# Amicus Brief — Quern v. Mandley > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385004_1712%3A07 ## Record - **Collection:** Supreme Court brief - **Document type:** Amicus Brief - **Published:** January 1, 1978 - **Citation:** 436 U.S. 725 ## Text — „ Supreme Court, U. & 3 JUL 25 1977 Supreme Court of the Octoszr Tanzt, 1976 Nos. 76-1159 and 76-1416 ARTHUR F. QUERN, 2 Director, ILIINOIS DEPARTMENT OF PUBLIC AID, et al., Petitioners, VENUS MANDLEY, Individually and on Behalf of All Others Similarly Si Respondents. JOSEPH A. CALIFANO, IR., SECRETARY OF HEALTH, EDUCATION AND WELFARE, v. Petitioner, VENUS MANDLEY, — Ginne 1. on Behalf of All Others ituat Respondents. On Writs of Certiorari to the United States Court of Appeals for the Seventh Circuit — . AMICUS CURIAE BRIEF OF THE STATE OF NEW JERSEY —_ Wipeeene F. A New J ttorney General of New Jersey Attorney for the State of New Jersey State House Annex Trenton, New Jersey 08625 TABLE OF CONTENTS INTEREST OF THE AMICUS — 2 Arcument—Section 406(e) of the Social Security Act does not require states participating in the program of “emergency assistance to needy fami- lies with children” to furnish assistance to all needy families with children to whatever extent is neces- sary to avoid destitution » 0 ConcLUSION 19 Baxter v. Minter, 378 F.Supp. 1213 (D. Mass. 1974) 11 Blue Chip Stamps v. Manor Drug Stores, 421 U.S. 723 (1975) 6 Burns v. Alcala, 420 U.S. 575 (1975) 14. 16, 17 Carleson v. Remillard, 406 U.S. 598 (1972 16 Dandridge v. Williams, 397 U.S. 471 (1970) 8,14 De Canas v. Bica, 424 U.S. 351 (1976 12 Goldberg v. Kelly, 397 U.S. 254 (1970) ll Gonzalez v. Young, 418 F. Supp. 566 (D.N.J. 1976) vacated and remanded, —— F.2d—— (3d Cir. July 15, 1977) 3 King v. Smith, 392 U.S. 309 (1968) 8, 15, 16 Lewis v. Martin, 397 U.S. 552 (1970) 16 Mandley v. Trainor 523 F.2d 415 (7th Cir. 1975) —.7, 13-17 ii TABLE OF CONTENTS PAGE N.Y. State Dept. of Social Services v. Dublino, 413 U.S. 405 (1973) 11-14 Ohio Bur. of Employment Services v. Hodory, 45 U.S.L.W. 4544 (May 31, 1977) oe Rosado v. Wyman, 397 U.S. 397 (1970) 8 Townsend v. Swank, 404 U.S. 282 (1971) 15-17 Williams v. Wohlgemuth, 540 F.2d 163 (3d Cir. 1976) 7, 16, 17 Wise v. Klein, Dkt. No. 76-274 (D.N.J., filed Feb- ruary 17, 1976) 3 Statutes Cited Social Security Act 2,3 Sec. 402(a) (10) 15-17 Sec. 408 4 See. 408(a) (5) 6, 9, 18, 19 Sec. 406(a) 8, 16 See. 406 (a) (1) 7 Sec. 406 (e) 4, 5, 8, 9, 11, 13-19 Sec. 406 (e) (1) — 6-8, 13 42 US.C.: See. 602(a) (10) 15 Sec. 603(a) (5) 5 See. 606(a) 8, 16 See. 606(e) 5 TABLE OF CONTENTS iii PAGE Regulations Cited 45 C. F. R.: Sec. 233. 10(a) (1) (ü) 17 Sec. 233.10 (a) (1) (i) A) 17 Sec. 233.120 (a) (1) (3) 14 N. J. A. C. 10:82-5.12 3 Other Authorities Cited Lupu, Welfare and Federalism: AFDC Eligibility Policies and the Scope of State Discretion, 57 B.U.L. Rev. (1977): 1, 22 18 S. Rep. No. 744, 90th Cong., Ist Sess. reprinted in (1967) U.S. Code Cong. & Adm. News: 2834 at 3002-3003 10, 11 — — —— Supreme Court of the United States Ocroser Term, 1976 Nos. 76-1159 and 76-1416 — ARTHUR F. QUERN, Acting Director, ILLINIOS DEPARTMENT OF PUBLIC AID, et al., Petitioners, v. VENUS MANDLEY, Individually and on Behalf of All Others Similarly Situated, _ Respondents. JOSEPH A. CALIFANO, JR., SECRETARY OF HEALTH, EDUCATION AND WELFARE, Petitioner, v. VENUS MANDLEY, Individually and on Behalf of All Others Similarly Situated, Respondents. On Writs of Certiorari to the United States Court of Appeals for the Seventh Circuit >. AMICUS CURIAE BRIEF OF THE STATE OF NEW JERSEY Interest of the Amicus The State of New Jersey is filing a separate amicus curiae brief in this matter because its outcome will un- questionably affect the State’s ability, legislatively and administratively, to fashion within reasonable fiscal limits a public assistance program providing emergency relief in a manner most responsive to public needs. The decision of the United States Court of Appeals for the Seventh Cireuit, which construed the Social Security Act to re- quire an emergency assistance program far broader in coverage than that envisioned by Congress, promises to substantially undermine the necessary flexibility a state must have to fashion such assistance programs attuned to the immediate local climate. This is particularly true with respect to the nationwide relief ordered by the court, the most immediate effect of which could be the revoca- tion by the Secretary of Health, Education and Welfare of his approval of New Jersey’s emergency assistance pro- gram and the consequent loss of federal matching funds which are so vital to the continued operation of public assistance in the State. Although New Jersey’s limited fiscal resources do not permit it to provide every desirable public assistance service, the State has nonetheless fashioned an extensive and wide-ranging welfare program. This program, of which emergency assistance is an integral part, reflects difficult choices made by the duly elected representatives of the people in terms of evaluating and balancing the complex and competing needs of the poor. The choices made by the State respecting emergency assistance grants are difficult in that, within the limits of a fixed appro- priation for that purpose, it must attempt to provide a meaningful amount of assistance to as broad a class of recipients as possible. It is precisely this dilemma, faced by regulation (N. J. A. C. 10:82-5.12) to provide meaning- ful assistance to those who find themselves facing immi- nent homelessness due to emergency circumstances. Shel- ter, food, and clothing are provided, as necessary, to people who suddenly find themselves in such a desperate situation. This emergency assistance program, however, has come under legal challenge in the courts as inconsistent with the Social Security Act. Indeed, lawsuits challenging New Jersey’s emergency assistance program, and raising issues similar to those presented in this case, are currently pend- ing in the federal courts. Gonzalez v. Young, 418 F.Supp. 566 (D.N.J. 1976) vacated and remanded, —— F.2d (3d Cir. July 15, 1977); Wise v. Klein, Dkt. No. 76-274 (D.N.J., filed February 17, 1976). As already mentioned, New Jersey’s program is also subject to possible challenge by the Secretary of Health, Education and Welfare as a result of the Seventh Cireuit’s decision in the instant matter. Thus, any decision by the Court in the present case will substantially, if not conclusively, impact on the outcome of the Gonzalez and Wise matters, future actions of the Secretary, and the validity of N. J. A. C. 10:82-5.12. An affirmance of the court of appeals’ decision may result in the imposition upon New Jersey by judicial de- has a vital interest in preserving the authority of its Legis- lature, consistent with the Social Security Act, to fashion provisions for emergency assistance which are in accord with its views of proper allocation of State resources among the competing interests of the poor. ARGUMENT Section 406(e) of the Social Security Act does not “(a) From the sums appropriated therefor, the Secretary of the Treasury shall pay to each State has an approved plan for aid and services to under the State plan during such quarter as emer- gency assistance to needy families with children” 42 US.C. § 608(a)(5). The definition of “emergency assistance to needy families with children,” for which Congress has offered 50% fed- eral funding, is set forth in § 406(e) of the Social Security Act, 42 U.S.C. § 606(e): “(e)(1) The term ‘emergency assistance to needy families with children’ means any of the following, furnished for a period not in excess of 30 days in any 12-month period, in the case of a needy child under the age of 21 who is (or, within such period as may be specified by the Secretary, has been) living with any of the relatives specified in sub- section (a)(1) of this section in a place of resi- dence maintained by one or more of such relatives as his or their own home, but only where such child is without available resources, the payments, care, or services involved are necessary to avoid destitution of such child or to provide living ar- rangements in a home for such child, and such destitution or need for living arrangements did not arise because such child or relative refused with- out good cause to accept employment or training for employment— “(A) money payments, payments in kind, or such other payments as the State agency may specify with respect to, or medical care or any other type of remedial care recognized under State law on behalf of, such child or any other member of the household in which he is living, and “(B) such services as may be specified by the Secretary ; _— —_ 9 ers with families in the State or in such part or parts thereof as the State shall designate.“ The State of New Jersey submits that this statute con- tains no mandatory eligibility eriteria binding upon all states which participate in § 406 (e) programs, but that it merely delineates the outer parameters within which federal moneys may be employed by the states to fund their individually tailored programs. “The starting point in every case involving construc- tion of a statute is the language itself.” Blue Chip Stamps v. Manor Drug Stores, 421 U.S. 723, 756 (1975) (Powell, J., concurring). The statute begins with the with children’ means any of the following... It is at once apparent that this is merely a definitional section, de- signed to be read with § 403(a)(5). Section 406(e)(1) is not in nature or tone directory since it does not man- date the performance of any act or the undertaking of any duty. The statute merely permits a term of art, “emergency assistance to needy families with children,” to be applied, for purposes of § 403(a)(5), to “any,” but not necessarily “all,” “of the following” items. “Any of the following” refers clearly to § 406(e)(1) (A): “money payments, payments in kind, or such other payments as the State agency may specify... .” Partici- pating states are thus not obligated to provide any spe- cific kinds of emergency relief but may choose, each in 7 its own discretion, the type[s] of aid to be made avail- able. This area of state diseretion has been recognized even by the decisions in Williams v. Wohlgemuth, 540 F.2d 163, 169 (3d Cir. 1976) and Mandley v. Trainor, 523 F.2d 415, 420 (7th Cir. 1975). Surely this Congres- sional delegation of discretion to the states respecting the types of assistance to be made available is evidence that Congress never intended that participating states must provide emergency assistance to avoid the destitu- tion of all individuals who, due to an emergency, are “without resources.” It makes little sense to mandate such a broad base of eligibility coverage, while at the same time permitting state discretion as to the types of aid to be made available. Under such an arrangement, it is not inconceivable that an individual “eligible” for assistance pursuant to the presumably binding criteria would nevertheless remain unaided simply because the state had not chosen to make available as part of its plan precisely the type of assistance necessary to remedy the emergent situation. Congress undoubtedly never in- tended such an anomalous result. Other than the decision as to the kinds of aid to offer, § 406(e)(1) entrusts other important elements of emer- gency assistance to state discretion. Thus, states may determine the period of time during which assistance is available (“not in excess of 30 days in ar, 12-month period”), and whether or not migrant workers are to be included. Williams v. Wohlgemuth, supra, 540 F.2d at 169; Mandley v. Trainor, supra, 523 F.2d at 420. One additional area of state discretion goes to the heart of the issue of eligibility determination. Section 406(e)(1) assistance is available “in the case of a needy child under the age of 21” living in the home of any relative specified in § 406(a)(1). It has long been settled 41 oh +f 38 a. F : 7 eurity Act.“ Dandridge v. Williams, 397 U.S. 471, 478 (1970); King v. Smith, 392 U.S. 309, 334 (1968). This Court has previously noted that the legislative history of Social Security Act makes it clear that states have 2 * * is a “needy child,” — What —7 — should be made available to such a child, and for how long a period it should be available, strongly indicates an intention to permit the states to fashion emergency assistance programs to fit their individual needs within broad federal guidelines. This conclusion is buttressed, rather than undermined, by that portion of § 406(e)(1) which must serve as the focus of the Court’s analysis. That portion provides, in essence, that “emergency assistance” means state-desig- * The term “needy child” should not be confused with the term “dependent child.” It is well settled that “dependent child” is defined by § 406(a) of the Social Security Act, 42 US. C. § 606(a), as a “needy child” who meets various conditions of eligibility for Aid to Families with Dependent Children (AFDC) set forth therein. It is equally well settled that the AFDC standard of need and level of benefits is fixed by the states. Rosado v. Wyman, 397 U.S. 397 (1970). Since the determination of who is a “needy child” is neces- sarily a function of the level of benfits and standard of need, the definition of that term is, in effect, also the product of state discretion. nated relief for a state-defined “needy child . . . but only where [1] such child is without available resources,” [2] the assistance is “necessary to avoid destitution of such child” or to provide living arrangements for ‘he child, and [3] the destitution is not attributable to a refusal, without good cause, by the child or his relative to accept employment or training. It is immediately apparent that this portion does not affirmatively direct that every indi- vidual who satisfies each of the three enumerated criteria shall be eligible for emergency assistance. To the con- trary, this portion of the statute is prefaced by words of limitation, the intent of which is not to set forth broad eligibility criteria against which the applications of indi- viduals for assistance will be measured but to delineate the conditions under which federal matching funds will be made available pursuant to § 403(a)(5) and its com- panion definitional counterpart, § 406(e). In effect, then, this portion of the statute means that § 403(a)(5) funds are available to the states, who may disburse them as emergency assistance but only where necessary to avoid the destitution of a needy child who lacks available re- sources, provided that destitution is not the result of a refusal to accept employment. The language of the stat- ute clearly indicates that the three specified conditions were intended to serve only as restraints upon the man- ner in which federal funds could be disbursed by the states. To read them otherwise, as did the court below, is to distort the clear meaning of these conditions, which are preceded by a phrase which limits the expenditure of funds rather than mandates eligibility coverage. The legislative history of § 406(e), though admittedly scanty, provides support for this construction. The Sen- ate Finance Committee report speaks of providing “flex- ible and appropriate tools to accomplish these objectives,” rather than imposing stringent standards upon the states. 10 8S. Rep. No. 744, 90th Cong., Ist Sess. reprinted in [1967 U.S. Code Cong. d Adm. News 2834 at 3002. In describ- in the class of recipients for whom emergency assistance was designed, the report states: “The eligible families involved are those with chil- dren under 21 who either are, or have recently been, living with close relatives. The families do not have to be receiving, or eligible upon applica- tion to receive, AFDC (although they are generally of the same type), but they must be without any available resources and the payment or service must be necessary in order to meet an immediate need that would not otherwise be met.” Id. at 3003. Interestingly enough, the report, like the statute, em- words of limitation to describe the conditions under federal funds may be made available. Had Con- gress intended to provide a definition of eligibility, it is more likely that the report would have stated, in direct terms, that “All individuals lacking available resources must be eligible.” When the report and statute are con- sidered together, and in context, it is far from clear that Congress ever attempted to define the class of benefi- ciaries of emergency assistance. Cf. Ohio Bur. of Em- ployment Services v. Hodory, 4 U.S. L. W. 4544, 4547 (May, 31, 1977). If indeed. Congress intended § 406(e) to serve as a mandatory eligibility standard binding upon the states, it did so by employing extraordinarily vague terms which are unwieldy in practice. Terms such as “to avoid des- titution” are so very general that, as specific criteria purportedly binding the states, they fail on account of imprecision and indefiniteness. As the Court has noted, 11 all welfare recipients are by hypothesis “destitute,” Gold- berg v. Kelly, 397 U.S. 254, 261 (1970), and the general purpose of every public assistance program is “to avoid destitution.” Oongress’ use of this term in § 406(a) strongly suggests that it intended to permit the states to play the major role in designing eligibility eriteria.“ For if “to avoid destitution” is viewed as a Congression- ally-designed eligibility standard, that standard is essen- tially meaningless and its utilization for that purpose would transform emergency assistance into an open-ended program by which anyone who mismanages his income or public assistance grant would be assured of further, supplementary assistance. This is a far ery from the announced Congressional desire to provide assistance to counteract the effects of bona fide emergencies which give rise to evictions, utility termination or lack of food. S. Rep. No. 744, 90th Cong., Ist Sess., reprinted in [1967] U.S. Code Cong. d Adm. News 2834 at 3002. In N.Y. State Dept. of Social Services v. Dublino, 413 US. 405 (1973), the Court was presented with the issue of whether the Work Incentive Program of the Social Security Act, which requires that certain employable pub- lie assistance recipients must register for employment, preempts work rules adopted by the State of New York. The plaintiffs contended that the State rules were more * This reasoning has been adopted by at least one federal court. In Baxter v. Minter, 378 F.Supp. 1213 (D. Mass. 1974), it was concluded that : “The terms ‘needy’ and ‘destitution’ were not defined by Congress and no explicit statutory standard is available for guidance. A court can infer, therefore, that Congress used general terms in the statute when describing the poverty line of eligibility because it intended the states to supply their own precise standards of need.” 378 F. Supp. at 1218. a Sn 12 stringent than the federal statute and that since the lat- “This Court has repeatedly refused to void state statutory programs, absent congressional intent to preempt them. “If Congress is authorized to act in a field, it should manifest its intention clearly. It will not be presumed that a federal statute was intended to supersede the exercise of the power of the state unless there is a clear manifestation of intention to do so. The exercise of federal supremacy is not lightly to be presumed.” 413 U.S. at 413. See De Canas v. Bica, 424 U.S. 351 (1976). The Court decided that this principle had direct application to fed- eral-state public assistance programs, such as Aid to Fam- ilies with Dependent Children (AFDC), especially in light of the acknowledged fact that states: . . . have considerable latitude in allocating their AFDC resources, since each State is free to set its own standard of need and to determine the level of benefits by the amount of funds it devotes to the „ N.Y. State Dept. of Social Services v. Dublino, supra, 413 U.S. at 414. — the Dublino Court held that: . If Congress had intended to preempt state „ r of the AFDC program as employment referrals for those on assistance, such intentions would in all likelihood have been expressed in direct and 13 unambiguous language. No such expression exists, however, either in the federal statute or in the com- mittee reports.” Id. (emphasis added). Similarly, had Congress intended to preempt the field of emergency assistance by foreclosing a state role in de- termining the eligibility standard, it should have clearly manifested its intention in “direct and unambiguous lan- guage,” and should just as succinctly have defined both the federal standard as well as the permissible areas of discretion reserved to the states. Like the Work Incen- tive Program, however, “no such expression exists” in § 406(e)(1) “except in the most peripheral way.” 413 U.S. at 417. Indeed, the Seventh Cireuit's opinion in Mandley v. Trainor, 523 F.2d 415 (7th Cir. 1975) unwit- ingly supports this conclusion. Even though that court held that Congress provided obligatory eligibility eri- teria in § 406(e)(1), it admitted that the standards set forth were “somewhat amorphous” and intapable of pre- cise definition. 523 F.2d at 422-423. The court, however, conveniently skirted this deficiency be declaring that “This court need not establish the exact meaning of the eligi- bility provision of Section 606(e) because this case re- quires only that the validity of the specifie Illinois pro- gram be determined.” 523 F.2d at 422. It is submitted, in response, that the Seventh Circuit refused to delineate the eligibility criteria which it “found” in § 406(e) be- cause given its vague and general terms, it is incredibly difficult, if not impossible, to do so with any degree of precision. When the vague “avoidance of destitution” term of § 406(e) is combined with the fact of state dis- cretion in defining “needy child” as well as the lack of an explicit statement indicating Congress’ intent to pre- empt this area by restricting the states’ role in fashion- ing eligibility standards, it becomes clear that Congress 14 never planned to impose an eligibility standard upon the states, but that this area was to be reserved to state discretion exercisable within broadly structured guide- lines. Had this been recognized by the Seventh Circuit that not have been faced with the dilemma statutory standard which it could not define. The Mandley court’s abdication (523 F.2d at 423) to the Secretary of Health, Education and Welfare of the responsibility for deciphering the eligibility standard of § 406(e) ignores the fact that the Secretary has, since 1969, consistently taken the position that states have the S, v “specify the emergency needs” which state plans will meet. 45 C.F.R. § 233.120(a)(1), (3). It need hardly be pointed out that the Secretary’s construction of this statute should be followed unless there are compelling indica- tions that it is wrong. N.Y. State Dept. of Social Services v. Dublino, supra, 413 U.S. at 421 (1973); Dan- dridge v. Williams, supra, 397 U.S. at 481-482 (1970). After Burns v. Alcala, 420 U.S. 575 (1975), it is clear that no special rule of construction exists by which Social r unless the Act or its legislative history clearly ex- hibits an intent to exclude them from coverage, in effect creating a presumption of coverage when the statute is ambiguous.” 420 U.S. at 580. Recognizing that such a rule represented a “departure from ordinary principles of statutory interpretation” un- 15 supported by its prior decisions, the Court declared that proper analysis should proceed according to the follow- ing principle: Once the federal standard of eligibility is de- fined, a participating State may not deny aid to persons who come within it in the absence of a clear indication that Congress meant the coverage to be optional. The method of analysis used to define the federal standard of eligibility is no dif- ferent from that used in solving any other problem of statutory construction.” Jd. (emphasis added). Thus, a necessary first step in eligibility analysis is to isolate and define the standard of eligibility. It may not merely be presumed that an eligibility standard exists, and then further presumed that an individual is eligibile absent any language indicating exclusion. The Mandley court’s analysis failed to follow these principles, because it nowhere defined the federal eligibility standard. Until such a definition is presented, courts which compare state emergency assistance plans against § 406(e) for the pur- pose of isolating possible conflicts are merely indulging in question-begging exercises. To date, neither Congress nor the courts have yet “defined” the elusive standard of § 406(e). The Mandley court's holding (523 F.2d at 422) was bottomed on the Court’s decisions in the line of cases which includes King v. Smith, supra, 392 U.S. 309, and Townsend v. Swank, 404 U.S. 282 (1971), each of which hold that, by virtue of § 402(a)(10) of the Act, 42 U.S.C. § 602(a)(10), federal participation in state AFDC pro- grams is conditional on the state’s offering benefits to all persons who are eligible under federal standards. Thus, all individuals who meet the federal definition of “de- 16 pendent child,” § 406(a) of the Act, 42 U.S.C. § 606(a), ae ens Cet cate aie Guan an Ae granted AFDC benefits according to § 402(a) (10). See Burns v. Alcala, 420 U.S. 575, 578 (1975). For instance, when Alabama attempted to deny AFDC assistance by ex- panding the definition of “parent” to include any male living in the household, King v. Smith, supra, and when California broadened the concept of “parent” to include a “male assuming the role of a spouse,” Lewis v. Martin, 397 U.S. 552 (1970), the Court had little diffieulty in strik- ing them down. Likewise, it struck down an Illinois regulation denying AFDC to otherwise eligible students who attended college, Townsend v. Swank, supra, and similarly disapproved of the California policy which spe- cified that a father absent from the home on account of military service was not “continuously absent” for the purpose of f 406(a). Carleson v. Remillard, 406 U.S. definition and funding provisions are entirely separate from those of AF DC—bhe paid to all eligible individuals.“ Ww . Wohlgemuth, supra, 540 F.2d at 169. Thus, ! Fe : : | 5 8 “Such a broad-based eligibility standard does not appear to have been imposed upon the states ex- pressly by the statutory amendments creating the 17 For similar reasons, the so-called Townsend regulation, 45 C.F.R. 5 233.10(a)(1)(ii), which is merely the HEW codification of the holding in Townsend v. Swank, is also inapplicable to the instant case. This regulation, relied upon in both Mandley (523 F.2d at 421) and Williams v. Wohlgemuth, supra, 540 F. Ad at 170, provides: (u) A State may: (A) Provide more limited public assistance coverage than that provided by the Act only where the Social Security Act or its legislative history authorized more limited coverage;” 45 C.F.R. § 233.10(a)(1)(ii)(A). It is submitted that the Burns principle is just as ap- plicable to this regulation as it is to the Townsend hold- ing. Thus, before a state may limit “coverage,” it must be determined that the federal statute, in the first instance, does indeed provide coverage through a defined eligibility standard. Again, no such standard has yet been defined or identified because none exists. Aside from the fact that § 402(a)(10) is unrelated to § 406(e), there is an even more basic reason why the King-Townsend holdings should not be extended to the area of emergency assistance. The King-Townsend cases recognize that the state fiscal resources appropriated for public assistance are finite and that whether those limited resources will provide effective assistance to needy people is a function of both the breadth of the class of eligible recipients, as well as the existing standard of need and level of benefits paid. In allocating their limited funds to expanding caseloads, the states, as a result of these holdings, are precluded from reducing the number of families eligible for assistance. Thus, adjustment of the standard of need and level of benefits paid is the only 19 i 7441 i 15 b og i dog %% 1 111 2] : AE j 2 = RE 11 ah 11 11271 41 al} 15 2948 : 171 144 388 IE 3 He tk lps aida: 8111 2215 M Hd: paige? 121 thy ; Ht 111 12 rt ‘i 110 19 An i l Hil] © 4 0 Glu 124 HE BHARATI N 1 ; 1271 ei 11 111 ift Gti t 10 --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385004_1712%3A07. Public record. Not legal advice.