Honorable Bob Bullock 

Secretary of State 

Austin, Texas 78711 

Opinion No. M- 1039 

Honorable Clyde Slavln 

County Attorney of Donley County 

Clarendon, Texas 79226 

Nonorable Jack K. Williams 

President, Texas A & M University 

College Station, Texas 77843 

Honorable Robert S. CalGert 

Comptroller of Public Accounts 

Austin, Texas 78711 

Honorable Charles R. Barden 

Executive Secretary 

Texas Air Control Board 

Austin, Texas 78751 

Gentlemen: 

Re: Saope, constltutlonallty, 

and effect of House 

Bill 203, 62nd Leg., 

Reg. Seas., 1971, 

amending Articles 

6252-9, V.C.S., the 

Texas Ethics Code. 

We have received five opinion requests relating to the 

scope, constitutionality, and effect of House Bill 2O3,1 . 

amending Article 6252-9, Vernon’s Civil Statutesi? the Texas s 

Ethics Code. We have concluded that House Bill 203 1s 

unconstitutional in its entirety for reasons we will 

hereinafter set forth in detail before passing upon 

those questions which we hold remain governed by the valid 

provisions of Article 6252-9, the original Texas Ethics 

Code enacted in 1957$ 

‘Acts 1971, 62nd Leg., Reg. Sess,, ch. 962, pp,2906-12. 

2Acts 1957, 55th Leg., ch. 100, p. 213-15. 

-5073- 
Hon. Bob Bullock, et al, page 2 (M-1039) 

Two lnqulrles submitted by the Honorable Bob Bullock, 

Secretary of State and by the County Attorney of Donley 

County asked whether Sections 4(0 and 4(e) of House Bill 

203 are constitutional. Section 1 (0) reads as follows: 

"On or before the last Friday of April of 

each calendar year, each elected state official 

and appointed state official and each state 

employee or legislative employee if such leglslative or state employee's annual salary from 

the State of Texas exceeds $11,000, shall file 

with the Secretary of State a financial statement which shall be a public record covering 

sources of income, acquisitions, investments, 

and divestments obtained or consummated during 

the preceding calendar year of the lndlvldual 

filing the statement, and his spouse, and shall 

be In the following form: 

FINANCIAL STATEMENT 

For the period 

Name 

Address 

to 

Office or position in the government of the 

State of Texas 

For your information: The interests or items 

required to be disclosed in this statement Include 

those of yourself and your spouse. The term 

business entity means any person, corporation, 

firm, partnership, joint stock company, 

receivership, trusteeship, or any other 

entity recognized by law through which business 

for profit may be conducted. 

1. List of all sources of income to be ldentlfled by employer and/or if a person is selfemployed, by the nature of his business. 

2. List of real property acquired or sold during 

the reporting period. 

-5074- 
Hon. Bob Bullock, et al, page 3 (M-1039) 

3. List of all stocks, bonds, or other commercial 

paper acquired or sold during the reporting period. 

4. List of all other assets acquired during 

the reporting period. 

5. List of all liabllltles originally incurred 

durlng the reporting period to any institution 

regulated or controlled by the State of Texas 

or the Federal Government. 

I swear that the Information 

given above is true to 

the best of my knowledge 

and belief. 

Date Signature 

n 

Sectlon4(e) reads as follows: 

"If any person covered under this Act or such 

person's spouse or a dependant 1s an officer, 

agent,flnancial associate or member of, or owns 

a substantial interest, directly or beneficially 

in any activity which 1s subject to the jurisdiction of a regulatory agenCy of this State, a 

record of such relationship or substantial 

interest shall be made a matter of public record 

by filing with the Secretary of State annually 

by January jlst." 

The Secretary of State further asked whether, if 

Sections 4(o) and (e) are unconstitutional, he has any 

duties under the provisions of Section 4(q) of Senate Bill 

15, Acts 1971, 62nd Leg., 1st C.S., p, 3442, ch. 10. 

Section 4(q) reads as follows: 

"All political candidates for positions and 

offices covered by this Act shall file with the 

Secretary of State a financial statement which 

-5075- 
Hon. Bob Bullock, et al, page 4 (M-1039) 

shall be a public record covering sources of 

Income, acquisitions, investments, and dlvestments obtained or consummated during the preceding 

calendar year of the lndlvidual filing the statement, and his spouse, and shall be in the form 

prescribed in Subsection (0) of this section. 

The financial statement shall be filed within 

15 days after the filing deadline for the election 

In which the lndlvidual is a candidate." 

The caption of House Bill 203 gives no notice that any 

ofthe persons covered by Its provisions are required to 

file any kind of financial interest disclosure. It is 

difficult to see how such detailed financial interest 

disclosures as those immediately set forth above in Sections 

4(e) and 4(o) could have been anticipated by a caption 

which provided merely for "establishing standards of 

conduct", "prohibiting certain acts", 'making procedures 

In the State Ethics Commission", and "providing penalties". 

The caption of Senate Bill 15 does declare that it relates 

'to the filing of financial statements by candidates for 

certain offices...." It falls to give any notice that 

said financial statements shall embrace the assets belonging to a candidate's spouse asls required by Section (q). 

We therefore think that there has been no compliance with 

Article III, Section 35 of the Texas Constitution, which 

requires that the subject of all acts shall be stated in 

the caption, and that these provisions must fall for this 

reason.4 

However, if such financial interest disclosures be 

deemed ancillary or consistent with the prescribing of 

-5076- 
Hon. Bob Bullock, et al, page 5 (M-1039) 

standards of conduct for persons covered by the Act, there 

are other compelling reasons which necessitated holding 

the foregoing sections of House Bill 203 unconstitutional. 

A case squarely in point is City of Carmel-by-the-Sea 

v 

466 P. 2d 225 (Callfornla 1970). The Court held 

lnva Id a similar financial lnterest public disclosure 

statute directing every public official and candidate 

to file as a public record a statement describing the 

nature of his investmentsin excess of $lO,OOO.OO, as we11 

as those owned by his spouse or a minor child. The court 

recognized as in the public Interest proper legislative 

concern about possible conflicts of interest between public 

employment and private financial interests, but held that 

the disclosures required by the statute were unconstitutionally 

overbroad. At pages 230-31, the court said: 

"The concept of personal liberties and fundamental human rights entitled to protection 

against overbroad intrusion or regulation by 

government is not limited to those expressly 

mentioned in either the Bill of Rights or 

elsewhere In the Constitution, but Instead 

extends to basic values llmplIclt in the 

concept of ordered liberty' (Palko v. State of 

Connecticut (1937) 302 U.S. 319, 325, 58 S.Ct. 

149, 152, 82 L.Ed. 288) and to 'the basic 

clvll rights of man.' (Skinner v. State of 

Oklahoma (1942) 316 u.s.,535, 541, 62 S.Ct, 

1110, 1113, 86 L.Ed; $625.)... 

"Certain of the protected rights and liberties 

not specifically mentioned in the Constltulon 

have been viewed as falling within the penumbra 

or periphery of the Bill of Rights, and others 

as being fundamental and basic personal rights 

'retained by the peo le' within the meaning of 

the Ninth Amendment. 3 

484-485 of 381 U.S., at pp. 1681-1 2 of $4 :'I&., 

(Griswold, ;;pra, 

and at pp. 487-499, at pp" 1683-1690 of first 

concurring 0pinlon.J * + 

"As plaintiff city points out, the right of prlvacy concerns one's feelings and one's own peace 

of mind (Fairfield v. American Photocopy etc. CO. 

(1955) 138 Cal.App.2d 82, 86, 291 P. 2d 194), and 

certainly one's personal financial affairs are 

an essential element of such peace of mind. 

-5077- 
Hon. Bob Bullock, et al, page 6 (M-1039) 

Moreover, personal financial affairs are clearly 

more than the 'adjunct to the domestic economy' 

referred to in Edwards, supra ( .11&g of 71 A.C., 

80 Cal. Rptr. 633, 458 P.2d 713 P ; Instead they 

would appear to constitute the primary supporting 

pillar of that economy. In any event we are 

satisfied that the protection of one's personal 

financial affairs and those of his (or her) 

spouse and children against compulsory public 

disclosure is an aspect of the zone of privacy 

which is protected by the Fourth Amendment and 

which also falls within that penumbra of constltutional rights into which the governmentmay not 

intrude absent a showing of compelling need and 

that the intrusion is not overly broad. &?/here 

fundamental personal liberties are involved, 

they may not be abridged by the States simply on 

a showing that a regulatory statute has some 

rational relationship to the effectuation of a 

proper state purpose. "Where there is a 

significant encroachment upon personal liberty, 

the State may prevail only upon showing f subordinati% Interest which is compelling. 

~I~tCitiO~~,.~ The,law must be shown "necessary, 

and not merely rationally related to , the accompllshment of a permissible state ,pollcy." BltationsJ' 

(Griswold v. State of Connecticut, 

479, 497, 85 s.ct. 1678, 1689). lT%%%a%~ %"' 

legislative abridgement must be viewed in the 

light of less drastic means for achieving the 

same basic purpose.' Shelton v. Tucker, 

suora, 364 U.S. 479, 81 S.Ct. 247, 252, 

5 L.Ed.2d 231.)" 

The court held that the disclosures required by the 

statutes were unconstitutionally overbroad and intruded into 

irrelevant, private financial affairs of the parties covered 

by the statute, and were In no way limited to such holdings 

as might be affected by the duties or functions of a particular office. The court took cognizance of the fact that 

a requirement of relevant disclosures of investments or 

assets whlch.bear a relationship to the valid purpose of 

preventing conflicts of interest on the part of public 

officers and employees could be, and had been in many cases, 

validly drawn. At pages 233-35, the court said: 

-5078- 
Han, Bob Bullock, et al, Page 7 (M-1039) 

I, 

*,. Those various enactments can be roughly 

divided Into two categories. The first group 

simply restricts public officials and employees 

from entering into transactions which may cause 

a conflict of Interests. The second group 

requires an actual disclosure of any conflict 

of interest relevant to the official duties 

ofthe officer or employee. Fmphasis supplIedJ 

*** 

"Thus although there are lndlvidual differences 

between the disclosure laws discussed above, 

there is clearly one common element in all of 

them.. The regulations prohibiting conflicts 

of interest and requiring the disclosure of 

financial holdings are limited to only those 

transactions nor holdings which have some 

relationship, direct or Indirect, to the official 

duties of the public officer or employee. .., 

*++ 

'We are satisfied that in light of the principles 

applicable to the constitutional rights here 

involved, no overriding necessity has been 

established which would justify sustaining a 

statute having the broad sweep of the one now 

before us, which, as stated, would Intrude 

alike into the relevant and the irrelevant 

private financial affairs of the numerous 

public officials and employees covered by the 

statute and is not limited to only such holdings 

as might be affected by the duties or functions 

of a particular public office. . ..Furthermore. 

the price which the state and the local agencies 

of government would be expected to pay, should 

the.constltutionalIty of such a statute be 

sustained, in the exodus of competent officials 

from public office and the displritlng effect 

on the willingness of other competent citizens 

to take on the burdens of public office, far 

outweighs any legitimate public interest to 

be served." 

. 

-5079- 

. 
Hon. Bob Bullock, et al, page a (M-1039) 

It Is evident that Sections 4(e), (o), and (q) of 

House Bill 203 and Senate Bill 15 are neither broad 

prohibitions of conflicts of Interest nor requirements 

of actual disclosure of such Interests as are per se in 

conflict with the office or position held or sough= 

Further, we think that the unconstitutionally broad 

requirements of the financial and personal relation 

disclosure provisions of Senate Bill 15 and of House 

Bill 203 are such an integral part of the regulatory 

scheme of House Bill 203 as to eliminate any possible ^ . . _ . ^ . 

severance 0s tnese unconstItuciona1 portions srom r;ne 

balance of the bill. Texas Highway Commission v. El 

Paso Bldg. & Const. Trades Council, 149 Tex. 457, 234 

d 85 (195 - Simmons v. Arnhlm, 11 

26 (lz20); g?ntral Ed 

0 Tex.309, 220 S.W. 

ucation Agency v. I.S.D. of City 

of El Paso,>2 Tex. 5b, 254 S . W . 2d 357 (1953) . 

S.W. 

We might be inclined to make a further effort In 

this regard were we not faced with an additional unconstltutional section. Section a of House Bill 203 provides 

for the establishment of a State Ethics Commission which 

IS t0 COnSiSt of three members of the Senate, elected by 

the Senate; three members of the House of Representatives; 

two persons appointed by the Chief Justice of the Supreme 

Court of the State of Texas; two persons appointed by the 

Presiding Judge of the Court of Criminal Appeals of the 

State of Texas; and two persons appointed by the Chairman 

of the State Judicial Qualiflcatlons Commission. 

(h) and (I) of Section 8 read as follows: 

Paragraph~s 

"(h) The commission shall have full investigatory 

powers and subpoena powers; however, no subpoena 

may be issued pertaining to any investlgatlon 

until the commission adopts a resolution by a 

majority vote of the members of the commission 

defining the nature and,scope of the investigation. 

"(I) Actions of the commission require the 

concurrence of majority of the members, including 

the concurrence of two members from the same 

House when the action pertains to that House or 

a member of that House." 

-5080- 
Hon. Bob Bullock, et al, page 9 (M-1039) 

It Is evident from reading the foregoing that, In 

the exercise of the Commission's full Investigatory 

powers, the balance against a legislative investigation 

or the investigation of a member or members of the 

Legislature 1s weighted against such Investigations as 

opposed to other Investigations authorized by the Act. 

This is so because of the fact that the 12 members of the 

Commission, six members are members of the Legislature, 

who, by voting In unison, could prevent obtaining the 

majority vote necessary to Institute a legislative 

investigation or the investigation of a member or members 

of the Legislature. Further, there Is the requirement 

of the concurrence of two members of the same house 

when the investigation pertains to that house or a 

member thereof. 

Although the foregoing Is only a possibility, it 

amounts to a protection-not accorded others covered 

by the provisions of the Ethics Code and Is therefore 

violative of the equal protection clauses of both the 

Federal and State Constitution. It clearly operates 

unequally on members of the various classes within 

the scope of the Act, and Is sufficient to render the 

entire bill unconstitutional. It cannot be obliterated 

from the Act since it goes to the enforcement of the Act, 

Itself, and would leave no plan of operation for the 

Ethics Commission which it purports to create. As a 

result, it would be necessary to attempt a wholesale 

rewriting of this portion of the state, a legislative 

function which no court would undertake to do. Texas 

Highway Commlsslon v. El Paso Bldg. & Const. Tramouncll, 

49 Tex. 457, 234 S.W.2d 857 (1950). 

Another reason for holding House Bill 203 unconstltutlonaI 

Is that Its Section 4, 5 and 6 are wholly Invalid because 

these penal provisions violate Articles 6 and 7 of the 

Texas Penal Code, The new statute is vague, IndefInIte and 

therefore void. Overt v. State, 260 S,W, 856 (1924); 

Ex Parte Meadows, 109 S . W . 2d 166 1 (1937); S ortatorlum 

v. State, 115 S.W.2d 483 (Tex.Clv.App. 3.93875isnE.). 

The Comptroller of Public Accounts has asked three 

questlons relating to Section 4(k) of House Bill 203, which, 

in view of the Invalidity of 4(k), are governed by Section 

3(i) of Article 6252-g as enacted In 1957. Section 3(i) 

reads as follows: 

-5081- 
Hon. Bob Bullock, et al, page 10 (M-1039) 

"No officer or employee of a state agency nor 

any firm, association, corporation or other business 

entity In which he Is a member, agent, or 

officer, or In which he owns a controlling 

interest, shall sell goods or services to any 

person, firm, association or corporation yhlch 

Is licensed by or regulated in any manner by 

the state agency In which such officer or 

employee serves." 

The Comptroller's questions are the following: 

"1 . A is a large department store which Is 

Issued a sales tax permit and a store tax 

license by the Comptroller, and makes regular 

sales tax reports and payments. 

Can an employee of this department work for 

A as a part-time sales clerk exercising no 

degree of management? 

2. B Is a gun shop which Is Issued a sale~s 

tax permit, a store tax license and a pistol 

dealers license by the Comptroller. 

Can an employee of this department sell his 

private gun to B? 

3. C is a used car dealer whlch'is issued a 

store tax license by the Comptroller. 

Can an employee of this department sell his 

private automobile to C?" 

In deciding these questions, we note at the outset that 

Texas is among many states that have enacted a wide 

variety of statutes regulating specific public servants 

In specific areas of potential conflict of public and 

private Interests. Such statutes are valid where the 

publlc'lnterest Is sufficient to justify the particular 

requirement or prohibition, and there Is no unwarranted 

-5082- 
Hon. Bob Bullock, et al, page 11 (M-1039) 

interference with fundamental individual rights or 

constitutional guarantees of personal freedom.5 

The common every day occurences typified by the 

Comptroller's three submitted questions must have 

arisen and been approved by the Comptroller In the absence 

of any Conflict of public and private interests on Innumerable 

occasions during the fourteen years.,he has been charged 

with the duty of complying with the provisions of the 

Ethics Code. Since there has evidently been no doubt 

as to the propriety of the types of employee actions 

covered In the submitted questions prior to the 1971 

amendment, we must assume that the conslstant departmental 

construction has been to permit such activities absent 

forbidden conflicts of Interest. We are In accord 

with this departmental construction. 

The general Declaration of Policy contained In 

Section 1 of the 1957 Act declares that the public 

servants covered by the Act shall have no Interest of 

any kind, direct or Indirect, or engage In any 

business transaction or professional activity, or 

Incur any obligation of any nature which is In substantial 

conflict with the proper discharge of his duties In the 

public Interest. It announces that It is for the 

Implementation of such policy and to strengthen the 

faith and confidence of the people of Texas In their 

government that the Code of Ethics Is enacted. It 

states that the Code shall serve not only as a guide for 

official conduct of the State's public servants, but 

also as a basis for dlsclpline for Improper conduct. 

5All men have certain basic or natural rights which 

are inherent and Inalienable, are generally enumerated In 

a Bill of Rights of life, and are protected against 

Invasion of government or any branch thereof. 16 C.J.S. 

975. Constitutional Law § 199. Rights of life, liberty 

and property are Inherent rights merely reaffirmed In the 

Constitution and restricted only as voluntarily surrendered 

by the people and their government. 12 Tex. Jur. 2d 432, 

Constitutional Law $ 85, Rhlne v. McKlnney, 53 Tex. 

354 (1880). 

-5083- 
Hon. Bob Bullock, et al, page 12 (M-1039) 

Eased primarily upon the Declaration of Policy as a declaration 

of legislative intent, and predicated upon an initial fact 

finding that In each of the submitted question8 there is no 

conflict between public and private interests, we answer 

all three questions in the affirmative. 

In holding that anemployee of the Comptroller's 

Department may work as a "part-time sales clerk exercising 

no degree of management" in the employ of "a large department store which Is issued a sales tax permit and a store 

tax license by the Comptroller,..,", we realize that the 

literal language of the prohibition of SecUon 3(l) prevents 

the employee from selling his services to a business entity 

subject to the Comptroller's regulations. We are cognizant 

of the elementary rule of law that there Is no room for 

construction of plain and unambiguous Xanguage In a 

staute.7 Nevertheless, there are numerous well-established 

exceptions to this rule; One of these Is that departure 

from the literal meaning of a staute will be made where 

such departure Is consistent with and essential to the 

effectuation of legislative intent.8 

We do not think that the..Leglslature Intended to 

absolutely prohibit State employees from holding any 

addltlonal jobs with a business entity subject In any way 

to regulation by the employing State agency. It Is 

common knowledge that a State employee might need to 

augment his Income by additional efforts on his part elther 

to raise his standard of living, or, In some cases, even 

6This office does not pass upon questions of fact. 

7 53 Tex. Jur.2d 174, Statutes, 8 123, and authorities 

cited therein. 

(185~~ ~%%I%% 

State v. Delesdenler, 7 Tex. 76 

ttT?H b k R 1 I Texas and quoted 

with akproxal the followl~or~to~ageul&~C6: 

1 A thing which Is within the Intention of 

the makers of a statute Is as much within the 

statute as If It were within the letter;' 'and 

a thing which Is within the letter of the 

statute Is not within the statute unless It be 

within the Intention of the makers.' (9 Bat. 

Abr., 247. )" 

-5084- 
. 

. 

Hon. Bob Bullock, et al, page 13 (M-1039) 

to exist. Certainly, it has never been the policy 

of this State to discourage legitimate diligence and 

Industry in Its citizens. It would be most unreasonable 

to conclude that the Legislature Intended any such prohibition where the second employment did not affect the 

employee's compliance with the highest standard of ethics 

In the proper discharge of his duties to the State. The 

Legislature Is never presumed to Intend an unreasonable, 

absurd or unjust result If the statute may be otherwise 

construed; ard the courts will depart from the literal 

Import when necessary to preserve legislative Intent,9 

Likewise, under the above-stated rule, we hold that 

the Legislature did not Intend for Section 3(i) to 

prohibit the employee from selling a gun to a gun shop 

holding a sales tax permit, a store tax license, and a 

pistol dealer's license; nor from selling his car to a 

used car 'dealer having a atore tax license. If additional 

facts exist which lndlcate a conflict of Merest even 

In such Isolated transactions, a contra result would, 

of course, be reached. 

Finally, the answers to all the Comptroller’s questions 

are necessitated by the rule that a statute must be sustained 

as constitutional wherever possible.10 If Section 3(l) 

constituted a blanket prohibition against the right of the 

Individual employee to work elsewhere or transact business 

dealings with his own property, It would be blatantly 

discriminatory as to him, and a denial of due process and 

equal protection of the laws In violation of both the State 

and Federal Constitutions. A statutory classification which 

953 Tex. Jur. 2d 134-135, 187-189, 195-197, Statutes, 

88 126, 134,, 135, and authorities cited therein. 

1053 Tex. Jur.2d 225-227, Statutes, B182, and authorities 

cited therein. State v. City of Austin, 160 Tex. 348, 331 

S.W.2d 737, 747 tl9bO). 

-5085- 
.- . 

‘. . 

Hon. Bob Bullock, et al, page 14 (M-1039) 

singles out certain individuals, or classes of individuals, 

and deals with them arbitrarily and unreasonably in a manner 

unjustifiably different from other Individuals, has many 

times been held In violation of the 14th Amendment to 

the Federal Constitution, which specifically pertains to 

the deprivation of life, liberty and property without due 

process of law.11 And, generally, the term 'liberty" 

as used In the Bill of Rights in 

12 

arious state constitutions, 

Including the Texas Constitution, Is as comprehensive 

as the same term used In the due process clause of the 

14th Amendment.I3 Many Texas cases recognize these 

fundamental principles as preserved by our Bill of Rlghts.14 

The Texas AIrControl Board asks whether its Board 

members or employees may have dealings with companies regulated 

by the Board. Texas Agricultural and Mechanical University 

asks essentially the same questions about faculty members, 

staff and employees of the University and Its various 

services. These questions must first be determined by 

the employing State agency in the manner heretofore 

discussed In answering the questions submitted by the 

Comptroller. 

The same rule of reasonable analysis of the facts 

pertaining to the QrOQOSed activity of any State Officer 

or employee would apply to persons connected with Texas 

Agricultural and Mechanical University, Texas Air Control 

Board, Donley County Hospital Board Directors, or Notaries 

Public. The employing State agency, or those to whom 

supervision has been confided, must determine whether the 

I116 C.J.S. 976, Const. Law, § 199. 

12Art. I, Sec. 19. 

%3 c, J. s. 988, Const. Law, § 202. 

14 12 Tex. Jur. 2a 432-434, Const. Law. $ 86-89. 

-5086- 
. - 

. .’ 

Hon, Bob Bullock, etal, page 15 (M-1039) 

facts of any particular case warrant a finding of fact 

that the activities of an individual reflect a conflict 

of interest under Section 3(l) of the 1957 statute. 

-SUMMARYHouse Bill 203, 62nd Leg., 1971, Reg. Sess., 

and Senate Bill 15, 62nd Leg,, 1st C,S., 1971, 

ch, 10, p. 3442, which sought to amend Article 

6252-9, V,C,S. (Texas Ethics Code) are both 

unconstitutional. The 1957 Ethics Code, as It 

existed before these attempted amendments by the 

62nd Legislature, Is In force as the law of 

Texas, No financial interest disclosure 

reports are required under existing law. 

Under the 1957 Ethics Code, whether conflicts 

of interest exist are fact determinations for 

those who exercise validly delegated supervisory powers* 

Prepared by Roger Tyler and 

Marietta McGregor Payne 

Assistant ,Attorneys General 

APPROVED: 

OPINION COMMITTEE 

Kerns Taylor. Chairman 

W. E. Allen, Co-Chairman 

Houghton Brownlee 

Gordon Cass 

Rex White 

Bob Lattlmore 

-5087- 
. . . 

Hon. Bob Bullock, et al, page 16 (M-1039) 

SAM MCDANIEL 

Staff Legal Assistant 

ALFRED WALKER 

Executive Assistant 

NOLA WHITE 

First Assistant 

-5088-