# Amicus Brief — Breed v. Jones

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385003_0122%3A07

## Record

- **Collection:** Supreme Court brief
- **Document type:** Amicus Brief
- **Published:** January 1, 1975
- **Citation:** 421 U.S. 519

## Text

IN THE

Supreme Court of the United States

OCTOBER TERM, 1974

No. 73-1995

ALLEN F. BREED,
Petitioner,

GARY STEVEN JONES,
Respondent.

ON WRIT OF CERTIORARI TO THE UNITED STATES
COURT OF APPEALS FOR THE NINTH CIRCUIT.

BRIEF FOR AMICUS CURIAE
NATIONAL COUNCIL OF JUVENILE
COURT JUDGES

ALFRED L. SCANLAN

I. MICHAEL GREENBERGER
734 Fifteenth Street, N.W.
Washington, D.C. 20005

Attorneys for National Council of
Juvenile Court Judges, Amicus Curiae

Of Counsel:

SHEA & GARDNER

734 Fifteenth Street, N.W.
Washington, D.C. 20005

January 14, 1975

SE NET EE Ee ae ET TTT
Washington, D.C @ CLB PUBLISHERS’ « LAW PRINTING CO. e (202) 393-0625

(i)
TABLE OF CONTENTS

Page

INTRODUCTORY STATEMENT ................... I
THE INTEREST OF THE AMICUS AND ITS

POSITION ON THE QUESTION PRESENTED ........ 2

A. Interest ofthe Amicus ................... 2

B. The Position of Amicus on the Issues ..... Pere e

SUMMARY OF ARGUMENT ...................... 5

EY ee Gee ee dees debi es en bh bece cas 9

1. THE DOUBLE JEOPARDY CLAUSE PRE-
CLUDES A TRIAL IN AN ADULT CRIMI-
NAL COURT PERTAINING TO THE SAME
OFFENSE FOR WHICH THE DEFENDANT
HAS BEEN ADJUDICATED A_ DELIN-
QUENT IN A JUVENILE COURT ............. 9

A. The Double Jeopardy Clause Has Been
Incorporated into The Fourteenth
Amendment to Apply to State Criminal
Rr er Peer 9

B. Jeopardy Attached in The Juvenile Court
ee dh Whe OREN Shand bb 6 440 ewe 11

C. Double Jeopardy Resulted When
Respondent Was Tried in An Adult
Criminal Court for The Same Course of
Conduct for Which He Was Determined a
Delinquent in The Juvenile Court ............. ly

1. The “continuing jeopardy” doctrine
does not apply to a trial in a
criminal court after a delinquency
determination has been made in a
ROR GUE wc ce hteceweeeescscnces:

2. The policies of the double jeopardy

clause are served by prohibiting the
reprosecution of respondent ..........-.-+. 20

(ii)

Page
Il. THE DETERMINATION OF WHETHER A
DEFENDANT IS ENTITLED TO DOUBLE
JEOPARDY PROTECTION IN A STATE
CRIMINAL COURT SHOULD NOT BE
BASED ON A CONSIDERATION OF
POSSIBLE INDIRECT CONSEQUENCES A
STATE MIGHT SUFFER FROM THE

GRANT OF SUCH A RIGHT .................22

lll. THE CONDUCT OF A TRANSFER HEAR-
ING PRIOR TO A DETERMINATION OF
DELINQUENCY WILL NOT DISRUPT THE
BENEVOLENT ASPECTS OF THE
STATE’S JUVENILE COURT SYSTEM
AND IS REQUIRED FOR FUNDAMENTAL
EE, OG eb th cheese he besetekeseesess 27

A. Requiring A Transfer Proceeding to Be
Conducted Prior to An Adjudication of
Delinquency Will Not Disrupt The Bene-
volent Aspects of The Juvenile Court
he, Ce ee al ae ain du b's Sa 6 6’ 27

1. Most jurisdictions preclude the use of
transfer after a delinquency deter-
mination has been made ............... 27

ty

Most model juvenile court acts and
other authorities preclude or dis-
courage the use of transfer after a
delinquency determination .............. 30

3. As a practical matter, a prior transfer
is the preferable procedure ............. 33

a. Prior transfer will not “engraft™ a
new procedure to, or cause undue
delay in, the juvenile system ......... 34

b. The need for judges who rule on
transfer to recuse themselves
from the delinquency proceeding
T -ischtu ns wawen ss ovcocuae

(iit)

Page
c. The bifurcation process will not
be disrupted by a prior transfer
ee re 39
d. The juvenile court has sufficient
resources to gather all relevant
information about a juvenile at a
prios transferhearing ...........0.. 40
e. Prior transfer will not lead to
unfair plea bargaining .............. 42
B. Allowing The Transfer Hearings to Be
Held after An Adjudication of Delin-
quency Is Fundamentally Unfair to The
DE +s SEGURA SSR ES EDS RS bd 0866 6 60088 43

1. Exposure of the juvenile’s entire case
to the State, which may have the
opportunity to retry the juvenile in a
criminal court, is fundamentally un-
i [which is held prior to the determination
delinquency] the decision be made as to whether
there should be a fitness hearing. At the detention
hearing it is clear that the police report may be
considered, anything probation introduces may be
considered.®® There is no requirement that evidence
be limited to competent evidence, and in the usual
case it should be at the detention hearing.

1 will go further and say I don’t think that the
Juvenile Court would be crippled if there were no
707 as it is now constituted, that is, / don’t know

California, as is true in most states, requires that a detention
hearing be held one judicial day after a delinquency petition is filed
in juvenile court. The purpose of the hearing is to determine
whether the minor should be released pending further hearings.
Cal. Welf. and Inst’ns Code § § 632, 635, 636 (1972). See In re
William M., 3 Cal.3d 16, 89 Cal. Rptr. 33 (1970). See also Levin &
Sarri, Juvenile Delinquency: A Comparative Analysis of Legal
Codes in the United States (National Assessment of Juvenile
Corrections) (1974) at 26-27, for a listing of the 36 states which
provide a similar screening apparatus.

One commentator has noted: “(T]he facts underlying
several juvenile court cases indicate that the probation report is
often prepared and given to the judge prior to the [delinquency |
hearing. Consequently, it is simply a matter of time spent waiting
for the report to be considered by the judge, not a matter of
time spent in preparation.” Note, supra, 24 Stan.L.Rev. at 897.

36

our operation would really be hampered if the rule
were laid down that at the arraignment or
detention hearing or in any event before the
introduction of evidence at the adjudication the
court may set the matter for a [transfer] hearing.”
Joint Appendix at 43 (emphasis added).

The recognition that prior transfer is preferred to
transfer after a delinquency determination by the
California Supreme Court,°’ by the California College of
Trial Judges,°* and by Judge Freeman, indicates that
many California juvenile courts are using the pnor
transfer at present, and that petitioner’s vision of a
third, cumbersome hearing is unwarranted.

In addition, a prior hearing does not have to be held
in every case. In many situations, a judge can determine
without a hearing that a child should not be

*’Donald L. v. Superior Court, supra note 46.
* California Juvenile Court Deskbook, supra, § 10.4 at 148-50.

37

transferred. For example, if the child is young, and has
committed a first minor offense, most courts immedi-
ately recognize that no transfer hearing is needed.*®

Finally, even when the juvenile court considers
transfer after a hearing on delinquency, it must hold a
separate transfer hearing. If the child proves he is
amenable to rehabilitation, the juvenile judge would
then consider other dispositional alternatives. Hence, in
such a situation, as when prior transfer is required,
there is a possibility that three hearings—relating to
delinquency, transfer, and disposition—will be held. In
fact, by requiring an early decision on transfer, the
juvenile court may eliminate, rather than add,
procedures. If the juvenile is transferred, there will be
no need for a delinquency or dispositional hearing.

b. The need for judges who rule on transfer to recuse

themselves from the delinquency proceeding is negligi-
ble.

Petitioner also contends that since many of the issues
considered at a _ transfer hearing are _ potentially
prejudicial to a consideration of the juvenile’s guilt”
juvenile court judges using prior transfer will be

“On the other hand, certain juveniles, because of their
recidivism may clearly be candidates for transfer. See, e.g., Note,
supra, 24 Stan.L.Rev. at 898-99. In these situations as well, a
transfer hearing should not be a time consuming process.

The juvenile court judge’s consideration of the juvenile’s
character and background at the transfer hearing might taint his
decision on the issue of whether the juvenile has committed the
crime with which he is charged.

38

compelled to recuse themselves from the delinquency
hearing. A few jurisdictions do require the reassignment
of a judge after he has chosen not to transfer the
juvenile.”'| However, these jurisdictions also permit the
juvenile, or an interested party, to waive the transfer
judge’s dismissal. ”?

The reason for this waiver provision is clear. A
juvenile will ordinarily not want to dismiss a judge who
has refused to transfer him to a criminal court. There is
a risk of having another judge assigned to the case who
is not as sympathetic. Moreover, in many cases, a
rapport has been established between the judge and the
juvenile, and the goal of rehabilitation is well on its
way to being met. In practice, then, the dismissal of a
judge in this instance would be rare. And, of course,
recusal would not even be an issue where the judge had
transferred the child to a criminal court or where the
judge did not conduct a hearing due to the child’s
obvious amenability to rehabilitation.

But even in situations where recusal does take place,
the supply of judges in large urban jurisdictions would
negate the problem. And, smaller jurisdictions do not
have the volume of juvenile case work that would cause
the recusal situation to arise frequently. Moreover, even
if the problem were to occur, it is not unusual for

"Fla. Stat. Ann. §39.09(2\g) (1974); Tenn. Code Ann.
§ 37-234(3) (Supp. 1973); Wyo. Stat. § 14-115.38(c) (Supp.
1973). See also, Donald L. v. Superior Court, 7 Cal.3d 592, 598,
102 Cal. Rptr. 850, 853, 498 P.2d 1098, 1101 (1972); Uniform
Juvenile Court Act, supra, note 51, § 34(E).

? Id.

39

judges in sparsely populated localities to cross jurisdic-
tional lines in order to avoid a local judge’s potential
conflict of interest.

c. The bifurcation process will not be disrupted by a
prior transfer proceeding.

Petitioner contends that a prior transfer requirement
would disrupt California’s commitment to a bifurcated
juvenile hearing,”? where the delinquency issue is heard
separately from the dispositional determination. The
juvenile judge, accurding to petitioner, would make
dispositional judgments relating to the child’s back-
ground and social behavior at the transfer hearing,
which could be prejudicial if the issue of guilt must be
decided.

Of course, the California Supreme Court, which
supports bifurcation,” has also indicated a preference
for prior transfer, thereby suggesting that in its view the
two are compatible.”* Moreover, the California statu-
tory provision’ which provides for transfer contem-
plates that issues relating to transfer could be
considered with the delinquency determination since
the trial judge is given the authority to enter a transfer
order at any time during the delinquency hearing.

In re Gladys R., 1 Cal.3d 855, 589-60, 83 Cal. Rptr. 671,
674-75, 464 P.2d 127, 130-31 (1970).

™ Id.
Donald L. v. Superior Court, supra note 46.
*Cal. Welf. and Inst’ns. Code § § 707 (1972).

40

Finally, this entire issue is easily resolved by a
requirement that juvenile court judges, having passed
upon transfer, must recuse themselves from the
delinquency determination, unless the child waives his
right to the judge’s dismissal. With this resolution, the
juvenile can either opt for complete bifurcation—ie., a
new judge who would determine delinquency and then,
if necessary, consider disposition—or allow the transfer
judge with whom the child may have established a
rapport to hear the issue of delinquency.

d. The juvenile court has sufficient resources to gather all
relevant information about a juvenile at a prior transfer

hearing.

In its petition for certiorari, petitioner complained
that requiring a prior transfer would prevent the State
from “removing disruptive or depraved individuals from
its programs, [thereby ending] a promising experi-
ment.” Petition for Certiorari at 17. By this argument,
petitioner has implied that the State does not have
adequate resources at its disposal to make an informed
judgment about the character of a juvenile prior to a
hearing on delinquency, an implication that has no basis
in fact. As one state supreme court has said:

“(I]f a county attorney is causing juvenile cases
to be investigated properly ... he will know in
advance whether he desires to prosecute criminally
and he can so move the court at or before the outset
of the hearing. He has available the investigative
facilities of the probation officer, the law
enforcement officers, and the social services
staff. ...” State v. Halverson, 192 N.W.2d 765. 769
(lowa 1971).

os a

41

Moreover, petitioner himself has said that California
juvenile correctional institutions are capable of handling
the worst kind of disciplinary problems.’’ But even if
this were not the case, this amicus believes that the
doctrine of double jeopardy is flexible enough to
permit transfer after an adjudication of delinquency
where information, which could not have been
discovered at an earlier stage, clearly demonstrates that
a youth is not amenable to juvenile treatment.”

7 4 commentator, summarizing an interview with petitioner
Breed, concluded: “[Petitioner Breed] has suggested that his
organization could easily handle [disruptive juveniles who have
mistakenly not been transferred] and has concluded that the
{California Youth Authority] could abide by a system of
irrevocable [transfer] decisions made prior to the attachment of
jeopardy with absolutely no alteration in its current attitudes,
administration, or effectiveness.’ Note, supra, Stan.L.Rev. at
900.

%One major exception to the double jeopardy clause is
found in the “manifest necessity” doctrine: that is, a second
trial is allowed when an unforeseen intervening force causes the
disruption of the initial trial. See, e.g., Downum v. United States,
supra, note 8; Gori v. United States, 364 U.S. 367 (1961); Wade
v. Hunter, 336 U.S. 684 (1949); Thompson v. United States, 155
U.S. 271 (1894). The doctrine has been limited to mistrials.
However, it could be argued that if a child withheld important
evidence from the court or juvenile authorities and such evidence
clearly indicated that the youth ought to be tried as an adult, then
the juvenile court might be able to transfer the juvenile to a
criminal court. Also, if a child not transferred proved to be
unpredictably and seriously disruptive after disposition, the
juvenile court might be free, after making suitable findings, to
transfer the youth to a criminal court on the ground of “manifest
necessity.” Indeed, such a ruling is compatible with state statutes
which permit a youth correctional authority to return a child to
the juvenile court if the child is incorrigible. Cal. Welf. and Instn’s.
Code § § 707, 780, 1731.1 (1972).

42

e. Prior transfer will not lead to unfair plea bargaining.

One commentator®' has suggested that requiring the
transfer decision to be made before a determination of
delinquency will cause an unwarranted increase in a
prosecutor’s plea bargaining power. According to the
argument, if a state has a weak case against a juvenile
with a bad prior record, the prosecutor, knowing that he
will not have to prove delinquency beyond a reasonable
doubt to achieve transfer,®° will be tempted to coerce the
child into pleading guilty by threatening to seek transfer
to a criminal court. The arument continues that a juvenile
to whom such a bargain is extended, uncertain of the
case against him and frightened by the prospect of a trial
in a criminal court, will be especially vulnerable to the
prosecutor’s offer.

” Carr, supra, 6 U. Tol. L. Rev. at 49-51.

“if the transfer hearing is held prior to a hearing on
delinquency, the prosecutor, in some states, does not have to
present any evidence demonstrating that the juvenile committed
the offense with which he is charged. See Appendix, column 3,
infra. Cf. n.40 supra. However, in some states the prosecutor
must show that there is probable cause that the juvenile
committed the act with which he is charged. See, e.g., Colo.
Rev. Stat. Ann. § § 22-3-6(4)(a){c)-8(1) (Supp. 1969). A great
many jurisdictions merely require that the seriousness of the offense
be considered in transfer. See, e.g, Okla. Stat. Ann. tit. 10,
§1112(b) (Supp. 1974). However, in all jurisdictions that permit
transfer the fundamental question is whether the child can be
rehabilitated in the treatment facilities available to the juvenile
court. See, e.g., The President’s Commission on Law Enforce-
ment and Administration of Criminal Justice, Task Force Report:
Juvenile Delinquency and Youth Crime, Appendix B, Table 5, at
78 (1967).

a

43

It is the view of this amicus, however, that this
hypothetical tactic would be unethical,*' if not illegal.*?
Moreover, the opportunities for questionable plea
bargaining may be worse if transfer is not decided until
after a hearing on delinquency. At that time, a
prosecutor will have been exposed to the juvenile’s case.
Absent a strict exclusionary rule, the chances of
reconviction in a criminal court will be strong. In this
circumstance, prosecutors will be in an_ excellent
bargaining position to obtain a guilty plea *%: a
lesser-included adult offense. And, since there would
clearly be sufficient evidence to convict after a
delinquency proceeding, such bargaining may not be
illegal.

B. Allowing the Transfer Hearings To Be Held
after An Adjudication of Delinquency Is
Fundamentally Unfair to The Juvenile.

In Winship and McKeiver, this Court made it clear
that the necessity of a procedure in a juvenile court is

81 ABA Standards, The Prosecution Function §§4.1(c), 4.2
(Approved Draft 1971). A commentary to the former standard
concludes:

“Although the prosecutor is under no obligation to
reveal any evidence to defense counsel in the course of plea
discussion, truth is required in the presentation of facts
relating to the case or any mitigating facts to the defense
counsel. The prosecutor's basic duty to seek a just result as
well as his obligation to eschew the use of deception in
dealing with the evidence also forbid his misrepresenting
the law or sentencing practices of the court in plea
discussions. .. .”” /d. at commentary to § 4.1(c).
82See, e.g., Monroe v. State Bar, 55 Cal.2d 145,10 Cal. Rptr.

257, 358 P.2d 529, 533 (1961). See also, ABA Standards, The
Prosecution Function, supra, commentary to §4.2 (explaining
requirement in many jurisdictions that the prosecutor prove a
prima facie case as a condition to entry of guilty plea).

44

measured by the “fairness” it brings to the juvenile
justice process.82 As we demonstrate below, the use of
transfer after disposition is “fundamentally unfair” to
juveniles, and therefore is not needed in that process.

1. Exposure of the juvenile’s entire case to the
government, which may have the opportunity to
retry the juvenile in a criminal court, is funda-
mentally unfair.

The Council believes that the greatest injustice
emanating from the use of transfer after a disposition
of delinquency is that if the juvenile is transferred, the
Government will have had the benefit of reviewing the
juvenile’s case prior to the criminal trial. In its decision
below, the Ninth Circuit stressed this problem:

‘“‘Nowhere in our criminal system do we allow
the prosecution to review in advance the accused’s
defense and, as here, hear him testify about the
crime charged. The most heinous and despicable
criminal is saved from such an invasion of his
fundamental rights. Yet, if we adopt California’s
position, we approve having such a procedure
applied to those of tender years. This offends our
ae of basic even-handed fairness.” 497 F.2d
at 1168.

Some jurisdictions which allow the use of transfer
after a delinquency determination have exclusionary
rules which prevent evidence obtained in a juvenile

In McKeiver, Mr. Justice Blackmun stated: “[T] he applic-
able due process standard in juvenile proceedings is fundamental
fairness, as developed by [Gault] and [Winship].” 403 U.S. at
528.

+ Manas —

45

process from being used in an adult court.** For
example, California, by case law,®* urges exclusion in a
criminal court of testimony given by the defendant in
the juvenile system. However, this limited rule still
permits the prosecutor to use any evidence that has
been obtained on the basis of the juvenile’s testimony
or to use any other testimony presented with the
juvenile’s case. See, e.g., Carr, supra, 6 U. Tol. L. Rev.
at 53. Hence, California’s limited exclusionary device
does not ameliorate the unfairness a youth may
experience in this regard.

2. The use of transfer after an adjudication of a
delinquency creates an unfair dilemma for juveniles.

If juveniles must wait until they have been tried on
delinquency charges to know whether they will be
transferred to a criminal court, after detention they will
be faced with the cruel decision of whether it is more
likely that they will be transferred if they cooperate with
juvenile authorities or if they remain silent. Some
juveniles, confronting this unfair choice, may tend to be
unduly reticent because of a belief that some aspect of
their behavior or background will be sufficiently
offensive to require transfer to an adult court. Indeed,

For a complete listing of states which provide various types of
exclusionary protection to the juvenile, see Carr, supra, 6 U. Tol. L.
Rev. at 53 and nn. 298-99; Rudstein, supra, 14 Wm. and Mary L. Rev.
at 293 and nn. 118&119.

8S Bryan v. Superior Court, 7 Cal.3d 575, 587, 102 Cal. Rptr.
831. 839, 498 P.2d 1079, 1087 (1972).

46

their belief may be unrealistic, because juveniles in some
instances are more critical of their own past behavior
than are seasoned juvenile authorities. On the other hand,
juveniles may also be unduly coerced into saying more
than they would wish out of fear that undue reticence, a
possible indication of unrepentance, will lead to transfer.
In this instance, their right to be free from self-
incrimination may be jeopardized because of the
pressures the system places upon them. The Supreme
Court of California recognized the severity of this
dilemma when it said:

“The minor who is subject to the possibility of
a transfer order should not be put to the unfair
choice of being considered uncooperative by the
juvenile probation officer and juvenile court
because of his refusal to discuss his case with the
probation officer, or of having this statement used
against him in subsequent criminal proceedings.”
Bryan yv. Superior Court, supra, 7 Cal. 3d at
587-88, 102 Cal. Rptr. at 840, 498 P.2d at 1088
(1972).

It is highly unfair to expose a juvenile to this kind of
uncertainty. And to the extent that this uncertainty
leads to reticence, the fact-finding process of the
juvenile court is hindered, a process which the plurality
opinion in McKeiver clearly established should never
purposefully be impeded. 403 U.S. at 543.

In sum, a requirement of prior transfer is the only
mechanism which ensures fundamental fairness to the
juvenile. Moreover, it best serves the interests of the
juvenile court system, for in most instances. it is the
most efficient procedure for deciding the transfer issue.
and is best suited to the informal, rehabilitative nature
of juvenile courts. Therefore, this amicus maintains that

—— 7 ee ”

47

the requirement of prior transfer does not justify
withholding the double jeopardy protection from
respondent, nor has there been any other justification
advanced which would warrant such a result.

CONCLUS!ON

| For the foregoing reasons, the Council urges that the
decision below be affirmed.

Respectfully submitted,

ALFRED L. SCANLAN

I. MICHAEL GREENBERGER
734 Fifteenth Street, N.W.
Washington, D.C. 20005

Attorneys for National Council
of Juvenile Court Judges,
Amicus Curiae

Of Counsel:

SHEA & GARDNER
734 Fifteenth Street, N.W.
Washington, D.C.

January 14, 1975

(1L61 PROP) SOL PT AN TOL “WOSsaapDyy 4 211g DON,
(TLOL) ODOC PC d OOS “806 OURPI BH ‘S9QN) 4 A1DIS vg,

(€L6l) (808 RE §

yn Om SVSNV
» (6961) TL 7ETS
uUy “2PO) emo} VMOl
(€L60) Pees ic $
“uuy “IRIS “pul
“MELEL) SEL-S-1E§
‘yUY “1815 “PUT VNVKINI
(ZLOIME)
L702 § “Le “WP
“yeIg “UUY “TH SIONITIH
¢ (161 “ddng)
(®X 1 9081-91 §
apo) oyep] OHVdl
O°]
a (¢L61 “ddng) (®)z7z
“ILS § “31S “AMY
wemeH (8961)
6r ILS § “VIS
om eae IVMVH
(pi61 “ddng)
(®)10SZ7-Wez §
‘uuy ePoD “e5 viswoad
(p61)
(®X7)60 6€ §
‘uUy “I8IS “el4 vanold
(7161 “ddng)
sc6§ ‘Ol
“uy epoD ‘Pa JYVAV1ad0
yg uWINIOD ¢ uWINIO) p UUIN}O) ¢ uIUNIO) ¢ aU 1 uunjod
MOIAQI jopun UOTSI Op oun S}UNO SIP uote 7u08a)R> si . AYPRunieNy 2
oan (CLOUD LER PT'd POS Hd 21 W208,
12jSUBI} SMO]
Ajuo) (p61 “ddng)
(®)09.1 § ‘uuy
IIS Ua “UUOD
LAOLLOINNOD
(6961 ‘ddng)
(L849 eX po
‘€77 §§ ‘uuy
“JEIS “AY “OFOD
OdVAO1O)
2 (TL61) LOLS
apo) “S,uysuy
FP JPM 12D
VINNOATTVO
. (P961) P7Z-SHS
uu 121s “wT
- vos VV svsnwV
= (£461) ZI
ci yeast uv WNOZRIV
(plol)
, (@)¢ “O1g “ang
JOE eysery
(O90 OI Le §
‘yeIS eysery
VXSV IV
(RSOLIPYTS EI
"WH ‘apoy “ery
VAVEV IV
UOT EUIWI2} aq) UO! PUIUII}9Gg UO! RUIWII}9qg awl) pesiey) 0}
Aduanbutjaq 121) Aouanbutjag 121 Aduanbutjaq Bunejay pe Moly mes ea aan SOHSEPeHNY
saysueiy sasinbay JOSUBI] SyMUuag sanjyy Jaysuesy ON Sautnbay pue _—
Suuag Ajqeqoig any Aseuorsnyo
“xq PUIg sey
9 uwinjo) ¢ uwNjo) p uuiNnjo) ¢ uwNjo) Z uunjo) | uwnjoy

(1L6t “ddy 1) OW) BT POMS SOR ‘Aydsnyy 4 suv) 295 ,

(p96!)

: VH
er er

es 494 HN
(¢L61) ORO 798 VOVAAIN

IS AI APN

x VUSVUGAN

(pLol

r-] ddng) 4 | 018
wv apo.) Ay WoW VYNVLNOW

» (6961) (LO 117$

nis uy OW PaNOSSIN

(£161)

if i7-te§ wy
apo.) SIN lddISSISSIW

(pio) (D128
‘yang “uuNy V LOSANNIW

(PLol MOP ROS) :
gLiciz§ wey

mS IW NV OIKOIN

g uuInIo) 5 UMNO) p UMNO) { uunjo) c unto) 1 oo

eaewwaere«: ee a OEIC — = + emer

(PLO1) TTX PO AN GOR SSSR Coptnange a4 Uy 20g,
; (plo)
vss ul
sig “SStW (6961)
19§ ‘ell “~
SME] A. “SSE SLLASNHOVSSVAW
(¢L6l) (®)
91-02 § “9T “uF
apo) “UV “PAW GNV 1AUNVAW
(S961) (O)TL9T §
‘stm “uuy
PIS “ASY OW 4INIVW
s x VNVISINOI
Lae)

(piel “ddng) oz
BOT § “VIS “AZY

Ay *papuau sp
(ZLOU) (LOL TE ROT §
“weig “Ay AN ANJO.LNAM
UOTJEUTUII} IG UOT PUIUID}9C] UOT RUTW2}3q awit) pasiry) 07 saysueay saysuely 10lg vor psuns
Aouanbuyag 191;V AQuanburjag 121j;V Aduanbutjag Bunejay jooig MOLY ION S20q saunbay
iaysursy Sauinbay 1aySuUes] SULA jayyy saysursy ON Souinbay pur
smuuag AjQeqoig any Aseuorsny>

X¥ LUIS StH

y UU ) 4 uno) p uWNO) ¢ UUWINIO,) 7 uno) | UmryOo)

oie asian ale (8961) £06
POV Cet Tip 1adng fd Z17 WMapuriiiaodns 4 UOMUIIY Jad XO YLOIMU NH) ) 2296,

(7961) C1 1Rezt
Si$ ‘gy
wuy apo) ys

VNIIONV)
HLAOS

(£161 ‘ddng)
Livis wy sary
um) 1H (6961)

Or iris way

sary we Py CINV IS! JGOHM

. (Lol
ddng) (e)sz¢
OSS iim
wey “IS &4 VINVA TASNNGd
(LLolb ers
OIF LOS olf
RP OIPSS I
AMY Woda NOOO
y GUO ) 4 Une) > uu) , Menge) « wane) | vane»
OO ree OK pre, wu =~ oom
{Pi61 ddng) (q
clit’ ‘O1om
1S "HO VWOHY 140
(PLOL) CV iO,
Ane CHG) OHO
(pLo1) ()
PL OCLi § apoy
402.) “CN VLOYVG HLYON
(6961) ORT-VZ § VNITONV
IS U9) IN HLYON
* WHOA MAN
(fol ddng)
(UTP
“uy PIS WN OO IW MAN
(Pio! ddng)
‘Gktrr Vi uy
IS “A241 N
(TS61) Of Vig
uuy “IIS TN AASHAL MAN
Horrunusaiag wen RUMI AT UN PUNUaCy aut ) PIBsey, yon ad Bae | fOpSUPa] song uO) Upsin
Av mibunag iy A mbuyaq hny munnejay penn MONTY HON rial. | Soumb ay ™ ,
LyUeL | Soumbay 1aySUr ay Speen ONY saysuRay ON Soumnbay pur
Hug AVQRqog Ny AseuOnAD
ey Pag | "'H
9 UuNjO) § uuINjo) > UMNO) { Uuno) 7 uwnyo) | uwnyO)

a

8a

(9961) PIS ob §
uuy 2PO) FAM

9 Sunjo:)

WOT BUT Ia aq
A>uanburjaq any
J9ySUeI] Sasuinbay

9 uwNyo )

UOH RUN I1aq
Aouanbutjag saiyy
JOjSUBI] Spnuiag

§ uno) bp wiuNjo)

SIVLOL
TOS 8 ‘SILO
mr] GN
Ay popuowir sr IN TANIA)
TOs § DSN BI Va Kit
(epOrT § ViIHWi) 1040
pe) oa YI Lua LSid
(¢i61 ‘ddng)
wesiioes§
uuy IIS OAM ONIWNOAM
(riot ddng)
x1 Rb} uuy
IS STA NISNOOSIM
VINIDMIA LS4M
x NOLONIHSVM
§ vUN}O) pb uuNyO) { VunyoO) qT wun) | wunyo.)
- + ree sr Retna . et

(PLOl °A CM) Orb opr ddng 4 py, PAOMOH A SIMI] AOE .

(tio! ddng)
(MPP TOTS

Hy apo > RA VINIOMIA
x LNOWNIA
(£261) ORO!
$$ § wuy apo»
YEN) (eg Zel)
(LISOLOI-SS §
uuYy apo) YyrH) HV.L)
(£261)
(CO(ZO Ks §
apo) wes Ka] SVX4L
(pio! ‘ddng) (e)
riole § uuy
apo) ‘uual 4ASSANNAL
(pi61 ddng)
ris
Lizero7z
>. uuy SMA]
Pajidwio ) (
rs VLOYVG HLNOS
HOUPPUNUI Jaq wut ) podiey 0) joysueiy JOjSUPI] 1Olld
‘ 0O1)9
Asuanbury aq BUNIPLIY poor MOLY ION Saag sounbay —-
ny Joysueiy ON souinbay pur
SHUI AlQeqoig FINY Aseuorsny

x4 hug Sey

¢ wUINyO > 7 uwNO) | uunpo >

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385003_0122%3A07. Public record. Not legal advice.