# Amicus Curiae Brief — Hochheiser v. United States

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Amicus Curiae Brief
- **Published:** January 1, 1990
- **Citation:** 498 U.S. 822

## Text

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No. 89-1991 tS Lin
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IN THE

Supreme Court of the United States

OCTOBER TERM, 1989

— ie

LAWRENCE HOCHHEISER,
Petitioner,

UNITED STATES OF AMERICA,

Respondent.

BRIEF OF CENTER FOR CONSTITUTIONAL
RIGHTS AS AMICUS CURIAE IN SUPPORT OF
PETITION FOR CERTIORARI TO THE
UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT

*MORTON STAVIS

MAHLON F. PERKINS, JR.
Center for Constitutional Rights
666 Broadway, 7th Floor

New York, New York 10012
(212) 614-6425

Counsel for Amicus Curiae

*Counsel of Record

TABLE OF CONTENTS

Page
TABLE OF AUTHORITIES Va we ie ee stew ee
pe a ae a: |
REASONS FOR GRANTING THE WRIT AND
SUMMARY OF ARGUMENT ......... 5
THE COURT SHOULD SEIZE THE OPPOR-
TUNITY PRESENTED BY THIS PETITION
TO REAFFIRM THE CONSTITUTIONAL
LIMITATIONS ON THE POWER OF COURTS
TO PUNISH SUMMARILY FOR CONTEMPT
ATTORNEYS WHOSE CONDUCT HAS NOT AC-
TUALLY OBSTRUCTED THE ADMINISTRATION
OF JUSTICE . > 7 - oo * . J . . . J > 7
1. The Circumstances of the
Petitioner's Conviction .... 7
2. The Parallels to Other
Attorney Contempts ...... 14
3. Origins of the Constitutional
Limitations on the Contempt
a. - ao he a ce a tee Se « «= = ee
4. Actual Obstruction as the
Sine Qua Non for Constitutional
Exercise of the Contempt
ee s+ ¢ ewe xk ce wee ess eS
5. Constitutional Limitations in
Lawyer Contempts ....... 25
CONCLUSION ee ee ee oe ee a er ee

ii

TABLE OF AUTHORITIES

v. Illinois,
U.S. 194 (1968) ..

Bridges v. California,

314

Brown
356

U.8. 282 (206803. .

v. United States,
U.S. 148 (1958)

Cammer v. United States,

350

U.S. 399 (1956)

Ex parte Hudgings,

249

U.S. 378 (1919)

Holt v. Virginia,

381

In re
404

In re
370

In re
326

In re
333

Nye v.

313

u.s. 1314 Ce...
Little,
U.S. 553 (1972)

McConnell,
U.8. 230 €3962) . «

Michael,
U.S. 224 (1945) .

Oliver,
v.64. 687 606 2 ee

United States,

v.86. 33 Of 3. 19,

Offutt v. United States,
11 (1954)

348

U.S.

24

22

Zo

22

21

26

27

25

22

23

22

24

iii
Statutes
Act of March 2, 1831, 4 Stat. 487 .. 18
18 U.S.C. § 401(1) ees «a « «© « £6, 29

Other Authorities

Stansbury, Report of the Trial of
James H. Peck on an Impeachment
for High Misdemeanors in Office
nt fe: =. . aoe + «le UR, 620, 22

BRIEF AMICUS CURIAE OF
CENTER FOR CONSTITUTIONAL RIGHTS

This brief amicus curiae is submitted
in support of the petition for certiorari
seeking review of the decision of the
United States Court of Appeals for the
Second Circuit in Lawrence Hochheiser v.
United States of America, 897 F.2d 1227

(2d Cir. 1990). Letters consenting to the
filing of this brief have been received
from the Solicitor General of the United
States, counsel for the respondent, and
from Vivian Shevitz, Esq., counsel for the
petitioner, and have been forwarded to the
Clerk of the Court under separate cover.
Interest of Amicus

The petition presents questions of
great importance for defining the consti-
tutional limitations on the summary con-
tempt power. They arise in this case out
of the summary contempt conviction of a

lawyer for a single brief outburst pro-

2
voked by the lawyer's frustration at the
court's refusal to let him utter one word
in his own defense against a previous
contempt citation founded on a misap-
prehendsion. This conviction for conduct
which did not come close to obstructing
the administration of justice flies in the
face of ruling precedents of this Court,

particularly In re McConnell, 370 U.S. 230

(1962), which capped a long history of
efforts to check the unbridled exercise of
the contempt power. Unfortunately, the
petitioner's plight is not an isolated
one. Herein lies the interest of the
Center.

Founded twenty-four years ago as an
outgrowth of the civil rights movement in
the South, the Center provides legal sup-
port to individuals and groups whose con-
stitutional rights have been infringed or

denied. In our work we rely not only on

3

our own staff attorneys but on a network
of cooperating lawyers and law professors
throughout the United States. We often
defend persons who have been prosecuted
for exercising their constitutional
rights. The causes we espouse are not
always popular. Out of our own experi-
ence we know how important it is that a
lawyer be free to defend his clients with
vigor, even vehemence, without having to
fear that he may be held in contempt if an
excess of zeal leads him to overstep the
bounds of courtroom propriety.

Because our own attorneys and coop-
erating attorneys have from time to time
been held in contempt, we are sensitive to
the dangers that an untrammeled contempt
power presents for our own work and that
of other public interest organizations
which seek to defend and enlarge constitu-

tional rights. Over the years we have

4
successfully defended lawyers in a number
of contempt cases and related disciplinary
cases, among them In the Matter of Pils-
bury, 866 F.2d 22 (2nd Cir. 1989); United
States v. Turner, 812 F.2d 1552 (11th Cir.
1987); In re Dellinger, 461 F.2d 389 (7th
Cir. 1972); Matter of Hinds, 90 N.J. 604
(1982). We are currently representing a
professor of law at the University of
North Carolina in his appeal of a criminal
contempt conviction in a North Carolina
state court. In the Matter of Barry Na-
kell, North Carolina Court of Appeals, No.
89 GO 848. We are also consulted from
time to time in other lawyer contempt
cases. We were, for example, requested to
submit an amicus brief in this Court in

support of the petition in In the Matter

of James B. Daniels v. Superior Court of

the State of New Jersey, Docket No. 89-

1972, and have recently filed a Motion for

5
Leave to File and Brief Amicus Curiae in
that case.

This special experience has led us to
conclude that the teachings of McConnell
are being widely forgotten or ignored,
with devastating consequences for the
constitutional rights of lawyers and their
clients, and explains our interest in sub-
mitting this amicus brief as well as the
amicus brief in Daniels.

REASONS FOR GRANTING THE WRIT
AND SUMMARY OF ARGUMENT

The petitioner, Lawrence Hochheiser, a
New York criminal defense attorney, was
summarily convicted in federal district
court of criminal contempt of court, with-
out any opportunity to present evidence in
his own defense, for a single brief out-
burst in protest at the court's refusal to
let him respond to an immediately previous

contempt citation. Although his conduct

6

did not obstruct, or imminently threaten
to obstruct, the administration of jus-
tice, the court of appeals, while revers-
ing the first contempt conviction, af-
firmed the second on the ground that the
petitioner's conduct affronted the dignity
of the court. Such a basis for isposing
contempt does not comport with the con-
stitutional requirements for exercise of
the summary contempt power as laid down by
this Court in In re McConnell, 370 U.S.
230 (1962), In e ittle, 404 U.S. 553
(1972), and many other cases. Permitting
a disrespectful utterance, without more,
to be grounds for contempt puts a damper
on fearless advocacy by attorneys and
diminishes the Sixth Amendment rights of
their clients.

We point out that the facts and cir-
cumstances of this case parallel those of

other lawyer contempt cases in which the

4
Center has been involved in representing
or counseling attorneys held summarily in
contempt. McConnell and Little are the
culmination of a long historical struggle
to limit the arbitrary power of judges to
convict summarily without the ordinary due
process safeguards. We fear that their
teachings are now too often forgotten, and
suggest that this petition and the peti-
tion in Daniels present an exceptional
opportunity to reestablish needed limita-
tions on the contempt power.
ARGUMENT

THE COURT SHOULD SEIZE THE OPPORTUNITY
PRESENTED BY THIS PETITION TO REAFFIRM THE
CONSTITUTIONAL LIMITATIONS ON THE POWER OF
COURTS TO PUNISH SUMMARILY FOR CONTEMPT
ATTORNEYS WHOSE CONDUCT HAS NOT ACTUALLY
OBSTRUCTED THE ADMINISTRATION OF JUSTICE

1. The Circumstances of the Petitioner's
Contempt Conviction

The petitioner, Lawrence Hochheiser,
was convicted in the course of a long

criminal trial for uttering a mere ten

8

words: "I won't pay. You can put me in
jail, Judge." This spontaneous outburst
followed on the heels of the judge's refu-
sal to permit him to defend himself

against a previous citation of contempt
for what she had characterized as "deli-
berately" disobeying her ruling against
the introduction of a police surveillance
report. In two state court trials for the
murder of a plain clothes police officer
and attempted murder of his companion,
Hochheiser's client, Federico Giovanelli,
together with two codefendants, had either
been acquitted, or the jury had failed to
agree on a verdict. They were then in-
dicted under RICO, with the murder and
attempted murder among the underlying
crimes. Critical to Giovanelli's defense
in the federal trial was the credibility

of the eyewitness testimony of an FBI

agent, who had refreshed his memory of

9

observations made four years earlier by
studying a surveillance log. When Hoch-
heiser, in the course of his cross-ex-
amination of the agent, offered the log in
evidence as past recollection recorded,
the judge erroneously refused to receive
it. Hochheiser continued his efforts to
impeach the agent's credibility by deter-
mining what part of his testimony was
based on actual recall and what part was
based on studying the log. Mistakenly
believing that Hochheiser was attempting
to lay a foundation for another offer of
the log in evidence, the judge twice tried
to cut him short. When he persisted, she
excused the jury and fined him $250 for
"deliberately disobeying [her] direction
with regard to the introduction of that
document." This was the first contempt
sanction.

When Hochheiser tried to explain that

10
he was not deliberately doing anything,
the judge stopped him cold, saying:
I'm not going to hear any more.

There is only one way to bring law-
yers into line, and that's to fine

them. Before this trial is over,
you may be paying a big bill in
fines.

She ordered the jury brought in. It was
at this moment, as the jury began to file
in behind him from the rear of the court-
room, that Hochheiser erupted with the ten
words that swiftly drew an additional fine
of $500. The judge accused him of delib-
erately saying these words in the presence
of the jury and refused to accept his
statement that he did not know the jury

were behind hin.’

In her Rule 42(a) Cer-
tificate, the judge accused Hochheiser of

"deliberately trying to bring about a

' Hochheiser never had an opportunity

to present the testimony of others in the
courtroom in support of the truthfulness
of this statement.

11

mistrial" (Pet. App. at 20a-21la), a
ceéinid aiaeiuiadl which he could hardly de-
fend himself since it was not made prior
to his conviction.®

The facts demonstrate that the behavior
for which the second fine was’ imposed
cannot be considered apart from Hoch-
heiser's stubborn efforts on behalf of his
client. They indicate that his momentary
explosion of anger, however improper and
however offensive to the trial judge, was
not calculated to disrupt the trial or
otherwise obstruct or imminently threaten
to obstruct the administration of justice,
and did not in fact do so. It clearly
sprang from his feelings of frustration at

the court's adamant refusal, based on a

misunderstanding of the tenor of his ques-

¢ The judge later accused the attor-

neys for the defendants of being in a
"contempt plot" as a tactic to bring about
a mistrial.

12
tions, to let him pursue a crucial line of
cross-examination of a dangerous witness,
capped by her citing him for contempt
without allowing him a word of explana-
tion.

In affirming petitioner's conviction on
the second contempt, the Court of Appeals
relied principally on notions of "dis-
respect" and "affront to the dignity of
the court." Pet. App. at lla-12a. The
opinion states:

Words of reproach directed in open

court to a judge's order must be

dealt with swiftly and firmly, since

to allow such conduct to go unsanc-

tioned risks the serious erosion of

the court's authority to control the
proceedings before it.
Pet. App. at 3a. This generality hardly
fits the case of an isolated and trans-
itory outburst in 2 trial as to which the
Court of Appeals itself noted its "hotly

contested nature" and the "severity of the

charges" against the defendants. Id. at

13
4a. In any event, a mere "risk" of ero-
sion of a court's authority does not pre-
sent an imminent threat of obstruction,
let alone an actual obstruction, to the
administration of justice, --- the con-
stitutional minimum for the exercise of
the summary contempt power. At the close
of its opinion, the Court does state that
the misbehavior "required" the jury to
retire once again and "in that way" ac-
tually obstructed the administration of

3

justice. This is no more than a per-

functory recitation of the statutory for-

; The Court states that the trial

judge's finding that Hochheiser was aware
when he spoke that several members of the
jury were in the back of the courtroom is
"persuasive." Pet. App. at 12a. Given
the circumstances, it seems at best inm-
probable; in any event, a persuasive find-
ing is not a finding established beyond a
reasonable doubt, the standard for a crim-
inal conviction. The opinion does not
allude to the judge's baseless finding
that Hochheiser deliberately attempted to
bring about a mistrial.

14
mula, a rationale that could be used to
justify any judge's overreaction to an
attorney's behavior. Plainly, it is
"disrespect" that is at the core of the
opinion, a standard that is constitution-
ally defective.

2. The Parallels to Other Attorney
Contempts

The Hochheiser contempt conviction pre-
sents features that are found in a number
of other attorney contempt cases in which
the Center has been involved.

Jeopardy of Client. The attorney is

faced with an adverse ruling which in-
perils the cause of his client and which
he believes to be erroneous as a matter of
law or based on a misunderstanding of the
facts. This causes him to exceed the
bounds of decorum in his efforts to over-
come the ruling, arousing the judge's ire.

Gross Blunder by the Court. Sometimes

a3

the court takes a position that appears
so unjustifiable to the attorney that he
involuntarily lets his frustration show in
a manner that offends the judge. This
happened to Hochheiser, confronted in
succession not only with adverse rulings
that could emasculate the defense but a
contempt citation to which he could not
respond.

Court's Perception of "Body Language."
An overly sensitive judge reads into an
attorney's demeanor, facial expression or
tone of voice an intent to insult or mock
the court, even where the content of the
attorney's language has been uniformly
respectful, or it is clear that the attor-
ney's misbehavior is not calculated, but a
momentary lapse. - The court dismisses any
apology or explanation. Irn the present
case, the trial judge kept imputing a

"deliberate" character to Hochheiser's ac-

16
tions without any apparent basis.

Court's Bias Against Party. The judge
exhibits antagonism to the attorney's
client because of the nature of the of-
fense with which he is charged or the
rights he is seeking to enforce. This an-
tagonism may then be transferred to the
attorney, a transfer that may readily oc-
cur when a rambunctious defendant engages
in courtroom antics. The judge's hos-
tility in the present case was displayed
by her intimidation of the lawyers with
threats of escalating fines, conveyed in
harsh language.

Disruption Caused by Court. The court
proceedings are unnecessarily interrupted
by a judge who takes umbrage at what he
perceives to be disrespect by the attor-
ney and orders his ejection from the
courtroom or pronounces summary contempt.

The attorney does not intend or foresee

17
such an interference with the orderly
administration of justice and should not
be held accountable therefor.

We recognize that there have been in-
stances when a lawyer has deliberately and
repeatedly provoked the court in order to
gain the attention of the press or create
grounds for a mistrial. Such behavior is
plainly punishable as an obstruction to
the administration of justice. Not so,
conduct which erupts in the tense atmo-
sphere of a trial where the attorney is
simply doing his utmost to protect the
interests of an endangered client.

3. Origins of the Censtitutional Limita-
tions on the Contempt Power

The contempt power of a federal court
is limited by statute, in the case of
conduct taking place before it, to "mis-
behavior of any person in its presence or

so near thereto as to obstruct the ad-

18

ministration of justice." 18 U.S.C.

§ 401(1). This restriction is rooted in
constitutional considerations that arose
in the impeachment trial of James H. Peck,
a federal district judge who had in-
prisoned a iawyer for publishing a criti-
cism of one of his opinions in a case on
appeal. Judge Peck was acquitted by a
Single vote after a trial that continued
over a period of almost two months.* The
day after his acquittal Congress’ took
steps to provide for a drastic delimita-
tion of the federal contempt power. With-
in a few days James Buchanan, the prin-
cipal manager of the case against Peck
(and aftervarée elected President),

brought in a bill that became the Act of

March 2, 1831, 4 Stat. 487. This Act,

* The trial is reported in full in

Stansbury, Report of the Trial of James H.
I wr . a a
demeanors in Office (1933).

19
“declaratory of the law concerning con-
tempts of court," confined the summary
contempt power, inter alia, to misbehavior
"in the presence of said courts, or so
near thereto as to obstruct the ad-
ministration of justice," -- language al-
most identical with that now found in
18 U.S.C. § 401(1). See, Nye v. United
States, 313 U.S. 33, 44-46 (1941).

The arguments by Buchanan and other
managers of the case against Peck demon-
strate that their passionate opposition to
the broad contempt powers urged by those
charged with Peck's defense sprang from
their conviction that such powers con-
travened the principles for which the Rev-
olution was fought and threatened liber-
ties guaranteed by the Constitution. Con-
stitutional concerns were at the heart of
the impeachment proceedings and the legis-

lation that ensued.

20

The arguments of the managers against
untrammeled powers of summary contempt
reflect concerns that persevere to this
day: the lack of ordinary due process
with the concentration of all powers in
the judge; the absence of any clear stan-
dard; dependence on the temperament of the
judge. As expressed by Buchanan: "the
dearest rights of a citizen may be taken
away without trial by jury, and by the
sole authority of an angry, offended, and
therefore partial judge." Stanbury, op.
cit., at 445-46. The managers recognized
the "plea of necessity," the right of a
court to preserve its own functioning;
but, as stated by M'Duffie, this plea must
be "pleaded in good faith, and clearly
made out. It must be a case of actual
necessity, obvious to the common sense of
every impartial person. The administra-

tion of justice must be actually obstruct-

21
ed." Id., at 87. The managers were un-
animous that this was a constitutional
minimum.
4. Actual Obstruction as the Sine Qua Non

for Constitutional Exercise of the
Contempt Power

Seventy years ago, in Ex parte Hudg-
ings, 249 U.S. 378 (1919), this Court, in
overturning the contempt conviction of a
witness for perjury, enunciated the prin-
ciples that set constitutional boundaries
to the contempt power. It held that the
existence of this power expressed no pur-
pose to exempt judicial authority from
constitutional limitations, since “its
great and only purpose" is to secure judi-
cial authority from obstruction to the
performance of its duties:

An obstruction to the performance of
judicial duty resulting from an act
done in the presence of the court
is, then, the characteristic upon

which the power to punish for con-
tempt must rest.

22
249 U.S. at 383.

In a number of later cases this Court
has plainly read the statutory requirement
of actual obstruction as a constitutional
limitation deriving from the Peck trial.

Nye v. United States, supra; In re Mi-

chael, 326 U.S. 224, 227 (1945); Cammer v.

United States, 350 U.S. 399, 406 (1956).
In Bridges v. California, 314 U.S. 252
(1941), this Court struck down, as viola-
tive of the First Amendment, the power of
a judge to punish publications as con-
tempts on a finding of "a mere tendency"
to interfere with the orderly administra-
tion of justice in a pending case. Re-
viewing the "celebrated case of Judge Pec-
k," the Court concluded:
But we do find in the enactment [of
the Act of 1831] viewed in its his-
torical context, a respect for the
prohibitions of the First Amend-
ment, not as mere guides to the

formulation of policy, but as com-
mands the breach of which cannot be

23
tolerated.
314 U.S. at 267.

Bridges demonstrates that the limi-
tation of the contempt power to actual
obstruction serves to protect, among oth-
er rights, the First Amendment right of
free expression which, under the Four-
teenth Amendment, binds the states. In In
re Oliver, 333 U.S. 257, 275 (1948), this
Court reversed a Michigan contempt con-
viction for failure to meet due process
safeguards, stating that the narrow ex-
ception to such due process requirements
includes only charges of misconduct, in
open court in the presence of the judge,
which disturbs the court's business and
where "immediate punishment is essential
to prevent 'demoralization of the court's
authority ... before the public.'"

In a multitude of cases this Court has

shown its continuing sensitivity to the

24

potential for abuse which resides in the
summary power of contempt. The vulner-
' ability of the judge is a frequent theme.
In Bloom v. Illinois, 391 U.S. 194, 202
(1968), which extended the constitutional
guarantees of jury trial to state prosecu-
tions for serious criminal contempts, this
Court commented:

Contemptuous conduct, though a pub-

lic wrong, often strikes at the most

vulnerable and human qualities of a

judge's temperament.

Again, in Offutt v. United States, 348

U.S. 11, 13 (1954), remanding a contempt
oututae for a second hearing by anoth-
er judge because the trial judge had be-
come personally embroiled with counsel for
the defendant, this Court said:

The power thus entrusted to the
judge [to punish without the for-
malities required by the Bill of
Rights] is wholly unrelated to his
personal sensibilities, be they
tender or rugged. But judges are
human, and may, in a human way,
quite unwittingly identify offense

25
to self with obstruction of law.
cf. Brown v. United States, 356 U.S. 148,
153 (1958), where this Court warned trial
judges against "confusing offense to their
sensibilities with obstruction to the ad-
ministration of justice."

5. Constitutional Limitations in Lawyer
Contempts

The danger of confusing perceived of-
fense with actual obstruction looms large
when confrontations arise between judge
and lawyer over disagreement on the
judge's rulings. Here not only First
Amendment and due process considerations
come into play, but also the need to give
uninhibited effect to the Sixth Amendment
right of a criminal defendant to assis-
tance of counsel. In such situations this
Court has required a clear showing of ac-
tual obstruction of justice. In re McCon-

nell, 370 U.S. 230 {1962). The lawyer in

26

this case, after being instructed by the
judge in the presence of the jury to refr-
ain from repeatedly asking questions on
certain subjects which the court had ruled
were not admissible, persisted in assert-
ing his right to ask the questions and
announced that he "propose[d] to do so
unless some bailiff stops us." After a
short recess requested by his co-counsel,
the lawyer did not continue to ask the
forbidden questions. In reversing his
conviction for contempt, this Court said:

The arguments of a lawyer in pre-

senting his client's case strenuous-

ly and persistently cannot amount to

a contempt of court so long as the

lawyer does not in some way create

an obstruction which blocks’ the

judge in the performance of his

judicial duty. The petitioner cre-

ated no such obstacle here.

3760 U.S. at 236. Cf. Holt v. Virginia,

381 U.S. 131 (1965) (reversing on Sixth
Amendment grounds the conviction of a law-

yer for using "vile, contemptuous or in-

————————— oe

27

sulting language" in violation of the Vir-
ginia contempt state; In re Little, 404
U.S. 553, 555 (1972) (pro se criminal def-
endant in state court "clearly entitled to
as much latitude in conducting his defense
as enjoyed by counsel vigorously espousing
a client's cause").

There was no clear showing in this
case that Mr. Hochheiser actually obstruc-
ted or imminently threatened to obstruct
the administration of justice. His case
displays many of the features catalogued
by Buchanan and his confreres as leading
to dangerous oppression when the contempt
power is untrammeled: a lawyer unable to
mask his involuntary feeling that the
judge's ruling was absurd, judicial hos-
tility, the susceptibility of the judge,
the offended judge as sole arbiter of the
offense imposing punishment before "his

resentment should have time to cool," con-

28
struing the lawyer's actions as deliber-
ately disrespectful unheeding of his dis-
avowals. A judge may not constitutionally
be permitted to "carry the standard in his
own breast."

We respectfully suggest that this peti-
cion presents an exceptional opportunity
for the Court to reassert the constitu-
tional limitations on the exercise of the
summary contempt power and thereby provide
much needed guidance both to the federal
courts and the courts of the fifty states.
we suggest, also, that the Court likewise
agree to hear the petitioner in In re
James B. Daniels v. Superior Court of the

State of New Jersey, Docket No. 89-1972,

which presents similar issues of lawyer
contempt, and that it consider the two

petitions jointly.

29
CONCLUSION
For the reasons stated, we respect-
fully urge that the petition be granted.

Respectfully submitted,

*MORTON STAVIS

MAHLON F. PERKINS, JR.

Center for Constitutional
Rights

666 Broadway, 7th Floor

New York NY 10012

(212) 614-6425

ATTORNEYS FOR AMICUS CURIAE

*Counsel of Record

---

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