2025-02-28T13:11:00-05:00 2023-12-31 364538293 LUDWIG KLEWER & RUDNER PLLC 4783 E CAMP LOWELL DR TUCSON AZ 85712 990 2023-01-01 860658103 FLORENCE IMMIGRANT & REFUGEE RIGHTS PROJECT FLOR 5207775600 PO BOX 86299 TUCSON AZ 857546299 LILLIAN APONTE EXECUTIVE DIRECTOR 5207775600 2025-02-26 true JULIE S KLEWER CPA P00343046 5205450500 2025-02-28 2023 2025-03-06 01:10:19Z X LILLIAN APONTE PO BOX 86299 TUCSON AZ 85754 35290911 false X FIRRP.ORG X 1989 THE FLORENCE PROJECT PROVIDES AND COORDINATES LEGAL SERVICES AND RELATED SOCIAL SERVICES TO INDIGENT MEN, WOMEN, AND UNACCOMPANIED CHILDREN DETAINED IN ARIZONA FOR IMMIGRATION REMOVAL PROCEEDINGS. 18 18 244 125 0 33683341 4890988 5505 11974862 551532 931357 0 34240378 17797207 0 0 13774985 15936549 0 1272279 3395504 3826004 17170489 19762553 17069889 -1965346 35440366 36255645 1034697 2487410 34405669 33768235 X THE FLORENCE PROJECT PROVIDES AND COORDINATES LEGAL SERVICES AND RELATED SOCIAL SERVICES TO INDIGENT MEN, WOMEN, AND UNACCOMPANIED CHILDREN DETAINED IN ARIZONA FOR IMMIGRATION REMOVAL PROCEEDINGS. false false 15563536 11974862 THE FLORENCE IMMIGRANT & REFUGEE RIGHTS PROJECT PROVIDES FREE LEGAL AND SOCIAL SERVICES TO ADULTS AND CHILDREN IN ARIZONA IMMIGRATION DETENTION THROUGH ITS ADULT LEGAL PROGRAM, CHILDREN'S LEGAL PROGRAM, AND SOCIAL SERVICES PROGRAM. THE FLORENCE PROJECT ADDITIONALLY PROVIDES LEGAL ORIENTATIONS AT THE U.S.-MEXICO BORDER AND ENGAGES IN ADVOCACY TO PROTECT AND ADVANCE IMMIGRANTS' RIGHTS. THROUGH OUR ADULT LEGAL PROGRAM, WE SERVED DETAINED ADULT INDIVIDUALS AT FACILITIES LOCATED IN ELOY AND FLORENCE, ARIZONA. WE PROVIDED CASE ASSISTANCE OVER 2,364 TIMES AND MAILED OVER 7,545 LEGAL EDUCATION PACKETS TO PROVIDE SELF-HELP CASE SUPPORT. WE PROVIDED DIRECT REPRESENTATION TO 216 ADULTS, INCLUDING 106 PEOPLE WHO WERE APPOINTED COUNSEL AFTER A JUDGE FOUND THEM UNABLE TO REPRESENT THEMSELVES. WE ALSO REPRESENTED ADULTS ON APPEAL AT THE BOARD OF IMMIGRATION APPEALS AND THE 9TH CIRCUIT COURT OF APPEALS. OUR CHILDREN'S LEGAL PROGRAM DELIVERED "KNOW YOUR RIGHTS" PRESENTATIONS TO 17,562 UNACCOMPANIED CHILDREN. WE MET WITH 14,520 CHILDREN TO PROVIDE INDIVIDUAL CASE ASSESSMENTS. OVER 1,050 CHILDREN RECEIVED FULL LEGAL REPRESENTATION. WE REMINDED EACH CHILD THAT THEY HAVE THE RIGHT TO SAFETY AND PRIVACY WHILE IN GOVERNMENT FACILITIES. WE INQUIRED AS TO THE LENGTH OF THEIR STAYS IN DETENTION AND ASKED THE CHILD IF THE GOVERNMENT POSED OBSTACLES TO THEIR REUNIFICATION WITH FAMILY. WE ADVOCATED ON THEIR BEHALF IF THEY WERE SEPARATED FROM THEIR CAREGIVERS OR DENIED MEDICAL CARE. OUR SOCIAL SERVICES PROGRAM PROVIDED LIFESAVING SOCIAL SERVICES TO 490 PEOPLE. BECAUSE IMMIGRATION REMOVAL PROCEEDINGS ARE COMPLEX AND MAY TAKE YEARS TO COMPLETE, OUR SOCIAL SERVICES PROGRAM ENSURES PEOPLE EXPERIENCING SERIOUS PSYCHOLOGICAL NEEDS, IN DIRE NEED OF MEDICAL SERVICES, AT RISK OF TRAFFICKING, OR IN NEED OF ADVOCACY ARE HOLISTICALLY SUPPORTED. OUR SOCIAL WORKERS CREATE BRIDGES FOR PEOPLE TO NAVIGATE NEW PROCESSES THAT MAY BE UNFAMILIAR DUE TO DIFFERENCES IN CULTURE, LANGUAGE, OR IMMIGRATION STATUS. OUR LEGAL AND SOCIAL SERVICES TEAMS RESPONDED TO 120 CASES OF FAMILY SEPARATION WITH ADVOCACY TO REUNIFY FAMILIES, INCLUDING 63 CASES BETWEEN A PARENT AND A CHILD. OUR LEGAL AND SOCIAL SERVICES TEAMS ALSO AIDED 270 CHILDREN WHO WERE UNDER THE AGE OF 5, MANY OF WHOM WERE PREVERBAL OR HAD DIFFICULTY EXPRESSING WHAT HAD OCCURRED TO THEM. EACH ONE OF THESE CHILDREN HAD AN ATTORNEY AND A SOCIAL WORKER ASSESS THEIR CASE DUE TO THEIR TENDER AGE AND THE NEED FOR INTENSIVE SUPPORT. AT THE BORDER, WE PROVIDED LEGAL ORIENTATIONS TO OVER 4,164 ADULTS IN NOGALES, SONORA, MEXICO, THAT DIRECTLY AFFECTED OVER 5,406 PEOPLE WHEN CONSIDERING THE ACCOMPANYING FAMILY MEMBERS. WE PROVIDED INDIVIDUAL CONSULTATIONS TO OVER 393 PEOPLE AT THE BORDER TO EXPLAIN CURRENT POLICIES AND TO PROVIDE GENERAL LEGAL EDUCATION ABOUT THE RIGHTS OF ASYLUM SEEKERS. FURTHERMORE, WE HOUSE A ROBUST PRO BONO PROGRAM THAT PROVIDES MENTORSHIP TO ATTORNEYS IN OUR COMMUNITY TO EXPAND OUR REACH. IN 2023, WE MENTORED PRO BONO ATTORNEYS THROUGH 53 NEW LEGAL MATTERS. OUR PRO BONO PARTNERS ENGAGED IN VARIOUS LEGAL MATTERS RANGING FROM INDIVIDUAL REPRESENTATION TO MAJOR LAWSUITS. THROUGH OUR ADVOCACY TEAM, WE ADVOCATED ON BEHALF OF OUR CLIENTS WITH VARIOUS GOVERNMENT AGENCIES. WE OPPOSED POLICIES AND REGULATORY CHANGES THAT LIMITED ASYLUM ACCESS AT THE BORDER BECAUSE THE LAW DICTATES THAT PEOPLE BE ALLOWED TO SEEK ASYLUM IN THE U.S. REGARDLESS OF MANNER OF ENTRY. WE PURSUED LITIGATION TO OPPOSE THE UNJUST TREATMENT OF PEOPLE AT THE SOUTHERN BORDER AND IN DETENTION. WE LITIGATED 30 INDIVIDUAL CASES BEFORE THE COURTS OF APPEAL (THE COURTS IMMEDIATELY UNDER THE SUPREME COURT) AND RESOLVED AT LEAST 13 OF THOSE CASES, INCLUDING SOME MAJOR WINS. WE SIGNED OR DRAFTED AT LEAST 7 AMICUS BRIEFS, FILED 10 ORGANIZATIONAL OR JOINT COMMENTS ON PROPOSED RULES AND REGULATIONS, AND JOINED MORE THAN 50 JOINT ADVOCACY EFFORTS. WE FOUND EVERY POSSIBLE AVENUE TO ADVOCATE ON BEHALF OF OUR CLIENTS. WE REMAIN COMMITTED TO A VISION WHERE ALL IMMIGRANTS FACING REMOVAL HAVE ACCESS TO COUNSEL, UNDERSTAND THEIR RIGHTS, AND ARE TREATED FAIRLY AND HUMANELY. 15563536 true true false true false false false false false true true false false false true true true false false false false false false false false false false false false true false false false false false false false false false false false false false false false false false true 47 0 244 true false false false false false false false false false false false false X 18 18 false false false false false false false true true false false true true true true true true true false false X X THE ORGANIZATION 5207775600 PO BOX 86299 TUCSON AZ 85716 LILLIAN APONTE EXECUTIVE DI 40.00 X 203859 0 6340 LAURA ST JOHN LEGAL DIRECT 40.00 X 153126 0 12989 GABRIELLA CORRALES DIR. OF PHIL 40.00 X 132196 0 10217 KAITLIN PORTER SOCIAL SERV 40.00 X 119009 0 11624 ROXANA AVILA-CIMPEANU CHILDREN'S P 40.00 X 106329 0 17983 DAVID K ANDROFF BOARD MEMBER 5.00 X 0 0 0 ANGELA BANKS BOARD MEMBER 5.00 X 0 0 0 JOSH BENDOR BOARD MEMBER 5.00 X 0 0 0 ARMANDO BERNASCONI BOARD MEMBER 5.00 X 0 0 0 TYLER CARRELL BOARD MEMBER 5.00 X 0 0 0 JOSE CARRILLO BOARD VICE P 5.00 X X 0 0 0 MILAGROS CISNEROS BOARD PRESID 5.00 X X 0 0 0 HAYLEIGH CRAWFORD BOARD MEMBER 5.00 X 0 0 0 IRA FELDMAN BOARD MEMBER 5.00 X 0 0 0 NATHAN FIDEL BOARD SECRET 5.00 X X 0 0 0 TY FRANKEL BOARD MEMBER 5.00 X 0 0 0 ALAN GOLD BOARD TRESUR 5.00 X X 0 0 0 LETICIA HERNANDEZ BOARD MEMBER 5.00 X 0 0 0 MARGARET KIRCH BOARD MEMBER 5.00 X 0 0 0 DEIRDRE MOKOS BOARD MEMBER 5.00 X 0 0 0 BENJAMIN A NUCCI BOARD MEMBER 5.00 X 0 0 0 CHRISTIAN RUIZ BOARD MEMBER 5.00 X 0 0 0 MARGARITA SILVA BOARD MEMBER 5.00 X 0 0 0 ANDREW SILVERMAN BOARD MEMBER 5.00 X 0 0 0 CINDY VILLANUEVA BOARD VICE P 5.00 X X 0 0 0 EMILY WARD BOARD MEMBER 5.00 X 0 0 0 ROBYN YOUNG BOARD MEMBER 5.00 X 0 0 0 714519 59153 5 false true false 4890988 1250 4890988 CONTRACT REVENUE 900099 11944831 11944831 OTHER INCOME 30031 30031 11974862 937382 937382 17487679 17493704 -6025 -6025 -6025 17797207 11974862 931357 210199 168159 31530 10510 12883632 10306907 1932544 644181 354267 283414 53140 17713 1565346 1252277 234802 78267 923105 738484 138466 46155 455851 455851 61286 61286 97059 97059 228052 118369 107122 2561 51309 51309 652323 345312 34259 272752 457040 337631 44235 75174 710355 664200 21785 24370 554789 489057 32797 32935 557 557 33727 33727 157410 129344 23786 4280 RECRUITING AND TRAINING 140525 72760 58254 9511 LEGAL MATERIALS 81393 81393 CLIENT SERVICES 75721 72979 2742 STAFF EVENTS 68607 47399 18647 2561 19762553 15563536 2926738 1272279 768017 1169243 2862736 7465522 4611789 3952236 102108 109801 813420 466912 361234 346508 27122287 21107950 229056 42692 1444832 35440366 36255645 1010552 1556115 24145 931295 1034697 2487410 X 25177819 25387488 9227850 8380747 34405669 33768235 35440366 36255645 X -1965346 1278106 18121 31685 X false true true false X 5890139 6933102 7971490 23306140 4890988 48991859 5890139 6933102 7971490 23306140 4890988 48991859 22495779 26496080 282598 107783 343920 551532 937382 2223215 29816 5505 30031 65352 51280426 45848646 0.51670 0.46100 X PART II, LINE 10 65,352 RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED false true false true 948 false false true 223 false false 1171 false SCHEDULE C, PART IV THE FLORENCE PROJECT (FIRRP)ENGAGES IN MINIMAL LOBBYING ACTIVITIES, PRIMARILY CONSISTING OF JOINING NATIONAL COALITIONS TO CALL FOR LEGISLATIVE, REGULATORY, AND FUNDING APPROACHES THAT SERVE IMMIGRANT COMMUNITIES AND ENHANCE ACCESS TO JUSTICE FOR IMMIGRANTS AT THE BORDER AND IN REMOVAL PROCEEDINGS. WE ALSO ENGAGE IN MINIMAL DIRECT OUTREACH TO ELECTED OFFICIALS ON ISSUES OF GREAT IMPORTANCE TO OUR MISSION, AND POST ON OUR SOCIAL MEDIA ACCOUNTS ABOUT THESE ISSUES. ONLY A FEW SELECT MEMBERS OF OUR ADVOCACY TEAM ENGAGE IN LOBBYING EFFORTS, AND EACH TRACKS TIME SPENT ON LOBBYING ACTIVITIES, WHICH IN 2023 AMOUNTED TO LESS THAN 25 HOURS, REPRESENTING A VERY SMALL PORTION OF THEIR OVERALL WORK AT FIRRP. 229056 50000 34446 2761 310741 112386 157000 -38909 1421 229056 102500 9886 112386 0.52000 0.48000 false false 42500 42500 414839 186089 228750 186520 141664 44856 169561 139159 30402 346508 LEASE LIABILITIES 931295 931295 X 19182818 1278106 204564 1482670 17700148 97059 97059 17797207 19935432 172879 172879 19762553 19762553 SCHEDULE D, PAGE 2, PART V, LINE 4 EARNINGS FROM ENDOWMENT FUNDS ARE USED FOR PROGRAM ACTIVITIES. SCHEDULE D, PAGE 3, PART X FLORENCE IMMIGRANT AND REFUGEE RIGHTS PROJECT, INC'S POLICY IS TO DISCLOSE OR RECOGNIZE INCOME TAX POSITIONS BASED ON MANAGEMENT'S ESTIMATE OF WHETHER IT IS REASONABLY POSSIBLE OR PROBABLE, RESPECTIVELY, THAT A LIABILITY HAS BEEN INCURRED FOR UNRECOGNIZED INCOME TAX POSITIONS. AS OF DECEMBER 31, 2023, THERE WERE NO UNCERTAIN TAX POSITIONS THAT ARE POTENTIALLY MATERIAL. SCHEDULE D, PAGE 4, PART XI, LINE 2D IN KIND SERVICES 172,879 CHANGE IN BEN INT HELD BY OTHERS 31,685 SCHEDULE D, PAGE 4, PART XII, LINE 2D IN KIND SERVICES 172,879 X X false false false false false false false false false LILLIAN APONTE EXECUTIVE DIRECTOR 185759 18100 6340 210199 LAURA ST JOHN LEGAL DIRECTOR 152026 1100 12989 166115 FORM 990, PAGE 1, ITEM B THE BOARD OF DIRECTORS LIST WAS INCOMPLETE ON THE PREVIOUSLY FILED FORM 990, AS A RESULT THE AMENDED RETURN IS BEING FILED. FORM 990, PAGE 2, PART III, LINE 4A THE FLORENCE IMMIGRANT & REFUGEE RIGHTS PROJECT PROVIDES FREE LEGAL AND SOCIAL SERVICES TO ADULTS AND CHILDREN IN ARIZONA IMMIGRATION DETENTION THROUGH ITS ADULT LEGAL PROGRAM, CHILDREN'S LEGAL PROGRAM, AND SOCIAL SERVICES PROGRAM. THE FLORENCE PROJECT ADDITIONALLY PROVIDES LEGAL ORIENTATIONS AT THE U.S.-MEXICO BORDER AND ENGAGES IN ADVOCACY TO PROTECT AND ADVANCE IMMIGRANTS' RIGHTS. THROUGH OUR ADULT LEGAL PROGRAM, WE SERVED DETAINED ADULT INDIVIDUALS AT FACILITIES LOCATED IN ELOY AND FLORENCE, ARIZONA. WE PROVIDED CASE ASSISTANCE OVER 2,364 TIMES AND MAILED OVER 7,545 LEGAL EDUCATION PACKETS TO PROVIDE SELF-HELP CASE SUPPORT. WE PROVIDED DIRECT REPRESENTATION TO 216 ADULTS, INCLUDING 106 PEOPLE WHO WERE APPOINTED COUNSEL AFTER A JUDGE FOUND THEM UNABLE TO REPRESENT THEMSELVES. WE ALSO REPRESENTED ADULTS ON APPEAL AT THE BOARD OF IMMIGRATION APPEALS AND THE 9TH CIRCUIT COURT OF APPEALS. OUR CHILDREN'S LEGAL PROGRAM DELIVERED "KNOW YOUR RIGHTS" PRESENTATIONS TO 17,562 UNACCOMPANIED CHILDREN. WE MET WITH 14,520 CHILDREN TO PROVIDE INDIVIDUAL CASE ASSESSMENTS. OVER 1,050 CHILDREN RECEIVED FULL LEGAL REPRESENTATION. WE REMINDED EACH CHILD THAT THEY HAVE THE RIGHT TO SAFETY AND PRIVACY WHILE IN GOVERNMENT FACILITIES. WE INQUIRED AS TO THE LENGTH OF THEIR STAYS IN DETENTION AND ASKED THE CHILD IF THE GOVERNMENT POSED OBSTACLES TO THEIR REUNIFICATION WITH FAMILY. WE ADVOCATED ON THEIR BEHALF IF THEY WERE SEPARATED FROM THEIR CAREGIVERS OR DENIED MEDICAL CARE. OUR SOCIAL SERVICES PROGRAM PROVIDED LIFESAVING SOCIAL SERVICES TO 490 PEOPLE. BECAUSE IMMIGRATION REMOVAL PROCEEDINGS ARE COMPLEX AND MAY TAKE YEARS TO COMPLETE, OUR SOCIAL SERVICES PROGRAM ENSURES PEOPLE EXPERIENCING SERIOUS PSYCHOLOGICAL NEEDS, IN DIRE NEED OF MEDICAL SERVICES, AT RISK OF TRAFFICKING, OR IN NEED OF ADVOCACY ARE HOLISTICALLY SUPPORTED. OUR SOCIAL WORKERS CREATE BRIDGES FOR PEOPLE TO NAVIGATE NEW PROCESSES THAT MAY BE UNFAMILIAR DUE TO DIFFERENCES IN CULTURE, LANGUAGE, OR IMMIGRATION STATUS. OUR LEGAL AND SOCIAL SERVICES TEAMS RESPONDED TO 120 CASES OF FAMILY SEPARATION WITH ADVOCACY TO REUNIFY FAMILIES, INCLUDING 63 CASES BETWEEN A PARENT AND A CHILD. OUR LEGAL AND SOCIAL SERVICES TEAMS ALSO AIDED 270 CHILDREN WHO WERE UNDER THE AGE OF 5, MANY OF WHOM WERE PREVERBAL OR HAD DIFFICULTY EXPRESSING WHAT HAD OCCURRED TO THEM. EACH ONE OF THESE CHILDREN HAD AN ATTORNEY AND A SOCIAL WORKER ASSESS THEIR CASE DUE TO THEIR TENDER AGE AND THE NEED FOR INTENSIVE SUPPORT. AT THE BORDER, WE PROVIDED LEGAL ORIENTATIONS TO OVER 4,164 ADULTS IN NOGALES, SONORA, MEXICO, THAT DIRECTLY AFFECTED OVER 5,406 PEOPLE WHEN CONSIDERING THE ACCOMPANYING FAMILY MEMBERS. WE PROVIDED INDIVIDUAL CONSULTATIONS TO OVER 393 PEOPLE AT THE BORDER TO EXPLAIN CURRENT POLICIES AND TO PROVIDE GENERAL LEGAL EDUCATION ABOUT THE RIGHTS OF ASYLUM SEEKERS. FURTHERMORE, WE HOUSE A ROBUST PRO BONO PROGRAM THAT PROVIDES MENTORSHIP TO ATTORNEYS IN OUR COMMUNITY TO EXPAND OUR REACH. IN 2023, WE MENTORED PRO BONO ATTORNEYS THROUGH 53 NEW LEGAL MATTERS. OUR PRO BONO PARTNERS ENGAGED IN VARIOUS LEGAL MATTERS RANGING FROM INDIVIDUAL REPRESENTATION TO MAJOR LAWSUITS. THROUGH OUR ADVOCACY TEAM, WE ADVOCATED ON BEHALF OF OUR CLIENTS WITH VARIOUS GOVERNMENT AGENCIES. WE OPPOSED POLICIES AND REGULATORY CHANGES THAT LIMITED ASYLUM ACCESS AT THE BORDER BECAUSE THE LAW DICTATES THAT PEOPLE BE ALLOWED TO SEEK ASYLUM IN THE U.S. REGARDLESS OF MANNER OF ENTRY. WE PURSUED LITIGATION TO OPPOSE THE UNJUST TREATMENT OF PEOPLE AT THE SOUTHERN BORDER AND IN DETENTION. WE LITIGATED 30 INDIVIDUAL CASES BEFORE THE COURTS OF APPEAL (THE COURTS IMMEDIATELY UNDER THE SUPREME COURT) AND RESOLVED AT LEAST 13 OF THOSE CASES, INCLUDING SOME MAJOR WINS. WE SIGNED OR DRAFTED AT LEAST 7 AMICUS BRIEFS, FILED 10 ORGANIZATIONAL OR JOINT COMMENTS ON PROPOSED RULES AND REGULATIONS, AND JOINED MORE THAN 50 JOINT ADVOCACY EFFORTS. WE FOUND EVERY POSSIBLE AVENUE TO ADVOCATE ON BEHALF OF OUR CLIENTS. WE REMAIN COMMITTED TO A VISION WHERE ALL IMMIGRANTS FACING REMOVAL HAVE ACCESS TO COUNSEL, UNDERSTAND THEIR RIGHTS, AND ARE TREATED FAIRLY AND HUMANELY. FORM 990, PAGE 6, PART VI, LINE 11B THE FORM 990 IS PREPARED BY A CPA FIRM. THE FORM 990 IS THEN REVIEWED BY THE TREASURER AND THE EXECUTIVE DIRECTOR BEFORE IT IS FILED. THE FORM 990 IS PROVIDED TO ALL BOARD MEMBERS BEFORE IT IS FILED AND PUBLISHED ON THE ORGANIZATION'S WEBSITE. FORM 990, PAGE 6, PART VI, LINE 12C EMPLOYEES ARE PROVIDED A COPY OF THE PROJECT'S PERSONNEL MANUAL WHICH INCLUDES A CONFLICT OF INTEREST POLICY. ALL EMPLOYEES ARE REQUIRED TO SIGN A FORM ATTESTING THEY HAVE READ, UNDERSTAND, AND WILL ADHERE TO THE POLICIES. VIOLATIONS ARE BROUGHT TO THE ATTENTION OF THE EXECUTIVE DIRECTOR AND AN INVESTIGATION IS CONDUCTED. STAFF ARE MADE AWARE THAT IF THEY ARE CONCERNED THAT A STAFF MEMBER HAS ENGAGED IN A CONFLICT OF INTEREST MATTER, THEY MUST ALERT THEIR SUPERVISOR, AND ALL CLAIMS WILL BE INVESTIGATED. IF IT IS DETERMINED THAT AN EMPLOYEE HAS ENGAGED IN A VIOLATION OF THE POLICY, THE EMPLOYEE WILL BE DISCIPLINED, WHICH MAY INCLUDE TERMINATION. FORM 990, PAGE 6, PART VI, LINE 15A THE EXECUTIVE DIRECTOR'S COMPENSATION IS REVIEWED AND APPROVED BY THE BOARD OF DIRECTORS. ALL SALARIES ARE APPROVED BY THE BOARD AS PART OF THE BUDGETING PROCESS. FORM 990, PAGE 6, PART VI, LINE 19 THE PROJECT PROVIDES GOVERNING DOCUMENTS, POLICIES, AND FINANCIAL STATEMENTS TO THE PUBLIC UPON REQUEST. FORM 990, PART XI, LINE 9 CHANGE IN BEN INT HELD BY OTHERS 31,685