UNITED STATES OF AMERICA,

Plaintiff,

and

GERALD OSBORN, and SUSAN
OSBORN PLUMMER,

Plaintiffs/Intervenors,

v.

BLUEBERRY HILL ASSOCIATES,
L.P.; COSTICH ENGINEERING;
and PASSERO ASSOCIATES, P.C.;

Defendants.

Defendant Blueberry Hill Associates, L.P., shall be responsible for taking all corrective actions pertinent to the public and common use areas at Blueberry Hill, including sidewalks, parking, and ramps, as follows:

1.    Accessible Routes: Routes among parking, ground floor units, mailboxes, and the common use clubhouse, laundry room, and rental office at Blueberry Hill shall be retrofitted to be "readily accessible to and usable by handicapped persons." ⁽¹⁾ See 42 U.S.C. 3604(f)(3)(C)(i). Such retrofits shall correct the following violations ⁽²⁾:
   1. There is not an accessible route that connects all the dwelling units to the clubhouse, pool, and public right of way.
   2. There are no accessible routes from the dwelling units to the dumpsters.

   3. The clear floor space near the dumpsters, which is part of the accessible route, is cross sloped more than 2%.

   4. Paths are less than 36" wide.

   5. The cross slope of curb ramps exceeds 2% (1:50) [1200C; 1300C; 1300R; 1600C; 1700C; 2000C].

   6. The cross slope in parking access aisles is greater than 2% (1:50) [200C; 900C; 1100C].

   7. Curb ramps are excessively sloped at greater than 8.33% (1:12) [100R; 400C; 700C; 900C].

   8. Curb ramps are needed but not provided.

   9. Designated accessible routes include steps.

   10. Slopes on flared side are greater than 8.33%.

   11. Access aisles are not provided at the designated accessible parking spaces.

   12. On common use doors, the thresholds are greater than .5".

   13. Parking signs are not mounted high enough to be seen over parked vehicles. Similarly, parking signs are mounted below 84". In other areas, there are no designated accessible parking signs on post or wall.

   14. The cross slope of paths is greater than 2% (1:50) [100rR; 200L; 300R; 500L; 500R; 700C; 900C; 1200L; 1200R; 1300C; 1300R; 1400L; 1400R; 1500L; 1500R; 1600R; 1700R; 1800L; 1900R; 2100L; 2100R].

   15. The slope of paths is between 5% (1:20) and 8.33% (1:12) and is not constructed as a ramp [500C; 500R; 900R; 1400C].

   16. Paths are sloped more than 8.33% (1:12) [300C; 1100L; 1300C].

   17. Portions of the path are sloped greater than 5% (1:20) and is not constructed as a ramp [100rC; 100rR; 400C; 500L; 500R; 600L; 600C; 700C; 900C; 900R; 1100L; 1100R; 1400L; 1700R; 2100L] .

   18. Portions of paths are cross sloped greater than 2% (1:50) [100R; 300R; 400C; 600C; 700C; 700R; 900C; 1000R; 1100R; 1200C; 1200R; 1400L; 1400C; 1800L; 1800R; 1900R; 2000R; 2100L; 2100R].

   19. The routes are not connected to designated accessible parking.

   20. There are gaps in paths that are wider than the maximum .5".

   21. There are vertical rises greater than .25" that are not beveled or ramped.

2. Common Entrance Foyers: The common entrance foyers leading to the ground floor units at Blueberry Hill shall be retrofitted to be "readily accessible to and usable by handicapped persons." See 42 U.S.C. 3604(f)(3)(C)(i). Such retrofits shall correct the following violations:

   1. At the exterior door of the side vestibules of all buildings, the depth of maneuvering space in front of the door on the designated accessible route side is less than 60".

   2. At the interior door of the side vestibules of all buildings, the width of maneuvering space beside the door on the designated accessible route side is less than 18".

   3. The side vestibules of all buildings have a clear length of less than 48".

   4. Door closers operate in less than 3 sec.

   5. Interior door pressure is greater than 5 lbs.

   6. Maneuvering space is sloped greater than 2% [100rC; 100R; 200L; 200C; 400C; 500L; 500C; 500R; 600C; 700C; 700R; 800rC; 800rR; 900C; 1000L; 1000C; 1000R; 1100L; 1100C; 1100R; 1200L; 1200C; 1200R; 1300L; 1300C; 1400L; 1400C; 1400R; 1500L; 1500C; 1500R; 1600L; 1600C; 1700L; 1700C; 1700R; 1800L; 1800C; 1800R; 1900L; 1900C; 1900R; 2000L; 2000C; 2000R; 2100L; 2100C; 2100R; ].

   7. The width of the maneuvering space is insufficient beside the doors on the designated accessible route side.

   8. The depth of maneuvering space is insufficient in front of the door on the designated accessible route side.

3.     Common Use Area Building Accessibility: The rental office, clubhouse (including the kitchen, meeting room, business center, and bathrooms therein), and common-use laundry room at Blueberry Hill shall be retrofitted to be "readily accessible to and usably by handicapped persons", see 42 U.S.C. 3604(f)(3)(C)(i), and to comply with 28 C.F.R. Pt. 36, App. A (commonly referred to as ADAAG) and UFAS. Such retrofits shall correct the following violations:

   1. The curb portion of the curb ramp is excessively sloped greater than 8.33% (1:12). There is also an abrupt vertical rise of 1" where the transition must be smooth.

   2. Parking signs are mounted below 84" to the bottom.

   3. The cross slope of the parking access aisles is greater than 2% (1:50).

   4. The water fountain alcove is less than 30" wide.

   5. At the entrance, the threshold of the public and common use swinging doors is greater than .5".

   6. In the common use kitchen, the faucet controls and the range controls require tight grasping, pinching or wrist twisting to operate.

   7. In the common use kitchen, the range has controls in the back and is higher than 34", which places the controls out of reach.

   8. In the common use kitchen, the counter at the sink and the work station are higher than 34".

   9. In the common use office, the knob lockset requires tight twisting or grasping.

   10. The clear floor space, which is part of the accessible route, at the rent drop slot is cross sloped more than 2%.

   11. The box lid for the rental brochures is mounted higher than 54".

   12. There is no van designated accessible parking space(s).

   13. The strobe light is mounted above 80".

   14. There are no strobe lights in the restrooms and the rental office area.

   15. The signs for the men's and women's restrooms at the rental office are mounted too low and on the doors rather than the wall and they do not include a properly placed description of the pictogram, braille, a contrasting color, and properly sized characters and pictograms.

   16. In the showers in both restrooms, the controls are difficult to grasp, the fixed shower head is mounted above 48", and the floor is cross sloped more than 2% (1:50) because the drain is set too low.

   17. In the both restroom, the door is more than 4" from the front corner of the stall opposite the water closet.

   18. In both restrooms, the coat hook in stall is mounted above 48".

   19. In the women's restroom, the water closet is not 18" from the wall.
   20. In the men's restroom, the wall-hung urinal has rim mounted above 17", and the flush valve is mounted above 44".
   21. The doors to both restrooms require more pressure to open than allowed- greater than 5 lbs. from inside the common use building, and greater than 8.5 pounds from the pool area. These doors also have a threshold that is greater than .5".
   22. In the women's restroom, there is a twisting latching mechanism on stall.
   23. Near pool area, the slope in parking access aisle is greater than 5% (1:20).

   24. From the parking area to the pool, portions of path cross sloped greater than 2% (1:50), and a curb ramp is needed but not provided.

   25. On pool deck, the path cross sloped greater than 2% (1:50).

   26. The door from the community center to the pool area has a threshold greater than .5".

   27. Width of maneuvering space at the gate to the pool area is insufficient beside the door on the designated accessible route side. It is less than 18". The maneuvering space is sloped greater than 2% (1:50).

   28. The pool gate latch requires tight grasping to operate.

       
       

       ---

       IN THE UNITED STATES DISTRICT COURT
       FOR THE WESTERN DISTRICT OF NEW YORK

       UNITED STATES OF AMERICA,

       Plaintiff,

       and

       GERALD OSBORN, and SUSAN
       OSBORN PLUMMER,

       Civil Action No. 02-CV-6548CJS

       Plaintiffs/Intervenors,

       APPENDIX B TO
       CONSENT ORDER

       v.

       BLUEBERRY HILL ASSOCIATES,
       L.P.; COSTICH ENGINEERING;
       and PASSERO ASSOCIATES, P.C.;

       Defendants.

       ____________________________________
       
       ACCESSIBILITY RETROFITS TO ALL GROUND FLOOR UNITS
       AT BLUEBERRY HILL

       Defendant Blueberry Hill Associates, L.P., shall be responsible for taking all corrective actions pertinent to the ground floor units at Blueberry Hill, as follows:

       1. Sufficiently Wide Dwelling Unit Doors: All doors designed to allow passage into and within the ground floor dwellings at Blueberry Hill shall be retrofitted to be "sufficiently wide to allow passage by handicapped persons in wheelchairs." 42 U.S.C. § 3604(f)(3)(C)(ii). Such retrofits shall correct the following violations:

          1. In all units, the nominal clear width of sliding patio door is less than 32".

          2. In all two- and three-bedroom units, the nominal clear width of the bedroom doors is less than 32" because the swinging door plank is less than 34".

          3. In all two- and three-bedroom units, the nominal clear width of the hall bathroom door is less than 32" because the swinging door plank is less than 34".

          4. In all two-bedroom units, the clear opening of bi-fold utility door is less than 32".

       2. Routes Into and Through Dwelling Units: All ground floor dwelling units at Blueberry Hill shall be retrofitted to contain "an accessible route into and through the dwelling." 42 U.S.C. § 3604(f)(3)(C)(iii)(I). Such retrofits shall correct the following violations:

          In all units, the change in level at patio door ranges between 6" and 30". ⁽³⁾

       3. Switches, Outlets & Environmental Controls Within Dwelling Units: All ground floor units at Blueberry Hill shall be retrofitted to place all light switches, electrical outlets, thermostats, and other environmental controls to be in "accessible locations." 42 U.S.C. § 3604(f)(3)(C)(iii)(II). Such retrofits shall correct the following violations:

          Electrical outlets mounted below 15". ⁽⁴⁾

       4. Bathroom Wall Reinforcement Within Dwellings: All ground floor units at Blueberry Hill shall be retrofitted to contain reinforcements in bathroom walls to allow later installation of grab bars. 42 U.S.C. § 3604(f)(3)(C)(iii)(III).

          In all units, there do not appear to be reinforcements in bathroom walls to allow later installation of grab bars. ⁽⁵⁾

       5. Useable Kitchens Within Dwellings: The kitchens of all ground floor units at Blueberry Hill shall be retrofitted such that they are usable by persons with mobility impairments and "such that an individual in a wheelchair can maneuver about the space." 42 U.S.C. § 3604(f)(3)(C)(iii)(IV). Such retrofits shall correct the following violations:

          In all units, the kitchens lack sufficiently wide clear floor space centered on the oven/cooktop for a parallel approach by a wheelchair user, in that the clear space for the is off center by 8".

       6. Useable Bathrooms Within Dwellings: The bathrooms of all ground floor units at Blueberry Hill shall be retrofitted to be usable by persons with mobility impairments and "such that an individual in a wheelchair can maneuver about the space." 42 U.S.C. § 3604(f)(3)(C)(iii)(IV). Such retrofits shall correct the following violations:

          1. In all one-bedroom units, the water closet of Type A bathrooms is less than 18" from the side wall, shower, or bathtub.

          2. In all one-bedroom units, the parallel clear space at the lavatory in Type A bathrooms is less than 30"x48", and is off center by 18.5".

          3. In all two-bedroom units, the accessible route to bathtub past the water closet in hall bathrooms narrows to less than 32".

          4. In all two-bedroom units, the water closet side approach clearance between fixtures located on both sides of toilet in Type A hall bathrooms is less than 33".

          5. In all two-bedroom units, the water closet in Type A hall bathrooms is less than 18" from the bathtub.

          6. In all two-bedroom units, Type A hall bathrooms do not have a 30"x48" clear space beyond the swing of the door.

          7. In all two- and three-bedroom units, the parallel clear space at the lavatory in Type A hall bathrooms is less than 30"x48", and is off center.

       
       

       ---

       IN THE UNITED STATES DISTRICT COURT
       FOR THE WESTERN DISTRICT OF NEW YORK

       UNITED STATES OF AMERICA,

       Plaintiff,

       and

       GERALD OSBORN, and SUSAN
       OSBORN PLUMMER,

       Civil Action No. 02-CV-6548CJS

       Plaintiffs/Intervenors,

       APPENDIX C TO
       CONSENT ORDER

       v.

       BLUEBERRY HILL ASSOCIATES,
       L.P.; COSTICH ENGINEERING;
       and PASSERO ASSOCIATES, P.C.;

       Defendants.

       __________________________________
       
       NOTICE TO TENANTS

       Dear Tenant,

       This is to advise you that, as a result of a settlement in a case brought by the United States against the owners of this apartment complex, we have agreed to modify the ground floor units at Blueberry Hill to provide greater accessibility for people with disabilities. Your unit is one of those that does not meet the accessible and adaptive design requirements of the Fair Housing Act.

       Although your apartment unit will be retrofitted automatically after your tenancy ends, we want you to know that you may request to have your apartment modified now at no cost to you. The actual work will take no longer than _____ days and we will provide you with comparable alternative living arrangements during that time. In scheduling when the repairs will take place, we will take into account your preferences and convenience.

       You should be aware that this work must be completed within the next four years and six months, regardless of your intention to stay in your apartment for a longer duration. Please let us know if you are interested in having the work done now and we will provide you with additional information.

       The Management

       
       

       ---

       IN THE UNITED STATES DISTRICT COURT
       FOR THE WESTERN DISTRICT OF NEW YORK

       UNITED STATES OF AMERICA,

       Plaintiff,

       and

       GERALD OSBORN, and SUSAN
       OSBORN PLUMMER,

       Civil Action No. 02-CV-6548CJS

       Plaintiffs/Intervenors,

       APPENDIX D TO
       CONSENT ORDER

       v.

       BLUEBERRY HILL ASSOCIATES,
       L.P.; COSTICH ENGINEERING;
       and PASSERO ASSOCIATES, P.C.;

       Defendants.
       __________________________________
       

       FULL AND FINAL RELEASE OF CLAIMS

       I, _______________________, on behalf of myself and family members, agents, heirs, executors, administrators, successors and assigns, pursuant to the terms, provisions, and conditions of the Consent Order approved by the United States District Court for the Western District of New York on_____________________, 2004 in the case of United States v. Blueberry Hill Associates, L.P., et al., Civ. No. 02-CV-6548CJS ("lawsuit") and in consideration of the payment of _______________ do fully, finally and forever release, discharge, and hold harmless Blueberry Hill Associates, L.P., Costich Engineering and Land Surveying, P.C., and Passero Associates, P.C. (hereinafter "Defendants"), along with their insurers, attorneys, related companies, principals, predecessors, successors, assigns, affiliates, partners, directors, officers, agents, employers, shareholders, subsidiaries, employees, former employees, heirs, executors, and administrators and any persons acting under their respective direction or control (hereinafter "Releasees"), from any and all fair housing claims set forth, or which could have been set forth, in the Complaint in this lawsuit that I may have against Defendants or any of the Releasees for any of Defendants' actions or statements related to those claims through the date of this Consent Order, including claims for damages (both compensatory and punitive), costs, fines and attorneys' fees.

       I affirm that the only consideration for signing this Full and Final Release of Claims are the terms stated in the Consent Order signed by the parties, and the monetary payment referenced above. I have accepted the terms of this Release and the Consent Order because I believe them to be a fair and reasonable settlement and for no other reason. This Release and the Consent Order contain and constitute the entire understanding and agreement between the parties.

       ______________________________
       NAME (PRINT)

       ______________________________             _______________
       SIGNATURE                                                   DATE

       
       

       ---

       IN THE UNITED STATES DISTRICT COURT
       FOR THE WESTERN DISTRICT OF NEW YORK

       UNITED STATES OF AMERICA,

       Plaintiff,

       and

       GERALD OSBORN, and SUSAN
       OSBORN PLUMMER,

       Civil Action No. 02-CV-6548CJS

       Plaintiffs/Intervenors,

       APPENDIX E TO
       CONSENT ORDER

       v.

       BLUEBERRY HILL ASSOCIATES,
       L.P.; COSTICH ENGINEERING;
       and PASSERO ASSOCIATES, P.C.;

       Defendants.
       __________________________________
       

       NOTICE TO POTENTIAL VICTIMS OF HOUSING DISCRIMINATION
       AT BLUEBERRY HILL APARTMENTS, ROCHESTER, NEW YORK
       [Insert Picture]

       On _________________, 2004, the United States District Court for the Western District of New York entered a Consent Order resolving a housing discrimination lawsuit brought by the United States against the owner, architect, and site engineer ("Defendants") of Blueberry Hill Apartments. The lawsuit alleges that the ground floor units and the common use areas (e.g., the Rental Office, Community Building, and Swimming Pool) at Blueberry Hill are not accessible to individuals with disabilities. As part of the Consent Order, the Defendants have agreed to retrofit the ground floor units and the common use areas at Blueberry Hill to comply with the Fair Housing Act.

       Under the Court Order, a Settlement Fund is also being established to identify and pay damages to people whose civil rights were violated as a result of this discrimination. You may be qualified to recover from this Settlement Fund if you:

       • were discouraged from living at Blueberry Hill Apartments because of the lack of accessibility features;

       • have been hurt in any way by the lack of accessibility features at Blueberry Hilll Apartments, including the inability to have visitors who have disabilities;

       • paid to have your apartment at Blueberry Hill Apartments modified to be more accessible; or

       • were not informed about, or offered, all available apartment units at Blueberry Hill Apartments because of your disability, or the disability of someone who would be living with you.

       If you believe you have been discriminated against
       at Blueberry Hill Apartments because of your disability,
       and if you believe you are consequently entitled to a share of the Settlement Fund,
       please contact the United States Department of Justice at:
       1-800-896-7743
       leave message in mailbox X
       You may also write to:
       United States Department of Justice
       Civil Rights Division
       Housing and Civil Enforcement Section
       950 Pennsylvania Ave. N.W. -G St
       Washington, DC 20530
       You must call or write on or before [no more than 90 days after ______________, 2004,] and your message or letter must include your name, address, and, if possible, at least TWO telephone numbers where you may be reached.

       
       

       ---

       IN THE UNITED STATES DISTRICT COURT
       FOR THE WESTERN DISTRICT OF NEW YORK

       UNITED STATES OF AMERICA,

       Plaintiff,

       and

       GERALD OSBORN, and SUSAN
       OSBORN PLUMMER,

       Civil Action No. 02-CV-6548CJS

       Plaintiffs/Intervenors,

       APPENDIX F TO
       CONSENT ORDER

       v.

       BLUEBERRY HILL ASSOCIATES,
       L.P.; COSTICH ENGINEERING;
       and PASSERO ASSOCIATES, P.C.;

       Defendants.
       __________________________________
       

       LIST OF ROCHESTER METROPOLITAN AREA
       HOUSING ORGANIZATIONS

       Center for Disability Rights
       584 Lake Avenue
       Rochester, NY 14613
       (585) 647-925
       

       The Fair Housing Coalition for a Community of Monroe
       c/o HOP
       400 Andrews Street, Suite 515
       Rochester, New York 14604
       (585) 546-6340

       The Housing Council
       183 E. Main St., Suite 1100
       Rochester, NY 14604
       (585) 546-3700

       Monroe County Legal Assistance Corp.
       Fair Housing Enforcement Project
       80 St. Paul Street, Suite 702
       Rochester, NY 14604
       (585) 325-2500

       Public Interest Law Office of Rochester
       80 St. Paul Street, Suite 701
       Rochester, NY 14604
       (585) 454-4060

       Regional Center for Independent Living, Inc.
       758 South Avenue
       Rochester, NY 14610
       (585) 442-6470

       
       

       ---

       IN THE UNITED STATES DISTRICT COURT
       FOR THE WESTERN DISTRICT OF NEW YORK

       UNITED STATES OF AMERICA,

       Plaintiff,

       and

       GERALD OSBORN, and SUSAN
       OSBORN PLUMMER,

       Civil Action No. 02-CV-6548CJS

       Plaintiffs/Intervenors,

       APPENDIX G TO
       CONSENT ORDER

       v.

       BLUEBERRY HILL ASSOCIATES,
       L.P.; COSTICH ENGINEERING;
       and PASSERO ASSOCIATES, P.C.;

       Defendants.
       _________________________________
       

       CERTIFICATION OF FAIR HOUSING TRAINING ATTENDANCE

       I have received a copy of the Consent Order entered in United States v. Blueberry Hill Associates, L.P., et al., United States District Court, Western District of New York, Civ. No. 02-CV-6548CJS This Consent Order was explained to me by my employer and all my questions were answered concerning it. I have read and understood the Consent Order.

       Initials: __________________

       ______________________________
       EMPLOYEE/AGENT NAME (PRINT)

       ______________________________           _______________
       EMPLOYEE/AGENT SIGNATURE                      DATE

       
       

       ---

       1. For purposes of this decree, "readily accessible to and usable by handicapped persons" means compliance with American National Standards Institute (ANSI)for Buildings and Facilities -- Providing Accessibility and Usability for Physically Handicapped People, ("ANSI"), 1986 edition, or a comparable standard that provides "access essentially equivalent to or greater than required by ANSI A117.1" See 54 Fed. Reg. 3241 (Jan. 23, 1989). Should defendants elect to follow a standard other than ANSI in retrofitting any portion of the public and common use areas of any property covered by this Decree, they will inform the United States in writing of the standard they intend to use. Such standard must provide access that is "essentially equivalent to" or "greater" than ANSI A117.1 (1986).

       2. The following convention will be used in Sections I and II to identify the location of certain categories of violations: #L = Left side entrance of Bldg. #; #C = Center entrance of Bldg. #; #R = Right side entrance of Bldg. #; #rL = rear Left side entrance of Bldg. #; #rC = rear Center entrance of Bldg. #; #rR = rear Right entrance of Bldg. #.

       3. To correct this violation, Defendant Blueberry Hill Associates, L.P., shall be responsible for installing a permanent wooden patio deck that is flush to the interior of the ground floor unit at the request of a resident of a ground floor unit at Blueberry Hill. Within 30 days from the date of the entry of this Consent Order, Defendant Blueberry Hill Associates, L.P., shall: (a) install one permanent wooden patio deck on a ground floor unit to serve as a model, which shall be available for all tenants and prospective tenants to view; (b) begin to maintain at all times at least three (3) wooden patio decks in stock at Blueberry Hill; (c) provide written notification to each and every current tenant who resides in a ground-floor unit, informing them that a permanent wooden patio deck can be installed for them at no cost; (d) begin to provide written notification upon move-in to each and every new tenant who will reside in a ground-floor unit, informing them that a permanent wooden patio deck can be installed for them at no cost; and (e) begin installing a permanent wooden patio deck within one week of a request to do so by a current tenant or prior to the move-in date if the request is made by a new tenant. However, if Defendant Blueberry Hill Associates, L.P., receives more than three (3) such requests within the same seven (7) day period, Defendant Blueberry Hill Associates, L.P., shall be entitled to a seven (7) day extension to install the requested permanent wooden patio decks.

       4. To correct this violation, Blueberry Hill Associates, L.P., shall complete a survey of the height of electrical outlets in ten ground-floor units in Phase I and ten ground-floor units in Phase II, including five randomly selected one-bedroom apartments, five randomly selected three-bedroom apartments, and ten randomly selected two-bedroom apartments. Documentation of this survey and an affidavit attesting to its accuracy shall be included in the "initial report" submitted to the United States 100 days after the date of entry of this Consent Order. If the survey shows that the heights of the electrical outlets are greater than or equal to those found during the December 12, 2002 inspection by Department of Justice officials, no retrofitting of the electrical outlets shall be necessary.

       5. To correct this violation, Defendant Blueberry Hill Associates, L.P., shall be responsible for installing a set of grab bars with winget fasteners at the request of a resident of a ground floor unit at Blueberry Hill. Within 30 days from the date of the entry of this Consent Order, Defendant Blueberry Hill Associates, L.P., shall: (a) begin to maintain at all times at least 30 sets of grab bars and winget fasteners in stock at Blueberry Hill;  (b) provide written notification to each and every current tenant who resides in a ground-floor unit, informing them that grab bars can be installed for them at no cost; (c) begin to provide written notification upon move-in to each and every new tenant who will reside in a ground-floor unit, informing them that grab bars can be installed for them at no cost; and (d) begin installing grab bars within one business day of a request to do so by a current tenant or prior to the move-in date if the request is made by a new tenant. However, if Defendant Blueberry Hill Associates, L.P., receives more than 30 such requests within the same seven (7) day period, Defendant Blueberry Hill Associates, L.P., shall be entitled to a seven (7) day extension to install the requested grab bars.

       
       

       ---

       Document Entered: February 18, 2004