Case 3:16-cv-00515-SMH-JPM Document 77 Filed 07/14/16 Page 1 of 20 PageID #: 2020

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF LOUISIANA
MONROE DIVISION
JUDGE SHARON INGRAM
MARCHMAN

CIVIL ACTION NO: 3:16-CV-00515

VERSUS

JUDGE HICKS

BRIAN E. CRAWFORD, LAWRENCE

E. PETTIETTE, JR., JAMES D.
BUDDY CALDWELL, JON K.
GUICE, JUDGE CARL V. SHARP,
JUDGE FREDERIC C. AMMAN,
JUDGE J. WILSON RAMBO, JUDGE
BENJAMIN JONES AND ALLYSON
CAMPBELL
:

MAGISTRATE JUDGE PEREZMONTES

DEFENDANT JUDGES REPLY MEMORANDUM IN SUPPORT OF

MOTION TO DISMISS ORIGINAL AND SUPPLEMENTAL, AMENDED
AND RESTATED COMPLAINTS
JEFF LANDRY
Attorney General
Brian D. Landry (#21688)(TA)
Special Assistant Attorney General
912 Kings Highway
Shreveport, LA 71104
Telephone: 318-222-2100
Facsimile: 318-226-5152
Email: landry@weems-law.com
ATTORNEYS FOR JUDGE CARL V.
SHARP, JUDGE FREDERIC C. AMMAN,
JUDGE J. WILSON RAMBO AND JUDGE
BENJAMIN JONES

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TABLE OF CONTENTS
I.

Preliminary Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

II.

Law and Argument .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

A.

B.
III.

Factual Allegations Against the Defendant Judges .. . . . . . . . . . . . . . 2

1.

General Allegations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2.

Defendant Judge Amman . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

3.

Defendant Judge Sharp . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

4.

Defendant Judge Rambo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.

Defendant Judge Jones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Immunity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

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TABLE OF AUTHORITIES
Statutes
42 U.S.C. 1983 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2, 7
42 U.S.C. 1985 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
42 U.S.C. 1986 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
FRCP, Rule 12(b)(1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4, 5
FRCP, Rule 12(b)(6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Louisiana Code of Judicial Conduct Canon 3A(9) . . . . . . . . . . . . . . . . . . . . . . . . . 6
Cases
Calhoun v. Hargrove,
312 F.3d 730, 734 (5th Cir. 2002) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Cleavinger v. Saxner,
474 U.S. 193, 199, 106 S.Ct. 496, 499, 88 L.Ed.2d 507 (1985) . . . . . . . . . 13
Doe v. Gooden,
214 F.3d 952, 955 (8th Cir. 2000) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Keenan v. Tejeda,
290 F.3d 252, 258 (5th Cir. 2002) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Malina v. Gonzales,
994 F.2d 1121 (5th Cir. 1993) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
McAlester v. Brown,
469 F.2d 1280-82 (5th Cir. 1972) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

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Morrison v. Lipscomb,
877 F.2d 463 (6th Cir. 1989) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Parsons v. United States DOJ,
801 F.3d 701 (6th Cir. 2015) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4, 5
Stump v. Sparkman,
435 U.S. 349, 357, 98 S.Ct. 1099, 1105,
55 L.Ed.2d 331 (1978) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Turkish Coal. of Am., Inc. v. Bruininks,
678 F.3d 617 (8th Cir. 2012) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5, 6
Walker-Serrano by Walker v. Leonard,
168 F. Supp. 2d 332, 347 (M.D. Pa. 2001) . . . . . . . . . . . . . . . . . . . . . . . . . . 7

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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF LOUISIANA
MONROE DIVISION
JUDGE SHARON INGRAM
MARCHMAN

CIVIL ACTION NO: 3:16-CV-00515

VERSUS

JUDGE HICKS

BRIAN E. CRAWFORD, LAWRENCE

E. PETTIETTE, JR., JAMES D.
BUDDY CALDWELL, JON K.
GUICE, JUDGE CARL V. SHARP,
JUDGE FREDERIC C. AMMAN,
JUDGE J. WILSON RAMBO, JUDGE
BENJAMIN JONES AND ALLYSON
CAMPBELL
:

MAGISTRATE JUDGE PEREZMONTES

DEFENDANT JUDGES REPLY MEMORANDUM IN SUPPORT OF

MOTION TO DISMISS ORIGINAL AND SUPPLEMENTAL, AMENDED
AND RESTATED COMPLAINTS
MAY IT PLEASE THE COURT
I. Preliminary Statement
On You Bet Your Life, the Groucho Marx radio and television game show
which ran from 1947 through 1960, if a contestant said the secret word of the day,
a duck would fly down and the contestant would win $50. When one considers the
pages and pages of briefing related to these motions to dismiss and oppositions, that
secret word could easily be obfuscate. The pages are voluminous, but the issues
in this motion to dismiss are neither obscure nor unclear.

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First, considering the factual allegations in her Complaints,1 has Plaintiff Judge
Marchman made a facially plausible claim under 1983, 1985 or 1986 for violations
of her First Amendment and Fourteenth Amendment rights which would allow a court
to draw a reasonable inference that the Defendant Judges are liable for any
constitutional misconduct? Secondly, even if she has a facially plausible claim
against her judicial colleagues, would those claims still fail because of judicial
immunity?
II. Law and Argument
A.

Factual Allegations Against the Defendant Judges

Plaintiff Judge Marchman is one of 10 district court judges on the Fourth

Judicial District Court. She has singled out four of her judicial colleagues as
defendants in this action, alleging that they violated her First and Fourteenth
Amendment rights. These allegations can be categorized as general in nature or
specific as to the four Defendant Judges.
1.

General Allegations

Plaintiff Judge Marchman contends that these four out of 10 somehow and nonspecifically interfered with her ability to discharge her duties as a judge, undermined

Unless otherwise stated, references to allegations and specific paragraphs will refer to
Doc. 22, the supplemental, amended and restated complaint.
2

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her authority in the eyes of the public, turned her into a virtual pariah, ignored her and
made her feel uncomfortable. [Doc. 22, 85, 89, 95]. However, there are no
specific factual allegations which flesh out any of these conclusory statements.
In 10, 62 and 86, Plaintiff Judge Marchman makes further conclusory
references to being forced to resign as chair of the personnel committee, stating she
was unable to perform the job with sole and unfettered authority; however, it is only
in 61, that she gives any factual context to this statement. There she alleges that
Chief Judge Winters, not named a defendant, assigned Defendant Judge Jones to
work with Plaintiff Judge Marchman on the personnel committee. Plaintiff Judge
Marchman clearly rescented this action of Chief Judge Winters, stating that it
prohibited her from doing her job, and that Defendant Judge Jones became the de
facto head of the committee.2 What is missing from these allegations is any factual
basis for how either Defendant Judge Jones or any of the other Defendant Judges are
responsible for actions alleged to have been taken by Chief Judge Winters. There are
no factual allegations which present any actions taken or interference by the
Defendant Judges in connection with Plaintiff Judge Marchmans position or alleged
forced resignation as personnel committee chair.

This argument is also discussed in more detail again where specific arguments
concerning Defendant Judge Jones are addressed. See Section II A 5 below.
3

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In 88, Plaintiff Judge Marchman claims her reputation was damaged by

allegations of Defendant Campbell and her counsel, but there is no other specific
reference to reputational injury in her Complaints. She does allege in 85 that she
has become a virtual pariah at the courthouse, but does not directly relate this to a
reputational injury in the general community, but in her standing among her peers.3
However, to the extent that they could be viewed as such, they will be addressed. In
this vein, Plaintiff Judge Marchman cites two cases for the proposition that
reputational injury is sufficient to establish injury in fact. [Doc. 62, pg. 12].
However, neither of the cases support her argument against the motion to dismiss for
failure to state a claim, and one undercuts her free speech claim altogether.
In Parsons v. United States DOJ, 801 F.3d 701 (6th Cir. 2015), fans of the
musical group Insane Clown Posse sued the United States over their fan group being
listed in the FBIs gang information database. The district court dismissed the lawsuit
for lack of standing. Pending before the Eighth Circuit was the question of whether
the federal court had standing or the judicial power to entertain the suit under
Rule 12(b)(1), FRCP. Id. pg. 709. The Eighth Circuit applying a standing analysis,
3

This claim appears to be more directed at Plaintiff Judge Marchmans standing among
her judicial peers, and not general reputation in the community. As the Cambridge Dictionary
defines the term pariah, it is a person who is avoided or not accepted by a social group, esp.
because he or she is not liked, respected, or trusted; an outcast: Because of its poor human
rights record, the country was treated as a pariah by other nations.
www.dictionary.cambridge.org (accessed 7/12/2016).
4

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held that general factual allegations of injury resulting from the defendant conduct
may suffice to support standing. Id. pg. 711. The plaintiffs in Parsons also alleged
specific damages, including, illegal traffic stops, searches, questioning by police and
prolonged detentions because of Insane Clown Posse insignia on shirts or vehicles.
One plaintiff was even instructed to undergo the painful process of having his Insane
Clown Posse tattoos removed at the order of his superiors in the U. S. Army.
Accordingly, unlike Defendant Judge Marchman, the plaintiff fans of Insane Clown
Posse were trying to overcome a Rule 12(b)(1) standing argument, and were further
found to have alleged very specific instances of injury and its effects.
Remaining in the Eighth Circuit, Plaintiff Judge Marchman cites Turkish Coal.
of Am., Inc. v. Bruininks, 678 F.3d 617 (8th Cir. 2012), again for the proposition that
reputation presents a cognizable injury.

A Turkish student and a non-profit

corporation (TCA) sued under the First Amendment when a university listed a
holocaust denying website as unreliable. The district court dismissed the case of
both plaintiffs pursuant to Rule 12(b)(6) for failure to state a claim. The Eighth
Circuit affirmed the students dismissal on that basis, but remanded the case for a new
dismissal to TCA pursuant to Rule 12(b)(1) for lack of standing. Id. pg. 620. The
case does not support Plaintiff Judge Marchman; indeed, it runs counter to her claim.
As the Eighth Circuit noted, the question presented was not the same as earlier cases
5

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where books were removed from the school library, thereby changing "the spectrum
of available knowledge" for students at the university. There is no hint in the
Complaint that university students were not free, for example, to read the TCA
website, email material from the TCA website to their friends, regale passers-by on
the sidewalk with quotes from the TCA website, and so forth. In short, TCA's
website was not removed from the university in any sense. Id. pg. 624.
Applying the Bruininks rationale to Plaintiff Judge Marchman, there is not a
hint in her Complaints that she is not free to proclaim her belief that Allyson
Campbell is a thief and a reprobate to passers-by on the sidewalk outside the Ouachita
Parish Courthouse. Exercising your First Amendment rights may result in your being
disliked, but you shouldnt be able to sue your colleagues who disagree with you.
2.

Defendant Judge Amman

As to Defendant Judge Amman, Plaintiff Judge Marchman contends he moved

to require en banc approval for videos or photographs in the courtroom, in an effort
to retaliate against her and keep her from having any positive press. [Doc. 22,
81]. Further, that he screamed at Plaintiff Judge Marchman after she lost the vote
to fire the law clerk. [Doc. 22, 51]. In her Opposition, Plaintiff Judge Marchman
does not address once how these allegations are sufficient to state a cause of action.
As to the media in the courtroom issue, the Louisiana Code of Judicial Conduct
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Canon 3A(9), already provides such a prohibition: Except as herein provided a judge
should prohibit broadcasting, televising, recording, or taking photographs in the
courtroom and areas immediately adjacent thereto at least during sessions of court or
recesses between sessions.

The exceptions allowed are limited to security,

presentation of evidence in trial and ceremonial proceedings.

Although Defendant Amman denies that he yelled or screamed at Plaintiff
Judge Marchman following any vote at a meeting by the judges of the Fourth Judicial
District, and even if it were true, it surely does not rise to the level of an actionable
claim. Verbal abuse does not give rise to a constitutional violation under 1983, as
yelling among colleagues or even subordinates is not actionable. See Calhoun v.
Hargrove, 312 F.3d 730, 734 (5th Cir. 2002); see also Doe v. Gooden, 214 F.3d 952,
955 (8th Cir. 2000) (holding that a teacher's statements, while "demeaning" and
"belittling" to his students, did not violate their constitutional rights); Walker-Serrano
by Walker v. Leonard, 168 F. Supp. 2d 332, 347 (M.D. Pa. 2001) (stating "verbal
abuse, whether coming from a student or a teacher, is not a constitutional violation.").
3.

Defendant Judge Sharp

As to Defendant Judge Sharp, Plaintiff Judge Marchman contends that he

refused in writing to work with her on any committee and disseminated the writing

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to court staff to undermine [her] authority and standing as a duly-elected judge.

[Doc. 22, 83]. Further, that Defendant Judge Sharp sought to admonish her in
relation to her response to a subpoena duces tecum related to the production of the
law clerks personnel file. [Doc. 22, 70].

In her Opposition, Plaintiff Judge

Marchman does not address the first allegation, but does reference the second, where
she notes the dispute between her and Defendant Judge Sharp as to exactly what was
meant in allowing a response to a subpoena duces tecum. See Doc. 62, pg. 2. This
is either a mistake by her attorney or an unusual admission that she did indeed
disclose information from Defendant Campbells personnel file, and that she did so
at Defendant Judge Sharps order: Of course they ignore the fact that she did so
because Defendant Judge Sharp ordered her to comply with a valid subpoena duces
tecum. Doc. 62, pg. 2. However, Defendant Judge Sharp did not order the
production of Defendant Campbells personnel file, and Plaintiff Judge Marchman
only sought permission to comply with the subpoena duces tecum by producing two
pieces of paper.4
4

See Doc. 40-14, pp. 49-51. At page 49 of the transcript, Plaintiff Judge Marchman
makes an appearance at the hearing. The record seems very clear that she was seeking
permission from Defendant Judge Sharp to give court-generated documents responsive to a
subpoena duces tecum to Mr. Ward, who would later become her counsel in the present action.
She states at page 50, lines 19-23, " I have my - a copy of my correspondence to [staff]
requesting documents responsive to the subpoena duces tecum and I have a copy of an email
[from staff] indicating that the documents would not be produced." After some discussion,
Plaintiff Judge Marchman again states her production will be two documents, her
8

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Ultimately, whether Plaintiff Judge Marchman gave Defendant Campbells

entire personnel file to Mr. Ward that day, any other day, or at all, is likely a question
for another court and another day. The question before this Court in connection with
the motion to dismiss by Defendant Judge Sharp is whether refusing to work with
Plaintiff Judge Marchman on any committees and communicating that to the court
staff, and any consideration he may have given to seeking to have her admonished by
her colleagues for actions she may have taken constitute constitutional claims. The
Opposition is silent as to how such activity is actionable.
Defendant Judge Sharp has the right to serve on whatever committees of the
Fourth Judicial District Court he wants. It is reasonable that, if there is a colleague
on the bench that he has a disagreement with, that he need not serve with the person.
It is clear from the allegations in 64-70 and 72, that there was a significant
conflict between Judges Sharp and Marchman on issues surrounding the hearing and
subpoena duces tecum discussed above. However, nowhere in those allegations is
found any hint that Plaintiff Judge Marchman was not free to voice her disagreement
with Defendant Judge Sharp at any time. The allegations of this dispute simply do
not show how Plaintiff Judge Marchmans free speech rights, if any, were in any way

"correspondence" and the "reply." Page 51, lines 18-21. Defendant Judge Sharp gave permission
to give the two documents to Mr. Ward, stating, "Give it to Mr. Ward. Mr. Ward do with it
what you will."
9

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curtailed. Nor does the allegation that Defendant Judge Sharp sought to have a
confidential matter on a later en banc meeting agenda to admonish Plaintiff Judge
Marchman rise to the level of chilling free speech.
On that chilling claim, Plaintiff Judge Marchman would have to show that:
(1) she "engaged in a constitutionally-protected activity;" (2) Defendant Judge
Sharps actions caused her "to suffer an injury that would chill a person of ordinary
firmness from continuing to engage in that activity;" and (3) Defendant Judge Sharps
"adverse actions were substantially motivated against" Plaintiff Judge Marchmans
exercise of constitutionally-protected speech. Keenan v. Tejeda, 290 F.3d 252, 258
(5th Cir. 2002).
First, the Opposition states, but does not cite any authority, that responding to
a subpoena duces tecum to produce a personnel file of a public employee in civil
litigation is a constitutionally-protected activity. There is simply no support for this
assertion. Secondly, refusing to work with a colleague with which you have a
disagreement, or the mere possibility of a judge seeking to have other judges consider
discipline against one of their colleagues would not chill a person of ordinary
firmness, especially another judge, who, if necessary, would have the ability and
opportunity to defend against the allegations. Finally, there is not a scintilla of
evidence that Defendant Judge Sharps motivations were to curtail constitutional
10

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rights. To the contrary, Plaintiff Judge Marchmans own allegation is that the
purpose was to undermine her authority, not chill her free speech rights. This was
clearly and simply a disagreement among two judges, who are both equals.
4.

Defendant Judge Rambo

As to Defendant Judge Rambo, Plaintiff Judge Marchman contends that he

glared at her and walked into her while exiting a courthouse elevator. [Doc. 22,
71]. There is no mention in the Opposition as to how these alleged actions
constitute an actionable claim. There is no specific reference that this is a free speech
or retaliation claim, but since this allegation is wedged in-between the allegations
discussed above concerning Defendant Judge Sharp, for the sake of this argument,
we will infer that it is meant to assert such a claim.
Just as before, the production of a public persons personnel file pursuant to a
subpoena duces tecum in a civil matter is not a constitutionally-protected activity.
While a wifes glare at her husband who is speaking too much at a party may be
enough to silence the talker, the idea that one judge staring down another coming out
of the elevator could be considered sufficient to chill a person of ordinary firmness
from exercising a constitutional right is ridiculous. Finally, there is no evidence that
Defendant Judge Rambos intent, if the event even occurred as alleged, was to curtail
anyones constitutional rights.
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5.

Defendant Judge Jones

One allegation against Defendant Judge Jones was discussed in Section II A

1 above, relative to Chief Judge Winters appointment for him to work with Plaintiff
Judge Marchman on the personnel committee. The only other allegation is that
Defendant Judge Jones, again with Chief Judge Winters, somehow pressured her to
recuse herself from the investigation of a certain employee who had requested her
recusal. [Doc. 22, 60]. This allegation is also completely ignored in the
Opposition. However, it seems that when viewed in context, the two incidents
together relate to the alleged forced resignation as chair of the personnel committee.
Again, though, where is the constitutional violation?
Even assuming a forced resignation occurred, the nexus to a free speech
retaliation claim is non-existent. First, serving on the personnel committee of the
Fourth Judicial District Court is not what one would ordinarily consider as a
constitutionally-protected activity. Secondly, the forced resignation does not appear
to reach the level of activity sufficient to chill a person of ordinary firmness from
exercising her constitutional rights. Finally, the motivation of both Chief Judge
Winters and Defendant Judge Jones seeking the recusal on one case, was stated in the
complaint as at the request of the employee being investigated, and not to curtail
constitutional rights.
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B.

Immunity
The Defendant Judges assert that even if Plaintiff Judge Marchman has valid

constitutional claims under the First and Fourteenth Amendments, that they are still
entitled to judicial immunity from such claims. "[F]ew doctrines were more solidly
established at common law than the immunity of judges from liability for damages
for acts committed within their judicial jurisdiction.'" Cleavinger v. Saxner, 474 U.S.
193, 199, 106 S.Ct. 496, 499, 88 L.Ed.2d 507 (1985) (quoting, Pierson, 386 U.S. at
553-54). The two-part Stump test and the four-part McAlester test were each
presented in the Defendant Judges original memorandum in support.5 In sum, the
Defendant Judges alleged actions were conducted in the Ouachita Parish Courthouse,
in courtrooms or adjacent spaces, and while conducting the business of the court,
either on the bench or in en banc meetings. Judicial immunity clearly applies.
In the Opposition, Plaintiff Judge Marchman does not even seek to undertake
an analysis under either the two-part Stump test or the four-part McAlester test.
Rather, the Opposition points to the exceptions, which prove the rule. First, in
addressing Malina v. Gonzales, 994 F.2d 1121 (5th Cir. 1993), the Opposition
correctly focuses on the nature and function of the act, in noting that it is not normally

Stump v. Sparkman, 435 U.S. 349, 357, 98 S.Ct. 1099, 1105, 55 L.Ed.2d 331 (1978); and
McAlester v. Brown, 469 F.2d 1280-82 (5th Cir. 1972).
13

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judicial in nature for a judge to stop a motorist or to file charges against them, as
those functions are normally performed by police and prosecutor. However, the
Opposition misses the point that all the functions which they complain of concerning
the Defendant Judges are normally performed by judges, including disagreements
with other judges serving in the same courthouse on how to run the court. Finally,
in Morrison v. Lipscomb, 877 F.2d 463 (6th Cir. 1989), the stated basis for the lack
of absolute judicial immunity was because the aggrieved plaintiff had no right of
appeal to a judges order to the clerk to place a blanket moratorium on writs of
restitution. However, the Opposition fails to note that qualified immunity still
applied in that case. Id. pg. 466. Of note, the judge in Morrison who issued the
order remained immune from a suit for damages.
The fact of the matter is, that for every activity alleged against the Defendant
Judges, they were acting as judges within the Ouachita Parish Courthouse, and
performing activities which were judicial in nature, including disagreeing with a
fellow judge from the same court about how to run their court.
III. Conclusion
The motion to dismiss for failure to state a claim should be granted. There is
no evidence of constitutional violations of the First or Fourteenth Amendments.
Alternatively, all Defendant Judges are entitled to absolute judicial immunity for all
14

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activities alleged in the Complaints.

Respectfully submitted,
JEFF LANDRY
Attorney General
s/Brian D. Landry
By______________________________
Brian D. Landry (#21688)(TA)
Special Assistant Attorney General
912 Kings Highway
Shreveport, LA 71104
Telephone: 318-222-2100
Facsimile: 318-226-5152
Email: landry@weems-law.com
ATTORNEYS FOR JUDGE CARL V.
SHARP, JUDGE FREDERIC C.
AMMAN, JUDGE J. WILSON RAMBO
AND JUDGE BENJAMIN JONES

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the above and foregoing Reply
Memorandum was filed with the Clerk of Court by using the CM/ECF system which
will send notice of electronic filing to all counsel of record unless otherwise indicated,
on this the 13th day of July, 2016.

s/Brian D. Landry
_______________________________
Of Counsel

16