DISTRICT OF COLUMBIA COURT OF APPEALS

430 E Street NW, Washington, DC 20001

18-AA-500 & 501

CYNTHIA CARSON, ET AL
v.
D.C. ZONING COMMISSION
Respondent
______________________________________________________
18-AA-1146
JAMES FOURNIER, ET AL.
Petitioners.
v.
D.C. MAYOR’S AGENT ON HISTORIC PRESERVATION
Respondent
______________________________________________________
REPLY IN SUPPORT OF WOLKOFF’S JOINT EMERGENCY
MOTION FOR AN INJUNCTION DATED AUGUST 30, 2019

Here come two Pro se Petitioners, Daniel Wolkoff and Chris Otten, with a reply in

support of the Joint Emergency Motion for an Injunction as filed by Daniel Wolkoff on August

30, 2019.

Vision McMillan Partners, LLC, intervened and filed a Response to the Joint Emergency

Motion on September 9, 2019, supporting by reference responses from other parties, including

the Deputy Mayor for Planning and Economic Development (DMPED) and the District of

Columbia Mayor's Agent on Historic Preservation (DCMA), both which filed responses on

September 6, 2019.

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 Pursuant to Court Rules 26 & 27, Petitioners Wolkoff and Otten file this timely reply to

challenge the baseless positions of all parties in opposition to an immediate injunction of the

demolition activities at the subject site in question -- the nationally registered historic McMillan

Sand Filtration Plant and Park ("McMillan Park").

Update on Deleterious Activities at McMillan Park

As shown by the Wolkoff Declaration dated August 29, 2019, and attached to the August

30, 2019, Joint Emergency Motion for Injunction, there are demolition activities underway at

McMillan Park and they have been exceedingly ramped up since the Court ordered a briefing

calendar for DCCA Case Nos. 18-AA-500 & 501.

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 DMPED responds to Petitioner's claims stating, "None of the filter beds or other

historical structures on the Site have been demolished pursuant to permit No. D1600814, nor is

such activity anticipated for at least four months," referencing a declaration from a DMPED

staffer. See, Opposition of Intervenor The Office of Deputy Mayor for Planning and Economic

Development to Daniel Wolkoff's Emergency Motion for an Injunction ("DMPED.Opp"), dated

September 6, 2019, at page 7.

It is within the ken of laypeople to understand that indeed the historically protected

topography at McMillan Park is being permanently altered. The open plains of the site are being

torn up and out. With these adverse activities, heavy demolition trucks are scraping the tops of

the historically protected water filter cells below. The manhole portals on top of the cells have

been moved off their foundations in some instances and those remaining in place have been

clawed at and damaged. This Court can see how far along these demolition activities have come

since the photos attached in Wolkoff's Declaration dated August 29, 2019.

Despite the obvious damage to the historic site and its assets now, DMPED expects the

Court and public to believe the current activities at McMillan Park, "... includes removing topsoil

from the concrete tops of the filter beds, which are made of unreinforced concrete, to determine

the extent of damage." DMPED.Opp at page 7.

The extent of the damage underway is bad, very bad. This damage however is largely, if

not completely, the direct result of the current illegal activities at the site at the hands of a

overzealous agency seeking to prematurely and permanently demolish these historic assets.

Without a doubt, as shown in the photos and any visit to the site, the historic characteristics and

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assets -- the open green plains, filter beds, and water cells -- are being severely altered and

damaged in this act of demolition preparations.

Laughably, DMPED staff says, "The current on-site activity, and any activity planned for

the coming months, involves testing the means and methods of anticipated construction to ensure

the historic structures on the McMillan Site are protected." DMPED.Opp at page 7.

Further, DMPED states, "... the Deputy Mayor will provide updates to community

groups, including the affected ANC and the McMillan Advisory Group, before demolition of

historic structures under the relevant permits commences." DMPED.Opp at page 8.

Despite these bold yet meaningless statements by DMPED, no one in the community was

made aware of when the very large machinery and trucks and substantial work at McMillan Park

now underway would begin. No one anticipated this current premature alteration and demolition

activities because it wasn't announced, and indeed was only ramped up after the Court issued a

briefing calendar on August 26, 2019, in DCCA Case Nos. 18-AA-500 & 501.

Responses in Opposition to the Emergency Injunction Are Baseless

DMPED is an agency of the District of Columbia and its taxpayers. DMPED admits the

current activities are born out of their office. DMPED.Opp at page 8. ('Moreover, no demolition

of the underground filter beds will take place at the Deputy Mayor’s behest under permit No.

D1600814 until several additional steps have been completed . . . The 2013 WASA

proceedings are not and have never been part of the present appeal, and that work was not

undertaken by the Deputy Mayor.')

DMPED, and others in opposition to the emergency injunction, wrongly claim:

Wolkoff has not argued that he is likely to prevail on the merits, and the merits
were decided in the Deputy Mayor’s favor in FOMP II – WRONG!

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 Petitioners are not sure what part of pending claims before the Court in DCCA Case Nos.

18-AA-500 and 501, DMPED can't understand. Petitioners survived a Motion to Dismiss

exactly because we argued that our pending claims are quite different and distinct from those

adjudicated in FOMP II. Those merits will be argued in briefing and a status quo posture to

enjoin permanent irreversible damage to the existing McMillan Park historic assets is critical

until this Court can hear those claims. We will remind DMPED that the DC Office of Planning

has demonstrated on the record that indeed many of the water filtration cells at McMillan Park

can be restored for a price, but not if they are purposefully altered, damaged, and ultimately

demolished. See, D.C. Office of Planning Report, “Summary of Recommendations

for Site Revitalization” dated, February 2002, at page 14.

Moreover, the "topsoil" DMPED references was deliberately filled more than 100 years

ago at the direction of Olmsted Jr, the designer of McMillan Park. DMPED wants to argue that

the historically protected plains of the site that which this topsoil largely consists of is some kind

of basic turf and lawn (as if in front of one's condo building) and thus has no merit in the

historically protected topography and aesthetic of the site. That couldn't be further from the truth

and the alteration and removal of this topography is a direct injury to the assets and characteristic

of the site.

The boundaries of the historic district include 19 contributing buildings, 66 contributing

structures (including the surviving 22 of29 sand bins), two sites (the Olmsted-designed
landscape and the McMillan Reservoir basin), and one object (the McMillan Fountain).

In 1907, Frederick Law Olmsted was hired to design the park, which resulted in a
picturesque drive and walking paths around the reservoir, landscaped grounds at the
filtration plant, and a recreation area at the southern end of the site, culminating at a high
point with a fountain, designed by architect Charles Platt and sculptor Henry Adams, in
honor of James McMillan.

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 The designation of the reservoir and sand filtration site as a publicly accessible park was
a testament to his efforts to beautify the nation's capital by enlarging and enhancing its
system of public open spaces as part of the City Beautiful Movement at the turn of the
century.

The underground filter beds were covered with topsoil to form an extensive flat lawn,
while the linear courts were planted with allees of cork trees to either side of the sand
bins, sand washers and regulator houses which aligned the central axis of the courts.

The grassy open space of the site actually corresponds with the roofs of the twenty,
below-grade concrete filter beds that have been covered by a layer of fill. To construct
these filter beds, the site's topography was re-graded, and an extensive campaign of cut
and fill created an artificial topography that rises approximately sixteen feet above the
level of Channing Street to the south and is depressed approximately ten feet from the
level of Michigan Avenue to the north.

Excerpts from the approved 2013 Nomination Application registering McMillan Park as a
national historic landmark per the Historic Preservation Act.
https://www.nps.gov/nr/feature/places/13000022.htm

Wolkoff has not demonstrated that he is in danger of suffering irreparable harm –

WRONG!

Wolkoff, Otten, and the other Petitioners are found throughout the various agency records

across numerous years as testifying in opposition to DMPED’s McMillan Town Center project,

and along with it the demolition of most of the site's historic resources including nearly all of the

fascinating and historically protected underground water cells.

Petitioners Wolkoff and Otten are members of DC for Reasonable Development,

McMillan Coalition for Sustainable Agriculture, The McMillan Conservancy, and Friends of

Lincoln's Cottage -- all organizations that have a direct organizational mission to protect

McMillan Park and a clear nexus with the outcomes at McMillan Park.

The alteration and demolition activities presently underway -- no matter if DMPED calls

its "testing" of the site -- is actually testing the bar of irreversible damage of a protected site as

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under the Historic Preservation Act and the Secretary of Interior Standards for Historic

Preservation (attached).

Joint Petitioners all have a definable aesthetic, financial, and personal stake in the

preservation of the site according to the standards found in the law and in the preservation

covenants permanently running with the McMillan Park deed. Again, as demonstrated

thoroughly throughout the record and as will be further demonstrated in briefing of the pending

claims.

The balance of the equities favors the intervenors – WRONG!

McMillan Park is a public historic site. Its owned by the public, including Petitioners, its

upkeep is being funded by taxpayers, its loved by the Petitioners for many reasons, its visited by

Petitioners regularly no matter the allegations of DMPED, and its value in benefit to the

environment -- air, water, noise -- cannot be underestimated for Petitioners well being. These

extent qualities and existing aesthetic of the site are undoubtedly providing value and enjoyed by

Petitioners now. There are no equities in favor of DMPED that support the breaking of the law

and directives of this Court.

"Thus, as long as legal obstacles to the completion of the entire project remain,
demolition of historic structures on the Filtration Complex will not be consistent with the
purposes of the Historic Preservation Act. One remaining legal obstacle is the on-going
appeal of the Zoning Commission’s approval of the PUD application for the project. Until
that appeal and any other obstacles to the applicant's ability to complete the project are
resolved, the applicants may not commence demolition.”

Page 52 of DCCA decision on Friends of McMillan Park vs Mayor's Agent Peter Byrne
(DMPED) petition for review of appeal stated:
https://www.dccourts.gov/sites/default/files/2019-05/18-AA-357.pdf

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 The Court has said any legal obstacles prevents the demolition of the site. Conveniently,

DMPED forgets that on August 26, 2019, this Court ordered briefing as to pending claims by the

Pro se Petitioners. Instead DMPED wants to deflect away from this fact and point to

administrative appeals of the Demolition Permit, which only provides further demonstration of

"obstacles" to starting and finishing DMPED's alteration and demolition of this historic national

landmark.

Purposefully bringing permanent damage to any historic sites, let alone one that has not

had all administrative and judicial reviews exhausted is anathema to the Historic Preservation

Act. The equities as such favor the Petitioners who seek to protect and preserve McMillan Park

and its historic characteristics, topography, and assets according to the Secretary of Interior

Standards for Historic Preservation.

An injunction would be contrary to the public interest – WRONG!

Speculation provided by DMPED of what could happen at the site in the future is far

different than preserving the public interest in this national historic landmark at McMillan Park

now. It is within the public interest, namely that DC for Reasonable Development, McMillan

Coalition for Sustainable Agriculture, The McMillan Conservancy, and Friends of Lincoln

Cottage – as Pro se Petitioners are members and all of whom have contested DMPED's proposed

project since day one. None of the officials -- City Council, Mayor, Advisory Neighborhood

Commission -- are above the law or supersede the directives of this Court.

DMPED is lying to the public and the Court, saying, "The current activities on the Site

consist primarily of topsoil removal and structural testing—that is, preparation work that does

8
not affect historical structures." DMPED.Opp at 12. Clearly they are damaging the historic

assets and protected topography of the site.

The public interest is to keep the status quo until all pending claims before agencies and

the Court are adjudicated.

CONCLUSION

For the reasons above, Petitioners ask the court grant the Joint Motion for Emergency

Injunction dated August 30, 2019.

Signed,

Daniel Wolkoff

Chris Otten

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ATTACHMENTS
Secretary of Interior’s Standards and guidelines for Rehabilitation of Historic Buildings
and McMillan restrictive Covenants GSA assigned in the deed upon sale to DC 1987

“any and all rehabilitation and renovation work at the parcel, will be undertaken in
accordance with the “Secretary of Interior’s Standards for Rehabilitation and Guidelines
for Rehabilitating Historic Buildings” (Standards) --substitute for Section 106

Secretary of interior’s Standards and Guidelines for Rehabilitation of Historic Buildings

The following Standards for Rehabilitation are the criteria used to determine if a rehabilitation
project qualifies as a certified rehabilitation. The intent of the Standards is to assist the long-term
preservation of a property’s significance through the preservation of historic materials and
features. The Standards pertain to historic buildings of all materials, construction types, sizes,
and occupancy and encompass the exterior and the interior of historic buildings. The Standards
also encompass related landscape features and the building’s site and environment, as well as
attached, adjacent, or related new construction. To be certified, a rehabilitation project must be
determined by the Secretary to be consistent with the historic character of the structure(s) and,
where applicable, the district in which it is located. The following Standards are to be applied to
specific rehabilitation projects in a reasonable manner, taking into consideration economic and
technical feasibility. A property shall be used for its historic purpose or be placed in a new use
that requires minimal change to the defining characteristics of the building and its site and
environment.

The historic character of a property shall be retained and preserved. The removal of historic
materials or alteration of features and spaces that characterize a property shall be avoided.

1. Each property shall be recognized as a physical record of its time, place, and use.
Changes that create a false sense of historical development, such as adding conjectural
features or architectural elements from other buildings, shall not be undertaken.
2. Most properties change over time; those changes that have acquired historic significance
in their own right shall be retained and preserved.
3. Distinctive features, finishes, and construction techniques or examples of craftsmanship
that characterize a historic property shall be preserved.
4. Deteriorated historic features shall be repaired rather than replaced. Where the severity of
deterioration requires replacement of a distinctive feature, the new feature shall match the
old in design, color, texture, and other visual qualities and, where possible, materials.
Replacement of missing features shall be substantiated by documentary, physical, or
pictorial evidence.
5. Chemical or physical treatments, such as sandblasting, that cause damage to historic
materials shall not be used. The surface cleaning of structures, if appropriate, shall be
undertaken using the gentlest means possible.
6. Significant archeological resources affected by a project shall be protected and preserved.
If such resources must be disturbed, mitigation measures shall be undertaken.
7. New additions, exterior alterations, or related new construction shall not destroy
historic materials that characterize the property. The new work shall be differentiated
from the old and shall be compatible with the massing, size, scale, and architectural
features to protect the historic integrity of the property and its environment.
8. new additions and adjacent or related new construction shall be undertaken in such a
manner that if removed in the future, the essential form and integrity of the historic
property and its environment would be unimpaired.
McMillan Sand Filtration Site

Summary of Recommendations
for Site Revitalization
February, 2002

Government of the District of Columbia

Office of Planning & Department of Housing and Community Development
 McMillan Sand Filtration Site

TABLE OF CONTENTS

Basic Site Facts 3

Historic Preservation Parameters 4

Community Goals 6

Site Conditions 12

Revitalization Needs & Current 17

Development Activity

Revitalization Scenarios & 24

Broad Stakeholder Participation

Key Planning Elements 36

“Making McMillan a Place” (Conceptual Diagram) 37

Next Steps Toward Implementation 38

Acknowledgements 40
 McMillan Sand Filtration Site

BASIC SITE FACTS

• 20 non-reinforced concrete cells about 1 acre each in

size and 2 courts; once connected to Reservoir site

• Approximately 25 acres total

• Conceived as part of Senator James McMillan Emerald

Necklace open space strategy for the Nation’s Capital;
Frederick Law Olmsted, Jr. hired as landscape architect

• Facility provided clean and safe drinking water until

outdated by technical advances

• Surplus site sold by federal government to District

government in 1987 for community development
purposes

• Listed on District’s Inventory of Historic Sites since 1991

3
McMillan Sand Filtration Site
HISTORIC PRESERVATION PARAMETERS
Historic Overview Collage

4
 McMillan Sand Filtration Site
HISTORIC PRESERVATION PARAMETERS

ƒ Built structures
above and below
ground on 25-acre
site are historic
ƒ On the DC
Inventory of
Historic Sites
ƒ Listing of site on
National Register is
pending
ƒ Ongoing
consultation
process
established by
MOA w/ US
Advisory Council
on Historic
N Preservation
(allowed sale to
District)

Planting Scheme by Frederick Law Olmsted, Jr.

5
McMillan Sand Filtration Site
SITE CONDITIONS
Stabilization of the site will
require a combination of
structural interventions:

Preservation – Reinforcing
the cell structure to
prevent future cracking
and to allow for re-use
either above or below
grade.

Fill – Compacting a cell

with sand to prevent
further cracking and
bulking and to allow for
above grade re-use.

Demolition – Removing a
portion or all of a cells
structure, particularly the
deck where there is
cracking and collapse.
Demolition costs include
amount for compacting the
land to make it suitable for
new development.
13
McMillan Sand Filtration Site

SITE STABILIZATION COSTS

CELL DESIGNATION

TYPE I TYPE II TYPE III

CELLS 19,22,23,24,26,2 10,11,12,13,14,15, 16,17,18,21

7,28,29 20,25

DESCRIPTION Built on fill, active Built in cut areas, Interior cells, built in
cracking, some active cracking cut areas, no signs
failures, add’l observed around of new cracking in
failures likely perimeter last 30 yrs.

Unstable, Unsafe Stable except at Stable

edges

OPEN SPACE

PRESERVE CELLS Not Feasible $2.02M per cell $1.79M per cell

DEMOLISH CELLS $860K per cell $860K per cell $860K per cell

FILL CELLS $440K per cell $440K per cell $440K per cell

FOUR STORY
BUILDING

PRESERVE CELLS Not Feasible $2.56M per cell $2.33M per cell

DEMOLISH CELLS $2M per cell $1.37M per cell $1.37M per cell
(Also Includes Site
Compacting Costs)
FILL CELLS $1.61M per cell $920K per cell $920K per cell

Source: C.C. Johnson & Malhotra, PC

14
 McMillan Sand Filtration Site
COST RANGES BY CELL CONDITION

TYPE I – Significant Deterioration – 8 Cells

Preservation Not Feasible

Fill for Open Space $3.52 M
Demolish for Building (4 stories) $16.0 M

TYPE II – Moderate Deterioration – 8 Cells

Fill for Open Space $3.52 M

Preserve for Building (4 stories) $20.5 M

TYPE III – Stable – 4 Cells

Fill for Open Space $1.76 M

Preserve & Open Space $7.16 M
Preserve for Building (4 stories) $9.32 M

TOTAL STABILIZATION COST RANGE***

Open Space - min $14.2M

Preserve for Building & Open Space - max $45.8 M

*** Cost do not include design and construction for preserving

and/or restoring the two (2) courts or any part of the Olmsted
scheme for the site.

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 McMillan Sand Filtration Site
CONCLUSIONS ABOUT SITE CONDITIONS

1. Site stabilization should occur on the entire site before

revitalization activities can occur and should occur as soon as
possible.

2. Final stabilization costs should be considered as a public

infrastructure investment.

3. The 4 TYPE III Cells are the most stable and should be
preserved and adaptively re-used as well as the 2 courts. These
cells are in the best location and in the best condition to
accommodate a central community open space.

4. The 8 significantly deteriorated TYPE I Cells are beyond

preservation and should be demolished. However, parts of the
column grid system could be maintained and incorporated into
future uses.

5. The 8 moderately deteriorated TYPE II Cells can be preserved

for adaptive re-use above and below grade or used as needed
to accommodate uses compatible with proposed revitalization
efforts.

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 McMillan Sand Filtration Site
REVITALIZATION NEEDS & CURRENT DEVELOPMENT ACTIVITY
The site is an
important
cultural
landscape in the
history of the
District of
Columbia. The
site is also one
of the few large
scale, District-
owned
revitalization
sites in Ward 5
and in the city.

Revitalization of
McMillan must
balance historic
PLANNED PROJECTS
ACRES OWNER preservation,
McMillan Sand Filtration Site 25 District community
2. Soldiers Home East Campus 49 Federal
impacts and
3. Soldiers Home West Campus (pending) 65 Federal
4. Rhode Island Metro/Brentwood Kmart 27.5 WMATA
economic
5. Proposed Conference Center / Hotel 5.48 District sufficiency.
6. Georgia Avenue / HU Town Center n/a Multiple
7. Brookland Metro Site + CUA Site 7.2 WMATA
8. Future New York Avenue Metro Area n/a Multiple
9. North Capitol Street Retail n/a Multiple
Also … Fort Totten Metro WMATA
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 McMillan Sand Filtration Site
REVITALIZATION NEEDS & CURRENT DEVELOPMENT ACTIVITY
Total Residents 16,048 (as of 1999)

Total # of Employees 22,000

Total # of Patients Served (annually) 560,000 (visitors also represent potential market)

Total # of Students (annually) 16,250 (parents also represent potential market)

Preferred Uses for Employees For sale housing, restaurants, dry cleaner, book store,
full service bank, post office, job training center, grocer,
fitness center, hotel/conference center, recreation

PRIMARY MARKET AREA SUPPORTABLE USES

A. Townhouse Sales 200 to 245 units

B. Condominium Sales 24 to 43 units annually (2000-2004)
C. Rental Apartments Approximately 120
D. Shoppers Goods (retail) Approximately 50,000 SF
E. Office 60,000 SF
F. N’hood Professional Offices Approximately 10,000 SF
G. Hotel 90 to 105 rooms

Townhomes
Condos Apts Retail Office Hotel
PLANNED PROJECTS
2. Soldiers Home East Campus x x x x x x
3. Soldiers Home West Campus x x
4. Rhode Island Metro/Brentwood Kmart x x x
5. Proposed Conference Center / Hotel x x
6. Georgia Avenue / HU Town Center x x x x x x
7. Brookland Metro Site + CUA Site x x x x
8. Future New York Ave Metro Area x x x x

9. North Capitol Street Retail x x

Also … Fort Totten Metro X X X

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 McMillan Sand Filtration Site
REVITALIZATION NEEDS & CURRENT DEVELOPMENT ACTIVITY
Open Space Analysis

There is essentially no publicly accessible open space within the Study Area.

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 McMillan Sand Filtration Site
REVITALIZATION NEEDS & CURRENT DEVELOPMENT ACTIVITY
Traffic Analysis & Intersections Performance

LOCATION LOS
1 – North Capital Street at Michigan Avenue D
2 – Michigan Avenue at First Street C
3 – Bryant Street at First Street C
4 – Harvard Street at 5th Street B
5 – Irving Street at North Capitol Street GSI
6 – Rhode Island Avenue at North Capitol GSI
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 McMillan Sand Filtration Site
REVITALIZATION NEEDS & CURRENT DEVELOPMENT ACTIVITY
Traffic Analysis & Intersections Performance
EXISTING AVERAGE DELAY/LEVELS OF SERVICE

AM Peak Hour PM Peak Hour

Intersection Average LOS Average Delay LOS

Delay Sec/veh.
Sec/veh.
Harvard St/5th St 14.7 B 16.8 B

Michigan Ave/1st St 24.9 C 22.2 C

Michigan Ave/North Capitol St 48.4 D 54.4 D

Bryant St/ 1st St 25.7 C 23.4 C

Source: O.R. George and Associates

AVERAGE DELAY/LEVELS OF SERVICE WITH PROJECTED WASHINGTON

HOSPITAL CENTER EXPANSION, 2015

AM Peak Hour PM Peak Hour

Intersection Average LOS Average Delay LOS

Delay Sec/veh.
Sec/veh.
Harvard St/5th St 15.8 B 17.6 B

Michigan Ave/1st St 33.2 C 35.2 D

Michigan Ave/North Capitol St 68.5 E 66.2 E

Bryant St/ 1st St 23.1 C 22.3 C

Source: O.R. George and Associates

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 CERTIFICATE OF SERVICE

I, Daniel Wolkoff, attest that copies of the included:

REPLY IN SUPPORT OF WOLKOFF’S JOINT EMERGENCY
MOTION FOR AN INJUNCTION DATED AUGUST 30, 2019
were sent by online court e-service & post mail to the following parties on
September 12, 2019, as follows:

RESPONDENT Joint Petitioners

District of Columbia Zoning Commission, James Fournier

Loren Ali Khan, Esquire, 441 4th Street NW, 69 Bryant Street NW
Suite 600S, Washington, DC 20001. Washington, DC 20001

James C. McKay, Jr. Esquire Linwood Norman

Senior Assistant Attorney General-DC 135 T Street NW
441 4th st. NW, 6th floor Washington, DC 20001
Washington, DC 20001
Jerome Peloquin
Mary Carolyn Brown, Esquire 4001 9th Street NE
Donohue & Sterns, LLP Washington, DC 20017
1750 K St. NW, Suite 1100
Washington, DC 20006 Melissa Peffers
2201 2nd Street NW, Unit 41
APPLICANT Washington, DC 20001

Vision McMillan Partners LLC, Chris Otten

c/o Philip T. Evans & Whayne Quin, Esqs., 2203 Champlain Street NW, #303
Holland & Knight LLP, Washington, DC 20009
800 17th St NW
Washington, DC 20006 Cynthia Carson
42 Adams Street NW
Washington, DC 20001

Jenifer Simpson
48 Adams Street NW
Washington, 20001

Signed,

Daniel Wolkoff
1231 Randolph Street NW
Washington DC 20017