Civil Jury Instructions – Use of Alternative Treatment Methods – Comment Period Expires June 28, 2024

Regarding CV324.
Removal of this instruction was long overdue. Defendants were attempting to have it included in the majority of medical malpractice cases, without any real explanation as to why it would apply. Judges seemed confused by the instruction and were often tempted to give into the defense argument that, “your honor, it’s in MUJI, so it must be a correct statement of the law.”
It is difficult to conceive of a scenario where this instruction would be appropriate. Giving the instruction is essentially a judicial declaration on how the jury should resolve disputes about which expert to believe. If the defense expert says there is more than one way to do something, this instruction tells the jury the defense expert is correct.
If there does happen to be a scenario where alternative methods of treatment would be within the standard of care, there is nothing stopping a judge from giving an appropriate, case specific, instruction. However, having a stock instruction in MUJI on this issue is not necessary.

It is great that CV324 was removed. It was way too confusing and defense counsel seemed to believe that it applied to every case and would push to have it in every trial even though it did not.

I agree with the removal of CV324 MUJI instruction because it is confusing for the Court and for jury members. It favors Defendants and is prejudicial to Plaintiffs. It should not be included in most medical malpractice case jury instructions. For example, in a retained object malpractice case, there is no argument that leaving the object in the person’s body is an alternative treatment method compliant with the standard of care.

June 28, 2024

Utah MUJI Committee
jacew@ucourts.gov

RE: MUJI 2d CV 324

Dear MUJI Committee:

The undersigned attorneys from the Utah State Bar practice in the area of medical malpractice defense. We hereby write to oppose the Committee’s removal of CV 324 from MUJI 2d. The reasons for our opposition are set forth below. We ask that CV 324 be returned to MUJI 2d and that public comment be allowed and considered before any changes to this instruction are adopted.

Procedural History of Removal of CV 324

The Committee made its decision to remove CV 324 without first giving notice of the proposed action and an opportunity to comment prior to its removal. The Committee’s unilateral decision to remove CV 324 is seemingly unprecedented. A review of the Committee’s meeting minutes reveals how this surprising action occurred.

MUJI is a Judicial Council Committee under the Utah Code of Judicial Administration. The Code of Judicial Administration does not prescribe procedures specific to MUJI Committee meetings. The MUJI Committee’s official website also does not include any rules or procedures overseeing drafting or meetings. For now, Meeting Minutes provide the most insight into the jury instruction revision process.

Apparent Procedure

From June 2021 through May 2024, the Committee held 23 meetings. Meeting Materials indicate that the Committee received public comments nine times in this span. From the Minutes, the Committee generally waits to formally adopt instructions or amendments until after the public comment period. For example, in the January 2024 meeting, the Committee voted to formally adopt CV132A once it noted that there were no public comments. Similar processes were followed in the September 2023 meeting on CV107A, CV632, CV632A, and CV632D, all of which were approved after noting there were no public comments. In February 2023, the Committee voted to keep proposed language in CV1607 in the absence of public comments on the amendment.

Similarly, when there are public comments, the Minutes indicate that the Committee will present, discuss, and consider public comments before voting to adopt an amendment. The Committee followed this procedure for CV2021 in the January 2024 meeting. In February 2023, the Committee reviewed a public comment on CV135 before voting to approve proposed clarifying language.

The Utah Judicial Council can also provide feedback on proposed instructions. In the December 2022 meeting, the Committee discussed Judicial Council feedback on instructions on avoiding bias. If the Judicial Council does not approve or disapprove of a proposed instruction, the Committee can send the instruction to the Board of District Court Judges for review or publish the instruction for public comment. Ultimately, the Committee decides which to do. Based off Meeting Materials for December 2022, the Committee sends all proposed jury instructions to Utah State Bar members for public comment. Here, the Committee sent this instruction on avoiding bias to the Judicial Council because of the possibility of controversy in the community “about the existence and impact of implicit bias.” However, the Materials indicate that this is not common, and the normal review process is to send proposed instructions for public comment.

The courts can also request that the Committee review certain instructions to be modified. For example, the Utah Supreme Court recommended the Committee review CV301C in Footnote 5 of Meeks v. Peng, 2024 UT 5, 545 P.3d 226. The Committee subsequently reviewed CV301C in the March 2024 meeting. This also appears to be uncommon because there were no similar instances in the last three years.

MUJI Committee Minutes on CV324

Minutes from the May 2024 meeting are still pending. Only the May Materials and the March Minutes discussing CV324 are available.

Todd Wahlquist from the Medical Malpractice Committee of the Utah Association for Justice was a guest at the March meeting and discussed potential issues with CV324. The Committee based its discussion on a case from eleven years ago, Turner v. University of Utah Hospitals and Clinics, 2013 UT 52, 310 P.3d 1212, wherein the trial judge issued a jury instruction based on CV324 for alternative treatment methods. Turner appealed the jury verdict of no negligence, alleging the district court erred by giving the instruction and that the jury was biased. The Supreme Court held that the lower court erred by including this instruction because there was “no evidence of any approved, alternate treatment method in the case.”

Mr. Wahlquist advocated for the removal of CV324, telling the Committee that the instruction may lead the jury to side with the defense because the court instructs them that there is more than one way to treat the plaintiff as a matter of law. However, some argued that the word “may” leaves it within the discretion of the jury, or that the instruction should be given when there is evidence that there is more than one way to meet the standard of care. After this discussion, a majority voted to remove the instruction. While the Committee did remove the instruction, it decided that there may be times where the instruction is still appropriate. Consequently, the Committee chose to note the removal, but stated that parties can still submit the instruction to the court for consideration. Discussion was scheduled to continue on the topic in the May meeting, however, the Minutes are not published yet. The next Committee meeting is scheduled for August.

Critically, there were no public comments in February or March 2024, prior to the Committee’s decision to remove CV324. Based on the Minutes, CV324 was only brought up in the March 2024 meeting, so the public had no notice to send comments prior to the instruction’s removal. This is unusual based on Minutes reviewed from the last three years. It is deeply concerning that advocacy by Mr. Wahlquist – an attorney who makes his living suing medical providers – prompted the Committee’s decision to remove CV324 without public comment.

Prior Meeting Minutes include instances where the Committee “informally approves” instructions, putting off a final vote until the next meeting, as in January 2024 for CV925A and June 2021 for CV1055. However, the Committee removed CV324 rather than opting for an “informal” decision as it has done in the past. The March Minutes note that discussion on CV324 would continue at the next meeting, but the May Minutes are not published and so it is unclear if discussion occurred.

There is possibly one other example of the Committee removing instructions in the June 2021 Minutes. The Minutes indicate that the Committee struck “CV1056 Product Liability- No duty to make a safe product safer” altogether after comparison with CV1002. However, the Committee noted it thought that CV1056 contained instructions already in CV1002. While this is a possible example of unilateral removal, it was because of duplicative instructions. This seems sufficiently distinct from CV324 because here there are no existing instructions similar to CV324.

CV 324 Should be Included in MUJI 2d

CV 324 was included as an instruction as far back as MUJI. The inclusion of CV 324 is well supported in Utah law. Mr. Wahlquist cited to Turner v. University of Utah Hospitals and Clinics, 2013 UT 52, 310 P.3d 1212, to support the removal of CV 324. However, under Turner, there may still be times when it is appropriate to give the instruction. The instruction at issue in Turner expressly stated that “it is not medical malpractice for a provider to select one of the approved methods…[w]hen there is more than one method of treatment.” 2013 UT 52 at ¶ 22 (emphasis added). There, the court was concerned that the instruction explicitly directed the jury to return a no negligence verdict if it found more than one method of treatment. Id. Here, CV324 does not explicitly instruct our juries that it is not medical malpractice when there is more than one method of treatment. MUJI 2d specifically revised the instruction to avoid this result. Rather, CV324 merely informs juries that the standard of care may include more than one acceptable method of treatment.

Moreover, the events at issue in Turner did not involve alternative methods of treatment. Id. at ¶ 24. There, the court held that there was no evidence to support the inclusion of the instruction because the defendant failed to show more than one method of treatment for the issue. Id. Accordingly, CV324 is still appropriate in cases where the condition at issue may be treated by a choice of accepted methods. Were this not the case, the court in Turner would have said not to use the alternative methods instruction anymore. Case law further provides that failure to treat a patient in the same way as another or to use a different method is not malpractice if the treatment used is approved by the medical community. See Walkenhorst v. Kesler, 92 Utah 312, 67 P.2d 654 (1937); see also, Butler v. Naylor, 1999 UT 85, 987 P.2d 41.

In addition, MUJI is consistent with numerous other states’ jury instructions that give a version of an alternative method of treatment instruction. These states’ instructions are generally more detailed than Utah’s and often include notes or case law from drafting committees. In states like New York, Ohio, Pennsylvania, and Wisconsin, the instruction notes specify that alternative methods should be mentioned when there is a showing that a condition has multiple acceptable treatments. Pennsylvania has the most detailed instructions, following the “two schools of thought” doctrine. However, numerous states outside Utah include jury instructions stating that doctors have discretion in choosing the method of treatment used, so long as the chosen method was performed with reasonable care. The following 18 states have very similar jury instructions.

Alabama

• Pattern instruction:

o “You have heard evidence in this case about different or alternative methods of treatment. If (name of defendant) had the choice of different or alternative methods of treatment and chose a method that was within the standard of care, the fact that there was a bad result because of the method used, cannot, in and of itself, be the reason to find against (him/her). However, you can find against (name of defendant) if the method used by (him/her) was not within the standard of care, or if the method used was proper, but (name of defendant) did not follow the standard of care in carrying out that method.” APJI 25.01.

• Notes on use:
o This instruction is to be used when it is contended that the method of treatment chosen by the doctor is the basis for the alleged negligent conduct of defendant doctor. This instruction may be used in conjunction with APJI 25.00, which refers to elements of proof for medical malpractice.

California
• Pattern instructions:

o “[A/An] [insert type of medical practitioner] is not necessarily negligent just because [he/she/nonbinary pronoun] chooses one medically accepted method of treatment or diagnosis and it turns out that another medically accepted method would have been a better choice.” CACI No. 506.

Florida

• Pattern instructions:

o Alternative 1: “If an individual health care provider [makes a diagnosis/provides treatment/follows a procedure] in a manner viewed as appropriate by other reasonably prudent health care providers with similar skill and training, then the health care provider cannot be found negligent. In other words, an individual health care provider is not held to the methods of one group of reasonably prudent and similar health care providers over the methods of other reasonably prudent and similar health care providers.”

[OR:]

o Alternative 2: “If more than one [method of diagnosis/method of treatment/procedure] is considered appropriate by reasonably prudent and similar health care providers, and an individual health care provider uses one of those [methods/procedures], he or she is not negligent merely because he or she chose the [method/procedure] that [choose from the following as appropriate: is not the most common or does not represent the most advanced (method/procedure)]. If the [method/procedure] utilized by the health care provider is approved by a respectable minority of the medical profession, then it meets the standard of care, and the provider may not be found negligent.” 3 Fla. Forms Jury Inst. § 80.20.

• Notes on use:

o Counsel is to choose between the two alternative jury instructions based on the evidence presented. Alternative 1 refers generally to evidence that various medical professionals hold different viewpoints. Alternative 2 refers specifically to evidence regarding the highest level of care or best-known technique. The Committee recommends Alternative 2 when, for example, an expert witness testifies and describes a quality of care and methods used at a specific hospital or research center, which may meet higher quality standards than those used by other medical professionals.

• Case law:

o Alternative methods of care are not substandard even if not the best, most effective, or most common method of care available. Medical professionals are permitted to use individual judgment and discretion, within reason. Baldor v. Rogers, 81 So. 2d 658 (Fla. 1954). If the method used is considered acceptable or appropriate by other reasonably skilled medical providers, liability does not arise. Baldor v. Rogers, 81 So. 2d 658, 660 (Fla. 1954). Whether a minority method of treatment is reasonable is a question for the trier of fact. See Russell v. Hardwick, 182 So. 2d 241 (Fla. 1966); see also Baldor v. Rogers, 81 So. 2d 658 (Fla. 1954) (emphasis added).

Hawaii

• Pattern instructions:

o “Where there is more than one recognized method of treatment, each of which conforms to the applicable standard of care, a physician does not breach the standard of care by utilizing one of these methods, provided such use conforms to the standard of care as defined by these instructions.” Haw. Civ. Jury Inst. No. 14.5.

Illinois

• Pattern instructions:

o “If more than one method of treatment for a [condition or illness or injury] is reasonable and appropriate, a [specify type of health care provider]’s choice of one method over another is not, in itself, a failure to exercise the appropriate skill and care, even if injury results. In determining whether [name of defendant] was negligent, you must consider whether [describe method of treatment] was a proper method of treatment for [describe plaintiff’s condition].” 2 Ill. Forms Jury Inst. § 62.13.

• Notes on use:
o This instruction is intended to clarify for the jury when expert testimony provides several different methods of treatment for a particular condition. The standard should be that of a reasonably well-qualified medical provider, rather than the highest level of care possible under the circumstances. Like Florida, here the Committee recommends this instruction especially when an expert witness is affiliated with a specific hospital or research center where treatment methods meet higher quality standards than those routinely used by other medical professionals.

• Case law:

o Defendant doctor’s choice of one treatment method over another alone is not a departure from the standard of care, even if it results in injury. Newell v. Corres, 466 N.E.2d 1085, 1088–1090 (1st Dist. 1984).

Indiana

• Pattern instructions:

o “[Health care providers] are allowed broad discretion in selecting treatment methods and are not limited to those most generally used.
o When more than one accepted method of treatment is available, the [type of health care provider] must use sound judgment in choosing which method to use.
o If a [type of health care provider] uses sound judgment in selecting from a variety of accepted treatments and uses reasonable care and skill in treating a patient, then the [type of health care provider] is not responsible if the treatment does not succeed.
o The fact that other methods existed or that another [type of health care provider] would have used a different treatment does not establish medical negligence.” Ind. Model Civ. Jury Inst. 1525.

Minnesota

Minnesota distinguishes the instructions between failure of treatment and error in diagnosis, but the language is otherwise identical.

• Pattern instructions:

o Failure of treatment: “A (doctor, dentist, specialist, advanced practice nurse or other healthcare provider) is not negligent (simply)(solely) because (his/her) efforts are unsuccessful.

o A failure of treatment is not negligence if the treatment was an accepted treatment based on the information the (doctor, dentist, specialist, advanced practice nurse or other healthcare provider) had or reasonably should have had, when the choice was made.
o A (doctor, dentist, specialist, advanced practice nurse or other healthcare provider) must use reasonable care to get the information needed to exercise his or her professional judgment. An unsuccessful treatment chosen because a (doctor, dentist, specialist, advanced practice nurse or other healthcare provider) did not use this reasonable care would be negligence.”
o Error in diagnosis: “A (doctor, dentist, specialist, advanced practice nurse or other healthcare provider) is not negligent (simply)(solely) because (his/her) efforts are unsuccessful.
o An error in diagnosis is not negligence if the diagnosis was an accepted diagnosis based on the information the (doctor, dentist, specialist, advanced practice nurse or other healthcare provider) had or reasonably should have had, when the diagnosis was made.
o A (doctor, dentist, specialist, advanced practice nurse or other healthcare provider) must use reasonable care to get the information needed to exercise his or her professional judgment. An error in diagnosis made because a (doctor, dentist, specialist, advanced practice nurse or other healthcare provider) did not use this reasonable care would be negligence.]” CIVJIG 80.10.

New Hampshire

• Pattern instructions:

o “[A/An] [insert type of medical practitioner] is not necessarily negligent just because [he/she] chooses one medically accepted method of treatment or diagnosis and it turns out that another medically accepted method would have been a better choice.” 1 N.H. Civ. Jury Inst. NS13.102.

New Mexico

• Pattern instructions:

o “Where there is more than one medically accepted method of [diagnosis] [treatment] [or] [care], it is not negligent for a [health care provider] to select any of the accepted methods.” 13-1111 NMRA.

New York

• Pattern instructions:

o “This paragraph should only be charged when there is evidence that the doctor made a choice among medically acceptable alternatives. See Caveat 2 below: A doctor is not liable for an error in judgment if (he, she) does what (he, she) decides is best after careful evaluation if it is a judgment that a reasonably prudent doctor could have made under the circumstances. In other words, a doctor is not liable for malpractice if he or she chooses one of two or more medically acceptable courses of action.” NY PJI 2:150.

• Caveat 2:

o This instruction should only be used when there is a showing that defendant considered and chose among several medically acceptable alternatives.

Ohio

• Pattern instructions:

o “DIFFERENT METHODS (ADDITIONAL). Although some other (physician) (surgeon) might have used a method of (diagnosis) (treatment) (procedure) different from that used by the defendant, this circumstance will not by itself prove that the defendant was negligent. You shall decide whether the (diagnosis) (treatment) (procedure) used by the defendant was in accordance with the required standard of care.” OJI-CV 417.03.

• Notes on use:

o This instruction should only be given if there is evidence that more than one method/diagnosis/treatment is acceptable for the medical condition. See Pesek v. University Neurologists Assoc., 87 Ohio St.3d 495.

Oklahoma

• Pattern instructions:

o “Where there is more than one medically accepted method of [diagnosis/treatment], a physician has the right to use his/her best judgment in the selection of the [diagnosis/treatment], after securing the informed consent of the patient, even though another medically accepted method of [diagnosis/treatment] might have been more effective.” Vernon’s Okla. Forms 2d, OUJI-CIV 14.3.

Pennsylvania

• Pennsylvania has adopted a “two schools of thought” doctrine when allegations involve the doctor’s error choosing between various treatment methods. The doctor has a burden to demonstrate sound judgment when deciding between treatment methods. There is no liability when the chosen method is acceptable by a “considerable number” of colleagues in the same or similar practice or specialty.

• Pattern instructions:

o “Where competent medical authority is divided, a physician will not be held responsible if, in using their judgment, the physician followed a course of treatment advocated by a considerable number of recognized and respected professionals in their given area of expertise. This is known as the ‘two schools of thought’ doctrine.

o [Name of defendant] claims that, in treating [name of plaintiff], [he] [she] [they] consciously chose to follow a course of treatment. [Name of defendant] has the burden of proving, by a fair preponderance of the evidence, that a considerable number of recognized and respected professionals advocated the same course of treatment, that [he] [she] [they] [was] [were] aware of these professionals advocating this same course of treatment at the time [he] [she] [they] treated [name of plaintiff], and that in treating [name of plaintiff] [he] [she] [they] consciously chose to follow their recommended course of treatment. If you decide that [name of defendant] has met this burden of proof, then you should find for [name of defendant].” Pa. SSJI (Civ) 14.50.

• Case law:

o It is improper to instruct the jury on the “two schools of thought” doctrine when the question is whether the doctor properly diagnosed the plaintiff’s condition. Morganstein v. House, 547 A.2d 1180 (Pa. Super. 1988) (emphasis added). The doctrine is applicable only where a condition has more than one method of accepted treatment. Jones v. Chidester, 610 A.2d 964, 965 (Pa. 1992). If medical authority is divided, a doctor will not be held responsible if, in the exercise of the doctor’s judgment, they followed a course of treatment “advocated by a considerable number of recognized and respected professionals in his given area of expertise.” Id. The burden of proving that there are two schools of thought falls to the defendant, but “[t]he proper use of expert witnesses should supply the answers.” Id.

South Carolina

• Pattern instructions:

o “A physician [cardiologist, dermatologist, surgeon, etc.] is not bound to use any particular method of treatment if among physicians [cardiologists, dermatologists, surgeons, etc.] of ordinary skill and learning, more than one method of treatment is recognized. It is proper for a physician [cardiologist, dermatologist, surgeon, etc.] to adopt any recognized method. The fact that some other method of treatment existed, or some other physician [cardiologist, dermatologist, surgeon, etc.] might or would have used or advised a different method, does not establish negligence on the part of the physician [cardiologist, dermatologist, surgeon, etc.]” S.C. Requests to Charge- Civ., 27-2.

Tennessee

• Pattern instructions:

o “When there is more than one accepted method of diagnosis or treatment, and no one of them is used exclusively and uniformly by all physicians of good standing, a physician is not negligent for selecting an accepted method of diagnosis or treatment that later turns out to be unsuccessful. This is true even if the method is one not favored by certain other physicians.” 8 Tenn. Prac. Pattern Jury Instr. T.P.I.- Civ. 6.14 (2023 ed.)

Virginia

• Pattern instructions:

o “It was the duty of the defendant to exercise that degree of skill and diligence [practiced/rendered] by a reasonably prudent [physician/dentist/nurse/hospital/health care provider] based on the standard of care found by the jury to be applicable in this case in accordance with [another instruction of the court/Instruction No. [number of instructions]]. If you believe from a preponderance of the evidence that the defendant failed to perform the foregoing duty, then the defendant was negligent. If you further believe from such evidence that any such negligence was the proximate cause of injury to the plaintiff, then you shall find your verdict in favor of the plaintiff.” Va. Prac. Jury Inst. § 41:2.

• Notes on use:

o A difference in views between medical professionals regarding treatment or medical judgment exercised is insufficient to support a malpractice action where it is shown that the judgment exercised is an acceptable method of treatment under the circumstances.

West Virginia

• Pattern instructions:

o “Sometimes the standard of care for treating a patient involves consideration of different methods of diagnosis or treatment that are widely and generally recognized within the medical community. A [insert type of health care provider] must use [his/her] professional judgment in choosing what [he/she] believes to be the most effective [treatment/diagnosis] option in a given situation. Just because a [insert type of health care provider] chooses one recognized method of [treatment/diagnosis] instead of another does not mean [he/she] breached the standard of care. When there is more than one recognized method of [treatment/diagnosis] used by [insert type of health care provider], a reasonable and prudent [insert type of health care provider] may select one of the recognized options of [treatment/diagnosis].

o However, a [insert type of health care provider] who uses a widely and generally recognized method of treatment or diagnosis must utilize the method with the degree of care, skill and learning that would be provided by a reasonable and prudent [insert type of health care provider] in the same or similar circumstances.” W.V. Pattern Jury Instr. Civ. § 505.

Wisconsin

• Pattern instructions:

o “Use this paragraph only if there is evidence of two or more alternative methods of treatment or diagnosis recognized as reasonable: If you find from the evidence that more than one method of (treatment for) (diagnosing) (plaintiff)’s (injuries) (condition) was recognized as reasonable given the state of medical knowledge at that time, then (doctor) was at liberty to select any of the recognized methods . (Doctor) was not negligent because (he) (she) chose to use one of these recognized (treatment) (diagnostic) methods rather than another recognized method if (he) (she) used reasonable care, skill, and judgment in administering the method.” WIS JI-CIVIL JI-1023.

CV 324’s Use in Utah Trials

Not only is CV 324 well supported by Utah law and in instructions from other jurisdictions, but its use is also common in medical malpractice cases tried in Utah. CV 324 has been given in several Utah trials including Knowles v. Smith, Case No. 190401925 (4th Dist. Ct. Utah County); Gillins v. Gardner, Case No. 150400088 (4th Dist. Ct. Utah County) Bolda v. Brian, Case No. 180907031 (3rd Dist. Ct. Salt Lake County); Spivey v. Douglas; Case No. 180302125 (3rd Dist. Ct. Tooele County); and Nelson v. Jahn, Case No. 190300289 (3rd Dist. Ct. Tooele County).

Conclusion

We have now demonstrated why CV 324 should be included in the MUJI 2d. We acknowledge that CV 324 may not be appropriate in every case, but there is no reason it should not be included. Judges should be allowed the discretion to give the instruction when supported by the evidence – just like every other instruction. The unilateral removal of CV 324 from MUJI 2d without public comment was inappropriate, and we ask the Committee not to make any unilateral removal of any instruction in the future. We welcome the opportunity to discuss CV 324 at a future meeting of the Committee.

Respectfully,

Electronically signed, with permission, by the following:

STRONG & HANNI KIPP & CHRISTIAN NELSON NAEGLE
Michael Miller Shawn McGarry Brandon Hobbs
Kathleen Abke Nan Bassett Cortney Kochevar
Karmen Schmid Kirk Gibbs Kristina Ruedas
Dustin Johnson Chelsey Phippen Greg Soderberg
Savanna Jones Katie Conrad

EPPERSON & OWENS RICHARDS, BRANDT, BURBIDGE, VAN KOMEN,
Steve Owens MILLER & NELSON TANNER & SCRUGGS
David Epperson Rafael Seminario Nate Burbidge
Scott Epperson Patrick Tanner
James Egan Paul Van Komen
Elliot Scruggs

HALL, PRANGLE & KIRTON McCONKIE CAMPBELL, WILLIAMS,
SCHOONVELD Mary Essuman BEECH & HALL
Shelley Doi-Taketa Justin Pendleton Vaun Hall
Derek Williams

SPENCER FANE JONES SKELTON RENCHER ANJEWIERDEN
Brian Miller Michael Collins Greg Anjewierden
Christopher Droubay Cami Schiel
Joel Taylor