June 2, 2023
Board of Ethics for the City of Lansing c/o Brian P. Jackson, Chief Deputy City Clerk City Hall
124 W. Michigan Ave., 9th Floor
Lansing, Ml 48933
BY EMAIL ONLY
RE: Request to Dismiss Ethics Complaint
Dear Ethics Board Members:
This office represents Council Member Jeffrey Brown with respect to the Ethics Complaint (the "Ethics
Complaint") filed against Council Member Jeffrey Brown on March 27, 2023. Dr. Brown, a minister who holds a Doctor of Ministry in Christian Leadership from Kingdom University International, is an unapologetic advocate for the homeless, for the poor, and for anyone else who just needs a helping hand. Because Dr. Brown is currently performing missionary work in the Philippines, he was not present for the May 30 Special Meeting of the Ethics Board and will also miss the June 6 Meeting of the Ethics Board.
A rookie member of the City Council, Dr. Brown is not afraid to take on the status quo to benefit the citizens of Lansing. As the saymg goes, "No good deed goes unpunished" and Dr. Brown's good deeds to protect Lansing are certainly being punished by the mere filing of a frivolous Ethics Complaint signed by the Mayor and a majority of the City Council. While it appears that Dr. Brown has ruffled some political feathers here, the Ethics Complaint represents an abuse of the ethics process. Therefore, as discussed in more detail below, each of the three allegations of the Ethics Complaint should be dismissed by this Board because:
l. Allegations #1 and # 2 of the Ethics Complaint are false, as confirmed by the investigator in the report
(the "Report") dated May 12, 2023 and submitted to this Board on May 30, 2023 (see Report, Pages 1415).
2.Allegation #3 of the Ethics Complaint is false because Dr. Brown never applied for funding with Congresswoman Slotkin's office. Although the investigator admitted being given conclusive documentation that this application was NOT completed (see Report, Pages 10, 13, Exhibit D), the investigator ignored this definitive evidence without explanation.
3.The investigator found that Dr. Brown did not commit any ethical violations as contained in Allegations #1 and #2 of the Ethics Complaint; however, the investigator went beyond the allegations contained in the Ethics Complaint to recommend ethical violations by Dr. Brown based primarily on unsubstantiated hearsay evidence from a single interview which was contradicted by the other nine interviews (see Report, Page 15). Not only is the investigator's recommendation here contrary' to the overwhelming evidence in her own Report, but neither the investigator nor this Board have the authority to go beyond the four corners of the Ethics Complaint to find an ethical violation against Dr. Brown.
Accordingly, Dr. Brown's reputation is being threatened because of flimsy, speculative, and nonexistent hearsay evidence. We greatly appreciate the Board's willingness to review Dr. Brown's side of this serious matter. As the remainder of this Request demonstrates, Dr. Brown committed no ethical violations as alleged in the Ethics Complaint or even as referenced in the Report.
THE ETHICS COMPLAINT CONTAINS NO ALLEGATIONS OF PERSONAL BENEFIT TO DR.
BROWN AND THE REPORT DID NOT FIND OTHERWISE
According to Section 290.01 of the Lansing Code of Ordinances, the pupose of the ethics provisions is to prevent personal gain:
"290.01. Declaration of purpose; findings.
The People of the City of Lansing declare public office and public employment are held as a public trust and any effort to realize personal gain through official conduct is a violation of that trust. It is the finding of Council that all City Officers and employees are tmsted with public ftnctions for the good of the public, that their official powers are fiduciary and are to be used to protect, advance and promote the public interest and not their own; that the people of the City want legislation to ensure that conflicts of interest of officers and employees are eliminated to the fullest extent possible and that violations of rules of ethical conduct are appropriately corrected." (Emphasis added)
As observed by the State Board of Ethics:
"The concept of personal gain or benefit requires some substance, some definable or tangible gain or benefit." Russell v. Dempsey, ETH 78-ED-3 (July Il, 1978). Consequently, where there is no personal gain or benefit, ethics complaints are dismissed. See, for example, Moore v. Davis, ETH 78-ED-I
21, 1978); Moore v. Wissman, ETH 78-ED-2 (Febtuary 21, 1978).
Significantly, the Ethics Complaint filed against Dr. Brown makes no allegations that Dr. Brown received any personal gain or benefit.
In Allegation #1, Dr. Brown is falsely accused of asking "Mr. Deehan's company or the mayor [to] agree to pay first and last month's rent for a constituent's apartment."
In Allegation #2, Dr. Brown is falsely accused of requesting that "Mr. Fleming find money in a LHC ' slush fund' and use it to pay various tenant related fees" for a housing assistance recipient named "Ms. Verlinde".
In Allegation #3, Dr. Brown is falsely accused of "requesting grant funding on behalf of the City of Lansing."
Similarly, the Report contains no findings that Dr. Brown received any personal gain or benefit.
As incredible as it sounds, the Ethics Complaint is actually attacking Dr. Brown for attempting to obtain assistance for a constituent (see Allegation #1), a housing assistance recipient (see Allegation #2), and the City of Lansing (see Allegation #3) ---nothing for his personal gain or benefit. Although one would expect that a City Council Member should take action to benefit citizens in need, the Ethics Complaint filed against Dr.
Brown takes a different view. Because the Ethics Complaint filed against Dr. Brown makes no allegations that Dr. Brown received any personal gain or benefit and neither does the Report, for this reason alone, the Ethics Complaint must be dismissed.
THE FEW "FACTS" REFERENCED IN THE ETHICS COMPLAINT ARE DEMONSTRABLY FALSE
In Allegation #1, Dr. Brown is falsely accused of asking "Mr. Deehan's company or the mayor [to] agree to pay first and last month's rent for a constituent's apanment."
As the Report concluded, both Jeff Deehan and Dr. Brown expressly denied that Dr. Brown made these statements. See Report, Page 14.
Consequently, Allegation #1 is false.
In Allegation #2, Dr. Brown is falsely accused of suggesting that "Council Member Brown 's decisions and any further support by voting yes on LHC resolutions that may come before City Council was dependent" on "Mr. Fleming find[ing] money in a LHC 'Slush fund' and use it to pay various tenant related fees" for a housing assistance recipient named "Ms. Verlinde". As the Report concluded, both Doug Fleming and Dr. Brown expressly denied that Dr. Brown made these statements. See Report, Pages 14-15.
Consequently, Allegation #2 is false.
In Allegation #3, Dr. Brown is falsely accused of "requesting grant funding on behalf of the City of Lansing."
This allegation is outrageous. Dr. Brown is the Chair of the Ad Hoc Committee on Homelessness and
Solutions. After Dr. Brown was approached to apply for grants by Congresswoman Slotkin herself at an MLK luncheon (see Report, Page 9), he initiated the process to obtain a federal grant to address homelessness for the people of Lansing. These noble actions were not done in secret. In fact, Dr. Brown initiated this process with the Mayor's knowledge and assistance. As the Ethics Complaint itself demonstrates by the mere fact that the Mayor was copied on Dr. Brown's initial email on March 9, 2023 to Representative Slotkin's office, the Mayor was fully advised at all times. Moreover, what the Ethics Complaint fails to disclose is that Dr. Brown's initial email on March 9, 2023, was a request or application for funding. Instead, as Representative Slotkin's office stated in a subsequent March 14, 2023, email:
"Congratulations on clearing this initial hurdle, but there is still much work to be done. That work begins with completing the full application for your project. The full application will require letters of community support, estimated project dates, and a full cost estimate, among other requirements." See Attachment l .
Significantly, the Repon acknowledges the receipt of this March 14, 2023 email (Attachment #1) (see Report,
Page 13 and Exhibit D to the Report); however, the Report ignores without explanation that this March 14,
2023 email (Attachment #1) demonstrates that Dr. Brown never applied for the funding as referenced in Allegation #3 and in the Report. Further, as the basis for its finding that Dr. Brown committed an ethical violation here, the Report relies upon the actions of City Council taken on March 27 2023• however, as the March 14, 2023 email (Attachment #1) demonstrates, Dr. Brown terminated any efforts to apply for funding on March 14 2023. Therefore, the basis of the Report's finding is flawed in many respects.
Moreover, it is deeply troubling that the Report could conclude any unethical conduct by Dr. Brown based on the following uncontradicted statements included within the Report itself:
"Council Member Brown stated that he never actually applied for the funding, he just sent proposals indicating interest in order to initiate the process. Once the Mayor indicated he would not support his proposals, Council Member Brown did not complete the application process.
Council Member Brown stated that he " 100%" believed he was following the process by working with the Mayor's office. He stated, "If I didn't, why would I cc the Mayor if I was trying to be ethically
Therefore, the Report confirms that Dr. Brown thought that he was acting within the rules, and once he became aware that the Mayor would not support these proposals, he immediately discontinued any efforts to obtain funding for Lansing's homeless from Representative Slotkin. What else could Dr. Brown have done under the circumstances?
Consequently, Allegation #3 is outrageous.
Accordingly, the few "facts" set forth in the Ethics Complaint filed against Dr. Brown are demonstrably false.
THE REPORT INAPPROPRIATELY INVESTIGATED MATTERS BEYOND THE ETHICS
COMPLAINT ITSELF TO INCORRECTLY FIND AN ETHICS VIOLATION AGAINST DR. BROWN
As a prerequisite to the jurisdiction of this Board, Section 290.03(a) of the Lansing Code of Ordinances requires:
"Any person may file a signed written complaint with the City Clerk alleging a violation of Chapter 5 of Article V of the City Charter or of this chapter."
Unless a person complies with Section 290.03(a) above, this Board must dismiss a complaint for lack of jurisdiction pursuant to Section 290.03(a)(5)(a) of the Lansing Code of Ordinances. The Lansing Code of Ordinances clearly indicates that the RepoWCity Attorney's analysis is limited to the "complaint" itself. Section 290.03(a). Similarly, the Lansing Code of Ordinances clearly indicates that the Board's opmion is limited to the "complaint" itself. Section 290.03(d). Even the Report itself states:
"1 was assigned to investigate the complaint." (See Report, Page I)
However, it is beyond dispute that the Report went well beyond the allegations of the Ethics Complaint. According to Page 15 of the Report:
"However, while I do not find that Council Member Brown engaged in the conduct as specifically alleged in paragraphs I and 2 of the ethics complaint, I do substantiate that Council Member Brown has suggested that his support on matters is based upon whether he has received reciprocal support on a matter of importance to him. Mr. Deehan, Council Member Spitzley, and, to some extent, Mr. Fleming, all provided examples of this. In addition, both Council Member Spitzley and Mr. Deehan expressed concern about Council Member Brown's comments, with Mr. Deehan indicating that he was concerned enough to consult with his own attomey and Council Member Spitzley indicating that she was concerned enough to warn Council Member Brown."
In other words, after the Report recommended dismissal of Allegations #1 and #2 of the Ethics Complaint, the Report then relied upon matters outside of the Ethics Complaint to find an ethical violation. Although the next section of this Request will demonstrate that this finding is factually flawed, the Lansing Code of Ordinances cited above clearly prevents the consideration of matters outside of the Ethics Complaint itself.
If the Report or this Ethics Board are allowed to base its findings on matters not within a complaint itself (as the Report attempts to do), then what are the limits of an ethical investigation or why even have a mandatory written complaint requirement?
In this regard, please note the mandate contained in Section 290.03(c) of the Lansing Code of Ordinances:
"No person shall knowingly make a false or misleading statement in any complaint filed with the City Clerk pursuant to this chapter."
The Ethics Complaint is subject to Section 290.03(c) above and each ofthe six signers of the Ethics Complaint is subject to this "false or misleading" requirement. As the Repon concluded with respect to Allegations #1 and #2, Jeff Deehan, Doug Fleming, and Dr. Brown each expressly denied that Dr. Brown made these statements as claimed in the Ethics Complaint. See Report, Pages 14-15. Significantly, each of the six signers of the
Complaint admitted that they had no personal knowledge of these allegations. See Report, Page I (Garza), Page 4 (Wood), Page 5 (Hussain), Page 6 (Spadafore), Page 6 (Schor), Page 10 (Spitzley). And yet, each declared that "upon information and belief', that these false statements were actually true.
The point here is that if the Report is allowed to render a finding on matters outside of the Ethics Complaint, then why are not the six signers of the Ethics Complaint also held responsible for their false or misleading statements? The answer is that the Lansing Code of Ordinances cited above clearly prevents the consideration of matters outside of the Ethics Complaint itself.
THE REPORT IGNORES THE OVERWHELMING WEIGHT OF EVIDENCE CONTAINED WITHIN THE REPORT ITSELF TO INCORRECTLY FIND AN ETHICS VIOLATION AGAINST
DR. BROWN
According to Page 15 of the Report:
"However, while I do not find that Council Member Brown engaged in the conduct as specifically alleged in paragraphs I and 2 of the ethics complaint, I do substantiate that Council Member Brown has suggested that his support on matters is based upon whether he has received reciprocal support on a matter of importance to him. Mr. Deehan, Council Member Spitzley, and, to some extent, Mr. Fleming, all provided examples of this. In addition, both Council Member Spitzley and Mr. Deehan expressed concern about Council Member Brown's comments, with Mr. Deehan indicating that he was concerned enough to consult with his own attomey and Council Member Spitzley indicating that she was concerned enough to warn Council Member Brown."
Contrary to the foregoing "findings", Mr. Deehan stated that "Council Member Brown did not indicate a direct quid pro quo" (see Report, Page 12) and "Mr. Fleming stated that Council Member Brown has never told him or suggested to him that he would or would not support LHC resolutions based on LHC doing him or a constituent a favor." (See Report, Page 4). Mayor Schor "stated that Council Member Brown did approach him about his support on the two (2) projects he wanted to submit for funding - the Lady Bug Center and the International Center - but there was never a quid pro quo proposed regarding Council Member Brown's support for the Ovation project." (See Report, Page I l). Five of the other interviewed people never even mentioned these alleged "quid pro quo" statements supposedly made by Dr. Brown. And of course, Dr. Brown denied making any such statements. (See Report, Pages 7-10).
So that just leaves the solitary' hearsay statements of Council Member Spitzley against the statements of the other nine interviewed people. And yet, against the ovenvhelming weight of evidence contained within the Report itself, the Report somehow states that this is a "close question" (see Report, Page 15) and makes the factual conclusion that Dr. Brown made these "quid pro quo" statements.
We can only hope that the Board finds this aspect of the Report to be as deeply troubling as we do.
THE FAILURE OF THE ETHICS COMPLAINT TO STATE A CLAIM OF A VIOLATION OF THE
ETHICS PROVISIONS CONTAINED IN THE LANSING CHARTER, LAW, OR ORDINANCES, REQUIRES ITS DISMISSAL
According to Section 290.03(a)(5)(b), this Board must dismiss an ethics complaint based on the following grounds:
"Failure of the complaint to state a claim of a violation of the ethics provisions contained in the Charter, law or ordinances."
In each of the three "allegations" set forth in the Ethics Complaint filed against Dr. Brown, even if the few facts asserted against Dr. Brown are true (which they certainly are not), then these "allegations" fail to state a claim of a violation of the ethics rules.
In Allegation #1, Dr. Brown is falsely accused of indicating that "he would make a decision, and ultimately support by voting yes on resolutions in front of Council that are related to the Ovation project if in return either Mr. Deehan's company or the mayor agree to pay first and last month's rent for a constituent's apartment. "
With respect to Allegation #1, the Ethics Complaint claims that Dr. Brown's actions were actually a violation of Lansing Ethics Ordinance 290.04(b) which reads as follows:
"(b) No officer, employee or candidate, a member of the immediate family of an officer, employee or candidate, or a business with which an officer, employee or candidate is associated shall directly or indirectly solicit or accept any payment, gift, loan, contribution, money, goods, services, reward, employment or other thing of value based on any agreement or understanding with a person, including any administrative board established under Article V, Chapter 2 of the City Charter, that a vote or official action or decision of an officer, employee or candidate would be influenced thereby."
However, the Ethics Complaint does not claim that Dr. Brown solicited or accepted anything for his personal benefit.
Therefore, Allegation #1 fails to state a claim of a violation of Lansing Ethics Ordinance 290.04(b).
In Allegation #2, Dr. Brown is falsely accused of suggesting that "Council Member Brown's decisions and any further support by voting yes on LHC resolutions that may come before City Council was dependent" on "Mr.
Fleming find[ing] money in a LHC 'slush fund' and use it to pay various tenant related fees" for a housing assistance recipient named "Ms. Verlinde".
With respect to Allegation #2, the Ethics Complaint claims that Dr. Brown's actions were actually a violation of Lansing Ethics Ordinance 290.04(b) which reads as follows:
"(b) No officer, employee or candidate, a member of the immediate family of an officer, employee or candidate, or a business with which an officer, employee or candidate is associated shall directly or indirectly solicit or accept any payment, gift, loan, contribution, money, goods, services, reward, employment or other thing of value based on any agreement or understanding with a person, including any administrative board established under Article V, Chapter 2 of the City Charter, that a vote or official action or decision of an officer, employee or candidate would be influenced thereby."
However, the Ethics Complaint does not claim that Dr. Brown solicited or accepted anything for his personal benefit. Therefore, Allegation #2 fails to state a claim of a violation of Lansing Ethics Ordinance 290.04(b). In Allegation #3, Dr. Brown is falsely accused of "requesting grant ftnding on behalf of the City of Lansing."
With respect to Allegation #3, the Ethics Complaint and the Report both claim that Dr. Brown's actions were actually a violation of Lansing Ethics Ordinance 290.04(d) and/or 290.04(i) which read as follows:
'(d) No officer or employee shall falsely represent his or her personal opinion to be the official position or determination of the governmental body of which he or she is a member or employee. This subsection shall not apply to statements by elected officials made in the course of fulfilling the responsibilities of their office or in running for election to office, nor shall it apply to the professional opinions of City Officers or employees rendered in the course of performing their duties, provided that such opinions are clearly identified as professional opinions."
"(i) No officer or employee shall act on behalf of the City by making any policy statements, promising to authorize or to prevent any future action, agreement or contract, when such officer or employee has, in fact, no authority to do so."
Lansing Ethics Ordinance 290.04(d) speaks in terms of "opinions". However, at no time does the Ethics Complaint even allege nor did Dr. Brown render any "opinions" by initiating (but not completing) the process to obtain a federal grant to address homelessness for the people of Lansing. Lansing Ethics Ordinance 290.04(i) speaks in terms of "policy statements" and "agreements". However, at no time does the Ethics Complaint even allege nor did Dr. Brown make any "policy statements" and "agreements" by initiating (but not completing) the process to obtain a federal grant to address homelessness for the people of Lansing.
Although the Report weakly suggests that initiating the process to obtain a federal grant "could be viewed as an official position or policy statement of the City" (see Report, Page 16) does this Board want to find an ethical violation based on such an uncertain statement? But again, this entire mental exercise is avoided because it is beyond dispute that Dr. Brown never applied for a federal grant to address homelessness for the people of Lansing.
Therefore, Allegation #3 fails to state a claim of a violation of Lansing Ethics Ordinance 290.04(d) and (i).
Accordingly, the failure of the Ethics Complaint or the Repon to state a claim of a violation of the ethics provisions contained in the Lansing Charter, law or ordinances, requires the dismissal of the Ethics Complaint.
ANY ETHICS COMPLAINT THAT IS ENTIRELY BASED "UPON INFORMATION AND BELIEF" MUST BE DISMISSED
Each of the three allegations set forth in the Ethics Complaint filed against Dr. Brown is based entirely "upon information and belief' statements.
According to Section 290.10 of the Lansing Code of Ordinances, the filing of the Ethics Complaint could lead to criminal enforcement. Where criminal charges are involved, in order to obtain a conviction, a prosecutor must "prove the elements of [a charged] crime beyond a reasonable doubt. " People v Nowack, 462 Mich 392, 400 (2000). "The obvious corollary of this is that acquittal is necessary when the prosecutor has not proven the elements of a crime beyond a reasonable doubt." People v. Mahan, Michigan Court of Appeals Case No. 344844 (2019). Evidence based "upon information and belief' is insufficient to support a prosecution proving guilt beyond a reasonable doubt. See, for example, Metropolitan Life Insurance Company v. Reist, 167 Mich Appli2 (1988).
Accordingly, because the Ethics Complaint filed against Dr. Brown is based upon such inconclusive and wishywashy "upon information and belief' allegations, it must be dismissed.
ANY ETHICS COMPLAINT WHICH ADMITS THAT "MUCH OF THE INFORMATION"
CONTAINED THEREIN IS INADMISSIBLE HEARSAY EVIDENCE, MUST BE DISMISSED
In Michigan, so-called "hearsay" evidence is inadmissible subject to limited exceptions. See Rule 802 of the Michigan Rules of Evidence Significantly, the Ethics Complaint filed against Dr. Brown sheepishly admits that "much of the infonnation related to these complaints was gained indirectly through various verbal conversations". In fact, the Report confirms each signer of the Ethics Complaint admitted that the statements made in the Ethics Complaint were hearsay statements made outside of their presence. See Report, Page I (Garza), Page 4 (Wood), Page 5 (Hussain), Page 6 (Spadafore), Page 6 (Schor), Page 10 (Spitzley). In other words, "much" of this Ethics Complaint is what is referred to as hearsay evidence. According to Rule 801(c) of the Michigan Rules of Evidence, "hearsay" is defined as a "statement, other than the one made by the declarant while testifying at the trial or hearing, offered in evidence to prove the truth ofthe matter asserted." To this point, neither Jeff Deehan (see Allegation #1) nor Doug Fleming (see Allegation #2) signed the Ethics Complaint falsely alleging that Dr. Brown made certain statements (which, in fact, Dr. Brown did not make).
Instead, the six signers of the Ethics Complaint (not Deehan or Fleming) are falsely making claims that Dr.
Brown made certain statements. Consequently, it is the signers of the Ethics Complaint who are making a "statement, other than the one made by the declarant while testifying at the trial or hearing, offered in evidence to prove the truth of the matter assened."
Such hearsay evidence is inadmissible. Accordingly, we respectfully request this Ethics Board to recognize that the Ethics Complaint filed against Dr. Brown a serious matter is largely based on inadmissible and flimsy hearsay evidence. The Ethics Complaint which admits that "much of the information related to these complaints was gained indirectly through various verbal conversations" must certainly be dismissed on this basis alone.
CONCLUSION: THE ETHICS COMPLAINT IS BASED UPON CONJECTURE AND SPECULATION RATHER THAN FACT According to the State Board of Ethics:
"It must be concluded, therefore, that the instant complaint is based upon conjecture and speculation rather than fact. Where the facts are too remote to find a violation, dismissal is proper." Michigan State AFL-CIO v Hunter, 98-ED-3 (February 26, 1999).
As illustrated in this Response:
l. The Ethics Complaint filed against Dr. Brown makes no allegations that Dr. Brown received any personal gain or benefit and the Report did not find otherwise.
2.The few "facts' set forth in the Ethics Complaint filed against Dr. Brown are demonstrably false.
3.The Report inappropriately investigated matters outside of the Ethics Complaint itself to incorrectly find an ethics violation by Dr. Brown.
4.The Report ignores the overwhelming weight of evidence to incorrectly find an ethics violation by Dr. Brown.
5.The failure of the Ethics Complaint to state a claim of a violation of the ethics provisions contained in the Lansing Charter, law or ordinances, requires its dismissal.
6.The Ethics Complaint filed against Dr. Brown is based upon inconclusive and wishy-washy information and belief' allegations.
7.The Ethics Complaint filed against Dr. Brown is largely based on inadmissible and flimsy hearsay evidence.
Consequently, the Ethics Complaint and the portion of the Repon "finding" an ethical violation against Dr.
Brown epitomize the definitions of "conjecture" ("the formation or expression of an opinion or theory without
sufficient evidence for proof' See Conjecture Definition & Meaning Dictionary.com) and "speculation" ("the ac_tiyity ofguessmg possible answers to a question without having enough information to be certain" See
SPECULATION definition in the Cambridge English Dictionary). Therefore, in an effort to fix the Ethics
Complaint's fatal "conjecture" and "speculation" flaws, the signers of the Ethics Complaint seek a
"comprehensive investigation.. .related to each allegation." However, as recognized by the State Board of Ethics, the duty of this Ethics Board is not to fix the Ethics Complaint's fatal "conjecture" and "speculation" flaws and conduct yet another fishing expedition, but to dismiss the Ethics Complaint.
We are deeply grateful that this Ethics Board is willing to consider our comments on this serious matter. The
Ethics Complaint represents a risk to Dr. Brown's status as a minister and to his unrelenting drive to assist Lansing's most vulnerable citizens. For the reasons set f01th in this Request to Dismiss, the only legal, factual, and fair outcome is to dismiss the Ethics Complaint in its entirety.
Respectfully submitted.
34-aua4w 3
June 02 2023 Brendon (P6936 )Date:
Counsel for Jeffrey Brown
909 N. Washington Avenue, Lansing, MI 48906 517-708-7830 brendon@basigalawfirm.com
June 02, 2023
Eric Doster (P41782)Date:
Eric Doster
Co-Counsel for Jeffrey Brown
2145 Commons Pkwy Okemos, MI 48864 517-977-0147 eric@ericdoster.com
Signature: encEric Doster [Jun 2,
Email: eric@ericdoster.com
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