Plaintiffs' Response to Defendants' Motion to Quash Subpoena of in the Alternative for a Protective Order

    EA

RALPH GINGLES, et a

Plai

v.

RUFUS EDMISTEN, eI

Defe

Plaintiffs, bl
action to enforce t

sentation. They as

Amendments to the U

of the VoEing Right

and 1973c ("The VoE

of the North Caroli

Congressional distr
Ehe apportionments

denying black citiz

and Ehat Ehe Genera

person-one voEe" pr

Discovery has

noticed the deposiE

Ehe Chairman of the

lative Redisrrictin

rhe Norrh Carolina

The subpoenae reque

DocumenEs of a

which relaEe E

Session of the

IN THE
UNITED STATES DISTRICT COURT

FOR THE
RN DISTRICT OF NORTH CAROLINA

MLEIGH DIVISION
N0. 8I-803-CrV-5

Eiffs, PLAINTIFFS' RESPONSE TO
DEFENDANTS' MOTION TO QUASH
SUBPOENAE OR IN THE ALTERNA-
TIVE FOR A PROTECTIVE ORDER1.,

dant s .

I. Introduct ion

ck ciEizens of North Carolina, bring this

ir right to vole and to have equal repre-

erE claims under the Fourteenth and Fifteenth
ited States ConstiEution and under $S2 and 5

Act of 1965, 3S amended, 42 U.S.C. S$f973

g Rights Ac.t"), challenging the apportionmenE

General Assembly and the UniEed StaEes

cEs in NorEh Carolina. Plaintiffs allege that
re adopted with the purpose and effect of

ns Ehe right Eo use Eheir voEes effectively
Assembly apportionments violate the "one

visions of Ehe equal protecEion clause.

onmenced. On December 3, 1981, plaintiffs

ons of and subpoenaed Senator Marshall Rauch,

Norrh Carolina SenaEe's Comnirtee on Legis-

and Senator'Helen Marvin, Ehe Chairman of

naEe's Commircee on Congressional RedisEricEing.

E thaE the senaEors bring to che depositions:

y kind which you have in your possession

Ehe adopEion of SB 3f3 t87l during Ehe 1981

NorEh Carolina General Assembly. This



request inclu
memoranda or o

any plan for a

I Congres s ional

Defendants mov

neither Senator can

mony of both Senato

Defendants' mo

Eions. Plaintiffs
Eiffs had taken the

fo Ilowing :

1. The natu

RedisEricting Cornmi

2. The sequ

Ehe redisEricEing 1

3. -- Normal pr

4.

5.

6.

The crite
FacEors n

The exist
from normal;

7. The exist

cial records which

or whole Senate deb

8. Their k

bers of the legisla
proposed apportio

9. The exisE

paragraph 8 above;

10. The exisr

involved in the pro

apporE ionment s .

Because Ehe Se

commiEEees which we

a recommended appor

has knowledge relev

s but is not limited to correspondence,

er writings proposing or objecting to

portionment of North Carolina's Senate

districts or any criteria therefore.
to quash the subpoenae on the grounds that

give any relevant testimony and that a1l testi-
s is privileged. Plainriffs oppose Ehis motion.

ion to quash is an objection to the entire deposi-

have not- asked particular quesEions. If plain-
depositions, the inquiry would have included the

e of Ehe Senatorrs role as Chairman of a

tee;

nce of events which lead to the enacEment of
gislat ion;

cedures for enacting Ehis type of legislation;
ia adopted by the redistricting cournittees;

rmally consiclered imporEanE in redisEricLing;

nce. of any substantive or procedural departures

nce of.documenEs, official records, oE unoffi-
ontain Ehe substance of conuniEEee, subcommiEtee

l-a.

ledge of the conEemporary staEements by mem-

ure.of the reasons for adopEing or rejecEing

nE plans;

nce of wiEnesses to statements as described in
nd

nce of ocher wiEnesses who observed

ess fhar led Eo the enactment of the

or were

challenged

ators were the Chairmen of the redisCricCing

e responsible for reporEing to Ehe full Senate

ionmenE for enactment, plainciffs believe each

nt Eo Ehese inquiries.

-2-



fs' allegations is that these apporLionments

them on the basis of race in violation of
clause of the Fourteenth Amendment. In

this claim, plaintiffs musE show that che

plans were conceive or maintained wiEh a purpose to discriminate.
Cicy of Mobile v. lden, 446 U.S. 55 (1980); Village of Arlinsron
Heights v. Iletropo tan Housing Corp., 429 U.S. 252 (L917);

Washington v. Davi , 426 u.s. 229 (1976).

In addition, is "rgu"b1" Ehat plainLiffs must show purpose

in order to prevail in their claims under 52

Act. See Mobile v. Bolden, supra, Washington

_, (4th Cir., #80-1277, November L7, 1981).

rE in Arlington Heights, supra, noEed Ehat

invidious discriminatory purpose was a moti-

v. Finley, F.2

One of plaint
discriminate again

the equal protecEi

order Eo prevail o

Eo diluEe black vot

of Ehe Voting Righr

The Supreme Co

"Determining wheEhe

vating factor deman

and direct evidence

Among the subjects

the Supreme CourE a

l. The speci

leilged de

Departure

Substanti

importanE

Conc empor

SenaEors Rauch

relevanE to each of

recognized, "In so

called Eo the stand

official action, . ..

from normal

departures

and

s a sensitive inquiry inEo such circumstantial
f intent as may be available." 429 U.S. aE 266.

f proper inquiry for proving inEenr lisred by

e:

ic sequence tof evenEs leading up Lo Ehe chal-
is ion;

procedural sequencei.

from factors usually considered

body, mir

ry staEemenEs by members of the decisionmaking

tes of its meetings, ots reports.
Arlin Eon Heiehts v l'leEro Housing Corp . , 429 U. S. aE 257 -268. See

also McMillan v. Es ernLia Co., 638 F.2d L239 (5rh Cir. 1981);

U.S. v. Citv of Par , 494 F. Supp. 1049, 1054 (N.D. Oh. 1980).

and }tarvin would be expecEed Eo give tesEimony

these inquiries. In addition, the Supreme Court

exrraordinary insEances Ehe members might be

aE crial to Eestify concerning the purpose of
" Arlington Heights, supra.



In addition,

in their Answer E

of the General Ass

rational sEate po1

"one person-one vo

of SenaEor Rauch,

Eive Redistricting,
staEe policies tha

Senate plan and wo

Ehat meE Ehese pol

These deposiEi

under Rule s 26 and

under the Federal R

II.

Rule 501 of th

Einent parE:

ExcepL as othe

UniEed SEares

prescribed by

authority, th

Stace, ots pol

by che princi

preted by the

reason and e

This rule app

Rule ll0l(c). Thu

Rauch and I'larvin i

che Federal Rules

is covered by Rule

q45 u.s. 360, 366 (

Defendants as

and Debate Clause

I{owever, the Speec

fendanLs have raised as the Fourth Defense

, "The deviations in the 1981 Apportionment

ly were unavoidable and are justified by

ies. " This defense relates to plaintiffsi
" claim. If allowed Eo take the deposition
airman of Ehe SenaEe Committee on Legisla-
plaintiffs would inquire abouE Ehe rational
caused the populaEion deviations in the

d inquire-about the exisEence of oEher plans

ies but had lorver population deviations.

ns and these lines of inquiry are permiEted

3 of Ehe Federal Rules of Civil procedure ancl

1es of Evidence.

E TESTIMONY OF SENATORS RAUCH
D },IARVIN IS NOT PRIVILEGED.

Federal Rules of Evidence provides, in per-

ise required by Ehe ConsEitution of Ehe

r provided by Acc of Congress or in rules

he Supreme Court pursuant to statutory
privilege of a witness, person, gov€Enment,

ical subdivision thereof shall be governed

les of Ehe common law as Ehey may be inEer-

ourts of the United Suaces in Ehe light of

rlence.

ies to discovery as well as Eo trial. F.R.Ev.,

, in order to determine if the testimony of SenaEors

privileged within Ehe meaning of Rule 26(b) of
f Civil Procedure, Ehe Court musE determine if ic
501 of Ehe Rules of Evidence See U.S. v. Gillock,
r980 )

rE a legislacive

f Arricle I, 56 of

and Debare Clause

privilege parallel to rhe Speech

the Uniced Scaces ConsEiEuEion.

applies only Eo members of che



United States Cong

sEate statute esta

the privilege unde

at 368, 374. Defe

Srates Constitutio

esEablishes a priv

Eifying. Thus the

vileged "by the pr

by Ehe courEs of t
F.R.Ev., Rule 501.

extended Eo Lhe te

of none. U.S. v.

defendants cite in

in which a state

tion, and- the Court

doing legislative

dicca, largely irr

and Debate Clause

helpful to analyze

IEs history is seE

L. Ed . 377 ( 188r) .

mentary provision

Ilembers of Parlia
t,ranslaEed into Eh

clause has thro pur

I.

ss, not Eo state legislators. Nor does the

lishing the privilege in state courts establish
Ehe Federal Rules. U.S. v. Gillock, 448 U.S.

dants do not cite any provision of the United

, Act of Congress, or Supreme Court rule which

lege vrhich exempts state legislators from tes-
urt must determine if the testimony is pri-

ciples of coutrnon law as they may be inEerpreted

United States in light of reason and experience.

Defendants ci no case in which legislative privilege is
imony of state legislators, and plaintiffs know

ndel, 415 F.Supp. L025 (D.Md. L976), which

support of Ehe evidenEary privilege, is a case

rnor asserted iunnunity from criminal prosecu-

eld thac Ehere was no inrnunity for governors

ts. The language quoted by defendants is only

evant to Ehe issue before that Court.

In order to ermine whether a privilege parallel to the Speech

uld be created for state legislaEors, it is
Ehe purposes of the Speech and Debate Clause.

ut in Kilbourn v. Thompson, 103 U.S. 168, 26

hostile j

he clause was patterned afEer an English parlia-
ich was designed Eo stop the crown from imprisoning

E for seditious libel. 26 L.Ed ar 390-391. As

American republican form of government, Ehe

ses:

Ehe members of Ehe co-equal legislauive
the federal governmenE from prosecuEion

bly hostile executive before a possibly

diciary, Kilbourn v. Thompson, supra; and

e Ehe independence of the legislacure by

e members from the burden of defending

in court and of ulrimace liabiliry.
v. Eastland, 387 U.S. 82 (L961).

To prese

freeing t

tl

To prote

branch o

by a pos

chemse lv
Dombrows

)

-5-



Neither of th

the Court.

Since a state

branches of the fe
apply. The Supre

supra, in holding t
federal prosecutio

and thar he had no

his legislaEive ac

similar in scope t
reaching the concl

The first rat
powers doctri
lege to stace

It requires

EhaL the Feder

to Ehe states,

monarchs exerc

however, in t
Federal Gover

dictates that

state exercis

we do not hav

and staEe sys

or DebaEe CIa

protecC feder

Since a staEe

federal legislacur

Federal CourEs, th

has no relation Eo

The second pu

thau che legislaco

licy. For rhis pr

e reason is applicable to the motion before

egislature is not one of the three co-equal

ral government, the first reason does not

CourE reached Lhis conclusion in U.S. v. Gillock,
t a state legislator is not irnmune from

for crimes committed in his legislative capacity

rivilege against the admission into evidence of
. Both would have been precluded if a privilege

the Speech and Debate Clause applied. In

ion the Court said:

nale, r€sting solely on the separation-of-

, gives no support to the granE of a privi-
egislaEors in federal criminal prosecutions.

ciEation of authorities for the proposition

I GovernmenE has limited powers wirh respect

unlike the unfettered authority which English

ised over the Parliament. By the same token,

se .areas whEte the Constitution grants the

nt the power to acL, the Supremacy Clause

federal enactmencs will prevail over competing

of power. Thus, under our federal structure,
che srruggles for power between Ehe federal

s such as inspired the need for the Speech

e as a resLrainE on the Federal Executive to
legislators. 445 U.S. at 370.

egislacure is not a co-equal branch wirh Ehe

which passed the Voring Righrs Act or wich the

first reason for rhe Speech and Debace Clause

his acEion.

ose for che Speech and Debare Clause is to assure

can be free to speek ouc rvithouc fcar of liabi-
osicion defendanEs cite Tu@, 341

-6-



U.S. 367 (195I) an

F.2d 4 (2d Cir. 19

However, in b

Ehe defendant. Th

rather a common 1

Eecting legislaci

are relieved of t
McCormack, 395 U.S

Plaintiffs do

Marvin 1iable. Ne

tion of having the

seek is to discove

Ehe claims or defe

In addition,

money damages. It
might inhibic a le
noE reasonable tha

stallce of legislaE

acEing in the inCe

seek money damages

I'larvin. Furthermo

enjoin a legislati

out thac the plain
comply with Ehe le

defense in contemp

asserE their claim

have no other reme

Finally, the

ancitheEical Eo th

che Vocing Rights

acCions rvhich sCat

v. Katzenbach, 383

After rejecci
legislacive priof

Ehe doctrine of com

-7-

Star Distributors Ltd. v. I,larino, 613

0).

th of those actions the state legislator was

cases discussed not an evidentiary privilege but

irununity from liability. The purpose of pro-
independence is fully protected if legislators
burden of defending Ehemselves. powell v.

486, 501-506 (1969).

not seek td hold either Senator Rauch

Eher is a defendanc. Neither is put

urden of defending the acrion. A11

whac evidence each has thac eicher

. s. 30r ( 1966) .

boch the separation of
lege, the Supreme Court

ty. The Courr scaced:

or Senator

].n a Posl-
p laint iffs

support s

Tenney, supra, the legislaEor was sued for
is reasonable Ehat possible financial liabitity
islator from acting his conscience. It is
merely having Eo disclose Ehe process or sub-

actions will prevenE a legislator from

sEs of the y'eople. Plainciffs herein do noE

from anyone, much less SenaEor Rauch or Senator

, in Star Distributors, supra, dt acEion Eo

investigation, the Court was careful to poinE

iff had another remedy available; to refuse to
islacive subpoena and asserE the claim as a

proceedings. In Ehis case, plaintiffs must

in a judicial proceeding or not ac all. They

cion of independence of state legislatures is
purpose of Ehe FourEeenth AmentmenE and of
t, boch of which have the purpose of limiring the

may cake. See, €.8., State of South Carolina

porvers and independence

in Gillock also considered



We conclude,

comiEy comman

close that wh

stake, zts in
statutes, com

erefore, that although principles
careful consideration, our cases

e important federal interests are

e enforcement of federal criminal
ty yields.

of

dis -

at

in Jordan v. Hutchi son, 323 F.2d 597, 600-601 (Arfr Cir. 1973),

in holding EhaE pl

Here we belie
privilege for
acEs would im

Federal Gover

with only spe

process. 445

In Gillock th

a criminal sEatute.

ConstiEuEion and o

This was -recognize

againsE the members

Icgislature seekin

racially moEivated

The CourE sEated, "

for sraEe inscituti
sion of citizen's
ciffsr.rereallowed
danCs. The intrus

In addition,

in an action under

is co be arvarded hi
i988. The reason

recognized the impo

as privaEe aEtorney

Ehe Conscicution.

that recognition

tate legislators

ir uhe legiuimate

nt in enforcing

lative benefit to

of an evidentiary

for their legislative
interest of the

its criminal statutes

the state legislaEive
. S. at 373.

importanE federal interest was enforcement of
However, enforcemenE of Ehe United States

the VoEing Rights Act is of equal importance.

by Ehe Court of Appeals for the FourEh Circuit

ntiffs, black lawyers, could maintain an action
of an investri.gatory commiEtee of the Virginia
Eo enjoin the legislaEors from engaging in
arassment of plaintiffs and their clienEs.

he concepE of federalism, i.e. federal respect

DS, will not be permitted to .shield an inva-

nsEitutional rights." Id at 601. Thus plain-
o maintain an action wirh legislators as defen-
n here is, of course, much more minor.

ngress has provided chat a prevailing plaintiff
he Voting Righrs AcE or under 42 U.S.C. S1983

attorney's fees. 42 U.S.C. SSf9731(e) and

r che fee award provision is that Congress

Eance of encouraging private cirizens, acEing

general, Eo enforce the VoEing Rights Act and

iddell v. Nacional Democraric Part

-8-

, 624 F.2d



539, 543 (5tn Cir.
trative News 5908,

represented are cen

DefendanEs' qu

(1978), Eo rhe effe

should not be great

inapposice. In But

tors should have Br

an individual's con

straEors. The ques

42 U.S.C. S1983 an

the Fourth and Fifr

The Court held that

That is a far cry

Congressional imrmrn

provision, is compa

creaEure of either

law.

Even if Ehere

tors, in this case

juscice. The courE

officials are in de

rhe extenE necessar

quesEion. see, e. g

U.S. v. I'landeI, 4l

However, in E

gaEion of Ehe truE

to prove an essent

ParE I, above, dis

clement of ac least

To hold one Ehe on

necessary and on t

is to make a mocke

Act.

980); 5 U.S. Code Congressional and Adminis-

910 (1976). The right ro vore and Eo be fairly
ral to our democratic government.

te from Bucz V_- lsqnomotr, 428 U. S. 478, 504

t that the irmnunity of a federal defendanr

r than the immuniLy of a state defendant, is
the question was whether federal administra-

ater innunity from liability for invading

titutional rights than do similar sEate admini-

ion involved comparing Ehe protection of
the Fourteenth Amendment to the protection of
Amendments to Ehe UniEed States Constitution.

the two could noE be rationally disEinguished.

the situation here in which the U.S.

ty, created by an unambiguous consEitufional

ed to the sEate legislator's privilege, a

tate statute or unprecedenEed federal common

s an evidentiary privilege for state legisla-
t musE give way i-n Ehe interest of Eruth and

have recognized that privileges of governmenE

ogaLion of the EruCh and must extend only to
to protect Ehe independence of the branch in
U.S. v. Nixon, 418 U.S. 683, 710 (L974)t

Supp. at 1030.

case privilege rvould be more than in dero-

; it would prevenc plaintiffs from being able

I elemenE of their claims. As discussed in
iminatory legislative purpose is a necessary

one and possibly Ewo of plainfiffs' claims.

hand chat evidence of legislacive purpose is
other Ehat ic is privileged and inadmissible

of both the Constitution and rhe Voting Righrs

-9-



This reasoning

Herbert v. Lando, 4

thaE a television n

privilege not to di
processes in a libe
recognized it would

prove actual malice

clude him from inqu

Eion. Id. aE 170.

The Court note

unfair Eo allow def

plaintiff from inqu

fal sehood.

Thus the Court

even one rooted in
stances, to a demon

In this case,

sEraEed a specific

Marvin have which

is, however, even s

Herbert, defendanEs

Secretary of Transp

for choosing Eo put

under Ehe circumsta

reasoned chat alcho

was no formal recor

case che privilege,

state statute.

The Supreme Co

i\uthoritv, supra, r
EesEimony about mot

Procecc OverEon Par

rt in Arlington Heights v. MeEropoliEan Housing

v. Volpe, 401 U.S. 402 (f971). 429 U.S. aE 268,

n. I8. In Overcon ark che Supreme Court considered whether Ehe

was recognized by the Supreme Court in
I U.S. 153 (f979). In Herbert the Court held

\^rs editor could not claim his First Amendment

close his sources, motivations, and thought

suit broughc by a public figure. The Courr

be grossly unfair to require the plaintiff to

or reckless disregard for the truth and pre-

ring to the defendanEs' knowledge and motiva-

, in addition, that it was particularly
ndants to testify to good faith and preclude

ring inEo direcE evidence of known or reckless

concluded that an evidenriary privilege,
the ConsEituEion, musE yield, in proper circum-

trated specific need for evidence.

s in Herbert y_:_lg!dq, plainriffs have demon-

eed for Ehe evidence which Senators Rauch and

y esEablish discriminatory purpose. This case

ronger than Herberr v. Lando because, in
asserted a ConsEituEional privilege. In Ehis

if one exisEs, comes only from common law or

cognized thaC in some circumsEances a member's

vaEion could be privileged and cired Citizens Eo

rtation could be examined as Eo his reasons

a highway Ehrough a park. The Courc held thac

ces in thac case he could be examined. The Court

gh ir was generally Eo be avoided, when Ehere

deEailing rhe reasons for rhe decision, iE is
ne the mental process of decisionmakers. Id. aC 420.permissible Eo exa

-10-



In chis case,

record adequate to

the legislaEors.

discovery regardi

to the subject mat

for objecEion Ehat

rhe rrial if Ehe i
Eo lead to the dis

defendants nrusE sho

irrelevanE and coul

view of Ehe broad t
motion will ordinar

Practice and Proce

The tesEimony

matter. Each senat

As discussed in Par

knowledge of the pr

Ehe criEeria used b

dered but rejecred,

che reasons that Eh

plainriffs challeng

supra, and Village

Corporacion, supra,

cricical Eo plainti

Defendancs ass

records speak for E

EesEimony is, there

records which conta

floor debate, Ehe c

posed apportionmenE

s in Overton Park, supra, there is no formal

termine the purpose, or even the process, of
direct examination is, therefore, permissible.

III. THE II.IONY OF SENATORS RAUCH AND MARVIN IS
RELEV TO THE SUBJECT MATTER OF THE ACTION.

Rule 26(b) pr ides in pertinent part, "Parties may obLain

any matter, not privleged, which is relevant
r in the pending acLion, ... IE is not ground

he information sought will be inadmissible at
ormaEion sought appears reasonably calculated
very of admissible evidence."

Thus, in orde to be enf if led to prevent the entire depositi-on,

Ehat the "informaEion sought was wholly
have no possible bearing on the issue, but

st of relevancy. at the discovery stage such

Iy be denied. " Wright and Miller, 8 Federal

re S2037.

f the Ei,ro senaEors is relevant to the subjecu

r was Chairman of a RedistricEing Cournittee.
. !'

I above, these senators are believed to have

cedures used for developing the apporEionment,s,

Ehe conrnittees, other plans which were consi-
and the documents and stat,ements which indicate
General Assembly adopted the proposals which

Under Ehe Supr Court decisions in City of Mobile v. Bolden,

f Arlingcoq Heights v. Metropolitan Housin

chis information is noE simply relevant, iE is
fs' abilicy to prove their claims.

rE thaE the legislarive hisEory and official
emselves and chat the individual senaEors'

ore, irrelevanc. Plainciffs know of no official
n any committee proceediogs, Ehe conE,ents of any

iceria used by Ehe comrnitEees, a lisu of pro-

available Eo bur rejected by Ehe committees,

ln

a

-tI-



asinD&W

is relevant.

or the contemporane

these records exist
Ehem so that plaint

Finally, defen

is not relevant whe

to use the testimon

defendanrs. Rathe

purpose. See Arli

Inc. Charlotte, 268 N.C. 577 (1966), cired by

us statements of the members. If, however,

perhaps Senators Rauch and Marvin can describe

ffs may discover them.

ants assert that the testimony of legislators
analyzing legislation. Plaintiffs do not seek

to interprer any ambiguity in the legislation,

, plaintiffs seek the testimony to establish
ron Heights, supra. To this end, the testimony

"Exceptions to

Iightly created nor

gaEion of the searc

"These rules s

tration, . .. to the

ceedings justly deE

The search for
Eo ascert a privile

of one of Lhe neces

plainEiffs Eo prove

abouE iE is neither

Plainriffs, th

Rauch and Marvin no

ary elemenEs of their claims.

purpose and to refuse to allow

IV. CONCLUSION

the demand for every man's evidence are not

expansively construed, for Ehey are in dero-

for truEh." Herbert v. Lando, 441 U.S. at 170.

all be consErued to secure fairness in adminis-

d that the truth may be ascertained or pro-
rmined. " Rule L02, F.R.Ev.

truth requires that defendants not be allowed

of the proof

To require

Ehem Eo inquire

which will deprive plainriffs

fair nor just.

refore, request that the subpoenae of SenaEors

be quashed.

rhis '3O 
aav of December, 1981.

LESLIE J. WINNER
Chambers, Ferguson, Warr, Wallas,

Adkins & Ful1er, P.A.
Suite 730 East Indepence PLaza
951 Sourh Independence Boulevard
CharlotEe, NorEh Carolina 28202
704/ 37 5-846L

Attorneys for Plainriffs

-L2-



I certify rha

To Defendants' Mot

A ProEective Order

enclosed in a post

office or official
of the United StaE

Mr. James Wallac
NC Attorney Gener
Post Office Box
Raleigh, NC 2760

This 70 aa

CERTIFICATE OF SERVICE

r have served Ehe foregoing plaintiffs' Response

n To Quash Subpoenae Or In The Alternative For

n all other parties by placing a copy thereof
e prepaid properly addressed wrapper in a post
epository under the exclusive care and custody

PoscaI Service, addressed to:
Jr.

I's Office
9

I^Iashington, DC 20006

of December, 198f

Mr. Jerris Leonard
900 tTuh Sr. NW
Suite 1020

-13-