# Appendix — Johnson v. Los Angeles Community College District

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386011_2414%3A2

## Record

- **Collection:** Supreme Court brief
- **Document type:** Appendix
- **Published:** January 1, 1993
- **Citation:** 509 U.S. 906

## Text

rY\ « |
a |) Wee Bupreme Court, U.S.
92 =1738h PE
‘ sia
APR 2 8 1993

CrACE OF THE CLERK

IN THE SUPREME COURT

OF THE UNITED STATES

October Term 1992

JACK P. JOHNSON, LINDA JOHNSON,
Petitioners,
Vv.

LOS ANGELES COMMUNITY
COLLEGE DISTRICT,

Respondent.

APPENDIX TO
PETITION FOR WRIT OF CERTIORARI
TO THE CALIFORNIA COURT OF APPEAL

William J. Cleary, Jr. Jack P. and Linda
1853 1/2 N. Canyon Drive Johnson
Los Angeles, CA. 90028 8807 Gold Creek
(213) 465-3633 Road
Lake View Terrace,
CA. 91342
(818) 370-8088
(818) 542-9300

Of Counsel Pro Se

Contents

Written Opinion Of Court Of Appeal....
Oral Opinion Of Trial Court...........
Order Denying Rehearing.......cccesece

Order Denying Review By The

California Supreme Court..............
Order Granting Extension of Time......

Constitutions, Statutes and Rules

Excerpt From Opening Brief In
ro eg ae eS ee re ee

Excerpt From Amended Complaint Filed
On January 10, 1985 by Johnsons
WEGLMBS BGNGOL DISS IGE «occ cccccccccss

Excerpt From Second Amended Complaint
Filed May 14, 1985 by Johnsons Against
aoe Ss 9 nr
Excerpt From Respondent School
District’s Brief in the California
eg eT ee ee ee Te eee ee ee

Second and Third Causes of Action of

Excerpts From Reporter’s Transcripts

Claude Rucker: 1RT 112:4-19

lestimony of Laurel Woodley,
District Gold Creek ad hoc
GOMES ECOG. i.6 6s 0 00 bee eh eee eee 8

TESTIMONY OF FLOYD BODLE,
Johnson’s predecessor in interest..... 89

CLARENCE JOE BROWN, commercial
user GE BOGEG RONG: +5400 6006 ee eee ee 93

DENNIS LEE, L.A.C.C. District

custodian OF r@COrage :« > Ue a - > ~ 5 2 = - ] “ y
boulders after 1 flood. When Bodle had to

ise big machinery an dvnamite to clear the

~hannel after a flood he did so with the

Watts’s knowledge. The Watts, on the other
hand, could keep the lower road clear with

only hand tools. Bodle moved the upper road
from one side of the canyon to the other
depending on where the flood washed out the
road. Bodle scraped rock, gravel and silt
out of the stream bed to repair the upper
road after a flood.

Although Bodle could not recall ever
asking the District for permission to repair
the road, an internal District memorandum
dated October 5, 1953, indicated he had done
so. The memorandum stated in relevant part:
"Mr. Floyd Bodle...who has an easement to
cross our Gold Creek site is desirous of
improving the access road. I accompanied
him to the site on September 28, 1953 to see
what his plan was in relation to existing

27

roads, trees, and stream courses.

Although I was originally opposed to
his plan, I must now reverse this position.
As he outlined his proposals, I am convinced
we stand to gain a permanent well-graded
road up the canyon. This will be of benefit
to us in any future development that may be
proposed. He plans to spend $2000.00 or
more and is just as desirous as we are of
maintaining a beautiful, natural landscape
in the area. [new para.] ...Mr. Bodle is
awaiting word from us, as he would like to
complete the work prior to the heavy rains."

The District, which acquired its
property from the Watts in 1950, maintained
its land in a natural state as an ecological
preserve for its student and faculty. The
District has not found it necessary to widen
the road, which was between 10 and 12 feet
wide, in order to accommodate the school
buses which bring students to the property.

When the Johnsons acquired Bodle’s

28

ry

property in 1975, they with the interest o
leasing it for motion picture filming and
camping. The Johnsons, believing that the
1908 agreement gave them = an undivided
ownership interest in the private road,
admittedly ignored the District’s protests
and widened, elevated and moved portions of
the road, cut down most of the trees along
the road, bulldozed slopes in the upper
canyon, and excavated the stream bed to make
the road suitable for large commercial
vehicles. The Johnsons widened the road
from about 10 to 12 feet to 30 feet in most
areas of the upper canyon and up to 60 feet
in some areas.

The District presented evidence that
the Johnsons’ commercial activities
significantly increased the traffic along
the private road through the District’s
property. AS many as several hundred people
a day were visiting the Johnsons’ property.
Hundareds of vehicles came up the road at a

29

time. The removal of trees and vegetation,
and the cutting of the toes [sic] of the
canyon’s slopes have increased the threat of
further erosion and landslides along the
District’s property. The loss of most, if
not all, of the tree canopy along the stream
has altered the climate in portions of the
District’s property and threatens to
transform portions of the area into a
desert. The elevation of portions of the
road above the stream bed without any safety
barriers has increased the District’s
exposure to liability.

The Johnsons contend that because
their changed use of their land is within
the normal and reasonable development of
their property, the accompanying changed or
increased use of the private road is also

reasonable. (Citing Norris v. State of

California ex rel. Dept. Pub. Wks. (1968)

261 Cal.App.2d 41, 49.) However, the record
Supports the trial court’s determination

30

+ 7 + / -~ + +
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Y + > +
k ¢ : —"
+ , f > - y 7 y . f
¢ + \ _ mmer a ¢ :
restricted |} yrant nd | nduct t
ncommercial usé nly WI e the hn:
tate that "the Zoning regulation: ire
presumptive evidence of reascnable use, an
this ordinance allows campgrounds and
film shooting," the zoning regulations were

not admitted at trial.

The Johnsons’ reliance on Laux V.

misplaced. The parties in that case were
formerly married, and upon dissolution of
their business partnership they divided (by
the toss of a coin) range land which they
had owned together and used for personal and
commercial hunting. The husband, who won

the coin toss, chose the northern portion

31

for himself and gave the wife a general
right of way to reach the southern half.
The husband later tried to prevent the wife
from using her right of way in the manner
the couple had used it during their
partnership. In rejecting the husband’s
attempt to limit the scope of the right of
way, the California Supreme Court made the
following statement upon which the Johnsons’
rely: "’A grant in general terms of an
easement of way will ordinarily be construed
as creating a general right of way capable
of use in connection with the dominant
tenement for all reasonable purposes...’
---’A grant of a right of way unrestricted
as to purpose is a grant of a way to be used
for any purpose whatever....’[Citations.]"
(Ibid. )

We distinguish Laux, in which the
division of the property created the
necessity for the right of way. (See 4
Witkin, Summary of Cal.Law, supra, section

32

459, pp. 636-637. ) In this case, the
Johnsons’ property did not become landlocked
because of a division of property. The

i

easement was created by agreement to provide

Silent and Thomas access tO the county road,
and this was the manner in which the
easement was used until 1975. The purpose

of the easement and the manner of its use
limit its scope, which "cannot thereafter be
changed against objection of the owner of
the servient tenement. (Citations. ]" (Id. at
section 445, p, 626.) The record supports
the District’s claim that the Johnsons
changed the manner +n which the private road
had been used prior. to is73, and
significantly ;ncreased the burden on the
District’s property, despite the District’s
repeated objections.

Similarly, we distinguish

Francheschi v. Kuntz (1967) 253 Cal.App.2d

1041, which the Johnsons also cite in their

brief. In Francheschi there was no evidence

33

of a changed use of the right of way or an
increased burden on the servient tenement.
We conclude the _ trial court’s
interpretation of the 1908 agreement to
preclude the Johnsons from changing and
increasing the use of the private road in
the manner described at trial iS amply

Supported by the record.

rik

The District contends on _ cross-
appeal that it presented sufficient evidence
of trespass and damages.

The District sought treble damages
of. about $1.5 million under Civil Code
section 3346, subdivision eer which
provides in relevant part: "For wrongful
injuries to timber, trees, or underwood upon
the land of another, or removal thereof, the
measure of damages is three times as much as
would compensate for the actual detriment,
except that where the trespass was casual or

34

involuntary, or that the defendant in any
action brought under this section had
probable cause to bel ieve that the land on
which the trespass was committed was his own
land or the land of the person in whose
service or by whose direction the act was
done, the measure of damages shall be twice
the sum as would compensate for actual
detriment...."

The trial court refused to award
damages, stating that the District had
failed to prove that the Johnsons were at
fault for the loss of trees on _ the
District’s property. The Johnsons had a
right to maintain the road, and it was
conceded that the fire and droughts which
hit the property caused damage to the trees.
The trial court stated: "Now I’m not at all
Sure that the actions of the Johnsons
contributed one hundred p[er]cent to the
damages claimed.... There has been a change
in the weather, for want of a better word,

2

in this community since 1902. (new para. ]
You talk about the [tree] canopy. You talk
about reverting to the desert. All you had
to do last night was look at the weather
report if you wanted to find that we are
five inches below norma l for the rain,
average rainfall in this state at this time.
That’s surely not the fault of the
Johnsons....[new para.]... [new para.] I’m
not sure that, by the preponderance of the
evidence on the cross-complaint that
trees...were cut down by Johnson....

Having reviewed the record, we are
not persuaded the evidence is insufficient
to support the trial court’s determination.

Mark Newton, one of the District’s

witnesses, admitted that most of the trees
were damaged by natural causes, and that it
was impossible to say what exactly which
trees were damaged by nature and which were
not. Ronald Bigelow, another District

witness, testified that when he surveyed the

36

District’s property for cut trees, he could
not tell when the trees were cut or why.
Bigelow admitted that some of the cut trees
may have been dead trees. Moreover, Bigelow
testified that a large pine trees.
Moreover, Bigelow testified that a large
pone tree which he believed to be healthy
iespite being blackened in the 1975 fire,
suddenly fell over onto the roof of the
District’s building, much to Bigelow’s
surprise.

The Johnsons presented witnesses who
testified that all of the trees on the
District’s property were damaged by the 1975
fire and 1978 and 1983 floods. Joe Brown,
who owns property below the District’s
property near the country road, testified
that the 1978 flood washed away all of the
trees in the creek channel and destroyed the
District’s road. Mr. Johnson testified that
his removal of the remaining trees along the
channel was necessary to protect the road

37

and did not cause the devastation and
flooding in 1983, because most of the trees
had been washed away in the 1978 flood.

Although the District presented a
Survey listing 60 or so trees which its
experts believed were unnecessarily cut
down, the trial court was not required to
accept that survey at face value. There was
substantial evidence that the three natural
disasters had caused heavy damage to the
trees, and the trial court was entitled to
conclude there was insufficient evidence to
determine which trees, if any, were
unnecessarily removed by the Johnsons.

In effect, the District is asking us
to reweigh the conflicting evidence. A
"’reviewing court is without power to
substitute its decisions for those of the
trial court.’ ...’In resolving the issue of
sufficiency of the evidence, we are bound by
the established rules of appellate review
that all factual matters will be viewed most

38

favorably to the prevailing party
(citations ] and in Support o f the

L

judgment.... “in brief, the appellate court
ordinarily looks only at the evidence

supporting the success ul party, and

disregards the contrary showing. ve

(Citation. ] All conflicts, therefore must
be resolved in favor of the respondent.’

(Citations. ]" (Campbell v. Southern Pacific

Co. (1978) 22 Cal.3d 51, 60.) ""’When a
finding of fact is attacked on the ground
that there is not any substantial evidence
to sustain it, the power of an appellate
court begins and ends with the determination
as to whether there is any substantial
evidence contradicted or uncontradicted

which will support the finding of fact.’

(Citations. ]" (Foreman & Clark Corp. v.
Fallon (1971) 3 Cal.3d 875, 881.)

"Except where additional evidence is
required by statute, the direct evidence of
one witness who is entitled to full credit

39

is sufficient for proof of any fact." (Evid.
Code, section 411; see 3 Witkin, Cal.
Evidence (3d ed. 1986) Introduction of
Evidence at Trial, sections 1750-1756, pp.
1704-1711.) "’Although an appellate court
will not uphold a judgment or verdict based
upon evidence inherently improbable,
testimony which merely discloses’ unusual
circumstances does not come within that
category. (Citation. ] To warrant’ the
rejection of the statements given by a
witness who has been believed by a trial
court, there must exist either a physical
impossibility that they are true, or their
faisity must be apparent without resorting
to inferences or deductions. [Citations. ]
Conflicts and even testimony which is
subject to justifiable suspicion do not
justify the reversal of a judgment, for it
is the exclusive province of the trial judge
or jury to determine the credibility of a
witness and the truth or falsity of the

40

¢
i

a+

upon which a determination depends.
(Citation. }’ (Citations. ]" (People v.
Thornton (1974) 11 Cal.3d 738 754

disapproved on other grounds in People v.

We affirm the judgment. Each party is to
hear its own costs on appeal.
NOT TO BE PUBLISHED.
ORTEGA, J.

We concur:

SPENCER, P.J.

ARANDA, J.*

*Assigned by the Chairman of the Judicial

Council.

—)

>

SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES

BURBANK JUDICIAL DISTRICT

JACK P. JOHNSON, et al.,

Plaintiff’s, Cross-Defendants,
Case No.

NCC
V. 25594B
LOS ANGELES COMMUNITY Oral
COLLEGE DISTRICT, Opinion
Of Trial
Defendant, Cross-Complainant court

eee

By Hon. Thomas C. Murphy, Judge, Superior
Court:

THE COURT: All right. Then let the record
show that the Court has made a study of the
exhibits over the weekend and again last night,
that the Court has had an opportunity to review
the trial briefs that have been filed and the
declarations in support of some of the motions,
that the matter has been before the court for
some seven days and before the district for

about five years.

>
N

We have proceeded on the second
amended complaint for plaintiffs and on the
cross-complaint for the Los Angeles

Community College District

With reference to_- what the
Court is saying at this time, it will be
construed as a statement of decision. The

person who prevails will prepare a statement
of decision to reflect the Court’s thinkinc
and prepare judgment that would be
supportive of it.

With reference to the second amended
complaint, the Court finds that there 1s no
evidence as to interference with economic
advantage, damages for injuries to property
right, intentional infliction of emotiona
distress, negligent infliction of emotional
distress, and any punitive damages based on
the second amended complaint.

The issues that the Court will
discuss when it gets to them is declaratory

relief, quiet title, pre

permanent injunction.

With reference to the cross-
complaint, the Court will direct its
attention to the quiet title, the question
of trespass, declaratory relief,
determinative injunction, and again I must
discuss again damages, but the Court is not
inclined on the evidence that it has heard
from either side to consider punitive
damages.

With reference to quiet title, I
don’t think the case will ever settle in the
minds of the people, although it will settle
with the judgment of the Court, as to where
the boundaries are. As late as yesterday,
there was discussion as to whether or not
barrels which have been moved from time to
time outline the boundary on the part of the
property that is not even involved in this
particular case. So the Court is inclined
to, and will order that a survey be made by
a competent licensed surveyor of the

44

property, particularly in connection with
the well and the underground reservoir, so
that, once and for all, the Johnsons and the
District will have an outline of their
property and know exactly what’s within
those boundaries. That must be done within
the next ninety days. The expense will be
borne equally by the parties at the present
time.

With reference to the causes of
action which both parties are maintaining,
the first cause of action in the cross-
complaint for quiet title, with reference to
the quiet title first cause of action in the
second amended complaint, the Court has
heard the evidence. The Court knows that

the intentions of the parties in any

agreement are important. I’ve heard both
those intentions. I’ve heard the evidence
from both sides. I’ve heard the evidence of

what took place.
The question is, is there a fee

45

title to that road? The court finds no.
The court finds that there is an easement.
Both the Johnsons and the Community College
have a right to cross each other’s property.
They have an easement of ingress and egress
within the scope of things as they existed.
Now I know we can’t limit people to
a 1902 traffic pattern, but at the same time
when you have evidence from the parties that
there was no commercial intent intended in
this, it was more or less a place for the
Bodles and others to go and rest and relax,
and if they could get some honey from the
Wild bees and make, as he referred to, a
dollar, he would do so. But this does not
permit either the community -- nor does it
permit you to open a road for public use,
turning them into camp sites, turning them
into weekend resorts. It has to be kept in
the position that it was in the wild-life
period. It may hurt some people. That’s
fine. But it will go along with that

46

particular consent of the parties.

With reference to the quiet title,
Gold Creek Ecological Reserve is going to be
used aS an instructional, training and
natural science by the students and faculty.
That’s their purpose and any change in
purpose on that would have to be effected in
some manner.

The question of -- I want to keep
these in balance as we go along -- trespass.
The Court is not convinced that the issue of
trespass has been carried. I Know trespass
is sort of an intentional type of action. I
don’t think the Johnsons intentionally did
anything. I think they believed that they
had a right to proceed as they were
proceeding, so much so that they have
pursued this case through a rather long and
tortuous litigation career without
attorneys.

The question of preliminary and
permanent injunction will be addressed and

47

it will sort of be directed to both sides,
because your neighbors and you are going to
live together and you are going to maintain,
I assume, a relationship under the Court’s
Supervision if necessary that will maintain
and keep the peace.

So, having ruled on trespass, I will
then move on to the question that is in my
mind as to the permanent injunction or
declaratory relief which we will base it on.
The Court is going to declare the right of
the parties and will set forth in more
detail in just a few minutes after I can get
to my notes.

All right, I’m going to, inasmuch as
I have ruled that this is not a fee title
and that the Johnsons have got nothing more
than an easement for ingress and egress,
that, with all the right to cross that road,
I am going to say that the judgment will be
for the cross-complainant, and find that
they are the owner in fee simple of the

48

roperty described; that the right-of-way

4
r

easement across it is for the sole purpose
of ingress and egress to the adjacent
property as more fully set forth.

I. am going to declare that the
cross-complainants own all of the property
described in Paragraph 2 of the first cause
of action, again subject to a private and
noncommercial right of way and easement to
cross the road for the sole purpos of
ingress and egress.

I am going to declare that the
cross-defendants and each of them or any of
the parties do not own any of the property
described in Paragraph 2 of the first cause
of action.

I am going to make a declaration
that the cross-defendants may not make
improvements without prior notice in writing
to the district.

You must cooperate. There must be a
meeting or a declaration that the cross-

49

defendants will not engage in maintenance
and repair without prior written notice, and
they are not entitled to alter the course
and width of the easement. And from the
evidence presented to this Court, the
guidelines will not be less than 8 feet and
not more than 18, from the evidence that has
been presented to me, period.

This easement will not be opened by
either side to the public or for use of the
easement for commercial purposes other than
as confined to students, period.

And we must address the question of
damages. Now I’m not sure at all that the
actions of the Johnsons’ contributed one
hundred precent [sic] to the damages
claimed. I have remarked many times during
the trial that this Court is stupid but
sometimes not dumb. There has been a change
in the weather, for want of a better word,
in this community since 1902.

You talk about canopy. You talk

io

0

——— SC Ee

about reverting to the desert. All you had
to do last night was look at the weather
report if you wanted to find that we are
five inches below normal for the rain,
average rainfall in this. state at this
particular time. That’s surely not the
fault of the Johnsons. It’s affecting the
whole -- we are reverting back to the
desert, at least eighty per cent of it. We
have grave concerns on a nat ional level.
The environmentalists have great concerns,
and it was addressed by President Bush as to
what steps are going to be taken to relieve
this effect.

From what I_ read, perhaps we‘re
getting to a point where the ozone layer 1s
being penetrated and we’re losing our
atmosphere. T don’t think the Johnsons are
a hundred percent at fault for that.

I’m not sure that, by the
preponderance of the evidence on the cross~
complaint that trees that were cut were cut

51

by Johnson. Somebody cut then. I’m a
Suspicious man. I would think so, but I’m
not going to assess anyone a million dollars
to refurnish with trees in this particular
area.

I’m going to say, with all due
respect to all of the parties, that there is
going to have to be a cooperation and a
community between you from here on in.
We’re going to have a survey to outline the
boundaries. You are going to have to live
with the fact that you have an easement and
not a direct right to do what you want, when
you want, where you want with the alleged
road. It will be within limits of 8 to 18
feet. You will not take it upon yourselves,
either one or both of you, to go on other
people’s property to maintain or to repair,
without first having conferred, meet and
confer and have written agreement such that
it will or will not be done or it will not
be done. And you are permanently enjoined

52

from doing otherwise.

I am not going to assess damages.
Some might be warranted, but not by the
preponderance of the evidence that I am
satisfied myself as to the nature and the
extent of them, and it would be unfair to
assess a million one plus $275 million [sic]
for this type of thing.

There will be no further damage, no
further cutting, no further repairs, no
further movement, period.

You, young lady, will prepare the
statement of decision and _ prepare the
judgment to support it.

The prevailing party will get their
costs as evidenced by a cost bill.

I thank you for a very interesting
case and a very interesting seven days.

I apologize to you that this
district took five years to try this case.
It should have never taken that long, but I
shall not comment on it other than the fact

53

that, no matter what you say, you’ve now had
your day in court.
Thank you.
MS. BENBEN: Thank you, Your Honor.
(Proceedings in the above-entitled

matter were concluded. )

OFFICE OF THE CLERK

COURT OF APPEAL

SECOND APPELLATE DISTRICT

JOSEPH A. LANE, CLERK
DIVISION: 1 DATE: 11/19/92

iam J. Cleary, Jr.
1/2 N. Canyon Drive
Angeles, CA. 90028

li
3

Doe

Wi
185
Lo

RE: Johnson, Jack P.
vs.
Los Angeles Community College
District
2 Civil BO50096
Los Angeles NO. NCC25594B

THE COURT:

Petition for rehearing denied.

~ }"

Second Appellate District, Division One,
No. BO50096
S016472

IN THE SUPREME COURT OF THE STATE OF
CALIFORNIA

IN BANK

JACK P. JOHNSON Et Al., Appellants

V.

LOS ANGELES COMMUNITY COLLEGE DISTRICT,
Appellant

Petition for review DENIED.
The request for an order directing
publication of the opinion is denied.

LUCAS

Chief Justice

SUPREME COURT OF THE UNITED STATES
No. A-692
Jack P. Johnson, et al.,

Petitioners

Los Angeles Community College District,
et al.

ORDER

UPON CONSIDERATION of the application of
counsel for the petitioner,

IT IS ORDERED that the time for filing a
petition for a writ of certiorari in the
above-entitled case, be and the same is

hereby extended to and including April 29,

1993.

/s/ Sandra D. O’Connor
Associate Justice of the Supreme
Court of the United States

Dated this 15th
day of March, 1993.

57

Constitutions, Statutes and Rules Cited

Ra) California Civil Code Section 1647:
Contracts explained by circumstance.

A contract may be explained by reference to

the circumstances under which it was made,

and the matter to which it relates.

2.) California Civil Code Section 1641:
Effect to be given to every part of
contract. The whole of a contract 1s to be
taken together, so as to give effect to
every part, if reasonably practicable, each

Clause helping to interpret the other.

3.) California Civil Code Section 1644:
Words to be understood in usual
sense. The words of a contract are to be
understood in their ordinary and popular
sense, rather than according to their strict
legal meaning; unless used by the parties in
a technical sense, or unless ae special
meaning 1S given to them by usage, in which

8

Oy

case the latter must be followed.

4.) California Civil Code Section 1638:
Interpretation to be ascertained
from language. The language of a contract
is to govern its interpretation, if the
language is clear and explicit, and does not

involve an absurdity.

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MAIL TAX STATEMENTS AS DIRECTED ABOVE ~~

EXHIBIT No. 1. Grant deed with zoning
marked and certified by L. A. County.

100

BEST AVAILA

p= &.A.C.C. DISTRICT

JOHNSON

Trem a and 01 @et o~f> hee
, , vanishes

—

Ames (

UNITED STATES GEOLOGICAL SURVEY
TOPOGRAPHIC MAP
1900
SAN FERNANDO CALIFORNIA
(SUNLAND QUADRANT IN CURRENT EDITIONS)

EXHIBIT No. 40

101

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UNITED STATES GEOLOGICAL SURVEY
TOPOGRAPHIC MAP
1924
SAN FERNANDO CALIFORINA
(SUNLAND QUADRANT IN CURRENT EDITIONS)

EXHIBIT No. 39

102

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EXHIBIT No. 4.
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EXHIBIT No. 4
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EXHIBIT No. 4
page 3 of 4

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COUNTY OF LOS ANGELES
CAMB 2847

ad fONE Ae cen: (NEFENDANTS

MAP OF L.A.C.C. DISTRICT PROPERTY

FROM COUNTY ACCESSORS MAP BOOK
EXHIBIT No. 6

109

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386011_2414%3A2. Public record. Not legal advice.