Tuesday, March 11, 2025
Contessa Hoskins v. City of Cleveland et al., Case No. 2023-1344
Eighth District Court of Appeals (Cuyahoga County)
John Doe et al. v. City of Columbus et al., Case No. 2024-0056
Fifth District Court of Appeals (Delaware County)
State of Ohio v. Aarin J. Clinkscale, Case No. 2024-0005
Tenth District Court of Appeals (Franklin County)
Disciplinary Counsel v. Eric E. Norton, Case No. 2024-1723
Cuyahoga County
Was City’s Immunity From Responsibility for Pool Drowning Removed by Lifeguard Chair Setup?
Contessa Hoskins v. City of Cleveland et al., Case No. 2023-1344
Eighth District Court of Appeals (Cuyahoga County)
ISSUE: Is a lifeguard’s use of a low chair, instead of an available elevated lifeguard chair, a physical defect that established an exception under R.C. 2744.02(B)(4) to a political subdivision’s immunity from liability?
BACKGROUND:
The city of Cleveland operates and maintains an indoor pool at the Thurgood Marshall Recreation Center. One day in December 2019, lifeguard Nieemah Hameed was staffing the pool when William Johnson drowned while he was swimming.
Johnson, who had epilepsy, typically swam at the pool three days a week. The pool is equipped with an elevated lifeguard chair placed alongside the pool. Lifeguards are told they can choose to use the elevated chair, sit in lower folding chairs, or walk around the pool.
Hameed, who joined the city as a lifeguard in 1998, said in a deposition that she knew Johnson’s regular routine and that he had epilepsy. On the day Johnson drowned, Hameed sat in a folding chair next to the elevated chair during her lifeguard duties. She said Johnson and another visitor were the only people using the pool at that time. The pool is a rectangle 50 yards long, ranging from 3.5 feet to 7 feet deep. Hameed described scanning the pool while Johnson was in the deep end and the other patron was in the shallow end. The elevated lifeguard chair had various objects hanging from it and was positioned between where Hameed was sitting and where Johnson was in the deep end of the pool.
Hameed said she stood up a few times to better see Johnson. At one point when she didn’t see him, she said she got up and walked over to the pool’s deep end. He was on his back at the bottom of the pool. Johnson was pulled out by pool staff. They performed chest compressions and tried to clear his airway. Hameed said Johnson’s tongue was swollen, blocking his airway.
Cleveland EMS arrived and took over, but Johnson died. The autopsy report concluded that his death was an accidental drowning due to an epileptic seizure.
Executor Files Lawsuit Against City and Lifeguard
Contessa Hoskins, executor of Johnson’s estate, sued the city and Hameed, as well as other employees who were later dismissed from the case. The lawsuit alleged that the city was negligent for a physically defective lifeguard chair and premises, and that Hameed’s conduct was reckless.
In March 2022, the city and Hameed asked the Cuyahoga County Common Pleas Court for summary judgment in their favor, based in part on a claim that the city and its employees had immunity from liability in the death. After hearing arguments, the trial court denied the request for summary judgment.
Cleveland and Hameed appealed to the Eighth District Court of Appeals, which upheld the trial court decision. The Eighth District concluded that there was a genuine factual dispute about whether the lower chair the lifeguard used was a physical defect on the pool grounds and whether Hameed acted recklessly that day.
The city and the lifeguard appealed to the Ohio Supreme Court, which agreed to review whether there was a physical defect on the pool grounds.
City Maintains No Exception to Its General Immunity Applies
A political subdivision, such as Cleveland, has immunity from liability unless an exception in Ohio law applies. One exception is when a death is caused by a government employee’s negligence and is due to physical defects within or on the grounds of the government building. Cleveland disagrees with the Eighth District’s finding that the discretionary use of the lower chair could be a physical defect on the pool grounds. Hameed’s choice to use that chair cannot be a physical defect under the law, the city maintains.
Cleveland notes that Ohio courts have defined “physical defect” in this context as “a perceivable imperfection that diminishes the worth or utility of the object at issue.” The other side presented no evidence that the elevated lifeguard chair was broken, had imperfections, or wasn’t working, the city argues. Hoskins’ expert witness, who specializes in aquatic safety, instead concluded that Hameed should have used the elevated chair, the city maintains. It notes that Hameed said she preferred the lower chair because the elevated chair was uncomfortable for her size. That preference, though, isn’t evidence of a physical defect with the elevated chair, the city argues.
Nor was there a physical defect with the lower chair, the city adds. Cleveland dismisses Hoskins’ argument that the lifeguard would’ve had a better view of Johnson from the elevated chair, so the use of the low chair was ineffective. The city counters that Hoskins’ argument isn’t evidence of a physical defect of the lower chair that would have removed the city’s immunity. A lifeguard’s choice to use or not use safety equipment doesn’t make it physically defective, the city maintains. Although courts have ruled that the lack of a safety feature can be a physical defect, that is not the circumstance in this case where the elevated lifeguard chair was there and wasn’t defective, the city argues.
The city contends that even if the Supreme Court would find a physical defect existed, the city’s immunity is restored under the third step in analyzing claims of an exception to government immunity. That step restores immunity when employees exercise their discretion in using equipment, Cleveland concludes.
Executor Argues Chair Setup Created ‘Blind Spot’ in Lifeguard’s View of Pool
Hoskins replies that the Court shouldn’t analyze the third step in this case. The argument that the third step restored Cleveland’s immunity was rejected by the trial court and the Eighth District, and the Court didn’t accept that issue for review, she argues.
Hoskins maintains that lifeguards at the pool were trained to sit in the elevated lifeguard chair. She notes that Hameed’s decision not to sit there was more than just a personal preference. Other lifeguards said they used lower chairs because the elevated chair becomes uncomfortable. Also, the aquatics safety expert found that Hameed’s view of Johnson from the lower chair was obstructed. The elevated chair had objects hanging from it, and Hameed’s chair was positioned on one side of the elevated chair, creating a “blind spot” blocking her view of the deep end of the pool where Johnson was swimming, the expert concluded.
Hameed’s obstructed line of sight meant she had to stand up to see Johnson in the deep end, and she didn’t realize he needed to be rescued until she walked around the elevated chair to the far end of the pool to check on him, Hoskins maintains.
An exception to the city’s immunity has been established, Hoskins contends. She maintains there was a physical defect on the pool grounds because the elevated lifeguard chair caused discomfort, impairing its utility. The numerous items hanging from the elevated chair contributed to its defective condition, she adds. If lifeguards felt comfortable using the elevated chair, it would have given them a better vantage point to survey the pool, and for Hameed to see Johnson struggling and prevent his drowning, Hoskins concludes.
– Kathleen Maloney
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing the City of Cleveland and Nieemah Hameed: James Russell Jr., jrussell2@clevelandohio.gov
Representing Contessa Hoskins: Paul Flowers, pwf@pwfco.com
Can Columbus Appeal Preliminary Injunction Placed on New Gun Laws?
John Doe et al. v. City of Columbus et al., Case No. 2024-0056
Fifth District Court of Appeals (Delaware County)
ISSUES:
- Can the government immediately appeal a court’s preliminary injunction that prevents enforcement of a statute or ordinance?
- Does a court’s preliminary injunction preventing enforcement of a law cause irreparable harm to the government’s sovereign interests, allowing the government to immediately appeal the order?
BACKGROUND:
In December 2022, the Columbus City Council passed an ordinance that affected aspects of gun ownership. One law prohibits possessing high-capacity magazines – specifically, magazines that could hold 30 or more rounds of ammunition to use in a firearm. The other law prohibits negligent storage of a firearm at a person’s residence when the person should know a minor can gain access to it.
Five anonymous individuals filed a lawsuit against Columbus, the city attorney, and the city council president in the Delaware County Common Pleas Court. The individuals argued the new laws violate the right to bear arms in the Ohio Constitution and a state law about gun rights. The city asked the court for a change of venue to Franklin County Common Pleas Court to consolidate the case with a similar one in Franklin County. The Delaware County court denied the request.
The Columbus City Council amended the laws in February 2023 to provide immunity from prosecution until July 1 for people who already possessed the high-capacity magazines before the new laws were enacted. In March 2023, the anonymous plaintiffs amended their complaint and added a sixth anonymous person to the case.
The plaintiffs – five identified as John Doe and one as Jane Doe – asked the Delaware County court for a preliminary injunction to put a hold on the new laws during the litigation. The court granted the injunction. Columbus appealed to the Fifth District Court of Appeals. The Does argued the appeals court couldn’t hear the case because the preliminary injunction wasn’t a final and appealable order. In November 2023, the Fifth District agreed and dismissed the case.
Columbus appealed to the Ohio Supreme Court, which will review legal issues raised about whether the preliminary injunction could be appealed.
State Law Explains When Appeals Are Permitted
In order for an appeal to be allowed, a court order must be final as described in R.C. 2505.02(B). Based on the law, the preliminary injunction is a provisional remedy that will be considered final if two requirements are met:
- The order determined the action with respect to the preliminary injunction and prevented a judgment in the city’s favor.
- The city wouldn’t have a meaningful or effective remedy through an appeal after the final judgment in the case.
Prerequisites Fulfilled for Appeal of Preliminary Injunction, City Contends
Columbus argues the trial court's decision issuing the preliminary injunction “determined the action” because the court made a final decision about the preliminary injunction. And the possibility of the preliminary injunction being denied – which would be a decision in the city’s favor – can no longer occur, the city maintains.
Although some Ohio appellate courts have ruled the first hurdle can’t be met if the preliminary injunction maintains the status quo, the city counters that the status quo issue is related to the second hurdle, not the first. The first hurdle only involves the finality of the order, the city argues. “An order may be final whether it compels or inhibits action, or disrupts or preserves the status quo,” the city’s brief contends.
Ohio appellate courts have also found a preliminary injunction that preserves the status quo doesn’t clear the second hurdle because there is no irreparable harm, and a meaningful remedy is still available after the final judgment in the case, the city notes. In those situations, an immediate appeal of the preliminary injunction wouldn’t be permitted. The city describes that legal conclusion as “profoundly flawed.”
In this case, for example, the city explains that it won’t be able to enforce the ordinances while the injunction putting them on hold remains in place. The city argues the delay will cause irreparable harm to people. The gun-owning residents of Columbus won’t know if they need to comply with the laws or not, and Columbus residents will be at risk of preventable gun violence, the city maintains.
The city asks the Supreme Court to rule that when a trial court places a preliminary injunction on a properly enacted statute or ordinance, the government can always appeal the decision immediately. A preliminary injunction on a statute or ordinance is the type of rare circumstance that causes serious harm to citizens whom laws are crafted to protect, the city contends. It argues a later appeal and court decision can’t make the law work retroactively, and that delay will cause harm that can’t be remedied.
City Can Appeal After Case Merits Are Decided, Plaintiffs Argue
The Does note that the state legislature, not the Court, is the proper place for the city to ask to change R.C. 2505.02(B) to always permit a municipality to appeal a preliminary injunction. While the appeal in this case was pending, the General Assembly did just that for the state – amending the statute to allow immediate appeals of preliminary injunctions placed on state statutes or regulations, the Does point out. They note, however, that the change didn’t extend to municipalities. The Does state that municipalities must still meet the two prerequisites in R.C. 2505.02(B).
They argue that appellate courts look at three factors to decide whether a party contesting a preliminary injunction will have a meaningful or effective remedy if the party must wait and appeal after the final judgment in a case. The three factors in this case are whether the preliminary injunction preserves the status quo, the extent to which the preliminary injunction matches the final remedy, and whether granting the injunction causes irreparable harm to the city.
The Does contend that if a court decision on the preliminary injunction keeps the current state of the law – the status quo – then the party isn’t truly harmed. In this case, the preliminary injunction maintains the current, uncontested state of the law while a court reviews the legality of the new laws, the Does argue. They assert that the city can appeal and seek a meaningful remedy later, after the trial court rules.
There also is no irreparable harm because a preliminary injunction temporarily blocking the new gun ordinances doesn’t ring a bell that can’t be unrung, the Does maintain. They add that harm to the government is different than harm to citizens. The city is relying on an allegation that harm will be caused to citizens, who are a third party, but the city must show it was harmed, the Does argue. The government also argues the irreparable harm is its inability to act as the legislative representatives elected by the people, but the Does believe that view presumes the law in question is constitutional. They disagree. Their position is that the new ordinances are unconstitutional, and a municipality can’t be harmed when stopped from enforcing an unconstitutional law.
The Does argue that practical concerns arise if the Court rules to always allow immediate appeals of preliminary injunctions by the government. Such appeals will cause delays, prolonging final decisions from trial courts on the merits of cases, and appeals courts will have to rule on appeals of preliminary injunctions even if the record is limited and incomplete, the Does assert. Such a bright line rule doesn’t align with R.C. 2505.02(B), they conclude.
Additional Briefs Filed in Support of City
An amicus curiae brief supporting the arguments of the city of Columbus was submitted by the Ohio Attorney General’s Office. The attorney general will participate in oral argument before the Court, sharing the time allotted to Columbus.
Also supporting the city through amicus briefs are the Ohio Council of Churches and the village of Scio, Ohio.
– Kathleen Maloney
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing City of Columbus et al.: Richard Coglianese, rncoglianese@columbus.gov
Representing John Doe et al.: Robert Alt, robert@buckeyeinstitute.org
Representing the Ohio Attorney General’s Office: T. Elliot Gaiser, thomas.gaiser@ohioago.gov
Does Jail-Time Credit Reduce Waiting Period for Judicial Release Requests?
State of Ohio v. Aarin J. Clinkscale, Case No. 2024-0005
Tenth District Court of Appeals (Franklin County)
ISSUE: When evaluating requests for judicial release from prison, does jail-time credit reduce the required waiting period after all mandatory prison terms have been served?
BACKGROUND:
In September 2016, Aarin Clinkscale entered a plea in a Franklin County case involving the October 2014 armed robbery of a Dollar General store. Two people died. Clinkscale pled guilty to aggravated robbery, two counts of involuntary manslaughter, and a firearm specification. He was sentenced in November 2016 to a mandatory three years in prison for the firearm specification plus 11 years total for the other offenses. He was given credit for 762 days he had served in jail while his case was pending.
In June 2020, Clinkscale requested judicial release from the Franklin County Common Pleas Court. The county prosecutor argued Clinkscale wasn’t eligible for release until at least October 2022. The court denied Clinkscale’s request. When October 2022 arrived, he again filed a motion for judicial release. The prosecutor’s office stated it was mistaken in the earlier calculation. The office argued Clinkscale had to serve eight years in prison – three years for the mandatory firearm specification plus a five-year waiting period – before being eligible for release. Clinkscale’s attorney countered that the 762 days of jail-time credit (roughly 25 months) should apply against the five-year waiting period.
The trial court agreed and released Clinkscale, placing him on community control. The prosecutor appealed to the Tenth District Court of Appeals, which upheld the calculation and his release. The prosecutor appealed to the Ohio Supreme Court, which agreed to hear the case.
State Contends Waiting Period Not Reduced by Jail-Time Credit
R.C. 2929.20 allows certain offenders to apply for early release from prison. The Franklin County Prosecutor’s Office explains that based on Clinkscale’s sentence, state law makes him eligible for judicial release after a waiting period – no earlier than five years after the end of his mandatory three-year prison term for the firearm specification.
The prosecutor notes the Tenth District found that Clinkscale’s 11-year prison term for his nonmandatory sentences is adjusted to account for his 762 days of jail-time credit, so the credit also reduces his five-year waiting period. The prosecutor disagrees.
First, an offender’s mandatory prison sentences must expire, then the offender must follow the applicable waiting period in state law before seeking judicial release, the prosecutor argues. The prosecutor contends that applying jail-time credit to an offender’s prison term doesn’t mean the credit also applies to how the offender’s waiting period and eligibility are calculated for judicial release. Jail-time credit sometimes factors into whether a person is eligible for judicial release, but only if authorized by statute, the prosecutor maintains. However, when the offender’s eligibility requires waiting a fixed time period after serving the mandatory prison terms, the waiting period cannot be reduced by jail-time credit, the prosecutor asserts.
The prosecutor points to the Court’s opinion in State v. Moore (2018). The Court ruled that state law prohibits applying jail-time credit to reduce a mandatory sentence for a firearm specification. The Court then calculated the offender’s eligibility for judicial release based on the 180-day waiting period in the law that applied to his situation. The offender had 283 days of jail-time credit, but the Court didn’t reduce the 180-day waiting period by 283 days, the prosecutor maintains. The Court’s calculation indicates that waiting periods, including Clinkscale’s, can’t be adjusted for jail-time credit, the prosecutor concludes.
Offender Counters That Time Served in Jail Counts Toward ‘Stated Prison Term’
Clinkscale responds that jail-time credit applies to nonmandatory prison terms for purposes of judicial release. He notes that Moore involved a state law about mandatory prison terms for a firearm specification and explicitly prohibited applying jail-time credit to reduce the mandatory sentence. However, that law about firearm specifications isn’t relevant to this case, Clinkscale maintains.
He contends that the relevant statute allows an eligible offender to file a request for judicial release no earlier “than the date on which the offender has served five years of the offender’s stated prison term.” The definition of “stated prison term” in R.C. 2929.01 includes jail-time credit, he notes. However, for an offender serving a mix of mandatory and nonmandatory prison terms, the offender can apply for judicial release “not earlier than five years after the expiration of all mandatory prison terms,” according to the law. These requirements are explained all in one sentence in the statute, and the pieces work together, Clinkscale argues. If there is a mandatory sentence as part of an overall sentence of a certain number of years, the offender must clear two “hurdles” – the mandatory prison terms must have expired and the offender must serve five years of incarceration on the nonmandatory sentences, Clinkscale maintains.
After serving his mandatory three-year sentence, he argues he has served the required five additional years. The five years include the 762 days served in jail before he was sentenced plus the roughly three years he was imprisoned after the mandatory sentence expired, he contends. Because he completed the five-year waiting period, he was eligible for judicial release, he concludes.
Clinkscale also maintains that the prosecutor is making arguments now that weren’t presented to the Tenth District. He argues the Tenth District had no opportunity to review and rule on issues the prosecutor is now raising, and the Court should dismiss the case as improvidently accepted.
Attorney General Files Brief, Will Argue Before Court
The Ohio Attorney General’s Office filed an amicus curiae brief supporting the Franklin County prosecutor. The Court will allow the attorney general to participate in the oral argument, sharing the time allotted to the prosecutor.
– Kathleen Maloney
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing the State of Ohio from the Franklin County Prosecutor’s Office: Seth Gilbert, sgilbert@franklincountyohio.gov
Representing Aarin J. Clinkscale: Kort Gatterdam, gatterdam@carpenterlipps.com
Representing the Ohio Attorney General’s Office: T. Elliot Gaiser, thomas.gaiser@ohioago.gov
Attorney Arrested for Bringing Drugs Into County Jail Contests Length of Proposed Suspension
Disciplinary Counsel v. Eric E. Norton, Case No. 2024-1723
Cuyahoga County
A Cuyahoga County lawyer faces a two-year suspension from the practice of law, with one year stayed, following his conviction for bringing methamphetamine into the county jail.
Eric Norton objects to the length of the suspension proposed by the Board of Professional Conduct. Norton admits he violated ethics rules, but notes the Ohio Supreme Court imposed an interim suspension following his indictment in March 2023. Because he hasn’t been able to practice law for nearly two years, barring him from practicing for at least another year is unduly harsh compared to other lawyers sanctioned for substance abuse issues, he argues.
Norton’s objections to the suspension triggered an oral argument before the Ohio Supreme Court.
Attorney Arrested at Justice Center
In December 2022, Norton entered the Cuyahoga County Justice Center to meet with a client who was an inmate at the jail. While going through security, Norton realized he had a small plastic baggie containing meth with him. Before going to the jail, Norton went into the restroom and hid the drugs under a trash can. He then entered the jail to visit with his client.
Security officers observed his quick trip to the restroom and found the drugs. A county sheriff’s sergeant questioned Norton and seized his cellphone. A search of the phone revealed two images that constituted “illegal child abuse material.” Norton maintained the meth was for his personal use and he didn’t intend to smuggle it into the jail.
He asserted the illicit material on his cellphone was sent to him by his drug dealer. Norton said he communicated with his dealer through an app he rarely used that had an auto-download feature, and that he didn’t download the photos. He told officials how to locate his dealer and the source of the images.
Lawyer Completes Program To Avoid Criminal Convictions
Three months after the incident, Norton was indicted in March 2023 for five felonies, including drug possession, illegal use of a minor in nudity-oriented material, and possession of criminal tools. Norton requested intervention in lieu of conviction (ILC), which the trial judge granted. Norton pleaded guilty to two counts, drug possession and possessing criminal tools. The other charges were dismissed. When he completed the requirements of his ILC one year later, the two charges he pleaded to were dismissed.
The ILC required Norton to abide by several conditions, including following all rules prescribed by the probation department and abstaining from the use of illegal drugs and alcohol.
When Norton was indicted, the Office of Disciplinary Counsel asked the Supreme Court to place Norton on an immediate interim remedial suspension, which the Court granted. Norton continues to be under the suspension and cannot practice law. After Norton received ILC, the disciplinary counsel filed a complaint alleging professional misconduct against Norton with the Board of Professional Conduct.
Lawyer Fails To Comply With Program Requirements
Along with agreeing to abide by the terms of his ILC, Norton entered into a contract with the Ohio Lawyers Assistance Program (OLAP) to help with his substance use disorder. Norton states that he developed a drug addiction in 2020 and describes his recovery as “admittedly uneven.”
The Board of Professional Conduct reported that Norton tested positive for meth in April 2023, the month after he was indicted. He also reported relapsing in January, March, and July 2024. His OLAP monitor directed him to enter inpatient rehabilitation, but he refused, and his OLAP contract was suspended until February 2024. The contract was reactivated in June 2024 when he completed a treatment program. At the time of his August 2024 disciplinary hearing, his OLAP monitor reported that Norton wasn’t in compliance with his contract.
At his hearing, he presented a written report from his counselor, stating that he remained sober and could return to the competent, ethical, and professional practice of law. When questioned, Norton admitted he had not told his counselor about his July 2024 positive test for meth.
The board found Norton’s actions violated conduct rules by engaging in an illegal act that reflects on his honesty and trustworthiness, and conduct that adversely reflects on his fitness to practice law. The board also noted Norton received a six-month stayed suspension in 2007 for neglecting two client matters and other rule violations.
After comparing his history and actions to previously sanctioned attorneys, the board recommends that the Supreme Court suspend him for two years, with the second stayed with conditions. Norton must comply with his OLAP contract, submit to random drug and alcohol testing, comply with all court orders, and pay the costs of the proceedings.
Credit for Time Served Should Be Awarded, Attorney Argues
Norton maintains a fully stayed suspension is appropriate because he has been unable to practice for nearly two years and none of his actions harmed any clients. He observes that the Court has imposed less time out for other attorneys who committed more serious crimes and harmed clients by their drug use.
Norton also notes that as his case was pending, the Court ruled in Disciplinary Counsel v. Hartley that credit can’t be granted for time served under an interim remedial suspension. Prior to that case, the Court gave credit for time served for interim remedial suspensions. While the Court noted in Hartley that the disciplinary rules don’t specifically state credit can be granted for time served under an interim remedial suspension, they also don’t specify that the Court can’t grant time served, he asserts. He urges the Court to use its inherent authority to grant time served.
Norton also disputes that child pornography was found on his cellphone during the criminal investigation. He argues the board found no evidence the young female in the images was a minor and maintains the false accusations were discredited during the criminal case. The charge against him was dismissed, he notes, and he claims the inflammatory accusation was factored into the disciplinary process as a way to get the Court to judge him more harshly.
Actual Suspension Appropriate, Disciplinary Counsel Maintains
The disciplinary counsel argues that Norton’s inability to sustain a sufficient period of sobriety justifies the suspension. He continuously violated terms of his ILC and OLAP contract by using drugs, including testing positive one month before his disciplinary hearing, the office notes. Norton points to cases where attorneys with drug issues received shorter suspensions than the one proposed for him, but the disciplinary counsel notes the lawyers in those cases provided proof of sustained periods of sobriety.
The disciplinary counsel explains that the goal of attorney discipline is to protect the public, and argues Norton needs to maintain a more sustained period of sobriety to ensure potential clients aren’t harmed by his conduct.
– Dan Trevas
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing the Office of Disciplinary Counsel: Joseph Caligiuri, joseph.caligiuri@sc.ohio.gov
Eric E. Norton, representing himself: enortonlaw@gmail.com
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