# Equal Employment Opportunity Commission v. Crain Automotive Holdings, LLC

> District Court, W.D. Arkansas · October 29, 2024

URL: https://www.frixlaw.com/law-library/cases/10633262

## Case

- **Court:** District Court, W.D. Arkansas
- **Decided:** October 29, 2024
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/10633262

## How later opinions describe it (automated extraction)

- applying same analysis in ADEA and Title VII actions
- finding when former employees have not filed a charge of discrimination nor sought EEOC representation, the EEOC is thus acting on its own authority and not as the aggrieved parties’ representative

## Opinion text

IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF ARKANSAS
FAYETTEVILLE DIVISION

EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION PLAINTIFF

v. CIVIL NO. 5:23-cv-05164-TLB

CRAIN AUTOMOTIVE
HOLDINGS LLC DEFENDANT

DISCOVERY ORDER
This case is before the undersigned because of a discovery dispute which has arisen
between the parties. During the deposition of Charging Party Galen L. Taylor (Taylor), counsel
for the EEOC asserted the attorney client privilege to questions being asked by counsel for
Defendant Crain Automotive Holdings LLC (Crain). Communications between counsel
deteriorated on related subjects, and the undersigned conducted a recorded telephone call during
the deposition. Deferring on the issue of whether a Charging Party has an attorney client
relationship with the EEOC, the Court directed the parties to finish Taylor’s deposition, to the
extent possible, but to hold open the deposition while parties submitted letter briefing on the
attorney client privilege issues. The parties have submitted their letter briefing and the issues
essentially revolve around (1) whether communications between Taylor and the EEOC are
attorney-client privileged; and (2) whether communication between Taylor and his prior lawyer
are privileged and/or whether Taylor has waived the privilege by his deposition testimony. The
Court also addresses related discovery issues, deadlines, and the resumption of Taylor’s
deposition.
Law on Attorney-Client Privilege and Work Product Doctrines
Discovery in federal court is governed by the Federal Rules of Civil Procedure, and Rule
26(b)(1) provides that
[p]arties may obtain discovery regarding any nonprivileged matter that is relevant
to any party’s claim or defense and proportional to the needs of the case,
considering the importance of the issues at stake in the action, the amount in
controversy, the parties’ relative access to relevant information, the parties’
resources, the importance of the discovery in resolving the issues, and whether the
burden or expense of the proposed discovery outweighs its likely benefit.

Fed. R. Civ. P. 26(b)(1). Rule 501 of the Federal Rules of Evidence supplies the process by which
federal courts are to determine privilege:
The common law – as interpreted by United States courts in the light of reason and
experience – governs a claim of privilege unless any of the following provides
otherwise: the United States Constitution; a federal statute; or rules prescribed by
the Supreme Court. But in a civil case, state law governs privilege regarding a claim
or defense for which state law supplies the rule of decision.

Fed. R. Evid. 501. The Federal Rules of Evidence provide that evidentiary privileges are
“governed by the principles of the common law ... in the light of reason and experience.” United
States v. Jicarilla Apache Nation, 564 U.S. 162, 169 (2011) (cleaned up). Pursuant to Rule 501,
where state law supplies the rule of decision, state privilege law applies; otherwise, federal law
governs the privilege analysis. See Von Bulow by Auersperg v. Von Burlow, 811 F.2d 136, 141
(2nd Cir. 1987); see also Wm. T. Thompson Co. v. Gen. Nutrition Corp., 671 F.2d 100, 103 (3rd
Cir. 1982). Here, the Court looks to federal common law for guidance. Von Burlow, 811 F.2d at
141.
Of the various recognized privileges, the attorney-client privilege – appearing as early as
the sixteenth century – is widely considered to be the oldest and most respected of them. See
Upjohn Co. v. United States, 449 U.S. 383, 389 (1981) (“The attorney-client privilege is the oldest
of the privileges for confidential communications known to the common law.”); see also United
States v. Bauer, 132 F.3d 504, 510 (9th Cir. 1997) (“[T]he attorney-client privilege is, perhaps, the
most sacred of all legally recognized privileges….”). “Generally, it is well established under
common law that confidential communications between an attorney and a client are privileged and
not subject to disclosure absent consent of the client.” United States v. Horvath, 731 F.2d 557, 562

(8th Cir. 1984). The privilege’s purpose is “to encourage full and frank communications between
attorneys and their clients and thereby promote broader public interest in the observance of law
and administration of justice.” Upjohn, 449 U.S. at 389. Preservation of the attorney-client
privilege is “essential to the just and orderly operation of our legal system.” United States v. Ivers,
967 F.3d 709, 715-716 (8th Cir. 2020). Simply described, “[a] client may refuse to disclose
confidential communications made for purpose of facilitating or rendering professional legal
services to the client by his attorney or a lawyer representing another in a matter of common
interest.” In re Bieter Company, 16 F.3d 929, 935 (8th Cir. 1994)
Despite the importance of the attorney-client privilege, it must be narrowly construed,
protecting only disclosures necessary to obtain informed legal advice which may not have been

made absent the privilege. See Fisher v. United States, 425 U.S. 391, 403 (1976). A party asserting
the privilege must the lawyer was “engaged or consulted” by the client for the “purpose of
obtaining legal services or advice services or advice that a lawyer may perform or give in his
capacity as a lawyer, not some other capacity.” Triple Five of Minnesota, Inc. v. Simon, 212 F.R.D.
523, 527 (D. Minn. 2002) (citations omitted). "The privilege only protects disclosure of
communications; it does not protect disclosure of the underlying facts by those who communicated
with the attorney: '[T]he protection of the privilege extends only to communications and not to
facts.'" In re Bieter Co., 16 F.3d 929, 941 (8th Cir. 1994) (quoting Upjohn, 449 U.S. at 395).
Communications which fall outside the scope of the attorney-client privilege may
nonetheless be protected by the work-product doctrine. Hickman v. Taylor, 329 U.S. 495 (1947).
While the purpose of the attorney-client privilege “is to encourage clients to make a full disclosure
of all favorable and unfavorable facts to their legal counsel,” In re Murphy, 560 F.2d 326, 337 (8th

Cir. 1977), the work-product doctrine “functions not merely and (perhaps) not mainly to assist the
client in obtaining complete legal advice but in addition to establish a protected area in which the
lawyer can prepare his case free from adversarial scrutiny.” Lamar Advertising of S.D., Inc. v. Kay,
267 F.R.D. 568, 575 (D. South Dakota, April 12, 2010) (citations omitted). The work-product
doctrine prevents “unwarranted inquiries into the files and mental impressions of an attorney” and
“recognizes that it is essential that a lawyer work with a certain degree of privacy, free from
unnecessary intrusions by opposing parties and their counsel.” Simon v. G.D. Searle & Co., 816
F.2d 397, 402 (8th Cir. 1987). “The scope of work product protection is broader than the protection
the attorney-client privilege provides because the work product doctrine is not confined to
confidential communications between an attorney and a client, but rather extends to protect all

‘documents and things’ prepared in ‘anticipation of litigation or for trial.’” Columbia Ins. Co. v.
Tibbott, 2012 WL 13027067, at *5 (D. Minn. June 21, 2012) (quoting Onwuka v. Fed. Ex. Corp.,
178 F.R.D. 508, 512 (D. Minn. 1997)). Work product may consist of “raw factual information,”
or it may include the attorney’s “mental impressions, conclusions, opinions, or legal theories.”
Baker v. General Motors Corp., 209 F.3d 1051, 1054 (8th Cir. 2000).
De Facto Attorney-Client Relationship
The case law is not definitive regarding whether or when the EEOC enters an attorney-
client relationship with the aggrieved individuals/Charging Parties whose interests it represents.
EEOC v. Morgan Stanley & Co., Inc., 206 F. Supp. 2d 559 (S.D. N.Y. 2002). Various courts have
found a de facto attorney-client privilege to exist between the EEOC and aggrieved individuals;
some decisions arise in Age Discrimination in Employment Act (ADEA) litigation and some
decisions are made in other contexts but rely upon case law developed in ADEA cases. A sample
of those cases, many cited in briefing by the EEOC and Crain, include: EEOC v. International

Profit Associates, Inc., 206 F.R.D. 215, 219 (N.D. Ill. March 27, 2002); EEOC v. Chemtech Int’l
Corp., 1995 WL 608333, at *1-2 (S.D. Tex. 1995) (ADA case relying on ADEA case law);
Bauman v. Jacobs Suchard, 136 F.R.D. 460, 462 (N.D.Ill.1990) (communications between the
EEOC and employees in ADEA cases are privileged because an individual’s right of action is
terminated when EEOC brings ADEA suit); EEOC v. NEBCO Evans Distribution, Inc., WL
416423, at *4 (D. Neb. 1997) (finding a de facto attorney-client relationship when the EEOC cuts
off the applicants’ private right of action); EEOC v. Collegeville/Imagineering Ent., 2007 WL
158735 (D. Ariz. January 17, 2007); EEOC v. Johnson & Higgins, Inc., WL 778369, at *4
(S.D.N.Y 1998) (ADEA case); EEOC v. HBE Corp., 1994 WL 376273 (E.D.Mo.1994) (Title VII
case relying on ADEA case law, finding a common interest between aggrieved party and EEOC);

Gormin v. Brown-Forman Corp., 133 F.R.D. 50, 53 (M.D. Fla. 1990) (applying same analysis in
ADEA and Title VII actions); EEOC v. Int'l Profit Assocs., Inc., 206 F.R.D. 215 (N.D. Ill. 2002)
(Title VII case relying on ADEA case law); but compare with EEOC v. McDonnell Douglas Corp.,
948 F. Supp. 54, 55 (E.D. Mo. 1996) (finding when former employees have not filed a charge of
discrimination nor sought EEOC representation, the EEOC is thus acting on its own authority and
not as the aggrieved parties’ representative).
Crain argues the undersigned should not make the same mistake courts have been making
for thirty years but observe a critical distinction based on whether the Charging Party retains the
right to bring private action. Crain points out that when an aggrieved party makes an ADEA
discrimination claim and the EEOC chooses to move forward with the complaint, the action is
brought by the EEOC on behalf of the charging or aggrieved parties who waive their right to bring
private actions. 29 U.S. Code § 623; see also EEOC v. Enterprise Leasing Comp., 2024 WL
1210364 (S.D. Fla. March 21, 2024) (ADEA). Under these circumstances, says Crain, the EEOC

should be viewed as representing the aggrieved party. The result should be different, however,
when Title VII claims are being pursued by the EEOC because – in Title VII actions – the Charging
Parties/aggrieved persons maintain the right to bring their own private actions even where the
EEOC pursues their case.1 See 42 U.S.C. § 2000e; EEOC v. Waffle House, Inc., 534 U.S. 279
0F
(2002). Acknowledging a plethora of inconsistent caselaw, Crain highlights EEOC v. HBE Corp.
– a Title VII case which Crain says was wrongly decided – when asking the undersigned not to
follow HBE (or other Title VII cases which incorrectly relied upon ADEA analysis) when
determining whether a de facto relationship exists between the EEOC and Taylor. Looking instead
to the reasoning of Bauman, Crain argues that under Title VII, the EEOC and aggrieved individuals
are separate parties who are not entitled to assertion of the attorney-client privilege. In support,
Crain points out that Taylor has not sought to be added as a party to the EEOC’s litigation and has
not filed a separate action against Crain.
While Crain’s argument is well-constructed, the undersigned declines to parse a sizeable
body of law so strictly. Instead, the Court finds an aggrieved party can establish manifestation of
assent to be represented by the EEOC and that manifestation may be enough to support existence
of an attorney-client relationship and its privilege. See EEOC v. CRST Van Expedited, Inc., 2009

1 The EEOC possesses statutory authority to bring a Title VII action in federal court, but this
authority was “intended to supplement, not replace, the private action.” See Gen. Tel. Co. of the
Nw. v. Equal Emp. Opportunity Comm'n, 446 U.S. 318, 326 (1980). Under Title VII, the aggrieved
may bring their own action after the exclusive jurisdiction of the EEOC expires (180 days) or they
may also intervene in the action. See 42 U.S.C. § 2000e.
WL 136025 (N.D. Iowa Jan. 20, 2009) (attorney client relationship does not begin unless the
employee asks for the EEOC’s advice); Gormin,133 F.R.D. at 53 (If an individual “has expressly
asserted his desire to have EEOC counsel render him confidential legal advice, and that desire is
demonstrable through affidavits or other documentation... then [the court] may conclude that

EEOC counsel has an attorney-client relationship with that individual.”); see also EEOC v.
Mitsubishi Motor Mfg. of America, Inc., 960 F. Supp. 164, 168 (C.D. Ill. 1997) (EEOC has
“legitimate interest in communicating legal advice and information to those persons that it will
potentially represent in this action,” citing Gulf Oil Co. v. Bernard, 452 U.S. 89 (1981)). Whether
an attorney-client relationship has been formed is not defined by a bright-line rule; the
circumstances alleged to have created the relationship must be evaluated with the general
requirement that both the attorney and client have consented, expressly or implicitly, to the
formation of the relationship. See Diversified Indus., Inc. v. Meredith, 572 F.2d 596, 602 (8th Cir.
1977) (applying a case-by-case analysis to determine existence of an attorney-client privilege).
Without any standard metric for evaluating assent to representation by the EEOC, the

undersigned finds that, in most instances, documentation of the de facto relationship should take
the form of a declaration (or affidavit) signed by the aggrieved or charging party, or a letter, email
or other written communication from the aggrieved party to the EEOC which reflects assent to
representation. For example, see EEOC v. Scottsdale Healthcare Hospitals, 2023 WL 5206131
(D. Ariz. August 14, 2023) where the Curt found such a relationship to exist “when an individual
contacted the EEOC through questionnaires and phone calls, consulted the EEOC with an intent
to seek legal advice, or signed an affidavit stating a belief that an attorney-client relationship
existed”. The EEOC bears the burden of sustaining the privilege. EEOC v. Johnson & Higgins,
Inc., 1998 WL 778369 (S.D.N.Y. Nov. 6, 1998).
Here, although the EEOC represents Taylor’s interests, the EEOC has not provided any
evidence to the undersigned that Taylor has manifested – in any form – assent to be represented
by the EEOC.
Common Interest Doctrine

The EEOC urges application of the common interest doctrine to shield communications
with Taylor from disclosure. EEOC v. HBE Corp., 1994 WL 376273 at *2 (E.D. Mo. May 19,
1994). Courts within the Eighth Circuit have described the common interest doctrine as an
exception to waiver of the attorney-client privilege in a situation where a party discloses otherwise
privileged information to a third-party with whom it shares a common interest. Ploen v. AIG
Specialty Ins. Co., 2022 WL 2208328, at *6 (D. Minn. June 21, 2022), aff'd, 2022 WL 4533800
(D. Minn. Sept. 28, 2022). Following In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910,
922 (8th Cir. 1997), where the Eighth Circuit examined whether a common interest existed
between the White House and Hilary Clinton, courts in this Circuit have varied in application of
the doctrine. See Williams v. BHI Energy I Power Services, LLC, 2022 WL 17485550 (D. Minn.

Dec. 7, 2022) (discussing cases).
The undersigned previously has been persuaded by an unpublished decision of U.S. District
Court Judge James M. Moody protecting communications between the United States and Mr. and
Mrs. Black in a case where the Government was enforcing the rights of the couple under the Fair
Housing Act. United States v. Webb, No. 4:00-CV-698, 2-3 (E.D. Ark. Aug. 1, 2000). Judge
Moody opined that although there was no technical attorney-client relationship between the United
States and the Blacks, the Government was pursuing the case to enforce their rights under federal
law, and it should “not follow that persons who choose to utilize this [Fair Housing] Act give up
their right to confidential communications with the attorney representing their interests.” Judge
Moody concluded that “[t]he substance and content of these communications between the
Government’s counsel and the Blacks is protected by the common interest in litigation privilege.”
United States v. Webb, supra.
While the reasoning of Webb is persuasive, and the undesigned will apply it as the better

approach, it is recognized that finding a common interest between the EEOC and Taylor here is
mildly at odds with Taylor’s lack of assent to be represented. Nevertheless, Taylor stands to
benefit if the EEOC is successful in representing his interests in this case, and Taylor and the
EEOC necessarily share a common interest in this litigation not unlike the common interest Judge
Moody recognized in Webb. The Court will thus protect confidential communications between
Taylor and the EEOC for the rendering of legal advice as discussed below.
Attorney Client Privilege & Waiver – Prior Lawyers
The issue of privileged communications arose during Taylor’s deposition when Crain’s
counsel asked Taylor about his communications with his “lawyer” concerning a recording Taylor
made. Both the EEOC and Crain appear to agree that the “lawyer” in question represented Taylor

in a different Title VII employment discrimination case against a different defendant, Landers
McCarty Bentonville Nissan.2 The parties disagree on whether Taylor waived this privilege when
1F
answering questions during his deposition about those confidential communications.
As noted above, communications between an attorney and her client, “made for the purpose
of facilitating the rendition of legal services to the client,” are privileged. See United States v
Horvath, 731 F.2d 557, 561-62 (8th Cir 1984). Equally clear is Eighth Circuit law on waiver –
“[v]oluntary disclosure of attorney client communications expressly waives the [attorney-client]

2 Taylor’s discrimination case against Landers McLarty Bentonville Nissan, LLC, Civil No.
5:210cv-05071, was resolved through a settlement conference conducted by the undersigned on
April 27, 2022.
privilege.” United States v. Hahn, 58 F.4th 1009, 1012 (8th Cir. 2023) (quoting United States v.
Workman, 138 F.3d 1261, 1263 (8th Cir. 1998)). Where a party voluntarily testifies about his
communications with his attorney, the party waives attorney-client privilege, but the waiver
extends only to “any information directly related to that which was actually disclosed.” United

States v. Davis, 583 F.3d 1081, 1090 (8th Cir. 2009) (quoting Workman, 138 F.3d at 1263).
During the deposition, Taylor was asked about a recording he made at a June 6, 2022, work
meeting at Crain where Taylor thought “racists” things were occurring, and feared he would be
fired. (Galen L. Taylor Deposition, pp. 103-110). Taylor testified that his “lawyer” told him to
record the meeting, but Taylor clarified he was not referring to the EEOC lawyers present in the
room at his deposition. (Deposition, p. 110). While perhaps a poor practice to ask a deponent
what his former lawyer advised, the following exchange occurred without objection by the EEOC
or hesitation by Taylor:
Q Who told you to record the meeting?
A My lawyer.
Q And when did she tell you that? This – Ms. Jackson told you to record the
meeting?
A No.
Q Ms. Bearden told you to record the meeting?
A No, ma’am.
Q None of the lawyers in the room here?
A No, ma’am.
Q Okay. When did she tell you that?
A When I told her that – what was going on.
Q When did you tell her what was going on?
A Like, when I told her, like, about that racist incident and stuff, she just said just –
Q When did you tell her?
A I do not recall.
Q Did you tell her the date of the sales meeting?
A I tried to get into contact with her the date at the sales meeting.
Q Did you tell her the date of the sales meeting?
A No ma’am.
Q Did you tell her the next day?
A I don’t recall.
(Deposition, p. 110). The undersigned finds that Taylor clearly waived the privilege as to the
exchange about the recording and to “any information directly related to that which was actually
disclosed.” North Dakota v United States, 64 F.Supp.3d 1314, 1346-47 (D.N.D. 2014). Taylor’s
waiver was intentional – it was neither accidental nor inadvertent. Fed. R. Evid. 502(a).

The Court notes that later in the deposition, Crain’s counsel asked Taylor what his “lawyer
at the time” advised Taylor about what Taylor could share with his therapist. (Deposition, pp.
202-209). Before Taylor could fully answer, the EEOC’s counsel objected, and another
acrimonious exchange ensued between counsel. When Crain’s counsel returned to the question,
Taylor clarified that he assumed but did not know if he could talk about his litigation during
therapy, but testified he did share some litigation information with his therapist. (Deposition, pp.
209-210). Neither the attorney client privilege nor waiver appear implicated in this brief exchange.
Generally, the attorney client privilege protects any remaining confidential
communications between Taylor and his prior lawyers in the Landers McLarty matter, provided
Taylor has not waived the privilege, and does not waive the privilege when the deposition resumes.

While the undesigned ‘s review of the deposition transcript reveals no other obvious waivers, this
observation is made without the benefit of reviewing all the EEOC’s discovery responses and thus
the Court cannot say with certainty there are no other instances of waiver.
Attorney Client Privilege with EEOC
Getting to the heart of the parties’ remaining dispute, Crain’s counsel asked if Taylor “met
with these two ladies” – identified as EEOC lawyers Ms. Jackson and Ms. Bearden – before his
deposition, asking whether he rode with them to the deposition, when they met and for how long
they met. (Deposition, pp. 10-12). There was no objection until Crain’s counsel asked what Taylor
discussed with the EEOC’s lawyers, and this line of questioning prompted not only objections but
instructions to Taylor not to answer, followed then by a string of accusations by both lawyers
which culminated in the involvement of the undersigned. (Deposition, pp. 114-144).
The undersigned finds that these communications between Taylor and the EEOC lawyers
are protected from disclosure – deposition preparation with a lawyer is consulting “with a lawyer

in his capacity as a lawyer, not some other capacity.” Triple Five of Minnesota, Inc. v. Simon, 212
F.R.D. 523, 527 (D. Minn. 2002) (citations omitted). As a practical matter, Crain’s counsel should
be very careful asking questions which seek to probe the contents of communications between the
EEOC’s counsel and Taylor related to the filing and prosecution of this litigation. Deposition
preparation may also implicate the protected work-product of the EEOC’s attorneys (i.e., mental
impressions, thought processes, opinions, legal theories, and strategies) so Crain should steer clear
of inquiries about what Taylor and the EEOC counsel have discussed in preparation for the
deposition(s) and/or trial. See Shelton v. American Motors Corp., 805 F.2d 1323, 1328 (8th Cir.
1986).
Discovery of Taylor’s Employment and Medical Records

During the deposition, counsel for Crain complained that the EEOC/Taylor had not
provided employment and medical records releases for Taylor until the morning of the deposition
which precluded counsel from obtaining records and then examining Taylor about these records.
The EEOC responded that medical records previously provided by the EEOC along with other
discovery responses concerning Taylor’s employment were sufficient. The undersigned finds that
Crain has the better argument here. As pointed out by U.S. District P.K. Holmes, III in EEOC v.
Randall Ford, Inc., 298 F.R.D. 573 (W.D. Ark. 2014), Crain does not have to agree with the EEOC
about which records are discoverable or accept the universe of documents provided by the EEOC
in its discovery. While the undersigned cannot order a non-party such as Taylor to produce items,
Crain has had sufficient time since obtaining the releases to exercise subpoena power and obtain
medical and employment records for Taylor. Crain will be entitled to examine Taylor concerning
these records.
Conclusion

Taylor’s deposition was held open and may now resume consistent with this Order and the
Federal Rules of Civil Procedure.
Because the Court anticipates the parties may need further instruction, the undersigned
offers the following guidance:
• The deposition of Taylor may resume at an agreeable date but must be concluded not
later than the close of business on Friday, November 22, 2024. This requires a
modest extension of Judge Brooks’ discovery deadline from October 31, 2024, to
November 22, 2024.
• Extension of the discovery deadline requires a modest extension of the dispositive

motion deadline from November 22, 2024, to December 20, 2024.
• As Taylor resides in Northwest Arkansas, the deposition should occur in Northwest
Arkansas unless Taylor agrees to travel a second time to Little Rock.
• No time limitation will be imposed for concluding the Taylor deposition; however, the
parties should be mindful of the time spent during the first deposition.
• Neither party should re-ask questions which did not draw objections in the first
deposition unless records discovered cause counsel to revisit a question or line of
questioning.
• Counsel may inquire about all medical and employment records obtained during

discovery; counsel may inquire about the June 6, 2022, recording made by Taylor since
the privilege has been waived; and counsel may ask other appropriate questions which
do not seek the contents of confidential communications between the EEOC and Taylor
for the purpose of legal advice.
e The EEOC may conduct and conclude its examination of Taylor during this deposition;
the undersigned notes the EEOC was provided less than fifteen (15) minutes to inquire
during the prior deposition.
e All counsel are reminded that objections should not devolve into personal attacks.
IT IS SO ORDERED this 29" day of October 2024.

( Asay Comatack
CHRISTY COMSTOCK
U.S. MAGISTRATE JUDGE

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10633262. Public record. Not legal advice.