IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO DEBORAH L. TOOMEY, et al., Plaintiffs, vs.

CITY OF TRUTH OR CONSEQUENCES, a municipal corporation, Defendant. PLAINTIFF DEBORAH L. TOOMEYS MOTION TO STRIKE INSUFFICIENT DEFENSES AND DENIALS OF FACTUAL ALLEGATIONS FROM DEFENDANTS ANSWER TO COMPLAINT COMES NOW self-represented Plaintiff DEBORAH L. TOOMEY to hereby file this Motion to Strike Insufficient Affirmative Defenses and Denials of Factual Allegations from Defendants Answer to Complaint, and as grounds states: 1. Defendant asserts 15 affirmative defenses in its Answer to Complaint No. 2:12-CV-01100-JB-LAM

for Declaratory Relief and Injunction [Doc. 6]. 2. Defendants affirmative defenses do not plead facts or apply law to

specific claims in the current complaint as required.

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3.

All 15 of Defendants affirmative defenses are invalid under

Fed.R.Civ.P. Rule 8 pleading standards. 4. Additionally, Defendant flagrantly and fraudulently denies factual

allegations based upon official documents contrary to the official documents in paragraphs 36, 37, 40, 41, 51, 52, and 53. 5. Defendant also admits to factual allegations 12, 14, 15, 23, 50, and 65

while denying remaining allegations in paragraph when there are no remaining allegations in the paragraph. 6. Defendants legally insufficient affirmative defenses and fraudulent

denial of factual allegations clutter and confuse the litigation needlessly, adding unnecessary costs and delays for the parties.
MEMORANDUM OF LAW

Rule 12(f) provides that upon a motion made by a party within 21 days after being served with a pleading [t]he court may strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter.1 Fed.R.Civ.P. 12(f). In addition, Rule 12(f) may be utilized to test the legal validity of a defense. The motion to strike should be granted only if the insufficiency of the defense is clearly apparent. See Cipollone v. Liggett Group,
1

Although the Answer was filed on November 2, 2012, Defendant did not serve any parties until November 8, 2012.

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Inc., 789 F.2d 181, 188 (3d Cir. 1986). Therefore, to prevail on a motion to strike an insufficient defense, a plaintiff must show that there is no issue of fact that might allow the defense to succeed, nor any substantial question of law. See EEOC v. Bay Ridge Toyota, Inc., 327 F. Supp. 2d 167, 170 (E.D.N.Y. 2004). A defense should be struck when it is clearly irrelevant and frivolous and its removal from the case would avoid wasting unnecessary time and money litigating the invalid defense. S.E.C. v. Elec. Warehouse, Inc., 689 F. Supp. 53, 73 (D. Conn. 1988), affd, 891 F.2d 457 (2d Cir. 1989). Furthermore, broad affirmative defenses such as laches may be stricken where these defenses are alleged in conclusory fashion without any factual basis, thereby depriving plaintiff a fair notice of the grounds upon which the defense rests. See Qarbon.com, Inc. v. eHelp Corp., 315 F. Supp. 2d 1046, 1049-50 (N.D. Cal. 2004). Plaintiffs are entitled to adequate advance notice of Defendants theories of defense. Without such, Defendants conclusory assertions must be stricken. Defendants conclusory affirmative defenses contain no factual support or context, much less any explanation. These conclusory assertions cannot satisfy the relevant pleading standard under Rule 8.

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Defendant also falsely denies factual allegations in violation of Rule 11(b)(4), denying official documents contain language that is clearly evidenced those documents do contain the language Defendants deny. A. First Affirmative Defense Defendants First Affirmative Defense asserts that plaintiffs have failed to state a claim upon which relief can be granted. An affirmative defense raises matters extraneous to the plaintiffs prima facie case . . . . [Other] defenses negate an element of the plaintiffs prima facie case; these defenses are excluded from the definition of affirmative defense in Fed. R. Civ. P. 8(c). In re Rawson Food Serv., Inc., 846 F.2d at 1349. Defendants First Affirmative Defense is not an affirmative defense and fails to meet the standards of pleading of Rule 8 and must be stricken as insufficient. B. Second and Third Affirmative Defense Defendants Second and Third Affirmative Defenses assert that plaintiffs have failed to join a necessary party, including the United States. Upon granting of the Motion to Remand [Doc. 8], the second and third affirmative defenses will become moot. Plaintiff Toomey reserves the right to request the second and third affirmative defenses to be stricken upon the granting of remand to the state court.

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Regardless, this defense fails to meet the standards of pleading of Rule 8 and must be stricken as insufficient. C. Fourth Affirmative Defense Defendants Fourth Affirmative Defense asserts that plaintiffs are not real parties in interest and have failed to join the real parties in interest. Upon granting of the Motion to Remand [Doc. 8], the fourth affirmative defense will become moot. Plaintiff Toomey reserves the right to request the second and third affirmative defenses to be stricken upon the granting of remand to the state court. Regardless, Defendant has failed to provide any basis of fact or law in this defense. This defense fails to meet the standards of pleading of Rule 8 and must be stricken as insufficient. D. Fifth Affirmative Defense Defendants Fifth Affirmative Defense asserts that plaintiffs assert claims under laws of the United States which provide no private right of action for plaintiffs. Upon granting of the Motion to Remand [Doc. 8], the fifth affirmative defense will become moot. Plaintiff Toomey reserves the right to request the fifth affirmative defense be stricken upon the granting of remand to the state court. Regardless, this defense fails to meet the standards of pleading of Rule 8 and must be stricken as insufficient.

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E.

Sixth Affirmative Defense Defendants Sixth Affirmative Defense asserts that plaintiffs lack standing to

pursue their alleged claims brought under the public land statutes of the United States. Upon granting of the Motion to Remand [Doc. 8], the sixth affirmative defense will become moot. Plaintiff Toomey reserves the right to request the sixth affirmative defense be stricken upon the granting of remand to the state court. Regardless, this defense fails to meet the standards of pleading of Rule 8 and must be stricken as insufficient. F. Seventh Affirmative Defense Defendants Seventh Affirmative Defense asserts that plaintiffs have not shown any cognizable injury as a consequence of Defendants actions. Once again, this defense fails to meet the requirements of an affirmative defense. This defense fails to meet the standards of pleading of Rule 8 and must be stricken as insufficient. G. Eighth Affirmative Defense Defendants Eighth Affirmative Defense asserts that plaintiffs claims are barred in whole or in part by applicable statute of limitations. Defendant advances no legal or factual basis upon which the court could conclude that the complaint was untimely. Defendant has the burden of at least identifying the appropriate

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limitations period and raising some plausible reason why it has expired. Defendant has not even tried to do so. This defense fails to meet the standards of pleading of Rule 8 and must be stricken as insufficient. H. Ninth Affirmative Defense Defendants Ninth Affirmative Defense asserts that plaintiffs claims are barred in whole or in part by statutory limitations on the time within which to perfect an appeal to the courts from a final administrative or legislative decision. Defendant admits there were no legislative actions (i.e., ordinances or resolutions) to acquire either a recycling facility in 2007 or a solid waste collection center in 2011. Defendant also admits there were no administrative actions to either grant or deny a special use permit for either the recycling facility or the solid waste collection center, since application was never made. As NMSA 39-3-1.1 allows an administrative appeal to the court only when a statutory right to appeal has been expressly granted, Defendant is required to identify the statute upon which the right to appeal lies. Defendant fails to do so because there are no New Mexico statutes which give Plaintiffs the statutory right to appeal a failure to perform a legislative action (i.e., enact an ordinance or resolution) nor a final administrative decision of granting or denying a special use

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permit available for administrative appeal since said permit was never granted or denied. If Defendant had either granted or denied the special use permit, Plaintiffs would have had the statutory right to appeal under NMSA 3-21-9. As Defendant has admitted, there was never application for a special use permit so there was no denial or grant and thereby no administrative decision to appeal. If Defendant had enacted an ordinance to acquire a recycling facility in 2007 or solid waste collection center in 2011, Plaintiffs still would have no statutory right to appeal since NMSA 3-48-2 does not grant such a right.2 Defendant advances no legal or factual basis upon which the court can conclude that the complaint was untimely or that the action should be an administrative appeal under NMSA 39-3-1.1, and its statute of limitations, rather than Declaratory Judgment under NMSA 44-6-1. Defendant has the burden of at least identifying the appropriate statutes granting an administrative appeal and corresponding limitations period. Defendant has not even tried to do so and cannot do so as a matter of law. The ninth defense is frivolous, fails to meet the pleading standards of Rule 8 and must be stricken as insufficient.

Plaintiffs have a right to referendum, however, if an ordinance is enacted. NMSA 3-14-17.

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I.

Tenth Affirmative Defense Defendants Tenth Affirmative Defense asserts that plaintiffs claims are

barred in whole or in part by the doctrine of laches. Defendants conclusory affirmative defense contains no factual support or context, much less any explanation, and does not satisfy the relevant pleading standard under Rule 8 and must be stricken. In addition, an affirmative defense of laches in this case will fail as a matter of law: Whether a claim is barred by laches must be determined by the facts and circumstances in each and according to right and justice. Laches, in legal significance, is not mere delay, but delay that works a disadvantage to another. In order to prove the affirmative defense of laches, the defendant must demonstrate that there has been an unreasonable delay in asserting the claim and that the defendant was materially prejudiced by that delay. Hutchinson v. Pfeil, 105 F.3d 562, 564 (10th Cir. 1997) (internal quotation marks and citations omitted); see Jicarilla Apache Tribe v. Andrus, 687 F.2d 1324, 1337 (10th Cir. 1982) (noting that [l]aches will bar relief only where the enforcement of the asserted right would work injustice. Hoehn v. Crews, 144 F.2d 665, 671 (10th Cir.), affd on other grounds, 324 U.S. 200, 65 S.Ct. 600, 89 L. Ed. 870. Thus laches must be determined in light of the particular remedy fashioned.). Simply, there has been no delay upon any of the claims.

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For example, Claim 1s factual basis is an administrative decision that Defendant had a right to appeal until October 9, 2012. Plaintiffs filed suit one week later which cannot reasonably be construed as delayed. Plaintiffs are not required by any stretch of the imagination to know the secret dealings of Defendant and to act upon those secret dealings until known. For example, the acquisition of the recycling center was NEVER discussed at any open meeting at any time. Although required by NMSA 10-15-1 to formulate policy or conduct business in an open meeting, Defendant asks the judiciary to reward this failure by barring claims for delay. Additionally, it appears as if a failure to comply with procedural due process and mandatory notice requirements isnt barred for delay even 12 years after the fact. Carter v. City of Salina, 773 F.2d 251 (10th Cir. 1985). An affirmative defense of laches also requires that Defendant be harmed by the delay. Defendant cannot truthfully assert any harm by the requested relief. Contrary to Defendants frivolous assertions, the State of New Mexico does not require municipalities to acquire or maintain solid waste collection centers or recycling facilities, or any other form of refuse disposal plants or areas. Nor will there be trash piled high in the streets. Nor will there be a need to drive our collection trucks 180 miles to the nearest refuse disposal facility, since the County

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has several transfer stations capable of accepting Defendants waste no more than 10 miles away. Defendants assertion of a defense of laches is nothing less than a request to be rewarded for secret dealings in violation of every Democratic principle upon which this nation was founded and the State of New Mexico is governed. The Tenth Affirmative Defense must be stricken for failure to satisfy the relevant pleading standard under Rule 8 and is frivolous. In addition, this defense should not be amended as it will fail as a matter of law regardless of any amendment. J. Eleventh Affirmative Defense Defendants Eleventh Affirmative Defense asserts that plaintiffs claims are barred because they seek to prevent City from performing actions it is obligated to perform under applicable law. Defendant advances no legal or factual basis upon which the court can make any conclusions and fails to meet the pleading standards of Rule 8. Defendant does not identify what action is being prevented nor under what statute Defendant is obligated to perform this unidentified action. If Plaintiff Toomey assumes, based upon other pleadings, that the action Defendant claims is being prevented from being performed as required by law is

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the acquisition of a solid waste collection center or recycling facility, this defense is frivolous. No New Mexico statute requires Defendant or any other municipality to acquire a solid waste collection center or recycling facility or any other type of refuse disposal plant or area. The eleventh defense must be stricken as insufficient in failing to meeting the pleading standards of Rule 8 and is frivolous. In addition, amendment of this defense will not cure its defect as a matter of law since Defendant will not be able to identify which New Mexico statutes require a municipality to acquire refuse disposal plants or areas since no such statute exist. K. Twelfth Affirmative Defense Defendants Twelfth Affirmative Defense asserts that at least some of plaintiffs are not residents or taxpaying electors and, therefore, lack standing to pursue claims alleging wrongful acts by Defendant. This defense also lacks the standard of pleading as required by Rule 8. Even upon amendment, however, this defense will be barred as a matter of law. Although the Defendants wording is vague, Plaintiff Toomey assumes Defendant asserts the Williamsburg adjacent property owners are the not residents or taxpaying electors of City that lack standing.

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Defendant has the duty to perform due investigation for a basis in fact or law of an affirmative defense. Defendant failed to perform said due investigation as to whether adjacent property owners to a foreign municipality have standing to pursue claims alleging wrongful acts of due process violations, etc., in zoning decisions, or lack thereof. Moore v. Middletown, 133 Ohio St.3d 55, 2012-Ohio3897. Defendant has no legal or factual basis for the Twelfth Affirmative defense, fails to meet the pleading standards of Rule 8, is frivolous, and must be stricken as insufficient. L. Thirteenth Affirmative Defense Defendants Thirteenth Affirmative Defense asserts that plaintiffs claims are barred because the relief is contrary to public policy. Defendant does not identify which relief is barred nor which public policy is contrary. Defendant fails to meet the pleading standards of Rule 8 and is frivolous. Even upon amendment, however, this defense will be barred as a matter of law. There is no stated public policy in New Mexico to violate due process. There is no stated policy in New Mexico for municipalities to commit ultra vires acts and illegally govern. There is no stated policy in New Mexico requiring or even supporting that a municipality must acquire or operate refuse disposal plants or

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areas. Defendants Thirteenth Affirmative Defense is clearly frivolous and must be stricken as insufficient. M. Fourteenth Affirmative Defense Defendants Fourteenth Affirmative Defense asserts that plaintiffs claims are barred in by the New Mexico Tort Claims Act. Defendant advances no legal or factual basis upon which the court could conclude that the New Mexico Tort Claims Act is relevant. Since Plaintiffs make no claims of tort in the complaint, the Fourteenth Affirmative Defense is irrelevant, frivolous fails to meet the pleading standards of Rule 8 and must be stricken as insufficient. N. Fifteenth Affirmative Defense Defendants Fifteenth Affirmative Defense asserts that plaintiffs claims are barred because they are made in bad faith with frivolous arguments. Regardless of the laughability that Plaintiffs are acting in bad faith with frivolous arguments (i.e., the municipality must follow its own local zoning ordinances) when Defendant is actually acting in bad faith (i.e., denying factual allegations of clear language in local ordinances and other official documents) with frivolous arguments (a municipality is a kingdom which doesnt have to follow any laws), this is simply not an affirmative defense per Rule 8 and must be stricken.

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O.

Denial of Factual Allegations 1. Denial of Recycling Application Boundary Survey Plat

Defendant fraudulently denies, without support, the allegation in 36 of the Complaint: In the 2009 [recycling] application, Defendant attached a Boundary Survey Plat which stated this tract is subject to easements, restrictions and reservations of record. The recycling application Boundary Survey Plat is an official document evidenced in this case and clearly states this tract is subject to easements, restrictions and reservations of record.

[Doc. 56, p. 25.] This denial is frivolous, contrary to evidence of official documents and in violation of Rule 11(b)(4). Defendant also fraudulently denies 37 that these restrictions and reservations of record are to restrict and reserve the patent land for recreational purposes. Said denial is not warranted upon the evidence. Whether or not Defendant disagrees with the substance of a final administrative decision is not evidence to deny a factual allegation based upon official documents. If the PLAINTIFF TOOMEYS MOTION TO STRIKE 15

restrictions and reservations of record on the land are NOT the patent restrictions and reservations, Defendant fails to provide evidence of what those restrictions and reservations entail. Denying that an official document of a boundary survey plat submitted by Defendant to the State of New Mexico as part of its application for a recycling facility does not state what it actually does state is fraudulent at best and demonstrates bad faith upon the part of Defendant. Defendants denial of allegations 36 and 37 must be stricken and entered as admitted. 2. Denial of the plain language of Ord. 11-9-8

Defendant fraudulently denies, contrary to evidentiary support, the allegations in 40-41 of the Complaint: Recycling is not listed as a permitted right in the M-1 District and Recycling is listed as a special use in the M-1 District, respectively. This denial is egregious beyond compare and clearly in violation of Rule 11(b)(4) and professional conducts of code of ethics. Even though Defendant supposedly exhibited relevant pages and sections of the Citys Code of Ordinances, Defendant actually failed to exhibit ANY relevant pages and sections of Ord. 11-9-8. [Doc. 5, p. 8, fn. 2.] However,

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Plaintiffs did include in their Complaint the entire text of Ord. 11-9-8, including special uses which clearly lists Recycling as a special use and not a permitted right. Complaint, p. 12. A snip of the codified ordinances from Citys website at www.torcnm.org clearly establishes Plaintiffs do not misstate recycling as a special use in an M-1 District, and Defendants denial is fraudulent and frivolous:

This denial is in violation of Rule 11(b)(4) and contrary to the plain language of evidenced local ordinance 11-9-8. Defendants denial of their own local ordinance which clearly lists recycling as special use and not a permitted right is fraudulent at best and demonstrates bad faith upon the part of Defendant. Defendants denial of allegations 40 and 41 must be stricken and entered as admitted.

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3.

Denial of Solid Waste Collection Center Application Documents

Defendant fraudulently denies, without support, the allegations in 51-53 which were based upon Defendants official application for registration of the Solid Waste Collection Center. Once again, Defendant denies the Boundary Survey Plat states: this tract is subject to easements, restrictions and reservations of record in 51 for the solid waste collection center.3 Although Defendant exhibited the Solid Waste Collection registration form [Doc. 5-2, pp. 3-7], Defendant did not exhibit the entire application form. Plaintiff Toomey includes as Exhibit A one of the missing pages from the entire application form referencing Boundary Survey Plat recorded as Document No. 1482, which is the same Boundary Survey Plat included in the 2009 application form exhibited in this case as Doc. 56, p. 25. Due to the small size of the Exhibit, the relevant section of Exhibit A is snipped and enlarged for ease of reading:

Although required by the State of New Mexico Solid Waste Bureau to include a Boundary Survey Plat in an application, the 2011 solid waste collection center application attached the Boundary Survey Plat utilized in 2009 through reference.

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As such, the same factual allegations remain for the boundary survey plat submitted with the 2009 application under 36-37 as it does for the 2001 application under 51-52. Defendant also fraudulently denies in 53 that the 2011 application was not a signed statement that the solid waste collection center is properly zoned in the M1 zoning district. This is simply another frivolous untrue denial by Defendant:

Doc. 5-2, p. 4. Defendants denial is fraudulent, contrary to official documents and in violation of Rule 11(b)(4). Defendants denial of allegations 51, 52 and 53 must be stricken and entered as admitted. 4. Denials of Remaining Allegations

In Defendants denial of factual allegations 12, 14, 15, 23, 50, and 65, Defendant admits to the factual allegation and denies any remaining allegations contained in said paragraph. However, in each of those instances, there are NO remaining allegations in the paragraph to deny. As such, the irrelevant denial of

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remaining allegations in a paragraph that do not exist must be stricken and allegations 12, 14, 15, 23, 50 and 65 should be admitted in full. CONCLUSION WHEREFORE, for the above-stated reasons, Plaintiff respectfully requests this Court to: A. B. Strike the affirmative defenses 1-15; Strike denial of factual allegations 36, 37, 40, 41, 51, 52 and 53 and

order those allegations as admitted; and C. Strike denial of nonexistent remaining allegations in Defendants

admission of factual allegations 12, 14, 15, 23, 50 and 65; D. Any other relief the Court deems just and necessary, including but not

limited to a pro hac vice imposition of sanctions against Defendant. DATED: NOVEMBER 29, 2012 _____________________________ Deborah L. Toomey, pro se 211 W. Riverside Drive Truth or Consequences NM 87901 505-315-8503 505-214-5771 (fax)

CERTIFICATE OF SERVICE The undersigned hereby certifies that PLAINTIFF DEBORAH L. TOOMEYS MOTION TO STRIKE INSUFFICIENT DEFENSES AND DENIALS OF FACTUAL ALLEGATIONS FROM DEFENDANTS ANSWER TO COMPLAINT was hand-filed, on November 29, 2012, which caused all counsel of record and parties pro se registered in the CM/ECF system to be served via electronic mail. In addition, I caused to be hand-delivered a copy of said document(s) on November 29, 2012, to all parties pro se not registered in the CM/ECF:

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BARBARA SALASIN 211 W. Riverside Drive T or C, NM 87901 575-497-9549 RON FENN BETHANN FENN 316 N. Foch Street T or C NM 87901 GERALD TRUMBULL 905 Pine Street T or C NM 87901 REBECCA OTERO 558 Mims T or C NM 87901 YARROW DANKERT 819 Ivy Street T or C, NM 87901 FELICITAS RODRIGUEZ 6 Mud Canyon Road T or C NM 87901 DEBRA GEORGE 822 N. Pershing Street T or C NM 87901 JAMES C. MALLEN 600 N. Foch Street T or C, NM 87901 PATRICK FINLEY 735 Clancy Street T or C NM 87901 LINDA SCOTT 508 S. Pershing Street T or C, NM 87901 PATRICIA SISTRUNK 506 S. Pershing Street, # 1 T or C, NM 87901 JOAN CONWAY 316 E. 3rd Avenue T or C, NM 87901 JOHN PAPE 212 Austin Avenue T or C, NM 87901 ALISON RASHEDI 214 Oak Street T or C NM 87901 ROBERT HANSECK 316 Broadway Avenue T or C NM 87901 WILLIAM CHARLES BENNETT JR. 560 Mims T or C, NM 87901

GORDON MISHLER MONICA MISHLER AUGUSTA MISHLER JOSEPH MISHLER 604 Sunset Ave Williamsburg, NM 87942 GLENN M. ALLEN 610 Sunset Avenue Williamsburg, NM 87942 JOHN E. RAYBURN LYNN LARA 611 Sunset Avenue Williamsburg, NM 87942 BENJAMIN A. SANCHEZ BONNIE SUE SANCHEZ 206 Central Street Williamsburg, NM 87942 MARYANN WALTER 703 Central Street Williamsburg, NM 87942 THOMAS P. BARTO GRETCHEN M. BARTO 606 Central Street Williamsburg, NM 87942 ARTHUR LEVINE RAMONA LEVINE 500 Central Street Williamsburg, NM 87942 ROBERT R. MUNNERLYN 503 Central Street T or C, NM 87901 EARL FOX DIANNE FOX DANA VILLINES DARONDA FOX 520 Central Street Williamsburg, NM 87942 LOUIE PALACIOS JAMES PALACIOS 500 Central Street Williamsburg, NM 87942 PHYLLIS MADISON DAVID MADISON MICHELLE CAMBROTO 401 Central Street Williamsburg, NM 87942 WILLIAM MATA 705 Ridge Road Williamsburg, NM 87942 AMANDA BAILEY 205 Central Street Williamsburg, NM 87942

MICHAEL W REED MILDRED I. REED 6306 Veater Street Williamsburg, NM 87942 CHERYL HOLLINGSWORTH 100 Rio Grande Williamsburg, NM 87942 DON CHILDERS SHIRLEY M. CHILDERS 701 Sunset Avenue Williamsburg, NM 87942 BETTY DURHAM 613 S. Broadway Williamsburg, NM 87942 MARY ROSE 706 Sunset Avenue Williamsburg, NM 87942 CAROL NARANJO 705 Carmen Williamsburg, NM 87942 JOHN B. GILLEM LUCY FARRESTER 717 Carmen Williamsburg, NM 87942 BRUCE THOMPSON EDNA COBLE 714 Carmen Williamsburg, NM 87942 ANN B. SMILEY KENNETH HUGHES SMILEY 408 N Magnolia T or C NM 87901 MICHAL SCHARTZ 675 S. Pershing T or C NM 87901 ALFREDO BACA MARIA BACA 201 W. Riverside T or C NM 87901 JOSEPH JARAMILLO MARCUS JARAMILLO 1208 Aluminum T or C NM 87901 MICHELLE ELLINGER 427 Van Patten T or C NM 87901 KATHE BACHTEL 590 Mims #5 T or C NM 87901

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DATED: NOVEMBER 29, 2012

____________________________________________ Deborah L. Toomey, pro se 211 W. Riverside Drive Truth or Consequences NM 87901 505-315-8503 505-214-5771 (fax)

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