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Bus Shelters and Lincoln Road Directories AgreementsBUDGET AND PERFORMANCE IMPROVEMENT Internal Audit Division INTERNAL AUDIT REPORT TO: VIA: FROM: DATE: Jorge M. Gonzalez, City Manager a Kathie G. Brooks, Budget and ~erf.o mance Improvement Director .p James J. Sutter, Internal Audit<::. "1:j~ May 28, 2010 AUDIT: PERIOD: Bus Shelters and Lincoln Road Directories Agreements October 1, 2005 through December 31, 2008 This report is the result of an audit performed on advertising revenues receipts from two agreements with Clear Channel Adshel for citywide bus shelters and Lincoln Road area directory structures, in accordance with our audit plan. INTRODUCTION On April18, 2001, the Mayor and City Commission authorized the execution of an agreement with Clear Channel Adshel ("Contractor") pursuant to Request for Proposals (RFP) Number 112-99/00 to construct, operate and maintain directory structures in the Lincoln Road area. The executed agreement was for an initial term of five years with the option to renew automatically, at the end of the initial term for five one-year terms. After approval of Resolution 2002-25064 by the Mayor and the City Commission, the terms of the initial agreement were amended on November 13, 2002, to add 10 additional street name signs and one directory structure, as well as to extend the initial term for two years. The contractor agreed to pay the City on a quarterly basis a minimum annual guarantee on an escalating scale. A similar agreement with this Contractor was executed on October 17, 2001, to construct, operate and maintain bus shelter structures and other street furniture throughout the City, pursuant to a separately issued RFP number 107-99/00. This agreement was for an initial term of ten years commencing on November 1, 2001, with the option to automatically renew for a five year term. The Contractor agreed to pay the City on a quarterly basis a minimum annual guarantee plus a percentage of revenue sharing, both on an escalating scale. Revenue payments received by the City for the audit period are as follows: FY 05-06 FY 06-07 FY 07-08 FY 08-09 (1) Grand Total Bus Shelters $340,500.02 $415,146.15 $404,702.78 $119,330.50 $1,279,679.45 Lincoln Road $115,014.41 $146,417.21 $144,192.48 $ 27,256.16 $ 432,880.26 $455,514.43 $561,563.36 $548,895.26 $146,586.66 $1,712,559.71 (1) Amounts represent revenue receipts for only three months (October 2008-December 2008) OVERALL OPINION As a result of our testing during the audit, we were able to confirm that the Contractor is making revenue payments to the City for bus shelters and Lincoln Road area, based on the net revenues received from advertising contracts identified on their quarterly reports; is providing maintenance to street furniture and Lincoln Road directories; and complying with other terms of the agreements. However, results from our testing identified deficiencies in reference to the City's review of the We are commitled Ia providing excellent public se1vice one/ sofety to oil who live, work, ond ploy in our vibronl, lropicol, historic community. Internal Audit Report Bus Shelters and Lincoln Road Directories Agreements May 28, 2010 accuracy and timeliness of quarterly revenue receipts; inspection and maintenance of bus shelters; and processing of revenue receipts by the Finance Department. Areas identified for corrective action include the following: 1. Revenue payments made by the Contractor for Lincoln Road directory advertising were short of Minimum Annual Guarantees by approximately $45,283 during the life of the agreement. 2. The Contractor consistently submitted the quarterly revenue payments under both agreements past the established due date, which represents approximately $8,792 of uncollected late charges for the City. 3. Several bus shelters inspected showed evidence of not being properly maintained by the Contractor, as graffiti was not removed in a timely manner in accordance with the terms of the agreements. 4. The Finance Department does not date-stamp payments when received from the Contractor. Since there are established due dates, the City is failing to require or collect late payment charges due from the Contractor. The accuracy of revenue payments based on percentage guarantees is not being reviewed by Finance. Furthermore, payments received are not being recorded to the EDEN system in a timely manner. 5. The title of the general ledger account used to record revenue receipts from bus shelters and Lincoln Road directory advertising does not properly reflect the use or purpose of the account. Additional details regarding the above mentioned areas in need of correction have been provided on the Findings, Recommendations, and Management Responses section of this report. PURPOSE The purpose of this audit is to determine whether the Contractor is complying with key terms and provisions of their agreements with the City regarding bus shelters and street furniture, and directory structures in the Lincoln Road area. SCOPE 1. Determine compliance with the key provisions of the two agreements, regarding quarterly revenue receipts, advertising, and insurance coverage, number of shelters I street furniture and directories to be provided for bus shelters, street furniture and Lincoln Road directories. 2. Verify that the Finance Department is reviewing the accuracy and timeliness of revenue receipts, and properly entering them into the City's Financial System. 3. Physically inspect bus shelters, street furniture and Lincoln Road directories to ensure proper maintenance and cleanliness, in accordance with the agreement. PROCESS DESCRIPTION Bus shelters and street furniture are constructed or replaced, operated, and maintained as mutually agreed between the City and the Contractor. The agreement for bus shelters and street furniture calls for the installation and maintenance of 107 bus shelters and street furniture to consist of the following: maximum of 180 bus benches; minimum of25 directory structures; minimum of 300 waste receptacles; minimum of 50 bicycle racks; minimum of 20 multi-purposes pillars; and a minimum of 75 news paper rack. The initial agreement for Lincoln Road Directories specifies the installation and maintenance of 10 directory structures and 10 street and block name signs. A subsequent Page2of10 Internal Audit Report Bus Shelters and Lincoln Road Directories Agreements May 28, 2010 amendment added an additional directory structure and 1 0 more street name signs. All activities related to revenue generation from advertising are the responsibility of the Contractor, who is to ensure that this is done in compliance with Federal, State, County and City laws, rule and regulations. The City shall receive revenue payments by the 51h day of the month following the end of each quarter, consisting of one quarter of the minimum annual guarantee, plus a percentage of net revenue sharing. Lincoln Road directory structures were constructed and are being operated and maintained by the Contractor. Similarly, all advertising and compliance with laws, rule and regulations is the responsibility of the Contractor. Revenue payments to the City are also to be submitted by the 51h day of the month following the end of each quarter. These consist of one quarter of the minimum annual guarantee per structure or a percentage of total net revenue for the quarter, whichever is greater. The Public Works Department, through its Special Projects Coordinator, oversees new construction and/or replacement of bus shelters and street furniture, and Lincoln Road advertising directories. Public Works also monitors contractor's maintenance of these structures, as well as reviews quarterly revenue receipts and insurance coverage required under the terms of the agreement. This specifies that bus shelters and street furniture "shall be maintained in a neat and clean condition and in good repair at all times." The Contractor's maintenance program, included as part of the agreement, describes monthly inspections of these structures, and cleaning on a weekly basis. These include scheduled or instant repair requirements, graffiti and sticker removal, etc. The Finance Department has the responsibility of ensuring that revenue payments are accurately calculated and received from the Contractor within the established payment timeframe, as well as collect payment of any revenue shortages and late payment fees. FINDINGS, RECOMMENDATIONS, AND MANAGEMENT RESPONSES 1. Finding-Revenue payments made by the Contractor for Lincoln Road advertising were short of Minimum Annual Guarantees. At the time the agreement between the City and the Contractor was signed for Lincoln Road directory structures in April2001, these directory structures were not in place. When the initial agreement was amended on November 2002, the initial term was extended from five to seven years, but the amendment specifically stated that the commencement date remained the same or April18, 2001. The Contractor agreed to pay the City the greater of an annual amount per structure or a percentage of net advertising revenues, as summarized below: YEAR Net Revenues 1 20% 2-3 25% 4-5 28% 6-7 30% 8-12 (extension) 30% According to the Contractor, there were no advertising revenues until January 2003, since the structures were in the development and construction phases, and the first revenue payment was made for the quarter ending March 31, 2003. This payment was calculated based on the Page 3 of 10 Internal Audit Report Bus Shelters and Lincoln Road Directories Agreements May 28, 2010 net revenue percentage for Year 1 (20 %) instead of the percentage for Year 2 (25 %). According to our calculations (see Exhibit A), the impact of the Contractor's interpretation for the first contract year represents a shortage of $47,236 in revenue payments to the City. It should be noted that the Special Projects Coordinator in the Public Works Department made an inquiry to the Contractor on July 2007, regarding the discrepancy of revenue percentages in the payment calculation, but there was no follow-up to the response provided by the Contractor. The Contractor contended that when the contract was signed, the Lincoln Road directories did not exist and no revenues were being generated; that an amendment to the original agreement adjusted the contract start date from April18, 2001 to November 15, 2002; and that Clear Channel started receiving revenues in January 2003, at which time they began following the revenue percentage sharing with the City. Recommendation(s) Since the Contractor is calculating quarterly revenues due to the City based on an incorrect contract start date, the terms of the agreement and subsequent amendment, should be brought to their attention, specifically the fact that the commencement date of the agreement remained as April18, 2001, as stated on page 2 of the amendment to the agreement executed November 13, 2002. In conjunction with this, the City should inform the Contractor of the revenue shortage amount for the Lincoln Road directories and request payment of revenues due. Contractor's Response Here is the correspondence from our July 2007 response mentioned above, which remains our point of contention. Please note that since we did not receive a reply, we believed that the issue was resolved. Hi Leo, We have reviewed your comments below and looked into the issue. We don't agree with your assessment due to the following reasons: 1. The Lincoln Road Directories were not in existence when we entered into the contract, thus no revenue was generated during the development and build-out period. The directories were still to be designed, manufactured, and installed. In addition, shortly before construction start, the city changed their previous instructions regarding permitting, which added some more time to it. 2. While the agreement is dated April18, 2001 the City and our company agreed in Nov 2002 to adjust the contract start date to 11115/02 due to the facts listed above. 3. We then had to develop the business (i.e. market the opportunity to the advertising industry, create sales demand, etc.) and did not have any revenues until January 1, 2003. From then on, we followed the revenue percentage share exactly as listed in the agreement. We believe that we have made all payments correctly. Please let me know how we can further be of assistance or if you wish to discuss this matter. Regards, Martina City's Response (Public Works) Contractor will be notified to pay balance due. The agreement, dated November 13, 2002, extended the contract by two years, but it did not change the start date. The agreement Page 4 of 10 Internal Audit Report Bus Shelters and Lincoln Road Directories Agreements May 28, 2010 extended the contract by two years in consideration of ten additional street name signs and one additional two-sided directory structure to be placed at the intersection of James Avenue and Lincoln Road, at no cost to the City. Although Clear Channel did not generate revenue during the development and construction period, the contract start date remained April 18, 2001. Therefore, the City's percentage of total net revenues also begins with the contract's start date. 2. Finding -The Contractor consistently submitted late quarterly revenue payments. Both agreements with the Contractor state that the City shall receive revenue payments no later than the fifth day of the month after the close of the quarter. The agreements also state that payments not made on or before the due date shall be subject to interest at a rate of 12 % per annum, from the payment due date until the time the payment is received by the City. We found that throughout the life of both agreements, the Contractor has consistently submitted the payments late. For the calculation of late charges, we used the number of days from the due date to the date the Contractor sent the payment, since the Finance Department does not date stamp payments when received. The total of uncollected charges for late revenue payments amounts to $8,792, consisting of $2,234 for the agreement on Lincoln Road directory structures since April 2003 (see Exhibit A), and $6,558 for payments on the bus shelter agreement since November 2002 (see Exhibit B). Recommendation(s) The Contractor should be informed and billed for the uncollected charges due to the City on late revenue payments during the life of both agreements. If the City and Contractor feel that the five day payment requirement is not feasible for these types of agreements, then consideration should be given to amend the established due dates within the agreements. Contractor's Response The President of Clear Channel Adshel, had a personal conversation with the Public Works Director very early in the contract period when we realized that the payment date should have been much later then the 5th of the month. It was mutually agreed that it wasn't physically possible to close the monthly books, reconcile revenue and cut a check and have it received by the City, all by the 5th of the month. We both felt that this must have been a typo and should have been the 25th, or at least the 15th. We then asked the contract be changed to reflect a more realistic date and to prevent exactly what is happening now. The Public Works Director said that in order to do that we would have to go before the City Commission and he requested not to go before them for this. It was verbally agreed that we would send the payment as soon as we could, following the end of each quarter. City's Response (Public Works) The Contractor will be advised that the payment due date remains the same. However, the Contractor will also be advised that the City is willing to consider modifying the due date based upon a review of the process required to calculate the amount due to the City. Internal Audit Observation Collection of late fees should be addressed with the contractor for both agreements. In addition, any changes to the agreement should be approved by the City Commission. 3. Finding -Bus Shelters are not maintained as required by the agreement. We selected a sample of 20 bus shelters of the 1 00 identified by the Public Works Department and a current maintenance report summary prepared by the Contractor. The shelters were Page 5 of 10 Internal Audit Report Bus Shelters and Lincoln Road Directories Agreements May 28, 2010 initially visited on March 24, 2009 through March 25, 2009 to inspect them for adequacy of advertising display contents, accessibility, cleanliness/appearance, and public safety. A follow-up inspection was done several days later on April 3, 2009, to allow time for maintenance work to be done on those shelters where deficiencies were observed during the initial inspection. We found eight shelters that had not received adequate maintenance by the Contractor to remove graffiti on the glass panels, and painted or metal surfaces. The Contractor's maintenance program requires the cleaning of bus shelters and street furniture structures, including graffiti removal, to be done weekly. One of the bus shelters inspected is in a poor state of repair, missing the back panels of the structure. The improper appearance of bus shelters and street furniture presents a negative image of the City. We also inspected all Lincoln Road directory displays for advertising content and appearance; these were all adequate. Recommendation(s) The Contractor should comply with their maintenance program for the proper maintenance and appearance of the bus shelters. We also recommend that the City periodically conduct their own inspections of these structures and street furniture to ensure the Contractor is complying with their obligations under the agreement. Contractor's Response Currently, Clear Channel Outdoor is in the final stages of completing the street furniture program. Within this program we are obtaining new bus shelter sites along with converting all existing structures to the new design. In 2009, a program was implemented to repaint and replace the glass of the structures pending conversion to the new design. The manufacturer, Daytech, of the old style units is no longer in business and replacement parts for this particular model are nonexistence. We make every effort to maintain these old units with existing materials until we have the opportunity to complete the conversions. The bus shelters are maintained on a weekly basis and on occasion, we are notified by the Public Works Department of various maintenance issues, which are addressed and repaired within a 24 hour period. City's Response (Public Works) The Public Works Department performs periodic inspections to verify compliance with the agreement. When deficiencies are found, they are communicated to the Contractor for correction. The Public Works Department has increased the frequency of its 2009/10 fiscal year inspections to address cleanliness and graffiti issues. 4. Finding -Quarterly revenue receipts are not being processed in a proper or timely manner. The Contractor submits quarterly payments for advertising revenues due for bus shelters (customer # C 12269) and Lincoln Road directories (customer # C 12269A) to the Revenue Supervisor in the Finance Department. Financial Analysts in the Department prepare payment vouchers with the information received from the Contractor (transmittal letter, quarterly revenue reports, and check payments) and include the date they process the payments. However, none of these documents are being stamped to evidence date received. Although the payment due date and the revenue guarantee terms are detailed on the payment voucher, the Finance Department does not take any action when these requirements are not met by the Contractor. Both agreements require revenue payments to be received on or before the 5th day of the month following the close of a quarter. Additionally, these revenue payments are not being recorded on the City's Financial System in a timely manner, since the posting date ranges from 5 to 63 days for customer C 12269 and from 3 to 50 days for customer C 12269A. Page 6 of 10 Internal Audit Report Bus Shelters and Lincoln Road Directories Agreements May 28, 2010 Recommendation(s) The Finance Department should date-stamp payment correspondence from the Contractor to accurately document when these are received. This date should be reflected on the payment vouchers prepared by the Financial Analyst(s). The terms of the agreements regarding due date should be verified by Finance, and any discrepancies identified should be addressed accordingly. City's Response (Finance) The Finance Department will date-stamp payment correspondence from the Contractor to document when payments are received. The date will be reflected on the payment vouchers prepared by the financial analyst responsible for recording these transactions. The Finance Department Collections Supervisor along with the Contract Manager from the Public Works Department will monitor payments from the Contractor and address late payments accordingly. 5. Finding -.General Ledger account is incorrectly titled. The title for general ledger account# 011-8000-362400-Rent-Bus Shelters-Taxable-does not properly reflect the purpose and use of this account, since revenues received for Bus Shelters, as well as Lincoln Road directories are posted to the account. Additionally, these revenues are not taxable, although both agreements state that payments submitted by the Contractor were to include applicable Florida State Sales and Use taxes. It appears that tax payments were being initially sent together with the revenue payments. However, since February 2003, the Contractor informed the City that advertising revenues were not taxable by the State. The City acknowledged and agreed with the Contractor on this issue. Recommendation ( s) The Finance Department should evaluate whether it wants to continue posting Lincoln Road area advertising revenues to the same general ledger account set up for bus shelters revenues, or modify the account title to properly reflect the two areas. In addition, the title's reference to taxable should be removed. City's Response (Finance) The reference in the general ledger title to "taxable" has been removed. Currently, Finance Department Revenue staff record Lincoln Road area advertising revenues to the same general ledger account set up for bus shelters revenues as originally requested by staff managing the contracts. Revenue staff will coordinate, with the Public Works Department and Chief Accountant's Office, to create an additional general ledger account to separately record the revenues for the aforementioned activities. Accounts were added May 12, 2010. EXIT CONFERENCE An exit conference call was held on January 19, 2010 with Paul Newman, Vice President of Finance, Clear Channel Outdoor -Miami, James Sutter, Internal Auditor and Luis Lopez, Audit Consultant. Their written management responses were received on February 11, 2010 whereby they disagreed to findings one and two and stated their position. Finally, management responses were received from affected City departments on March 20, 2010 and May 27, 2010 so that the audit report could be issued shortly thereafter. JJS:LL:II Audit performed by Luis Lopez, Internal Audit Contractor Page 7 of 10 Internal Audit Report Bus Shelters and Lincoln Road Directories Agreements May 28, 2010 F:\obpi\$AUD\INTERNAL AUDIT FILES\DOCOS-09\REPORTS-FINAL\Bus Shelters-Lincoln Rd Directories.doc cc: Jorge Gomez, Assistant City Manager Fred Beckman, Public Works Director Fernando Vazquez, City Engineer Patricia D. Walker, Chief Financial Officer Paul Newman, Vice President of Finance, Clear Channel Outdoor-Miami. Page 8 of 10 Internal Audit Report Bus Shelters and Lincoln Road Directories Agreements May 28, 2010 Exhibit A-Lincoln Road Advet·tising (I) (2) Period Revenue Contract •y., CCA % Payment Year(s) Guarantee Year I' aid Due 4/18/0 l-I 20% 4/30/02 May-Dec 02 25% 2 Jan 03-Mar 03 50,965 25% 20% 12,741 Apr 03-J un 03 68,240 2&3 25% 20% 15,691 I .lul 03-Sep 03 95,860 25% 20% 23,965 Oct 03-Dec 03 55,698 25% 20% 13,925 3 Jan 04-Mar 04 46,150 25% 25% 10,897 Apr-04 22,325 25% 25% 5,581 May 04-Jun 04 49,275 28% 2 25% 13,797 Jul 04-Sep 04 68,300 4 28% 25% 19,124 Oct 04-Dec 04 65,074 28% 25% 18,221 Jan 05-Mar 05 77,700 28% 25% 21,756 Apr 05-Jun 05 98,300 4&5 28% 25% 27,524 3 Jul 05-Sep 05 96,550 28% 25% 27,034 Oct 05-Dec 05 90,900 28% 25% 25,452 5 Jan 06-Mar 06 96,480 28% 28% 27,014 Apr-06 38,800 28% 28% 10,864 May 06-Jun 06 62,300 30% 4 28% 18,690 Jul 06-Sep 06 134,950 6 30% 28% 39,667 Oct 06-Dee 06 131,525 30% 28% 39,458 Jan 07-Mar 07 129,007 30% 28% 38,702 Apr 07-Jun 07 125,877 6&7 30% 28% 37,110 5 Jul 07-Scp 07 138,842 30% 28% 41,653 Oct 07-Dcc 07 143,187 7 30% 28% 42,956 Jan 08-Mar 08 126,085 30% 30% 37,826 Apr 08-Jun OS 125,056 7 & 8 30% 30% 37,517 6 Jul 08-Sep 08 98,137 8 30% 30% 28,758 Oct 08-Dec 08 90,854 30% 30'% 27,256 (l) Contract year used by Clear Channel Adshcl (CCA) in revenue sharing calculations. (2) Payment due and sent amounts arc net of costs for maps and mall directories. (2) Payment Sent 0.00 0.00 10,193 12,279 19,172 11,140 !0,897 17,900 17,075 16,269 19,425 24,575 24,138 22,725 27,014 28,308 36,967 36,827 36,122 34,593 38,876 40,092 37,825 37,517 28,758 27,256 (3) No difTerenee is noted due to percentage rate guanmteed to percentage rate paid being equal. (4) Late Charge is calculated based on payment sent, 12% per annum, days late and 365 year base. (*) Quarterly revenue was estimated based on payment amount posted to EDEN. Page 9 of 10 (4) Difference Date Days Late Paid Late Charge 2,548 04/15/03 lO 34 3,412 07/16/03 ll 44 4,793 10/!7/03 12 76 2,785 0 l/14/04 9 33 (3) 04/13/04 8 29 1,478 07/15/04 10 59 2,049 10/13/04 8 45 1,952 Reports not available (*) 2,331 04/14/05 9 57 2,949 071!4/05 9 73 2,896 l0/13/05 8 63 2,727 0 l/17/06 12 90 (3) 04/20/06 15 133 1,246 38,918.00 15 140 2,700 10/30/06 25 304 2,631 0 l/17/07 12 145 2,580 04/!7/07 12 143 2,517 071!9/07 14 159 2,777 101!8/07 13 166 2,864 Ol/15/08 10 132 (3) 041!4/08 9 ll2 (3) 07/l0/08 5 62 (3) lOll 0/08 5 47 (3) Ol/15/09 10 90 Internal Audit Report Bus Shelters and Lincoln Road Directories Agreements May 28, 2010 Exhibit B-Bus Shelters Amount Revenue Sharing Payment Payment Other Pmts Period Guarantee Revenues •y., Amount Due Sent or Credits Nov 0 1-Jan 02 15,000 Reports 10% - 15,000 Not 10% Reports Not Available Available - May-Jul 02 15,000 10% Aug-Oct 02 15,000 262,585 10% 26,259 41,259 26,259 16,707 Nov 02-Jan 03 30,000 220,660 10% 22,066 52,066 22,066 30,000 Feb-Apr 03 30,000 270,578 IO'X. 27,058 57,058 57,058 May-Jul 03 30,000 260,901 10% 26,090 56,090 40,753 15,337 Aug-Sep 03 20,000 106,182 10% 10,618 30,618 6,526 (24,092) Oct-Dec 03 30,000 267,978 10% 26,798 56,798 50,096 (6,702) Jan-Mar 04 30,000 222,200 10% 22,220 52,220 52,220 Apr-Jun 04 30,000 300,407 10% 30,041 60,041 60,041 Jui-Scp 04 30,000 286,374 10% 28,637 58,637 58,637 Oct04 85,909 10% 8,59! 30,000 73,940 62,157 1!,783 Nov -Dec 04 235,660 !5% 35,349 Jan-Mar 05 30,000 254,430 15% 38,165 68,165 68,164 Apr-Jun 05 30,000 277,748 !5% 41,662 71,662 71,662 .lui-Sept 05 30,000 329,467 15% 49,420 79,420 79,420 Oct-Dec 05 30,000 418,665 15% 62,800 92,800 92,800 Jan-Mar 06 30,000 354,481 15% 53,!72 83,172 83,!72 Apr-.ltm 06 30,000 385,53! 15% 57,830 87,830 87,830 Jui-Sep 06 30,000 311,323 15% 46,698 76,698 76,699 Oct06 204,264 !5% 30,640 30,000 106,566 95,084 !!,482 Nov-Dec 06 229,630 20% 45,926 Jan-Mar 07 30,000 216,279 20% 43,256 73,256 73,256 Apr-.ltm 07 30,000 5!2,547 20% 102,509 132,509 132,509 Jul-Scp 07 30,000 364,077 20% 72,815 102,815 102,815 Oct-Dec 07 30,000 451,823 20% 90,365 120,365 120,365 Jan-Mar 08 30,000 243,540 20% 48,708 78,708 78,708 Apr-Jun 08 30,000 478,25! 20% 95,650 125,650 125,650 Jul-Sep 08 30,000 249,90! 20% 49,980 79,980 79,980 Oct-Dec 08 50,000 346,653 20%. 69,331 119,331 69,331 50,000 (*) Late Charge is calculated based on payment sent, 12% per annum, clays late and 365 year base. Page 10 of 10 Date Days (*)Late Paid Late Charge 11/20/02 15 129 02/18/03 13 94 05/13/03 8 150 Reports Not Available 10/27/03 22 47 01/15/04 10 165 04/13/04 8 137 07/!5/04 10 197 l 0/!3/04 8 !54 01/!3/05 8 163 04/!4/05 9 202 07/14/05 9 2!2 10/13/05 8 209 Ol/!7/06 !2 366 04/20/06 !5 410 07/20/06 15 433 10/28/06 23 580 Ol/17/07 12 375 04117/07 12 289 07/19/07 14 6!0 I 0/18/07 !3 439 0 l/15/08 lO 396 04/14/08 9 233 07/!0/08 5 207 10/10/08 5 131 Ol/15/09 !0 228