Opinion

Randal Law v. Texas Department of Insurance – Division of Workers' Compensation Subsequent Injury Fund, Jeff Nelson, Kara MacE, and Blaise Gerstenlauer

Court
Texas Court of Appeals, 15th District
Filed
Apr 18, 2025
Status
Published
Cited by
0 cases
Authority
More cited than 34.9%

The opinion

ACCEPTED

15-24-00097-CV

FIFTEENTH COURT OF APPEALS

AUSTIN, TEXAS

4/18/2025 3:11 PM

Appellate Docket Number: 15-24-00097-CVCHRISTOPHER A. PRINE

CLERK

FILED IN

15th COURT OF APPEALS

In The Court Of Appeals AUSTIN, TEXAS

4/18/2025 3:11:24 PM

CHRISTOPHER A. PRINE

For The Fifteenth Court Of Appeals District Clerk

Austin, Texas

Randal Law

Appellant,

v.

Texas Department of Insurance – Division of Workers ’

Compensation Subsequent Injury Fund, Jeff Nelson, Kara Mace,

and Blaise Gerstenlauer TDI-DWC-SIF

Appellee.

ON APPEAL FROM THE 353rd Civil District Court, TRAVIS

COUNTY , TEXAS

Civil District Court CAUSE NO . D-1-GN-24-003462

----------------------------------------------------------------------------------------------------------------------

Reply Brief of Appellant Randal Law in

Conjunction with Initial Brief on the Merits

Oral Argument Not Requested

Randal Law - Pro Se

1

Identity of Parties and Counsel:

Appellant/Plaintiff:

Randal Law, 701 E 11th St, Del Rio Tx 78840

Telephone: (830) 768-1556

rlaw9@stx.rr.com

Appellee/Defendant:

Texas Department of Insurance – Division of Workers ’

Compensation - Subsequent Injury Fund, Jeff Nelson, Kara Mace,

and Blaise Gerstenlauer TDI-DWC-SIF

Defendant/Appellee’s Appellate Counsel:

CANON HILL

State Bar No. 24140247

Assistant Attorney General

Administrative Law Division

OFFICE OF THE ATTORNEY GENERAL OF TEXAS

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

Telephone: (512) 936-1838

Canon.Hill@oag.texas.gov

2

TABLE OF CONTENTS

INDEX OF AUTHORITIES ........................................................... 3-5

SUMMARY OF THE ARGUMENT ................................................ 7-9

ARGUMENT ................................................................................ 10-31

A.) Texas Labor Code Section 408.161(a), Tex Lab Code § 408.201

Supersede

The New Adopted Rule 28 TAC §131.5 (Adopted Rule with rebut)

………………………………………………………………………. ..20-31

STANDARD OF REVIEW .................................….. …......…………32

CONCLUSION AND PRAYER...........…………...…………………33

CERTIFICATE OF COMPLIANCE ..........…...…...………………..34

CERTIFICATE OF SERVICE................…......……….…………….35

INDEX OF AUTHORITIES

Supreme Court of Texas Chambers-Liberty Cntys. Navigation Dist. v. State,

575 S.W.3d 339, 344 (Tex. 2019). "The basic justification for this ultra vires

exception to sovereign immunity is that ultra vires acts-or those acts without

authority-should not be considered acts of the state at all. Consequently,

'ultra vires suits do not attempt to exert control over the state-they attempt to

reassert the control of the state' over one of its agents." … ………………15

Supreme Court of Texas Van Boven v. Freshour, S.W.3d-,-2022 WL- (Tex.

June 3, 2022) “The Board's sovereign immunity from suit as a state agency

extends to its officials who act consistently with the law but not to those who

3

act ultra vires-that is, "without legal authority or by failing to perform a

purely ministerial act." An official acts without legal authority when he

"exceeds the bounds of his granted authority or if his acts conflict with the

law itself." An official fails to perform a ministerial act when he fails to

comply with a law that "prescribes and defines the duties to be performed

with such precision and certainty as to leave nothing to the exercise of

discretion or judgment." An official who acts ultra vires is not acting for the

state and not entitled to its immunity.”----------------------------------------- 11

Supreme Court of Texas Hall v. McRaven, 508 S.W.3d 232, 238 (Tex. 2017)

“Plaintiffs who seek to bypass sovereign immunity using an ultra vires claim

must plead, and ultimately prove, that the defendant government official

"acted without legal authority or failed to perform a ministerial act."

Heinrich, 284 S.W.3d at 372. An officer acts without legal authority "if he

exceeds the bounds of his granted authority or if his acts conflict with the

law itself”--------------------------------------------------------------------------- 12

Supreme Court of Texas CITY OF EL PASO, et al., Petitioners, v. LilliM.

HEINRICH 284 S.W.3d 366, 373, 376 (Tex. 2009). "Even if a government

entity's immunity has not been waived by the Legislature, a claim may

proceed against a government official in his official capacity if the plaintiff

successfully alleges that the official is engaging in ultra vires conduct”.. 12

4

Supreme Court of Texas: In Schroeder v. Escalera Ranch Owners 'Ass 'n,

Inc., S.W.3d-, (Tex. June 3, 2022) ”Governmental immunity protects the

State's political subdivisions from suit and liability. The Legislature may

waive governmental immunity by statute. .. However, governmental

immunity will "not bar a suit against a government officer for acting outside

his authority-i.e., an ultra vires suit." "To fall within this ultra vires exception,

a suit must not complain of a government officer's exercise of discretion, but

rather must allege, and ultimately prove, that the officer acted without legal

authority or failed to perform a purely ministerial act." "[A] government

officer with some discretion to interpret and apply a law may nonetheless act

'without legal authority,' and thus ultra vires, if he exceeds the bounds of his

granted authority or if his acts conflict with the law itself."…..… …… 11-12

5

STATUTES

• Texas Labor Code Section 408.161(a)……………….…

• SUBCHAPTER K. PROTECTION OF RIGHTS TO BENEFITS, Sec.

408.201.BENEFITS EXEMPT FROM LEGAL PROCESS…...

Rules: Tex. R. App. P. 33.1(a).

28 Tex. Admin. Code § 131.5 (2025)

6

Summary of the Argument

We would establish that the only very severe core issue submitted in

front of this 15th Court of Appeals is a question of law that was glanced

over by the District Court in a abuse of discretion - rush to judgement.

In that - do the, listed below, Texas State Statutes apply to the Texas

Department of Insurance - Division of workers Compensation -

Subsequent Injury Fund?

We are of the point of Law view that these Texas State Statutes are an

unequivocal/inescapable Texas Legislative Directive aimed directly

at the Payer of the Lifetime Income Benefit thus they prescribe and

define the duties to be performed with such precision and certainty

as to leave nothing to the exercise of discretion or judgment period.

Jurisdiction is very clearly warranted within Severe Ultra Vires on the

behalf of the Appellant to be fairly and reasonably heard by the Texas

Judicial Review System.

Furthermore this question of law should have been properly answered

by the District Court during the zoom hearing (CR 90-99) and then

again under Tex. R. Civ. P. 296-297-298 Finding of Facts and

Conclusions of Law as has been establish within Appellants initial

brief that has been accepted before this Court. We would respectfully

request that this 15th Court of Appeals Please review and grant the

motion/request for Finding of Facts and Conclusions of Law or in

the alternative this 15th Court ofAppeals answer the Question of Law.

The narrow issue brought before this 15th Court ofAppeals is to have

the Appellees of the Texas Department of Insurance - Division of

Workers Compensation - Subsequent Injury Fund to comply with the

Law as it has been set out in its directive enactment and intended by

the Texas Legislature. Appellees acted with very Severe Ultra Vires

conduct in their official capacity and without legal authority and their

acts conflict with the law itself and exceeds the bounds of their granted

administrative authority in making an egregious judgment and claim

to interrupt an over two decades long history of an “Established

Equitable”grandfathered on the merits Lifetime Income Benefit.

(CR page 10, #18)

7

The State of Texas Enacted Legislative Directive Statute:

1. Tex. Lab. Code § 408.161

Section 408.161 - Lifetime Income Benefits

(a) Lifetime income benefits are paid until the death of the

employee for:

(1) total and permanent loss of sight in both eyes

This Texas State Statute does not say:

Section 408.161 - Lifetime Income Benefits

(a) Lifetime income benefits are not paid until and at which time the

employee proves monthly, throughout the employees Lifetime,

that they are living by means of personal contact for::

(1) total and permanent loss of sight in both eyes

To have a State Administrative Agency along with its

Administrators totally omit the State of Texas Enacted

Legislative Directive Statute and virtually substitute their own

calling it a legislatively mandated duty and Severe Ultra Vires

act on it is a blatant disregard and beyond just a usurpation of

this Texas Enacted Legislative Directive Statute period.

This Texas State Statute does not say:

Section 408.161 - Lifetime Income Benefits

(a) Lifetime income benefits are paid at the judgment and other

action or claim of a Texas State Administrative Agency at

any time it deems it necessary for:

(1) total and permanent loss of sight in both eyes

Thus this was made Extremely Clear, Precise and Certain by the

Texas State Legislature in Texas State Statute #2 listed below.

8

2. Tex. Lab. Code § 408.201

Section 408.201 - Benefits Exempt From Legal Process

Benefits are exempt from:

(1) garnishment;(2) attachment;(3) judgment; and(4) other actions or

claims.

The State of Texas Enacted Legislative Directive Statutes Supersedes any

TDI/DWC/SIF State Administrative Construed/Usurped Interpretation of a

Texas State Statute and/or State Agency Rule.

In Texas, The Texas State Legislature enacts statutes. State agencies are

given rule making authority by The Texas State Legislature. The Texas State

Courts interpret the law not the state agency and their respective

commissioners, general counsels, administrators.

State agencies are bound to uphold the The Texas State Statutes and not act

as though they have the power and ability to conduct the state agency as

their own unilateral Texas State Legislature and Texas Judiciary period.

9

ARGUMENT

Please be advised that I, Randal Law, am a Pro Se’ Catastrophic Injured

Worker since 03/04/1998 and I am trying my darnedest to protect my “Life”

time Income Benefit. This very serious matter is forever Life changing and

extremely stressful and though I try and keep emotion out of the Judicial

Proceedings I want to Apologize to this 15th Court ofAppeals for my

inabilities and experience to engage as an accomplished attorney would.

(feel as though I’m a twig to a cannon fight) The only way I know to reply to

appellees brief is to approach their judgments and claims individually and

label them as Appellees Claim-Appellants Rebut. Again I apologize for

my structure, content/format of the briefs that may be a bit out of tune.

Appellees claim in Statement of Facts:

“Beginning in September 2022, DWC, in an effort to ensure only living

recipients were being paid LIBs, began calling recipients once a month over

the phone before disbursing any funds.”

Appellant rebut:

Blaise Gerstenlauer of the SIF began calling, in person, around September

2022 this was the first call and was very cordial mostly asking how

everything was going in life and that he was the now SIF administrator.

Approximately 6 months later there was another call with the same content.

Then through all of 2023 the cordial calls were 3 - 4 months apart until early

2024 a call was received 8:30am (sleeping) by a female SIF employee, other

than by Blaise Gerstenlauer, that asked a long list of questions. After

stumbling through answering her questions it was asked how often is this

phone calling going to happen and her response was once a month. She was

advised that this is going to be a serious issue and the call was ended. The

call made this Catastrophic Injured Worker feel as though he was a criminal

and an officer just called conducting a criminal checkup and thought what

would be next an abused legislatively mandated duty of a property

surveillance camera, an abused legislatively mandated duty of a electronic

body monitor, an abused legislatively mandated duty of in-home surprise

visits, an abused legislatively mandated duty of drug test? (CR 19-22).

The SIF stated in their letter dated

10

4/3/2024 (CR page 16-17) that they use a very very powerful research tool

known as https://legal.thomsonreuters.com/en/products/clear and

we ask is this not more than enough to verify life as an addition to their

many methods (CR page 19-20) We would like to remind this Court that

we are Catastrophic Injured Workers and should not be treated as though a

criminal by non certified office workers having absolutely no Mental and

Medical education in dealing with or understanding a Catastrophic Injured

Worker and very a many folks also don’t take into account that a “lifetime

benefit equates to a lifetime of phone calls” under the Appellees plan. Call

it what it appears to be and that would be a lifetime sentence of calls period.

All for getting Catastrophically Injured on the Job and proven Legally Blind

plus other injuries through absolutely no fault of my own mind you.

The need for truth of record is very important to maintain court integrity.

Furthermore it should be very very gravely concerning to anyone who truly

understands the meaning of LIB’s along with the Texas State Directive

Statutes to then view Appellees claim, “before disbursing any funds”, in

which Appellees are admitting, as they have done throughout, that they are

purposely, and will continue, interrupting/holding hostage any LIB’s

recipient payment and refuse to comply with the Texas State Statutes.

Surely this Severe Ultra Vires Act conflicts with the Law itself

§ 408.201 and thus

acted without legal authority and exceeds the bounds of their granted

administrative authority!, (CR page 90-92)

Supreme Court of Texas Van Boven v. Freshour, S.W.3d-,-2022 WL- (Tex.

June 3, 2022) [20-0117] the supreme court made very clear: ***An official

fails to perform a ministerial act when he fails to comply with a law that

"prescribes and defines the duties to be performed with such precision and

certainty as to leave nothing to the exercise of or ." An

official who acts ultra vires is not acting for the state and not entitled to its

immunity. (CR page 90)

Supreme Court of Texas: In Schroeder v. Escalera Ranch Owners 'Ass 'n,

Inc., S.W.3d-, (Tex. June 3, 2022) [20- 0855] ”Governmental immunity

protects the State's political subdivisions from suit and liability. The

11

Legislature may waive governmental immunity by statute. .. However,

governmental immunity will "not bar a suit against a government officer for

acting outside his authority-i.e., an ultra vires suit." "To fall within this ultra

vires exception, a suit must not complain of a government officer's exercise

of discretion, but rather must allege, and ultimately prove, that the officer

acted without legal authority or failed to perform a purely ministerial act."

"A government officer with some discretion to interpret and apply a law may

nonetheless act 'without legal authority,' and thus ultra vires, if he exceeds

the bounds of his granted authority or if his acts conflict with the law itself."

Supreme Court of Texas Hall v. McRaven, 508 S.W.3d 232, 238 (Tex. 2017)

(citation omitted and quoting Heinrich, 284 S.W.3d at 372).Plaintiffs who

seek to bypass sovereign immunity using an ultra vires claim must plead,

and ultimately prove, that the defendant government official "acted without

legal authority or failed to perform a ministerial act." Heinrich, 284 S.W.3d

at 372. An officer acts without legal authority "if he exceeds the bounds of

his granted authority or if his acts conflict with the law itself. (CR page 91)

Supreme Court of Texas CITY OF EL PASO, et al., Petitioners, v. LilliM.

HEINRICH 284 S.W.3d 366, 373, 376 (Tex. 2009). "Even if a government

entity's immunity has not been waived by the Legislature, a claim may

proceed against a government official in his official capacity if the

plaintiff successfully alleges that the official is engaging in ultra vires

conduct."

Appellees claim in Statement of Facts:

“Mr. Law filed his Original Petition in Val Verde County, seeking injunctive

relief from the district court to restrain DWC and its Employees from

discharging their legislatively mandated duty to ensure that Mr. Law was

alive before his LIBs were disbursed.”

12

Appellant rebut:

Here AGAIN the Appellees are abusing “legislatively mandated duty” as a

construed/usurp/guise to interrupt/hold hostage any LIB’s recipient payment

and refusing to comply with the unequivocal/inescapable Texas State

Directive Statutes. (CR pages 19-22)

Proven in the Summary of the Argument:

The State of Texas Enacted Legislative Directive Statute:

1. Tex. Lab. Code § 408.161

Section 408.161 - Lifetime Income Benefits

(a) Lifetime income benefits are paid until the death of the employee

for: (1) total and permanent loss of sight in both eyes

This Texas State Directive Statute Intent does not say:

Section 408.161 - Lifetime Income Benefits

(a) Lifetime income benefits are not paid until and at which time

the employee proves monthly, throughout the employees Lifetime,

that they are living by means of personal contact for:

(1) total and permanent loss of sight in both eyes

There is clearly an opposite and glaring difference between “are paid

until” and “are paid until” !

To have a State Administrative Agency along with its

Administrators totally omit the State of Texas Enacted

Legislative Directive Statute and virtually substitute their own

calling it a legislatively mandated duty and then Severe Ultra

Vires act on it is a blatant disregard and beyond just a usurp of

this Texas Enacted Legislative Directive Statute period.

13

This Texas State Statute Intent does not say:

Section 408.161 - Lifetime Income Benefits

(a) Lifetime income benefits are paid at the judgment and

other action or claim of a Texas State Administrative

Agency at any time it deems it necessary for:

(1) total and permanent loss of sight in both eyes

Thus this was made Extremely Clear, Precise and Certain by the

Texas State Legislature in Texas State Statute #2 listed below.

3. Tex. Lab. Code § 408.201

Section 408.201 - Benefits Exempt From Legal Process

Benefits are exempt from:

(1) garnishment;(2) attachment;(3) judgment; and(4) other actions or

claims.

The State of Texas Enacted Legislative Directive Statutes Supersedes any

TDI/DWC/SIF State Administrative Construed/Usurped Interpretation of a

Texas State Statute and/or State Agency Rule.

In Texas, The Texas State Legislature enacts statutes. State agencies are

given rule making authority by The Texas State Legislature. The Texas State

Courts interpret the law not the state agency and their respective

commissioners, general counsels, administrators.

State agencies are bound to uphold the The Texas State Statutes and not act

as though they have the power and ability to conduct the state agency as

their own unilateral Texas State Legislature and Texas Judiciary period.

14

Appellees claim in Summary of the Argument:

“Mr. Law’s claims are an impermissible attempt to control state action and

affirmatively negated the existence of the district court’s jurisdiction. For all

these reasons, this Court should affirm the district court’s grant of the

Appellees’ Plea to the Jurisdiction.”

Appellant rebut:

We are not attempting to control state action at all. The TDI/DWC/SIF fails

to comply with a law and acted without legal authority and their acts conflict

with the law itself and exceeds the bounds of their granted administrative

authority!,

This is an attempt to reassert the control of the state over its administrators.

Therefore this 15th Court ofAppeals should surely negate the district court’s

grant of the Appellees’Plea to the Jurisdiction. Grant Jurisdiction to the

Appellant for the stated justifications/supporting authority. (CR page 90-92)

Supreme Court of Texas Chambers-Liberty Cntys. Navigation Dist. v. State,

575 S.W.3d 339, 344 (Tex. 2019). "The basic justification for this ultra vires

exception to sovereign immunity is that ultra vires acts-or those acts without

authority-should not be considered acts of the state at all. Consequently,

'ultra vires suits do not attempt to exert control over the state-they attempt to

reassert the control of the state' over one of its agents."

15

Appellees claim in Argument:

Mr. Law asserts statutory provisions in his Petition as the basis for this suit,

but none of them provide valid grounds to maintain a suit against a state

agency. See Plaintiff-Appellants’ First Am. Pet. at 4-5 ¶¶ 15–16 (citing Tex.

Civ. Prac. & Rem. Code § 65.011; Tex. Lab. Code §§ 408.161, 408.201).

The statutes cited by Mr. Law create no separate cause of action under the

Labor Code to enjoin alleged “bullying” and “harassment” by employees

of a state agency.

Appellant rebut:

The Appellees would attempt to distract and sway this Honorable 15th

Court ofAppeals with their guise claims throughout their actions and

submitted brief to this court with a claim such as that.

I the Plaintiff-Appellant brought forth Tex. Civ. Prac. & Rem. Code §

65.011; Tex. Lab. Code § 408.161, 408.201 in our original first amended

petition because the letter (CR 16-17) received from Blaise Gerstenlauer

said the Lifetime Income Benefit would be interrupted. This sent me the

Plaintiff-Appellant into a pure panic mode (Please view CR 37 and CR

5-8)

The Appellees claim throughout their brief similar statements like this:

“Mr. Law asserts statutory provisions in his Petition as the basis for this suit,

but none of them provide valid grounds to maintain a suit against a state

agency.”

I would invite this 15th Court ofAppeals to Please view (CR 5-27, 64-72) the

“whole petition” CR 5-10 in particular page 9 and I have to Trust this 15th

Court of Appeals will deploy keen eyes within Judicial Prudence to gain the

truth of the mattter that I the Plaintiff-Appellant was, still are, providing

the best valid grounds with what I had and have period.

In the beginning of their Severe Ultra Vires conduct I did not know how to

construct a petition or have any iota of what an e-file was at all and the

myriad of complications the e-file system has. Then I had to have someone

take time out of their busy schedule and transport me and the documents to

the Clerks Office and trying to get this accomplished in pure panic mode

with little to no proper resources to aide me at all.

16

I was certain that once I got in front of a Texas State District Court Judge

“ and showed them the letter to interrupt the LIB’s and then

show the controlling Texas State Directive Statutes that my LIB’s would

continue to be paid as they always were “over two decades of an

Established Equitable grandfathered on the merits - status quo!.”

Still waiting for this to occur because as of yet the Appellees do not want to

have the question of law Jurisdictional/Judicially truthfully answered.

I took, and still take Great Offense to this as they were, and still are, trying

to Exploit My Disabilities in furtherance their Severe Ultra Vires Conduct!.

The Appelles claim in their statement “bullying” and “harassment” but

they purposely omit, as they do blatantly and frequently, “Threaten”

irreparable harm which is exactly what the letter did to my “Life”time and

Income period!.(LIB’s monthly Direct Deposit being one week late had

already just recently caused catastrophic financial hardship at that time and

another hit at this time would have strangled me) (CR Page 14 top of page)

Appellees claim in Argument:

“Thus, it is clear that the crux of this dispute is that Mr. Law does not like

the mechanism DWC and its Employees have utilized to ensure he is still

alive before he receives his LIBs.”

Appellant rebut:

The Crux and the DWC mechanism ?

We would respectfully request, with the keen eyes and mind of the 15th

Court of Appeals, to apply Appellants Summary ofArgument- this time

denoting {Crux} and {DWC mechanism}.

17

The State of Texas Enacted Legislative Directive Statute:

1. Tex. Lab. Code § 408.161

Section 408.161 - Lifetime Income Benefits {Crux}

(a) Lifetime income benefits paid until the death of the

employee for: (1) total and permanent loss of sight in both eyes

This Texas State Statute Intent does not say: {DWC mechanism}

Section 408.161 - Lifetime Income Benefits

(a) Lifetime income benefits are not paid until and at which time

the employee proves monthly, throughout the employees Lifetime,

that they are alive by means of personal contact for:

(1) total and permanent loss of sight in both eyes

There is clearly an opposite and glaring difference between “are” and

“are ” and the added intent Appellees have rule forced into 408.161

compared to the legislative intent.

A Texas Administrative Agency adoption of a rule cannot convert the

State of Texas Legislative Enactment of a Directive Statute Period !

{DWC mechanism}

To have a State Administrative Agency along with its

Administrators totally omit the State of Texas Enacted

Legislative Directive Statute and virtually substitute their own

through abusing a legislatively mandated duty and then

Severe Ultra Vires act on it is a blatant disregard and beyond

just a usurp of this Texas Enacted Legislative Directive

Statute period.

This Texas State Statute does not say: {DWC mechanism}

Section 408.161 - Lifetime Income Benefits

(a) Lifetime income benefits are paid at the judgment and

other action or claim of a Texas State Administrative

Agency at any time it deems it necessary for:

(1) total and permanent loss of sight in both eyes

18

Thus this was made Extremely Clear, Precise and Certain by the

Texas State Legislature in Texas State Statute #2 listed below.

4. Tex. Lab. Code § 408.201

Section 408.201 - Benefits Exempt From Legal Process {Crux}

Benefits are exempt from:

(1) garnishment;(2) attachment;(3) judgment; and(4) other actions or

claims.

The State of Texas Enacted Legislative Directive Statutes Supersedes any

TDI/DWC/SIF State Administrative Construed/Usurped Interpretation of a

Texas State Statute and/or State Agency Rule. {Crux}

In Texas, The Texas State Legislature enacts statutes. State agencies are

given rule making authority by The Texas State Legislature. The Texas State

Courts interpret the law not the state agency and their respective

commissioners, general counsels, administrators. {Crux}

State agencies are bound to uphold the The Texas State Statutes. {Crux}

Not act as though they have the power and ability to conduct the state

agency as their own unilateral Texas State Legislature and Texas Judiciary

period. {DWC mechanism}

Yes! it is true Mr. Law does not like the mechanism DWC and its Employees

have utilized because the Appellees acted with very Severe Ultra Vires

conduct in their official capacity and without legal authority and their acts

conflict with the law itself and exceeds the bounds of their granted

administrative authority in making an egregious judgement and claim and a

Texas Administrative Agency adoption of a rule cannot convert the State of

Texas Legislative Enactment of a Directive Statute Period !

Thus Jurisdiction should be Ordered and Granted on behalf of the

Appellant to be reasonably and fairly heard .

19

Note: 28 TAC §131.5. was constructed and adopted after this case

15-24-00097-CV and D-1-GN-24-003462 was filed and during this

pending litigation. Plaintiff-Appellant had no knowledge of and was not

notified of the New Rule existence until it was used as a defense in

Appellees Brief - (page 12 content/footnote)

The Extreme Effrontery to absolutely transform an unequivocal/inescapable

Texas State Legislative Directive Statute Intent of “are paid until death”

and usurp/severe ultra vires it to an administrative mandated abuse of “

paid until…” is a direct arbitrary and capricious undermining and

thumbing of the nose at the Texas State Legislature and the Texas State

Judiciary period!

The Extreme Effrontery to absolutely and unlawfully transform:

The long established Legislative Legal definition and Intent of a Lifetime

Income Benefit and the recipient of the Lifetime Income Benefit long

known and affirmed/established as a Catastrophic Injured Worker and for

good reason.

The New Rule 131.5 has effectively subjugated and completely thrown out

the long affirmed/established respectable, reasonable and fair legal

definitions/terms/intent and substituted its own completely arbitrary and

capricious definitions/terms/intent. The New Rule 131.5 capricious

construction and arbitrary language is beyond Extremely Offensive and a

down right demeaning, degrading, undermining, and unlawful thumbing of

the nose at any truthful meaning and interpretation of reasonableness,

respect, fairness, ethics, and morals. The New Rule should be abolished in

its entirety and those individuals, in their official capacity, of its

construction and adoption be held accountable period!. (CR Page 8)

We would point out now in regard to the New Rule 28 TAC §131.5 that we

would respectfully request the 15th Court of Appeals to please forgive and

understand the Appellants use of a Respectable Texas Hunting Ranch

analogy of “aiming for-skinning-gutting-and quartering/dressing for public

consumption” phrase as it is the best description available to bring to the

forefront of what the TDI-DWC-SIF Administrative Agency has done to the

Texas State Directive Statutes and Lifetime Income Benefit and Recipient

via a Rule/Judgment and claim under an abuse of Legislative Mandated Duty.

I digress and you be the Honorable Justices as you cast keen eyes and mind

of Judicial Prudence in contemplating the New Rule.

20

(A.)

TITLE 28. INSURANCE Adopted Section

Part 2. Texas Department of Insurance, Page 1 of 6

Division of Workers’ Compensation

Chapter 131. Benefits--Lifetime Income Benefits

SUBCHAPTER A. GENERAL PROVISIONS.

28 TAC §131.5.

INTRODUCTION. The Texas Department of Insurance, Division of Workers’

Compensation (DWC) adopts new 28 TAC §131.5, concerning verification by the

Subsequent Injury Fund (SIF).

New §131.5 is adopted with changes to the proposed text published in the

September 27, 2024, issue of the Texas Register (49 TexReg 7837). Section 131.5 will be

republished. In response to comments, DWC replaced the terms “lifetime income benefits

recipient” and “recipient” with “injured employee” to be consistent with other income

benefit rules, and added a sentence to clarify that, if the injured employee is unable to

provide the required information, the SIF will hold any pending benefit payments until

verification is complete.

{Here the Appellees have completely aimed at, skinned and gutted Tex. Lab.

Code § 408.161 and Tex. Lab. Code § 408.201. as well as degraded/insulted

and demeaned the Catastrophic Injured Worker as was brought forth on page

20 above in this reply brief.

(PLEASE! View CR 19-20, #1. that is now proven here by arbitrary Appellees)

I digress -This would be the equivalent of a new appellate rule saying the 15th

Court of Appeals Honorable Justices will now be known as and referred to as

just a Court Participant}

REASONED JUSTIFICATION. The new section requires the SIF to verify that the lifetime

income benefits (LIBs) recipient (injured employee) is living, receiving LIBs payments, and

their contact information has not changed. The new section also requires the injured

employee to certify the information with the SIF each month over a telephone call, video

call, or other online verification system to receive the LIBs payment from the SIF. It clarifies

that the SIF will hold any pending benefit payments until the injured employee verifies

the information in subsection (a). New §131.5 is necessary to implement Labor Code

§§408.081, 408.161, and 408.162.

21

{DWC mechanism quote - “The new section requires the SIF to verify that

the lifetime income benefits (LIBs) recipient (injured employee)…” -

We are certain that this 15th Court of Appeals can detect the nonsensical in

that statement by the arbitrary Appellees after they just obliterated the use of

the name of Lifetime Income Benefit and Recipient in their first paragraph

above in their INTRODUCTION.}

{DWC mechanism quote - “is living, receiving LIBs payments, and their

contact information has not changed.”

This is exactly what CLEAR https://legal.thomsonreuters.com/en/products/clear

does and much much more. As was pointed out on top of page 11 in this reply

brief and 4/3/2024 (CR page 16-17, 19)}

{DWC mechanism quote - “or other online verification system.”

Clearly the Appellees should continue to use their CLEAR program. Thus one

of very many reasons this new rule 131.5 and its unlawful arbitrary

transformation, subjugation and usurping should be totally abolished.}

{DWC mechanism quote - “New §131.5 is necessary to implement Labor

Code §§408.081, 408.161, and 408.162.”

We demand Tex. Lab. Code § 408.161 is and always has been an

unequivocal/inescapable Texas Legislative Directive Statute aimed

directly at the Payer of the Lifetime Income Benefit period. What the

Appellees have done with this new rule 131.5 is they have absolutely

effectively transformed and subjugated 408.161 NOT implemented.

A Texas Administrative Agency arbitrary adoption of a rule cannot

convert the State of Texas Legislative Enactment of a Directive Statute

Period !

Thus act Severe Ultra Vires conduct in their official capacity and without

legal authority and their acts conflict with the law itself and exceeds the

bounds of their granted administrative authority in making an egregious

judgement and claim to interrupt an over two decades long history of an

“Established Equitable” on the merits LIB’s (CR page 10, #18) .}

22

Labor Code §§408.081 and 408.161 pertain to when and how injured employees receive

LIBs and require that LIBs are payable only while the injured employee is alive. New §131.5

is necessary to implement those sections effectively by ensuring that DWC is notified of

the injured employee’s death before the SIF issues a LIBs payment to that injured

employee.

{DWC mechanism quote - "implement those sections effectively by ensuring that

DWC is notified of the injured employee’s death before the SIF issues a LIBs

payment"

There is clearly an opposite and glaring difference between “are paid until”

and “are paid until” -

Here the Appellees have effectively transformed and very crafty aimed

for and skinned, gutted,and quartered/dressed for public consumption a

unequivocal/inescapable Texas Legislative Directive Statute 408.161.

A Texas Administrative Agency adoption of a rule cannot convert the

State of Texas Legislative Enactment of a Directive Statute Period !

{We demand Tex. Lab. Code § 408.161 is and always has been an

unequivocal/inescapable Texas Legislative Directive Statute aimed directly at

the Payer of the Lifetime Income Benefit period. What the Appellees have

done with this new rule 131.5 is they have absolutely effectively transformed

and subjugated 408.161 NOT implemented.

Thus act Severe Ultra Vires conduct in their official capacity and without

legal authority and their acts conflict with the law itself and exceeds the

bounds of their granted administrative authority in making an egregious

judgement and claim to interrupt an over two decades long history of an

“Established Equitable” grandfathered on the merits Lifetime Income Benefit

…………………………………………(CR page 10, #18) .}

Labor Code §408. 162 applies when an injury combines with a subsequent injury to qualify

an injured employee for LIBs. In these situations, the insurance carrier for the subsequent

injury pays benefits for the subsequent injury as if the previous injury did not happen, and

the SIF pays the difference between the LIBs and the amount the insurance carrier pays

for the subsequent injury. New §131.5 is necessary for DWC to verify that the injured

employee is still alive, preventing the waste of public funds when the SIF makes these

payments to the injured employee.

23

{We demand Tex. Lab. Code § 408.161 is and always has been an

unequivocal/inescapable Texas Legislative Directive Statute aimed

directly at the Payer of the Lifetime Income Benefit period. What the

Appellees have done with this new rule 131.5 is they have absolutely

effectively transformed and subjugated 408.161 NOT implemented.

Thus act Severe Ultra Vires conduct in their official capacity and without

legal authority and their acts conflict with the law itself and exceeds the

bounds of their granted administrative authority in making an egregious

judgement and claim to interrupt an over two decades long history of an

“Established Equitable” grandfathered on the merits Lifetime Income

Benefit …………………………………………(CR page 10, #18) .}

SUMMARY OF COMMENTS AND AGENCY RESPONSE.

Commenters: DWC received two written comments, and no oral comments. The Office

of Injured Employee Counsel (OIEC) requested several clarifications. Texas Mutal

Insurance Company (TMIC) commented in support of the proposal with changes.

Comment. OIEC asked DWC to clarify that any income payments withheld because a

recipient failed to verify the required information will only be placed on hold and released

to the recipient once verification is made.

Agency Response to Comment. DWC appreciates the comment. Under §131.5, the SIF

will release the withheld payments when the recipient provides the information required

by subsection (a). In addition, DWC has added a sentence to subsection (b) to clarify that

any benefits that are on a temporary hold will be released once verification is complete.

{We demand Tex. Lab. Code § 408.161 is and always has been an

unequivocal/inescapable Texas Legislative Directive Statute aimed

directly at the Payer of the Lifetime Income Benefit period. What the

Appellees have done with this new rule 131.5 is they have absolutely

effectively transformed and subjugated 408.161 NOT implemented.

Thus act Severe Ultra Vires conduct in their official capacity and without

legal authority and their acts conflict with the law itself and exceeds the

bounds of their granted administrative authority in making an egregious

judgement and claim to interrupt an over two decades long history of an

“Established Equitable” grandfathered on the merits Lifetime Income

Benefit …………………………………………(CR page 10, #18) .}

24

TITLE 28. INSURANCE Adopted Section

Part 2. Texas Department of Insurance, Page 2 of 6

Division of Workers’ Compensation

Chapter 131. Benefits--Lifetime Income Benefits

Comment. OIEC asked DWC to clarify that DWC will continue to make monthly outreach

to injured employees and that the intent of the rule is not to shift the burden to the injured

employees.

Agency Response to Comment. DWC appreciates the comment. The SIF will attempt to

contact the injured employee before the SIF makes each payment. The injured employee

must provide the information required by subsection (a) to the SIF.

{DWC mechanism quote - “shift the burden to the injured employees - before

the SIF makes each payment”

Burden does not even begin to describe what irreparable harm this new rule

131.5 can induce in regard to a “Catastrophic” Injured Worker!

FACT !!! - This Catastrophic Injured Worker thought that a Automatic Bill

Pay feature was a blessing due to Closed Head Injury resulting in forgetfulness.

This banking feature proved beneficial for a very long time until the SIF was

one week late with the LIB’s direct monthly deposit that took place not long

after the new SIF administrator began duty. The late LIB’s resulted in a

snowball effect of inefficient funds fees, late fees, other fees/fines that eventually

forced this Catastrophic Injured Worker to file for bankruptcy and credit

score going from 712 to as of this day a 506. So PLEASE do not burden a

Catastrophic Injured Worker with a unlawful withholding of the LIB’s period.

(CR Page 14 top of page) }

{We demand Tex. Lab. Code § 408.161 is and always has been an

unequivocal/inescapable Texas Legislative Directive Statute aimed

directly at the Payer of the Lifetime Income Benefit period. What the

Appellees have done with this new rule 131.5 is they have absolutely

effectively transformed and subjugated 408.161 NOT implemented.

Thus act Severe Ultra Vires conduct in their official capacity and without

legal authority and their acts conflict with the law itself and exceeds the

bounds of their granted administrative authority in making an egregious

judgement and claim to interrupt an over two decades long history of an

“Established Equitable” grandfathered on the merits Lifetime Income

Benefit …………………………………………(CR page 10, #18) .}

25

Comment. OIEC asked DWC to clarify that an authorized representative is permitted to

verify the information.

Agency Response to Comment. DWC appreciates the comment. A representative, as

defined by Labor Code §401.011 and 28 TAC §150.3, can verify the information required

by this rule. A representative that fails to comply with the Labor Code or a DWC rule may

be subject to sanctions as provided by law.

Comment. TMIC expressed concern that the proposed rule does not provide for notice

to the insurance carrier that the injured employee has not provided the required

verification, because the insurance carrier may also be making payments to an injured

employee under §131.3. TMIC recommended that the proposed rule be revised to provide

sufficient written notice to the injured employee and the insurance carrier if the SIF

suspends or later reinstates LIBs.

Agency Response to Comment. DWC appreciates the comment but declines to make

the change. DWC’s practice is to communicate with the insurance carrier only if the

insurance carrier is paying a portion of the LIBs.

{We demand Tex. Lab. Code § 408.161 is and always has been an

unequivocal/inescapable Texas Legislative Directive Statute aimed

directly at the Payer of the Lifetime Income Benefit period. What the

Appellees have done with this new rule 131.5 is they have absolutely

effectively transformed and subjugated 408.161 NOT implemented.

Thus act Severe Ultra Vires conduct in their official capacity and without

legal authority and their acts conflict with the law itself and exceeds the

bounds of their granted administrative authority in making an egregious

judgement and claim to interrupt an over two decades long history of an

“Established Equitable” grandfathered on the merits Lifetime Income

Benefit …………………………………………(CR page 10, #18) .}

26

TITLE 28. INSURANCE Adopted Section

Part 2. Texas Department of Insurance, Page 3 of 6

Division of Workers’ Compensation

Chapter 131. Benefits--Lifetime Income Benefits

Comment. TMIC recommended that DWC consider providing a clear

process in the rule to suspend or reinstate benefits if verification is later

completed or the injured employee becomes entitled to LIBs again under

the provisions of Labor Code §408.1615.

Agency Response to Comment. DWC appreciates the comment

and has added a sentence to the rule to clarify that any LIBs payments

that were left pending due to the injured employee not completing

the required verification will be issued once the verification is

complete.

Comment. TMIC recommended that the proposal be revised to replace

the term “lifetime income benefit recipients” with “injured employees.”

Agency Response to Comment. DWC appreciates the comment and

has replaced the terms “lifetime income benefit recipient” and “recipient

” with “ injured employee” to be consistent with other income benefit

rules.

{DWC mechanism quote - replaced the terms “lifetime income

benefit recipient” and “recipient” with “injured employee”

I digress, the words this Appellant - Catastrophic Injured

Worker has at this particular moment for such arbitrary

language as demonstrated here now by Appellees and throughout

the construed content of the New Rule 131.5 would not be

suitable, but true, to this Honorable 15th Court of Appeals

Justices.

(PLEASE! View CR 19-20, #1. that is now proven here by

arbitrary Appellees)

“may be just a precursor of a very much larger scheme to

eventually eliminate the LIBS recipient altogether through the

slow collective manipulation of Texas State statutes/rules and

your proven usurping of the Texas State statutes and rules”

27

We therefore defer back to the statement in this reply brief located on page 20

paragraph 4.

The New Rule 131.5 has effectively subjugated and completely thrown out the

long affirmed/established respectable, reasonable and fair legal

definitions/terms/intent and substituted its own completely arbitrary and

capricious definitions/terms/intent.

The New Rule 131.5 capricious construction and arbitrary language is beyond

Extremely Offensive and a down right demeaning, degrading, undermining,

and unlawful thumbing of the nose at any truthful meaning and interpretation

of reasonableness, respect, fairness, ethics, and morals. The New Rule should

be abolished in its entirety and those individuals, in their official capacity, of its

construction and adoption be held accountable period!. (CR Page 8)

28

TITLE 28. INSURANCE Adopted Section

Part 2. Texas Department of Insurance, Page 4 of 6

Division of Workers’ Compensation

Chapter 131. Benefits--Lifetime Income Benefits

SUBCHAPTER A. GENERAL PROVISIONS.

28 TAC §131.5.

STATUTORY AUTHORITY. The commissioner of workers' compensation adopts new 28

TAC §131.5 under Labor Code §§402.00111, 402.00116, 402.00128, 402.021, 402.061,

408.081, 408.161, and 408.162.

Labor Code §402.00111 provides that the commissioner of workers' compensation

shall exercise all executive authority, including rulemaking authority under Title 5 of the

Labor Code.

Labor Code §402.00116 provides that the commissioner of workers' compensation

shall administer and enforce this title, other workers' compensation laws of this state, and

other laws granting jurisdiction to or applicable to DWC or the commissioner.

Labor Code §402.00128(b)(12) provides that the commissioner may exercise other

powers and perform other duties as necessary to implement and enforce the Workers'

Compensation Act.

Labor Code §402.021(b)(3) provides that the workers' compensation system must

provide appropriate income benefits and medical benefits in a manner that is timely and

cost-effective.

Labor Code §402.061 provides that the commissioner of workers' compensation

shall adopt rules as necessary to implement and enforce the Texas Workers'

Compensation Act.

{(CR pages 19-23 covers Appellant Response to the statutes listed here)}

29

TITLE 28. INSURANCE Adopted Section

Part 2. Texas Department of Insurance, Page 5 of 6

Division of Workers’ Compensation

Chapter 131. Benefits--Lifetime Income Benefits

Labor Code §408.081(d) provides that an employee's entitlement to LIBs ends on the

death of the employee.

Labor Code §408.161(a) provides that LIBs are paid until the death of the employee.

Labor Code §408. 162(a) provides that, when an injury combines with a subsequent injury

to qualify an injured employee for LIBs, the insurance carrier for the subsequent injury

pays benefits for the subsequent injury as if the previous injury did not happen.

Section 408. 162(b) requires the SIF to pay the difference between the amount of LIBs and

the amount the insurance carrier pays for the subsequent injury.

TEXT.

§131.5. Verification by the Subsequent Injury Fund.

(a) The Subsequent Injury Fund must confirm the following information before

making a payment to the injured employee:

(1) the injured employee is living;

(2) lifetime income benefits are being received; and

(3) the injured employee’s contact information is correct.

(b) The injured employee must provide the information required by subsection

(a)(1) - (3) to the Subsequent Injury Fund each month over a telephone call, video call, or

other online verification system to receive the lifetime income benefit payment from the

Subsequent Injury Fund. If the injured employee is unable to provide the information, the

Subsequent Injury Fund will hold any pending payments until verification is complete.

{We demand Tex. Lab. Code § 408.161 is and always has been an

unequivocal/inescapable Texas Legislative Directive Statute aimed

directly at the Payer of the Lifetime Income Benefit period. What the

Appellees have done with this new rule 131.5 is they have absolutely

effectively transformed and subjugated 408.161 NOT implemented.

Thus act Severe Ultra Vires conduct in their official capacity and without

legal authority and their acts conflict with the law itself and exceeds the

bounds of their granted administrative authority in making an egregious

judgement and claim to interrupt an over two decades long history of an

“Established Equitable” grandfathered on the merits Lifetime Income

Benefit …………………………………………(CR page 10, #18) .}

30

TITLE 28. INSURANCE Adopted Section

Part 2. Texas Department of Insurance, Page 6 of 6

Division of Workers’ Compensation

Chapter 131. Benefits--Lifetime Income Benefits

CERTIFICATION. The agency certifies that legal counsel has reviewed the adoption and

found it to be a valid exercise of the agency's legal authority.

Issued at Austin, Texas, on January 29, 2025.

Kara Mace

General Counsel

TDI, Division of Workers' Compensation

The commissioner adopts new 28 TAC §131.5.

Jeff Nelson

Commissioner

TDI, Division of Workers' Compensation

Commissioner's Order No. 2025-9108

31

A. Standard of Review

Addressing this very Severe Issue may require interpretation of

Labor Code, Chapter 408. Workers ’ Compensation Benefits which

occurs under a de novo standard of review. Otherwise this is an

abuse of discretion/rush to judgement review.

A district court abuses its discretion in a rush to judgement

by erroneously interpreting a law or by resting its decision on

an inaccurate view of the law.

* Plaintiff Randal Law would respectfully request that this

Honorable Fifteenth Court Of Appeals to please be mindful during

this very crucial appellate review application process that Plaintiff

Randal Law is a pro se Catastrophic Injured Worker receiving a

Lifetime Income Benefit (LIBs) from the Subsequent Injury Fund

(SIF). The LIBs from the SIF are not very well known at all or

understood by Many involved within the Texas Judicial Review

System due to the very low number of active LIBs cases at the SIF

(the actual number of active LIB’s cases was respectfully requested

and denied). This very low number of active LIBs at the SIF

therefore has resulted in next to no case history or precedent that we

can find and therefore found this case reliant on other Similarly

Ultra Vires cases and Supreme Court Decisions.

*Appellant Randal Law being with catastrophic disabilities is trying

to protect his LIBs with whats available and would ask this court at

what point does a Catastrophic Injured Workers disabilities for a

proper defense against a Severe Ultra Vires Act become unfair,

unreasonable or God Forbid unattainable?.

32

CONCLUSION AND PRAYER

We demand Tex. Labor Code § 408.161 in conjunction with Tex. Labor

Code § 408.201 are and always have been an unequivocal/inescapable Texas

Legislative Directive Statute aimed directly at the Payer of the Lifetime

Income Benefit period. What the Appellees have done with the new rule 28

TAC §131.5 is they have absolutely effectively transformed and subjugated

Tex. Labor Code § 408.161- Tex. Labor Code § 408.201 NOT implemented.

The New Rule 131.5 has effectively subjugated and completely thrown out

the long affirmed/established respectable, reasonable and fair legal

definitions/terms/intent and substituted its own completely arbitrary and

capricious definitions/terms/intent.

The New Rule 131.5 capricious construction and arbitrary language is

beyond Extremely Offensive and a down right demeaning, degrading,

undermining, and unlawful thumbing of the nose at any truthful meaning and

interpretation of reasonableness, respect, fairness, ethics, and morals. The

New Rule should be abolished in its entirety and those individuals, in their

official capacity, of its construction and adoption be held accountable period!.

(CR Page 8)

A Texas Administrative Agency's arbitrary adoption of a rule must not and

cannot be allowed to subjugate and convert the State of Texas Legislative

Enactment of a Directive Statute Period !

Thus the Appellees acted Severe Ultra Vires conduct in their official

capacity and without legal authority and their acts conflict with the law itself

and exceeds the bounds of their granted administrative authority in making

an egregious judgment and claim and/or other action to interrupt an over

two decades long history of an “Established Equitable” grandfathered on

the merits Lifetime Income Benefit (CR page 10, #18).

Therefore, this Court should set the lower court’s judgement aside and

render a Plaintiff has Jurisdiction judgement and have it answered the

questions of Law in all reasonableness and fairness to a Catastrophic Injured

Worker and Lifetime Income Benefit Recipient to be heard on an over two

decades long established equitable grandfathered On The Merits.

Respectfully submitted,

/s/ Randal Law

Randal Law. Plaintiff

701 E. 11th St.

Del Rio, Texas 78840

(830)-768-1556

Rlaw9@stx.rr.com

33

CERTIFICATE OF COMPLIANCE

I certify that this brief complies with Texas Rule of

Appellate Procedure 9.4(i)(3), and the word count of this document is

8,498 words including all portions that are not exempted by the rule. The

word processing software used to prepare this filing and calculate the word

count of the document is WPS Office.

/s/ Randal Law

Randal Law. Plaintiff

34

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument was forwarded

to all counsel of record shown below by e-service and/or e-mail in accordance with the

Texas Rules of Civil Procedure on April 18, 2025.

CANON HILL

State Bar No. 24140247

Assistant Attorney General

Administrative Law Division

OFFICE OF THE ATTORNEY GENERAL OF TEXAS

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

Telephone: (512) 936-1838

Canon.Hill@oag.texas.gov

/s/ Randal Law

Randal Law. Plaintiff

35

Automated Certificate of eService

This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system

on the date and to the persons listed below. The rules governing

certificates of service have not changed. Filers must still provide a

certificate of service that complies with all applicable rules.

Envelope ID: 99845483

Filing Code Description: Other Brief

Filing Description: Reply Brief of Appellant Randal Law in Conjunction with

Initial Brief on the Merits

Status as of 4/18/2025 3:34 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Paul Pruneda paul.pruneda@oag.texas.gov 4/18/2025 3:11:24 PM SENT

Randal Law rlaw9@stx.rr.com 4/18/2025 3:11:24 PM SENT

Canon ParkerHill canon.hill@oag.texas.gov 4/18/2025 3:11:24 PM SENT

Canon Hill Canon.Hill@oag.texas.gov 4/18/2025 3:11:24 PM SENT

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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