elimination of CPA

From: pmorris@morrisiplaw.com
Sent: Wednesday, July 25, 2001 8:03 PM
To: AB37 Comments
Subject: elimination of CPA

The "RCE" and CPA are not redundant. When a notice of appeal has been filed,
and an agreement is essentially reached, an RCE cannot be filed. The CPA is the
most efficient route for all concerned in this instance. Furthermore, it is not clear to
this commentator that an RCE gives you the same scope of review as a CPA.
How many additional actions does an RCE require--only one. Or, are a first office
action and a final action provided?