United States v. Hartmann Studios, Inc.

UNITED STATES DEPARTMENT OF JUSTICE EXECUTIVE OFFICE FOR IMMIGRATION REVIEW OFFICE OF THE CHIEF ADMINISTRATIVE HEARING OFFICER UNITED STATES OF AMERICA, Complainant, v. HARTMANN STUDIOS, INC., Respondent. July 8, 2015 8 U.S.C. § 1324a Proceeding OCAHO Case No. 14A00008 FINAL DECISION AND ORDER Appearances: For the complainant: Sherry Nohara For the respondent: Steven Bovarnick and John Lofton I. PROCEDURAL HISTORY This is an action pursuant to the employer sanctions provisions of the Immigration and Nationality Act (INA), as amended by the Immigration Reform and Control Act of 1986 (IRCA), 8 U.S.C. § 1324a (2012). The United States Department of Homeland Security, Immigration and Customs Enforcement (ICE or the government) filed a complaint alleging that Hartmann Studios, Inc. (Hartmann or the company) engaged in 818 violations of 8 U.S.C. § 1324a(a)(1)(B). ICE subsequently amended its complaint by categorizing the violations into five counts and by providing a more specific statement of the factual basis for the violations in each count.

Count I alleged that Hartmann failed to prepare and/or present Forms I-9 for Terrence Anderson, Roberto Barrera, Guillermo Gomez, and Ricardo Mendoza. Count II alleged that Hartmann failed to timely prepare and/or present I-9s for Grace E. Abad, Carlos E. Alba, Refugio Alba, Kenneth Bradford, Juan Ramon Cruz Miranda, Manuel T. Maldonado, Jose Javier Ponce Published 7/15/1511 OCAHO no. 12551 Castillo, and Greg Sullivan. Count III alleged that the company failed to ensure that Salvador Cruz, Veronica Huerta, Gerardo Mata, Richard E. Olson, Melchor Parra, and Jorge Milton Rivera Luna properly completed section 1 of Form I-9. Count IV alleged that Hartmann failed to properly complete section 2 of the I-9 forms for 797 named individuals.

Count V alleged that the company failed to properly complete section 3 of the I-9 forms for Zonia Mirna Carillo, Carlos Orlando Suazo Zepeda, and Maria Silvia Urbina. ICE seeks penalties totaling $812,665.25. Hartmann filed an amended answer denying the material allegations and asserting thirteen affirmative defenses, including, inter alia, estoppel and limitations. Prehearing procedures were undertaken, in the course of which discovery disputes ensued.

Hartmann produced one-page, unaudited statements of income and balance sheets for 2011, 2012, 2013, and part of 2014, but explicitly stated in a letter to ICE dated November 6, 2014, that it “has not put ability to pay a fine as . . . [an] issue in the case.” ICE sought to discover the underlying financial documents on which the financial reports were ostensibly based, and ultimately filed a motion to compel discovery. On February 20, 2015, I issued an order compelling Hartmann to produce, inter alia, the financial documents requested by ICE, but only if it intended to raise an issue respecting the company’s ability to pay the proposed penalty. The order explicitly stated that the issue of ability to pay would be waived if the documents were not produced. They were not produced, and the issue is waived.

The order compelling discovery also directed Hartmann to respond to an interrogatory by providing a list of any individuals as to whom the company contends that the allegations are barred by limitations, together with the termination dates for those employees, or in the alternative, to state affirmatively that all such information has been provided. The order compelling discovery warned the company that its limitations defense would be deemed waived as to any individual for whom the information was not provided. Hartmann failed to produce the information and did not raise this defense in its response to ICE’s motion for summary decision. The limitations defense is also deemed waived.

Presently pending is the government’s motion for summary decision. In its response to ICE’s motion, the company proffered various exhibits related to its ability to pay, and also argued that the government should be estopped from fining the company. ICE filed a motion for leave to reply to Hartmann’s response, together with its proposed reply. Hartmann filed a response to the government’s motion in opposition to the reply, along with a surreply accompanied by the declaration of Steven H. Bovarnik and exhibits A, B, and C. The reply and surreply are accepted for the limited purpose of considering Hartmann’s defense of estoppel; they are not considered with respect to the waived issue of ability to pay.

II.

BACKGROUND INFORMATION

Hartmann Studios, Inc., incorporated in 1985, is an event design and production company, with its main office in Richmond, California, and a smaller office in Atlanta, Georgia. Hartmann Published 7/15/1511 OCAHO no. 12552 produces a variety of events including weddings, charitable fundraisers, corporate exhibitions, trade shows, and civic events like the parades in San Francisco following victories by the Giants in the World Series. The company operates in the United States, Asia, and Europe, and characterizes itself as having “a stellar reputation as a premier event design and production company.” In 2011, the year of the audit, Hartmann had gross revenues of about seventy-three million dollars. Matthew James Guelfi is the company’s vice president, and Steve Tanaka is its controller.

In approximately 1994, legacy Immigration and Naturalization Service conducted an audit of Hartmann’s I-9s. The company was not fined, but did terminate some employees who could not provide updated documentation. On February 17, 2011, ICE served Hartmann with a Notice of Inspection and agreed the next day to postpone the inspection until March 4, 2011, at which time Hartmann gave ICE an employee list, I-9 forms, payroll records, Articles of Incorporation, and other documents. At the time of this inspection, Hartmann employed 718 individuals.

ICE served Hartmann with both a Notice of Suspect Documents and a Notice of Technical or Procedural Failures on October 12, 2011. ICE issued Hartmann a Notice of Intent to Fine (NIF) on May 14, 2013, and Hartmann requested a hearing on June 12, 2013. ICE filed its complaint on November 20, 2013, and all conditions precedent to the institution of this proceeding have been satisfied. Four hundred of the employees whose I-9s Hartmann is responsible for preparing are members of International Alliance of Theatrical Stage Employees Union Local 16 (Local 16).

Since September 2008, Hartmann and Local 16 have been parties to a Collective Bargaining Agreement (CBA) pursuant to which Local 16 supplies Hartmann with skilled stage technicians. Hartmann hires these union members on a project-by-project basis, and classifies them as “on- call workers.” Hartmann pays them in accordance with its regular pay periods, and the technicians are not terminated upon completion of a project, but remain “on-call.” These Local 16 workers are also available to work for any other employer with whom Local 16 has a CBA when the individual completes what the parties refer to as a “three-in-one” form. The three-in- one form is a one-page document developed by Local 16 that combines a portion of a W-4 form, parts of sections 1 and 2 of an I-9 form, and a “check-off authorization” that permits 3.5% of the employee’s wages to be deducted and paid to Local 16 for the individual’s union dues. The four hundred Local 16 workers, 399 of whom are named in the complaint,1 each presented a three-in- one form to Rayna Peters, staff accountant for Hartmann.

No separate I-9 was completed for any of them.

III.

STANDARDS APPLIED 1 ICE says the complaint contains the names of 400 employees who presented three-in-one forms, but Count IV of the complaint actually contains the names of only 399 employees who did so. The name Bryan Hornbeck appears in the list of employees who presented three-in-one forms (Exhibit H with ICE auditor Gary Fong’s affidavit), but the name Bryan Hornbeck does not appear anywhere in the complaint, and no findings are made with respect to his I-9 or lack of it. Published 7/15/1511 OCAHO no. 12553 A. Summary Decision A motion for summary decision is granted under OCAHO regulations if a party demonstrates that there is no genuine issue of material fact and that the party is entitled to summary decision as a matter of law. 28 C.F.R. § 68.38(c) (2014).

This rule is similar to and based upon Rule 56 of the Federal Rules of Civil Procedure, which permits the entry of summary judgment in federal cases. Accordingly, OCAHO jurisprudence looks to federal case law interpreting that rule for guidance in determining when summary decision is appropriate. See United States v. Candlelight Inn, 4 OCAHO no. 611, 212, 222 (1994).2 The party seeking summary decision bears the initial burden of showing the absence of a material factual dispute. See Celotex, Corp. v. Catrett, 477 U.S. 317, 323 (1986); United States v. Primera Enters., Inc., 4 OCAHO no. 615, 259, 261 (1994).

Once the moving party satisfies its burden, the burden shifts to the nonmoving party to come forward with evidence that a genuine issue of material fact does exist. See Primera Enters., 4 OCAHO no. 615 at 261 (citing Fed. R. Civ. P. 56(e . An issue of material fact is genuine only if it has a real basis in the record. See Cormia v. Home Care Giver Servs., Inc., 10 OCAHO no. 1160, 5 (2012) (citing Matsushita Elec.

Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586-87 (1986 . All facts must be viewed in favor of the nonmoving party. See Primera Enters., 4 OCAHO no. 615 at 261.

B. Proper Completion of Form I-9 The INA imposes an affirmative duty upon employers to prepare and retain certain forms for employees hired after November 6, 1986 and to make those forms available for inspection on at least three business days’ notice. 8 C.F.R. § 274a.2(b)(2)(ii) (2015). Regulations designate the I- 9 form as the Employment Eligibility Verification Form to be used by employers. 8 C.F.R. § 274a.2(a)(2).

An employer must ensure that a new employee completes section 1 of the I-9 form on the individual’s date of hire, 8 C.F.R. § 274a.2(b)(1)(i)(A), and the individual must sign section 1 to attest under penalty of perjury that he or she is a U.S. citizen, lawful permanent resident, or alien authorized to work in the United States, 8 U.S.C. § 1324a(b)(2). The employer must then 2 Citations to OCAHO precedents reprinted in bound Volumes 1 through 8 reflect the volume number and the case number of the particular decision, followed by the specific page in that volume where the decision begins; the pinpoint citations which follow are thus to the pages, seriatim, of the specific entire volume. Pinpoint citations to OCAHO precedents subsequent to Volume 8, where the decision has not yet been reprinted in a bound volume, are to pages within the original issuances; the beginning page number of an unbound case will always be 1, and is accordingly omitted from the citation. Published decisions may be accessed in the Westlaw database “FIM-OCAHO,” or in the LexisNexis database “OCAHO,” or on the website at http://www.justice.gov/eoir/OcahoMain/ocahosibpage.htm#PubDecOrders.

Published 7/15/1511 OCAHO no. 12554 complete section 2 of the form within three business days of the hire, 8 C.F.R. § 274a.2(b)(1)(ii)(B), and sign section 2 to attest under penalty of perjury that it reviewed the appropriate documents to verify the individual's identity and employment authorization, 8 C.F.R. § 274a.2(a)(3), (b)(1)(ii). Acceptable documents include either a List A document, or both a List B and a List C document for each employee. 8 C.F.R. § 274a.2(b)(1)(v). List A documents establish both identity and employment eligibility, 8 C.F.R. § 274a.2(b)(1)(v)(A); List B documents establish identity only, 8 C.F.R. § 274a.2(b)(1)(v)(B); and List C documents establish only employment authorization, 8 C.F.R. § 274a.2(b)(1)(v)(C).

IV.

LIABILITY A.

The Government’s Motion Count I ICE says that the names Terrence Anderson, Roberto Barrera, Guillermo Gomez, and Ricardo Mendoza appear on Hartmann’s employee list, but the company never produced I-9s for them. The government points out that Hartmann admitted that it couldn’t locate I-9s for these individuals and couldn’t prepare new I-9s for them as requested because the individuals had been terminated. Count II ICE alleges that Hartmann failed to timely present I-9s for Grace E. Abad, Carlos E. Alba, Refugio Alba, Kenneth Bradford, Juan Ramon Cruz Miranda, Manuel T. Maldonado, Jose Javier Ponce Castillo, and Greg Sullivan. The government says that their names appear on Hartmann’s employee list, but their I-9s were not promptly presented upon the government’s request for them.

ICE points out that Hartmann admits that at the time of the inspection, the company could not locate the original I-9s for these eight individuals. Count III ICE says Hartmann failed to ensure that Salvador Cruz, Richard Olson, and Jorge Milton Rivera Luna each checked a box in section 1 of their I-9 forms to indicate their immigration status. ICE also says the company failed to ensure that Salvador Cruz and Veronica Huerta signed section 1 of their respective I-9s. The government also says that Gerardo Mata and Melchor Parra checked boxes attesting respectively to status as a lawful permanent resident and an alien authorized to work until a date certain, but Hartmann failed to ensure that they entered their alien numbers on the form.

Count IV Published 7/15/1511 OCAHO no. 12555 ICE says that visual inspection of 7883 of the forms for individuals named in Count IV, 4004 of which consist of three-in-one forms, reflects that Hartmann failed to sign section 2 of all the forms. See Appendix, Count IV. ICE says the company takes issue with the allegation that it actually hired the unionized workers who had three-in-one forms instead of I-9s, but Hartmann did hire the workers according to 8 C.F.R. § 274a.1(c), which defines hire as “the actual commencement of employment of an employee for wages or other remuneration.” ICE points out, moreover, that these workers appear on Hartmann’s employee list with their respective hire dates, and Hartmann’s 2010 payroll records reflect that all but ten of them earned wages between February 17, 2010 and December 31, 2010. One individual not on the 2010 payroll, Michael Barnard, was hired in January 2011, which explains why his name does not appear on the 2010 payroll records.

ICE agreed to withdraw the allegations respecting the other nine in the interest of streamlining the litigation and avoiding inquiry into their possible termination dates. ICE accordingly withdrew its allegations involving Per Bjornstad, Edward Church, Dwight McBride, Brian Thomas Meek, Greg Shine, Alva Thompson, David Vernali, Arthur Bassard, and Gary Dwayne Moorman, and reduced the proposed penalty by $8835.75. ICE also acknowledged that it listed the name of Omar Mota Perez twice in Count IV, and should have listed him only once. ICE says further that the I-9s of Margarita Arroyo, Jose J. Martinez, Mario Martinez, Zalvador Munoz, and Jose Guadalupe Ortiz are missing List A or B documents in section 2, and that Derek James Maddox’s I-9 is missing List A or C documents.

Felipe de Jesus Leon Magana’s I- 9 is missing a document number under List A, and Juan C. Ramirez’s I-9 is missing the expiration date for his driver’s license. ICE says that copying employees’ documents rather than fully completing their I-9s does not constitute substantial compliance with the employment verification requirements, and that Steve Tanaka’s and Matthew James Guelfi’s belief that the company did not need to sign the section 2 attestation cannot not absolve the company from liability for the violations in Count IV. Count V ICE says that Hartmann failed to complete section 3 of the I-9s for Zonia Mirna Carillo, Carlos Orlando Suazo Zepeda, and Maria Silvia Urbina after their respective employment authorization documents expired. The government’s motion was accompanied by the following exhibits: G-1) Gary Wong’s affidavit with accompanying exhibits: A) Notice of Inspection (4 pp.); B) email from Steve Tanaka; C) Hartmann’s employee list (16 pp.); D) emails between Steve Tanaka and Gary Fong (2 pp.); E) email between Steve Tanaka and Gary Fong (2 pp.); F) email between Steve Tanaka 3 The Notice of Intent to Fine attached to and incorporated into ICE’s amended complaint alleges that Hartmann failed to sign section 2 of 789 forms.

4 But there were only 399 of these individuals that were actually named in the complaint. Published 7/15/1511 OCAHO no. 12556 and Gary Fong (3 pp.); G) Notice of Suspect Documents (7 pp.); H) Notice of Technical or Procedural Failures and list of 400 employees with three-in-one form (10 pp.); I) I-9s that Hartmann sent in response to NTPF (436 pp.); J) email from Gary Fong to Steve Tanaka; K) email between Steve Tanaka and Gary Fong (3 pp.); L) ICE’s worksite enforcement guide (47 pp.); M) ICE’s Memorandum to Case File (33 pp.); N) I-9s for Count II (8 pp.); O) I-9s for Count III (6 pp.); P) I-9s for Count IV (803 pp.); Q) additional I-9s for Count IV (9 pp.); R) I-9s for Count V (3 pp.); and S) Notice of Intent to Fine (2 pp.); G-2) Respondent’s Responses to Complainant’s First Set of Requests for Admission (168 pp.); G-3) deposition of Matthew James Guelfi (27 pp.); G-4) deposition of Steve Tanaka (33 pp.); G-5) deposition of Rayna Ruth Peters (41 pp.); G-6) deposition of Gary Fong (12 pp.); G-7) Interim Guidelines: Section 274A(b)(6) of the Immigration & Nationality Act Memorandum (11 pp.); and G-8) Respondent’s Responses to Complainant’s First Set of Interrogatories and Request to Produce (12 pp.). B. Hartmann’s Response Count I Hartmann admits to the violations alleged in Count I. Although it denies that it failed to prepare I-9s for the four individuals, it does admit that it could not locate the forms and that it failed to present them to ICE. Count II Hartmann’s answer denied the allegations in Count II.

The company says it provided the eight I- 9s to ICE on April 25, 2011, but it does not elaborate on this assertion or address it in response to ICE’s motion for summary decision. The company does not contend that it presented these I-9s upon at least three business days’ notice in response to the NOI, as directed by 8 C.F.R. § 274a.2(b)(2)(ii). Count III Apart from the assertion in the answer that the allegations as to five employees named in Count III were barred by limitations, Hartmann did not address the allegations in this count. Count IV Hartmann does not deny that it was the employer of 400 members of Local 16.

In fact, it points out that its collective bargaining agreement with Local 16 states, “Whereas the Employer has the need to hire skilled technicians, and whereas Local 16 can supply such skilled technicians to the Employer, the Employer agrees to the wages and conditions hereinafter specified in this CBA” (emphasis added). Hartmann also does not deny that the three-in-one forms for the 399 Local 16 union workers that are named in the complaint all lacked a signature in section 2. The company instead emphasizes that it believed that the three-in-one forms were sufficient to confirm that the Published 7/15/1511 OCAHO no. 12557 Local 16 workers had proper employment authorization and that nothing further needed to be done to confirm their eligibility for employment. Hartmann admits that its belief was mistaken, and does not argue that use of the three-in-one form should shield it from liability, but says instead that its belief should be considered in assessing the penalty.

As to the remaining allegations in Count IV, Hartmann does not deny that it also failed to sign section 2 of the I-9 forms the company filled out itself. Steve Tanaka stated in his deposition that he previously did not view signing section 2 as one of an employer’s key responsibilities in complying with the employment verification requirements. Hartmann does not address the remaining allegations in this count. Count V Hartmann’s answer denied the allegations in Count V as being vague, ambiguous, and unclear, and said it could not provide a proper response, but the company did not specifically address these allegations in its response to ICE’s motion.

Hartmann’s response was accompanied by the following attachments: R-1) affidavit of Matthew James Guelfi (20 pp.), and attached exhibits A-LL (135 pp.); R-2) deposition of Matthew James Guelfi (32 pp.); R-3) deposition of Steve Tanaka (27 pp.); and R-4) deposition of Rayna Ruth Peters (15 pp.); R-5) deposition of Gary Fong (71 pp.); and R-6) Complainant’s Responses to Respondent’s Request for Admission (19 pp.). C. Discussion and Analysis Count I Hartmann’s employee list reflects that Terrence Anderson was hired on August 1, 2008 and terminated on March 26, 2010; Roberto Barrera was hired on August 11, 2009 and terminated on October 15, 2010; Guillermo Gomez was hired on March 18, 2008 and no termination date appears; and Ricardo Mendoza was hired on October 8, 2009 and terminated on January 21, 2011. An employer is obligated to retain an I-9 form for a former employee for a period of three years after the individual's hire date or one year after the termination date, whichever is later. 8 U.S.C. § 1324a(b)(3)(B); 8 C.F.R. § 274a.2(b)(2)(i)(A).

All the employees named in Count I are within the retention period and Hartmann admits it did not present I-9 forms for them. ICE accordingly met its burden of demonstrating that there is no genuine issue of material fact and that it is entitled to summary decision as to Count I. Count II Hartmann did not timely present I-9 forms for the employees named in Count II upon request by the government and does not contend that it did. ICE set the inspection date for March 4, 2011, but Hartmann says it presented the forms on April 25, 2011. Examination of the I-9 forms for these individuals reveals that most were not prepared until after the NOI was issued.

ICE is Published 7/15/1511 OCAHO no. 12558 entitled to summary decision as to Count II. Count III Visual inspection of the I-9 forms reflects that the violations alleged in Count III are facially apparent. Employers must ensure that employees check a box in section 1 attesting to status as a U.S. citizen, lawful permanent resident, or alien authorized to work in the United States. 8 U.S.C. § 1324a(b)(2); United States v. Ketchikan Drywall Servs., Inc., 10 OCAHO no. 1139, 6, 15 (2011).

The I-9s of Salvador Cruz, Richard Olson, and Jorge Milton Luna Rivera reflect that each failed to check a box in section 1 attesting to status as either a U.S. citizen, lawful permanent resident, or alien authorized to work. It is also facially apparent that Veronica Huerta and Salvador Cruz did not sign section 1 of their respective I-9s. Hartmann will, however, be held liable for only one violation on Salvador Cruz’s I-9: failure to ensure that he checked a status box in section 1. Failure to ensure that an employee enters an alien number after selecting status as a lawful permanent resident or alien authorized to work is also a substantive violation.

See Horno MSJ, 11 OCAHO no. 1247 at 8 (citing Ketchikan, 10 OCAHO no. 1139 at 6); see generally Paul W. Virtue, Interim Guidelines: Section 274A(b)(6) of the Immigration & Nationality Act Added by Section 411 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (Mar. 6, 1997), available at 74 Interpreter Releases 706 (Apr. 28, 1997) (hereinafter Virtue Memo). Gerardo Mata’s I-9 reflects that he failed to enter an alien number after checking the box in section 1 indicating status as lawful permanent resident.

His alien number does not appear in section 2 of the form, and no copy of his permanent resident card was attached to his I-9. Similarly, Melchor Parra’s I-9 reflects that this individual failed to enter an alien number after checking the box in section 1 indicating status as an alien authorized to work until a date certain. ICE is therefore entitled to summary decision as to Count III. Count IV Hartmann hired at least 3905 members of Local 16 who had three-in-one forms, and the section of that form that resembles section 2 of Form I-9 reflects no employer signature.

Visual inspection confirms that Hartmann did not sign section 2 of these 390 three-in-one forms. See Appendix A, Count IV. Visual inspection of the forms for the other individuals named in Count IV reflects that Hartmann also failed to sign section 2 of the I-9s for 3896 of them. Id. An 5 Excluding Per Bjornstad, Edward Church, Dwight McBride, Brian Thomas Meek, Greg Shine, Alva Thompson, David Vernali, Arthur Bassard, and Gary Dwayne Moorman, all of whom also had three-in-one forms, but as to whom the allegations were withdrawn.

6 ICE withdrew one violation related to Omar Mota Perez because his name was listed twice in Count IV. He did not have a three-in-one form. Published 7/15/1511 OCAHO no. 12559 employer is required to sign section 2 to attest under penalty of perjury that it reviewed the appropriate documents to verify the individual's identity and employment authorization. 8 C.F.R. § 274a.2(a)(3), (b)(1)(ii).

Failure to comply with this requirement is a substantive violation. Although ICE characterizes the three-in-one forms as “modified I-9s,” these forms are not an adequate substitute for filling out an actual I-9 as regulations require. 8 C.F.R. § 274a.2(a)(2). ICE did not charge these violations as failure to prepare I-9s, however, and chose instead the slightly less serious violation of failure to sign section 2.

Because the government withdrew nine Count IV allegations and acknowledged that the name Oscar Perez Mota was inadvertantly listed twice, ICE is entitled to summary decision that Hartmann failed to sign 779 I-9s. Employers are required to review either a List A document, or both a List B and a List C document for each employee. 8 C.F.R. § 274a.2(b)(1)(v). ICE’s allegation that the I-9s for Jose J. Martinez, Mario Martinez, Zalvador Munoz, and Jose Guadalupe Ortiz contain only a List C document and are missing either a List A or B document is factually inaccurate, but visual inspection of these employees’ I-9 forms, along with the form for James Derek, reflects that these forms show only a List B document and are missing either a List A or C document in section 2.

Visual inspection also reflects that a “military ID” appears under List C on Margarita Arroyo’s I- 9, but a military ID does not establish work authorization for civilian employment.7 Arroyo’s I-9 reflects neither a List A nor a List B document. See Appendix, Count IV. Hartmann will be held liable for only one violation on her I-9. Felipe de Jesus Leon Magana’s I-9 reflects that Hartmann entered a lawful permanent resident card under List A but did not include a document identification number.

This is a substantive violation. See Virtue Memo (no document identification number in section 2 is a substantive violation where no legible copy of the document is presented with the I-9). Juan C. Ramirez’s I- 9 reflects that a driver’s license is entered, but no expiration date is entered. This is also a substantive violation.

Ketchikan, 10 OCAHO no. 1139 at 6. ICE is entitled to summary decision with respect to liability for 787 of the 797 violations originally charged in Count IV. Count V If an individual’s employment authorization expires, the employer is required to reverify the individual’s work authorization by completing section 3 of Form I-9, and must do so no later than the date of expiration. 8 C.F.R. § 274a.2(b)(1)(vii); cf. United States v. Split Rail Fence Co., 11 OCAHO 1216a, 7-8 (2015).

The employer must require the employee to present evidence of new or continuing authorization prior to the expiration of the employment authorization document. Id. Presentation of a permanent resident card, a Social Security card, or any other acceptable List A or List C document could satisfy this requirement. See United States 7 A military ID is acceptable to show both identity and employment authorization only if the employer is the Armed Forces. 8 C.F.R. § 274a.2(a)(v)(A)(7).

Published 7/15/1511 OCAHO no. 125510 v. Split Rail Fence Co., 11 OCAHO no. 1216a, 8 (2015). Visual inspection of the I-9s for Zonia Mirna Carrillo, Carlos Orlando Suazo Zepeda, and Maria Silvia Urbina reflects that each checked a box in section 1 indicating that he or she was an alien authorized to work until a date certain, and that the employees’ respective Employment Authorization Documents (EADs) are entered under List A in section 2. Zonia Mirna Carrillo’s EAD expired on September 9, 2006; Suazo Zepeda’s EAD expired on July 5, 2000; and Maria Silvia Urbina’s EAD expired on September 9, 2002. Section 3 of each of these I-9s is blank, indicating that Hartmann never re-verified these employees’ documentation after their EADs expired.

ICE is entitled to summary decision as to Count V. V. PENALTY Civil money penalties are assessed for paperwork violations according to the parameters set forth at 8 C.F.R. § 274a.10(b)(2): the minimum penalty for each individual with respect to whom a violation occurred after September 29, 1999, is $110, and the maximum is $1100. The penalties in this case range from a low of $88,880 to a high of $888,880. Because the government has the burden of proof with respect to the penalty, United States v. March Construction, Inc., 10 OCAHO no. 1158, 4 (2012), ICE must prove the existence of any aggravating factor by a preponderance of the evidence, United States v. Carter, 7 OCAHO no. 931, 121, 159 (1997). In assessing an appropriate penalty, the following factors must be considered: 1) the size of the employer’s business, 2) the employer’s good faith, 3) the seriousness of the violations, 4) whether the individual was an unauthorized alien, and 5) the employer’s history of previous violations.

8 U.S.C. § 1324a(e)(5). The statute neither requires that equal weight be given to each factor, nor rules out consideration of additional factors. See United States v. Hernandez, 8 OCAHO no. 1043, 660, 664 (2000). While the government bears the burden of proof with respect to the statutory factors, a party seeking consideration of a nonstatutory factor, such as ability to pay the penalty, bears the burden of showing that the factor should be considered as a matter of equity and that the facts support a favorable exercise of discretion.

See United States v. Century Hotels Corp., 11 OCAHO no. 1218, 4 (2014) (citing United States v. M & D Masonry, Inc., 10 OCAHO no. 1211, 11 (2014 . A. The Government’s Position ICE set a baseline fine of $935 for each violation in accordance with internal guidance that sets this base when the employer has an error rate of more than fifty percent. The government says that ninety percent of the 912 I-9s for which Hartmann was responsible either were not presented at all, or contained substantive paperwork violations, and that certification was lacking on more than 700 forms. ICE’s Memorandum to Case File Determination of Civil Money Penalty characterized the company as medium-sized, but nevertheless treated the size of Hartmann’s business as a neutral factor.

It also treated good faith and the company’s lack of history of previous violations as neutral factors. The government enhanced the penalty by five percent based on the seriousness of Published 7/15/1511 OCAHO no. 125511 the violations and by an additional five percent for each of the 205 allegedly unauthorized workers in Hartmann’s workforce. ICE also points out that of the 259 employees listed in the Notice of Suspect Documents, only six were able to provide valid work documents. ICE says the seriousness of the violations is amplified by the testimony of Rayna Peters that she entered additional information in section 2 after the NOI, and that her supervisee, Brendo Velasquez, backdated the hire dates on the forms.

Even though Peters’ name appears on most of the forms, she was not necessarily the person who entered the information. Peters said in her deposition that she did not recall reviewing documents before signing 300-400 forms during the audit. ICE says further that Hartmann cannot establish good faith based on this record, and that the penalties proposed are not excessive. The government points out that although Hartmann enrolled in E-Verify, it waited until after being served with a NIF to do so.

The government says that Hartmann hired workers without examining their documents, which shows a disregard for ensuring that its employees have proper authorization documents. ICE anticipates that Hartmann will claim it detrimentally relied on its belief that it would not be fined. The government points out that Steve Tanaka testified that he doesn’t remember ICE auditor Gary Fong ever telling him that there would be no fine, and that Matthew Guelfi similarly testified that Fong never said that Hartmann would not be subject to a fine. The government says in addition that Fong himself testified that he never told Hartmann there would be no fine.

The government also points out that respondents are not entitled to a warning prior to the issuance of a NIF. ICE argues that Hartmann needs a significant penalty to be motivated to change its behavior. ICE says that after the government notified it that the three-in-one forms were unacceptable, Hartmann modified the three-in-one forms, but never ensured that such a form would fully comply with the law. Even though Guelfi said the union’s original three-in-one form was no longer being used by Local 16 or itself, he later testified that he had no idea if the union had in fact stopped using the three-in-one form.

ICE says, furthermore, that it found a three-in-one form for Christopher Shatterly that was dated in 2013, well after ICE notified the company that such a form was unacceptable. B. Hartmann’s Response Hartmann points out that the NIF was issued over two years after the inspection began and more than a year after the inspection was concluded. Hartmann says it was prejudiced by the undue delay in issuing the NIF, and that the company detrimentally relied on ICE’s “intimation” that the company would not be fined. Hartmann says it believed that it would not be fined if it took the remedial steps called for pursuant to the NSD and NTPF, and that in reliance on this belief it entered into a class action settlement pursuant to which it paid more than $2 million to settle wage and hour claims.

Hartmann points to an email from Steve Tanaka to ICE auditor Fong stating, “Hopefully we now have the documents in good order, but just let us know if anything more is needed.” Hartmann acknowledges, however, that Fong never told the company it would not be fined. Published 7/15/1511 OCAHO no. 125512 Hartmann says further that ICE’s baseline penalty is excessive as well as disproportionate to the violations, and that the government’s consideration of the statutory factors is too narrowly constrained. The company points out that the proposed penalty is 89% to 94% of the maximum permissible, and OCAHO cases say penalties at this level are reserved for the most egregious violations. The company says the aggravating factors in cases where ICE’s proposed penalties were left undisturbed involved intentional misconduct, falsifying I-9s, or having a workforce that was mostly unauthorized, factors that don’t apply to Hartmann.

Hartmann points out that the penalties are designed to deter future violations, not to punish employers, and that its remedial efforts are entitled to great weight. The company argues that the penalties should be substantially reduced because the company acted in good faith by 1) copying and retaining employees’ work authorization documents, 2) providing I-9s to ICE and cooperating with the inspection, 3) terminating the unauthorized workers, 4) ceasing use of the three-in-one form, 5) correcting the technical and procedural violations, and 6) hiring an HR manager and enrolling in E-Verify following the inspection. Hartmann also points out that even when the hiring was handled through warehouse and operations departments, the company completed I-9 forms and made photocopies of work authorization documents, which it then turned in to Hartmann’s payroll office to be put into individual employee files. As to the on-call workers supplied by Local 16, the company says it just followed the procedures established by the union.

Hartmann admits that the violations are serious, but says they are not all equally so, nor are they so egregious as to warrant so substantial a fine. C. Discussion and Analysis Although legacy INS did audit the company in or around 1994, it is undisputed that Hartmann has no history of previous violations. The parties are also in accord in their views that the penalty should not be aggravated based on the size of Hartmann’s business. While there were times when Hartmann had hundreds of workers, there were other times when it had substantially fewer.

The size of the workforce is thus difficult to assess because the workforce varied depending upon the number of events produced. The parties disagree, however, as to whether Hartmann made sufficient good faith efforts to warrant reduction of the penalties, how serious the violations were, whether the penalty is excessive, and whether Hartmann can make out an estoppel defense. The short answer to Hartmann’s claim of equitable estoppel is that the government is virtually impervious to such a claim. See United States v. Tom & Yu, Inc., 3 OCAHO no. 412, 163, 169 (1992).

It is well established that the government may not be estopped on the same terms as other litigants, and there must be at minimum some affirmative government misconduct, not just a delay or omission, upon which to premise an estoppel. See United States v. Greif, 10 OCAHO no. 1183, 5 (2013). The lead case in the Ninth Circuit, in which this case arises, sets out a two- prong threshold inquiry. See Watkins v. U.S. Army, 875 F.2d 699, 706-09 (9th Cir.

1989) (en banc). First, there must be affirmative misconduct going beyond mere negligence, delay, inaction, or failure to follow internal agency guidelines. Second, there must be a showing that Published 7/15/1511 OCAHO no. 125513 the misconduct will cause a serious injustice and that estoppel will not unduly burden the public interest. Neither of these threshold elements has even been articulated, let alone shown.

If an express oral misstatement cannot estop the United States, United States v. Corporate Loss Prevention Associates, 6 OCAHO no. 908, 967, 983-84 (1997) (modified by CAHO), an estoppel is a fortiori not created merely by silence or delay. As pointed out in United States v. Sunshine Building Maintenance, Inc., 7 OCAHO no. 997, 1122, 1168-69 (1998), moreover, the Supreme Court has left open the question of whether even affirmative misconduct would be sufficient to estop the government, citing Office of Personnel Management v. Richmond, 496 U.S. 414, 419- 23 (1990). There appears in addition to be no causal relationship between ICE’s delay in issuing the NIF and the resolution of the wage and hour case; Hartmann would still have had to resolve that claim in some fashion regardless of when the NIF issued. The fact that Hartmann not only violated the verification requirements, but also evidently violated wage and hour laws, is not in any event an equity warranting the reduction of a penalty.

The company points to its good faith conduct during and after the inspection, but OCAHO case law assessing good faith looks primarily to the steps an employer took before issuance of the NOI, not what it did afterward. See United States v. Durable, Inc., 11 OCAHO no. 1229, 14 (2014) (affirmed by CAHO) (assessing good faith by examining “what the steps, if any, the employer took prior to the NOI to ascertain what the law requires and to conform its conduct to it”). There is minimal evidence here that Hartmann made reasonable efforts before the NOI. Although the government did not claim that Hartmann acted in bad faith, it argued that the company could not establish good faith because its verification procedures were too defective, as evidenced in the testimony of Rayna Peters.

Even if Peters did actually examine non-union workers’ original identity and employment authorization documents, she did not fill out section 2 herself, and the date on section 2 may not be the date that the documents were actually reviewed. As to the Local 16 employees who had three-in-one forms, Peters checked only their names, birthdates, Social Security numbers, withholdings, and checkoff authorizations, but did not review their identity and work authorization documents. These employment verification procedures are sufficiently defective to foreclose a claim of either good faith or substantial compliance. Hartmann says its violations aren’t the most serious, such as failing to prepare an I-9 at all, see United States v. Reyes, 4 OCAHO no. 592, 1, 10 (1994).

But the company did fail to present I-9s for four individuals, and failure to sign the section 2 attestation, the vast majority of Hartmann’s violations, is also among the most serious of possible violations. See United States v. Emp’r Solutions Staffing Grp. II, LLC, 11 OCAHO no. 1242, 11 (2015) (describing section 2 as “the very heart” of the verification process). The following violations are serious as well: failure to ensure that an employee signs section 1; failure to ensure than an employee checks a box in section 1 attesting to status as a U.S. citizen, lawful permanent resident, or alien authorized to work; and failure to verify the proper identity and employment authorization documents in section 2.

Ketchikan, 10 OCAHO no. 1139 at 6. Failure to include an expiration date on a driver’s license, as well failure to ensure that an employee enters an A number in section 1 after selecting status as a lawful permanent resident or alien authorized to work, are also serious Published 7/15/1511 OCAHO no. 125514 violations. Id. Hartmann’s conduct is nevertheless not comparable to that of the employers in United States v. Symmetric Solutions, Inc., 10 OCAHO no. 1209, 8-9, 11 (2014), where the company paid workers in cash under the table, or that in Employer Solutions, 11 OCAHO no. 1242 at 8, where company representatives falsified attestations. Neither does Hartmann have a history of previous violations and a workforce more than ninety percent of which was unauthorized, like the employer in Durable, 11 OCAHO no. 1229 at 17.

Penalties as high as those proposed here are ordinarily reserved for the most egregious violations, United States v. Fowler Equip. Co., 10 OCAHO no. 1169, 6 (2013), and Hartmann’s violations are not of that order. VI. CONCLUSION ICE is entitled to summary decision as to liability for 808 violations.

OCAHO case law has emphasized that penalties should have a deterrent effect on an employer’s behavior and not merely be a cost of doing business. Emp’r Solutions, 11 OCAHO no. 1242 at 11 (“[A] penalty cannot be set so low that the employer can comfortably pay it simply as a cost of doing business; the prophylactic purpose of a penalty is best served when a penalty is sufficiently significant to motivate a change of behavior.”). The record reflects that, although Hartmann’s violations were not among the most egregious, the company does appear to need additional motivation to conform its employment verification processes to what the law requires. Based on the record as a whole and the statutory factors in particular, the penalty will be adjusted to be somewhat closer to the midrange.

The 799 violations in Counts I, II, and IV are assessed at a rate of $700 each for a total of $559,300, while the nine less serious violations in Counts III and V are assessed at $550 each for a total of $4950. Added to this is an additional $200 for each of the 205 unauthorized aliens, or $41,000. The penalties accordingly total $605,250.

VII.

FINDINGS OF FACT AND CONCLUSIONS OF LAW A.

Findings of Fact 1. Hartmann Studios, Inc., incorporated in 1985, is an event design and production company, with its main office in Richmond, California, and a smaller office in Atlanta, Georgia. 2. Matthew James Guelfi is Hartmann Studio, Inc.’s vice president, and Steve Tanaka is the controller.

3. When legacy Immigration and Naturalization Service conducted an audit of Hartmann’s I-9s in 1994, the company was not fined, but it terminated some employees who could not provide updated documentation. 4. The Department of Homeland Security, Immigration and Customs Enforcement served Published 7/15/1511 OCAHO no. 125515 Hartmann Studios, Inc. with a Notice of Inspection (NOI) on February 17, 2011, and agreed the next day to postpone the inspection until March 4, 2011.

5. The Department of Homeland Security, Immigration and Customs Enforcement served Hartmann Studios, Inc. with a Notice of Suspect Documents and a Notice of Technical or Procedural Failures on October 12, 2011. 6. The Department of Homeland Security, Immigration and Customs Enforcement served Hartmann Studios, Inc. with a Notice of Intent to Fine on May 14, 2013.

7. On June 12, 2013, Hartmann Studios, Inc. filed a request for hearing before the Office of the Chief Administrative Hearing Officer. 8. The Department of Homeland Security, Immigration and Customs Enforcement filed a complaint with this office on November 20, 2013.

9. Hartmann Studios, Inc., hired Terrence Anderson, Roberto Barrera, Guillermo Gomez, and Ricardo Mendoza, and failed to present I-9s for them upon request by the government. 10. Hartmann Studios, Inc. hired Grace E. Abad, Carlos E. Alba, Refugio Alba, Kenneth Bradford, Juan Ramon Cruz Miranda, Manuel T. Maldonado, Jose Javier Ponce Castillo, and Greg Sullivan, and failed to timely present I-9s for them.

11. Hartmann Studios, Inc. hired Salvador Cruz, Richard E. Olson, Jorge Milton Rivera Luna, and failed to ensure that they checked a box in section 1 attesting to status as a U.S. citizen, lawful permanent resident, or alien authorized to work. 12. Hartmann Studios, Inc. hired Veronica Huerta and failed to ensure that she signed section 1 of Form I-9.

13. Hartmann Studios, Inc. hired Gerardo Mata and failed to ensure that he entered his alien number in section 1 after checking the box in section 1 indicating status as lawful permanent resident; the alien number does not appear in section 2, and no copy of the permanent resident card was attached to the I-9. 14. Hartmann Studios, Inc. hired Melchor Parra and failed to ensure that he entered an alien number in section 1 after checking the box in section 1 indicating status as an alien authorized to work until a date certain; the alien number does not appear in section 2, and no copy of the employment authorization document was attached to the I-9.

15. Hartmann Studios, Inc. hired 779 individuals listed in Count IV, as reflected in the Appendix hereby incorporated by reference, and failed to sign section 2 of their I-9 forms. 16. Hartmann Studios, Inc. hired Jose M. Martinez, Mario Martinez, Zalvador Munoz, Jose Guadalupe Ortiz, and James Derek, and entered only a List B document in section 2 of their I-9 Published 7/15/1511 OCAHO no. 125516 forms.

17. Hartmann Studios, Inc. hired Margarita Arroyo and entered only a List C document in section 2 her Form I-9. 18. Hartmann Studios, Inc. hired Felipe de Jesus Leon Magana and entered a lawful permanent resident card under List A of his I-9, but failed to enter a document identification number.

19. Hartmann Studios, Inc. hired Juan C. Ramirez and entered a driver’s license in section 2 of his I-9, but did not enter an expiration date. 20. Hartmann Studios, Inc. hired Zonia Mirna Carrillo, Carlos Orlando Suazo Zepeda, and Maria Silvia Urbina, and failed to re-verify their employment eligibility by completing section 3 of their I-9 forms after their respective Employment Authorization Documents expired.

21. Since September 2008, Hartmann and International Alliance of Theatrical Stage Employees Union Local 16 (Local 16) have been parties to a Collective Bargaining Agreement (CBA) pursuant to which Local 16 supplies skilled stage technicians for hire by Hartmann. 22. International Alliance of Theatrical Stage Employees Union Local 16 (Local 16) workers are available to work for any employer with whom Local 16 has a Collective Bargaining Agreement when the individual completes a “three-in-one” form, which is a one-page document that combines a portion of a W-4 form, parts of sections 1 and 2 of Form I-9, and a “check-off authorization” that permits 3.5% of the employee’s wages to be deducted and paid to Local 16 for the individual’s union dues.

23. For employees who were not members of Local 16, Rayna Peters, staff accountant for Hartmann, received I-9 forms that were already filled out from Hartmann’s operations assistant or warehouse assistant manager. 24. Upon receipt of an I-9 for an employee who was not a member of Local 16, Rayna Peters confirmed that the document numbers on the employee’s I-9 matched the numbers on the documents the employee submitted.

25. Rayna Peters, staff accountant for Hartmann, did not review International Alliance of Theatrical Stage Employees Union Local 16 (Local 16) workers’ employment verification documents upon receipt of a “three-in-one” form. 26. When reviewing a “three-in-one” form, Rayna Peters, staff accountant for Hartmann, checked for the employees’ full name, birthdate, Social Security number, withholdings, and union checkoff authorization, but did not compare the employees’ identity and employment authorization documents to the numbers listed on the three-in-one forms.

B. Conclusions of Law Published 7/15/1511 OCAHO no. 125517 1.

Hartmann Studios, Inc. is an entity within the meaning of 8 U.S.C. § 1324a(a)(1) (2012). 2. All conditions precedent to the institution of this proceeding have been satisfied. 3.

Hartmann Studios, Inc. is liable for 808 violations of 8 U.S.C. § 1324a(a)(1)(B) (2012). 4. The INA imposes an affirmative duty upon employers to prepare and retain I-9 forms for employees hired after November 6, 1986 and to make those forms available for inspection on at least three business days’ notice. 8 C.F.R. § 274a.2(b)(2)(ii).

5. Employers are obligated to ensure that each employee checks a box in section 1 attesting to status as a U.S. citizen, lawful permanent resident, or alien authorized to work in the United States. 8 U.S.C. § 1324a(b)(2); see Ketchikan Drywall Servs., Inc., 10 OCAHO no. 1139, 6, 15 (2011). 6.

Failure to ensure that an employee enters an alien number after selecting status as a lawful permanent resident or alien authorized to work is a substantive violation. See United States v. Horno MSJ, Ltd., 11 OCAHO no. 1247, 8 (2015) (citing United States v. Ketchikan Drywall Servs., Inc., 10 OCAHO no. 1139, 6 (2011 ; see generally Paul W. Virtue, Interim Guidelines: Section 274A(b)(6) of the Immigration & Nationality Act Added by Section 411 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (Mar. 6, 1997), available at 74 Interpreter Releases 706 (Apr. 28, 1997).

7. An employer is required to sign section 2 to attest under penalty of perjury that it reviewed the appropriate documents to verify the individual's identity and employment authorization. 8 C.F.R. § 274a.2(a)(3), (b)(1)(ii). 8.

Employers are required to review either a List A document, or both a List B and a List C document for each new employee. 8 C.F.R. § 274a.2(b)(1)(v). 9. An employer’s failure to enter a document identification number associated with a List A, B, or C document in section 2 is a substantive violation.

See Paul W. Virtue, Interim Guidelines: Section 274A(b)(6) of the Immigration & Nationality Act Added by Section 411 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (Mar. 6, 1997), available at 74 Interpreter Releases 706 (Apr. 28, 1997). 10.

If an individual’s employment authorization expires, the employer is required to reverify the individual’s employment eligibility by completing section 3 of Form I-9, and must do so no later than the date the employment authorization expires. 8 C.F.R. 274a.2(b)(1)(vii); cf. United States v. Split Rail Fence Co., 11 OCAHO no. 1216a, 7-8 (2015). 11. In assessing the appropriate penalty, the following factors must be considered: 1) the size of the employer’s business, 2) the employer’s good faith, 3) the seriousness of the violation(s), 4) Published 7/15/1511 OCAHO no. 125518 whether or not the individuals involved were unauthorized aliens, and 5) any history of previous violations of the employer.

8 U.S.C. § 1324a(e)(5) (2012). 12. The statute neither requires that equal weight be given to each factor, nor does it rule out consideration of additional factors. See United States v. Hernandez, 8 OCAHO no. 1043, 660, 664 (2000).

13. While the government bears the burden of proof with respect to the statutory factors, a party seeking consideration of a nonstatutory factor, such as ability to pay the penalty, bears the burden of showing that the factor should be considered as a matter of equity and that the facts support a favorable exercise of discretion. See United States v. Century Hotels Corp., 11 OCAHO no. 1218, 4 (2014) (citing United States v. M & D Masonry, Inc., 10 OCAHO no. 1211, 11 (2014 . 14.

The government is virtually impervious to a claim of equitable estoppel. See United States v. Tom & Yu, Inc., 3 OCAHO no. 412, 163, 169 (1992). 15. In assessing good faith, case law looks primarily to an employer’s actions before the issuance of the NOI, not after.

See United States v. Durable, Inc., 11 OCAHO no. 1229, 14 (2014) (assessing good faith by examining “what the steps, if any, the employer took prior to the NOI to ascertain what the law requires and to conform its conduct to it”) (affirmed by CAHO). 16. Failing to prepare an I-9 at all is one of the most serious violations. See United States v. Reyes, 4 OCAHO no. 592, 1, 10 (1994).

17. An employer’s failure to sign section 2 of Form I-9 is a very serious violation. See United States v. Emp’r Solutions Staffing Grp. II, LLC, 11 OCAHO no. 1242, 11 (2015) (describing section 2 as “the very heart” of the verification process).

18. The following violations are all very serious: failure to ensure that an employee signs section 1; failure to ensure than an employee checks a box in section 1 attesting to status as a U.S. citizen, lawful permanent resident, or alien authorized to work; and failure to verify the proper identity and employment authorization documents in section 2. See United States v. Ketchikan Drywall Servs., Inc., 10 OCAHO no. 1139, 6 (2011). 19.

Failure to include an expiration date on a driver’s license, as well failure to ensure that an employee enters an alien number in section 1 after selecting status as a lawful permanent resident or alien authorized to work, are serious violations. See United States v. Ketchikan Drywall Servs., Inc., 10 OCAHO no. 1139, 6 (2011). 20. Penalties close to the maximum permissible should be reserved for the most egregious violations.

See United States v. Fowler Equip. Co., 10 OCAHO no. 1169, 6 (2013). 21. Civil money penalties should have a deterrent effect on an employer’s behavior and not merely be a cost of doing business.

See United States v. Emp’r Solutions Staffing Grp. II, LLC, Published 7/15/1511 OCAHO no. 125519 11 OCAHO no. 1242, 11 (2015) (“[A] penalty cannot be set so low that the employer can comfortably pay it simply as a cost of doing business; the prophylactic purpose of a penalty is best served when a penalty is sufficiently significant to motivate a change of behavior.”). To the extent that any statement of fact is deemed to be a conclusion of law or any conclusion of law is deemed to be a statement of fact, the same is so denominated as if set forth as such.

ORDER

Hartmann Studios, Inc. is liable for 808 violations of 8 U.S.C. § 1324a(a)(1)(B) and is ordered to pay civil money penalties totaling $605,250. All other pending motions are denied.

SO ORDERED.

Dated and entered this 8th day of July, 2015. __________________________________ Ellen K. Thomas Administrative Law Judge Appeal Information This order shall become the final agency order unless modified, vacated, or remanded by the Chief Administrative Hearing Officer (CAHO) or the Attorney General. Provisions governing administrative reviews by the CAHO are set forth at 8 U.S.C. § 1324a(e)(7) and 28 C.F.R. pt. 68. Note in particular that a request for administrative review must be filed with the CAHO within ten (10) days of the date of this order, pursuant to 28 C.F.R. § 68.54(a)(1). Provisions governing the Attorney General’s review of this order, or any CAHO order modifying or vacating this order, are set forth at 8 U.S.C. § 1324a(e)(7) and 28 C.F.R. pt. 68.

Within thirty (30) days of the entry of a final order by the CAHO, or within sixty (60) days of the entry of an Administrative Law Judge’s final order if the CAHO does not modify or vacate such order, the Attorney General may direct the CAHO to refer any final order to the Attorney General for review, pursuant to 28 C.F.R. § 68.55. A petition to review the final agency order may be filed in the United States Court of Appeals for the appropriate circuit within forty-five (45) days after the date of the final agency order pursuant to 8 U.S.C. § 1324a(e)(8) and 28 C.F.R. § 68.56. Published 7/15/1511 OCAHO no. 125520 APPENDIX COUNT I No. Employee Name 1 Anderson, Terrence Failure to prepare and/or present I-9 Unknown Violation(s) Alleged Status 2 Barrera, Roberto Failure to prepare and/or present I-9 Unknown 3 Gomez, Guillermo Failure to prepare and/or present I-9 Unknown 4 Mendoza, Ricardo Failure to prepare and/or present I-9 Unknown COUNT II No. Employee Name Abad, Grace E. 1 Violation(s) Alleged Failure to timely prepare and/or present I-9 Status Authorized 2 3 Alba, Carlos E. Failure to timely prepare and/or present I-9 Authorized Alba, Refugio Failure to timely prepare and/or present I-9 Authorized 4 Bradford, Kenneth Failure to timely prepare and/or present I-9 Authorized 5 Cruz Miranda, Juan Ramon Failure to timely prepare and/or present I-9 Authorized 6 7 8 Maldonado, Manuel T. Failure to timely prepare and/or present I-9 Authorized Ponce Castillo, Jose Javier Failure to timely prepare and/or present I-9 Authorized Sullivan, Greg Failure to timely prepare and/or present I-9 Authorized Finding Violation as alleged Violation as alleged Violation as alleged Violation as alleged Finding Failure to timely present I-9 Failure to timely present I-9 Failure to timely present I-9 Failure to timely present I-9 Failure to timely present I-9 Failure to timely present I-9 Failure to timely present I-9 Failure to timely present I-9 Published 7/15/1511 OCAHO no. 125521 No. Employee Name Cruz, Salvador 1 COUNT III Violation(s) Alleged Employee failed to check status box in section 1; Employee failed to sign section 1 2 3 4 5 6 Huerta, Veronica Employee failed to sign section 1 Mata, Gerardo Employee failed to provide A # after checking box indicating status as LPR Olson, Richard E. Employee failed to check status box Parra, Melchor Rivera Luna, Jorge Milton in section 1 Employee failed to provide A # after checking indicating status as alien authorized to work Employee failed to check status box in section 1 Status Unauthorized Unauthorized Unauthorized Finding Employee failed to check status box in section 1 Violation as alleged Violation as alleged Authorized Authorized Unauthorized Violation as alleged Violation as alleged Violation as alleged COUNT IV No. Employee Name Violation(s) Alleged 1 2 3 4 5 Abbot, Brian Craig Acosta, Geysell M. Adams, Thomas B. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Agrillo, Joseph Paul Employer did not sign section 2 Aguilar, Alfredo Ceja Employer did not sign section 2 6 Aguilar, Dora Employer did not sign section 2 7 Aguilar, Jose De Jesus Ceja Employer did not sign section 2 Modified I-9? Y N Y Y N N N Status Finding Authorized Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125522 8 9 Aguilar, Ruben Ferreira Employer did not sign section 2 Aguilera, Mauricio C. 10 Aker, Jeffrey 11 Alegre, Anselma Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 Employer did not sign section 2 12 Alejandre, Ana Maria Employer did not sign section 2 13 Alejandre, Raul 14 Alejo, Victor Hugo Employer did not sign section 2 Employer did not sign section 2 15 Aleman Renteria, Alfredo Employer did not sign section 2 16 Ali, Zaid 17 Allen, Joseph J. Employer did not sign section 2 Employer did not sign section 2 18 19 Alley, Robert Brooks Employer did not sign section 2 Alvarez Dawling, Susana Employer did not sign section 2 20 Amescua, Luis Employer did not sign section 2 21 Amin, Nirali Mukund Employer did not sign section 2 22 Anaya, Claudia Employer did not sign section 2 N N Y N N N N N Y Y Y N N N N Authorized Authorized Authorized Unauthorized Authorized Authorized Unauthorized Unauthorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125523 23 Anderson, William Employer did not sign section 2 24 Annecston, Shawn David Employer did not sign section 2 25 Araujo, Juan Carlos 26 Arellano, Jesus 27 Arellano, Paul 28 Arevalo, Carlos E. 29 Arias H, Nuvia 30 Arroyo, Margarita 31 Arteaga, Nestor Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Missing List A or B document Employer did not sign section 2 32 Ashe, Michael Charles Employer did not sign section 2 33 Audie, Judith 34 Avalos, Salvador 35 Avery, Robert Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 36 37 Avila, Luis E. Morales Employer did not sign section 2 Aviles, Engelmer A. Employer did not sign section 2 N Y N N N N N N N Y N N Y N N Authorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Authorized Unauthorized Authorized Unauthorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125524 38 Avina, Jessica 39 Axelrod, Samantha 40 Bahena, Modesto 41 Balbuena, Edgar 42 Banuelos, Anthony Myles 43 Barajas, Elvia 44 Barajas, Erendira 45 Barajas, Gilberto S. 46 Barajas, Leyde E. 47 Barajas, Lucia 48 Barajas, Luis A. 49 Barajas, Martin E. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document 50 51 Barajas Velasquez, Rafael Employer did not sign section 2 Barba Garcia, Cesar Employer did not sign section 2 52 Barnard, Michael Employer did not sign section 2 N N N N N N N N N N N N N N Y Authorized Authorized Unauthorized Unauthorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Unauthorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125525 53 Barr, Jennifer Employer did not sign section 2 54 Barron, Paulino Employer did not sign section 2 55 Bassard, Arthur 56 Bassett, Mark 57 Basulto, Ruben 58 Beard, James Philip 59 Becerra, Erik R. 60 Becker, Dennis 61 Bell, Gordon 62 Bell, Kevin Ross 63 Bell, Lee Alan 64 Bellamy, Richard Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 65 Ben Yisrael, Joanna Employer did not sign section 2 66 Benson, Cheyenne Employer did not sign section 2 Y Y Y Y N Y N Y Y Y Y Y Y Y Authorized Authorized Authorized Authorized Unauthorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged; Employee’s signature appears in section 2, not employer’s No violation (allegation withdrawn) Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125526 67 Berg, Jon Employer did not sign section 2 68 Bermejo Verdin, Jaime Employer did not sign section 2 69 Bermudez, Melchor Employer did not sign section 2 70 71 Bermudez Murillo, Luis Angel Employer did not sign section 2 Bermudez Murillo, Santos Employer did not sign section 2 72 Bigbee, Maurice 73 Bjornstad, Per 74 Blain, Gabriel N. 75 Blakely, Richard Bolanos Villalobos, Agustin 76 77 Bor, Jesse 78 Boschin, William 79 Bott, Zoe 80 Bradford, Roberto 81 Brawley, John A. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Y N N N N N Y Y Y N Y Y Y Y Y Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged No violation (allegation withdrawn) Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125527 82 Brigance, Timothy 83 Briggs, Bonnie 84 Britton, Ian 85 Brodhead, Will 86 Brown, Andrew G. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or C document Employer did not sign section 2 Employer did not sign section 2 87 Brown, Christopher Robert Employer did not sign section 2 88 Brown, Dustin 89 Brown, Paul R. 90 Buffington, Alan 91 Burke, Paul Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 92 93 94 Burns Gaoiran, Kelly Employer did not sign section 2 Bustos, Maria Cristina Employer did not sign section 2 Cabello Rivera, Raul Employer did not sign section 2 95 Cabrera, Neftaly 96 Calderon, Carlos Employer did not sign section 2 Employer did not sign section 2 Y Y Y Y Y Y Y Y N Y N N N N N Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125528 97 Calderon, Elizabeth 98 Campbell, Samuel 99 Cardona, Amy Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 100 Carmona Garcia, Jorge Employer did not sign section 2 101 Cartagena, Julio Employer did not sign section 2 102 Casey, Sean Michael Employer did not sign section 2 103 Cassidy, Sean Michael Employer did not sign section 2 104 Castellanos, Jaime 105 Castellanos, Omar Employer did not sign section 2 Employer did not sign section 2 106 Castillo, Norman Xavier Employer did not sign section 2 107 Castro, Elisa 108 Caudill, Ryan Scott 109 Caughell, Emily 110 Cavaletti, Deron Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 111 Cazares Rodriguez, Patricia Employer did not sign section 2 N Y N N N Y Y Y N N N Y N Y N Unauthorized Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Unauthorized Violation as alleged Published 7/15/1511 OCAHO no. 125529 112 Cazares Vargas, Maria Elizabeth Employer did not sign section 2 113 Cecaci, Anthony Steven Employer did not sign section 2 114 Cedeno, Salvador 115 Ceja, Omar 116 Cervantes, Abelina 117 Cervantes, Lorenzo Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 118 Chacon Villanuera, Julio Cesar Employer did not sign section 2 119 Chadwick, Nicholas Robert Employer did not sign section 2 120 Chan, Stanley Employer did not sign section 2 121 Chandler, Scott Alan Employer did not sign section 2 122 Chapot, John F. 123 Chavez, Victoriano Employer did not sign section 2 Employer did not sign section 2 124 Chevalier, Philippe Richard Employer did not sign section 2 125 Chevoor, Michael G. Employer did not sign section 2 126 Chew, Sedley Employer did not sign section 2 N Y N N N N N Y Y Y Y N Y Y Y Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Authorized Unauthorized Authorized Authorized Unauthorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Published 7/15/1511 OCAHO no. 125530 127 Chicas, Christian 128 Childers, David O. 129 Chriss, Ian 130 Church, Edward 131 Ciccarone, Richard Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 132 Cisneros Hernandez, Cesar Employer did not sign section 2 133 Cisneros Zavala, Jose Edgardo Employer did not sign section 2 134 Clary, Gareth R. 135 Cobalt, Stacey 136 Coenen, Braden 137 Coleman, Sean M. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 138 Collard, Daniel Timothy Employer did not sign section 2 139 Condon, Andrew P. Employer did not sign section 2 140 Conran, Chris Michael Employer did not sign section 2 Y Y Y Y Y N N Y Y Y Y Y Y Y Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged No violation (allegation withdrawn) Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears, not employer’s Published 7/15/1511 OCAHO no. 125531 141 Contreras, Julio H. Employer did not sign section 2 142 Cook, Jared Weston Employer did not sign section 2 143 Cook, Ryan Wesley Employer did not sign section 2 144 Cordova, Steven Employer did not sign section 2 145 Cornejo, Mauricio A. Employer did not sign section 2 146 Cortez, Wilfredo 147 Corti, Dino R. 148 Courtney, Colleen Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 149 Coyle Johnson, Elisabeth Carey Employer did not sign section 2 150 Crist, Kelly A. 151 Critchfield, John 152 Crouchet, Zepp 153 Cruz, Jose I. 154 Cruz, Virginia Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 155 Cruz Ortiz, Humberto Employer did not sign section 2 N Y Y Y Y N Y N Y Y Y N N N N Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Unauthorized Violation as Authorized alleged Violation as alleged Published 7/15/1511 OCAHO no. 125532 156 Cuellar, Jose A. 157 Culloty, John Employer did not sign section 2 Employer did not sign section 2 158 Curcio, Jon Andrew Employer did not sign section 2 159 Dagesse, Lawrence Gerard Employer did not sign section 2 160 Dalton, John Michael Employer did not sign section 2 161 Dauley, Carol 162 Davies, Evan F. Employer did not sign section 2 Employer did not sign section 2 163 De Leon Cabrera, Juan Jesus Employer did not sign section 2 164 De Waart, Boris 165 Deckner, Colin M. 166 Del Rio, Antonio 167 Del Rio, Jonathan Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 168 Destiny, Michael James Employer did not sign section 2 169 DeWitt, Zoltan Employer did not sign section 2 N Y Y Y N Y Y N Y Y N N Y Y Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Unauthorized Unauthorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears in section 2, not employer’s Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125533 170 DeWolf, John W. Employer did not sign section 2 171 Diaz Echevarria, Ambrosio Employer did not sign section 2 172 Diprima, Rudi 173 Dixon, Kevin J. 174 Dominguez, Jency Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 175 Donnelly, Kieran Francis Employer did not sign section 2 176 Dooling, George Thomas Employer did not sign section 2 177 Downs, Polly Lee 178 Dupuie, Jody 179 Duran, Juan Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 180 Duran Rodriguez, Paola Employer did not sign section 2 181 Durst, John D. 182 Early, Brian J. Employer did not sign section 2 Employer did not sign section 2 183 Edelhauser, James E. Employer did not sign section 2 184 Eduardo Bonilla, Fredy Employer did not sign section 2 Y N Y Y N Y Y Y N N N Y Y Y N Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125534 185 Eisler, Larry 186 Elliott, Shane Paul 187 Ellis, Alicia S. 188 Engle, Jesse M. 189 English, Teressa 190 Erbach, Robert H. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or C document Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 191 Escalante, Alberto Flores Employer did not sign section 2 192 Escareno M, Jose Luis Employer did not sign section 2 193 Escobar, Santana Employer did not sign section 2 194 Escobar Navarro, Serbelio Employer did not sign section 2 195 Espinoza, Perla 196 Estes, Robert Scot 197 Estrada, Margarita Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 198 Evans, Danicholas C. Employer did not sign section 2 199 Fabian, Luis Employer did not sign section 2 Y Y N Y N Y N N N N N Y N N N Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Authorized Unauthorized Authorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125535 200 Fahrner, John Farias, Juan A. 201 202 Farr, Richard Allan 203 Fernandez, Gabriel 204 Fierros, Rosa Maria 205 Figueroa, Patrick 206 Finholt, Mike 207 Fletes, Bob S. 208 Flood, Sean P. 209 Flores, Ana A. 210 Flores, Virginia 211 Flowers, Reshaad Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 212 Foley, Emmet Employer did not sign section 2 213 Fotiu, Huey Employer did not sign section 2 Y N N N N Y Y Y Y N N N Y Y Authorized Unauthorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears in section 2, not employer’s Violation as alleged Published 7/15/1511 OCAHO no. 125536 214 Franco, Saul Employer did not sign section 2 215 Franco Melendez, Maria O. Employer did not sign section 2 216 Freeze, Josh 217 Fukushima, John 218 Fung, Robert 219 Fuquay, William Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 220 Gallegos, Juan Carlos Employer did not sign section 2 221 Garcia, Aquileo 222 Garcia, Claudio 223 Garcia, Elver 224 Garcia, Flor 225 Garcia, Isidro Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 226 Garcia, Jesus Munoz Employer did not sign section 2 227 Garcia, Joan M. Employer did not sign section 2 228 Garcia, Jose Antonio Employer did not sign section 2 N N Y Y N Y Y N N N N N N N N Unauthorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Authorized Authorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125537 229 Garcia, Victor Employer did not sign section 2 230 Garcia Contreras, Geronimo Employer did not sign section 2 231 Garcia N, Rafael 232 Garibay, Rodrigo 233 Garnica, Alberto 234 Garsva, Timothy Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 235 Gerry, Nicholas Thomas Employer did not sign section 2 236 Gill, Ernest A. 237 Goings, Kiernan 238 Gomez, Adriana 239 Gomez, Baldemar 240 Gomez, Edwin 241 Gomez, Rosa N. 242 Gomez, Sergio Employer did not sign section 2 Employer did not sign section 2; Employer did not print name Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 243 Gonzales, Jose Montes Employer did not sign section 2 N N N N N Y Y N N N N N N N N Unauthorized Authorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Authorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125538 244 Gonzalez, Adolfo Employer did not sign section 2 245 Gonzalez, Alejandra Employer did not sign section 2 246 Gonzalez, Arturo 247 Gonzalez, Bertha 248 Gonzalez, David 249 Gonzalez, Joaquin Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 250 Gonzalez, MA Esther Employer did not sign section 2 251 Gonzalez, Rogelio Employer did not sign section 2 252 Gonzalez De Cabrera, Gloria Employer did not sign section 2 253 Goodno, David 254 Gould, Chris 255 Graelish, Ryan 256 Graham, James 257 Green, Edward 258 Gregory, Jon Dale Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 N N N N N N N N N Y Y N Y Y Y Authorized Unauthorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125539 259 Guelfi, Michael J. 260 Guerra, Artemio 261 Guerra, Rony 262 Guerrero, Abram Employer did not sign section 2; Employer did not print name Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or C document 263 Guerrero Prado, Alberto Employer did not sign section 2 264 Gutierrez, Blanca C. Employer did not sign section 2 265 Gutierrez, Cesar 266 Gutierrez, Jesse M. 267 Gutierrez, Jose Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 268 Gutierrez, Luz Elena Employer did not sign section 2 269 Gutierrez Lopez, Alvaro Employer did not sign section 2 270 Guzman, Jose M. Employer did not sign section 2 271 Guzman, Julio Cesar Employer did not sign section 2 272 Guzman, Victor S. Employer did not sign section 2 273 Guzman Machado, Luis Alberto Employer did not sign section 2 N N N Y N N N N N N N N N N N Authorized Unauthorized Unauthorized Authorized Unauthorized Authorized Unauthorized Authorized Authorized Unauthorized Unauthorized Unauthorized Authorized Unauthorized Unauthorized Employer did not sign section 2 Violation as alleged 2 Violation as alleged Employer did not sign section Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125540 274 Hall, Shaunna Elizabeth Employer did not sign section 2 275 Halley, Elton P. 276 Hanrahan, Benito Employer did not sign section 2 Employer did not sign section 2 277 Hanrahan, Dennis Patrick Employer did not sign section 2 278 Hansen, Daniel Wayne Employer did not sign section 2 279 Hansen, Patrick G. 280 Harlan, Barbara 281 Harper, Lisa 282 Harrington, Guy 283 Harris, Neil F. 284 Hartley, Jacques M. 285 Hartman, Aaron F. 286 Hartz, Melanie 287 Harutoonian, Lydia 288 Hatch, David Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Employer did not print name Employer did not sign section 2 Employer did not sign section 2 Y Y Y Y N N Y Y Y Y Y Y N Y Y Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125541 289 Haugen, Michael Employer did not sign section 2 290 Havandjian, Christine Sevan Employer did not sign section 2 291 Heartsill, Ronald G. Employer did not sign section 2 292 Helbig, Frank Employer did not sign section 2 293 Hemmatianpour, Valentino Employer did not sign section 2 294 Henn, Galen Employer did not sign section 2 295 Hennes, Paul Anthony Employer did not sign section 2 296 Heredia, Jose 297 Hernandez, Ana Estela 298 Hernandez, Catalina 299 Hernandez, Delia Employer did not sign section 2 Employer did not sign section 2; Employer did not print name Employer did not sign section 2 Employer did not sign section 2 300 Hernandez, Eduardo Rodriguez Employer did not sign section 2 Y Y N Y N Y Y N N N N N Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Violation as alleged Violation as alleged; Employee’s signature appears in section 2, not employer’s Violation as alleged Violation as alleged; Employee’s signature appears in section 2, not employer’s Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125542 301 Hernandez, Eladio 302 Hernandez, Exman Employer did not sign section 2 Employer did not sign section 2 303 Hernandez, Francisco A. Employer did not sign section 2 304 Hernandez, Jairo Employer did not sign section 2 305 Hernandez, Janea D. Employer did not sign section 2 306 Hernandez, Jesus Rueda Employer did not sign section 2 307 Hernandez, Joe D. Employer did not sign section 2 308 Hernandez, Jose Enrique Employer did not sign section 2 309 Hernandez, Luis 310 Hernandez, Luis A. 311 Hernandez, Melvin 312 Hernandez, Ramiro 313 Hernandez, Sergio Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 314 Hernandez, Veronica Employer did not sign section 2 315 Hernandez Aguirre, Eduardo Employer did not sign section 2 N N N N N N N N N N N N N N N Unauthorized Unauthorized Authorized Unauthorized Authorized Unauthorized Authorized Unauthorized Unauthorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125543 316 317 Hernandez Jeronimo, Antonio Jesus Hernandez Jimenez, Guillermo Employer did not sign section 2 Employer did not sign section 2 318 Hernandez Luz, Jose Luis Employer did not sign section 2 319 Herrera, Harold D. 320 Herrera, Rosalio Employer did not sign section 2 Employer did not sign section 2 321 Hess, Robert Employer did not sign section 2 322 Hetrick, Mark J. Employer did not sign section 2 323 Heywood, James Stephen Employer did not sign section 2 324 Hill, Jaeger Bryce Employer did not sign section 2 325 Hill, Leighton Cyrus Employer did not sign section 2 326 Hill, Tonyette K. 327 Holguin, Nathan 328 Holt, Jimmy R. 329 Hoobyar, Jason Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or C N N N N N Y Y Y Y Y N Y N Y Unauthorized Unauthorized Unauthorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears in section 2, not employer’s Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Published 7/15/1511 OCAHO no. 125544 document 330 Hoobyar, Peter Scott Employer did not sign section 2 331 Horn, Lisa Rani Employer did not sign section 2 332 Hornbeck, Lawrence Employer did not sign section 2 333 Horowitz, Jay William Employer did not sign section 2 334 Houghton, Scott Anthony Employer did not sign section 2 335 Hudson, Peter Daniel Employer did not sign section 2 336 Huebner, David Michael Employer did not sign section 2 337 Huerta, Antonio Cisneros Employer did not sign section 2 338 Huerta, Lorena M. 339 Huerta, Silvia 340 Huft, Douglas W. Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 Employer did not sign section 2 341 Hunt, Richard Allen Employer did not sign section 2 342 Hutchinson, Joel A. 343 Hutchinson, Neil Employer did not sign section 2 Employer did not sign section 2 Y Y Y Y Y Y Y N N N Y Y Y Y Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Unauthorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125545 344 Ibarra, Juan M. 345 Iraheta, Karla Employer did not sign section 2 Employer did not sign section 2 346 Jacobson, Phillip Andrew Employer did not sign section 2 347 Janusch, Rod M. 348 Javius, Sirmac B. 349 Jaworski, Jay Carl 350 Jett, Bradford Alan Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 351 Johannsen, Jon 352 John, Edward William Employer did not sign section 2 Employer did not sign section 2; Missing List A, B, and/or C document 353 Johnson, Adam James Employer did not sign section 2 354 Johnson, Gregory R. Employer did not sign section 2 355 Johnson, Michael Troy Employer did not sign section 2 356 Juarez, Elvia Employer did not sign section 2 357 Juarez de Barcenas, Besi M. Employer did not sign section 2 358 Jury, Andrew Mark Employer did not sign section 2 N N Y Y N Y Y Y Y Y Y N N N Y Unauthorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125546 359 Karlsen, Kirsten Employer did not sign section 2 360 Kasprzak, Brian Paul Employer did not sign section 2 361 Kassab, Karim L. Employer did not sign section 2; Missing List A or C document 362 Kavanagh, Neale James Employer did not sign section 2 363 Kelly, Jon Paul Employer did not sign section 2 364 Kendrix, Christopher Keith Employer did not sign section 2 365 Kerswell, Jake Employer did not sign section 2 366 Khaleel, Jonathon S. Employer did not sign section 2 367 Khalsa, Japji S. Employer did not sign section 2 368 Kiely, James William Employer did not sign section 2 369 Kimball, Michael D. Employer did not sign section 2 370 Kimbrough, Reginald Albert Employer did not sign section 2 371 Kirkland, Ken E. Employer did not sign section 2 372 Klincko, Kenneth William Employer did not sign section 2 373 Knight, Patrick M. Employer did not sign section 2 N Y N Y Y Y Y N Y Y Y Y Y Y Y Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125547 374 Koeper, Michael Ralph Employer did not sign section 2 375 Kramer, Jeffrey E. Employer did not sign section 2 376 Kramlich, Jeffrey A. Employer did not sign section 2 377 Krebser, John Employer did not sign section 2 378 Kumarezas, James John Employer did not sign section 2 379 Kyle, Stephen Corbett Employer did not sign section 2 380 LaBarre, Elizabeth Ann Employer did not sign section 2 381 Lacabe, Keith Andrew Employer did not sign section 2 382 LaConte, Richard G. Employer did not sign section 2 383 Lagios, Demetre 384 Lakota, Anne Employer did not sign section 2 Employer did not sign section 2 385 Lambert Jr., Roger Lee Employer did not sign section 2 386 Lamons, Peter James Employer did not sign section 2 387 Landaverde, Carlos J. Employer did not sign section 2 388 Landaverde, Ronald A. Employer did not sign section 2 Y Y N Y Y Y N Y Y Y Y Y Y N N Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125548 389 Landrum, Zachary Reed Employer did not sign section 2 390 Larsen, Eric J. 391 Lau, Helen Employer did not sign section 2 Employer did not sign section 2 392 Lawrence, Andrew David Employer did not sign section 2 393 Lawrence, Toby Edward Employer did not sign section 2 394 Lazaris, Paul W. 395 Lazzarini, Dan 396 Lee, Derrick 397 Lee, Jonathan Brian Employer did not sign section 2; Missing List A or C document Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 398 Leinweber, Melanie N. Employer did not sign section 2 399 Lemi, Kristina G. 400 Leon, Catalina 401 Leshne, Carla Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 402 Lewis, Emmett Russell Employer did not sign section 2 403 Liebenguth, John Employer did not sign section 2 Y N N Y Y Y Y N Y N N N Y Y Y Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125549 404 Lim, James C. Employer did not sign section 2 405 Limon, Rosa Imelda Employer did not sign section 2 406 Loo, Derek 407 Lopez, Guadalupe 408 Lopez, Luis A. 409 Lopez, Maria 410 Lopez, Victor A. Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document 411 Lopez Mederos, Jose Fernando Employer did not sign section 2 412 Lovitt, Keith D. Employer did not sign section 2 413 Lubensky, Joshua Lashem Employer did not sign section 2 414 Lucero, Eugene Paul Employer did not sign section 2 415 Lucero, Steven R. 416 Lucero, Wilfredo 417 Luevano, Mark 418 Luon, Mettiana Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Y N Y N N N N N N Y Y N N Y Y Authorized Unauthorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125550 419 Mac Donald, James Robert Employer did not sign section 2 420 Macachor, Jeremy 421 Macias R, Fidel 422 Maciel, Anabell 423 MacLeod, James Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 424 Macpherson, Kevin Michael Employer did not sign section 2 425 Maddox, Derek James Missing List A or C document 426 Magana, Felipe De Jesus Leon Missing document number under List A 427 Magdaleno B, Antonio Employer did not sign section 2 428 Maidenberg, Reed A. Employer did not sign section 2 429 Maner, Samantha 430 Manigault, Erin Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 431 Manjarrez Montano, Ruben Employer did not sign section 2 432 Manning, Anne M. 433 Manrique, Anel Employer did not sign section 2 Employer did not sign section 2 Y Y N N Y Y N N N Y N Y N N N Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Authorized Authorized Authorized Authorized Authorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125551 434 Manrique, Mercedes 435 Manship, Blake A. 436 Manuel, Andre J. Employer did not sign section 2; Employer did not print name Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document 437 Marin, Felipe De Jesus Employer did not sign section 2 438 Marin, Rex 439 Mariscal, Elizabeth 440 Markovski, Daniel 441 Marquez, Eric Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 442 Martin, William Christopher Employer did not sign section 2 443 Martinez, Genaro 444 Martinez, Jesus 445 Martinez, Jorge A. 446 Martinez, Jose J. 447 Martinez, Luis F. Employer did not sign section 2; Missing List A, B, and/or C document Employer did not sign section 2 Employer did not sign section 2 Missing List A or B document Employer did not sign section 2 N Y N N Y N Y N Y N N N N N Unauthorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Unauthorized Unauthorized Authorized Employer did not sign section 2 Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Unauthorized Missing List A or C document Unauthorized Violation as alleged Published 7/15/1511 OCAHO no. 125552 448 Martinez, Mario 449 Martinez, Oscar 450 Martir, Marta A. 451 Massol, Alexis 452 Maynier, John P. 453 McBride, Dwight 454 McCann, Robert J. Missing List A or B document Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 455 McClendon, Gary R. Employer did not sign section 2 456 McCombe, Michael F. Employer did not sign section 2 457 McCracken, Sean Anthony Employer did not sign section 2 458 McCraw, Joseph Employer did not sign section 2 459 McDonough, Meghan Employer did not sign section 2 460 McGrath, Diarmaid 461 McGriff, Anna M. 462 McGuinn, Timothy Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 N N N Y Y Y Y Y N Y Y Y Y Y Y Authorized Missing List A or C document Authorized Employer did not sign section 2 Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged No violation (allegation withdrawn) Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125553 463 McKereghan, Kevin Douglas Employer did not sign section 2 464 McLaughlin, David K. Employer did not sign section 2 465 McMillan, Donald A. Employer did not sign section 2 466 McNicoll, Edward 467 McNutt, Scott 468 Medina, Blanca Estela Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Employer did not print name 469 Medina, Maria Elena Employer did not sign section 2 470 Meek, Brian Thomas Employer did not sign section 2 471 Mejia Martinez, Petronila Employer did not sign section 2 472 Melano, Octavio Employer did not sign section 2 473 Melgar, Rolando Atilio Employer did not sign section 2 474 Mendoza, Maria E. 475 Merten, Randal W. Employer did not sign section 2 Employer did not sign section 2 476 Middlemiss, Edward J. Employer did not sign section 2 477 Milanes, Mario Alberto Employer did not sign section 2 Y Y N Y Y N N Y N N N N Y Y N Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged No violation (allegation withdrawn) Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125554 478 Miller, Christopher David Employer did not sign section 2 479 Miller, Kimberly Anne Employer did not sign section 2 480 Miller, Ryan 481 Miller, Seth Employer did not sign section 2 Employer did not sign section 2 482 Milligan, Russell C. Employer did not sign section 2 483 Minifie, Darren 484 Mitchell, James 485 Mohagen, Craig E. 486 Molina, Miguel M. 487 Molnar, Dan L. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 488 Mondoux, Raymond E. Employer did not sign section 2 489 Montaner, Julian 490 Montano, Maria E. 491 Montano, Ramon S. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document 492 Montante, Justin Max Employer did not sign section 2 Y Y Y Y Y N Y Y Y Y Y Y N N Y Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Published 7/15/1511 OCAHO no. 125555 493 Montes, Mauricio Employer did not sign section 2 494 Montiel, Emanuel C. Employer did not sign section 2 495 Moore, Gregory Thomas Employer did not sign section 2 496 Moore, Timothy Merritt Employer did not sign section 2 497 Moorman, Gary Dwayne Employer did not sign section 2 498 Morales, Juan Gabriel Employer did not sign section 2 499 Morales, Yanira 500 Moreira, Amilcar Employer did not sign section 2 Employer did not sign section 2 501 Moreira Munoz, Wilson Y. Employer did not sign section 2 502 Moreno, Daniel Patrick Employer did not sign section 2 503 Moreno, Martin Employer did not sign section 2 504 Morgan, Michael L. Employer did not sign section 2 505 Morgan, Timothy J. Employer did not sign section 2 506 Morgante, Joel Scott Employer did not sign section 2 507 Mota Perez, Omar* *This employee is also employee no. 571 and will only be counted once Employer did not sign section 2; Employer did not print name N N Y Y Y N N N N Y Y Y Y Y N Unauthorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged No violation (allegation withdrawn) Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Published 7/15/1511 OCAHO no. 125556 508 Movillion, Reynaldo Employer did not sign section 2 509 Muchlinski, Arthur Henryk Employer did not sign section 2 510 Mueller, Craig Ernest Employer did not sign section 2 511 Muldowney, Davina R. Employer did not sign section 2 512 Munos, Amparo 513 Munoz, Francisco 514 Munoz, Juan Jose 515 Munoz, Teresa 516 Munoz, Zalvador 517 Murillo, Jose 518 Murillo, Maria A. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Missing List A or B document Employer did not sign section 2 Employer did not sign section 2 519 Murillo Gomez, Nely Employer did not sign section 2 520 Murphy, Kenneth 521 Murray, Melanie Employer did not sign section 2 Employer did not sign section 2 522 Murray, Rovell Lamon Employer did not sign section 2 Y Y Y N N N N N N N N N Y Y Y Authorized Authorized Authorized Authorized Unauthorized Unauthorized Authorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Unauthorized Missing List A or C document Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears in Published 7/15/1511 OCAHO no. 125557 523 Myers, Sarah Camille Employer did not sign section 2 524 Nakahara, Mark S. Employer did not sign section 2 525 Nava, Manuel Flores Employer did not sign section 2 526 Navarijo, Dimas 527 Navarijo, Elder N. 528 Navarijo, Melvin E. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 529 Navarijo Doniz, Jose Manuel Employer did not sign section 2 530 Navarijo Juares, Juan A. Employer did not sign section 2 531 Navarro, Carlos 532 Navarro, Moises Employer did not sign section 2 Employer did not sign section 2 533 Navarro Gonzalez, Alicia Employer did not sign section 2 534 Ness, Kjell A. 535 Newell, Scott Employer did not sign section 2 Employer did not sign section 2 536 Nichols, James Timothy Employer did not sign section 2 section 2, not employer’s Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Authorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Unauthorized Unauthorized Unauthorized Authorized Unauthorized Authorized Authorized Authorized N Y N N N N N N N N N Y Y Y Published 7/15/1511 OCAHO no. 125558 537 Nixon, Andrew Derek Employer did not sign section 2 538 Nodal, Hector 539 Noel, Jason Employer did not sign section 2 Employer did not sign section 2 540 Noj, Karina Gonzalez Employer did not sign section 2 541 Nolasco, Felipe De Jesus Employer did not sign section 2 542 North, Jeff J. 543 North, Robert 544 Nunez, Hilda Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 545 Nunez Ramirez, Roberto Employer did not sign section 2 546 Nyberg, Peter James Employer did not sign section 2 547 Obrien, Andrew Patrick Employer did not sign section 2 548 Ohta, Casey W. Employer did not sign section 2 549 Oliva Landaverde, Jose Napoleon Employer did not sign section 2 550 Olness, James Paul 551 Orellana, Ana Employer did not sign section 2 Employer did not sign section 2 Y N Y N N Y Y N N Y Y Y N Y N Authorized Authorized Authorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Unauthorized Violation as Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125559 552 Orona, Orlando J. Employer did not sign section 2 553 Ortiz, Jose Guadalupe Missing List A or B document 554 Ortiz Reyes, Ricardo Employer did not sign section 2 555 Osorio, Ana D. 556 Osorio, Carlos C. Employer did not sign section 2 Employer did not sign section 2 557 Osorio Robles, Saul Employer did not sign section 2 558 Oster, John 559 Ozier, Jason M. 560 Padilla, Orlando E. 561 Padilla, Osvaldo M. 562 Palmer, Jeffery Ian Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 563 Parish, Alfred Phillip Employer did not sign section 2 564 Parrish, Wesley Estes Employer did not sign section 2 565 Paulino, Francisco 566 Pena, Marlon Employer did not sign section 2 Employer did not sign section 2 Y N N N N N Y Y N N Y Y Y N N Authorized Violation as alleged Authorized Missing List A or C document Authorized Authorized Authorized Unauthorized Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Unauthorized Violation as alleged Violation as alleged Unauthorized Published 7/15/1511 OCAHO no. 125560 567 Peralta, Paul James 568 Perez, Abel 569 Perez, Filomena Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 570 Perez, Mayra Toscano Employer did not sign section 2 571 Perez, Omar Mota Employer did not sign section 2 572 Perez, Ricardo 573 Perez, Ruben A. 574 Perez Pacheco, Miguel A. 575 Perretti, Charles A. 576 Perrin, Jeffrey 577 Peters, Richard Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Employer did not print name Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 578 Peterson, Kurt Richard Employer did not sign section 2 579 Pilette, Paul Joseph Employer did not sign section 2 580 Pineda Gutierrez, Carlos Employer did not sign section 2 Y N N N N N N N Y Y Y Y Y N Authorized Unauthorized Unauthorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged No violation; duplicate listing of employee, who is also listed as employee no. 507 Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Authorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Authorized Authorized Unauthorized Published 7/15/1511 OCAHO no. 125561 581 Pino, Michael Deane Employer did not sign section 2 582 Pitta, Ernest 583 Pochapin, Lee Employer did not sign section 2 Employer did not sign section 2 584 Podwil, Daniel Adam Employer did not sign section 2 585 Pollek, Gary Employer did not sign section 2 586 Polson, Fredric Wayne Employer did not sign section 2 587 Pope, Bradley Fleming Employer did not sign section 2 588 Pope, Valerie Employer did not sign section 2 589 Portillo Salazar, Sergio Employer did not sign section 2 590 Powell, Robert E. Powell, Stephanie 591 592 Powers, Robert B. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 593 Presotto, Paulo Rogerio Employer did not sign section 2 594 Puch, Marcela Employer did not sign section 2 Y N Y Y Y Y Y Y N Y Y Y Y N Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears in section 2 rather than emloyer’s Violation as alleged Authorized Unauthorized Published 7/15/1511 OCAHO no. 125562 595 Quattrin, Cian Amergin Employer did not sign section 2 596 Rabe, Paul 597 Ramirez, Carlos A. 598 Ramirez, Eric 599 Ramirez, Juan C. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Missing Driver’s License Expiration Date 600 Ramirez, Juan Francisco Employer did not sign section 2 601 Ramirez, Lazaro Alvaro Employer did not sign section 2 602 Ramirez, Norma 603 Ramirez, Silvia I. 604 Ramos, Maribel 605 Ramos, Medel Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 606 Ramrakha, Subharid Chand Employer did not sign section 2 607 Rapisura, Erick 608 Ray, Charles H. 609 Raymond, Daniel Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Y N N N N N N N N N Y Y Y Y Y Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125563 610 Raymond, Derek Scott Employer did not sign section 2 611 Raymond, Travis Lee Employer did not sign section 2 612 Reade, George Employer did not sign section 2 613 Recinos, Roberto 614 Record, Raven 615 Regan, Christopher 616 Regan, David 617 Rege, Nichole Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 618 Reinis, Danielle Misha Employer did not sign section 2 619 Rembert, Charles 620 Retana, Guillermo 621 Revolorio, Lester 622 Rexroat, Travis Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 623 Richardson, Edward T. Employer did not sign section 2 Y Y Y N Y Y Y N Y N N N Y Y Authorized Authorized Violation as alleged Violation as alleged Authorized Violation as alleged; Employee’s signature appears in section 2 rather than employer’s Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Published 7/15/1511 OCAHO no. 125564 624 Rico Casillas, Jeffery Employer did not sign section 2 625 Rienecker, Thomas D. Employer did not sign section 2 626 Riley, Marlowe 627 Rinfret, Gary 628 Rios, Maria 629 Rios Lopez, Juan Ripka, James H. 630 631 Rivera, Reyes 632 Rivera, Sergio Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 633 Rivera Negrete, Jose Luis Employer did not sign section 2 634 Roberts, Shea Employer did not sign section 2 635 Robinson, Terrell Employer did not sign section 2 636 Roblero Acevedo, Jonathan Employer did not sign section 2 637 Rodriguez, Alberto Employer did not sign section 2 N Y Y Y N N Y N N N Y N N N Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears in section 2 rather than employer’s Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125565 638 Rodriguez, Alma 639 Rodriguez, Cesar 640 Rodriguez, Daniela 641 Rodriguez, Gabriel 642 Rodriguez, Luiz 643 Rodriguez, Norma 644 Rodriguez, Oscar 645 Rodriguez, Yulissa 646 Rodriguez Martinez, Alejandro 647 Rogers, Kevin 648 Rojas, Ana 649 Romero, Laura 650 Romero De Gonzalez, Ruth Estela Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 651 Romo, Jose De Jesus Employer did not sign section 2 652 Rosado, Jacqueline Employer did not sign section 2 N N N N N N N N N Y N N N N N Unauthorized Unauthorized Unauthorized Unauthorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Authorized Unauthorized Unauthorized Authorized Unauthorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125566 653 Rose, Joseph A. Employer did not sign section 2 654 Roulston, Katherine Employer did not sign section 2 655 Rua Martinez, Felipe Employer did not sign section 2 656 Ruiz, Rafael A. Employer did not sign section 2 657 Rutia Hernandez, Petra Employer did not sign section 2 658 Ryan, Anne Employer did not sign section 2; Missing List A or C document 659 Ryan, Kathleen Grace Employer did not sign section 2 660 Ryan, Patrick E. Employer did not sign section 2 661 Saarni, Nelson Oliver Employer did not sign section 2 662 Saavedra, Jorge Employer did not sign section 2 663 Salazar, Diana Karen Employer did not sign section 2 664 Salceda, Laura 665 Salomon, Amber Employer did not sign section 2 Employer did not sign section 2; Missing List A or C document 666 Samayoa Donis, Jose M. Employer did not sign section 2 667 Samayoa Garcia, Jose A. Employer did not sign section 2 Y Y N N N N Y Y Y N N N N N N Authorized Authorized Violation as alleged Violation as alleged Unauthorized Violation as alleged Unauthorized Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Unauthorized Authorized Authorized Authorized Authorized Unauthorized Authorized Unauthorized Authorized Authorized Unauthorized Published 7/15/1511 OCAHO no. 125567 668 Samish, Ian Harvey 669 Sammon, Jeff Employer did not sign section 2 Employer did not sign section 2 670 Samudio, Robert Anthony Employer did not sign section 2 671 Sanchez, Berenice 672 Sanchez, Enrique 673 Sanchez, Maria Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 674 Sanchez Cruz, Maria Employer did not sign section 2 675 Sanders, Christopher James Employer did not sign section 2 676 Sandoval, Savino 677 Santos, Powell Employer did not sign section 2 Employer did not sign section 2 678 Sapien, Victor Manuel Employer did not sign section 2 679 Sarabia, Maria F. Employer did not sign section 2 680 Saud, Chris Employer did not sign section 2 681 Saunders, Catherine Ruth Employer did not sign section 2 Y Y Y N N N N Y N Y N N Y Y Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears in section 2 instead of employer’s Violation as alleged Published 7/15/1511 OCAHO no. 125568 682 Scharfenberg, Gretchen Employer did not sign section 2 683 Schempp, Stephanie Rose Employer did not sign section 2 684 Schirmang, Vanessa Edith Employer did not sign section 2 685 Schoening, John Employer did not sign section 2 686 Schoening, Paul Ronald Employer did not sign section 2 687 Schwalbach, David 688 Sciacqua, Edward 689 Seamas, Craig 690 Segal, Lauren 691 Seifert, Jason 692 Senick, Joshua 693 Servin, Jesse 694 Shafer, Susan 695 Shankel, Erin 696 Shankel, Mark Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Y Y Y Y Y N N Y N Y Y Y Y Y Y Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125569 697 Shea, Paul 698 Shellenberger, Christopher Thomas Employer did not sign section 2 Employer did not sign section 2 699 Sherer, Daniel H. Employer did not sign section 2 700 Sherwood, Govinda 701 Shine, Chris 702 Shine, Greg 703 Shores, Aaron 704 Short, Allen E. 705 Sierra, Heraldo 706 Sims, Molly Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 707 Sims, Ndiko Jamal 708 Sion, Adam 709 Small, Kendall Employer did not sign section 2 Employer did not sign section 2; Missing List A, B, and/or C document Employer did not sign section 2 N Y Y Y Y Y Y N N N Y Y N Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears in section 2 instead of employer’s Violation as alleged Violation as alleged No violation (allegation withdrawn) Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Authorized Authorized Employer did not sign section 2 Violation as alleged Published 7/15/1511 OCAHO no. 125570 710 Smart, Robert William Employer did not sign section 2 711 Smith, Kenneth Employer did not sign section 2 712 Smith, Kevin Russell Employer did not sign section 2 713 Smith, Ronald 714 Soledad, Martin 715 Soogian, Daniel 716 Sotiras, Pete Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 717 Souza, John Christopher Employer did not sign section 2 718 Spangler, Mark 719 St. Arnaud, Patrice 720 St. Hilaire, John 721 Starobin, Michael 722 Starr, Michael 723 Steele, Timothy Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Y Y Y Y N Y Y Y Y Y Y Y Y N Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged; Employee’s signature appears in section 2 instead of employer’s Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125571 724 Stover, Kevin 725 Stoye, Abram 726 Sullivan, Terry S. 727 Summers, Kent Sweeney, Bryan James 728 Tanaka, Steven 729 730 Tapia, Ricardo Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 731 Taravella, Michael Robert Employer did not sign section 2 732 Taylor, Douglas 733 Teele, Michael Employer did not sign section 2 Employer did not sign section 2 734 Tenorio Revuelta, Ismael Employer did not sign section 2 735 Teo, Benjamin V. 736 Terrell, Brent C. 737 Thompson, Alva 738 Thompson, Joshua Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Y Y Y N Y N N Y Y N N Y N Y Y Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged No violation (allegation withdrawn) Violation as alleged Published 7/15/1511 OCAHO no. 125572 739 Thompson, Kevin A. Employer did not sign section 2 740 Thompson, Shadi Johnny Employer did not sign section 2 741 Thomson, Kevin Robert Employer did not sign section 2 742 Thonus, Michael Employer did not sign section 2 743 Tisnados, Alexander Employer did not sign section 2 744 Tolmie, David L. 745 Tran, Benny 746 Trefry, Leah 747 Trejos, Deborah G. 748 Trimmer, Brian 749 Tunks, Timothy 750 Urban, Robert J. 751 Uribe, Juan Carlos 752 Utrera, Miguel 753 Valdez, Erica Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Employer did not print name Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Y N Y Y N Y Y N N Y Y Y N N N Authorized Authorized Authorized Authorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Unauthorized Unauthorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125573 754 Van Bockern, Brendan Employer did not sign section 2 755 Van Perre, Ivan J. Employer did not sign section 2 756 Vande Moortel, Jean Employer did not sign section 2 757 Vasquez, Anner 758 Vasquez, Claudia 759 Vasquez, Milton 760 Vazquez, Alberto Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 761 Vazquez Cruz, David Employer did not sign section 2 762 Vega Ortiz, Javier Employer did not sign section 2 763 Vega Vizcaino, Jose De Jesus Employer did not sign section 2 764 Venerable, Randall Jon Employer did not sign section 2 765 Vernali, David 766 Visco, Louis 767 Vogel, Douglas G. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 768 Vollendorf, Dorothy Employer did not sign section 2 Y Y Y N N N N N N N Y Y Y Y Y Authorized Authorized Authorized Unauthorized Unauthorized Unauthorized Unauthorized Unauthorized Unauthorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged No violation (allegation withdrawn) Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125574 769 Vournas, John Employer did not sign section 2 770 Vukmanic, Thomas George Employer did not sign section 2 771 Wade, Colin 772 Waldron, David 773 Walton, Marcellis Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Employer did not print name 774 Weiser, Isaac Yosef Employer did not sign section 2 775 Wessling, Timothy Francis Employer did not sign section 2 776 Whalen, David 777 White, Randall 778 Whitfield, Collin 779 Whitmore, Jennifer 780 Williams, Carl 781 Williams, Mary 782 Willis, Chris A. Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Missing List A or B document Employer did not sign section 2 Employer did not sign section 2 Y Y Y Y N Y Y Y Y Y Y N Y Y Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged; union signed the form and is listed as the employer Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125575 783 Wilson, Alfred 784 Wilson, Greg 785 Wilson, Joshua Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 786 Winslow, Trenton Robb Employer did not sign section 2 787 Wolfersperger, Karl Employer did not sign section 2 788 Wolohan, Joseph 789 Woodward, Lisa 790 Wright, Nicholas 791 Wright, Sean 792 Wyman, Scott 793 Young, David Ellis 794 Zamora, Alexander 795 Zeh, Alex Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2; Employer did not print name Employer did not sign section 2 Employer did not sign section 2 Employer did not sign section 2 796 Zermeno Cornejo, Adrian Employer did not sign section 2 797 Zermeno Cornejo, Juan Francisco Employer did not sign section 2 N Y N Y Y Y Y Y Y N Y N Y N N Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Authorized Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Employer did not sign section 2 Violation as alleged Violation as alleged Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125576 COUNT V No. Employee Name Violation(s) Alleged Status Finding 1 2 3 Carrillo, Zonia Mirna Suazo Zepeda, Carlos Orlando Urbina, Maria Silvia Failure to complete section 3 Authorized Failure to complete section 3 Authorized Failure to complete section 3 Authorized Violation as alleged Violation as alleged Violation as alleged Published 7/15/1511 OCAHO no. 125577