was troubled by continual pain in the lower back which radiated into his left leg to the Achilles tendon and into the foot. He also had shooting pains and pins and needles in his buttocks.
The surgery revealed compression from a bulging disc, but it was not “incised”. Both S1 nerve roots were decompressed. Mr Cursley’s leg pain diminished after the surgery, but his back and buttock pain continued.
Dr Pell readmitted Mr Cursley to hospital on 3 September 2008 because of increasing back pain in the week prior to presentation. In the days prior to presentation, Mr Cursley noticed reduced sensation in his perineal region and some urinary urgency and hesitancy. Dr Pell did not recommend further surgery. By 11 October 2008, the perineal numbness had settled, though there was some ongoing muscle spasm.
By February 2009, Dr Pell noted that Mr Cursley still had some “grabbing pain” in his back. There was still some left buttock pain, but no leg pain. He was taking Tramal, Lyrica, Mobic and Pariet. Mr Cursley felt that his situation had plateaued. On examination, lumbar movements were restricted.
At some stage in early 2009, Mr Cursley underwent peri-radicular cortisone injections, which only gave a few days relief. Dr Pell saw the worker again on 21 April 2009, when he recorded that his back pain continued. There was also some pain in the left buttock and calf. Dr Pell recommended bilateral L5/S1 facet joint injections. He also discussed “the differing opinions between decompression, fusion and artificial discs”. According to Dr Millons’ history, Dr Rosenberg “counselled the possibility of a discogram and possibly a spinal fusion”.
Dr Millons recorded that Mr Cursley was not glad he had the operation. He said he had continual pain in his lower back, radiating into his left buttock. He got occasional shooting pain through the left leg to the calf, but there was no weakness or numbness in the left leg. Mr Cursley woke at night and found it hard to get comfortable. Standing was easier than sitting. Bending aggravated his symptoms. He avoided lifting. Jarring and sneezing particularly increased his symptoms.
In a report dated 10 June 2009, Dr Hanson, general practitioner, provided a list of Mr Cursley’s attendances from 5 May 2008 until 16 October 2008. That list included entries for “complex regional pain syndrome” and an entry for “depressive anxiety disorder”.
In support of his claim, Mr Cursley tendered two statements. The first is headed “annexure A” dated 16 July 2009 and the second is headed “section 67”, but is undated. In his first statement, he confirmed the accuracy of the history recorded by Dr Millons. He rated his pain at the time of the injury as 7 or 8 out of 10 where 0 was no pain and 10 was the worst pain imaginable. In the time leading up to his surgery, his pain increased within that range and, following the surgery, he rated it at “9 or 10 out of 10 for three or four weeks”. Since then, it had abated a bit and, at the time of his July 2009 statement, he rated it at “somewhere between 7 and 8 out of 10”.
As at July 2009, Mr Cursley was due to start a pain management course at St Vincent’s Hospital. He managed his pain with medication and by alterations to his lifestyle. Basically, he has had to stop doing everything he liked.
Prior to the accident, Mr Cursley had been active in sport and always maintained a very high standard of fitness. He enjoyed working as a police diver and he described the diving unit as a “small group of highly motivated, hard working police officers” who were qualified commercial divers. Prior to his injury, Mr Cursley surfed between one and three times per week, ran between 8 and 16 kilometres three to five times per week, and did weight training or resistance training one to three times per week. He competed in adventure races and did marathon distance runs. He played football on and off until the end of 2007. He also played golf about once a week prior to his accident.
At the time of his statements, Mr Cursley’s physical activity was “basically non-existent” and was limited to hydrotherapy/swimming and low impact activities like Pilates, yoga and light machine weights. He has found it hard to motivate himself to exercise when he has been unable to achieve his desired level of fitness.
Since his injury, his mental state has “varied between depression to panic/anxiety attacks”. He has received treatment from Dr Lindsay Duncan, psychologist, to address those issues. He has also developed “a jaw/face disorder called TMJ” as a result of his back pain and stress. He has been unable to open his mouth properly because his jaw locks. As a result, he cannot eat properly and he has stopped going out to dinner.
His social life has been affected due to his back injury as he cannot stay up and socialise because his ability to sit is restricted and medication affects his consumption of alcohol. He cannot pursue the “social pace” that his wife and friends pursue. He has only attempted to sit in a cinema once since his accident, but had to leave early.
Mr Cursley’s sex life has deteriorated significantly due to his back injury and his depression. This has put a strain on his relationship with his wife, as well as his self-confidence. He feels that he has been neglecting his wife and has been unable to take her on planned overseas trips.
After originally planning to marry in October 2008, the marriage was postponed to March 2009 because of the surgery in July 2008. Mr Cursley feels as though his wife has been “cheated into marrying someone who can’t do the things” that he used to do when they met. Their plans to start a family have been put on hold because of his circumstances. On their honeymoon, he was restricted to his airconditioned room because he had a bad reaction to the opiate-based painkillers he had taken and he developed heat blisters on the back of his hands.
Mr Cursley has put on about 10 kilograms since the accident. He has made two unsuccessful attempts to return to work as a police officer. At the time of his statement, he was in the process of being offered a permanent restricted position that he feared would put him in an “unfulfilling desk job” until he resigned or retired.
ARBITRATOR’S REASONS
After referring to the evidence, the Arbitrator made specific reference to the following matters (at [20]) of her Statement of Reasons in assessing Mr Cursley’s compensation:
· Mr Cursley is a 32 year old police diver who because of his injury is now unable to carry out his pre injury duties in the Diving Unit and who will have many years of varying degrees of pain and suffering from the injury which occurred approximately 2 ½ years ago.
· He has already undergone surgery for the injury to his lumbar spine and has been readmitted on two additional occasions because of pain and surgery complications and for injections. There is a strong possibility that he will face further surgery in the near future.
· He states he is in constant pain from his injury, finding it difficult to sit or stand for long periods, and to sleep comfortably. He states the pain in his lower back radiates into the left buttock and occasionally down through his left lower limb to his calf.
· His evidence is that both the pain and the medication he takes causes significant interference to his social life, to the point where he does not participate in activities in which he previously engaged.
· Mr Cursley states, and is supported by the notes of the GP, that he has suffered a depressive anxiety condition for which he is being treated. I accept Mr Cursley’s evidence that both the pain and the psychological condition have caused difficulties within his new marital relationship.
She concluded that Mr Cursley was entitled to section 67 compensation for “pain and suffering in relation to his injury” and she assessed that compensation to be 40 per cent of a most extreme case.
ISSUES IN DISPUTE
The issues in dispute in the appeal are whether the Arbitrator erred in:
(a)incorrectly referencing the award of compensation for pain and suffering to the worker’s injury rather than to the permanent impairment flowing from any injury;
(b)failing to exercise “common sense and judgment”, and
(c)making a determination of the worker’s level of pain and suffering that was not “reasonably proportionate to a most extreme case of pain and suffering and was thus excessive”.
SUBMISSIONS, DISCUSSION AND FINDINGS
The appellant employer has challenged the Arbitrator’s decision on the ground that she has awarded compensation for pain and suffering referable to the “injury”, rather than for the permanent “impairment” that resulted from the injury.
Section 67 of the 1987 Act provides
“67 Compensation for pain and suffering
(1) A worker who receives an injury that results in a degree of permanent
impairment of 10% or more is entitled to receive from the worker’s
employer as compensation for pain and suffering resulting from the
permanent impairment an amount not exceeding $50,000. Pain and
suffering compensation is in addition to any other compensation under this
Act.Note. Section 65A provides that pain and suffering compensation for permanent impairment arising from psychological injury is not payable unless the injury is a primary psychological injury (as defined in that section) and the degree of permanent impairment arising from the injury is 15% or more.
(2) Because there is a distinction between injury and impairment resulting
from an injury (and compensation is payable under this section only for pain and suffering resulting from impairment), the pain and suffering for which compensation is payable does not include pain and suffering that results from the injury but not from the impairment.
(3) The maximum amount of compensation under this section is payable only
in a most extreme case and the amount payable in any other case shall be reasonably proportionate to that maximum amount having regard to the degree and duration of pain and suffering and the severity of the permanent impairment.
(4) The amount of compensation payable under this section in any particular
case shall, in default of agreement, be determined by the Commission.
(5) Compensation under this section is not payable after the death of the worker concerned.
(6) If an amount mentioned in this section at any time after the commencement
of this Act:
(a) is adjusted by the operation of Division 6, or
(b) is adjusted by an amendment of this section,
the compensation payable under this section is to be calculated by reference to the amount in force at the date of injury.
(7) In this section:
pain and suffering means:
(a) actual pain, or
(b) distress or anxiety,
suffered or likely to be suffered by the injured worker, whether resulting
from the permanent impairment concerned or from any necessary
treatment.”
The appellant employer has submitted that the Arbitrator incorrectly determined the level of pain and suffering experienced by Mr Cursley and, therefore, incorrectly determined his entitlement to compensation for pain and suffering under section 67.
The worker has conceded that an award of compensation under section 67 must relate to the pain and suffering resulting from the impairment and not from the injury. He has also conceded that the Arbitrator used the term “injury” when referencing the pain and suffering. However, he argued that, in this case, the factors considered relevant as arising from the “injury” equally arise from the “impairment”.
The worker referred to the finding of a significant lumbar spine injury by the AMS, which he categorised as “DRE III” by reference to the AMA Guides to Permanent Impairment. The impairment has reduced the worker’s ability to perform household tasks, and to engage in sporting and recreational activities. It has also left him with ongoing pain. Essentially, Mr Cursley’s submission was that, as a matter of fact, each and every one of the effects cited by the Arbitrator as having resulted from the injury has also “flowed from the impairment as found by the AMS”.
Section 67 makes it clear that compensation for pain and suffering is only available for the pain and suffering that has resulted from the impairment. Fugen Holdings Pty Ltd v Brassington [1999] NSWCA 107 (‘Brassington’) concerned a claim for lump sum compensation under the Table of Disabilities applicable for a back injury received before 1 January 2002. Though section 67 was in slightly different terms at that time, the distinction drawn in the current subsection (2) was contained (in substantially similar terms) in subsection (1A). The trial judge assessed the worker’s compensation for pain and suffering “as a result of the injury”. The employer appealed, arguing that compensation for pain and suffering was only payable for pain and suffering resulting from the loss and not for pain and suffering resulting from the injury. In dismissing the appeal, Giles JA (Priestley JA and Studdert JJ agreeing) concluded at [24]:
“On the facts as found by his Honour, the injury suffered by the respondent brought immediate impairment of his back and loss of efficient use of his legs. In short, he could not work, was in constant pain, and could not walk properly. He suffered loss, meaning permanent impairment of his back and permanent loss of efficient use of his legs, from the time of the injury, even though the permanency of the losses may not have become apparent without the passage of time. In this last respect, reference may be made to the judgment of Clarke JA in Borovac v Corporate Ventures Pty Ltd at 95, recognising a permanent impairment from the time of the injury even though it was only at a later time that it could be said that all of the impairment was permanent. Further, there was no suggestion of pain and suffering arising from something other than the respondent’s losses. On the facts before his Honour, there was no difference between pain and suffering resulting from injury and pain and suffering resulting from a loss. It is understandable, therefore, that his Honour should have used the language he did in stating his finding, and while it was incorrect language I do not think it demonstrated departure from s 67(1A).” (emphasis added)
In the present case, Mr Cursley suffered his impairment from the time of his back injury. There is no suggestion that his pain, distress and anxiety have arisen from something other than his impairment. It follows that, as Giles JA found in Brassington, there is no difference in the present case between pain and suffering resulting from Mr Cursley’s injury to his back and the pain and suffering that has resulted from his impairment. They are, in the circumstances of this case, effectively one and the same. The only injury Mr Cursley suffered was to his back and it is as a result of that injury that he has a significant whole person impairment. All of his pain and suffering has therefore resulted from his impairment.
The distinction is well illustrated in the decision by Acting Deputy President Snell in Brewster v Proline Plumbing Pty Ltd [2010] NSWWCCPD 32 (‘Brewster’). In that case, the worker received “multiple injuries”, many of which were unconnected with the impairments later identified in the MAC (see [31]). Those injuries included an injury to the worker’s head, scarring to the face, blunt injury to the chest and abdomen, puncture wound to the right thigh with resultant scarring, and a fractured toe of the right foot. Evidence from the worker’s general practitioner referred to injuries to the left thumb, left thigh, right foot, right knee, and numerous cuts and bruises. However, the AMS only assessed whole person impairment on the basis of the condition of the worker’s back, left upper extremity (left thumb), and right lower extremity (right knee). It followed that, in that case, “the effects of the injury were not co-existent with the effects of the permanent impairment” (Brewster at [39]).
The facts in Brewster are in sharp contrast to the facts in the matter before me. There is virtually a precise correlation in the present matter between Mr Cursley’s injury to his back and his resulting impairment. It follows that the overwhelming majority of Mr Cursley’s actual pain, distress and anxiety has resulted from his impairment and the treatment he has received for it. Therefore, the Arbitrator’s reference to “injury” instead of “impairment” was, in the circumstances of this case, of no consequence. In my view, all of the matters the Arbitrator took into account in assessing compensation for pain and suffering were matters that clearly resulted from the worker’s impairment to his back. Therefore, though the Arbitrator used incorrect language, I do not believe she departed from the terms of section 67(2). If she did, I do not believe it was of any consequence.
In support of the second and third grounds of appeal, it was submitted that the factual situation is not dissimilar to that in New South Wales Police Service v Westling [2008] NSWWCCPD 99 (‘Westling’). In that case, Acting Deputy President Candy took into account the police officer’s relative youth (34), inability to carry out his pre-injury duties, interference with social life, significant inability to partake in previous sporting and recreational activities, and the impact upon the worker’s love life and marital relations in assessing compensation for pain and suffering at $12,500.00, representing 25 per cent of a most extreme case of pain and suffering.
It was argued that, though Mr Cursley is slightly younger than the worker in Westling and has a slightly higher assessment of permanent impairment (12 per cent instead of 10 per cent), Mr Cursley does not have any significant or embarrassing scarring and the alleged “lock jaw” has not been adequately linked to the permanent impairment such that it may be taken into account in assessing compensation for pain and suffering.
It was further submitted that an award of 40 per cent of the most extreme case was “grossly in excess of one guided by ‘sound discretionary judgment’” and that an appropriate award, given the guidance provided in Westling, was $15,000.00, representing 30 per cent of the most extreme case of pain and suffering. It was submitted that this figure would more accurately reflect the pain and suffering flowing from Mr Cursley’s permanent impairment when compared to the pain and suffering of, for example, a quadriplegic.
I do not accept the appellant employer’s submissions.
First, each case much be assessed on its own facts. That is especially so in cases involving an assessment of compensation for pain and suffering. No two cases are identical. The level of pain experienced by Mr Cursley as a result of his impairment is, in my view, severe and is likely to continue into the foreseeable future. I do not regard it as decisive that Mr Cursley does not have significant and embarrassing scarring. Even if I were to exclude the complaints relating to the “lock jaw”, I am comfortably satisfied that the Arbitrator’s determination fell within the reasonable range of compensation payable for pain and suffering in the circumstances of this case.
Second, it is complete nonsense to suggest that the Arbitrator’s assessment was “grossly in excess of one grounded by ‘sound discretionary judgment’”. Determining quantum under section 67 involves “in a sense, a value judgment” (Alvorac General Engineering Pty Limited v Arlotta (1993) 29 NSWLR 734 at 739A). Its resolution involves “questions of fact and degree, matters of opinion, impression, speculation and estimation calling for the exercise of common sense and judgment (Dell v Dalton)” (Galley v Pasminco Mining Limited (1993) 9 NSWCCR 288 at 297). The Arbitrator had careful regard to the evidence and the parties’ submissions before reaching her conclusion. It is a conclusion with which I fully agree.
Third, the submission on proportionality has compared the present case to the pain and suffering of a quadriplegic. Whilst quadriplegia may well represent a most extreme case, it is not the only example of a most extreme case. As noted by Kirby P (as his Honour then was) in Jones Bros Bus Co Pty Ltd v Baker (1992) 26 NSWLR 322 (at 338F) “it was not necessary to establish ‘the most extreme case’ as being the apex of a descending list of injuries catalogued according to their severity”. For a young man with a significant impairment, and substantial ongoing pain and anxiety, I do not accept that 40 per cent was an incorrect assessment of proportionality relative to a most extreme case.
If I am wrong in the above analysis, conducting an independent assessment of the matter, and taking into account Mr Cursley’s submission that the proper figure should have been $25,000.00 (50 per cent of a most extreme case), which was not without merit, I have reached the same conclusion as that reached by the Arbitrator.
Mr Cursley was born in April 1977 and is now 33 years of age. His life expectancy is 46.5 years. He has endured and will continue to endure significant actual pain, distress and anxiety as a result of his back impairment. He has undergone unsuccessful surgery that not only did not alleviate his symptoms, but increased the level of his pain and distress. After that surgery, he required a further admission to hospital and subsequent injections. Whilst he manages pain with medication, I infer that the medication does not entirely relieve his symptoms and he has been referred to a pain management course.
His evidence as to the level of his pain, distress and anxiety is uncontested and I have no hesitation in accepting it. That evidence includes evidence of depression and panic/anxiety attacks. Dr Hanson’s evidence confirmed that Mr Cursley has attended his surgery for complex regional pain syndrome and for his depressive anxiety disorder. I am comfortably satisfied that those conditions have resulted from Mr Cursley’s back impairment and that they have caused and will continue to cause him significant distress and anxiety.
I am satisfied that Mr Cursley also feels significant distress and anxiety as a result of his loss of sporting prowess, his inability to engage in a full and rewarding relationship with his wife, and his general inability to function at his pre-injury level. I accept that he also feels distress and anxiety that he will be placed in an unfulfilling “desk job” until he resigns or retires from the Police Force.
The evidence as to Mr Cursley’s “lock jaw” is contained in his statement headed “Section 67” where he said that the condition had been diagnosed as a result of his “back pain and the stress” it placed on him physically and psychologically. He has been referred to a maxillofacial surgeon for treatment as he has been unable to open his jaw properly. The report to Allianz from Ryan Ellmoos, physiotherapist, dated 9 July 2009 included the following under diagnosis “Lumbar disc injuries. L3/4, L4/5 and L5/S1 Disc injury – Mechanical and neuropathic features; TMJ jaw pain and dysfunction caused by chronic pain related mood disorder”.
Given that the appellant employer has tendered no evidence on the cause of the “jaw lock”, the overwhelming inference is that it has resulted from the stress and anxiety as a result of the back impairment and I am comfortably satisfied that that is the case. As a result of the jaw lock, Mr Cursley has stopped going out to dinner. His social life has also been disrupted because of his restricted ability to sit (because of his pain), his medication (which affects alcohol consumption), and the general effect that “being out too long” has on his ability to function in the following days. I infer from Mr Cursley’s evidence that all these matters have caused an increase in his distress and anxiety as a result of his impairment. Given the disruption to his social life because of his level of pain, I do not believe that the distress and anxiety from the “lock jaw” is significant in assessing compensation for pain and suffering.
In all the circumstances, it is my assessment that the appropriate compensation that is “reasonably proportionate” to the maximum payable “having regard to the degree and duration of pain and suffering and the severity of the permanent impairment” in the present case is 40 per cent of a most extreme case.
CONCLUSION
Having conducted a review on the merits, I am comfortably satisfied that the Arbitrator’s conclusion is true and correct and I agree with it.
DECISION
The Arbitrator’s determination dated 10 March 2010 is confirmed.
COSTS
The appellant employer is to pay the respondent worker’s costs of the appeal, as agreed or assessed.
Bill Roche
Deputy President
16 June 2010
I, MARIE JOHNS, CERTIFY THAT THIS IS A TRUE AND ACCURATE RECORD OF THE REASONS FOR DECISION OF BILL ROCHE, DEPUTY PRESIDENT OF THE WORKERS COMPENSATION COMMISSION.
ASSOCIATE
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