79-15 Amended 2015 TJ's Land Development LLC

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AMENDED
(CRC Variance) STATE OF NORTH CAROLINA
Department of Environmental Quality
and
Coastal Resources Commission
Permit
for
X Major Development in an Area of Environmental Concern
pursuant to NCGS 113A-118
Excavation and/or filling pursuant to NCGS 113-229
Permit Number
79-15
Issued to TJ's Land Development, LLC., PO Box 125, Pantego, NC 27860
Authorizing development in Beaufort - County at adi. Punao Creek, off SR 1718,
Yeatesville Road, near Belhaven as requested in the permittee's application dated 515115, including the
attached drawing (1), dated revised 2/10/14.
This permit, issued on December 17, 2015 , is subject to compliance with the application (where consistent
with the permit), all applicable regulations, special conditions and notes set forth below. Any violation of these terms may
be subject to fines, imprisonment or civil action; or may cause the permit to be null and void.
Marina
1) Prior to the occupancy of any new slips authorized under this permit, a marine pumpout sewage
disposal facility shall be installed in an.easily accessible location, and a representative of the Division
of Coastal Management shall meet on -site with the permittee to ensure that the required pumpout
facility is in place and operable. The pumpout facility shall be operable and maintained for the life of
the marina.
2) The marina shall display a sign showing the location of the on -site pumpout facility, including other
appropriate waste disposal information, at the entrance and exit from each of the main piers.
(See attached sheets for Additional Conditions)
This permit action may be appealed by the permittee or
other qualified persons within twenty (20) days of the issuing
date.
This permit must be accessible on -site to Department
personnel when the project is inspected for compliance.
Any maintenance work or project modification not covered
hereunder requires further Division approval.
All work must cease when the permit expires on
December 31, 2018
In issuing this permit, the State of North Carolina agrees
that your project is consistent with the North Carolina Coastal
Management Program.
Signed by the authority of the Secretary of DEQ and the
Chairman of the Coastal Resources Commission.
r J� f1.Lrti
V Bra on C. Davis, Director
Division of Coastal Management
This permit and its conditions are hereby accepted.
Signature of Permittee

TJ's Land Development, LLC
ADDITIONAL CONDITIONS
Permit No.
Page 2 of 4
3) No sewage, whether treated or untreated, shall be discharged at any time from any boats using the
marina. Any sewage discharge at the marina shall be considered a violation of this permit for which the
permittee is responsible. This prohibition shall be applied and enforced throughout the entire existence
of the permitted structure.
4) The permittee shall provide a Spill Prevention Control and Countermeasure plan to the Division of
Water Resources before fueling facilities are constructed and she supply a copy of the plan to the
Division of Coastal Management.
5) Unless specifically altered herein, this permit authorizes only the docks, piers, and other structures and
uses located in or over the water that are expressly and specifically set forth in the permit application.
No other structure, whether floating or stationary, shall become a permanent part of this marina facility
without permit modification. No non -water dependent uses of structures shall be conducted on, in or
over public trust waters without permit modification.
6) In accordance with the CRC Variance granted on 11/17/15, all portions of the access pier/walkway built
over Coastal Wetlands shall not exceed a width of eight (8) feet and shall be elevated a minimum of five
(5) feet over the marsh substrate as measured from the bottom of the decking.
7) No attempt shall be made by the permittee to prevent the full and free use by the public of all navigable
waters at or adjacent to the authorized work.
8) The permittee shall maintain the authorized work in good condition and in conformance with the terms
and conditions of this permit. The permittee shall not be relieved of this requirement if he abandons the
permitted activity without having it transferred to a third party.
9) This permit does not authorize the interference with any existing or proposed Federal project, and the
permittee shall not be entitled to compensation for damage to the authorized structure or work, or injury
that may be caused from existing or future operations undertaken by the United States in the public
interest.
10) The permittee shall install and maintain at his expense any signal lights or signals prescribed by the U.S.
Coast Guard, through regulation or otherwise, on the authorized facilities. At a minimum, permanent
reflectors shall be attached to the structure in order to make it more visible during hours of darkness or
inclement weather.
11) This permit authorizes a maximum of 66 docking spaces. At no time shall more than 66 vessels be
moored or docked at the marina facility.
Easement
12) . The permittee may be required to apply for a submerged lands lease from the Department of
Administration's State Property Office. Contact the Department of Administration's State Property
Office directly at [phone] for this determination. Should it be determined that an Easement is
required, the permittee shall supply a copy of the easement to the Division within 30 days of issuance of
the Easement.

Development, LLC
ADDITIONAL CONDITIONS
Upland Development
Permit No. 79-15
Page 3 of 4
13) Unless specifically altered herein, this permit authorizes the grading and other land disturbing activities
associated with the development of the above referenced property, including the campsites, bathroom
facilities, laundry mat, store, reception venue, pond modification with associated bulkhead, and required
access infrastructure, all as expressly and specifically set forth in the attached permit application and
workplan drawings. Contact a Division of Coastal Management representative at [phone] for this
determination.
Sedimentation and Erosion Control
14) Appropriate sedimentation and erosion control devices, measures or structures shall be implemented to
ensure that eroded materials do not enter adjacent wetlands, watercourses and property (e.g. silt fence,
diversion swales or berms, etc.)
General
15) The permittee understands and agrees that, if future operations by the United States requires the
removal, relocation, or other alteration of the structure or work authorized by this permit, or if in the
opinion of the Secretary of the Army or his authorized representative, said structure or work shall cause
unreasonable obstruction to free navigation of the navigable waters, the permittee will be required, upon
due 'not ice from the Corps of Engineers, to remove, relocate or alter the structural work or obstructions
caused thereby, without expense to the United States or the State of North Carolina. No claim shall be
made against the United States or the State of North Carolina on account of any such removal or
alteration.
16) No Coastal Wetlands shall be excavated or filled, even temporarily.
17) This permittee and/or his contractor shall meet with a representative of the Division prior to project
initiation in order to discuss the conditions set forth in this permit.
18) No open water areas shall be excavated or filled, even temporarily.
19) This permit does not eliminate the need to obtain any additional state, federal or local permits, approvals
or authorizations that may be required, including any authorizations from the NC DEMLR Stormwater
Section.

TJ's Land Development, LLC
ADDITIONAL CONDITIONS
Permit No.
Page 4 of 4
NOTE: Future development of the permittee's property may require a modification of this permit.
Contact a representative of the Division of Costal Management at [phone] prior to the
commencement of any such activity for this determination. The permittee is further advised that,
in accordance with the rules of the Environmental Management Commission, many non -water
dependent activities are not authorized within 50 feet of the normal water level or landward edge
of any coastal wetlands, whichever is more restrictive. Contact the Division of Water Resources
at [phone] for project specific clarification.
NOTE: The N.C. Division of Water Resources has authorized the proposed project under General Water
Quality Certification No. 3900 (DWR Project No. 14-0275 V2), which was issued on 7/8/15.
NOTE: The U.S. Army Corps of Engineers authorized the proposed project under COE Action Id. No.
SAW-201501116.

Coastal Management
ENVIRONMENTAL QUALITY
December 17, 2015
T J's Land Development, LLC
P.O. Box 125
Pantego, N.C. 27860
Dear Sir or Madam:
PAT MCCRORY
Gocernar
DONALD R. VAN DER VAART
Secretary
BRAXTON DAVIS
Director
The enclosed permit constitutes authorization under the Coastal Area Management Act, and
where applicable, the State Dredge and Fill Law, for you to proceed with your project proposal. The
original (buff -colored form) is retained by you and it must be available on site when the project is
inspected for compliance. Please sign both the original and the copy and return the copy to this office in
the enclosed envelope. Signing the permit and proceeding means you have waived your right of appeal
described below.
If you object to the permit or any of the conditions, you may request a hearing pursuant to NCGS
113A-121.1 or 113-229. Your petition for a hearing must be filed in accordance with NCGS Chapter
150B with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27611-6714,
[phone] within twenty (20) days of this decision on your permit. You should also be aware that
another qualified party may submit an objection to the issuance of this permit within twenty (20) days.
The project plan is subject to those conditions appearing on the permit form. Otherwise, all work
must be carried out in accordance with your application. Modifications, time extensions, and future
maintenance requires additional approval. Please read your permit carefully prior to starting work and
review all project plans, as approved. If you are having the work done by a contractor, it would be to your
benefit to be sure that he fully understands all permit requirements.
From time to time, Department personnel will visit the project site. To facilitate this review, we
request that you complete and mail the enclosed Notice Card just prior to work initiation. However, if
questions arise concerning permit conditions, environmental safeguards, or problem areas, you may
contact Department personnel at any time for assistance. By working in accordance with the permit, you
will be helping to protect our vitally important coastal resources.
Enclosure
Sincerely,
d ggw -
uglas V. Huggeti�
Major Permits and Consistency Manager
N.C. Division of Coastal Management
Nothing Compares��
State of North Carolina I Environmental Quality I Coastal Management
400 Commerce Avenue I Morehead City, NC 28557
252-808-2808

DCM Coordinator: SLAWS Permit #:
MAILING DISTRIBUTION SHEET
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DCM Field Offices
Elizabeth City
Morehead City
Washington
Wilmington
US ACOE Offices:
Washington:
Wilmington:
Cultural Resources:
Public Water Supply:
DCM/
Fisheries Specialist
NC DOT:
DMF/
Shellfish Sanitation:
State Property:
Water Resources:
Washington:
Wilmington:
DEMLR
Washington:
Wilmington:
Wildlife Resources:
LPO:
(with revised work plan drawings)
Raleigh Bland
William Westcott (NC DOT)
Bill Biddlecome (NC DOT)
Tyler Crumbley
Liz Hare
Renee Gledhill -Early
Diane Williams (WIRO)
Joey White (WARO)
Shane Staples
Gregg Bodnar
Ken Pace
Patti Fowler
Shannon Jenkins
Tim Walton
Karen Higgins (Raleigh)
John Hennessy (NC DOT)
Anthony Scarbraugh-401
Joanne Steenhuis — 401
Chad Coburn - 401
Scott Vinson-Stormwater
Georgette Scott- Stormwater
Maria Dunn
Fax Distribution: Permitee
Agent #:.
N . C. �ePcu }�r�e rt { o f J u�ii ce
PO 60X
goof mmi l Servile Uh+er

STATE OF NORTH CAROLINA
COUNTY OF BEAUFORT
IN THE MATTER OF:
PETITION FOR VARIANCE
BY TJ'S LAND DEVELOPMENT, LLC
BEFORE THE NORTH CAROLINA
COASTAL RESOURCES COMMISSION
CRC-VR-15-06
FINAL AGENCY DECISION
On October 2, 2015, Petitioner TJ's Land development, LLC submitted its request
seeking a variance from 15A NCAC 07H .0208 to allow construction of an 8-foot wide dock
over the wetlands adjacent to Pungo Creek near Bath in Beaufort County, North Carolina. This
matter was heard on oral arguments and stipulated facts at the regularly scheduled meeting of the
North Carolina Coastal Resources Commission (hereinafter Commission) on November 17, 2015
in Atlantic Beach, North Carolina pursuant to N.C. Gen. Stat. § 113A-120.1 and 15A NCAC 7J
.0700, et seq. Assistant Attorney General Shawn Maier and Christine A. Goebel, Esq. appeared
for the Department of Environmental Quality, Division of Coastal Management (DCM) and
Franz Holscher, Esq., of Rodman, Holscher, Peck & Edwards, P.A. appeared on behalf of
Petitioner.
Upon consideration of the stipulated facts and stipulated exhibits which together
comprise the record documents in this case and the arguments of the parties, the Commission
adopts the following:
FINDINGS OF FACTS
The Petitioner in this case is TJ's Land Development, LLC ("Petitioner").
2. Petitioner is a North Carolina limited liability company. Tobin J. Tetterton, Sr., is
the Registered Agent and sole member and manager of the company. (Stipulated Exhibit 1)
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3. The property subject to this variance is owned by Petitioner, is located off of SR
1718 near Belhaven in Beaufort County, North Carolina, and has a physical address of 1711
Yeatesville Road, Bath, North Carolina 27808 ("Site"). Petitioner acquired this property in 2013
from John Tankard Jones and wife, Mary Etta Jones, through a deed recorded at Book 1809,
Page 753 of the Beaufort County Registry. (Stipulated Exhibit 2)
4. The Site is adjacent to Pungo Creek. At this Site, the waters of Pungo Creek are
classified by the Environmental Management Commission as SC NSW waters. These waters are
Inland Waters regulated by the North Carolina Wildlife Resource Commission and are closed to
shell fishing.
S. The Site has coastal wetlands, public trust, and public trust shoreline Areas of
Environmental Concern ("AEC"). Pursuant to the North Carolina Coastal Area Management Act
of 1974 ("CAMA"), any "development" proposed for these AEC requires authorization under
CAMA and the North Carolina Dredge & Fill Law. N.C. Gen. Stat. § 113A-118 and § 113-229.
6. Currently, the Site is undeveloped. As seen in photographs, the Site consists of a
mix of cleared agricultural land, wooded 404 scrub shrub wetlands and coastal wetlands marsh.
The total acreage of the property is 46.5 acres, which includes approximately 854 linear feet of
coastal wetlands shoreline along Pungo Creek. The coastal wetlands are approximately 240 feet
wide between the normal high water 'level of Pungo Creek and the waterward extent of the
wetlands, and are vegetated with black needlerush (Juncus roemerianus), sawgrass (Cladium
jamaicense), and giant cordgrass (Spartina cynosuroides). (Stipulated Exhibits 3, 5, and 7)
7. On May 20, 2015, DCM received a complete CAMA major permit application
from Petitioner, through its authorized agent Hood Richardson requesting permission to
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construct a 66-slip marina and accessway, the infrastructure for a 106-lot RV camping ground
with associated septic systems, a community building (housing showers, laundry, a provisions
store, and reception facilities), an upland pond (with bulkhead and pier), parking, and fuel and
pump -out facilities. The marina is designed to provide dockage for the general public who desire
to rent a slip, including patrons of the RV camping ground. (Stipulated Exhibit 6)
8. Petitioner proposed that the 66-slip T-head marina would be accessed by an 8-foot
wide access dock of which approximately 50 feet is located over high ground, approximately 300
feet is located over wooded 404 wetlands, approximately 240 feet is located over coastal
wetlands and approximately 140 feet is located over open water. Petitioner proposed the entire
eight foot -wide dock be constructed five feet high, including the middle section over the coastal
wetlands substrate. This is two feet higher than the three foot height required by the
Commission's rules.
9. The access dock is designed to be eight feet wide by 586 feet long ending in a T-
shaped dock with 66-slips. The dock will have a thirty foot square, roofed platform at the
intersection with the access dock. This platform will support the fueling area and the marine
pump -out. Two 15 by 30-foot slips will be used by boats fueling or pumping out onboard
holding tanks. The dock.will have two 25 foot square roofed platforms at each end of the dock,
along with twenty-four 18-foot by 40-foot slips with a "stern to" orientation on the offshore side
of the dock accessed by fourteen finger piers. The inshore side of the dock will have forty 10 feet
by 10 feet boat lifts accessed by twenty-two finger piers. (Stipulated Exhibit (6)
10. As part of the CAMA major permit process, notice was sent to the two riparian
owners adjacent to the Site: JHG Farms, LLC and WMT Holding, LLC. These owners executed
3

an Adjacent Riparian Property Owners Statement indicating that they had no objection to the
proposed development and JHG Farms, LLC agreed to waive the 15 foot pier setback.
(Stipulated Exhibit 4) DCM received no additional feedback from these adjacent owners.
11. Also as part of the CAMA major permit process, notice was posted on Site and
was published in the Washington, Daily News. DCM received no comments related to this
proposed project.
12. Also as part of the CAMA major permit process, information about the proposed
development, including the DCM Field Investigation Report (Stipulated Exhibit 5) was sent to
state and federal resource agencies for comment. No adverse comments were received by DCM.
The Division of Water Resources issued a 401 Certification for the project on June 8, 2015.
13. On August 4, 2015, DCM issued CAMA major permit 79-15 (the "Permit")
(Stipulated Exhibit 6) authorizing construction of the 66-slip marina. However, Condition 6 of
the Permit limited the proposed access dock to a maximum width of 6 feet in the middle section
over approximately 240 feet of coastal wetlands as required by the Commission's rule found at
15A NCAC 7H .0205(b)(6)(C).
14. The Commission's rules generally prohibit development in the Coastal Wetlands
AEC, but allow development for water dependent uses per 7H .0208(a)(1). The Commission's
rule 7H .0208(b)(6)(A) requires piers located in AECs other than Coastal Wetlands to be six feet
wide, but allows greater width " if the greater width is necessary for safe use, to improve public
access, or to support a water dependent use that cannot otherwise occur." However, for the
Coastal Wetlands AEC, the Commission's rule at 7H .0208(b)(6)(C) limits the pier width to six
feet wide without exception. Given these rules, DCM permitted that portion of the access dock
4

located over the 404 wetlands and open water to be eight feet wide, but limited the width of that
portion of the pier located over coastal wetlands to six feet as required by 7H .0208(b)(6)(C).
15. On October 2, 2015, DCM received Petitioner's variance petition seeking a
variance from Condition No. 6 on the Permit in order to construct an 8 foot wide pier over the
approximately 240 foot long middle section of the access dock located over the coastal wetlands.
16. The access dock currently permitted by DCM will shade approximately 1,440
square feet of coastal wetlands. If the variance is granted, the addition of two feet in width would
shade approximately 480 additional square feet for a total of approximately 1,920 square feet
shaded Coastal Wetlands AEC.
17. As part of its petition, Petitioner stipulated that constructing a pier eight feet wide
over the coastal wetlands would not be consistent with 15A NCAC 7H .1205(d).
18. Aerial and ground -level photographs of the Site were provided to the Commission
in DCM's PowerPoint presentation. (Stipulated Exhibit 7)
STIPULATED EXHIBITS
Included with the Petition and the Staff Recommendation for the Commission's review
were the following Stipulated Exhibits:
1. TJ's Land Clearing, LLC Secretary of State filing;
2. Deed recorded at Book 1809, Page 753 of the Beaufort County Registry;
3. CAMA Major Permit application including the site plan;
4. Notice to Adjacent Riparian Owners;
5. DCM Field Investigation Report;
6. CAMA Major Permit No. 79-15, issued August 4, 2015;
7. Powerpoint Presentation with -aerial and ground -level photos of the Site, including
google earth images from Petitioner.
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CONCLUSIONS OF LAW
1. The Commission has jurisdiction over the parties and the subject matter.
2. All notices for the proceeding were adequate and proper.
3. Petitioner has met the requirements in N.C.G.S. § 113A-120.1(a) and 15 NCAC
07J .0703(f) which must be found before a variance can be granted as set forth below.
A. • Strict application of the Commission's Rule limiting the width of the access
dock will cause unnecessary hardships.
The Commission affirmatively finds that strict application of Rule 15A NCAC 7H
.0208(b)(6)(c) would cause Petitioner unnecessary hardship. Without the variance, the width of
the access dock would be limited to six feet. Given the length of the proposed access dock and
the extent of the marina traffic association with the proposed 66-slip facility, limiting the width
of the dock would cause Petitioner unnecessary hardship and make it difficult to provide safe
passageway to the marina. In addition, given Petitioner's voluntary elevation of the access dock
to five feet above the coastal wetlands substrate, even though only a three foot elevation is
required by rule, the impacts of the proposed design will be limited. For these reasons, the
Commission affirmatively finds that Petitioner has met the first factor without which a variance
cannot be granted.
b. Petitioner has demonstrated that the hardship results from conditions
peculiar to the property.
The 46.5 acre Site has approximately 854 linear feet of coastal wetlands shoreline along
Pungo Creek. In its Recommendation, DCM agrees that there was no other location on the Site to
locate the access dock which would reduce the impact on the coastal wetlands. Additionally, the
depth of the marsh and coastal wetlands extending landward from Pungo Creek requires a long
2

access pier of approximately 630 linear feet.to reach open water of sufficient depth to
accommodate the marina. The access dock progresses from high ground over wooded 404
wetlands and coastal wetlands to the open water. Approximately 240 linear feet of the access
dock is located over the coastal wetlands. Petitioner argues that the hardship is caused by
conditions peculiar to the property such as the size of the property, the depth of the coastal
wetlands, and the length of the pier required to bridge the coastal wetlands.
Moreover, Petitioner argues that given the size of the property, it could be subdivided and
applications submitted for additional access docks over the coastal wetlands. Petitioner
represents that by requesting permission to build just one eight -foot wide dock over the coastal
wetlands instead of two six-foot wide access docks, the impact to the coastal wetlands will be
minimized.
For the reasons set forth above, the Commission affirmatively finds that Petitioner has
demonstrated that the hardship results from conditions peculiar to the property. Therefore,
Petitioner has met the second factor required to grant its request for a variance.
C. Petitioner has demonstrated that the hardship does not result from actions
taken by Petitioner.
The Commission affirmatively finds that Petitioner has demonstrated that the hardship
does not result from actions taken by the Petitioner. Specifically, the shoreline at this Site are
covered with coastal wetlands and there is no other location on the Site which could be used for
the access dock that would significantly reduce the impact to the coastal wetlands. In addition,
Petitioner has voluntarily proposed elevating the decking by two feet more than the minimum
height required by the rules. The increased height of the access dock will reduce the impact of
shading on the coastal wetlands.
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For these reasons, the Commission affirmatively finds that Petitioner has taken steps to
reduce the hardship while exercising its riparian rights. In this way, Petitioner has demonstrated
that the hardships do not result from its action. Accordingly, Petitioner has met the third factor
required for a variance.
d. Petitioner has demonstrated that the requested variance is consistent with
the spirit, purpose and intent of the Commission's rules, will secure public
safety and welfare, and will preserve substantial justice.
The Petitioner has demonstrated that the requested variance (a) is consistent with the
spirit, purpose and intent of the Commission's rules, (b) will secure public safety and welfare,
and (c) will preserve substantial justice. The principal purpose of the Rule limiting the width of
piers located in coastal wetlands AECs is to minimize impacts to the coastal wetlands. 15A
NCAC 7H .0208(b)(6)(c). However, the proposed expansion of this access dock would have
minimal impacts to the coastal wetlands. As designed the eight foot wide dock would add shade
approximately 480 additional square feet of coastal wetlands (based on an additional two feet in
width for 240 linear feet over the coastal wetlands). Additionally, the design for the proposed
development will elevate the access dock by two feet and in this way reduce shading impacts.
For these reasons, the Commission affirmatively finds that Petitioner's proposed pier design is
consistent with the spirit, purpose, and intent of the Commission's rule limiting the width of
piers over coastal wetlands.
The second assessment to be made is whether the variance proposed by the Petitioner will
impact public safety and welfare. Petitioner argues and the Commission agrees that increasing
the width of the access pier from six feet to eight feet will improve the safety and welfare of
persons using the marina by making it easier for people and carts to pass on the long narrow
8

access dock. In addition, the increased width will secure public safety and welfare by allowing
the safe passage of golf carts in urgent/emergency situations, with limited impacts on the
important Coastal Wetlands resources. For these reasons, the Commission agrees that the
proposed development, if granted a variance, will have no adverse effect on public safety and
welfare.
Finally, the Commission agrees that a variance will preserve substantial justice by
allowing Petitioner to reasonable exercise his riparian rights to develop the water -dependent
marina while reducing impacts to the coastal wetlands on the Site.
For all the reasons set forth above, the Commission affirmatively finds that Petitioner has
met the fourth factor required by N.C.G.S. § 113A-120.1(a).
ORDER
THEREFORE, the requested variance from 15A NCAC 7H.0208(b)(6)(c) is GRANTED.
The granting of this variance does not relieve Petitioner of the responsibility for obtaining any
required permits from the proper permitting authority. This variance is based upon the Stipulated
Facts and Stipulated Exhibits. The Commission reserves the right to reconsider the granting of
this variance if there is a material change to any of the stipulated facts.
This the 101h day of December 2015.
Frank D. Gorham, III, Chairman
Coastal Resources Commission
0

CERTIFICATE OF SERVICE
This is to certify that I have this day served the foregoing FINAL AGENCY DECISION
upon the parties by the methods indicated below:
Tobin J. Tetterton, Registered Agent
TJ's Land Development, LLC
P.O. Box 125
Pantego, NC 27860
Franz F. Holscher, Esq.
Rodman, Holscher, Peck & Edwards
P.O. Box 1747
Washington, NC 27889
Christine A. Goebel, Esq.
Assistant Attorncy General
N.C. Department of Justice
Braxton C. Davis
Angela Willis
Division of Coastal Management
400 Commerce Avenue
Morehead City, NC 28557
Certifred Mail/Return Receipt Requested
and electronically:[e-mail]
U.S. Mail
Electronically at
[e-mail]
This the l Oh day of December, 2015
Electronically at
[e-mail] and
[e-mail]
Speci a,p6ty Attorney General and Commission Counsel
N.C. epartment of Justice
P.O. Box 629
Raleigh, N. C. 27602
10