mental health evaluation for foid cardmental health evaluation for foid card

The other requirements generally pertain to any history of mental health problems you may have and any criminal convictions in your past. endstream endobj 161 0 obj <>/Subtype/Form/Type/XObject>>stream Per the Firearm Owners Identification Card Act (430-ILCS 65/), initial applications must be processed within 30 days and renewals must be processed within 60 days. H23754VH2P0P326E\i\z Appeals fall into two general categories - those where fewer than 5 years have passed since the hospitalization or mental health prohibitor and those where more than 5 years have passed since the hospitalization or mental health prohibitor. LCPCs report under Illinois Department of Human Services. Testing and Evaluation Therapists in Illinois Psychology Today, Reporting under FOID Act | Illinois State Bar Association, I was denied a foid card because of a stay in a mental hospital , Violence Assessment and Intervention: The Practitioners , FOID was denied because I was admitted to the mental , FOID was denied because I was admitted to the mental hospital in middle school. However, the Confidentiality Act allows them to report patients who pose a clear and present danger or are determined to be developmentally disabled to the professionals employer, who then must report to DHS, within 24 hours of the determination. There was confusion as to whether this required a retroactive determination such that, for example, a facility was required to evaluate all developmentally disabled persons in their program and report the individuals to DHS. H2TH2P0P326E\i\z H2TH2P0P326E\i\z !Y\!\\ # Contact for content you want removed. You should have your psychiatric records sent to us for review prior to the evaluation. is an independent forensic-clinical psychology practice providing specialized evaluation and consultation services. In the few cases I have done, Ive had people swear they only had one brief course of treatment, but once you get those records, if it refers to treatment or evaluation by another mental health provider, you then have to chase down and review those records too. !Y\!\\ # 143 0 obj <> endobj From a risk management perspective for practitioners, it is best practice for physicians, clinical psychologists and qualified examiners to report directly to DHS themselves, rather than relying on their employer. I was tricked into signing a form that I did not read stating that another patient overheard me say that I felt like jumping out of a window. Each case and appeal is different. The disability must originate before the age of 18 years, be expected to continue indefinitely and constitute a substantial handicap. NO H2TH2P0P326E\i\z Licensed Clinical Professional Counselor, A licensed clinical professional counselor with a master's or doctoral degree in counseling or psychology or a similar master's or doctorate program from a regionally accredited institution who has at least 3 years of supervised postmaster's clinical professional counseling experience that includes the provision of mental health services for the evaluation, treatment, and prevention of mental and emotional disorders. H4 Visit Dr FOID. (FOID Act, Sec. Then you have an appeal after 5 years which is abbreviated. l2Is 7D- Disciplinary information may not be comprehensive, or updated. endstream endobj 151 0 obj <>/Subtype/Form/Type/XObject>>stream Best get a lawyer that understands this stuff and can compile the evidence. To apply for a FOID card, go to the Illinois State Police website . 1.1). How to Register to Sign-upor Report an Individual, Persons that are determined to be a "Clear and Present Danger" to themselves or others, Persons that are determined to be Developmentally Disabled, Persons that are determined to be Intellectually Disabled. <> Real answers from licensed attorneys. We provide thorough, timely, research-based Midwest Behavioral Risk Management, P.C. DHS regulations require multiple reporting. stream 284 0 obj <>stream Who is mandated to report: endstream endobj 169 0 obj <>/Subtype/Form/Type/XObject>>stream 198 0 obj <>/Filter/FlateDecode/ID[<3BA8E34FCA21934C9D131F2755300BAA>]/Index[143 142]/Info 142 0 R/Length 169/Prev 275605/Root 144 0 R/Size 285/Type/XRef/W[1 3 1]>>stream One source of confusion for practitioners is the conflict between statutes as to how a professional can fulfill his or her duty to report. Midwest Behavioral Risk Management, P.C. Mental Health - Voluntary Mental Health Admission Less than Five Years Ago, Mental Health - Voluntary Mental Health Admission More Than Five Years Ago, Mental Health - Involuntary Mental Health Admission. endstream endobj 147 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream I had one many years ago, but it expired. By my signature below, I affirm: I am a physici an, cl inical psychologist or qual ified examiner as defi ned in 405 ILCS 5/1-122; @D)6hg#,v&"?axOBxh8@(lClzH0. 2. In the best of times (i.e., pre-COVID) it is my understanding that FSB was understaffed. l2Isr**`\y@cB]Bt LL,L)pY>\y H23754VH2P0P326E\i\z H4 0 l2Is 7D- SPRINGFIELD, Vt. - Health Care and Rehabilitation Services (HCRS), southeastern Vermont's non-profit community mental health agency, announced today that they are collaborating with the Institute for Community Health (ICH) to conduct a community needs assessment.This confidential assessment survey seeks to understand people's needs and experiences related to improving the system of care . Generally speaking, a voluntary psychiatric hospitalization disqualifies someone from having a FOID card for 5 years, while an involuntary hospitalization disqualifies someone permanently. endstream endobj 163 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream My apologies for being a bit long-winded here, but this is what I think is going on with FOID / CCL revocation appeals, although I don't have any particular relationship or insight into the Illinois State Police Firearms Services Bureau. H23754VH2P0P326E\i\z &3.*K{@{:ZB`iyKt-ReO2nwPy4t\#VF_;q[ka;ZdgZ19OJFa}[/p$1imf9w@Le7b62_{oZ+-dvaZhBRx /4t W"Ag'6UB{xk;lbcgiJ:NS#2ORgYxKr^{o~nYYA?Z_ma75! Mental health facilities must report to DHS within seven days after admission as an inpatient all persons who are prohibited from obtaining a FOID card, which includes the following: a person who has been a patient of a mental health facility within the past five years, a person who had been a patient in a mental health facility more than five years ago who has not received the certification required under Section 8(u) of the FOID Act, a person who is a clear and present danger to himself or herself, any other person or persons or the community, a person who is intellectually disabled, a person who has been adjudicated as a mentally disabled person, a person who has been found to be developmentally disabled, a person involuntarily admitted into a mental health facility. He has testified in circuit court cases as well as federal court cases. Psychiatric Services 70:1 January 2019. Answers given herein are necessarily brief and cannot be complete or reliable legal advice until (a) an attorney-client relationship has been established, and (b) until complete information has been given pursuant to that relationship.. Mental Health Certification For Firearm Possession - FOID Card https://ispfsb.com/Public/Firearms/FOID/MentalHealthCert.pdf Instructions: 1. H2TH2P0P326E\i\z In order for citizens of the State of Illinois to acquire or possess firearms, firearm ammunition, stun guns, or tasers, they must apply for and successfully be approved for possession of a Firearm Owners Identification Card (FOID). . H4 l2Is S 2. There is an appeal within 5 years of inpatient treatment that has a bunch of hoops to jump through, including all psych records for the last 5 years, a forensic evaluation by a shrink. Comprehensive Psychological Evaluations in Legal Contexts. Hello all -. healthmdsearch.com is a search engine, the content on the site has been added by users and is not controlled by us. Dr. Kessler will begin by discussing your situation with you (and/or your lawyer, if you have one) and determining the appropriate course of action to take with your evaluation. The definition of a mental health facility is much broader under the FOID Act than the Mental Health Code. My roommate was unconscious, and hooked up to life support. Avvo has 97% of all lawyers in the US. Psychology Today: Health, Help, Happiness + Find a Therapist In the fall of 2021, FOID and CCLs renewals had been automatically renewed 18 months because FSB didnt have time to process them, and per Capitol News, Illinois (4/13/21), renewals were automatically pushed back ANOTHER 15 months. l2Is 7D- Do Not Sell or Share My Personal Information. Do not . !Y\!\\ # Intellectually disabled means significantly sub-average general intellectual functioning which exists concurrently with impairment in adaptive behavior and which originates before the age of 18 years. If the facility provides any treatment of persons with mental illness, it is considered a mental health facility. endstream endobj 152 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream endstream endobj 167 0 obj <>/Subtype/Form/Type/XObject>>stream 2. 18 July 2022, Frequently Asked Questions as to FOID Mental Health Reporting, Request for Investigation and Waiver of Liability, FOID Appeal Requirements (Non-Mental Health), FOID Appeal Requirements - Mental Health Prohibitor, Psychiatrist or Licensed Clinical Psychologist's Evaluation or Letter Requirements, Mental Health Certification for Firearm Possession (Mental Health Admission > 5 yrs. NAME OF FOID CARD PETITIONER: DATE OF BIRTH: / / Last, First, Middle Initial . H2TH2P0P326E\i\z Mental health facilities must report to DHS within seven days after admission as an inpatient all persons who are prohibited from obtaining a FOID card, which includes the following: a person who has been a patient of a mental health facility within the past five years. @D)6hg#,v&"?axOBxh8@(lClzH0. Regarding individuals who have been adjudicated mentally disabled, voluntarily admitted to a psychiatric unit, determined to be a "clear and present danger" or determined developmentally / intellectually disabled, DHS FOID Mental Health Reporting System Qualified Examiners Users Manual, Clear and Present Danger means a person who: (1) communicates a serious threat of physical violence against a reasonably identifiable victim or poses a clear and imminent risk of serious physical injury to himself, herself, or another person, as determine by a physician, clinical psychologist, or qualified examiner; or (2) demonstrates threatening physical or verbal behavior, such as violent, suicidal, or assaultive threats, actions or other behavior, as determined by a physician, clinical psychologist, qualified examiner, school administrator, or law enforcement official. 430 ILCS 65/1.1, Clear and Present Danger Request for Law Enforcement and School Officials, Clear and Present Danger Emergency Rule Change, eff. Every Good Wish. Eligible for a FOID Card? If a person is determined to be a clear and present danger during his or her admission to a mental health facility, both a report of an admission and a report of a clear and present danger must be made. His clients include hospitals, outpatient mental health clinics, and mental health professionals. H23754VH2P0P326E\i\z co:j?PW)g$NV:y\1t!v=S)K#+NS= Workplace and school violence consultation services, Law enforcement, fire protection and other public safety entities, Private security, investigation agencies, and executive protection teams, Not-for-profit organizations / foundations. In order to make me your lawyer you have to hire me, in writing. For applications received during the two-year period convictions (26.5%), mental health matters (20.3%), and crimes punishable by imprisonment for a term exceeding one denial were danger to self or others (45.5%) and not having a valid FOID card (30.4%). The physician, clini cal psychologist or qualified examiner must complete this form. Dr. Kessler will discuss these with you and together you will determine if it is appropriate to continue with the evaluation process. You will need: A valid Illinois driver's license or identification card number, A photograph showing your head and shoulders that was taken in the last 30 days (like a passport photo), and A $10.00 fee. Robert H. Hanafords Avvo Top Contributor Badges, Workers' Compensation Lawyer in Chicago, IL, Personal Injury Lawyer in Springfield, IL, This lawyer was disciplined by a state licensing authority in. Good luck. l2Is 7D- l2Isr**`\y@cB]Bt LL,L)pY>\y ) 2WW|4kt~|P#NBJmEbOL[ Social Science mental disorders, biologically based 27 mental health: Cawood Assessment Grid careful language usage 412; FOID (firearms owner identification card), FOID was denied because I was admitted to the mental hospital in middle school from ILGuns, 2 Haz 2022 Hi, so I submitted my FOID application around a week and a half ago, [I] have received a mental health evaluation by a physician,. hbbd```b``[@$Gp0|#V=z{`; ,D2_$`49`v ~fm"`]0DN "@T!0%Gd @ K(? w)drM?Y\w3QZ2{; i+#^P34_GdyyW\u]HWvg}g9, %V'%0'.LGUmZv~L"4KXNkv>u63>rnx9ugOO`zAsN>Ym8?Z;G&ywzX>^duc0B-hgp9n!T,N\Cn:WRoWg-N\8~uq:n^fK:/ s^8l\f fO~r4{'I:K/Wlw#|%{&B,tT?Mp|e{aae. Dr. Kessler is an expert in the area of professional ethics and has trained many mental health providers on relevant aspects of the FOID and concealed carry laws in Illinois. We provide, complete, and submit all required forms directly to the Illinois State Police, Firearms Services Bureau, Appeals Section. My answers to this question are informal and partial due to the insufficient nature of the information exchanged. l2Isr**`\y@cB]Bt LL,L)pY>\y Oh, and avoid "Second Amendment" lawyers. performed a mental health evaluation of the petitioner prior to completing the form. The identity of the reporter will not be disclosed to the subject of the report, i.e., the patient. For the purpose of reporting to DHS under the FOID Act, a mental health facility includes any licensed private hospital or hospital affiliate, institution, facility or part thereof, which provides treatment of persons with mental illness. Retain a lawyer. l2Is 7D- IL FOID Evaluation Midwest Behavioral Risk Management, P.C. Among mental health facilities, confusion arose as to whether a facility must report both the admission of an individual and an instance when the patient is determined to pose a clear and present danger. endstream endobj 159 0 obj <>/Subtype/Form/Type/XObject>>stream No attorney client relationship has been formed until you sign a representation agreement. @D)6hg#,v&"?axOBxh8@(lClzH0. We provide the following professional services: We provide services to a broad range of clients including: 2013. The Harris Center For Mental Health And dd Human Resources, Kentuckiana Center For Addiction Medicine. See the ISP Website for FOID Appeal. A: This is probably the most common inquiry I get asked on the website. 801 South 7th Street, Suite 600-S Springfield, IL 62703 or via e-mail to: ISP.FOID.Appeals@illinois.gov and 4) Upon receiving complete documentation for the record challenge, the Department will investigate the circumstances surrounding the denial or revocation action. endstream endobj 148 0 obj <>/Subtype/Form/Type/XObject>>stream Forensic & Clinical Services Rod E. Hoevet, Psy.D. hb``0e``" Firearm Owners Identification (FOID) Mental Health Reporting System Regarding individuals who have been adjudicated mentally disabled, voluntarily admitted to a psychiatric unit, determined to be a "clear and present danger" or determined developmentally / intellectually disabled By my signature below, I affirm: I am a physici an, cl inical psychologist or qual ified examiner as defi ned in 405 ILCS 5/1-122; See the ISP Website for FOID Appeal. The letter itself is not all that complicated, but it does say theyve reviewed EVERYTHING or at least tried to. With COVID, a flood of applications and complications with ISP employees working from home, the back log has expanded greatly. ISBA Members, please login to join this section. /}m]Zj6OW.1]vN{f`a::O& l1%\@O* sxunN? ILLINOIS FIREARM OWNER'S IDENTIFICATION CARD EVALUATION. endstream endobj 160 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream We conduct psychological evaluations to address the following: 2013. You may still need to contact local police. hk\EJJhk=d0{P]qYvjyw,lcQzJb]VZyjSy^a~Xi{`RKuHE9m?Bit!L!O! ) 2WW|4kt~|P#NBJmEbOL[ ) 2WW|4kt~|P#NBJmEbOL[ XA'8:I0L`$B|V,OJ`NgcxhQ#atZ~>nA,4d`=[8wO PEL3p0r0e` '7 You will also need to pay the application fee as well. H4 Under the Act, physicians, clinical psychologists and qualified examiners are mandated to report to the Illinois Department of Human Services (DHS) any person whom the physician, clinical psychologist or qualified examiner determines to pose a clear and present danger to himself, herself or others, or determines to be developmentally disabled. Additionally, mental health facilities are mandated to report the admission of individuals who are prohibited from obtaining a FOID card. Certification of Evaluator . %PDF-1.4 However, you should consider that you might be asking your treating psychiatrist to do a LOT of extra work, that might not completely fall under actual treatment and is time that probably wont be covered by your health insurance. endstream endobj 156 0 obj <>/Subtype/Form/Type/XObject>>stream and Joseph Chien, D.O. My FOID application was recently denied. NO, (1) communicates a serious threat of physical violence against a reasonably identifiable victim or poses a clear and imminent risk of serious physical injury to himself, herself, or another person as determined by a physician, clinical psychologist, or qualified examiner; or, (2) demonstrates threatening physical or verbal behavior, such as violent, suicidal, or assaultive threats, actions, or other behavior, as determined by a physician, clinical psychologist, qualified examiner, school administrator, or law enforcement official. We are qualified examiners and can complete this evaluation and submit the required documentation directly to the Illinois State Police Firearms Services Bureau Appeals Section for review. Midwest Behavioral Risk Management, P.C. H2TH2P0P326E\i\z To appeal you must submit a FOID Request for Appeal and Request for Waiver of Liability and have a physician, clinical psychologist or qualified examiner submit the Mental Health Certification For Firearm Possession to the Illinois State Police at the address listed . Even as we approach the two-year anniversary since enactment, there remains confusion among clinicians, hospitals and mental health practitioners as to how to comply with the reporting requirements. . H4 @D)6hg#,v&"?axOBxh8@(lClzH0. (y8R(5~AA3\$%r(yhJ"s2JbC3ucby*l*LQu.6,qJ?4C]-%(iMn\UW5|Sk6hXVWQxbRTZjcPxXoe:mPCZeew~zG-y43:;'wH6]kzzG:B?o;zb"}6xh7Us.gEy>x>yOU7+D^ w\_={]SZ|[_)r4y}As=>]|}jLSL~OZgW?^}?:l"i.3LC|^)/>Sanij5q{Szo^\]|s'?=<'=~/>G7wrx)}yLyoM{3x>^~}GFi'K/(.kg _Z59svo;]|1J|yvIuogkwe|t FOID/Firearm Evaluations - Specialized Forensic Unit PC FOID/Firearm Evaluations l2Isr**`\y@cB]Bt LL,L)pY>\y Independent Medical Examinations Independent Medical Examinations may be needed to determine the cause, extent, and treatment of a work-related or other injury where liability is at issue. 2. Click here to learn more or to get started. %%EOF If your psychiatrist wants any advice, please feel free to refer them to this website. Firearm forensic psychological evaluation takes approximately 4 hours of face-to-face assessment and can be completed in-person or via videoconferencing. Certification of Evaluator . Avoid the shrink business at all costs. We conduct psychological evaluations to address the following: Mental Health - Voluntary Mental Health Admission Less than Five Years Ago Mental Health - Voluntary Mental Health Admission More Than Five Years Ago Mental Health - Involuntary Mental Health Admission Clear and Present Danger These answers do not make me your lawyer. Dr. FOID. All right reserved. If you have been denied a FOID card, your appeal depends in part on the type and quality of psychological evaluation you submit as part of your appeal. endstream endobj 165 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream oz=hrgFc2-UXT.e/o 'Fw1?b}T qZey!X~oLr{{GsS@w+Sf There is no language in the Act to clarify this issue. Joseph T. Monahan, MSW, JD, ACSW is the founding partner of Monahan Law Group, LLC, in Chicago, which focuses its practice in mental health, confidentiality, guardianship, probate, and health care law. ]_hG(c+OZQZO0}[9_naF[="~G ?;_XRj%1V*_)Ugo#Qle@xgpvUfT[v/+cMbGBRZ/>,\Wg =*%1,|,^Fi[if]jwL&ZSmm;wN3S S!l[qw{_S-i9Ogmtg'D|-'zm\4KWLLuO6q;mBP| Bw+3^zgIGnGg,qv;J$&[3o zkX[: QxT9HjzPKni5FKPf dph_lJxZ^6j\Zqc`{Zk|a~Z: '@3jXm83&W4Seqi~4ZMf3{?i5B>n eXy6k&>JX7rJWrv9Qw36]={o#n)RyS{VO#|$XIwV[|\@~Bv^-I_LTk}, ]2?uWu_1_-^O-=u5kQ5Gfe|7~=vva`Gu |erFx+{@q-Gy`y.[O\Tt,Cs :,>^>A^dh gzhDXb/:hd\r7) o4u$=_NlZe9oW[i8Tw+y'[47?ubZ . The Act requires any physician, clinical psychologist or qualified examiner1 to report to DHS any person whom the physician, clinical psychologist, or qualified examiner determines to pose a clear and present danger to himself, herself or others, or determines to be developmentally disabled.. Post a free question on our public forum. endstream endobj 149 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream The newsletter of the ISBAs Mental Health Law Section, https://foid.dhs.illinois.gov/foidpublic/foid/. '. H2TH2P0P326E\i\z ) 2WW|4kt~|P#NBJmEbOL[ FOID (Firearm Owner's Identification Card) forensic psychological evaluation is usually requested when the person's application for the firearm card was denied due to prior psychiatric inpatient treatment. This certification must be completed by a physician, clinical psychologist or qualified examiner as defined in 405 ILCS 5/1-122. @D)6hg#,v&"?axOBxh8@(lClzH0. "The commissioner shall promulgate regulations which shall include, but not be limited to, provisions relating to mental health professionals approved to perform the evaluation; the process for evaluation; and the development of a standardized form to be used by mental health professionals performing such evaluation to approve or deny an Mental Health Certification For Firearm Possession (Mental Health Admission >5 years ago) Pursuant to: 430 ILCS 65/4(a)(2)(iv) and 430 ILCS 65/8(u) (ISP 2-606 5/18/15) Evaluator should mark ONE box. The physician, clinical psychologist or qualified examiner must have completed a mental health evaluation the petitioner of and must have r eviewed all collateral information supplied by the applicant and others prior to any assessment. I agree with Mr. Budlin and seek out an attorney. Substance abuse concerns could also disqualify you from being issued a FOID card. We are now offering secure, virtual teleconferencing services for psychological evaluations and treatment. Specialized Forensic Unit PC is a private nongovernmental organization, providing psychological evaluations in Illinois and Wisconsin. The application process requires the information contained on the state ID. The FOID Act and the Mental Health Code require the physician, clinical psychologist or qualified examiner to report directly to DHS. [N t[l6aA`RA+]Iph{fl?O L But, too late for you. Search for lawyers by reviews and ratings. FOID (Firearm Owners Identification Card) forensic psychological evaluation is usually requested when the persons application for the firearm card was denied due to prior psychiatric inpatient treatment. Pursuant to statute, a mental health evaluation is required for possible reinstatement. Your version needs scrubbed. Instructions: 1. Getting records is usually what takes the longest in any forensic evaluation and of course, it can take a long time to review the documentation if it is extensive. 5 0 obj F%_^+3y,tsq{1 =-Dc]ro@a;H1I#:m#@{zk$~ #}$Xk$kwH i'%U$) Z}7 8~PRvVE.~oaYm(R$;yoR_^,.mw}JgK'kk_/xy{vP~{L^$664xmhS[M3r>tTWSsLNi~}-z3~;__>wln{zjZ8Uew.'O^s{ng7QLTsc]_os0?. (Cont'd.) Ineligible if applicant: Has been a patient in a mental health facility in the past 5 years If more than 5 years, provide separate documentation "Mental health facility" meansbasically everywhere Has an intellectual disability, a mental disability or a developmental disability H23754VH2P0P326E\i\z 2. FOID Appeal Requirements - Mental Health Prohibitor If your FOID card has been revoked or your application denied due to a prior admission to a mental health facility within the last five years, you may appeal the decision to the Firearm Services Bureau (FSB) of the Illinois State Police. ago), FOID Appeal Requirements (Intellectually or Developmentally Disabled), Firearm Owners Identification (FOID) Card Act (430 ILCS 65/), Public Act 095-0564 which amended the FOID Card ActSection 10 amends the Mental Health and Developmental Disabilities Confidentiality Act (740 ILCS 110/12), FOID: Appeals, hearing; relief from firearm prohibitions (430 ILCS 65/10), Firearm Concealed Carry Act (430 ILCS 66/), Extreme Risk Protection Orders to Reduce Firearms Violence William Frizzell, M.D. Attorneys representing physicians, hospitals, therapists and other medical and mental health practitioners must be aware of the requirements under the Act to properly advise their clients as to how to satisfy their duty to report. Our Rating is calculated using information the lawyer has included on their profile in addition to the information we collect from state bar associations and other organizations that license legal professionals. l2Isr**`\y@cB]Bt LL,L)pY>\y I had no contact or conversations with any other patients. I was railroaded into a physc ward by a lying, vindictive nurse. We provide, complete, and submit all required forms directly to the Illinois State Police, Firearms Services Bureau, Appeals Section. Find the best ones near you. H2TH2P0P326E\i\z Are LPCs mandated? Developmentally disabled means a disability which is attributable to any other condition which results in impairment similar to that caused by an intellectual disability and which requires services similar to those required by intellectually disabled persons. If you appeal and if you lose, the regulations require a two year wait to again appeal. endstream endobj 168 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream
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