# Petition — Waterhouse v. Florida (No. 83-5567) > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385011_1692%3A1 ## Record - **Collection:** Supreme Court brief - **Document type:** Petition - **Published:** January 1, 1983 ## Text 895567 IN THE Supreme Court, U.S. SUPREME COURT OF THE UNITED STATE FILED October Term, 1982 JUL 26 1983 Alexander L. Stevas, Clerk ee a ROBERT BRIAN WATERHOUSE, Petitioner, Vv. STATE OF FLORIDA, Respondent. PETITION FOR A WRIT OF CERTIORARI TO THE SUPREME COURT OF FLORIDA JAMES C. McKAY* JOHN H. MORE 1201 Pennsylvania Avenue, N.W. Post Office Box 7566 Washington, D.C. 20044 (202) 662-6000 Attorneys For Petitioner Of Counsel: COVINGTON & BURLING 1201 Pennsylvania Avenue, N.W. Post Office Box 7566 Washington, D.C. 20044 *Attorney of Record July, 1983 QUESTIONS PRESENTED 1. Whether petitioner's pre-trial statements to police officers were obtained in violation of his right to counsel under the Fifth and Fourteenth Amendments to the United States Constitution, after petitioner had requested counsel and particularly after counsel had been appointed? 2. Whether petitioner's pre-trial statements made after counsel had been appointed to police officers who knowingly failed to advise petitioner's attorney that they were interrogating petitioner? 3. Whether petitioner's pre-trial statements to police officers and tangible evidence taken from petitioner's automobile were obtained in violation of his rights under the Fourth and Fourteenth Amendments to the U.S. Constitution, when they were the result of an illegal arrest or detention by the police without probable cause? 4. Whether tangible evidence taken from peti- tioner's automobile pursuant to a search warrant were ob- tained by police officers a result of an illegal seizure of the car without probable cause prior to the issuance of the search warrant, thereby violating petitioner's rights under the Fourth and Fourteenth Amendments to the U.S. Constitution? TABLE OF CONTENTS TABLE OF AUTHORITIES “rseeeveeveeervreeeeveeeveeeeeeeeneee eee eee OPINIONS BELOW eeseeeeaooeeoeoeaes eceoeeeneeeeee0e20¢080 oe ee ee JURISDICTION eee eeweevreee eee eeeeeeeeeer eee ereereerr ree ee CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED STATEMENT OF THE CASE ...ccccccccccccccosescsese eccece Ri Introduction oeereinereeneeneneeenee vee ee sneer @eee#eee#es: 7, 2. Motions to SuppresSS .......2e06. cocccccecoes 3- TRE TELA] cccccccsecesecssscvccccssceccccce 4. The SeEnt@NGing TEAEL cccicccccccctecccccccce REASONS FOR GRANTING THE WRIT ....e0ee0ee000% eoccccce I. PETITIONER'S PRE-TRIAL STATEMENTS TO THE POLICE WERE OBTAINED IN VIOLATION OF PETITIONER'S RIGHT TO COUNSEL UNDER THE FIFTH AND FOURTEENTH AMENDMENTS TO THE UNITED STATES CONSTITUTION ....ccccecccecveces If. PETITIONER'S PRE-TRIAL STATEMENTS TO THE POLICE WHO FAILED TO ADVISE PRE- VIOUSLY APPOINTED COUNSEL OF THE IN- TERROGATION WERE OBTAINED IN VIOLATION OF PETITIONER'S RIGHT TO COUNSEL UNDER THE FIFTH AND FOURTEENTH AMENDMENTS TO THE UNITED STATES CONSTITUTION ......--22eee000- III. PETITIONER'S PRE-TRIAL STATEMENTS TO THE POLICE EVIDENCE TAKEN FROM HIS CAR WERE OBTAINED AS THE RESULT OF AN ARREST OR DETENTION WITHOUT PROBABLE CAUSE IN VIOLATION OF THE FOURTH AND FOURTEENTH AMENDMENTS TO THE UNITED STATES CONSTITUTION .ccccccccccccccccccccccccccccccce IV. TANGIBLE OBJECTS TAKEN FROM PETITIONER'S CAR WERE OBTAINED AS THE RESULT OF AN ILLEGAL SEIZURE OF THE CAR WITHOUT PROBABLE CAUSE IN VIOLATION OF THE FOURTH AND FOURTEENTH AMENDMENTS TO THE UNITED STATES CONSTITUTION ....ccccccccccsccscccceces CONCLUSION seer eee ereeeevreeeeeeeeeeen eee eeeeeeeeeeeeeere 18 20 21 31 34 38 40 - iii - Page APPENDICES A. Opinion of the Supreme Court of Florida ee eereeeeeeeeeneeneneneneeeeneee la B. Judgment, Orders and Sentencing Determination “ese ee eeeeneeeneneeneeneeeneeneeeeee lb C. Denial of Rehearing by Supreme Court of Plorida ee eeneweeneeeneneeneneneeneneeeeesee le TABLE OF AUTHORITIES Page A. Cases Aguilar v. Texas, 378 U.S. 108 (1964) ............ 37 cree enied 4310.5. 925 (1977) erro econ ee 38, 32 Brookhart v. Janis, 384 U.S. 1 (1965) ...... ecccee 28 Chambers v. Maroney, 399 U.S. 42 (1970) ......eee. 38 Clewis v. Texas, 386 U.S. 707 (1967) ...cccccccces 37 Dunaway v. New York, 42 U.S. 200 (1979) .......... 36 Edwards v. Arizona, 451 U.S. 477 (1981) .......... passim Escobedo v. Illinois, 378 U.S. 478 (1964) ........ 32 Fare v. Michael C., 442 U.S. 707 (1979) ....ceeee. 21 Fields v. Wyrick, 682 P.2d 154 (8th Cir. 1982) nenereereereeeeeeee ne ereineweeeees #¢£f# © *# © © © ne feeee 25, 29 Florida v. Royer, 51 U.S.L.W. 4293 (U.S. March 23, 1983) (No. 8l- 2146) ef eweeeeeeree * enrineneneeneneene eneenene © eee © @ *-* 36 Glasser v. United States, 315 U.S. 60 (1941) o@e@eeeoeeeed @ © ef ee eewee ere ereeeeeneeeeeeee 28 Johnson v. Zerbst, 304 U.S. 458 (1938) .......22e. 28, 32 Maglio v. Jago, 580 F.2d 202 (6th Cir. 978) ef eweneweee eeeee ne fe feweweeeeneereereneeeneee#eee#eee#ee 22 Massiah v. State, 377 U.S. 201 (1964) ....cccceees 32 McCree v. Housewright, 689 F.2d 797 (8th Cis. 1982) eee ete eweeeneeneneneneeneneneneneeeee ere eee 25. 26, 28 Miranda v. Arizona, 384 U.S. 436 (1966) ee ef eeeeeeneneneneneeneneneneeeneeee ec ermhlUc mC rmhUcr CC PT ee emcee passim Nash v. Estelle, 597 F.2d 513 (5th Cir.), cert. denied, 444 U.S. 981 (1979) ee eeeneeneneneeeeneeeeneeeneneeeneeeeeneeeee 24 Oregon v. Bradshaw, 51 U.S.L.W. 4940 (No. 81-1857) (U.S. June 23, 1983) re fe ee eeeneneeneeeneeeneneeneeneeeneeeeeeeeeeeeee 25, 27 « 28 Payne v. State, 424 So.2d 722 (Ala. Crim, App. 1982) eee eereeeeneneneneneeneeneneeneeeeeeee 26 People v. Thomas, 98 Ill. App. 3d 852, 24 N.E.2a 985 (1982) eee eee eeeereeeeeneeeeeee 26 Sanders v. State, 378 So.2d 880 (Fla. Se Oise. Ce. 1908) ccocceces eer re TT Tr TT Tree State v. Brezee, 66 Haw. 162, 657 P.2d 1044 (1983) ne © ff © © e*eneeneeneenseetieineieneee ee ee eee ee eee * State v. Royer, 389 So.2d 1007 (Pla. ABP. 1980) ccccvcccccccccccccccescccsces Stumes v. Solem, 671 F.2d 1150 (8th Cir. 1982), cert. granted 51 U.S.L.W. 3938 (july - 1983) ie, GROREON) - sccacnsees leave sut sis sar was i2pcunded ‘or S@arcaisg sursuansc 323 Fights, Ficcheox asxed iim, “Se were right ecple anc sot as sclice cfficers. Ze =nen said “Bat se Sad some perscnal sroblems wich alconcl, sex, and 7.Cclence. The swo detectives interscgated appellanc again sn Januar’ 9. Again appellanc said se wanted => talk =o them as pecple ratner =nan as police officers. the victin'’s scat were similar = fibers from =he fabric of aave a Sangcver and said te was ‘seling cough. The witness said That at “his cise appellant cad icratcnes sm 2:3 face. The Wismess alsc said chat appellant nad =:al Sours erred -2 resented =re arxec cn ¢ appellant's car sendics issuance :/ «ie wartant Isr 03 se@arcnh was proper, sased om srccasle cause and @xigent circumstances. Carzoll 7. Tnited States, 267 7.$. 122 .2928). Appellant contends = some sags 2/ cari:uana “nat vers found sy tne cfficers +nc searcned and collected evicence ‘sce appellant's car. This testiaony constituted eviience sendiag provice the context ic which the statement «as tace. The Tul-ng was 10t error. Be come scw Left four finsers Teft ~ RASr.t Right four fingers i sy e * 4 kL. : Thunb Thumh + + "* - . > att... ® “ os 4 a ae a > ™ ay gee: ABs = “7 ve > : « Mes ‘ 3 =~ S SS Z od ; Ty & “reg! ¥: “ % *e ei. 2 A = Y a - ay a y 2. SS 3 z #3 -4 2: «2% e--. % . oe By < (Bot - eee ee 4 - =~ —_ —- tA" 3 “ on -_ Pet 5 a =. = pa + ie anal Pd es Fr’. I ane certify that the above ard foregoi: ¢ firgerpri:.ts or this ae Judgment are the firgerprints of the defendant, ROBERT BRIAN WATERHOUSE » and that they were p reon by sa defe.da:t ir my presence, ir oper. court, this the 3rd day of September —.» 62... ort reult Court ; IN THE CIRCULT COURT FOR PINELLAS COUNTY, FLORIDA CRIMINAL DIVISION CIRCUIT CRIMINAL NO. 80-192 STATE OF FLORIDA ) : vs. MURDER IN THE FIRST DEGREE ROBERT BRIAN WATERHOUSE 5g +/4(, ; FILED ORDER SEP 15 i989 THIS CAUSE came on to be heard on the sen ete eur: fos ~——~ Depaty Clerk Defendant, ROBERT BRIAN WATERHOUSE, foll Grit the conviction 6 Murder in the First Degree and an advisory verdict recommending the death penalty by a jury of twelve of his peers and the Court having heard the case in chief and considered the mitigating and aggravating circumstances, makes the following Findings of Facts and Orders: AGGRAVATING CIRCUMSTANCES A. The Defendant, ROBERT BRIAN WATERHOUSE, was previously convicted in New York of the felony of Murder in the Second Degree. The Defendant was sentenced to twenty (20) years to life for the commission of that crime but was paroled after serving approximately eight (8) years in the New York prison system. At the time of the commission of the present homicide, ROBERT BRIAN WATERHOUSE was on lifetime parole from New York. B. At the time of the commission of the present homicide, - ROBERT BRIAN WATERHOUSE was previously convicted of the said New York felony involving the use or threat of violence to the victim of the said New York homicide. C. The Murder in the present case was committed by ROBERT BRIAN WATERHOUSE while ROBERT BRIAN WATERHOUSE was engaged in the commission of a Rape, also known as an Involuntary Sexual Battery, a life felony, upon the victim. D. The Murder in the present case was committed for the purpose of avoiding or preventing a lawful arrest in that the victim _in the instant case was killed in order to eliminate her as a witness Po ieetaees wo ¢ E. The Murder was committed by ROBERT BRIAN WATERHOUSE in an extremely wicked, outrageous, shocking, evil, and vile manner, and in a way designed to inflict 4 high degree of pain upon the victin with utter indifference to the suffering of the victim, and, therefore, was especially heinous, atrocious, and cruel. MITIGATING CIRCUMSTANCES A. None. THEREFORE, it is the order of this Court that the Defendant, ROBERT BRIAN WATERHOUSE, be sentenced to death in the electric chair. DONE AND ORDERED in Chambers at St. Petersburg, Pinellas County, Florida, this JL d— day of September, -1980. HLL A. ual CIRCUIT JUDGE Copies furnished to: JACK HELINGER and ROBERT MERKLE, State Attorney's Office, 150 - Fifth Street North, St. Petersburg, Florida; PAUL SCHERER and JOHN WHITE, Attorneys for the Defendant, 2901 - First Avenue North, St. Petersburg, Florida. : ROBERT SRIAN WATERHOUSE, Appellant, vs. STATE OF FLORIDA, Appellee. On consideration of the attorney for appellant, IT IS ORDERED by the Court that said same is hereby denied. ALDERMAN, C. ADKINS, BOYD, MCDONALD, -, Dissencs A True Copy TEST: == Sid IT White Clerk Susreme Court IN THE SUPREME COURT OF FLORIDA WEDNESDAY, APRIL 27, 1983 Appendix C :* ads CASE NO. 59,765 ee Circuit Court Case No. 80-1325 (Pinellas) 2? 22 Petition for and OVERTON, JJ., Cc cc: Hon. Karleen Hon. Philip J. Padovano, rehearing filed by petition be and the Concur °. DeBlaker, Clerk Robert E. Beach, Chief Judge Esquire Mr. Robert Brian Waterhouse Peggy Quince, Esquire . - No. IN THE SUPREME COURT OF THE UNITED STATES OCTOBER TERM, 1982 ROBERT BRIAN WATERHOUSE, Petitioner, v. STATE OF FLORIDA, Respondent. AFFIDAVIT OF SERVICE DISTRICT OF COLUMBIA: ss: The undersigned, John H. More, being duly sworn, hereby deposes and states on his oath that on this 26th day of July, 1983, he has served one copy each of Petitioner's Petition for Writ of Certiorari to the Supreme Court of Florida and Motion to Proceed in Forma Pauperis with attach- ments, by first-class mail, postage prepaid, upon the Honorable Jim Smith, Attorney General of the State of Plorida, The Capitol, Tallahassee, Florida 32304. All parties required to be served by me have been served. MM Lf [Myre OVINGTON & BURLING R20] Pennsylvania Avenue, N.W. Post Office Box 7566 Washington, D.C. 20044 (202) 662-6000 Subscribed and sworn to before me this 26th day of July, 1983. IN THE SUPREME COURT OF THE UNITED STATES October Term, 1983 ROBERT BRIAN WATERHOUSE, Petitioner, v. STATE OF FLORIDA Respondent. MOTION TO PROCEED IN FORMA PAUPERIS The petitioner, Robert Brian Waterhouse, who is now held in the Florida State Prison at Starke, Florida, asks leave to file the attached Petition for a Writ of Certiorari to the Supreme Court of Florida without pre- payment of costs and to proceed in forma pauperis pursuant to Rule 46. 28 U.S.C. § 1915(a); Adkins v. Du Pont Co., 335 U.S. 331 (1948). Attached hereto are copies of an Affidavit of Insolvency, Orders of Insolvency, and Appointing Attorney filed for petitioner in the Circuit Court for Pinellas County, Florida. Attached also is a copy of an affidavit in the hands of petitioner who presently is incarcerated in the State of Florida. I will file the affidavit when it has been executed and delivered to me. The firm of Covington & Burling has taken this case on a pro bono publico basis. c. M« Kan, att J C. MCKAY JI (Gounsel) OHN H. MORE Covington & Burling 1201 Pennsylvania Avenue, N.W. P.O. Box 7566 Washington, D.C. 20044 (202) 662-6000 Attorneys for Petitioner July 26, 1983 —<_. fadtet 5. CatnArwa 0 ee tout JOKWS Zee os COUNTY COURT, PINELLAS COUNTY, FLORIDA CRIMINAL DIVISION CASE NO. FO 20/9 Ch PSe STATE OF FLORIDA FILE D JAN 10 1980 AFFIDAVIT OF INSOLVENCY Affiant being first duly sworn on oath deposes and says that he is totally insolvent and utterly unable to pay the charges, costs or fees in this cause either in whole or in part; that he has no property or other means of payment either in his possession or under his control and that he has not divested himself of any property, either real or personal, for the purpose of receiving benefit from his oath; that he, at this time, is wholly without funds and unless this Court makes and enters an Order adjudging hia, this defendant, insolvent, he will be deprived of his rights under the law in such cases made and provided. This affiant offers himself up to the Court for the purpose of further examination into his insolvency. : Affiant further says that he has been informed that a lien for the value of the services rendered him by the Public Defender, and/or his costs of defense may be impressed by law on any property he now has, or may hereafter have, in the State of Florida, and he hereby waives notice of any proceedings at which the value of the services of the Public Defender and/or costs of defense, as aforesaid, may be determined, and further waives any notice of the filing of the aforesaid lien. QRDER OF INSOLVENCY AND APPOINTMENT OF PUBLIC DEFENDER The above named Defendant, being before the Court and the said Defendant having filed in this Court his Affidavit of Insolvency; and testimony having been taken before the Court; and the Court being otherwise fully advised in the premises, it is, thereupon ORDERED AND ADJUDGED that the Defendant be, and he is hereby, declared to be insolvent within the meaning of Sec. 27.52 FLORIDA STATUTES; and it is further ORDERED AND ADJUOGED that the Office cf the Public Defender for the Sixth Judicial Circuit, in and for Pinellas County, Florida, is hereby appointed to represent said Defendant in the above styled cause. IT IS FURTHER ORDERED that in the event the defendant, or his parents, is ordered to pay for the costs of the Public Defender's services, then the Public Defender shall, within 30 days of the final determination of this cause, submit a Motion to this Court to Establish the Value of the Services of the Public Defender. If the Court has also ordered the defendant to pay for the costs of defense, then the Public Defender shall, within 30 days of final deter- mination of this cause, submit an Itemized Statement of Costs of Defense, such lists be obtained from the Clerk's Office of the Board of County Commissioners. aay re yoa0eren this day of __ MN 7 at Re at OB , Florida. 225 1 a oS . + oe me mre mtg : ss IN THE CRCUIT COURT FOR PINELLAS COUNTY, FLORIDA CASE NO, CRC8000192CFASO FILED STATE OF FLORIDA OCT 8 3980 ~ ae Che —_ SID J. WHITE ROBERT BRIAN WATERHOUSE ey . SUPREME COURT ° 50456 “~at Ommaney Chart The following was done in open court this 4th day of September , 19 80. IT IS CONSIDERED AND ORDERED THAT THE COURT HEREBY APPOINTS ATTORNEY PHILLIP PADAVANO TO REPRESENT THE DEFENDANT IN THE ABOVE CAUSE FOR PURPOSES OF APPEAL. naa Cia ne sl F l L E D Beda) sera agen 5 SEP 10 965 WITNESS, ws bared aol Us. “atisd. Seal, Usis HAROLD g dy o?. a ae D., 3° | = Pcount me, < is — ms ied epaty Lad Dated this 4th day of September , 19 80 , in St. Petersburg, Florida. No. IN THE SUPREME COURT OF THE UNITED STATES October Term, 1982 ROBERT BRIAN WATERHOUSE, Petitioner Vv. STATE OF FLORIDA, Respondent AFFIDAVIT I, Robert Brian Waterhouse, being first duly sworn according to law, depose and say, in support of any motion for leave to proceed without being required to prepay costs or fees: (1) I am the petitioner in the above-titled case. (2) Because of my poverty I am unable to pay the costs of my petition. (3) I am unable to give security for the same. (4) I believe that I am entitled to the redress I seek in said case. (5) The nature of the case is briefly stated as follows: I was sentenced to death by the Circuit Court of Pinellas County, Florida, on a first degree murder charge. The present proceeding was commenced to reverse my conviction and sentence on constitutional grounds. Robert Brian Waterhouse Duly witnessed and sworn before me, a Notary Public, this day of June, 1983. Notary Public No. A-1008 IN THE SUPREME COURT OF THE UNITED STATES October Term, 1982 ROBERT B. WATERHOUSE, Petitioner, v. STATE OF FLORIDA, Respondent. On Writ of Certiorari to the Supreme Court of the State of Florida ‘ APPLICATION FOR EXTENSION OF TIME IN WHICH TO PILE PETITION FOR WRIT OF CERTIORARI AND PERMISSION TO FILE A SUBSTITUTE PETITION To the Honorable Lewis F. Powell, Jr., Associate Justice of the United States and Circuit Justice for the Eleventh Circuit: Petitioner Robert B. Waterhouse prays that an order be entered further extending the time for filing a petition for writ of certiorari to and including August 25, 1983. This application is being submitted together with a Petition for a Writ of Certiorari in order to preserve petitioner's constitutional issues. The reasons for this extraordinary request are set forth below at p. 3. The relevant dates for this application for extension are: April 27, 1983: Petition for rehearing denied by the Supreme Court of Florida. June 27, 1983 (June 26 is a Sunday): Expiration of time for filing petition for writ of certiorari in this Court, unless extended. July 26, 1983: © Expiration of requested 30-day extension of time for filing a petition in this Court. July 26, 1983: Time for filing per Order Ex- tending Time to File Petition for Writ of Certiorari, dated June 17, 1983, by Justice Lewis PF. Powell, Jr. No opinion was rendered by the Supreme Court of Plorida in the course of denying the petition for rehearing. The pertinent nature of the petitioner's case is as follows: 1. Petitioner was sentenced to death in 1980 in the Circuit Court for Pinellas County, Florida, after a trial and sentencing hearing before a jury. 2. On February 17, 1983, the Supreme Court of Plorida in a per curiam opinion affirmed the conviction of murder in the first degree and sentence of death, overruling Petitioner's constitutional contentions that (a) his state- ments should have been excluded from evidence on the grounds that (i) they were obtained as the result of an illegal ar- rest or detention, (ii) they were obtained after he had ex- pressed his intention to remain silent, (iii) his final statement was obtained in an interview conducted without notice to his court-appointed attorney, and (iv) there was no showing that the statements were made voluntarily; (b) tangible evidence seized from his car should have been excluded on the grounds that the evidence was obtained as the result of an illegal arrest or detention and of a search made without probable cause or search warrant; (c) evidence of Petitioner's alleged use of marijuana and an alleged homosexual rape attempt should have been excluded on grounds of lack of relevance; (d) the evidence was insufficient to support a finding that a capital felony had been committed by Petitioner for the purpose of avoiding or preventing a lawful arrest or a finding that the capital felony was par- ticularly heinous, atrocious, and cruel; (e) the trial judge erred in basing two of the aggravating circumstances on a single prior act of Petitioner; and (f) involuntary sexual battery was an essential element of the homicide and, as such, could be used as an aggravating circumstance. This Court's jurisdiction under 28 U.S.C. § 1257(3) will be invoked. This extension of time and permission to substi- tute a final Petition is requested since (1) the undersigned were ordered by the petitioner, Robert B. Waterhouse, today by telephone not to file the Petition for a Writ of Certio- rari, which accompanies this Application, on the grounds that he has not reviewed and approved the final version of the Petition to be filed; (2) petitioner wishes to have an extension of time to be able to review the final version before it is filed; (3) petitioner has refused to sign an affidavit for the Motion to Proceed in Forma Pauperis until he has reviewed the draft and approved its filing, (4) petitioner indicates that he will write the Supreme Court to have the Petition withdrawn if he does not receive the op- portunity to review and approve; and (5) the gravity of the death penalty warrants the provision of sufficient extra time to enable petitioner to review the Petition and suggest any reasonable changes. Extension of the time for filing to August 25, 1983, would provide enough time to accomplish the tasks mentioned above. Since Petitioner continues to be incarcerated in the Florida State Prison, no prejudice to the State's con- cerns can result from an additional 30-day extension of time requested. Wherefore, Petitioner respectfully requests an order extending the time for filing a petition for writ of certiorari to and including August 25, 1983. July 26, 1983 Respectfully submitted, ae e. Me Kay Sire James C. McKay =. ounsel of Record John H. More COVINGTON & BURLING 1201 Pennsylvania Avenue, N.W. Post Office Box 7566 Washington, D.C. 20044 (202) 662-6000 Attorneys for Petitioner CERTIFICATE OF SERVICE I hereby certify that on this 26th day of July, 1983, copies of this application were mailed, postage pre- paid, to the Attorney General of the State of Plorida, Tal- lahassee, Florida. I further certify that all parties re- quired to be served have been served. / Mas as for Petitioner --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385011_1692%3A1. Public record. Not legal advice.