Veteranclaims’s Blog

December 19, 2021

Single Judge Application; inadequate reasons and bases; Johnson v. Wilkie; it is unclear how the Board determined that the appropriate standard to applied under DC 5284 was based upon pain, additional functional limitation, and limitation of motion; because DC 5284 only contemplates a foot disability in terms of moderate, moderately severe, and severe. 38 C.F.R. § 4.71a, DC 5284. The Board failed to define the necessary criteria for each disability rating or explain why appellant did not meet the requirements of the same, in turn frustrating judicial review. Johnson v. Wilkie, 30 Vet.App. 245, 255 (2018) (“Without a standard for comparing and assessing terms of degree, such conclusory findings are unreviewable in this Court.”); see also Buczynski v. Shinseki, 24 Vet.App. 221, 224 (2011) (“The Board must explain, in the context of the facts presented, the rating criteria used in determining the category into which a claimant’s symptoms fall ….”);

Designated for electronic publication only
UNITED STATES COURT OF APPEALS FOR VETERANS CLAIMS
No. 20-2907
OZELL W. GAINER , APPELLANT,
V.
DENIS MCDONOUGH,
SECRETARY OF VETERANS AFFAIRS, APPELLEE.
Before GREENBERG, Judge.
MEMORANDUM DECISION
Note: Pursuant to U.S. Vet. App. R. 30(a),
this action may not be cited as precedent.
GREENBERG, Judge: Ozell W. Gainer, widow of U.S. Marine Corp. veteran Ulysses
Gainer, appeals, through counsel, that part of a February 18, 2020, Board of Veterans’ Appeals
decision that (1) denied service connection for an acquired psychiatric disorder; (2) denied service
connection for erectile dysfunction; and (3) granted an initial 10% disability rating, but no higher,
for a left foot condition with arthritis.1 Record (R.) at 5-31. The appellant argues that (1) VA failed
to satisfy the duty to assist; (2) the Board failed to provide an adequate statement of reasons or
bases in reaching its determinations concerning the veteran’s acquired psychiatric disorder and left
foot condition with arthritis; and (3) the veteran’s erectile dysfunction is inextricably intertwined
1 The Board also (1) found that new and material evidence had been submitted and reopened the appellant’s
service-connection claim for an acquired psychiatric disorder; and (2) granted service connection for a right foot
disability. The Court will not disturb these favorable findings. See Medrano v. Nicholson, 21 Vet.App. 165, 170
(2007). Also, to the extent the grant of an initial disability rating for the appellant’s service-connected left foot
condition is favorable, the Court will not disturb it. Id. Additionally, a claim seeking service connection for a nerve
disorder, claimed as body twitching, to include as due to Camp Lejeune contaminated water exposure was remanded
in the February 2020 Board decision. This matter is not currently before the Court. See Hampton v. Gober, 10
Vet.App. 481, 482 (1997). Finally, the Board denied service connection for tinnitus. The appellant presents no
challenge as to this argument and the Court deems the matter abandoned. See Pederson v. McDonald, 27 Vet.App.
276, 285 (2015) (en banc) (holding that, where an appellant abandons an issue or claim, the Court will not address it).
2
with his acquired psychiatric disorder. Appellant’s Brief at 5-14. For the following reasons, the
Court will set aside that part of the February 2020 Board decision and remand the matters for
readjudication.
I.
The Veterans Administration was established in 1930 when Congress consolidated the
Bureau of Pensions, the National Home for Disabled Volunteer Soldiers, and the U.S. Veterans’
Bureau into one agency. Act of July 3, 1930, ch. 863, 46 Stat. 1016. This Court was created with
the enactment of the Veterans’ Judicial Review Act (VJRA) in 1988. See Pub. L. No. 100-687, §
402, 102 Stat. 4105, 4122 (1988). Before the VJRA, for nearly 60 years VA rules, regulations,
and decisions lived in “splendid isolation,” generally unconstrained by judicial review. See Brown
v. Gardner, 513 U.S. 115, 122 (1994) (Souter, J.).
Yet, the creation of a special court solely for veterans is consistent with congressional intent
as old as the Republic. Congress first sought judicial assistance in affording veterans relief when
it adopted the Invalid Pensions Act of 1792, which provided “for the settlement of the claims of
widows and orphans . . . and to regulate the claims to invalid pensions,” for those injured during
the Revolutionary War. Act of Mar. 23, 1792, ch. 11, 1 U.S. Stat. 243 (1792) (repealed in part and
amended by Act of Feb. 28, 1793, ch. 17, 1 Stat. 324 (1793)). The act, though magnanimous,
curtailed the power of the judiciary, by providing the Secretary of War the ability to withhold
favorable determinations to claimants by circuit courts if the Secretary believed that the circuit
court had erred in favor of the soldiers based on “suspected imposition or mistake.” See id.
3
Chief Justice John Jay2 wrote a letter3 to President George Washington on behalf of the
Circuit Court for the District of New York4 acknowledging that “the objects of this act are
exceedingly benevolent, and do real honor to the humanity and justice of Congress.” See
Hayburn’s Case, 2 U.S. (2 Dall.) 409, 410 n., 1 L. Ed. 436 (1792). Jay also noted that “judges
desire to manifest, on all proper occasions and in every proper manner their high respect for the
national legislature.” Id.
This desire to effect congressional intent favorable to veterans has echoed throughout the
Supreme Court’s decisions on matters that emanated from our Court. See Shinseki v. Sanders, 556
U.S. 396, 416, 129 S. Ct. 1696, 1709 (2009) (Souter, J., dissenting) (“Given Congress’s
understandable decision to place a thumb on the scale in the veteran’s favor in the course of
administrative and judicial review of VA decisions”); see also Henderson v. Shinseki, 562 U.S.
428, 440, 131 S. Ct. 1197, 1205 (2011) (declaring that congressional solicitude for veterans is
plainly reflected in “the singular characteristics of the review scheme that Congress created for the
adjudication of veterans’ benefits claims,” and emphasizing that the provision “was enacted as part
of the VJRA [because] that legislation was decidedly favorable to the veteran”).
2 John Jay served as the first Secretary of State of the United States on an interim basis. II DAVID G. SAVAGE,
GUIDE TO THE U.S. SUPREME COURT 872 (4th ed. (2004)). Although a large contributor to early U.S. foreign policy,
Jay turned down the opportunity to assume this position full time. Id. at 872, 916. Instead, he accepted a nomination
from President Washington to become the first Chief Justice of the Supreme Court on the day the position was created
by the Judiciary Act of 1789. Id. Jay resigned his position in 1795 to become the second Governor of New York. Id.
He was nominated to become Chief Justice of the Supreme Court again in December 1800, but he declined the
appointment. Id.
3 The Supreme Court never decided Hayburn’s Case. See 2 U.S. (2 Dall.) 409, 409 (1792). The case was
held over under advisement until the Court’s next session and Congress adopted the Invalid Pensions Act of 1793,
which required the Secretary of War, in conjunction with the Attorney General, to “take such measures as may be
necessary to obtain an adjudication of the Supreme Court of the United States.” Act of Feb. 28, 1793, ch. 17, 1 Stat.
324 (1793). Hayburn’s Case has often been cited as an example of judicial restraint, see, e.g., Tutun v. United States,
270 U.S. 568 (1926), but Supreme Court historian Maeva Marcus has argued persuasively to the contrary. See Maeva
Marcus & Robert Teir, Hayburn’s Case: A Misinterpretation of Precedent, 1988 WIS. L. REV. 527. After all, Jay’s
letter included by Dallas, the Court Reporter, in a note accompanying the decision to hold the matter under advisement,
is nothing more than an advisory opinion that compelled Congress to change the law in order to make the judiciary
the final voice on the review of a Revolutionary War veteran’s right to pension benefits. See Hayburn’s Case, 2 U.S.
(2 Dall.) 409, 410 n.
4 At this time, each Justice of the Supreme Court also served on circuit courts, a practice known as circuit
riding. See RICHARD H. FALLON, JR., ET AL., HART AND WECHSLER’S THE FEDERAL COURTS AND THE FEDERAL
SYSTEM (7th ed. 2015).
4
II.
Justice Alito5 observed in Henderson v. Shinseki that our Court’s scope of review is “similar
to that of an Article III court reviewing agency action under the Administrative Procedure Act,
5 U.S.C. § 706.” 562 U.S. at 432 n.2 (2011); see 38 U.S.C. § 7261. “The Court may hear cases
by judges sitting alone or in panels, as determined pursuant to procedures established by the
Court.” 38 U.S.C. § 7254. The statutory command that a single judge 6 may issue a binding
decision is “unambiguous, unequivocal, and unlimited,” see Conroy v. Aniskoff, 507 U.S. 511, 514
(1993). The Court’s practice of treating panel decisions as “precedential” is unnecessary,
particularly since the Court’s adoption of class action litigation. See Wolfe v. Wilkie, 32 Vet.App.
1 (2019). We cite decisions from our Court merely for their guidance and persuasive value.
III.
The veteran served on active duty in the U.S. Marine Corps from September 1980 to
September 1983 as an embarkation clerk. R. at 1561 (DD Form 214). The veteran was awarded a
Meritorious Mast and a Marksman Badge with the rifle. Id.
IV.
VA treatment records from August 2011 noted the veteran was diagnosed with dysthymia,
with associated alcohol abuse and noncompliance with his depression medication regimen; and
erectile dysfunction for which he was prescribed Levitra. R. at 1518, 1538. The veteran reported
that he suffered from symptoms of insomnia, decreased appetite, decreased energy level, lack of
motivation, social withdrawal, lack of interest in his usual activities, and anhedonia, R. at 1536;
that he “exhibit[ed] some passive suicidal ideation but has no plan”; and that “[s]ometimes he
would rather be dead.” R. at 1538.
5 Justice Alito was born in Trenton, New Jersey. SUPREME COURT OF THE UNITED STATES,
https://www.supremecourt.gov/about/biographies.aspx (last visited Mar. 4, 2020). He began his career as a law clerk,
then became assistant U.S. attorney for the district of New Jersey before assuming multiple positions at the Department
of Justice. Id. He then became a U.S. attorney for the district of New Jersey. Id. Before his nomination for the
Supreme Court, he spent 16 years as a judge on the U.S. Court of Appeals for the Third Circuit. Id. In 2005, President
George W. Bush chose Alito to replace retiring Supreme Court Justice Sandra Day O’Connor. Id.
6 From 1989 to 1993, West (the publisher of this Court’s decisions) published this Court’s single-judge
decisions in tables in hard-bound volumes of West’s Veterans Appeals Reporter. Since 1993, West has published this
Court’s single-judge decisions electronically only. I believe the Court should publish all its decisions in print form.
See, e.g., Passaic Cty. Bar Ass’n v. Hughes, 401 U.S. 1003 (1971).
5
In March 2012, the veteran’s sister submitted a statement in support of the veteran’s
application for Social Security disability benefits describing how the veteran’s behavior had
changed in 1984 after he separated from the military, R. at 1343, 1341, and stating that the veteran
had had difficulties with agitation, moodiness, impulse control, communication, and focus. R. at
1342.
In May 2012, the veteran appellant submitted an intent to file for benefits, seeking service
connection for a left foot condition and depression. R. at 1587. He then filed a formal claim for
the same benefits in June 2012. R. at 1562-68.
In March 2013, the regional office (RO) denied service connection for a left foot condition
and depression. R. at 1496-99.
Thereafter, in July 2013, the veteran reapplied for disability benefits seeking service
connection for a foot condition with arthritis. R. at 1465-70.
In August 2013, VA obtained a mental disorders disability benefits questionnaire (DBQ).
R. at 1458-62. The examiner noted that the veteran had been diagnosed with dysthymia and
alcohol abuse, R. at 1458, and listed the veteran’s symptoms as (1) depressed mood; (2) anxiety;
(3) chronic sleep impairment; (4) disturbances of mood and motivation; and (5) difficulty in
establishing and maintaining effective work and social relationships. R. at 1461.
In June 2014, the veteran submitted a VA foot conditions DBQ that included diagnoses in
2014 of bilateral hammer toes and hallux valgus, R. at 1244-45, as well as degenerative arthritis
of the left foot. R. at 1245. The veteran reported that he began having foot pain during service in
1980, after running in wet boots and socks while he was stationed at Parrish Island, but that he did
not seek medical attention for his feet. Id. X-rays of the veteran’s left foot revealed a small plantar
calcaneal enthesophyte, hammertoe deformities of the 2nd through 5th toes, degenerative changes
of the 1st metatarsophalangeal joint, moderate hallux valgus, and “presumed remote posttraumatic
versus postsurgical deformity of the 5th proximal phalangeal head.” R. at 1250.
In July 2014, the RO granted service connection for a left foot condition with arthritis, with
a noncompensible rating, effective July 24, 2012. R. at 944-50.
In August 2014, the veteran filed a Notice of Disagreement alleging that he had had
problems with his feet during service, and as a result, has had surgery since leaving service. R. at
759-60.
6
In October 2014, the veteran filed a supplemental claim for compensation benefits, seeking
service connection for erectile dysfunction. R. at 757.
In a January 2015 VA mental health treatment session, the veteran was diagnosed with
unspecified insomnia and unspecified depressive disorder. R. at 558.
Also in January 2015, the RO denied service connection for erectile dysfunction. R. at 681-
83.
A May 2015 VA treatment record noted that the veteran was treated for a callus on the
bottom of his left foot, R. at 408, and was diagnosed with pes planus; metatarsalgia of the left foot
with a history of surgery; a painful callus and tyloma of the left foot; bilateral interdigital and
moccasin tinea pedis; hammer toe contracture; and bilateral venous insufficiency. R. at 408-09.
The veteran died in August 2016 and the causes of death were listed as hypertension and
post-traumatic stress disorder (PTSD). R. at 323. Later that same month, the appellant requested
to be substituted for the veteran based on the veteran’s death. R. at 321, and she applied for
dependency and indemnity compensation (DIC) benefits as the veteran’s surviving spouse. R. at
310-14.
In September 2016, the RO granted service connection for the veteran’s cause of death. R.
at 305-07.
In October 2019, the appellant testified at a Board hearing. R. at 34-68. Concerning the
veteran’s left foot condition, she testified that the veteran (1) had difficulty walking; (2) put a lot
of pressure and placed his weight on his right foot because of his left foot problems; (3) had “some
sort of growth” removed from the bottom of his foot; and (4) was given special shoes and used a
cane to aid his walking. R. at 36-37, 39-43. With regard to erectile dysfunction, the appellant
testified that the veteran “couldn’t have no sex or no nothing,” R. at 49, didn’t function, and had
something wrong with his body, R. at 50. Finally, with regard to the veteran’s mental health, the
appellant testified that he suffered from nightmares, mood swings, hypervigilance, difficulty
controlling his temper and emotions, R. at 51-53, had difficulty interacting with other people and
being socially distant, and that he avoided watching television shows that depicted war or the use
of guns. R. at 55-57. She claimed that when she first met the veteran he cried over “things that he
had to do in his service that … he [couldn’t] speak about,” R. at 57, because he served in
reconnaissance or the special forces. R. at 58.
7
V.
In February 2020, the Board (1) denied service connection for an acquired psychiatric
disorder; (2) denied service connection for erectile dysfunction; and (3) granted an initial disability
rating of 10%, but no higher, for a left foot condition with arthritis. R. at 5-27. Concerning the
veteran’s acquired psychiatric disorder, the Board discussed the veteran’s service and postservice
treatment records, as well as the veteran’s lay statements. R. at 13-14. The Board then concluded
that
[a]fter a review of all of the evidence, lay and medical, the Board finds that the
weight of the evidence is against a finding that the Veteran had a diagnosis of
PTSD, and, further, that the weight of the evidence is against a finding that his
psychiatric disability, primarily diagnosed as depression and/or dysthymia, was
related to events that occurred in active service.
R. at 14. The Board reasoned that although “the Veteran’s death certificate lists PTSD as a
contributory cause of his death . . . , no treating physician ever diagnosed the Veteran with PTSD,
nor did the Veteran ever discuss a military stressor in the course of seeking treatment for his
psychiatric symptoms. His PTSD screens were also consistently negative.” R. at 15. The Board
further reasoned that the veteran’s “symptoms of a psychiatric disability were not continuous or
recurrent since service separation in September 1983. Following service separation in September
1983, the evidence of record shows no mention of psychiatric symptoms until 2004.” R. at 16. In
reaching this determination, the Board found the “[v]eteran and appellant were/are competent to
provide evidence regarding matters that can be perceived by the senses, they were/are not shown
to be competent to render medical opinions on questions of etiology.” Id.
The Board then denied service connection for erectile dysfunction because of a lack of a
“medical nexus” between the claimed condition and service, R. at 19. The Board reasoned that (1)
“service treatment records are completely silent as to any reports, symptoms, findings, treatment,
or diagnoses of the claimed disabilities,” id.; (2) “the weight of the evidence demonstrates that
symptoms of the claimed disabilities were not continuous or recurrent since separation from active
service in September 1983,” id; (3) “the evidence of record does not show any complaints,
diagnosis, or treatment for the claimed…erectile dysfunction until 2011, when VA treatment
records show the Veteran requested medication for it,” id., and (4) the more recent assertions made
by the veteran and appellant “in the context of the current disability claim of continuous or
recurrent symptoms of the claimed disabilities since service . . .are outweighed by the other, more
8
contemporaneous, lay and medical evidence of record, both in service and after service, and are
not reliable.” R. at 20. In reaching this determination, the Board noted that the veteran and
appellant “were/are competent to provide evidence regarding matters that can be perceived by the
senses, they have not been shown to be competent to render medical opinions on questions of
etiology.” R. at 21. The Board then noted that “service connection for erectile dysfunction on a
secondary basis as due to the psychiatric disability or the medications taken for such disability
cannot be granted as service connection for the claimed psychiatric disability is denied herein.” R.
at 20-21.
Finally, concerning the appellant’s left foot disability, the Board relied upon the veteran’s
lay statements; treatment records from June 2012 and May 2015; and VA examinations and
medical opinions from June 2014, and May 2017, R. at 24-25, when it concluded that the veteran’s
“left foot disability could be characterized as moderate in severity, but no more than moderate. “
R. at 26. The Board reasoned that
the overall evidence does not show that pain or other factors have resulted in
additional functional limitation or limitation of motion (a moderately severe foot
injury) such as to enable a finding that the disability picture more nearly
approximates a disability rating in excess of 10 percent for the any part of the initial
rating period on appeal.
R. at 27.
VI.
Section 4.71a, title 38, Code of Federal Regulations, contains Diagnostic Code 5284, which
defines the disability ratings for “foot injuries, other” as follows:
Severe 30%
Moderately Severe 20%
Moderate 10%
NOTE: With actual loss of use of the foot, rate 40%
38 C.F.R. § 4.71a (2020).
“The Secretary shall make reasonable efforts to assist a claimant in obtaining evidence
necessary to substantiate the claimant’s claim for a benefit under a law administered by the
Secretary.” 38 U.S.C § 5103A(a). “In the case of a claim for disability compensation, the assistance
provided by the Secretary under subsection (a) shall include providing a medical examination or
9
obtaining a medical opinion when such an examination or opinion is necessary to make a decision
on the claim.” 38 U.S.C. § 5103A(d)(1).
This Court has held that with respect to a veteran’s claim for benefits, to determine whether
the duty to assist requires that a VA medical examination be provided or a medical opinion
obtained, four factors are to be considered: (1) Whether there is competent evidence of a current
disability; (2) whether there is evidence establishing that an event, injury, or disease occurred in
service, or evidence establishing certain disease manifesting during an applicable presumption
period; (3) whether there is an indication that the disability or symptoms may be associated with
the veteran’s service or with another service-connected disability; and (4) whether there otherwise
is sufficient competent medical evidence of record to enable a decision on the claim. McLendon,
20 Vet.App. at 81 (2006).
“Each decision of the Board shall include . . . a written statement of the Board’s findings
and conclusions, and the reasons or bases for those findings and conclusions, on all material issues
of fact and law presented in the record.” 38 U.S.C. § 7104(d)(1). This statement of reasons or
bases serves not only to help a claimant understand what has been decided, but also to ensure that
VA decisionmakers do not exercise “naked and arbitrary power” in deciding entitlement to
disability benefits. See Yick Wo v. Hopkins, 118 U.S. 356, 366 (1886) (Matthews, J.).
VII.
The Court concludes that the Board failed to provide an adequate statement of reasons or
bases for denying service connection for an acquired psychiatric disorder, specifically because it
failed to determine whether a medical examination was warranted. 38 U.S.C. § 7104(d)(1). The
Board acknowledged (1) the veteran’s lay statement that “he began experiencing symptoms of
depression during active service, and that these symptoms were continuous after separation of
service,” R. at 11; (2) that he had been diagnosed with “depression and/or dysthymia,” R. at 14;
and (3) that one of the veteran’s listed causes of death was PTSD. R. at 15. Additionally, the
veteran’s sister reported that his behavior had changed after he returned home from service, R. at
1343, 1341; and the appellant testified that when she first met the veteran he cried over “things
that he had to do in his service that…he [couldn’t] speak about,” R. at 57, because he had served
in reconnaissance or the special forces. R. at 58. Yet, the Board made no determination as to
whether a medical examination was necessary to decide the appellant’s claim. 38 U.S.C. §
10
5103A(d)(1); see also McLendon, 20 Vet.App. at 83. Remand of the psychiatric disorder claim is
required for the Board to provide an adequate statement of reasons or bases for its duty-to-assist
determination. See 38 U.S.C. § 7104(d)(1); see also McLendon, 20 Vet.App. at 83.
The Court will also remand the erectile dysfunction claim as inextricably intertwined with
the psychiatric disorder claim. See Harris v. Derwinski, 1 Vet.App. 180, 183 (1991) (holding that
where a decision on one issue may have a “significant impact” upon another, the two claims are
inextricably intertwined), overruled on other grounds by Tyrues v. Shinseki, 23 Vet.App. 166
(2009) (en banc), aff’d, 631 F.3d 1380, 1383 (Fed. Cir. 2011), vacated and remanded for
reconsideration, 132 S. Ct. 75 (2011), modified, 26 Vet.App. 31 (2012). The veteran was
diagnosed with unspecified depression, R. at 1518, for which he was prescribed medication. R. at

  1. At the February 2019 hearing, the Board member noted this information and opined that
    the veteran’s erectile dysfunction may be related to or secondary to his depression and medication.
    R. at 60-61. The Board then determined that “service connection for erectile dysfunction on a
    secondary basis as due to the psychiatric disability or the medications taken for such disability
    cannot be granted as service connection for the claimed psychiatric disability is denied herein.” R.
    at 20-21.
    Finally, the Court concludes that the Board provided an inadequate statement of reasons or
    bases for denying an initial disability rating in excess of 10% for a left foot condition with arthritis.
    38 U.S.C. § 7104(d)(1). As noted above, the Board concluded that
    the overall evidence does not show that pain or other factors have resulted in
    additional functional limitation or limitation of motion (a moderately severe foot
    injury) such as to enable a finding that the disability picture more nearly
    approximates a disability rating in excess of 10 percent for the any part of the initial
    rating period on appeal.
    R. at 27. It is unclear how the Board determined that the appropriate standard to applied under DC
    5284 was based upon pain, additional functional limitation, and limitation of motion; because DC
    5284 only contemplates a foot disability in terms of moderate, moderately severe, and severe. 38
    C.F.R. § 4.71a, DC 5284. The Board failed to define the necessary criteria for each disability
    rating or explain why appellant did not meet the requirements of the same, in turn frustrating
    judicial review. Johnson v. Wilkie, 30 Vet.App. 245, 255 (2018) (“Without a standard for
    comparing and assessing terms of degree, such conclusory findings are unreviewable in this
    Court.”); see also Buczynski v. Shinseki, 24 Vet.App. 221, 224 (2011) (“The Board must explain,
    11
    in the context of the facts presented, the rating criteria used in determining the category into which
    a claimant’s symptoms fall ….”).
    Remand is required for the Board to provide an adequate
    statement of reasons or bases and specifically address the appropriate standard to be applied under
    DC 5284. 38 U.S.C. § 7104(d)(1).
    Because the Court is remanding the appellant’s claims, it will not address his remaining
    arguments. See Dunn v. West, 11 Vet.App. 462, 467 (1998). On remand, the appellant may
    present, and the Board must consider, any additional evidence and arguments. See Kay v. Principi,
    16 Vet.App. 529, 534 (2002). This matter is to be provided expeditious treatment. See 38 U.S.C.
    § 7112; see also Hayburn’s Case, 2 U.S. (2 Dall.) at 410, n. (“[M]any unfortunate and meritorious
    [veterans], whom Congress have justly thought proper objects of immediate relief, may suffer
    great distress, even by a short delay, and may be utterly ruined, by a long one.”).
    VIII.
    For the foregoing reasons, the February 18, 2020, Board decision is SET ASIDE and the
    matters are REMANDED for readjudication.
    DATED: May 19, 2021
    Copies to:
    Daniel G. Krasnegor, Esq.
    VA General Counsel (027)

Powered by WordPress.com.