CHARLES LEE RANDOLPH,
Appellant,
CASE NO. 36080

V .

THE STATE OF NEVADA,
Respondent.

FILED
JAN -2 2002

RESPONSE TO ORDER TO SHOW CAUSE/

SPRa^MURT

MARCUS D. COOPER

WILLIAM KEPHART

Nevada Bar No. 001879

Nevada Bar Number 3649

309 South TWrd Street, Suite 226

Clark County District Attorney's Office
200 South Third Street, Suite 701

Clark County Public Defender
Post Office Box 552610

Las Vegas, Nevada 89155-2610

(702)4!5-4685

Chief Deputy District Attorney

Post Office Box 552212

Las Vegas, Nevada 89155-2211

JAN 0 2 2002
^ WNCTIEIABIOOM

CURXOFSUHlEKECOtmT
ofPurycuRK ^

5rAppellant

02.-600'/l

 •

•

T N T H E S U P R E M E C O U R T O F T H K S TAT E O F N E VA D A

1
2
3
4

5

CHARLES LEE RANDOLPH

Appellant,

6

CASE NO. 36080

7

V .

8

THE STATE OF NEVADA,

9

Respondent.

10
11
12

RESPONSE TO ORDER TO SHOW CAUSE

13

COMES NOW William Kephart, Chief Deputy District Attorney, and submits

14

this response in obedience to the Order to Show Cause issued by the Honorable Court

15

on December 14, 2001.

16

Dated this 28th day of December 2001.

17

18

^ WILLIAM KfiPmkT

R v

19

Chief D^uty District Attorney

20

Nevada Bar Number 3649

21

Clark CounW District Attorney's Office
200 South Third Street, Suite 701

22

Post Office Box 552212

Las Vegas, Nevada 89155-2211
23
24
25
26
27
28

 •

t

•

1

INDEX
2

A f fi d a v i t s a n d L e t t e r
3

1. Affidavit of Chief Deputy District Attorney William Kephart

4

2. Affidavit of District Attorney Stewart L. Bell
5

3. Affidavit of Chief Deputy District Attorney David T. Wall

6

4. Affidavit of District Judge Michael Douglas
7
8

9

5. Affidavit of Chief District Judge Mark Gibbons

6. Affidavit of District Judge Michael Cherry
7. Affidavit of District Judge Joseph Bonaventure

10

8. Affidavit of District Judge Jeffrey D. Sobel
11

9. Letter from District Judge Donald Mosley

12

10. Affidavit of Senior District Judge Joseph Pavlikowski
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2

 r r R T T F T PAT F,

1

OF

MAILING

2

I hereby certify and affirm that I mailed a copy of the foregoing Response to

3

Order to Show Cause to the attorney of record listed below on December 28,2001.

4

Curtis Brown
5

Deputy Public Defender
30$ South Third Street, Suite 226

6

Post Office Box 552610

Las Vegas, Nevada 89155-2610
7
8
9
10

Employ^, Clark Co
Districtf^ttomey's

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
2 7

28

TUFTELANDj/Jerry Tao/English
I ; V U ' P I U J . AT i W P D O C S \ S E C R E r A R \ S U C X j M J S B J W N D O L P » . W P D

3

 3 S TAT E O F N E VA D A
4 COUNTY OF CLARK

6 I, WILLIAM KEPHART, having been first duly sworn, hereby deposes and says:
7 I am an attorney duly licensed to practice law in the State of Nevada and am currently
8 employed as a Deputy District Attorney with the Clark County District Attorney's Office.
9 In my capacity as Deputy District Attorney, I volunteered to assist Chief Deputy District
10 Attorney David Wall with the prosecution of the case State of Nevada vs. Charles Lee Randolph.
11 wherein Randolph was charged with the brutal, execution style murder of Shelly Lokken.
12 In accordance with standard jury instructions submitted by the State, the Honorable
13 Michael Douglas, District Judge of the Eighth Judicial District Court, Department XI thereof,
14 instructed the jury on the definition of reasonable doubt, which, in pertinent part, read: "A
15 reasonable doubt is one based on reason. It is not mere possible doubt, but is such a doubt as

16 would govern or control a person in the more weighty affairs of life. If the minds of the jurors,
17 after the entire comparison and consideration of all the evidence, are in such a condition that
18 they can say they feel an abiding conviction of the truth of the charge, there is not a reasonable
19 doubt. Doubt to be reasonable must be actual, not mere possibility or speculation".
20 During final argument of defense counsel, much time was spent on the concept of

21 reasonable doubt. In fact, the State objected to the defense's effort to explain reasonable doubt,
22 which objection was sustained. The court reminded the jury that Instruction 48, wherein the
23 court defined reasonable doubt, was the legal and proper definition of reasonable doubt.

24 One of the responsibilities assigned to me by Chief Deputy District Attomey David Wall
25 was to make the State's rebuttal argument. I felt it necessary to rebut what I believed was a
26 misimpression left with the jury by the arguments made by defense counsel in regard to
27 reasonable doubt. In endeavoring to do so, I directed the jury's attention to the court's
28 instruction on reasonable doubt, which was of course the law of the case.

 .

%

' %

1

In my argument I was endeavoring to give to the jurors what I believed was a fair and

2

lawful lay explanation of the concept "abiding conviction of the truth of the charge" contained

3

in the court's instruction to the jury. I endeavored to explain this concept because I believed

4

defense counsel had left a misimpression with the jury about how much doubt was "reasonable".

5

Another reason for endeavoring to explain this concept was in post verdict discussions

6

with jurors in previous trials I have been asked what is a "weighty affair", or what is meant by

7

"an abiding conviction". In fact, in one instance in post jury discussions, I heard one juror tell

8

another that an abiding conviction was a "feeling in her gut".

9

Just as I commenced to try to explain in lay terms the concept of "abiding conviction"

10

within the framework of the instruction given by the court, there was a defense objection which

11

was sustained. As a result of the court sustaining the defense objection, I did not press the issue,

12

but simply went on to the next focus of my rebuttal argument, respecting the ruling of the trial

13

court.

14

In that regard, however, the full content of the argument I had intended to present would

15

have been as follows: "If you have a gut feeling he's guilty, he's guilty based on that feeling, tliat

16

feeling in your heart and mind after comparing and considering all the evidence is what is meant

17

by abiding conviction and proof beyond a reasonable doubt". At the time I was making this

18

argument, I fully believed that the argument, taken in total, would have been proper.

19

In any event, in light of the Randolph decision and the position of the Court taken therein,

20

it is my intent in future closing arguments to simply read the Court's instruction on reasonable

21

doubt, and use no words of explanation other than the specific language contained within the

22

instruction of the Court.

23

During my career I have prosecuted 82 felony jury trials, as well as hundreds and

24

hundreds of misdemeanor trials. I have made thousands of appearances to handle incidental

25

matters and argue motions. I have never intentionally violated the rules of any court, nor did I

26

do so in the Randolph case.

27

Commencing the day after oral argument in the Randolph case when Chief Deputy

28

District Attorney David Wall advised me of the Court's strong concern with the sentence that
-2-

 .

i

1
2

of professional conduct; and I attended a two hour course on ethics for prosecutors conducted

3

in house by the Clark County District Attorney's Office wherein the prime focus was errors

4

made by prosecutors in opening and closing arguments.

5

1 apologize to the Court for anything that I have said or done in the Randolph case, or

6

elsewhere, that has given the Court the misimpression that 1 do not take seriously my

7

professional responsibilities.

8

1 have already been professionally embarrassed by the Court's opinion in the Randolph

9

case. This has been very difficult for me because 1 always strive to maintain a reputation for

10

honesty and integrity.

11

I can insure this Court that the opinion in the Randolph case and the consequences

12

flowing therefrom have already had a great impact upon me, to the point that 1 can assure the

13

Court that there will not be a bona fide allegation of prosecutorial misconduct against me in the

14

future.

15

DATED this "Z--7day ofDecember, 2001.

16
17
18

19

SUBSCRIBED and SWORN before me
20

this 20. d^of December, 2001.

21
22

23

in and for said

ounty and State

24
25
26
27
28
-3-

 1
A F F I D AV I T O F S T RWA RT L . B E L L

2
3

STATE OF NEVADA )
4
5

;

ss

COUNTY OF CLARK )

6

1, STEWART L. BELL, having been firsl duly sworn, hereby deposes and says:
7

Your Affiant is an attorney duly licensed to practice law in the State of Nevada and

8
9

currently, and for the last seven years, the elected District Attorney of Clark County.
As elected District Attorney of Clark County, your Affiant takes very seriously the

10
11
12

responsibility of the entire District Attorney's Office to properly and fairly represent the public's
interest in all of the roughly 100,000 cases filed on the public's behalf annually. Furthennore, your

13
14

Affiant expects and insists that every of the 130 attorneys currently employed by the Clark County

15

District Altoniey's Office endeavor at all times not only to comply with the minimum standards

16

of professional conduct adopted as rules of practice of this Stale, but in fact to uphold even higher

17
18

standards.

While in the past there have been employees of the District Attorney's Office that

19

have intentionally bent rules to achieve an end on the theory that the end justifies the means, your
20
21

Affiant can say without equivocation that every single attorney currently employed by the Clark
County District Attorney's Office is dedicated and committed to professionalism and recognizes
that performing his or her job responsibilities properly, and upholding the highest standards of
integrity, is our firsl and foremost responsibility.

 1
2

Your Affiant has known William Kephart for approximately twenty (20) years.

3

Your AfBant can state without equivocation that Bill Kephart would never intentionally "strike a

4

foul blow", nor would he use an improper method "calculated to produce a wrongful conviction".

5

In fact, your Affiant can state, without equivocation, that Bill Kephart would never intentionallv

6

use an improper method calculated to produce what he believed to be a proper conviction.
7

Bill Kephart is a hard working, enthusiastic prosecutor who is a credit to the Clark

8
9

County District Attorney's Office. He is always one of the first lawyers in the Clark County

10

District Attorney's Office to volunteer to help others in the office when assistance is needed. By

11

way of example, prosecution of State v. Randolph was assigned to Chief Deputy District Attomey

12

David Wall. When he needed assistance with the prosecution. Bill Kephart was the first to
13
14

v o l u n t e e r.

15

In the Randolph case, this Honorable Court found erroneous a statement made by

16

Deputy Kephart in trying to explain to jurors the concept of reasonable doubt. The Court having

17

made such finding, there is no purpose in arguing that issue. However, it is respectfully submitted

18

that the'Court should consider the thin line between the Court's definition of reasonable doubt and
19
20

the statement by Deputy Kephart. The law requires that a jury reach a "subjective state of near

21

certitude" to find guilt. It is respectfully submitted that "subjective state" means an individual

22

feeling, in the gut, in the heart, in the mind, such that had Mr. Kephart said "if you have a certitude

23

in your gut that he's guilty, he's guilty", such would have been in compliance with standards

24

established by this Court, whereas the statement that "if you have a feeling in your gut thai he's

25
26

guilty, he's guilty" is not.

27
28

2

 1
2

That your Affiant, in the performance of your Affiant's responsibilities as the elected

3

District Attorney of Clark County, has reviewed the entire record of the Randolph case, including

4

the tape recording of the appellate argument before this Honorable Court. This review, in

5

conjunction with your Affiant's knowledge of the character of Deputy District Attorney William

6
7

Kephart, leads your Affiant to a subicctive slate of certiuidc that there was no intent whatsoever

8

on the part of Bill Kephart in the Randolph case to do anything to prejudice the rights of Mr.

9

Randolph. Nor was there any intent whatsoever to use an improper method calculated to produce

10
11

a wrongful conviction. (In fact, this Honorable Court found that the conviction was proper.)
Your Affiant respectfully requests that this Honorable Court take no further action

12

other than to warn the Deputy District Attorney at issue, the Clark County District Attorney's
13
14
15
16

Office in general, and all the prosecutor's offices around the State, to redouble their efTorts to
avoid even an argument of impropriety in the future.
DATED this 24th day of December, 2001.

17
18

/V

STEWART?BELL

19
20
21
SUBSCRIBED and SWORN before me

CHCflMAINE D. GORD

ay of December, TQOl.

Notary Public • Nwada
No. 94 -1455-1

Myappt. Bxp. Fob. 23,2002

A Notary Public in and for said
County and State

3

 #
1

A F F I D A V I T

2

STATE OF NEVADA }

3

COUNTY OF CLARK )

) SS*

4

DAVID T. WALL, being first duly sworn, deposes and says:

5

1. That I am an attomey duly licensed to practice in the State of Nevada and as such am

6

competent to testify to the matters set forth herein.

7

2. That as a Chief Deputy District Attomey with the Clark County District Attorney's

8

Office, I was assigned, along with William Kephart, to prosecute the companion cases of Slals

9

of Nevada vs. Charles Randolph and State of Nevada vs. Tyrone Gamer for the murder of Shelly

10

Lokken on May 5, 1998, and as such I have personal knowledge of the matters set forth herein.

11

3. That the two cases were severed and separate trials were conducted, and both

12

defendants were convicted on all charges, including Murder in the First Degree With Use of a

13

Deadly Weapon, and that this Court affirmed both convictions.

14

4. That the trial in State of Nevada vs. Charles Randoloh commenced in January of 2000

15

before the Honorable Michael Douglas, District Court Judge. Deputy Public Defenders Curtis

16

Brown and Willard Ewing represented Mr. Randolph.

17

5. That throughout the pendency and trial in this matter, your affiant and Mr. Kephart

IS

acted in good faith in prosecuting Mr. Randolph. Your affiant is aware of a suggestion of bad

19

faith on behalf of Mr. Kephart due to comments he made during the rebuttal argument in the

20

guilt phase portion of the trial. It is your affiant's belief that no bad faith can be attributed to Mr.

21

Kephart's comments.

22

6. Throughout the case, Mr. Kephart joined your affiant in preserving the fairness of the

23

proceedings against Mr. Randolph. Prior to the trial, the State removed certain theories of

24

liability from the murder count so as not to prejudice Mr. Randolph. The State also deleted u

25

cognizable aggravating circumstance listed on the Notice of Intent To Seek Death Penalty to

26

protect against the possibility of double-counting by the jury.

27

7. At no time during the case did Mr. Kephart, in the opinion of your affiant, act in a

28

manner that could be described as in bad faith. It is your affiant's belief that Mr. Kephart did not

 1

engage in any intentional misconduct, and that any comments during rebuttal argument deemed

2

inappropriate by this Court were the result of the adversarial and extemporaneous nature of

3

rebuttal and not any bad faith toward the Defendant or the Court.

4
5

8. That your affiant respects the manner in which Mr. Kephart prepares for trial and the
commitment with which he carries out his duties with the District Attorney's Office.

6
7

D AV I D T. WA L L
8

9

SUBSCRIBED AND SWORN to before me

10
11

NOTARY PUl ILIC in and for said
12

County and State

13

14

KATHUEN I HENKEL
NMin MJk S«irt> sf Nn«da

15

No. 90-293U.1

% oppt. wp. Pac 31.2002

16
17
18

19
20
21
22

23
24
25
26
27

28
-2-

l:\MVU\RAN [X>LPH\RANDOLPH.WPDM(jh

 1
A F F I D AV I T O F J U D G E M I C H A E L D O U G L A S

2
3

STATE OF NEVADA )

4

COUNTY OF CLARK)

:

5

ss

1, MICHAEL DOUGLAS, having been first duly sworn, hereby deposes and

6
says:

7
8
9

Your Affiant is a District Judge in the Eighth Judicial District Court,
Department Xi thereof.

10

Your Affiant was the trial judge in the case of State of Nevada vs. Charles

11

Lee Randolph, which was prosecuted by Chief Deputy District Attorney David Wail and

12

Deputy District Attorney William Kephart.

13

During the argument phase. Deputy District Attorney Kephart made an
14
15
16
17
18
19

Incorrect statement of law in regard to reasonable doubt, which prompted a defense
objection, which objection your Affiant immediately sustained.
After the objection was sustained, Deputy District Attorney Kephart directed
the focus of his argument elsewhere and did not press the issue.

it is the opinion of your Affiant that although the statement made during

20

argument was clearly an incorrect statement of the law, it was not done maliciously or with
21

an eye towards prejudicing the rights of Defendant Randolph.
22
23

DATED this^2.^ay of Decemb

24
MICHAEL DOUGLAS.
DISTRICT COURT JUDGE

25
26

SUBSCRIBED and SWORN before me

27

this-^iteay of Decernt5eK 2001.

28

^ Cu^-c f 0

A" Notary PublioJn.aad for safb
County and State

ALICIA PHILLIPS

Notary Public • '■'svada '
No.

I

My appl. exp. Sept. 20,2002

 1

2

A F F I D AV I T O F M A R K G I B B O N S
S TAT E O F N E VA D A

)
) ss.

COUNTY OF CLARK

)

3
4
5

MARK GIBBONS, being first duly sworn, deposes and says:

6

That he is the Chief District Judge of the Eighth Judicial District Court.

7

That he has personal knowledge of the facts contained in this affidavit and is

8

competent to testify as to those facts.

9

That Deputy District Attorney William Kephart has appeared before your
10
11
12
13
14

affiant on numerous occasions involving various types of criminal proceedings.
That Mr. Kephart has always acted with the utmost professionalism and
decorum when he has appeared before your affiant.

That Mr. Kephart is always well prepared in his arguments and argues points

15

of law supported by statutory and case authority.
16
17
18

That your affiant has never encountered any problems with Mr. Kcphart's
conduct or legal arguments made in court.

19
20
21
22
23

SUBSCRIBED AND SWORN to before

me this ^4^^dav of December, 2001.

24
25
26
27
28

ary Public in and for said County
State
JANET M. ALLEN
Notaiy Public-State of Nevada
Appomtnital fiecBted is CIvt Coonlv
Ur Aopontmnt Ewe Asl 30.2003
S1-O032-I

 f?

A F F I D AV I T

1
2

S TAT E

3

COUNTY OF CLARK )

OF

N E VA D A

OF

MICHAEL

CHERRY

)
) SS*

4

MICHAEL CHERRY, being first duly sworn, deposes and says:

5

That 1 am a District Judge of the Eighth Judicial Court.

6

That I have personal knowledge of the facts contained in this affidavit and 1 am

7

competent to testify as to those facts.

8

That from the years 1977 to 1997,1 was an alternate Las Vegas Municipal Court Judge,

9

That during my time as an alternate Municipal Court Judge, Deputy District Attorney

10

William Kephart, then Deputy City Attorney, appeared before me numerous times on behalf of

11

the City of Las Vegas.

12
13
14
15

16
17
18

19

That during these appearances William Kephart always practiced law with the utmost
professionalism and impeccable ethics.
That between the years 1990 and 1998,1 practiced as a defense attorney in the State of
Nevada.

That during my practice I defended numerous cases in which William Kephart was the
prosecuting attorney.
That during my defense of these cases I never wimessed any misconduct or

unprofessional behavior on the part of Mr. Kephart.

20

That between 1999 to the present, I have sat as a District Court Judge for the Eighth

21

Judicial Court and Deputy District Attorney William Kephart has appeared before me on

22

numerous occasions involving various types of criminal proceedings.

23
24
25

26
27
28

That Mr. Kephart has always acted with the utmost professionalism and decorum when
he has appeared before my court.
That Mr. Kephart has always come into my court well prepared and has performed with
the utmost excellence that can be bestowed upon a prosecutor.
That I have never called Mr. Kephart's ethical conduct into question during his practice
before the court.

 1
2

That 1 have never encountered any problems with^Mr. Kephart's conduct during
arguments he has made before me.

3
4
5
6
7

SUBSCRiaED AND SWORN to before

me this<-2c day of December, 2001.

8
9

ILEEN SPOOR

M«ary Puwic. Nevada
No. 9S-50e80-1

10

My "PPt. exp. Jan. 7, aoca

Notaryy Public in and for said County
11

and State

12

13
14
15

16
17

18
19
20
21
22
23
24
25

26
27
28
-2-

 1
2

A F F I D AV I T O F J U D G E J O S E P H B O N AV E N T U R E

3
4

STATE OF NEVADA )
:

5

ss

COUNTY OF CLARK )

6
7
8

9

1, JOSEPH BONAVENTURE. having been first duly sworn, hereby
deposes and says:

Your Affiant is a District Judge In the Eighth Judicial District Court,

10
11

Department VI thereof.

12

Your Affiant has been a District Judge for nearly two decades. During

13

that period of time, Deputy District Attorney William Kephart has appeared in

14

Department VI dozens and dozens, and in fact probably hundreds, of times.

15
16
17
IS
19

Deputy District Attorney Kephart has tried a number of jury trials before
of your Affiant in Department VI.
During all those trials, and in fact during all his appearances before
your Affiant. Deputy District Attorney Kephart has acquitted himself honorably.

20

It is the opinion of your Affiant that Deputy District Attorney Kephart,
21
22

and for that matter the District Attorney's Office as a whole as it is currently

23

constituted, strives to play by the rules and to exhibit a high degree of

24

professionalism.

25

Your Affiant is aware that Deputy District Attorney Kephart was found
26
27
28

to have made a misstatement of the law in the case of State of Nevada vs. Charles

Lee Randolph.

 Based upon your Affiant's significant interaction with Deputy Distric
Attorney Kephart over many years, your Affiant is satisfied that any misstatemen
was unintentional, and not designed to gain an unfair advantage against Defendan
Randolph.
DATED this day of December, 2001.

JOQEPH BONAVENTURE,
IS rlRICT COURT JUDGE

SUB^CRj^D and SWORN before me
"Tayof December, 2001.

CHERMAir4E D. QORD
NoUry PjbNc • Nevada
No. 94-U55-1

' i h m / u
A Notary Public in ancf?or said
County and State

My eppt. exp. Fab. 23,2002

 A F F I D AV I T O F J U D G E J E F F R E Y D . S O D E L

JEFFREY D. SOBEL, being first duly sworn, deposes and says:
I have been a District Court Judge for eleven years and for twenty two years was a
6 litigator.

Unfortunately I have run across a few prosecutors in those thirty plus years who I

felt were either deliberately unethical or careless in discharging their ethical obligations.
Attorney William Kephart has appeared in front of me dozens and dozens of times
10
1
12

(perhaps even one hundred times) without ever committing an unethical act.
I am convinced, beyond a reasonable doubt, as defined by our Nevada Supreme

1

Court recently in Randolph where Bill was criticized, that he intended absolutely no

14

unethical conduct by his comments.

r - .

I

15
16
17

JEFFRI^ D. SOBI

18
19
20

Subscribed and sworn to before me

this ^ day of December, 2001.

21
22

NOTARY PUBLie

23
24

JUNE SAIZ
Nolaiy PubMc • Navacta
No. aa-asesa-i

25

Wy appt. exp. Nov. 23, 2003

26

27
28

District Court Judge

 Eighth Judicial District Court
CLARK
200

COUNTY
SOUTH

COURTHOUSe

THIRD

STREET

L A S V E G A S . N E VA D A 8 9 1 S S - 2 3 7 4

Donald

M.

DISTRICT

Mosley
JUDGE

D E PA R T M E N T F O U R T E E N
(702)465-4304
FA X : ( 7 0 2 ) 3 8 2 - 6 0 4 0

December 26, 2001

To whom it may concern,

Mr. William Kephart has appeared in my Court (Clark County District Court Department
XIV) for approximately five years. Within that period of time, he has handled items on the
motion calendar as well as actual trials. He has conducted himself in an ethical and forthright
manner in all of his appearances before me.

If additional information is required, 1 may be contacted at my office at 455-4304 located at
200 South Third Street.

Sincerely,

DMM/jjn

 A F F I D A V I T

I
2

S TAT E O F N E VA D A

3

COUNTY OF CLARK )

ss:

4

5

JOSEPH PAVLIKOWSKJ, being first duly sworn, deposes and says:

6

That 1 am a Senior District Court Judge for the Eighth Judicial District Court.

7

That I have personal knowledge of the facts contained in this affidavit and I am

8

competent to testify as to those facts.

That Deputy District Attorney William Kephart has appeared before me in excess of one

9
10

hundred time involving various criminal proceedings.

That many of his appearances involved criminal trial conducted before me, including but

11
12

not limited to cases involving mandatory life sentences.

That Mr. Kephart has always conducted himself as a professional and conscientious

13
14

aggressive prosecutor.

That Mr. Kephart was always well prepared in his arguments and endeavored to assist the

15
16

Court in making proper decisions.

That I have never has/reason to question Mr. Kephart's ethical conduct during any of his

17

18

appearances before this Court.

That Mr. Kephart was alwavs courteous and fair to opposing counsel as well as their

19
20

clients.

That

21

I

never

encountered

mduct

before

22
23
24
25

SUBSCRIBED AND SWORN/fp 'bpfore me
^

^

t

i

f

'

26
27

NDTAKY PUBLIC in and for said
28

County and State

^

:aORAH BURRESS

m W 'd u r t .