Kraków, 12 October 2026

Chairman of the Referees’ Committee
Polish Football Association
7 Bitwy Warszawskiej 1920 r. Street, 02-366 Warsaw
e-mail: pzpn@pzpn.pl

cc:
Ekstraklasa S.A.
6D Wybrzeże Gdyńskie Street, 01-531 Warsaw
e-mail: info@ekstraklasa.org

Re: 10th-round match of the PKO BP Ekstraklasa, 2026/2027 season: Legia Warszawa - Wisła Kraków, played on 11 October 2026 in Warsaw, at 3 Łazienkowska Street

Officiating team: referee: Damian Sylwestrzak; assistant referees: Paweł Sokolnicki, Adam Karasewicz; fourth official: Mateusz Jenda; VAR: Bartosz Frankowski; AVAR: Marcin Szczerbowicz

Acting on behalf of Towarzystwo Sportowe Wisła Kraków Spółka Akcyjna, with its registered office and address in Kraków (30-059), at 20 Reymonta Street, entered in the Register of Entrepreneurs of the National Court Register maintained by the District Court for Kraków-Śródmieście in Kraków, 11th Commercial Division of the National Court Register, under KRS number: 0000130748, NIP: 6771022149, REGON: 350908122, with share capital of PLN 89,162,300.00, paid in full, e-mail address: sekretariat@wislakrakow.com (hereinafter referred to as the “Club” or “Wisła Kraków”), as President of the Club’s Management Board, in connection with the match of the 10th round of the PKO BP Ekstraklasa, Legia Warszawa - Wisła Kraków, played on 11 October 2026 (hereinafter referred to as the “Match”), I hereby request:

1. conducting by the PZPN Referees’ Committee (hereinafter referred to as the “Committee”) a separate and unequivocal assessment of the correctness of the Match officiating team’s decisions in relation to each of the incidents described in points II-XIII of this letter, indicating the factual and interpretative grounds for that assessment in light of the IFAB Laws of the Game in force for the 2026/2027 season (hereinafter referred to as the “Laws of the Game”), and, with regard to the incident described in point VI, also a separate assessment of the correctness of the referee’s decision not to award a penalty kick and of the VAR team’s correct application of the VAR Protocol;
2. providing the Club, to the extent permitted by applicable regulations and procedures, with a recording of the audio communication between the referee and the VAR team concerning the incident described in point VI, or, if this is not possible, providing a written explanation of the course and outcome of the VAR team’s review of this incident, in particular indicating which circumstances were taken into account during the review and which grounds determined that no recommendation was made to conduct an on-field review of the incident on the monitor (OFR);
3. informing the Club whether the event described in section XIII was noticed by the refereeing team and included in the referee's match report;
4. where irregularities are found in the decisions of the refereeing team or in the application of the VAR Protocol - indicating the nature of those irregularities and informing the Club whether, and what, actions provided for by the applicable procedures have been or will be taken to reduce the risk of similar situations occurring in the future;
5. with regard to the events described in sections II, III and VII-XII of this letter - identifying them, to the extent possible, on the basis of the freeze-frames included in this letter and the video footage from the Match available to the Committee, then establishing the full course of each event, indicating the decisions taken by the refereeing team and assessing their correctness in light of the Laws of the Game, and, where it is not possible to identify a particular event, informing the Club of the additional information needed to assess it.

I. SUBJECT MATTER AND NATURE OF THE REQUEST

This letter does not constitute a protest and is not intended to change the result of the Match. The Club is aware that, pursuant to Law 5 of the Laws of the Game, the referee's decisions regarding facts connected with play, including whether a goal is scored and the result of the match, are final. The purpose of this request is to obtain the Committee's assessment, as the body competent in refereeing matters, including the assessment of the referees' performance, and to learn the criteria applied by the refereeing team, including the VAR team.

The events described below concern, in particular, the assessment of offences and the justification for cautions, the correctness of restarts, the decision not to award a penalty and the VAR procedure, as well as player safety. Some of them occurred as early as the initial phase of the Match and, in the Club's view, may, considered both separately and collectively, have had a significant impact on its course. The Club expects each event to be assessed separately on the basis of its individual circumstances, as presented in the freeze-frames in this letter and the video footage from the Match available to the Committee, and, with regard to the events covered by recordings attached by the Club, also on the basis of those recordings.

As a Club, we bear the direct consequences of decisions made on the pitch. We are committed to fully understanding the standards applied in assessments and the criteria for applying the applicable regulations, as well as to constructive dialogue that will help avoid similar controversies in the future.

In the Club’s view, the materials presented indicate that irregularities may have occurred in the decisions of the refereeing team and justify the need for a detailed analysis thereof. In light of the foregoing, the Club requests that the College identify the incidents in question on the basis of the still images included in this letter and the video footage from the Match available to the College, establish their complete course, and then conduct a substantive assessment of the correctness of the refereeing decisions made. The Club emphasizes that the purpose of presenting the still images is to enable the identification of specific match situations requiring assessment, while their final classification should take into account the full course of each incident.

II. INCIDENT NO. 1 – HOLDING KACPER DUDA AND FAILURE TO ISSUE A CAUTION

Facts

The still image below shows a situation in which a Legia Warsaw player makes physical contact with Kacper Duda, in particular by holding him by the shirt during a Wisła Kraków attacking move. In the Club’s view, this conduct may have constituted an offence involving the interruption or prevention of a promising attack, warranting a caution for the Legia player. The Club requests that the full course of the incident be reconstructed and an assessment be made of whether the referee’s response, including the failure to issue a caution, was correct:

Relevant regulations

Under Law 12 of the Laws of the Game, holding an opponent constitutes an offence punishable by a direct free kick. If the offence prevents or interrupts a promising attack by the opposing team, the player is, as a rule, cautioned, subject to the exceptions provided for in the Laws of the Game, in particular those concerning the application of advantage. Holding an opponent alone does not, however, automatically constitute grounds for issuing a caution.

The Club requests that the following be indicated:

1. whether the holding constituted an offence that prevented or interrupted a promising attack by Wisła Kraków;
2. whether, in light of the circumstances of the play, the failure to caution the Legia Warsaw player complied with Law 12 of the Laws of the Game;
3. what criteria for assessing a promising attack were applied in relation to this incident.

III. INCIDENT NO. 2 – HOLDING AND BRINGING KACPER DUDA DOWN WHILE WINNING THE BALL

Facts

The still image below shows physical contact between Kacper Duda and a Legia Warsaw player while contesting the ball. In the Club’s view, the Legia player’s conduct may have involved illegally holding the opponent, causing him to fall. The Club requests that the complete sequence of the incident be established, in particular the order of both players’ actions, the nature and intensity of the contact, as well as the decision made by the referee and whether cautioning the Legia player was warranted:

Relevant regulations

Law 12 of the Laws of the Game includes, among other things, holding an opponent and offences committed in a reckless manner. Whether a caution may be issued depends on the specific circumstances, including the nature of the contact, the manner in which the action was stopped, and any stoppage of a promising attack.

The Club requests that the following be indicated:

1. whether the Legia Warsaw player's conduct constituted the offence of holding an opponent or another offence specified in Law 12;
2. whether the manner in which it was committed or its significance to the development of the action justified issuing a caution;
3. whether the reaction of the refereeing team was correct in light of the course of events.

IV. INCIDENT NO. 3 – IMPROPER AWARDING OF A THROW-IN TO LEGIA WARSAW PRECEDING THE 1:0 GOAL

Facts

The action that led to Legia Warsaw scoring its first goal began with a throw-in awarded to the home team. In the Club's view, as confirmed by the video recording, the last player to touch the ball before it completely crossed the touchline was Legia Warsaw player Mateusz Szczepaniak, and therefore the throw-in should have been awarded to Wisła Kraków. Despite this, the refereeing team awarded the throw-in to Legia Warsaw, which then restarted play and continued its attacking move, ending with the 1:0 goal in the 18th minute of the Match. In the Club's view, this decision constituted an incorrect application of Law 15 of the Laws of the Game and was of material significance to the course of the Match. The situation described is documented in the attached video material (recording no. 1) and in the following still images:

Relevant regulations

Under Law 15 of the Laws of the Game, a throw-in is awarded to the opponents of the player who last touched the ball before it completely crossed the touchline, regardless of whether the ball crossed the line on the ground or in the air. In light of the above, if Mateusz Szczepaniak was the last player to touch the ball, the throw-in should have been awarded to Wisła Kraków, not Legia Warsaw. The Club is aware that the VAR Protocol does not provide for the possibility of changing a decision to award a throw-in after play has restarted, including where the subsequent action has ended with a goal being scored. For this reason, the Club does not raise an allegation against the VAR team in this regard, but requests an assessment of the correctness of the decision taken by the on-field referees.

The Club requests that the following be indicated:

1. which player last touched the ball before it completely crossed the touchline and whether, in light of the established course of events, the throw-in was correctly awarded to Legia Warsaw, and if so - what specific circumstances justified that decision;
2. whether, if it was confirmed that Mateusz Szczepaniak was the last player to touch the ball, awarding the throw-in to Legia Warsaw constituted a refereeing error within the meaning of Law 15 of the Laws of the Game;
3. which member of the refereeing team was responsible for assessing this incident and what circumstances justified the decision taken.

V. INCIDENT NO. 4 – IMPROPER THROW-IN BY RAFAŁ AUGUSTYNIAK PRECEDING THE 1:0 GOAL

Facts

Irrespective of the incorrect award of the throw-in described in section IV of this letter, the Club draws attention to a separate irregularity concerning the manner in which this restart was taken by Legia Warszawa player Rafał Augustyniak. As follows from the video recording, at the moment of throwing the ball, Rafał Augustyniak lifted one of his feet off the ground, thereby violating the requirement set out in Law 15 of the Laws of the Game, according to which, when taking a throw-in, part of each foot of the player must be on the touchline or on the ground outside that line. Despite this irregularity, the officiating team did not challenge the manner in which the throw-in was taken and allowed play to continue. Immediately after this restart, Legia Warszawa mounted an attack that ended with a goal making it 1:0 in the 18th minute of the Match. In the Club's view, this therefore constituted another violation of Law 15 of the Laws of the Game, independent of the incorrect award of the throw-in. The irregularity was documented in the attached video material (recording no. 1) and in the still frames below:

Relevant regulations

Under Law 15 of the Laws of the Game, at the moment of delivering the ball, the thrower must face the field of play, have part of each foot on the touchline or on the ground outside the touchline, and throw the ball with both hands from behind and over the head, from the point where the ball left the field of play. If a throw-in is taken incorrectly, it is awarded to the opposing team. The Club is aware that, in certain circumstances, advantage may be applied if the opposing team gains a greater benefit from play continuing than from being awarded a throw-in. In the Club's view, the conditions justifying the application of advantage in favour of Wisła Kraków were not present in the situation at issue, because immediately after the throw-in, Wisła did not gain possession of the ball or any other actual benefit from play continuing. On the contrary, play was continued by Legia Warszawa and ended with a goal making it 1:0. The Club is also aware that the VAR Protocol does not provide for the possibility of changing a decision concerning the legality of a throw-in after play has restarted. Consequently, this allegation concerns exclusively the assessment of the performance of the on-field officials responsible for the proper restart of play.

The Club requests that the following be indicated:

1. whether the throw-in taken by Rafał Augustyniak immediately before Legia Warszawa scored to make it 1:0 was taken in accordance with the requirements set out in Law 15 of the Laws of the Game;
2. whether, based on the video recording, it can be established that Rafał Augustyniak did not maintain the required contact of both feet with the ground when throwing the ball and, consequently, took the throw-in in breach of Law 15 of the Laws of the Game;
3. whether, in the circumstances of the incident in question, there were grounds for applying the advantage to Wisła Kraków and, if so - what specific circumstances justified allowing play to continue;
4. which member of the officiating team was responsible for assessing whether the throw-in in question was taken correctly and whether failing to challenge the manner in which it was taken constituted a refereeing error.

VI. INCIDENT NO. 5 – PENALTY KICK NOT AWARDED TO WISŁA KRAKÓW

Facts

In the 24th minute of the Match, with the home team leading 1:0, Wisła Kraków player Julius Ertlthaler was controlling the ball in Legia Warszawa’s penalty area. Legia Warszawa player Bartosz Kapustka attempted to win the ball. As shown by the video footage (recording no. 2), he did not play the ball, and his leg made contact with the ankle of the Wisła Kraków player, causing him to fall onto the pitch. The referee did not whistle for an offence, and the VAR team did not recommend an on-field review (OFR) to the referee. Play continued. This is also documented by the following frames from the recording:

Relevant regulations

The basis for assessing the incident in question is Law 12, paragraph 1 of the Laws of the Game, according to which a direct free kick is awarded, among other cases, when a player carelessly, recklessly or using excessive force kicks or attempts to kick an opponent, trips or attempts to trip an opponent, or tackles an opponent incorrectly in a challenge for the ball. Under Law 14 of the Laws of the Game, if an offence punishable by a direct free kick is committed by a player inside their own penalty area, a penalty kick is awarded. Assessing the incident therefore requires consideration of the nature of the contact, the manner in which the attempt to win the ball was made, and the effect of that contact on the opponent.

In accordance with the VAR Protocol, the VAR team may intervene, among other situations, in cases concerning the award or non-award of a penalty kick if the referee’s decision constitutes a clear and obvious error or a serious missed incident has occurred. In the Club’s assessment, Bartosz Kapustka’s contact with Julius Ertlthaler’s ankle, which occurred while attempting to win the ball, without the defending player playing the ball, constituted an offence committed at least carelessly, making the award of a penalty kick necessary. Regardless of the assessment of the offence itself, the Club maintains that the circumstances of the incident also warrant assessing whether the failure to award a penalty kick constituted a clear and obvious error within the meaning of the VAR Protocol. For this reason, the Club requests a separate explanation of the correctness of the referee’s decision and the grounds for the VAR team’s failure to recommend an on-field review (OFR).

The Club requests that the following be indicated:

1. whether Bartosz Kapustka's contact with Julius Ertlthaler in the 24th minute of the Match constituted an offence within the meaning of Law 12 of the Laws of the Game, resulting in the award of a penalty, and if not, what specific circumstances supported considering this contact permissible under the Laws of the Game;
2. whether the referee's decision not to award a penalty was correct and, if it was found to be incorrect, whether it constituted a clear and obvious error within the meaning of the VAR Protocol;
3. whether and how the VAR team reviewed the incident in question, what circumstances and assessment criteria were taken into account during that review, and what grounds supported the failure to recommend an on-field review (OFR);
4. what criteria for assessing contact with the foot when attempting to win the ball in the penalty area arise from the Laws of the Game and applicable refereeing guidelines, particularly where the defending player does not play the ball but makes contact with the leg of the opponent controlling the ball, and how these criteria were applied in relation to the incident in question.

VII. INCIDENT NO. 6 – CHALLENGE ON A WISŁA PLAYER WHILE TURNING WITH THE BALL AND FAILURE TO CAUTION

Facts

The still image presented below illustrates a situation in which, while a Wisła Kraków player was turning with the ball, physical contact occurred with a Legia Warszawa player. In the Club's view, the manner and intensity of this contact may indicate an offence committed recklessly, warranting a caution. The Club requests an analysis of the full course of the incident, in particular the direction and dynamics of the challenge, the nature of the contact and the correctness of the referee's decision, including the failure to apply a disciplinary sanction:

Relevant regulations

Under Law 12, the referee assesses the intensity, dynamics and manner of the challenge against an opponent; a careless challenge may result in an offence without a disciplinary sanction, whereas a reckless challenge warrants a caution. Where excessive force is used, a separate assessment of the more severe sanction is necessary.

The Club requests that the following be indicated:

1. whether the described contact constituted an offence within the meaning of Law 12 and how its intensity should have been classified;
2. whether the failure to caution the Legia Warszawa player was correct;
3. which circumstances concerning the manner and intensity of the contact supported the decision made.

VIII. INCIDENT NO. 7 – FAILURE TO AWARD A CORNER KICK TO WISŁA KRAKÓW

Facts

The Club draws attention to the situation shown in the still image below, concerning the ball leaving the field of play over Legia Warszawa's goal line. In the Club's view, there are grounds for concluding that the last player to touch the ball before it left the field of play was a Legia Warszawa player, which should have resulted in a corner kick being awarded to Wisła Kraków. Instead, play was restarted with a goal kick. The Club requests a replay of the incident in question, determination of the last contact with the ball, and an assessment of the correctness of the officiating team's decision:

Relevant regulations

Under Laws 16 and 17 of the Laws of the Game, whether a goal kick or corner kick is awarded after the ball completely crosses the goal line without a goal being scored depends on which team touched it last. The possibility provided for in the VAR Protocol for the 2026/2027 season of reviewing a clearly incorrectly awarded corner kick, provided it has been implemented by the competition organiser, does not cover a situation in which a goal kick is awarded instead of a corner kick. For this reason, the Club's request concerns an assessment of the correctness of the on-field officials' decision.

The Club requests that the following be indicated:

1. which player last touched the ball before it left the field of play;
2. whether restarting play with a goal kick for Legia was in accordance with Laws 16 and 17;
3. whether a referee or assistant referee made an error in this regard.

IX. INCIDENT NO. 8 – WHISTLING FOR AN OFFENCE AFTER WISŁA KRAKÓW WON THE BALL

Facts

The still image below shows a situation involving an attempt by a Wisła Kraków player to win the ball. In the Club's view, the play may have constituted a legal challenge that did not require play to be stopped. Nevertheless, the referee awarded a free kick to Legia Warszawa, preventing Wisła from continuing the attack. The Club requests a replay of the full sequence of events, in particular determination of the order of contact with the ball and the opponent, and an indication of whether the referee's decision was justified under Law 12 of the Laws of the Game:

Relevant regulations

Law 12 of the Laws of the Game requires an assessment of the player's conduct as a whole when winning the ball. Merely touching the ball first does not rule out an offence; however, a legal challenge without a careless challenge, holding, or any other infringement of the Laws does not constitute grounds for awarding a free kick.

The Club requests that the following be indicated:

1. whether, in the situation in question, the Wisła Kraków player committed an offence specified in Law 12;
2. what specific elements of the conduct of the Wisła player justified awarding a free kick to Legia Warszawa;
3. whether the decision to stop play and award a free kick was correct.

X. INCIDENT NO. 9 - HOLDING KACPER DUDA BY A LEGIA WARSAW PLAYER AND AWARDING A FREE KICK TO LEGIA

Facts

The still image below shows a situation in which physical contact occurs between Kacper Duda and a Legia Warsaw player during a contest for the ball near the touchline. In the Club's view, the Legia player may have unlawfully held the opponent, restricting his freedom of movement. Despite this, a free kick was awarded to Legia Warsaw. The Club requests that the full course of the incident be established, in particular the sequence of actions by both players, the initiator of any offence, and the correctness of the referee's decision:

Relevant regulations

Under Law 12, holding an opponent and other forms of illegal physical contact must be assessed separately. The sequence of actions by both players, the initiator of the illegal contact, and whether one or both sides committed an offence must be taken into account.

The Club requests that the following be indicated:

1. whether either player committed an offence in the sequence described and, if so - which of them first breached the Laws of the Game and what that breach consisted of;
2. whether the manner in which the Legia player held Kacper Duda constituted an offence within the meaning of Law 12;
3. whether awarding a free kick to Legia Warsaw was correct.

XI. INCIDENT NO. 10 - CHALLENGE BETWEEN BARTOSZ KAPUSTKA AND ANGEL RODADO AND CAUTION OF THE WISŁA PLAYER

Facts

The still image below shows part of the challenge between Bartosz Kapustka and Angel Rodado during a contest for the ball. In the Club's view, the situation requires a detailed analysis of the sequence of actions by both players, in particular the moment the ball was played, the subsequent physical contact, and the manner in which it occurred. The Club disputes the correctness of awarding a free kick to Legia Warsaw and the legitimacy of cautioning the Wisła Kraków player. It therefore requests that the full sequence of the incident be reviewed and that the specific factual and regulatory basis for the decisions taken be identified:

Relevant regulations

Law 12 of the Laws of the Game requires the play of the ball, subsequent contact with an opponent, and any possible disciplinary sanction to be assessed separately. The fact that the ball was played first does not automatically exclude an offence committed during the subsequent phase of contact. The grounds for the caution should be assessed independently of the direction in which the free kick was awarded.

The Club requests that the following be indicated:

1. whether either player committed an offence in the situation described and which of them was responsible for the illegal contact;
2. whether awarding a free kick to Legia Warsaw was correct;
3. what specific conduct by Angel Rodado justified cautioning him, and was the caution consistent with Law 12.

XII. INCIDENT NO. 11 – SHOULDER-TO-SHOULDER CHALLENGE NEAR THE WISŁA PENALTY AREA AND CAUTION OF A CLUB PLAYER

Facts

The still image below shows an incident involving physical contact between Wisła Kraków and Legia Warszawa players near the Wisła penalty area. In the Club's view, this contact may have fallen within the limits of a permitted shoulder-to-shoulder challenge, without breaching the Laws of the Game. Nevertheless, the referee awarded Legia Warszawa a free kick and cautioned a Wisła player. The Club requests an analysis of the incident in its entirety, in particular the nature and intensity of the contact, whether awarding the free kick was correct and the basis for issuing the caution:

Relevant regulations

Under Law 12, physical contact while challenging for position does not automatically constitute an offence; relevant factors include the manner in which the body was used, the direction of movement, the intensity of the contact and any careless or reckless conduct. A caution requires an independent basis provided for in the Laws of the Game.

The Club requests that the following be indicated:

1. whether the challenge in question constituted an offence by the Wisła Kraków player within the meaning of Law 12;
2. whether awarding a free kick to Legia Warszawa was correct;
3. what specific circumstances justified cautioning the Wisła player.

XIII. INCIDENT NO. 12 – GLASS BOTTLE THROWN ONTO THE FIELD OF PLAY

Facts

At approximately the 64th minute of the Match, a glass bottle was thrown onto the field of play towards the Wisła Kraków players and landed near the touchline. The bottle was noticed by Wisła Kraków player Raoul Giger, who then threw it off the field, as documented in the attached video material (recording no. 3). Despite the glass bottle appearing on the field of play, the match was neither stopped nor suspended, and play continued. The Club is unaware whether the incident was noticed by the refereeing team or whether any measures were taken to ensure the players' safety.

Relevant regulations

Under Law 5 of the Laws of the Game, the referee may stop, suspend or abandon the match due to outside interference, including an object thrown by a spectator, depending on the seriousness of the incident. The Club is aware that throwing an object onto the field of play does not always require the match to be stopped, and that factors including the impact on play and the degree of danger are relevant. In the Club's view, however, a glass object thrown towards the players posed a direct threat to their health, and any further throws could have resulted in serious injuries.

The Club requests that the following be indicated:

1. whether the incident involving a glass bottle being thrown onto the field of play was noticed by any member of the refereeing team and whether it was recorded in the referee's match report;
2. what rules and procedures govern referees' actions when an object that may pose a threat to the players' health or safety appears on the field of play, in particular an object made of glass;
3. whether, in the circumstances of the incident in question, taking into account the nature of the object thrown, where it landed, and the potential threat to the players' health, the actions of the refereeing team, in particular continuing play without stopping it, were consistent with Law 5 of the Laws of the Game and the applicable refereeing procedures concerning the safety of participants in the match;
4. whether, upon the refereeing team noticing the incident in question, an assessment of the threat to the players' safety was conducted and, if so, what circumstances were taken into account during that assessment and whether any measures were taken to eliminate or mitigate the threat.

Any potential liability of the Match organizer for breaches of safety rules remains subject to a separate assessment by the Club and is not covered by this request, without excluding the possibility of the Club taking further action before the competent authorities. Notwithstanding the foregoing, this letter is forwarded to Ekstraklasa S.A. for information as the organizer of the competition.

XIV. SUMMARY

In view of the foregoing, Wisła Kraków hereby submits the request set out above, in particular for a separate, substantive assessment of each of the events described, indicating the specific factual and interpretive grounds for the position adopted, and, with regard to the incident in the 24th minute of the Match, also for an explanation of the criteria applied by the VAR team when assessing whether intervention was warranted. The Club's intention is not to undermine the authority of the referees or change the result of the Match, but to obtain a clear and predictable interpretation of the standards applied by refereeing teams, including VAR teams. The Club remains at the disposal of the Committee, in particular to provide additional video footage or further explanations concerning the events described. Given the significance of the issues presented for assessing the correct application of the Laws of the Game and the safety of the players, the Club requests that a written position be presented, if possible, within 14 days of receipt of this letter.

Yours faithfully

Jarosław Królewski
President of the Management Board

Attachments:

1. recording no. 1 – a throw-in and the goal making it 1:0, 17th minute;
2. recording no. 2 – an incident in Legia Warsaw's penalty area, 24th minute;
3. recording no. 3 – a glass bottle thrown onto the field of play, 64th minute.

Original document for download

* We thank Mr. Karol Michalak for his pro bono work in preparing some of the materials.