Wednesday, August 31, 2016
State ex rel. James F. Cordell v. Pallet Companies, Inc. and Industrial Commission of Ohio, Case no. 2015-0163
Tenth District Court of Appeals (Franklin County)
Gary L. Bibler et al. v. Jill D. Stevenson et al., Case no. 2015-1737
Third District Court of Appeals (Hancock County)
In re C.C.S., Case no. 2016-0395
Tenth District Court of Appeals (Franklin County)
Disciplinary Counsel v. Ronnie M. Tamburrino, Case no. 2016-0858
Ashtabula County
Does Failing Post-Accident Drug Test Constitute Voluntary Job Abandonment?
State ex rel. James F. Cordell v. Pallet Companies, Inc. and Industrial Commission of Ohio, Case no. 2015-0163
Tenth District Court of Appeals (Franklin County)
ISSUES:
- Can termination of employment based on failure of a post-injury drug test constitute voluntary abandonment, making an injured worker ineligible for temporary total disability benefits?
- If an employee is already disabled by a workplace accident at the time of termination for violation of a drug-free workplace policy, is the employee eligible for temporary total disability benefits?
BACKGROUND:
James Cordell worked as truck driver for Pallet Companies in 2012 when he suffered a workplace accident that broke bones in his leg. He sought immediate medical attention and filed a workers’ compensation claim. Pallet Companies did not contest the claims to cover the medical injuries, which have increased over the years. Cordell was administered a post-accident drug test on the day of the injury and the results tested positive for marijuana and morphine (which was assumed to be from medication while he was being treated for the leg injuries.)
Cordell applied for workers’ compensation temporary total disability (TTD) payments to compensate from his time off of work because of the injury. Pallet Companies contested the payment asserting it terminated Cordell the day it received the positive drug test results and argued the Cordell had voluntary abandoned his position by testing positive. The company clarified that it does not believe the drug use was a factor in the accident causing Cordell’s injuries.
An Industrial Commission of Ohio district hearing officer found Cordell ineligible for TTD agreeing with the company that Cordell violated a known drug-free workplace rule. A commission staff hearing officer concluded Cordell was already injured at the time of termination and was eligible for TTD. The Industrial Commission found Cordell was not eligible and he sought a writ of mandamus from the Tenth District Court of Appeals to overturn the commission. A magistrate found Cordell was eligible, and the Appeals Court accepted the magistrate’s findings. Pallet Companies and the Commission appealed the decision to the Ohio Supreme Court, which agreed to hear the case.
Link Between Injury and Wage Loss Broken, Company Argues
Pallet pointed to Supreme Court precedent that finds eligibility for disability benefits is based on a causal link between the injury and loss of wages. The Court has found a voluntary action by an employee might sever the link by making the voluntary act, such a breaking a rule or being arrested, the cause of wage loss. The company noted a “voluntary act” may actually be involuntary, such as being sent to jail, and there need not be express intention to abandon the job for the commission to find the employee’s action constitute abandonment.
In Cordell’s case, the company and commission argue the moment Cordell ingested marijuana, he committed a rule violation that could lead to termination and at that time he voluntarily abandoned his job. The fact that the violation wasn’t discovered until the company mandated post-injury drug test took place doesn’t disqualify the company from declaring Cordell ineligible for TTD, Pallet maintains. The company cited the Tenth District’s 2009 State ex rel. Paysource v. Indus. Comm decision, which found a post-injury drug test can be the basis for a voluntary abandonment finding, and that the commission considered the violation of the company policy was the cause of the loss of earning and not the injury. Pallet argues Cordell’s situation is similar.
“His intentional violation of the rules occurred when he set foot on company property that day. By all accounts, he should have been fired at the time he ingested those illegal substances. He had no right to any earnings that day because of his intentional conduct. That link was, in fact, severed, yet not discovered until after his injury. His injury did not repair the breach between his injury and his loss of earnings, it just brought it to light. He had no expectations to future earnings because each day he came to work after using drugs, he was forfeiting his right to earn,” Pallet’s brief states.
Had Cordell not tested for positive for drug he would have been able to return to work for the company once he recovered from his work injuries, and he would have been eligible for TTD until he went back to work, the company concluded.
Commission Raises Public Policy Concerns
In its brief, the Industrial Commission argues that providing Cordell TTD benefits “sends a message that pre-injury illegal behavior is rewarded and this creates bad public policy.” The commission admonishes the 10th District for discounting its own decision in Paysource, but instead relying on the Supreme Court’s 2007 State ex rel. Gross v. Indus Comm decision. The commission claims the Tenth District interpreted Gross to mean that a post-injury drug test can’t be the basis for declaring a worker voluntarily abandoned his job. The Commission asserts the appellate court focused too much on the timing of the termination, which occurred after the injury, rather than the time that Cordell violated the workplace rule. The commission points out that it in most cases the use of an illegal drug taken before an injury will not be discovered until after the injury, and refusing to consider pre-injury conduct when awarding TTD is bad public policy.
Timing of Injury Determines TTD Eligibility, Cordell Submits
Cordell argues the law is clear that an injured worker who is unable to return to work can’t voluntarily abandon the position and is entitled to TTD compensation. Citing the Tenth District more recent reviews of Industrial Commission rulings, Cordell maintains that violating company policy may be ground for termination, but a pre-injury infraction of the rule can’t be grounds for abandonment and TTD can’t be denied if worker was disabled by the injury at the time of termination.
Cordell notes the Court has ruled that a post-injury voluntary act can sever the link between the injury and the loss of wages, but has never ruled that compensation can be denied based on pre-injury conduct discovered after the injury occurred; Cordell argues that it was not the violation of the work rule that prevented him from working, but the injury.
Cordell cited the Tenth District’s decision that found the company had submitted him and others to regular drug tests since he worked there, which he passed, and could have fired him anytime for the failure. However, the employer must show an injured worker was impaired by the illegal substance at the time of the accident if it wants the commission to deny TTD benefits.
Friend-of-the-Court Brief
An amicus curiae brief supporting Cordell’s position was submitted by the Ohio Association of Claimants’ Counsel and the Ohio Association for Justice. The group notes there is no need for the commission to rely on the theory of voluntary abandonment since the General Assembly has already enacted an exception to TTD eligibility for pre-injury drug use. The brief states that R.C. 4123.54 allows for denial of the compensation if the employer can show that the illegal substance was the proximate cause of the injury.
- Dan Trevas
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing Pallet Companies Inc.: Christen Hignett, 614.628.6880
Representing The Industrial Commission of Ohio from the Ohio Attorney General’s Office: Lisa Miller, 614.466.6696
Representing James Cordell: Craigg Gould, 614.445.6123
Is City Liable for Traffic Accident Attributed to Obstructed Stop Sign?
Gary L. Bibler et al. v. Jill D. Stevenson et al., Case no. 2015-1737
Third District Court of Appeals (Hancock County)
ISSUES:
- Does the word “mandated,” as used in R.C. 2744.01(H), mean any traffic-control device approved for use by the Ohio Manual of Uniform Traffic Control?
- Are local authorities required by R.C. 4511.65 to erect stop signs, yield signs, or other traffic-control devices at all intersections with state routes under their jurisdictions?
- Are traffic-control devices required by R.C. 45211.65 part of the public roads as defined in R.C. 2744.01(H)?
BACKGROUND:
On May 27, 2011, Gary Bibler was driving his pickup truck east on Ohio Route 568, which is also Sandusky Street in the city of Findlay. Jill Stevenson, driving her car north on Wilson Street, approached a stop sign at the intersection of Sandusky and Wilson streets. Stevenson drove across Sandusky Street without stopping or yielding, and her vehicle collided with the truck driven by Bibler, who had the right of way. The accident resulted in property damage and injury.
Stevenson claimed that she didn’t see the stop sign until it was too late to stop. A police officer from the city of Findlay testified in a deposition that in his opinion, the stop sign was obstructed by the foliage of a tree that was growing in the right of way, and that the tree should be removed. He also referenced a similar accident at the same spot the previous summer.
Pickup Driver Sues for Negligence
Bibler sued Stevenson and the city of Findlay alleging she was negligent for failing to stop and the city was negligent for allowing the tree to grow in a right of way and obscure the stop sign. The city asserted that, as a political subdivision, it’s entitled to statutory immunity. The city maintained that the law placed a burden on Bibler to show a recognized exception to the immunity provision.
At trial, the Hancock County Common Pleas Court found for the city in summary judgment and dismissed all claims against the city. Bibler appealed to the Third District Court of Appeals, which affirmed the decision of the trial court. Bibler filed an appeal with the Ohio Supreme Court, which accepted the case.
At issue is the matter of sovereign immunity for municipalities when they are conducting governmental and proprietary actions – an issue that has been debated for decades – and when exceptions to immunity are to be applied.
Differing Views on City’s Immunity
Bibler contends that maintenance of streets and roads fall under a city’s governmental duties and that traffic-control devices, such as stop signs, must be placed at intersections with state highways.
The city of Findlay, in asking the Court to affirm the Third District’s decision, contends in its brief that immunity is the rule and liability is the exception, and that the General Assembly two decades ago extended immunity to political subdivisions due to an “overflow of lawsuits” that alleged “negligence or nuisance.” Among the cases cited by the city is the Ohio Supreme Court’s decision in Franks v. Ohio (1994), which addressed “failure to maintain traffic signs already in place.”
Was Stop Sign Mandated?
Regarding the issue of whether a stop sign is a mandated traffic-control device, Bibler’s brief states that the answer is yes because R.C 2744.01(H) “means any device approved for use by the Ohio Manual of Uniform Traffic Control Devices.”
The city counters that the statute “clearly and unambiguously provide(s) immunity for negligence in connection with the erection or maintenance of stop signs …” and that the Court should make “neither additions nor subtractions” from the law.
Stop Signs as Part of Highway
Bibler also argues that stop signs must be erected by political subdivisions at state highway intersections in their jurisdictions under R.C. 4511.65 and that “the Legislature surely didn’t intend to exclude them (stop signs) as part of the highway.”
But Findlay maintains that in R.C. 2744.02(A)(1), “the General Assembly provided blanket immunity declaring that political subdivisions are not liable in civil damages for injury, death or loss allegedly caused by an act or omission in connection with a governmental or proprietary function.”
“Shall” Versus “Should” Versus “May”
Bibler notes that the traffic manual regulates the use and maintenance of stop signs and states that stop signs “should be used if engineering judgment indicates” a condition that calls for a sign. The manual gives examples, including the “intersection of a less important road with a main road”; a street that enters “a through highway or street”; a “signalized area” that lacks a signal; and places where “high speeds, restricted views or crash records indicate a need for a stop sign.”
Findlay responds that the manual “does not mandate” a stop sign at the intersection of Sandusky and Wilson streets and that “under R.C. 4511.11, local authorities must use only those traffic-control devices according to the (OMUTCD) manual’s instructions.”
“The OMUTCD regulates the installation of traffic control devices in terms that are mandatory, recommended, or those which are discretionary,” the city writes. Standards using the word “‘shall’ are considered mandatory,” the city explains, while the word “should” is advisory, and “may” carries no requirement. Since the manual wording identified by Bibler spells out that a stop sign “should be used if engineering judgment indicates,” then the manual simply is imparting advice not creating a requirement.
- Edward Miller
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing Gary L. and Yvonne Bibler: William E. Clark, 419.423.0242
Representing the City of Findlay et al.: Donald Rasmusson, 419.429.7338
Was Mother Under Duress When She Permanently Surrendered Rights to Her Child?
In re C.C.S., Case no. 2016-0395
Tenth District Court of Appeals (Franklin County)
ISSUES:
- When deciding whether a parent has voluntarily relinquished custody of a child, is it imperative that all steps be taken to ensure that the relinquishment was given without duress?
- Is there a fiduciary relationship between a parent placing a child for adoption and an adoption agency in which the agency has the duty to protect the parent?
BACKGROUND:
On March 15, 2014, Caroline Stearns called Adoption by Gentle Care, a Columbus adoption agency, to inquire about their services. Pregnant and approaching her April due date, Stearns spoke with a Gentle Care social worker about her options. Stearns was living in Dublin with her five children and her boyfriend, Jeff Griffith. Stearns had become pregnant by another man, and she indicated Griffith told her she couldn’t bring the new baby into the home because he wasn’t the father. Griffith also isn’t the father of Stearns’ other children.
Stearns and the social worker met at a restaurant on March 27, 2014, to further discuss adoption. The social worker provided pamphlets and forms concerning various types of adoption. Stearns went into the hospital on March 31 for a scheduled cesarean section and gave birth to a boy, identified as C.C.S. The next day, she left the hospital and contacted Gentle Care to set a time to sign the adoption paperwork for a permanent surrender of the child.
Two Gentle Care social workers met with Stearns at her home on April 4 to complete the paperwork, and most of the discussion was recorded by the social workers. Stearns signed the permanent surrender agreement, which stated that all of her rights as a parent would end by signing the document. She also signed an “affidavit of relinquishment,” which noted her right to an attorney before making the decision, her right at that time to refuse to place the child for adoption, and that the surrender was “final and irrevocable.” Gentle Care then placed the child with an adoptive family.
Around April 12 or 13, Stearns contacted her Gentle Care social worker asking for her son back and to revoke the surrender agreement. Gentle Care denied the request. She then petitioned the Franklin County Probate Court to withdraw her consent to the adoption. When the adopting parents became aware of her desire to have her child returned, they gave him back to Gentle Care. The boy was placed in foster care.
Mother Alleges Duress in Agreeing to Adoption
In July 2014, Stearns filed a case in Franklin County Juvenile Court, asserting that the permanent surrender agreement should be rescinded because she signed it under duress. During the trial, Gentle Care filed a motion to dismiss the case, which the court granted.
Following an appeal and a remand, Stearns appealed a second time to the Tenth District Court of Appeals, which affirmed the trial court’s dismissal of the case. The appeals court reviewed the “totality of the circumstances” and decided that “ample” evidence supported the validity of the surrender agreement.
Stearns appealed to the Ohio Supreme Court, which agreed to review the case.
Parties Cite 1952 Case that Addresses Duress
Both sides refer to a 1952 Ohio Supreme Court decision, Tallmadge v. Robinson, which discussed the legal concept of “duress” as it related to a family dispute about rightful heirs to an inheritance. In Tallmadge, the Court stated, “The real and ultimate fact to be determined in every case is whether the party affected really had a choice; whether he had his freedom of exercising his will.” In addition, “[i]n determining whether a course of conduct results in duress, the question is not what effect such conduct would have upon an ordinary man but rather the effect upon the particular person toward whom such conduct is directed, and in determining such effect the age, sex, health and mental condition of the person affected, the relationship of the parties and all the surrounding circumstances may be considered.”
Mother Maintains Surrender Agreement Wasn’t Voluntary
Stearns asserts that the permanent surrender agreement is invalid because it was made under duress and undue influence, and was involuntary. She notes she was weeks away from her due date when Griffith told her she couldn’t bring the baby home. To keep her newborn son, she states that she would’ve had to find another home for her children and they would be deprived of their father figure and provider with whom they had lived for six years. Because of Griffith’s pressure, she stresses that she had no choice but to give up the child for adoption. She never would have surrendered her son otherwise, she argues. She adds that her duress was heightened because the biological father wanted her to have an abortion and she was on pain medication following the C-section when she signed the agreement.
Stearns also maintains that Gentle Care and its social workers had a duty to act in her and the child’s interests, and to protect their rights, during the adoption process. This created a fiduciary relationship in her view. The social worker was aware of Griffith’s demand and violated the agency’s position of trust and its policy to not allow permanent surrenders of a child under those conditions, Stearns argues. While she told the social worker she was 100 percent sure about the adoption, Stearns explains that she also told the social worker she was being forced to give up the baby and had no choice.
Stearns also contends that Gentle Care didn’t discuss all the options available to her, such as temporary placement, before she signed the surrender document, and she accuses the agency of acting only to protect the substantial fee it would earn for the adoption.
Adoption Agency Argues It Informed Mother of All Options
Gentle Care responds that Stearns initiated contact with the agency about a possible adoption and to schedule the surrender of the newborn. She was capable of understanding her choice, and her decision was informed and voluntary, the agency asserts. Stearns, her aunt, and the hospital’s social worker all conveyed to the agency that Stearns “was resolute in her intent to surrender,” the agency brief states.
The agency explains that the trial court concluded: Stearns wasn’t a person who was easily pressured; the agency discussed and provided documents about alternatives to a permanent surrender of her child, and Stearns’ state of mind was reflected by her answers on the recording indicating the voluntariness of her decision the day she signed the adoption paperwork. The trial court’s rejection of Stearns’ duress claim was supported by “competent, credible evidence,” the agency argues, adding that the facts don’t describe “extreme circumstances” that warrant undoing the signed permanent surrender.
The agency points out that the social worker met with Stearns more than three days before the child’s birth, explained the mother’s options and the adoption process, and waited at least 72 hours after the birth to execute the adoption agreement. The social worker and the agency fulfilled their duties according to the law, the agency maintains. In addition, it contends that Ohio law has never recognized a fiduciary relationship between a birth mother and an adoption agency and, even if there were such a requirement, the agency met its duties, fully informed Stearns of her adoption choices, and acted in her interest by implementing her wishes.
“Ms. Stearns, like most if not all birth mothers considering surrender, faced challenging circumstances and a difficult choice, but that does not mean that her decision was not a product of her own free will,” the agency wrote.
Organizations Submit Friend-of-the-Court Briefs
The Ohio Birthparent Group and its founding director, Professor Kate Livingston, have submitted an amicus curiae brief supporting Stearns. They raise concerns about Gentle Care’s application of the law and its policies to Stearns’ case, contending that the discussions with her were inadequate.
The American Academy of Adoption Attorneys has filed an amicus brief supporting Gentle Care, arguing that a reversal would allow any birth parent to revoke a voluntary surrender of a child for adoption by claiming duress or difficult circumstances. That view would create uncertainty for all future adoptions, the group contends.
- Kathleen Maloney
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing Caroline Stearns: Steven Hillman, 614.766.6346
Representing Adoption by Gentle Care: Jon Oebker, 216.696.4884
Attorney Discipline
Disciplinary Counsel v. Ronnie M. Tamburrino, Case no. 2016-0858
Ashtabula County
In a disciplinary case stemming from the 2014 election for judges on the Eleventh District Court of Appeals, the Board of Professional Conduct has concluded that Ron M. Tamburrino, a candidate in the race, approved and ran two television ads containing false statements, violating two judicial conduct rules.
Though the panel that reviewed the case proposed a stayed six-month suspension, the board noted Tamburrino has repeatedly refused to admit the content was false and continues to assert that the ads were appropriate. Given his perspective and its concern about “the chilling effect” false ads could have on the functioning of the judicial branch, the board recommends a one-year suspension with six months stayed.
Teenage Drinking Ad
Tamburrino, who is seeking election to the Eleventh District again this year, ran against Judge Timothy P. Cannon in the 2014 race. On Oct. 28 or 29, an ad approved by Tamburrino began to air on local television. The ad showed a judge in a courtroom serving what seems to be alcohol to children. Along with words appearing on the screen, the narration stated:
“Everyone knows that a judge would never serve alcohol to kids in a courtroom. But appellate judge Tim Cannon did something almost as bad. In the case State versus Andrews, Cannon ruled that cops couldn’t enter a house to arrest a parent who was hosting a teenage drinking party, because he felt teenage drinking wasn’t a serious crime. Cannon doesn't think teenage drinking is serious. What else does he think isn’t serious? We can’t afford Tim Cannon’s bad judgment. Elect Ron Tamburrino to the Eleventh District Court of Appeals.”
Judge Cannon wrote a concurring opinion in the Andrews case, which involved the suppression of evidence obtained during a warrantless search by police of a Geauga County home, where teenagers were allegedly drinking at a party. The homeowner was charged with contributing to the delinquency of a minor.
The board explains in its report that the court’s majority opinion and Judge Cannon’s concurring opinion concluded the police should’ve first obtained a warrant before searching the home. In neither opinion was there language indicating that teenage drinking isn’t a serious crime or that police couldn’t enter a house or arrest a parent hosting a teenage drinking party, the board notes.
Judge Cannon instead acknowledged concerns about underage drinking and stressed that he didn’t want to impede law enforcement’s efforts to address underage drinking. He added that the alleged activity was a misdemeanor, which he determined is a factor for police to consider when deciding whether exigent circumstances exist to justify an intrusion and search without a warrant.
The board concluded that Tamburrino’s ad contained several “patently false” statements and that Tamburrino knew they were false or acted with reckless disregard for whether they were false.
Travel Expense Disclosure Ad
The second ad, first broadcast in mid-October 2014, stated that “Cannon won’t disclose his taxpayer-funded travel expenses.” The board found that Tamburrino never asked Judge Cannon to disclose his travel expenses, nor did anyone else during the campaign. In addition, the board noted that the Ohio Supreme Court, not the Eleventh District, paid Judge Cannon’s expenses, which then had no effect on the appeals court’s budget. The implication that Judge Cannon didn’t produce his expense reports in violation of the state’s public records law was false, the board concluded.
“Tamburrino’s use of false statements in both of the ads to unfairly denigrate Judge Cannon is inconsistent with the independence, integrity, and impartiality of the judiciary,” the board wrote.
Candidate’s Objections
Tamburrino objects to the board’s conclusions and recommended sanction, arguing that all charges should be dismissed. He maintains that the ads’ statements identified by the board as false are instead true.
In the ad involving the Andrews decision, the majority opinion and Judge Cannon’s concurring opinion both ruled the police shouldn’t have entered the house without a warrant, Tamburrino states. The ad said that Judge Cannon concluded “cops couldn’t enter a house to arrest a parent who was hosting a teenage drinking party,” not that Judge Cannon said police could never enter a house to arrest any parent hosting an underage drinking party, Tamburrino asserts. Judge Cannon also wrote that he didn’t want the decision to deter police from taking action if an officer observed a “serious misdemeanor offense.” Judge Cannon then considers teenage drinking not to be a “serious misdemeanor offense,” and the ad fairly summarizes the judge’s view, Tamburrino alleges.
Tamburrino contends he has as much right as the dissenting justice in the case to criticize Judge Cannon’s ruling. Tamburrino also asserts that his ad was an expression of free speech protected by the U.S. Constitution. Citing a 1996 federal court opinion and a 2002 U.S. Supreme Court decision, Tamburrino argues that judicial candidates have the same free speech rights as other candidates for elected office.
As far as the “won’t disclose” ad, Tamburrino argues he meant that the Eleventh District wouldn’t post its budget, including expenses such as Judge Cannon’s travel costs, on the court’s website. While Judge Cannon didn’t refuse any direct request to disclose the information, Tamburrino was of the opinion that the judge wouldn’t publish such information in the future. This opinion is protected under the U.S. Constitution’s First Amendment, Tamburrino concludes.
He adds that the Sixth U.S. Circuit Court of Appeals ruled earlier this year in Susan B. Anthony List v. Driehaus that Ohio laws barring false statements in campaign materials during political campaigns were unconstitutional. The board found Tamburrino violated a judicial conduct rule that mirrors the statutes struck down in Anthony, he notes. In his view, Ohio’s disciplinary process for the legal profession regarding campaign speech is also unconstitutional.
Disciplinary Counsel’s Positions
The Office of Disciplinary Counsel, which filed the complaint against Tamburrino with the board, counters that the In re Campaign Complaint Against O’Toole 2014 decision from the Ohio Supreme Court presented a sound analysis upholding the constitutionality of the current judicial conduct rule prohibiting false campaign speech by judicial candidates. The Anthony ruling didn’t affect the O’Toole decision, the disciplinary counsel asserts.
In discussing the ads, the disciplinary counsel’s brief states that the teenage drinking piece “twist[s] Judge Cannon’s discussion of the Fourth Amendment into a referendum on Judge Cannon’s personal views regarding teenage drinking.” In the context of the ad specifically citing the Andrews ruling, and the larger context of the judicial campaign, the statements made “could only be interpreted as fact,” not as opinion, the disciplinary counsel wrote.
The disciplinary counsel adds that the “won’t disclose” ad also “can only be interpreted to mean that Judge Cannon refused to disclose his taxpayer funded travel expenses after having been asked to do so,” which was untrue.
Noting shared concerns with the board, the disciplinary counsel, however, suggests a stayed six-month suspension and maintains that any stayed discipline would be adequate to protect the public and deter this type of conduct in the future.
- Kathleen Maloney
Docket entries, memoranda, briefs (including amicus briefs), and other information about this case may be accessed through the case docket.
Contacts
Representing Ronnie M. Tamburrino: Donald Brey, 614.221.2838
Representing the Office of Disciplinary Counsel: Joseph Caligiuri, 614.461.0256
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