Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 1 of 16 Page ID #1
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF ILLINOIS
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`EAST ST. LOUIS DIVISION
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`Donna Burns, individually and on behalf of all
`others similarly situated,
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`3:21-cv-01099
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`Plaintiff,
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`- against -
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`Class Action Complaint
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`General Mills Sales, Inc.,
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`
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`Defendant
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`Jury Trial Demanded
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`Plaintiff alleges upon information and belief, except for allegations pertaining to plaintiff,
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`which are based on personal knowledge:
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`1. General Mills Sales, Inc. (“defendant”) manufactures, labels, markets, and sells a dry
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`mix identified as “Fudge Brownie Mix,” under the Betty Crocker brand (“Product”).
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`2.
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`The representation is misleading because it gives consumers the impression it
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`contains a greater relative and absolute amount of the expected fudge ingredients than it does.
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`1
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF ILLINOIS
`
`EAST ST. LOUIS DIVISION
`
`Donna Burns, individually and on behalf of all
`others similarly situated,
`
`3:21-cv-01099
`
`Plaintiff,
`
`
`
`- against -
`
`Class Action Complaint
`
`General Mills Sales, Inc.,
`
`
`
`Defendant
`
`Jury Trial Demanded
`
`Plaintiff alleges upon information and belief, except for allegations pertaining to plaintiff,
`
`which are based on personal knowledge:
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`1. General Mills Sales, Inc. (“defendant”) manufactures, labels, markets, and sells a dry
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`mix identified as “Fudge Brownie Mix,” under the Betty Crocker brand (“Product”).
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`2.
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`The representation is misleading because it gives consumers the impression it
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`
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`contains a greater relative and absolute amount of the expected fudge ingredients than it does.
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`1
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 2 of 16 Page ID #2
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`I.
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`DEFINITIONS OF FUDGE
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`3.
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`4.
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`Fudge “is a type of sugar candy that is made by mixing sugar, butter and milk.”1
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`Though fudge can have any flavor, milkfat is the central component.
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`5. An 1893 recipe for fudge called for “Four cups granulated sugar; one cup cream; one
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`cup water; one-half cake chocolate; one-half Cup butter.”2
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`6.
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`In 1896, The Los Angeles Times published the original fudge recipe by the Vassar
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`students credited with first making fudge: “Two cups of sugar, one cup of milk, a piece of butter
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`one-half the size of an egg” and added flavoring.3
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`7. A 1902 fudge recipe from Mrs. Rorer's New Cook Book includes:4
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`4 ounces of chocolate
`2 cups of sugar
`1 teaspoonful of vanilla
`1/2 cup of milk
`1 rounding tablespoonful of butter
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`8. Molly Mills, one of today’s leading authorities on fudge, recently described it as
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`made “most commonly from butter, milk, sugar, and chocolate.”5
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`9.
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`The Oxford Companion to Sugar and Sweets notes that:
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`Traditionally, fudge is made by gently boiling granulated
`sugar and milk to the soft-ball stage (234° to 240°F/ 112° to
`115°C); adding butter; cooling the mixture somewhat
`(120°F/49°C); then beating until thick, creamy, and less
`glossy.6
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`1 Wikipedia contributors. "Fudge." Wikipedia, The Free Encyclopedia. Wikipedia, The Free Encyclopedia, 5 Jan.
`2021. Web. 8 Jan. 2021.
`2 Mrs. J. Montgomery Smith, of Wisconsin, Alternate Lady Manager.
`3 Los Angeles Times, “‘Fudges’ Are Vassar Chocolates,” May 11, 1896, p.2.
`4 Sarah Tyson Rorer [Arnold and Company: Philadelphia] 1902, p. 629.
`5 Molly Mills, Come Get Your Fudge: 40 Tasty and Creative Fudge Recipes for Everyone, Amazon Digital Services
`LLC, June 11, 2019.
`6 Goldstein, Darra, and Sidney Mintz. The Oxford companion to sugar and sweets. Oxford University Press, 2015.
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`2
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 3 of 16 Page ID #3
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`10. The encyclopedic, An A-Z of Food and Drink, describes fudge as “a sort of soft,
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`somewhat toffee-like sweet made by boiling together sugar, butter, and milk.”7
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`11. A leading treatise on confectionary science and technology offers a model
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`commercial formulation for fudge which includes between eight and sixteen percent butter and
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`between twelve and twenty percent sweetened condensed milk.
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`12. Dictionaries confirm the definitions held by confectionery experts.
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`13. Google Dictionary – based on its leading search engine that discovers the most
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`relevant and accurate information – defines fudge as “a soft candy made from sugar, butter, and
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`milk or cream.”8
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`14. The Cambridge Dictionary defines fudge as “a soft sweet made from sugar, butter,
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`and milk.”9
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`15. Collins Dictionary defines fudge as “a soft brown candy that is made from butter,
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`cream, and sugar.”10
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`7 John Ayto, An A-Z of Food and Drink, Oxford University Press, 2002, p. 133.
`8 Fudge definition – Google search.
`9 Cambridge Dictionary, fudge.
`10 Collins Dictionary, fudge.
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 4 of 16 Page ID #4
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`16. Dictionary.com defines fudge as “a soft candy made of sugar, butter, milk, chocolate,
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`and sometimes nuts.”11
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`17. Macmillan Dictionary defines fudge as a “soft brown sweet food made from sugar,
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`butter, and milk or cream.”12
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`18. Fudge can be made and/or applied in various forms – solid, liquid (“hot fudge”) and
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`as part of a dry mix (“cake mix”).
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`19. “Hot fudge” is a chocolate product often used as a topping for ice cream and desserts,
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`in a heated form.
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`20. When making “hot fudge,” butter is typically replaced with heavy cream, resulting
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`in a thick, pourable liquid while hot, becoming more viscous as it cools.
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`21. The difference between “hot fudge” and “chocolate sauce” is due to the fat content,
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`as the former is thicker and richer, while the latter is thinner and more pourable.
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`22. Cake mix – or brownie mix – is a ready-made mixture of dry ingredients and
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`additives necessary to the blending and baking process.13
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`23. “Complete” mixes are all-inclusive dry powder blends that only require the addition
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`of water.
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`24. “Partial” mixes require the addition of water, shortening and/or eggs.
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`25. The type of fat used in complete mixes may be specially designed to be incorporated
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`into a dry mix.
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`26. Since a cake mix is a dry blend, the dairy ingredients will typically include whole
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`milk powder or buttermilk powder.
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`11 Dictionary.com, fudge.
`12 Macmillan Dictionary, fudge.
`13 The Complaint will use the terms “cake mix” and “brownie mix” interchangeably.
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`4
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 5 of 16 Page ID #5
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`II. FAT INGREDIENTS ARE ESSENTIAL TO FUDGE, REGARDLESS OF FORM
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`27. The quality of fudge depends on the amount and type of fat-contributing
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`ingredients.14
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`28. The small droplets of fat are dispersed throughout the fudge mass, providing
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`lubricity, and imparting desirable flavor release.
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`29.
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`If the fat content is too high, it can lead to oil separation and a greasy texture.15
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`30. The fat ingredients are typically from dairy or vegetable oils.
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`31. The dairy ingredients are based on milk fat, mainly added through butter, which is
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`80% milkfat.
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`32.
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`In the context of a cake mix blend, buttermilk powder will often be used.
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`33. Other dairy ingredients like milk and milk derivatives may be added as well.
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`34. Vegetable oil ingredients like palm oil, are solid at room temperature, and referred
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`to as “hard [vegetable] fats.”
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`35. Dairy ingredients impart a creamy, rich taste to fudge, because milkfat contains
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`hundreds of lactones, aroma compounds which contribute to its taste.
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`36. Milk fat melts at about mouth temperature (35 °C/95 °F) and does not contribute to
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`a waxy sensation.
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`37. Alternatives to milk fat – such as vegetable oils – do not melt at mouth temperature
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`and leave a waxy mouthfeel.
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`38. Vegetable fats do not contribute to the flavor of fudge, because they are theoretically
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`“refined, bleached and deodorized.”
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`14 International Dairy Federation, Bulletin, 1982.
`15 Hartel R.W., von Elbe J.H., Hofberger R. (2018) Caramel, Fudge and Toffee. In: Confectionery Science and
`Technology. Springer, Cham. https://doi.org/10.1007/978-3-319-61742-8_10
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`5
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 6 of 16 Page ID #6
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`39. However, these ingredients are subject to reversion where they contribute off-odors
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`to foods.
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`40. One popular recipe website echoes the importance of dairy ingredients to fudge,
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`advising, “When making fudge, be sure to use good quality butter and do not substitute margarine
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`(vegetable oils),” since they contain more water and can prevent the fudge from setting up
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`properly.16
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`41. Another site cautions, “Look for recipes that call for butter instead of margarine
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`(vegetable oils).”17
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`42. One chef recommends to “Never use margarine (vegetable oils) instead of butter [in
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`fudge], because your fudge won’t taste as good and will have a shorter shelf life.”
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`III. STATE AND FEDERAL REGULATIONS REQUIRE FRONT LABEL TO
`IDENTIFY PRODUCT AS SOMETHING OTHER THAN FUDGE, I.E.,
`“CHOCOLATE FLAVORED CAKE MIX”
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`43. Federal and identical state regulations require a product’s front label to contain a
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`common or usual name which accurately identifies or describes, “in as simple and direct terms as
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`possible, the basic nature of the food or its characterizing properties or ingredients.” 21 C.F.R. §
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`102.5(a); Illinois Food, Drug and Cosmetic Act (“IFDCA”), 410 ILCS 620/1 et seq.; 410 ILCS
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`620/21(j) (“federal [food labeling] regulation[s] [are] automatically adopted”).
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`44. Defendant’s representations violate 21 U.S.C. § 343(a)(1) and 410 ILCS 620/11,
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`which deem a food misbranded when the label contains a statement that is “false or misleading.”
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`45. Thus, a violation of federal food labeling laws is an independent violation of Illinois
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`law and actionable as such.
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`16 Use Real Butter For Making Best Fudge, RecipeTips.com.
`17 Easy Fudge Making Tips, The Happy Housewife.
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`6
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 7 of 16 Page ID #7
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`46. The Illinois Consumer Fraud and Deceptive Business Practices Act provides
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`protection for consumers purchasing products like Defendant’s Product, and states:
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`Unfair methods of competition and unfair or deceptive acts or practices, including
`but not limited to the use or employment of any deception, fraud, false pretense,
`false promise, misrepresentation or the concealment, suppression or omission of
`any material fact, with intent that others rely upon the concealment, suppression or
`omission of such material fact . . . are hereby declared unlawful
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`815 ILCS 505/2.
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`47. Whether a product contains fudge is basic front label information consumers rely on
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`when making quick decisions at the grocery store.
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`48. The Product lacks essential fudge ingredients – dairy ingredients with milkfat – and
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`substitutes lower quality and lower-priced palm oil, as shown by the ingredient list on the side
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`panel.
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`Ingredients: Sugar,
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`Enriched Flour Bleached
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`(wheat flour, niacin, iron,
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`thiamin mononitrate,
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`riboflavin, folic acid), Cocoa
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`Processed with Alkali, Palm
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`Oil, Corn Syrup, Corn
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`Starch. Contains 2% or less
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`of: Carob Powder, Salt,
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`Canola Oil, Artificial Flavor.
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`CONTAINS WHEAT;
`MAY CONTAIN MILK
`INGREDIENTS.
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`49. Reasonable consumers are misled by the identifying term, “Fudge,” because they
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`expect this means a non-de-minimis relative amount of dairy ingredients containing milk fat.
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 8 of 16 Page ID #8
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`50. Even in the context of a dry mix, which cannot accommodate traditional dairy
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`ingredients for obvious reasons, consumers expect at least a semblance of fudge ingredients, viz,
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`dairy ingredients.
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`51.
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` The result of substituting dairy ingredients with vegetable oils is that the Product
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`provides less satiety, a waxy and oily mouthfeel, and leaves an aftertaste.
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`52. Consumption of dairy ingredients with milk fat does not have the negative effects on
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`cholesterol compared to vegetable oils.
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`53. Consumption of vegetable oil is linked to health problems, like increased chances of
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`heart disease.
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`54. Milk fat ingredients also contain the fat-soluble vitamins A, D, E, and K, which are
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`absent from hardened vegetable fats.
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`55. Dairy ingredients contain hundreds of lactones, or aroma compounds, which impart
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`a creamy, rich taste and texture to a product containing fudge.
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`56. Dry complete cake mixes which have a relatively significant amount of dairy
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`ingredients containing milkfat are not a rare or pricy delicacy that would make a reasonable
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`consumer “double check” their presence by scouring the packaging.
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`57. Dry (fudge) cake mixes with milkfat from exist in the marketplace and are not
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`technologically or otherwise unfeasible to produce.
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`58. The Product’s representations are misleading because its common or usual name –
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`“Fudge Brownie Mix” – fails to include a statement that the characterizing fudge ingredients –
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`milkfat – are absent from the dry mix. 21 C.F.R. § 102.5(c)(1)-(3).
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`59. The front label fails to inform consumers that if they want a “Fudge Brownie Mix,”
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`they will have to supply their own fudge.
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 9 of 16 Page ID #9
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`60. The presence of dairy ingredients (in a dry form) has a material bearing on price and
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`consumer acceptance of the Product.
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`61. The front label creates an erroneous impression that fudge ingredients – from dairy
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`products – are present in the mix.
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`62. Federal and state regulations require that the front label disclose the absence of fudge
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`ingredients through a statement such as “Contains No Fudge,” “Does not Contain Fudge,” or “No
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`Dairy Ingredients.”
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`63. The absence of fudge ingredients is required to be disclosed directly below the
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`Product’s common or usual name, in boldfaced type:
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`Fudge Brownie Mix
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`Contains No Fudge
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`IV. CONCLUSION
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`64. Reasonable consumers must and do rely on a company to honestly identify and
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`describe the components, attributes, and features of the Product, relative to itself and other
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`comparable products or alternatives.
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`65. The value of the Product that plaintiff purchased was materially less than its value as
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`represented by defendant.
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`66. Defendant sold more of the Product and at higher prices than it would have in the
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`absence of this misconduct, resulting in additional profits at the expense of consumers.
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`67. Had Plaintiff and proposed class members known the truth, they would not have
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`bought the Product or would have paid less for it.
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`68. The Product is sold for a price premium compared to other similar products, no less
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`than $3.49 for 18.3 OZ (519 g), a higher price than it would otherwise be sold for, absent the
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`misleading representations and omissions.
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 10 of 16 Page ID #10
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`Jurisdiction and Venue
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`69.
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`Jurisdiction is proper pursuant to Class Action Fairness Act of 2005 (“CAFA”). 28
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`U.S.C. § 1332(d)(2).
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`70. The aggregate amount in controversy exceeds $5 million, including any statutory
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`damages, exclusive of interest and costs.
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`71. Plaintiff Donna Burns is a citizen of Illinois.
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`72. Defendant General Mills Sales, Inc. is a Delaware corporation with a principal place
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`of business in Minneapolis, Hennepin County, Minnesota
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`73. The parties are citizens of different states.
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`74. Venue is in this district because plaintiff resides in this district and the actions giving
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`rise to the claims occurred within this district.
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`75. Venue is in the East St. Louis Division because plaintiff resides in St. Clair County,
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`which is where the events giving rise to the present claims occurred.
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`Parties
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`76. Plaintiff Donna Burns is a citizen of O'Fallon, St. Clair County, Illinois.
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`77. Defendant General Mills Sales, Inc., is a Delaware corporation with a principal place
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`of business in Minneapolis, Minnesota, Hennepin County.
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`78. Defendant is one of the largest food companies in the world.
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`79. Defendant owns and controls the Betty Crocker brand of baking products, including
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`cake mixes.
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`80. Betty Crocker has been known as the “Grandmother of American Baking.”
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`81. While some claim she was a fictional character, other reports describe her as a
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`composite of several influential women who helped achieve food standards, through testimony
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 11 of 16 Page ID #11
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`and organization before Congress, during the passage of the Food, Drug & Cosmetic Act.
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`82. As a result, the Betty Crocker brand has always been synonymous with quality
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`ingredients and authenticity.
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`83. The Betty Crocker name is used for various baking products, because of her influence
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`in this sphere.
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`84. Consumers know that “If it’s good enough for Betty Crocker,” it is good enough for
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`them.
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`85. The Product is sold at thousands of retail locations – grocery stores, drug stores, big
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`box stores, convenience stores, etc. – and online.
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`86. Plaintiff bought the Product on one or more occasions within the statute of limitations
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`for each cause of action alleged, at stores including Walmart, 1530 W Hwy 50, O'Fallon, IL 62269,
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`between July and August 2021, among other times.
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`87. Plaintiff bought the Product because she expected it would contain ingredients
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`essential to fudge, understood by her as containing the above-identified traditional fudge
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`ingredients.
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`88. Plaintiff wanted more than a “fudge taste,” which she nevertheless failed to receive,
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`due to the relatively greater amount of vegetable oil vis-à-vis any dairy fat ingredients.
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`89. Plaintiff did not expect cake mix described as “fudge brownie” to have no fudge
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`ingredients.
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`90. Plaintiff bought the Product at or exceeding the above-referenced price.
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`91. Plaintiff relied on the representations identified here.
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`92. Plaintiff would not have purchased the Product if she knew the representations were
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`false and misleading.
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 12 of 16 Page ID #12
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`93. Plaintiff chose between Defendant’s Product and other similar products which were
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`represented similarly, but which did not misrepresent their attributes and/or lower-priced products
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`which did not make the claims made by Defendant.
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`94. The Product was worth less than what Plaintiff paid and she would not have paid as
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`much absent Defendant's false and misleading statements and omissions.
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`95. Plaintiff intends to, seeks to, and will purchase the Product again when she can do so
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`with the assurance that Product's representations are consistent with its composition.
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`Class Allegations
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`96. Plaintiff seeks certification under Fed. R. Civ. P. 23(b)(2) and (b)(3) of the following
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`classes:
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`Illinois Class: All persons in the State of Illinois who
`purchased the Product during the statutes of limitations for
`each cause of action alleged.
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`Consumer Fraud Multi-State Class: All persons in the
`States of Iowa and Arkansas who purchased the Product
`during the statutes of limitations for each cause of action
`alleged.18
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`97. Common questions of law or fact predominate and include whether defendant’s
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`representations were and are misleading and if plaintiff and class members are entitled to damages.
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`98. Plaintiff's claims and basis for relief are typical to other members because all were
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`subjected to the same unfair and deceptive representations and actions.
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`99. Plaintiff is an adequate representative because her interests do not conflict with other
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`members.
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`100. No individual inquiry is necessary since the focus is only on defendant’s practices
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`18 The States in the Consumer Fraud Multi-State Class are limited to those States with similar consumer fraud laws
`under the facts of this case: Iowa (Consumer Fraud and Private Right of Action for Consumer Frauds Act, Iowa Code
`Ann. § 714.16 et seq.); Arkansas (Arkansas Deceptive Trade Practices Act, Ark. Code § 4-88-101, et. seq.).
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`12
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 13 of 16 Page ID #13
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`and the class is definable and ascertainable.
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`101. Individual actions would risk inconsistent results, be repetitive and are impractical
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`to justify, as the claims are modest relative to the scope of the harm.
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`102. Plaintiff's counsel is competent and experienced in complex class action litigation
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`and intends to protect class members’ interests adequately and fairly.
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`103. Plaintiff seeks class-wide injunctive relief because the practices continue.
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`Illinois Consumer Fraud and Deceptive Business Practices Act
`(“ICFA”), 815 ILCS 505/1, et seq.
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`(Consumer Protection Statute)
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`104. Plaintiff incorporates by reference all preceding paragraphs.
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`105. Plaintiff and class members desired to purchase a product that contained fudge made
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`with the expected dairy ingredients of butter and milk, in their dry form, instead of substitutes for
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`these ingredients in the form of vegetable oils.
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`106. Defendant’s false and deceptive representations and omissions are material in that
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`they are likely to influence consumer purchasing decisions.
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`107. Defendant misrepresented the Product through statements, omissions, ambiguities,
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`half-truths and/or actions.
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`108. Plaintiff relied on the representations.
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`109. Plaintiff and class members would not have purchased the Product or paid as much
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`if the true facts had been known, suffering damages.
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`Violation of State Consumer Fraud Acts
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`(On Behalf of the Consumer Fraud Multi-State Class)
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`110. The Consumer Fraud Acts of the States in the Consumer Fraud Multi-State Class
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`Case 3:21-cv-01099 Document 1 Filed 09/03/21 Page 14 of 16 Page ID #14
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`prohibit the use of unfair or deceptive business practices in the conduct of trade or commerce.
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`111. Defendant intended that plaintiff and each of the other members of the Consumer
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`Fraud Multi-State Class would rely upon its deceptive conduct, and a reasonable person would in
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`fact be misled by this deceptive conduct.
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`112. As a result of defendant’s use or employment of artifice, unfair or deceptive acts or
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`business practices, plaintiff, and each of the other members of the Consumer Fraud Multi-State
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`Class, have sustained damages in an amount to be proven at trial.
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`113. In addition, defendant’s conduct showed malice, motive, and the reckless disregard
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`of the truth such that an award of punitive damages is appropriate.
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`Breaches of Express Warranty,
`Implied Warranty of Merchantability and
`Magnuson Moss Warranty Act, 15 U.S.C. §§ 2301, et seq.
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`114. The Product was manufactured, labeled, and sold by defendant and expressly and
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`impliedly warranted to plaintiff and class members that it contained fudge made with the expected
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`dairy ingredients of butter and milk, in their dry form, instead of substitutes for these ingredients
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`in the form of vegetable oils.
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`115. Defendant had a duty to disclose and/or provide non-deceptive descriptions and
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`marketing of the Product.
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`116. This duty is based on Defendant’s outsized role in the market for this type of Product.
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`117. Plaintiff provided or will provide notice to defendant, its agents, representatives,
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`retailers, and their employees.
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`118. Defendant received notice and should have been aware of these issues due to
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`complaints by regulators, competitors, and consumers, to its main offices.
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`119. The Product did not conform to its affirmations of fact and promises due to
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`defendant’s actions and were not merchantable because they were not fit to pass in the trade as
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`advertised.
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`120. Plaintiff and class members would not have purchased the Product or paid as much
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`if the true facts had been known, suffering damages.
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`Negligent Misrepresentation
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`121. Defendant had a duty to truthfully represent the Product, which it breached.
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`122. This duty is based on defendant’s position, holding itself out as having special
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`knowledge and experience this area, as custodian of the Betty Crocker brand.
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`123. The representations took advantage of consumers’ cognitive shortcuts made at the
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`point-of-sale and their trust in defendant, a nationally recognized and trusted brand.
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`124. Plaintiff and class members reasonably and justifiably relied on these negligent
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`misrepresentations and omissions, which served to induce and did induce, their purchase of the
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`Product.
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`125. Plaintiff and class members would not have purchased the Product or paid as much
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`if the true facts had been known, suffering damages.
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`Fraud
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`126. Defendant misrepresented and/or omitted the attributes and qualities of the Product,
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`that it contained fudge made with the expected dairy ingredients of butter and milk, in their dry
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`form, instead of substitutes for these ingredients in the form of vegetable oils
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`127. Defendant’s fraudulent intent is evinced by its knowledge that the Product was not
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`consistent with its representations.
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`Unjust Enrichment
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`128. Defendant obtained benefits and monies because the Product was not as represented
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`and expected, to the detriment and impoverishment of plaintiff and class members, who seek
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`restitution and disgorgement of inequitably obtained profits.
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`Jury Demand and Prayer for Relief
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`Plaintiff demands a jury trial on all issues.
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` WHEREFORE, Plaintiff prays for judgment:
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`1. Declaring this a proper class action, certifying plaintiff as representative and the
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`undersigned as counsel for the class;
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`2. Entering preliminary and permanent injunctive relief by directing defendant to correct the
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`challenged practices to comply with the law;
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`3. Injunctive relief to remove, correct and/or refrain from the challenged practices and
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`representations, and restitution and disgorgement for members of the class pursuant to the
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`applicable laws;
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`4. Awarding monetary damages, statutory and/or punitive damages pursuant to any statutory
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`claims and interest pursuant to the common law and other statutory claims;
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`5. Awarding costs and expenses, including reasonable fees for plaintiff's attorneys and
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`experts; and
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`6. Other and further relief as the Court deems just and proper.
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`Dated: September 4, 2021
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`Respectfully submitted,
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`Sheehan & Associates, P.C.
`/s/Spencer Sheehan
`60 Cuttermill Rd Ste 409
`Great Neck NY 11021
`Tel: (516) 268-7080
`spencer@spencersheehan.com
`
`16
`
`
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