# Respondents Brief in Opposition — Ritholz v. Michigan (No. 468) > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386420_0658%3A3 ## Record - **Collection:** Supreme Court brief - **Document type:** Respondents Brief in Opposition - **Published:** January 1, 1960 ## Text FILE COPY Supreme Court, U.S, Pie oO: 7 OCT 28 1950 JAMES 8. BROWNING. Clerk ‘IN THE SUPREME COURT OF THE UNI October Term 1960 No. 468 BENJAMIN D.. RITHOLZ, Petitioner vs. THE PEOPLE OF THE STATE OF MICHIGAN. ‘ Respondent. Petition for Writ of Certiorari To the Supreme Court of ° the State of Michigan RESPONDENT'S BRIEF IN OPPOSITION TO - PETITION FOR WRIT OF CERTIORARI * PAUL L. ADAMS Attorney General of the Stat Michigan SAMUEL J. TORINA Solicitor General of the Stat: Michigan Counsel for Respondent The Canitol, Lansing 2. Mic! SPEAKER-HINES ANO THOMAS. INC... LANSING. MICH. -— te60 ES: (Ny THE SUPREME COURT OF THE UNITED STATES October Term 1960 No 468 EL EO A _ BENJAMIN D. RITHOLZ . Petitioner VS. THE PEOPLE OF THE STATE OF MICHIGAN Respondent ie —— nl Petition for Writ of -Certiorar To the Suprem ye Court of the State of Michigan : — — eae RESPONDENT'S BRIEF IN OPPOSITION TO PETITION FOR WRIT OF CERTIORARI OPINION BELOW STATUTES INVOLVED Ea! aes joining room when he conversed with Dr. Feiler on January 12. The petitioner telephoned Dr. Feiler and told him ot this information (191a). Prior to March 27th there was a te! phone conversation between Dr. Feiler and the defendant and they srranged a meeting in Detroit for March 27th and 28th. Dr. Feiler testified’ that petitioner telephoned him stating he would be in Detroit on thase dates and requested him to meet him there (192a). The ‘petitioner testified that Dr. Feiler called him (192a). On eross-examination, when the de fendant's telephone number was brought out, petition: Y admitted telephoning Dr. Feiler and talking to him for 21 minutes on March 22nd (540a); on Mareh 24th for 5 minutes; for 5 minutes on March 25th (341a); and for S minutes on March 26th f54la). The petitioner sought to explam these calls to Dr. Feiler saying they had an arrangement whieh had existed for several years that when Dr. Feiler called him colleet, he wonld refuse to accept the call and later eall Dr. Feiler back (541a). — On March 27th the petitioner telephoned Dr. Feiler at his hotel room in the Shen ‘aton-Cadillae hotel and expressed a-desire to mect with him to diseuss the Sanchiek’« (12a). Dr. Feiler informed the members of the cea of the call and went to the petitioner’s room at the Statler Hotel (192a-198a-194a). Taere Ritholz asked him to sev what he could do about getting the Sanchick case washed out and said that it would be worth one thousand dollars (194a-195a). Dr. Feiler replied he didn't think he could ’ ‘help and Ritholz said he wanted to meet Dr. -Feiler the following day for a further diseussion. Feiler agreed to meet him and lett (195a). He reported this to the ptometry Board in the morning of March 28th and was advised by the board and Detective Sergeant Chrispell to have no further contact with the defendant (195a). Later on Mae “aa March 2sth, dhe received: aeeall from othe petitioner who expressed the desire te meet hint and further diseuss the Sanchick case, Feiler told the petitioner Le contd net de anything for himioand ‘that he was going shopping (bia). Potitioter asked bim where and Peiler gave him the mare the ¢tore dha): Subbequently Feiler weit shopping at Harry Sutfrin’s store in Detroit. The petitioner entered and Sduotiondd hin to follow (iva). Tle did Si, PP etitianienr’ entered at nien’s room, looked to see df anyvene else was present, took anenvelope, placed it in Feiler gqeoat pocket, . andl satel see What. von edn do. Waitt a few Yo after [leave and. then voutean we™ cine) lett. Pedder watted a roment, deft the store and returned te ’his hotel reom and ther’ found S500 in curreney in the envelope (187a 48a), He returned te Flint (197s), Kept the money until Septem: ber 20, 1955. when he reported this event to an Assistant Attorney General and turned the mone\ over to the State Poliew (2000). The S500 was admitted in evidences on the trial, withont objection (20TaZevad. As oacresult of his - receiving this S900 and failing te repert it to The Optometry Board or law enforcement efticials nntil September, Ti, he was removed ‘fromm office by the Governor (ena aera), Ritholz testitied that Dr. Feiler came to his reaom.on this occasion, Mareh 27th, (476a), told he was: being watehed and would talk fast (476a0: that De Pedler told) hime he hind one baayel member in his pocket and qrewded: one more and thoneht he had him sewed up: that he teld hime that board member was in town and te wanted te take him ont and show him a good time and that would provide three hoard metbers to clean up the sitnation ar To keep him in good shate: that Dro Feiler then asked hia for SoH te entertain the third member; that he agreed to give Dr, Feiler the sno, but did) not have it on his person and promised to deliver it. the following dave(477a). We further testitied that Dr. Feiler talked to him the following after: a °. ma noon and told him he was going shopping, gave him the name and locgtion of thesstore and requested him to mest him there (477a); that he wenf to the store, saw Dr. Peiler on the first thoor (478a): that Dr. Feiler motioned him toward the lavatory and. that he followed Dr.-Feiler ther s .that there was no one else present (478a). He further testified that Dr. Feiler pulled out his overcoat pocket and that he placed an envelope containing S500 in Lr. Feiler’s poeket (480); that Dr. Feiler’ left) immediately (272a-2i4a) and that no words were spoken by eather piarty on this ocension (48Ua). The petitioner.testified that he did not reeall hearing from Dr. Feiler again until June (48la-482a), however, on cross-examination when the telephone numbers were supplied, the defendant reealled telephoning. Dr. Feil: "2 on March 30, April 22. and May 17th. In April 1955, the petitioner instituted suit in the Federal Court for the Eastern Distriet of Michigan against all ot the members of the Michigan Board of Examiners in Optometry, individually, and -many other optometrist. alleging a violation of the Clayton Anti Trust Law and claiming damages and cests in the stim, of $1,Q00,000.00 (481a-531a-33ba). “er Ay Both Dr. Feiler and the petitioner testified to a telephion "cali on about June 17, 1955, wherein Ritholz made inquiry regarding the status ef the Sanehiek case; that Dr. Feil: tolel the defendant there was nothing he could de, or word - to that effect. (04a -205a-200a-548a). 0° Dr. Grigware, A People’s witness, testified that June 14. 1955 petitioner telephoned and told him Dr. Sanehtek wa unhappy with the proceedings of the Optometry Board and asked him to see what he conld do ty have thee eats —11— , Sharges dropped. Hie offered te refer several hundred patients a vear te Dr. Grigware Prem his Grane braepeud~ Ofties (214dad; that Ritholz further said that he hod enenuh power in the Senate te prevent fatnre appeittrsents ter the Optometry Board of anyone recommended by the Michigren Optotiet ric Association or Governor William. (pete vty) Dr. Feiler testified that on Judy Soh petitioner telephoned him and asked him af there wae anything he could de ‘th wash ont the Sanehick ese and that when he replied . . . . . ey . * . in the newative, petitioner satd he was going te start taking depositions in the Federal Court case against “the board . members the following week ¢206a-2eT). Phe further . . e m * . . ; testified that he received telephone ealls from the petitioner Rithelz every day for several days in speeession Wherein Ritholz said de wanted the Sanehiek case washed ont, metitionsed the Federal Court ease. and said that the at- torneys world beeome wealthy as a result of the squabble between himself and the Optometry Board. and that he reported the substance of then telephone calls to peal tes oticers (20Ta-2USa). On Aneust o. 1955, Dr. Peiler. at the reqnest of an Assist aut Attorney General, went te the Olds Perel ta Dain-ine, nyt with Dr. Howe, seeretary cof the Optometry Board, Detective Lot. Pdeorcalel Derry of the Michigan State Polies, Lristeetor Keyl Braun. Myetorietry Board investigater. cate Irving B. Beattie: an Assistant Attornes General: that he reviewed his recent conversations with the defendant bith oly and.stated that Rithelz expressed: aodesire te eampe te Michigan to offer a bribe and had requested him te eal him back (20Sa). At the snggestion of Mr. Beattie. Dr. . beiher telephoned the detent in’ hieave. This eall was monitored by Detective Lt. Berry onan extension telophase’ ead. Dr. Peiler and Lt. Berry testitied that Dr. Petler told Rithdlz he was getting things lined up oli dda) SS a ee and asked dim when they econld meet: that fhe putitions reqnested Qomeeting at Detroit on Sunday, Anenst 7: at the Statler drotel e420a0. Dr. Boiler asked the: petitios ithe was bringing the stil With hit amd petithener redid he was not paying until the goods were delivered i ytoa): that the petitionerssaid "TP have a big stiek in ome heat and kid) eloves in’ the other and DT would rather hand): a this with kid-gloves:” (4200). He warned Feiler te be eare. Mi what he saidoon the telephone sbecanse they have thes damned rooms bnegeds* (4200): that Dro Reiler asked Rithol# if he Wanted three members of the Board te moe with him and that petitiqner replied ‘don't be atdanin fool, This ° between vou and B If there is anybody wpee I? the ceal they'll be taken earé of (4200). Petitioner sae vested the mse cof aomiddleman and suggested first one o his own attorneys in) Detroit: (421a) and then gave the names of three State Senators (21a). He stated that be Wanted to meet Feiler in Detroit om Amgeust th ¢2tbae. Noo sum oof money was mentioned ino this conversation (421a). Rithelz did- most of the talking. The petition: agreed that this testimony was correct: (44a). On ANuenst 4.17955, Rithelz ‘telephoned Dr.sFeiler, ctl) and voiced his suspicions beeause Dr Feiler hive not mes tioned the Federal Court case inthe conversation of Nmwust Srdy and imquired as to whether or not he wanted. that cas dropped (Sis). A On Nuguet oth, Lt. Berry testified that Dro Feiler. re ported this conversation to him (421a) Qn Aneust 9. 1955, petitioner telephoned Dr. Peles and contivmed the time and place of meeting on Aug ist ot! He requested Dr Feiler to bring the other two beard Themibers with him ¢213a). men | The substance of this conversation was reported te Lt. Berry by Dr. Beiler (42a). ie Blackwell, a Pinkerton agent, testified that on Anqust $th petitioner had one of his attorneys contact Burns and Pinkerton detective agencies (12a-36%—), that on August ath. the petitioner engaged the servi des of Pinkerton’ In vestigators (26Sa),: that petitioner represented te this ageney that a Dr. Julian might try to shake him dewn in a business deal (69a); that Dr. Julian was not a publie oficial or a part of State government (270a545a), and that he wanted a reeording of an anticipated conversation for future reference for whatever purpose he desired: to use it (547a-500a). Ritholz, admitted he didi not give the Pinkerton investigators any information of anv previous alleged acts of extortion or any details (o44a). Petitioner was present at the Statler hotel on Sunday, Angust 7, with three Pinkerton Investigators who had* setup a recording machine (46a). The anticipated visitor did notearrive and the petitioner telephoned? Dr. Feiler’. home and Dr, Feiler finally returned his call (47a). This telephone eall was monitored by Lt. Berry ¢215a-t22ah and the petitioner agreed that the substance of the con- Versation was correct (o46ao47a). The petitioner asked Dr. Feiler why he had not come te Detroit and Dr. Feiler replied that he could not get the board members together (215a). The petitioner then suggested a meeting the follow- ing day at the Olds Hotel in Lansing (216a-546a). He said he had to make reservations and would call baek in fifteen minutes (216a). Petitioner Ritholz called baek and in- formed Dr. Feiler that he had his suite at the Olds and for him to bring the other board members and meet with him eat S50 on Auguyt sth A16n-422a). Dr. Feiler asked if this Was final and if he had the stuff with him and the petitioner am sat the Kellogg Center in Bast Lansing in the earky event — > = warned Feiler that someone might be listening oan the tel phone (42200. Rithelz then directed the Pinkerton invest! waters to meet him at the Olds hetel om ANtwust sth sed to register under fictitious mames (72a). On cross examination the petitioner admitted that he never reported any of these alleged: aets of extortion te law enforcement officials of Hlineis, Miehigan, of any other place, and when he was questioned regarding that repli d ‘as follows: “AL DT reported nothing to the police. To intended te report to the police on August sh. Q. In other words, the day after vou were eanght! | AL Yes. Pwasn't ready to present miv case to Three preteen” THE BRIBERY TRANSACTION - On August s, Io, at the request of State Polies. Drs Howe, Girigware, and Feiler met with State Poltee detec . . * —" . tives and an Assistant Attorney General beving Beat (2800 loa 2a dad. At this time Dr Reider and: others reviewed recent events. ALL persons present were infer | of Rithola’s request for a meeting at the Olds Hotel S230 pam. (21Tad. The three doctors were given genera instructions and were advised that if Ritholz requested them te wash ont the Sanehiek case, they could agree to the purpose of obtaining evidences, and were instructed to aecept anv Money Ritholz offered and turn it ever te police Otiieers who would be stationed: in a reoni aed jotni = the Rithola suites (16a). Drs. Howe, Grigware, and bell Went te the ds Plotel ane there met State Police ade? tives, were searched. their money counted. “They the — _— proceeded to thee Rithelz stiite Mider observation of Thies police ¢20Ta vila 42 ba}. The three doetors were adtuitted te the suite bey bathed and a eotversation emened betyweeti the petitioner pase the tharees Ene tybe ae of the OMoteretyy Pere’ ¢olbat. Withedy elie nest oof the talking and explained the purpose of the rave tia, stating that it was cabled te see if there eoorbed bee aa truce Coda dette tele the boevctred opepetreboers. ter Peres that he was a lawyer as he-died net praetice haw (o4hi O70a) The referred te the Peelera cotrt rit it Whieh the Seocared ronereboers biaaed beeen jeritiend its parties theferebamt ate said that the lawyers would become wealthy ane further stated, —“soehere we are im the middbewith these bastards cleaning upon beth of usc Solas. Rithelz brought up the nate of Edwin Le Sanehiek (o31a) whe rented space —. hit in the Tussing Building in Lansing. and te whom the King Optical Company referred persons wwhes responded te their newspaper advertisements, and satd he wanted the Sanchick case called off: that he wattted: preaece Carola, Heoassured the board members that they ¢d- nothing to Worry about because iD he made tromble for amyene he wonld make trouble for himself, get publicity ane would ruin his business ooo). Phe satel hie edieda’t. weart te try anything. Tie Wanterl to se home cand take eare of histbusiness (oda. He then sated he wie mreepniae te ~pergel troney on lawyers and that he woald rather spend it seme other way and asked the board mergbers whether they Wanted him te cdisenss it with all of them oer with Dr. Feiler (350da). Dr. Feiler suggested: that it he disenssed with all of thetn and Rithol then said) that: he was? pre- aired’ te) pay them 85,000 (4550): that this yas the sam he had allotted te spend anethat he would rather, give tt te therm than spend it en lawyers (othad. Dr. Grigware inquired what Ritholz wanted in return waned Ritheolz satel. bie Watited the Samehick ense washed out (ooba), Dr. Llowe —16— iar then inquired what the board members would get in retry and Ritholz said the Federal case would be washed out too, (Oo0a). Rithoelz then told the hoard members they would not be able to hold the hearing on the Sanehies’ ease as scheduled on August 16th when there was a stay of proceedings (57a). Dr. Grigware said that Mr. Moule: ano assistant attorney general, had never informed) the. hoard of such stay of proceedings (95sa). Rithelz said they had better check with Mr. Moule, for S5000 and then said he would go another $1000 to make it even (omwsa-ootke). Ritholz then suggested that Sanchick’s attorney file a motion to dismiss on the ground the complaint did) net nake out a cause of action (559). Tle farther said) thers would hiave to be a show of good faith (561a): said he would draw up a dismissal of his federal court ‘ease and deposit it with the attorneys and that he would eal! th attorneys and immediately’ cad) off the hearings in the Federal court ease (963a). Ritholz made notes of things to be cone Cobta-oita) and Dr. Feiler sat next. te hime and copied his notes (J600a). Ritholz sugeested tliat the Sar chick case be washed out by the beard on an ‘informs hearing (221a) and assured the board members that one would interfere with them, saying that pressure had been put oon Lt. Gevernor Hart amd Deputy Attore, General Gilmore but that he could: pull the pressure off, He named senators whom he claimed put oon this pressure and said “This is a nice clean way for everybody” (70a). Heo went on’to say that he wanted to operate in Michisay aud wanted to operate as legally as he could; that | had ne horns, and that lite was tee short) (S70a 57 ta). And he continued by saying that he would “hyeht if he had to fight: that he had lots of pep and said. .vdesus. Vii handle this case if it takes me six years and every State in the United States” (S72a). He then said it world be better to avoid this as it would be like, a war with cs a. fom - a), atomic bonths; that if he won dhe world lose ready. Amel he again stuwested that the bord lotd.an informal fearins and wash out the Sanehiek ease Co72an. He said he cdiad Dr. Howe down for two days testimony on deposition in the Federal court ease but that he wouldnt get throngh with him inawo dave. that it would take two weeks (9750), “He then said he would deliver the money the following day (otmorrnd: that he thought Dro Feiler was Kidedine becatse he didn't show Wt In Ddetredt cared hier edtedn't thin anvone would ever show up Corba). Withelz then sugetsted “Various means of delivery of the money CaTsad. Me said he had S500 with him asad: that the beard: mepibers could Lave that oon accent and that tie wonld deliver the balanee the following day coTsay: that there weld bene need for a hotel room: as lie: eonld give dt te therm in a restaurant anywhere boasad. tbe assured them all he would. take cee of paytnent and again reitetated his pro posal by saving that he wonld give them So.000 if thes world wash oat the Sanehiek case and ted that they contd het held a hearing (o7%ad: that they world be in conternupt of Court (3TGa)s he then padisedt the anmennmt te S20 eed: “OO it would ive split eveth and then iiegiadreed “Yorn fellows tring to pull sotrethine Pleo ray P54 hen). Jr. ‘oe deer replied a» ves VSTGa). He then handed three one. hundred dalfir bills te Dr. Pedder who in tarn handed S100) each te Dr, Howe and DirsGivigware Oda atta deed. Dre Howe prt theo sto intial Y0 hin on the eoueh) Coseacdstad. Ritholz pieked it up and handed it back to [yr Howe and) told hire he wanted him te have dt (oSdad. Ritholz then snweeested that the hoard cooperate with him and let him knew if they thoneht that he had done anything wrong and that bie wanted dlso teooperate (INdiana). Vyas then siteure steel that he eonld send a certified cheek for the Dalanee payable teat fietitious.person wud that it would be as good as scash aed suevested as an alternative “DL cam meet you in a meh tals restaurant: we go ina toilet, and T throw it in vonr pocket Thats all. Simples isn’t it?" He then asked Dr. Briler if b« eould deliver the balanee of the money te him and Dy Feiler agreed. Ritholz then said he would call Dr. Boiler the next night and would tell hin ome restaurant sare ity two minntes he would be an his war home Os2aJsiu i, He then asked the board members if they trusted him for dismissal of the Federal court case: Was given assurance that they did. (D84a-585a-58Ga). The notes. detailing th: transaction made by Ritholz and Dr. Peder were completed cand Dr. Feiler’s notes were admitted in evidence on the trial (222a). The netes made by Ritholz were never fornel by police officers, Ritholz testified he left the motes in the: hotel suites and later on cross-examination he testithed he didn't Know what had: become of the notes (ostko. Ritholz then said, “Allright. are we set?" Dr. Powe said “Ves.” Ritholz said. “All right. TP got it all wrertten dew: Tid yon've gof it all written down. Tomorrow night} wilfimeet vou in Flint and you ean trust mes” He then sail “You don't think Tam trying to sefew anybody. TP wend only be serewing myself. Powant peace that’s ally and auvthing comes up, Doctor, where vor think semethous has vone wrong, tell me” Cassa). Rithols then explain how he used to fight with the Better: Business Bares but that new they Called himoand he straighten. it ov (a80a), Ritholz then said “That's all” rossad. Drs. Phew Grigware, and Feiler. then bade hime farewell and Rit! “said “Okeh, see veu tomorrow. Toam happy with this (osfa), ° Drs. Howe, Grigware, and Feiler left the Rithelz suit and went immediately to the adjeining room: occupied State Police detectives and turned ower the one tind dollar tills they fick reeemvedd (S20a). State Police DP tective Lt. Sheridan and Sergeant Charispeell Went Teo 1 Ritholz suite, identitied themselves as police Gilcers, wel ~ et oe admitted by Rithelz and placed him under’ arrest for” violation of the bribery. statutes Ola dota). Havine in- formation that the snite heed Teen reuisteyeed dn fwer niceties, the officers asked Ritholz if anvene was with him (ita). He told them he hid his own policemen (la) Rithely ther knocked on the connecting door of his suite. aecorde, ing tea prearranged signal. anel seme Pinkerton agents eame ont the door (hola), Ritholz was handentfed te one of them but when the Pinkerton agents identified therm selves, the handeutf. were removed beta), Mr. Wievins. the Pinkerton agent in charge of the detail. turned “over the recorder and recordings te the spolies 42a d27a) and explained that the petitioner had tela ther that he expected a Dr Julian te atternpt te extert money from him and. that he wanted their services te. prevent theextortion and that they were retained te take ao tame “reeareding of a conversation amd te turn it aver te Rithels for his “future reference” Codon oda) The clef fered: int Ritholz was taken te the. Miehione State Police Headquarters by Det. Lt. Berry. (42Ta) Oh his arrival at State Polies Headuarters the abererelant Was searched byw pelies d) then ynestioned: by an Mics attarney general abet fiYtecr minutes Tater ¢ot The etitiener refused: te answer whether feo gave amy treney ar AS treeetry baer af the Cdyeleorre TEV Poosered Chaat evcenpmer. stating he was an attorney, aormetiber at the Chieage Bort wal American Bar As-oetation.: was withent an attern and that all questions titafit tered tee dterinaitmate hit, aed ) : The defestise: oraaede am oop redtiee Sfaateetitetat detailing it- theory thiat the petit bers *t chil reat brit viel te bop gtaee ert Aunt S155. but only te eomnly with the last of ao series of U.S... - 273 Fed. 35 (18, ALR 145) to the following effect: . ‘Where the criminal intent originates in the mind of . ; the defendant, the fact that the officers of. the govern- . ment. used decoys. or truthful statements to furnish opportunity for or to aid the aceused in the commis- sion of:a crime, in order suecessfully to prosecute him therefor, constitutes no defense to such a prosecu- | tion.’’ . : As a result, the court in this Sith case held that defend- ants were not inspired into crime by police authorities; they merely furnished opportunity or’ aid in furtherance of an already completed conspiracy in order to acquire evidence of the wontemplated crime. The Smith ease, we believe, is on all fours with the in- stant case and refutes defendant’s claim of entrapment. See also United States v Cerone, 150 F 2d 3882; cert. de- nied, 66S. Ct. 98, in which the facts were parallel to those of the instant ease and in which the court held, furthermore, there was no entrapment. From the above it is clear that the trial “court was cor- rect in his comment to the effect that he could remember no evidence which showed that the officers of the law per- sonally or through Board members induced or persuaded the defendant initiated the proceedings which led to the bribe attempt and it was not until then that the officers furnished him with the opportunity he sought of bribing the board.’’ (p. 82). The Court’s charge was therefore - proper and in accord not only with Michigan rulings but is Federal rulings also. No Federal or State rights of re- spondent were violated thereby. —28— CONCLUSION Petitioner was given a fair and impartial trial. He was well and ably represented by counsel, took the stand him- self, produced numerous witnesses in his behalf, and cross examined all the People’s \vitnesses at length. He was thns able to present to the jury all the evidence which was available to him. The trial Court was fair and impartial in its treatment of petitioner and its instructions to the jury, which found him guilty. . -Proof of petitioner’s guilt was overwhelming. Witnesses testified who participated in the transaction, and most im- portant of all, petitioner admitted that he attempted to bribe the board members. He sought to evade the conse- quences of his admission by presenting the claim that he made the bribe attempt in order to obtain evidence which would be used by him to entrap the board members in order to prevent further extortion upon him. The jury disbelieved this story, and we agree that their verdict was proper. A significant factor which we believe contributed to the jury’s conclusion that petitioner’s story was in- credible, is this: Petitioner, an experienced and successful businessman — and a: lawyer in the bargain — admitted on the stand that at no time did he use the simple and common sense means of protecting himself which were in his power —that is, the filing of a complaint with law enforcement officers, either in Illinois or Michigan, who would hive used all resources of both States to protect him. mae RELIEF _-For the above reasons, it is respectfully submitted that this petition for writ of certiorari should be denied. Respectfully submitted, PAUL L. ADAMS Attorney General of the State of Michigan : SAMUEL J. TORINA Solicitor Gieneral of the State of Michigan - Counsel for Respondent --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386420_0658%3A3. Public record. Not legal advice.