B&C News: States Issues
March 2, 2023
Register Now for the “Extended Producer Responsibility” Webinar
March 22, 2023
12:00 p.m. - 1:00 p.m. EDT
REGISTER NOW
Rooted in the circular economy concept and the “polluter pays” principle, extended producer responsibility (EPR) laws have a long tradition in Europe for many product categories, including packaging. In the United States, EPR is much newer and is viewed as a funding mechanism to support recycling programs by shifting the responsibility to pay for these programs from municipal, public sources to private, product producer sources. Twenty states have adopted EPR legislation that applies to certain types of ... read more >
January 6, 2023
Bergeson & Campbell, P.C. Releases 2023 Forecast for U.S. Federal and International Chemical Regulatory Policy
Bergeson & Campbell, P.C. (B&C®) and its global consulting affiliate The Acta Group (Acta®) and consortia management affiliate B&C® Consortia Management, L.L.C. (BCCM) are pleased to offer you our Forecast 2023, our seasoned team’s collective take on what to expect regarding global industrial, agricultural, and biocidal chemical initiatives in the New Year. We have worked hard to offer our best-informed judgment on the trends and key developments we expect to see in 2023.
Here at home, most would agree the Biden Administration has made bold and consequential ... read more >
January 3, 2022
Bergeson & Campbell, P.C. Releases 2022 Forecast for U.S. Federal and International Chemical Regulatory Policy
Bergeson & Campbell, P.C. (B&C®) and its consulting affiliate The Acta Group (Acta®) and consortia management affiliate B&C® Consortia Management, L.L.C. (BCCM) are pleased to offer you our Forecast 2022. The extraordinary diversity and complexity of global industrial, agricultural, and biocidal chemical initiatives in which our clients engage are reflected in the detailed summary that follows, prepared by the legal, scientific, and regulatory professionals of B&C, Acta, and BCCM. In this comprehensive overview, we offer our best informed judgment as to the trends ... read more >
November 12, 2021
James V. Aidala Quoted in Inside TSCA Article “Former Official Says PFAS Patchwork Shows Failures Of TSCA Preemption”
On November 11, 2021, James V. Aidala, Senior Government Affairs Consultant, Bergeson & Campbell, P.C. (B&C®), was quoted by Inside EPA’s Inside TSCA regarding state regulations of per- and polyfluoroalkyl substances (PFAS).
A former EPA toxics chief says Michigan’s new executive order limiting purchases of products made with per- and polyfluoroalkyl substances (PFAS) not only expands a nationwide patchwork of state-level PFAS policies, but shows that the reformed TSCA’s preemption provision “works on paper, but rarely works in ... read more >
February 20, 2020
Pesticide Roundup—A Conversation with Sheryl Dolan
This week, I sat down with my colleague, Sheryl Dolan, a Senior Regulatory Consultant here at Bergeson & Campbell and The Acta Group. As Sheryl’s practice focuses primarily on pesticide matters, we addressed a few hot topics captivating our interest. Sheryl briefed us on the Environmental Protection Agency’s (EPA) Office of Pesticide Programs’ (OPP) forthcoming move from Crystal City, Virginia, to D.C. later this year, OPP’s recent deployment of its Emerging Pathogen Policy in light of the Coronavirus gripping the world, OPP’s continuing efforts to help ... read more >
January 15, 2020
Bergeson & Campbell’s Forecast 2020
This week, I sat down with my colleagues Sheryl Lindros Dolan, Chris Bryant, and Dr. Richard Engler to discuss our fabulous 2020 Forecast, B&C’s and The Acta Group’s (Acta®) richly detailed overview of key trends in U.S. and global chemical law and policy. This 67-page document provides a comprehensive “one-stop” overview of global initiatives for the New Year of which stakeholders in the global chemical market must be aware. My colleagues provide a spirited overview of key developments, speculate on the impact of the U.S. general elections later this year, ... read more >
September 5, 2019
Celebrating the Environmental Law Institute’s 50th Anniversary with President Scott Fulton
This week, I sat down with Scott Fulton, President of the Environmental Law Institute, on the occasion of ELI’s 50th anniversary.
Scott is ELI’s 5th President. As a former ELI Board member myself and a practicing lawyer in the environmental space, I have known Scott for years given his many high profile roles as a former EPA General Counsel, Assistant Chief of the Environmental Enforcement Section at the U.S. Department of Justice, among other prominent positions.
In our conversation, Scott explains the various lines of work in which the ELI is currently engaged, how ... read more >
March 20, 2019
WEBINAR - - Prop 65: Exposure Monitoring and Compliance Implications
Available On Demand
California’s Safe Drinking Water and Toxic Enforcement Act of 1986, also known as Proposition 65 (Prop 65), requires businesses in California to provide warnings about certain consumer product, occupational, and/or environmental exposures to substances that the State of California has determined to be known to cause cancer or reproductive toxicity. Amendment regulations pertinent to these warnings effective as of August 2018 focused many companies on the requirements, content, and transmission of such warnings.
The warning requirements are ... read more >
January 25, 2019
Bloomberg Environment Features Comments By Lynn L. Bergeson Regarding A Delayed Deadline for New York’s Ingredient Disclosure Requirements
On January 25, 2019, Bloomberg Environment spoke with Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), for the article “New York Pushes Back Cleaning Products’ Disclosure Deadline.”
Cleaning product manufacturers and their suppliers are hard put to comply with both New York’s and California’s ingredient disclosure requirements because they are dissimilar, said Lynn Bergeson, managing partner of Bergeson and Campbell PC, a Washington, D.C.-based firm specializing in chemical policies.
New York’s program set ... read more >
October 12, 2018
Fall 2018 Regulatory, Testing, and Policy Trends for Chemical Consortia
Now more than ever, chemical industry stakeholders with shared business and advocacy interests are urged to consider collaborating on regulatory, testing, and related advocacy opportunities. Two years post-passage of the Frank R. Lautenberg Chemical Safety for the 21st Century Act means the U.S. Environmental Protection Agency (EPA) is well underway with implementation of the amended Toxic Substances Control Act (TSCA).
Industry groups that are already established and working efficiently when EPA initiates an action under TSCA will be most successful in nimbly and ... read more >
January 18, 2018
Christopher R. Bryant Quoted in Bloomberg Environment Article “Toxic Pollutants in California Mudslide Present Cleanup Challenges”
On January 18, 2018, Christopher R. Bryant, Senior Regulatory Consultant at Bergeson & Campbell, P.C. (B&C®), was quoted by Bloomberg Environment regarding the possible environmental ramifications of a recent California mudslide.
“That mud could contain everything from sewage, to oil and gas from ruptured lines, as well as pesticides, ash, maybe chemicals from inside houses,” said Chris Bryant, a regulatory consultant with Bergeson and Campbell, a Washington D.C.-based law firm focused on issues related to chemical regulatory compliance.
[…]
“Even if ... read more >
May 4, 2017
Lynn L. Bergeson and Richard E. Engler, Ph.D., Contribute to ABA SEER’s The Year in Review 2016
Bergeson & Campbell, P.C. (B&C®) is pleased to announce the publication of The Year in Review 2016: Environment, Energy, and Resources Law by the American Bar Association (ABA) Section of Environment, Energy, and Resources (SEER). The Year in Review provides an annual summary of developments in environmental, energy, and resources law. B&C Managing Partner Lynn L. Bergeson and Senior Chemist Richard E. Engler, Ph.D., co-authored the Pesticides, Chemical Regulation, and Right-to-Know 2016 Annual Report.
The 2016 Annual Report provides a detailed ... read more >
January 11, 2017
The Top Chemical Regulatory Stories of 2016
The attorneys, scientists, policy experts, and regulatory advisors of Bergeson & Campbell, P.C. (B&C®), The Acta Group (Acta®), and B&C® Consortia Management, L.L.C. (BCCM) endeavor year-round to keep you informed on key developments as they happen, and prepared for looming changes and deadlines, to help you maintain compliance and competitive advantage as you market your products throughout the world. As the new year begins, we offer you this look back at the top stories of 2016 (as measured by clicks, reads, and shares by readers of our blogs and e-mails), a ... read more >
June 17, 2016
Lynn L. Bergeson Quoted In Bloomberg BNA Daily Environment Report Article “California Agency To Look At TSCA Reform Impacts On Safer Consumer Products Effort”
On June 17, 2016, Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article “California Agency to Look at TSCA Reform Impacts on Safer Consumer Products Effort.”
Lynn Bergeson, managing partner of Bergeson & Campbell PC, said federal preemption would apply only to certain actions, such as restrictions.
It wouldn’t extend to state laws that require reporting or monitoring.
‘‘That said, TSCA preemption would appear to have its most potentially consequential impact on ... read more >
June 16, 2016
Bloomberg BNA Daily Environment Report features comments by Lynn L. Bergeson On Conflicts Between TSCA Reform and California DTSC
On June 16, 2016, Lynn L, Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), was quoted in the Bloomberg BNA Daily Environment Report article, “California Agency Examining Impacts of TSCA-Reform Bill.”
Lynn Bergeson, managing partner of Bergeson & Campbell PC, said federal preemption would apply only to certain actions, such as restrictions.
It wouldn't extend to state laws that require reporting or monitoring.
“That said, TSCA preemption would appear to have its most potentially consequential impact on the Safer Consumer ... read more >
June 14, 2016
Richard E. Engler Presents “U.S. Market Pressure and the Battle between Hazard and Risk” at the Green Chemistry & Engineering Conference
On June 14, 2016, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), presented “U.S. Market Pressure and the Battle between Hazard and Risk” at the 2016 Green Chemistry & Engineering Conference. Dr. Engler discussed the various risk-based regulations at play in the U.S., including the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Federal Food, Drug, and Cosmetic Act (FFDCA), the Toxic Substances Control Act (TSCA), and the Plant Protection Act. Dr. Engler stated that there are also a variety of hazard-based regulations ... read more >
April 13, 2015
Stewardship 2015 Presents Vital Program for Product Stewardship Professionals
Lynn L. Bergeson Joins Product Stewardship Society Board
of Directors
Stewardship
2015, June 1-3, 2015, Salt Lake City, Utah, is
the only national conference dedicated to educating and
equipping product stewards, industrial hygienists,
environmental health and safety (EHS) professionals, and
others involved in the day-to-day work of product
stewardship. Stewardship 2015 is co-located with
AIHce2015,
the premiere conference and exposition for occupational and EHS professionals.
Stewardship 2015 is presented by the
Product
Stewardship Society, a membership organization ... read more >
March 27, 2015
Interest in West Coast Sustainable Futures Training
Bergeson
& Campbell, P.C. (B&C®) and its affiliate
organizations are investigating the possibility of hosting
a U.S. Environmental Protection Agency (EPA) Sustainable
Futures workshop on the West Coast in late 2015. As you may know,
Sustainable
Futures training focuses on a
variety of tools, methods, and models that can be used to
assess the hazard and potential exposure of chemicals.
The intensive, hands-on training provided at Sustainable
Futures workshops allows attendees to utilize the EPA
methods of hazard and risk screening for human health,
ecotoxicity, and ... read more >
March 16, 2015
Jim Aidala’s Neonicotinoid Webinar Discussed In Inside EPA Article “State Agriculture Officials Oppose Pesticide Limits In EPA Pollinator Plan"
A February 18, 2015 Daily News feature on InsideEPA.com included comments made by James V. Aidala as part of a presentation before the National Association of State Departments of Agriculture:
In a Feb. 3 presentation to NASDA, Jim Aidala of the Washington, DC, law and consulting firm Bergeson & Campbell PC, said the federal strategy will include strict requirements on pesticide labels that must be followed wherever state plans are not in use.
But Aidala said EPA’s role in overseeing the state plans and the degree of autonomy states will have in developing, ... read more >
March 2, 2015
Acta Offers Complimentary Private Sessions at GlobalChem
The Acta Group (Acta®) is pleased to offer to
GlobalChem attendees a complimentary 30-minute private
session on March 3 with Acta professionals and Acta's
South Korean-based affiliate, SHES Chemical Consulting
(SHES), to answer questions relating to K-REACH,
European REACH, TSCA, or other Asian chemical
notification/regulation programs, as requested. This
service is offered free of charge, provides an
excellent opportunity to maximize your attendance at
GlobalChem, and is designed to enable you to obtain
specific answers to targeted questions from experts in
their field.
To take ... read more >
December 3, 2014
Experts from Bergeson & Campbell, P.C. and The Acta Group Publish Global Chemical Control Handbook: A Guide to Chemical Management Programs
The attorneys, scientists, and regulatory professionals of Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are proud to have authored Global Chemical Control Handbook: A Guide to Chemical Management Programs, recently released by the American Bar Association. Lynn L. Bergeson, Managing Partner of B&C and President of Acta, provided the guiding vision for this comprehensive desk reference book as editor and co-author.
Reflecting on the work of her colleagues, and others, on this book, Ms. Bergeson stated: "The Global Chemical Control Handbook reflects ... read more >
November 7, 2014
Key Presentations, Video Clips, and Daily Reports from ChemCon The Americas 2014
New ABA book edited by Lynn L. Bergeson, Global Chemical Control Handbook, Announced at Conference
ChemCon the Americas 2014 brought together an international audience of over 200 industry, regulatory, and policy leaders in Chicago, Illinois, October 27-31, 2014, to go in-depth on virtually every major chemical regulatory issue worldwide. Speakers included Mike Rasenberg of the European Chemicals Agency (ECHA), Dr. Jeffrey Morris of the U.S. Environmental Protection Agency (EPA), Dan Bastien of Environment Canada, Qiang Liu of the Chinese State Administration of Work Safety (SAWS), ... read more >
October 14, 2014
Imminent Events of Note in Nanotechnology, Biobased Chemicals, California Safer Consumer Products, and Chemical Regulation Globally
Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) are proud to be sponsors, presenters, and/or exhibitors at a select number of special events this Fall that will present focused education and guidance on key issues:
WEBINAR -- Regulation of Nanotechnology: Practical Information for Industry, Researchers and Other Stakeholders, October 16, 2014, 1:00 p.m. - 2:30 p.m. (EDT)
This webinar, presented by the Air & Waste Management Association (A&WMA), will feature James Alwood and Kenneth Moss of the U.S. Environmental Protection Agency's (EPA) ... read more >
October 1, 2014
Lynn L. Bergeson Quoted in Chemical Watch's ChemCon The Americas 2014 Preview Article "California and South Korea Among Chicago Highlights"
Chemical Watch quoted Lynn L. Bergeson discussing California’s influence on US and world regulatory programs: " 'In a word, size matters,' said Lynn L. Bergeson. 'California's economy is the eighth largest in the world if it is compared to those of whole countries, and it accounts for 13% of US gross domestic product (GDP). The state has a rich, and well-deserved, reputation as a trendsetter. Its approach to the regulation of volatile organic compounds has been adopted by the federal US EPA because of its proven track record and recognised efficacy. When California implements a new ... read more >
September 26, 2014
California's Release of Draft Initial Priority Product Work Plan Drives Agenda of 5th Safer Consumer Products Summit
October 22-24, 2014, San Francisco, California
With the Draft Initial Priority Product Work Plan by the California Department of Toxic Substances Control (DTSC) now released, it is important for manufacturers, importers, and retailers of consumer products in the categories listed by DTSC in the Work Plan to understand and address any issues. The upcoming Safer Consumer Products Summit, of which Bergeson & Campbell, P.C. (B&C®) is a proud sponsor, will bring together DTSC staff, brand owners, chemical companies, and industry associations to discuss these developments in ... read more >
September 8, 2014
Upcoming Green Chemistry and Safer Consumer Products Events
Stay Compliant and Competitive Under the Newer, Greener Chemical Control Paradigms
The dramatic shift in law and policy away from the regulation of end-of-pipe discharges of chemicals into the environment toward a more proactive focus on greener ingredient selection and manufacturing processes to prevent pollution at the source continues unabated, with over two dozen states having considered and/or passed new legislation in 2014. Bergeson & Campbell, P.C. (B&C®) is deeply engaged in green chemistry issues and is pleased to be sponsoring and presenting at key events this Fall ... read more >
March 31, 2014
Safer Consumer Products Summit to Feature EPA’s Jim Jones, California DTSC’s Meredith Williams
The 4th Safer Consumer Products Summit, the only national conference of its kind, will provide the most up-to-date information available on California's implementation of the Safer Consumer Products Regulations (SCPR), the most expansive Green Chemistry law in the world, drill down on the rapidly evolving state and international consumer safety regulatory landscape, and discuss the latest developments in legislative efforts to reform the Toxic Substances Control Act.
Jim Jones, the U.S. Environmental Protection Agency's (EPA) Assistant Administrator, Office of Chemical Safety and ... read more >
March 18, 2014
Draft List of Products Will Test California’s Safer Consumer Products Program, Markets
Lynn L. Bergeson was quoted in a Bloomberg BNA Daily Environment Report article, “Draft List of Products Will Test California’s Safer Consumer Products Program, Markets.“
“Draft Could Trigger Litigation. The draft list could trigger litigation challenging the regulations, the listed products or even DTSC’s implementation of the program rules, Washington D.C.-based attorney Lynn Bergeson of Bergeson & Campbell told Bloomberg BNA March 10. Businesses involved in marketing consumer products
in California should pay close attention to the DTSC’s draft list, Bergeson ... read more >
March 17, 2014
California Regulators Optimistic About Prevailing on Priority Products
Lynn L. Bergeson was quoted in a Chemical Watch article regarding the priority products listed in March under California’s Safer Consumer Products Regulations (SCPR): “Spray polyurethane foam products containing unreacted diisocyanates are different in an important aspect. Spray foams are primarily used in the construction industry by smaller and mid-sized companies represented by a wide range of small trade associations, said Lynn Bergeson of Bergeson & Campbell, a law firm representing chemical industry clients. The smaller companies and their trade groups may not want to ... read more >
October 17, 2013
Regulator Stresses REACH and California’s SCPR are Different
Lynn L. Bergeson was quoted in a Chemical Watch article on California’s new Safer Consumer Products Regulations (SCPR): “Information generated by REACH analyses could help position entities ‘favourably to be aware of what their obligations are under the Safer Consumer Products Regulations, and perhaps position them better to meet those requirements,’ said Lynn Bergeson of Bergeson & Campbell, ... read more >
August 21, 2013
Friday is last day to register for ChemCon Asia 2013, and last day to save $400 on Safer Consumer Products Summit
Bergeson & Campbell, P.C. (B&C®) is proud to be a sponsor of both of these dynamic gatherings of industry leaders, government and policy officials, and science and business visionaries.
For full agenda and registration click:
ChemCon Asia 2013, with its unique global approach and comprehensive review of global chemical issues, will take place in Seoul, South Korea, from September 9-13, 2013.
Lynn L. Bergeson will present "Green Chemistry and California Safer Consumer Products Regulations and How This Is a Game-Changing Event in North America" and ... read more >
August 12, 2013
Join Summit Chair Lynn L. Bergeson for the 3rd Safer Consumer Products Summit -- National Policy Outlook
Early Bird Registration Deadline Friday, August 16, 2013!
Bergeson & Campbell, P.C. is proud to be a sponsor of and program advisor to the 3rd Safer Consumer Products Summit -- National Policy Outlook, September 17-19, 2013, Washington, D.C. Join us at the conference to:
Stay Ahead of the Regulatory Curve with the Most Up-to-Date Status on the Toxic Substances Control Act (TSCA)
Avoid Brand Reputation Risk and Stay on the Shelves with Updates on the Latest State-Level Policy Developments in States Like CA, MA, ME, OR, and WA
Acquire the Strategies ... read more >
March 18, 2013
B&C Consortia Management, L.L.C. Is a Proud Sponsor of the 2nd Safer Products Summit
Bergeson & Campbell, P.C. (B&C), B&C Consortia Management, L.L.C. (BCCM), and The Acta Group (Acta) are pleased to announce that BCCM is a proud sponsor of the 2nd Safer Products Summit, which will be held on April 2-4, 2013, in San Francisco, California. The conference will bring together policy makers, leading consumer brands, and green chemistry experts to lay out the framework for complying with California's Safer Consumer Products Regulations. On April 4, 2013, Kathleen M. Roberts will moderate the panel on "Home and Personal Care Value Chain: Leaning on the Supply ... read more >
February 15, 2013
EPA Studies, California Rules May Guide “Risk” Level Absent TSCA Reform
The February 15, 2013, issue of Inside EPA quoted Lynn L. Bergeson extensively. “In lieu of reform legislation clearing Congress, Lynn Bergeson, a TSCA attorney and owner of law firm Bergeson & Campbell, told a recent legal conference that industry lawyers should be closely watching the agency’s first batch of five draft risk assessments, released last month, given that they could serve as an early indication of how EPA’s toxics office will handle risk analyses of existing chemicals — which are currently ‘grandfathered’ under TSCA. The assessments ... read more >
July 27, 2012
California Revises Green Chemistry Plan, Setting Stage For EPA Model
The July 27, 2012, issue of Inside EPA quotes Bergeson & Campbell, P.C.’s, November 2, 2011, memorandum regarding the California Department of Toxic Substance’s (DTSC) informal draft Safer Consumer Products ... read more >
June 29, 2012
CalNIN Workshop Registration Now Open
Workshop Registration Now Open -- Challenges and Opportunities for Businesses Engaged in Nanotechnology
B&C Consortia Management, L.L.C. (BCCM) is pleased to announce that registration is now open for the September 25, 2012, workshop: "Challenges and Opportunities for Businesses Engaged in Nanotechnology." The workshop, organized by BCCM and the California Nanotechnology Industry Network (CalNIN), is hosted by the UCLA Center for Environmental Implications of Nanotechnology in Los Angeles, CA. Registration for this workshop is $150.
Workshop participants and ... read more >
May 24, 2012
California DTSC Consults with Two Key Groups on “Working” Draft Regulation
The May 24, 2012, issue of Chemical Watch references Bergeson & Campbell, P.C.’s May 22, 2012, memorandum regarding the California Department of Toxic Substances Control’s (DTSC) revised informal draft Safer Consumer Products ... read more >
March 30, 2012
CalNIN Sponsoring Workshop on Challenges and Opportunities for Businesses Engaged in Nanotechnology
B&C Consortia Management, L.L.C. Announces That The California Nanotechnology Industry Network Will Sponsor a Workshop on Challenges and Opportunities for Businesses Engaged in Nanotechnology
SEPTEMBER 25, 2012 -- SAVE THE DATE
The B&C Consortia Management, L.L.C. (BCMM) is pleased to announce that the UCLA Center for Environmental Implications of Nanotechnology will be hosting a workshop that will be sponsored by The California Nanotechnology Industry Network (CalNIN) on Challenges and Opportunities for Businesses Engaged in Nanotechnology on September 25, 2012.
Planned ... read more >
November 29, 2011
EPA Offers California Help Crafting Landmark Green Chemistry Rules
The November 29, 2011, issue of Inside EPA quotes Bergeson & Campbell, P.C.’s November 2, 2011, memorandum regarding the California Department of Toxic Substances Control’s (DTSC) "informal draft" Safer Consumer Products ... read more >
September 16, 2011
BCCM Creates Website for Nanotechnology Initiatives in California
B&C Consortia Management, L.L.C. (BCCM), an affiliate of Bergeson & Campbell, P.C., wishes to ensure that you are aware of a new website designed to be a platform for sharing information on nanotechnology policy, legislative, and regulatory initiatives in California. The website -- www.calnin.org -- provides regular updates on areas and initiatives that could potentially impact the development or use of nanomaterials in California. It also includes information on broader nano-initiatives, recognizing that such initiatives can and will influence nanomaterials policy developments and ... read more >
March 29, 2011
Latest California “Labor Code” Prop. 65 Listings Inflame Industry Fears
The March 29, 2011, issue of Inside EPA's Risk Policy Report quotes a March 9, 2011, Bergeson & Campbell, P.C. memorandum regarding the California Office of Environmental Health Hazard Assessment's intent to list several chemicals on Proposition 65 through the labor code ... read more >
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2200 Pennsylvania Avenue, NW, Suite 100W
Washington, D.C. 20037
202-557-3800 • 202-557-3836 (fax) | lawbc.com
Contact • Twitter
Privacy Policy | Terms of Use | Cookie Policy | Attorney Advertising | Trademarks
©2023 Bergeson & Campbell, P.C.
All Rights Reserved.