Q: In the next-to-last paragraph, you say, "The proceedings were 
     also counter to APS bylaws."
A: Okay.  I understood--Bill Reppy--I understood--Bill Reppy told 
     me that.  That's what he said.  I think Bill Reppy was 
     referring to the invalidity of the process as a de novo 
     process.  And I understood that it meant the bylaws, but I 
     was wrong.
Q: So that's not true.
A: I thought it was true then.  I know now it's not, because I 
     spoke to Bill Reppy and he clarified that for me.
Q: So you didn't review the bylaws before making that statement.
A: I was told--I understood--I was told by Bill Reppy, so I 
     relied on what he was saying.  So essentially I was relying 
     on counsel in the appeals process.
Q: It would shorten things if you would answer the question first 
     and then explain, so I don't have to ask it again.
A: Well, I don't know what you mean.
Q: You did not review the bylaws before making that statement, 
     did you?
A: I wasn't allowed to see the bylaws.  I requested the bylaws.  
     I was declined that request.  I was not allowed to see 
     bylaws.
Q: Yes or no?  Did you review the bylaws before you made that 
     statement?
A: I wasn't allowed to see them.  I didn't have them.
Q: So the answer is no, you did not?
A: No, because I didn't have them.
Q: Oh, you can say it.  Thank you.  Have you reviewed the bylaws 
     since?
A: Uh-huh (affirmative).  Yes.
Q: And you know that the appeals process is not mentioned in the 
     APS bylaws; is that correct?
A: That's right, and that's another indication of arbitrary and 
     capricious policies, because the policies are not stated in 
     writing.  So that supports my arbitrary and capricious.

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