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Dispute Resolution:
Know What You Want
A huge heartfelt “Thank You”
and Select the Right Process.............6
to our WCBA members!
When Avoiding Probate Does Not
Avoid a Mess: Pitfalls and Strategies
when Planning with Beneficiary
Designations and Ladybird Deeds.....8
Thank you for reaching out to your colleagues
and supporting each other.
Thank you for staying engaged and involved.
Thank you for being a WCBA member
May/June 2021 and supporting our organization.
Volume 30, Number 3
The WCBA remains dedicated to the
success of our members.
Personal Jurisdiction: New Limitations
PROCEED WITH CAUTION – WHY STATE EQUALIZED
and theMAY
VALUE Consent-by-Registration
NOT BE YOUR CLIENT’S FRIENDWorkaround
Personal
Probatejurisdiction
personal
enter
recent
a money
YOUR MEETING
dles years,
this typetheof
Don’t let a real estate
is a big deal.process
can be a complicated
representative,
judgment orwho
situation
United
Without
likely only
injunction
once
States
forit,the
against
or twice
Supreme Court
a court cannot
han-a defendant. In
Consent to
of an inappropriately Personal
provided Jurisdiction
basis. Via Business
Equally important,
caliber may help substantiate your claim that the values within the report
In theand
are well-founded
in ahas narrowed Rated ★★★★ by Orbitz/Travelocity wake
Registration
a report
of the new limitations on personal jurisdiction,
accurate.
of this
asset delay a
lifetime. As an attorney, the process makes plaintiffs have increasingly argued that regardless of the extent
THIS GOOD
thesense
circumstances
to you, butunder
yourN which personal jurisdiction
has a IT may be
exercised,
EVER
client likely HAD
only Other tips about appraisals:
a defendant does business within a forum, a defendant consents
WEBER’S
cursory particularly
understanding against
of theout-of-state
process. Acorporate
proper defendants.
to general jurisdiction the moment it registers under the forum’s
Seeassessment of the value
generally Michael of the decedent’s
H. Hoffheimer, The StealthrealRevolution in It is important to remember that sometimes the person paying for the ap-
property is particularly difficult for the layper- praisal is business
not the registration
appraiser’s statute,
client. which invariably
For example, requireslending
in a mortgage the
Personal Jurisdiction, 70 Fla. L. Rev. 499 (2018). Yet these changes
settlement.
son or the attorney who is unfamiliar with real scenario, theappointment
borrower is of paying for the
an agent appraisal.
for service The appraiser,
of process how-
within the forum.
areestate
not fully reflected
transactions. in Michigan decisions addressing personal ever, is developing theirisanalysis and reporting for their client: Court
the lender.
This theory not without precedent—the Supreme
jurisdiction, leading to a potential trap for a practitioner looking If you have a client purchasing property and they would like to engage
When determining the services accepted it in Pennsylvania Fire Insurance Co. right
of Philadelphia
to do so, v.
only at Michigan case date of death
law. This values
article for the
provides a brief overview of an appraiser, it is completely within their
decedent's assets, the temptation may be to use
of assessment
the recent constitutional constraints imposed on personalRachel MasseyPaul T. Stewart Gold from
but it is separate Issue the
Mining & Milling
mortgage Co., 243 U.S. 93 (1917). And in some
process.
data in order to arrive at the opinion post-Daimler instances, the consent-by-registration theory has
jurisdiction,
of value asand thendate
of the considers thebut
of death, potential
is this for a Michigan With appraisals, the intended use can be forCo.,
mortgage financing,
working in your client’sjurisdiction
best interest? Is the as-
worked. See, e.g., Senju Pharm. Ltd. v. Metrics, Inc.,for96es-
F.
court to exercise personal under a consent-by- tablishing a value in an equitable dissolution issue, or it can be for buying
sessment data
registration theory,a good
whereindicator of value?
jurisdiction would Does having
otherwise bealacking.
value that is sub- a house without a loan. There are myriad reasons someone mayParts
Supp. 3d 428, 436-40 (D.N.J. 2015); see also Genuine wishCo. to v.
stantially higher or lower than actual SPECIALIZING
value hurt the client andIN SELLING
potentially Cepec,
have REAL
an137 A.3dESTATE
123, 149,
independent n.30ASSOCIATED
opinion (Del.
of the 2016) (Vaughn,
property’s value. J., dissenting)
One constant (surveying
is
subject you
Essential Backgroundto misrepresentation in WITH
the end? ESTATE SALES, PROBATE,
that the
cases). AND
appraisal DIVORCE.
report should CALL to the client and in-
be understandable
tended users.
A In orderexercise
court’s to determine whether
of personal or notFOR
jurisdiction these Acomport
mustsources CONFIDENTIAL
arewith
reliable,
both theI pulled ASSESSMENT.
Yet personal jurisdiction law has evolved significantly since Pennsylvania
twenty random
jurisdictional salesininthe
statutes thestate
area, and compared
where the court theirand
sits, sales
the prices to the as- Appraisal
Fourteenth reports should
Fire, and numerous decisionsbe clear
afterand help have
Daimler lead the clientconsent-by-
rejected to a logical con-
sessment data. The TCV is the TrueALEX Cash Value (See
MILSHTEYN chart below.) , CRS, GRI,clusion.
CRS, GRI, ABR Even if the client does not agree with the results in the end, they
Amendment’s Due Process Clause. Goodyear Dunlop Tires Operations, ,S.A. registration,
ABR including decisions from the highest
should always be able to understand how the appraiser got to their state appellate courtscon-
v. Brown,
MICHIGAN’S PREMIER MEETING FACILITY See
564 U.S.
This random 915, 918of(2011).
sampling twentyThe cornerstone
sales
(734) that417-3560
occurredof modern
in |the personal
area, inwww.alexmi.com
compared |clusion.
alex@alexmi.com Delaware, Illinois,
appraisaland
The WEBER’S Missouri.
| report beGenuine
shouldBroker
Associate Partsthe
able to help Co.appraiser’s
v. Cepec, 137 client
to assessment
jurisdiction Renowned
theorydata, shows
full-service
under assessment
theindependent
Due Process information
hotel with food
Clause bothfrom
is aservice above
defendant’s andRestaurant
Weber’s below
“contacts” make
A.3d an informed
123, 138-48
BOUTIQUE decision
(Del.
HOTEL2016);asAspen
to how Am.to Ins.
proceed
Co. v.on whatever
Interstate the basis
Warehousing,
sales Coldwell Banker Weir Manuel, 2723 S. State St., Suite 130,
theprice,
forumand onlythethree instances within a five percentDuevariance
Process (which was Inc., for obtaining 440,this
447professional opinion to Norfolk
begin with.
Michigan’s finest meeting rooms – bright, contemporary, high-tech ANN ARBOR, MICHIGAN
with (i.e., stronger
is the variance that most appraisers
the contacts,
Ann
Serving genuine Arbor,
consider
the less
MI
thefor
hospitality
theyears
7548108
tolerance they look for in
90 N.E.3d (Ill. 2017); State
Jackson Ave. at I-94 | Ann Arbor, MI
ex rel. S. Ry. v. Dolan, 512
concerns).
terms of acceptability).
Ideally located That
in Annmeans
Arbor onthat
I-94 assessment dataatwould
Kelsey Baptist only have
734-794-2262 S.W.3d 41,www.webersannarbor.com
51-52 (Mo. 2017). Courts have tended to reject consent-by-
(734) 769-2500 | (800) 443-3050
been useful fifteen percent of the time. An exclusive affiliate of Coldwell Banker
Personal jurisdiction comes in two flavors: general (“all-purpose”) and
Previews
registration on statutoryInternational
ab
interpretation grounds rather than constitutional
grounds—holding that there is no actual consent where the statutes do
specific (“limited”).
The most reliable General jurisdiction
and defensible numberis constitutionally
will come from permissible
a formal ap- when
praisal, conducted by a atcertified not make personal jurisdiction a condition of registration. But even those
a defendant is “essentially home” real estatein
in a state, appraiser.
which case that state’sthe
Throughout val-
courts Rachel Massey, SRA, AI-RRS, IFA, is an AQB Certified USPAP instructor
uation process, the appraiser analyzes and reconciles the collected data to decisions
and haveappraising
has been expressed skepticism over whether
full-time since 1989. She consent-by-registration
is a Certified Residen-
can “hear any and all claims” against the defendant, regardless of whether the
arrive at conclusions regarding the final value opinion. In the final recon- could
tial be constitutionally
Appraiser in Michigan, compatible with
specializing Daimler.
in And inwork
relocation somefor cases, that
various
claims have the
ciliation, anyappraiser
factual connection
considers to allthe
thestate. See Daimler
available data and AGusesv. Bauman,
knowl- skepticism
clients, as has
well been
as usedproperties
lake as a rationaleand forother
interpreting the jurisdictional
residential properties. She
571edge,
U.S. experience
117, 122 (2014).and professional judgment
In contrast, specific to arrive atis apermissible
jurisdiction final opinion only
for the property. import of
covers allthe
of business
Washtenaw registration
County,statutes
and parts narrowly (underand
of Jackson the prudential
Livingston
where the suit “arises out of or relates to the defendant’s contacts with the Counties.
doctrine ofPlease
construingvisit https://annarborappraisals.com
statutes to be consistent with the U.S. for Constitution,
more informa-
forum. Id. at
The ”cost of118.
an appraisal is minimal compared to the potential tax burden tion.
when possible). See Genuine Parts Co. v. Cepec, 137 A.3d at 144-48; Brown v.
Following the Supreme Court’s seminal decision of Int’l Shoe Co. v. Lockheed Martin Corp., 814 F.3d 619, 639-41 (2d Cir. 2016). The skepticism
Washington, 326 U.S. 310 (1945), courts recognized that a corporate over consent-by-registration is understandable, given it would permit
defendant may be subject to general jurisdiction based on “continuous and the exercise of general jurisdiction far beyond a corporation’s place of
systematic” contacts with the forum. But in the decades following Int’l Shoe incorporation and principal place of business, thereby making Daimler a
Co., courts have wrestled with the question of what constitutes “continuous Formerly
practical nullityknownfor corporations as Miller & Ass
with a national Associates,
sociates, PP.C.
presence. ..C.
and systematic” contacts. Similarly, for specific jurisdiction, courts have
Consent-by-Registration in Michigan
disagreed over the requisite nexus between the claims alleged and the
defendant’s contacts with the forum. No published Michigan decisions have addressed consent-by-registration.
However, it did arise Accounting
in federal court l Audit
in Magna Business
l Busi Consulting
inessdeConsulting
Powertrain Mex. S.A. g
The Supreme Court’s Recent Clamp Down
The discord surrounding “continuous and systematic” contacts was largely
Entrepreneurial and Family
de C.V. v. Momentive Performance Materials USA LLC, 192 F. Supp. 3d 824
Family Business
(E.D. Mich. 2016), where the court considered its own exercise of personal
Business s
put to rest in the Supreme Court’s Daimler AG v. Bauman decision, issued in jurisdiction from the perspective Fraud
Frau Detection
of a Michigan
n andand(under
state court Prevention
Prevention n
the general
2014, which essentially confined general jurisdiction over a company to its rule that the boundaries of personal jurisdiction in federal court are equal to
place of incorporation and its principal place of business (albeit leaving the IT state
the Consulting l Political
where the federal Campaign
court sits). Finance
nance Judge
In Magna Powertrain, Reporting
Reporting
Lawson g
door open for an “exceptional case” where general jurisdiction could exist rejected consent-by-registration on the basis that the language of Michigan’s
in the absence of those two conditions). Daimler, 571 U.S. at 137-39, 139 Retirement
business Planstatute
registration does not permitlan
Administration Retir rement
Retirement
inference Planning
Planning
of consent. By g
deciding the issue on this ground, the court avoided the constitutional
n.19. In other words, Daimler “eliminate[d] the traditional ‘continuous and
systematic’ contacts test for general jurisdiction.” See Charles Rhodes, Toward question of whether Daimler would TTax Planning
apermit such an and andPreparation
Preparation
inference—the n
approach
a New Equilibrium in Personal Jurisdiction, 48 U.C. Davis L. Rev. 207, 209 often taken in other jurisdictions, as mentioned above.
(2014). The Court’s decision in Daimler coincides with increasingly restrictive
ll BAY CITY CITY ll GRAND RAPIDSYet shortly after Magna Powertrain, Judge Potts (ret.) of the Oakland County
ANN
positions Court haslltaken
theARBOR AUBURN HILLS
on specific jurisdiction, most recently in Bristol- l GREATER T LANSING ll MI
MIDLAND ll OWO
OWOSSOOSSO llSAGINA SAGINAW W
Circuit Court reached an entirely different conclusion, holding that business
Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017).
registration—and corresponding appointment of a registered agent—was
305 E.
305 E. Eisenhower
Eisenhower Pkwy,
Pkwyy, Suite
Su
uite 100 l Ann Arbor
Arbor,, MI 48108
48108
734.971.3900 l www
734.971.3900 www.ahpplc.com
.ahpplc.com
Res 7
6 Ipsa Loquitur July/August 2019
2
2 May/June
July/August 2021
2020
May/June 2019
2019
Washtenaw County Bar Association
2020-2021 Board of Directors
Officers and Directors of the Bar Association
President
Elizabeth C. Jolliffe Directors at Large
Paul C. Fessler
President Kristin A. Davis
Mark W. Jane Alexander W. Hermanowski
President President
Elect Elect John K. Kline
S. JoyC.Gaines
Paul Fessler Kymberlie B. London
Vice President Sarah M. Meinhart
Vice President
S. Joy Gaines Scott E. Munzel
Samuel J. Bernstein
Treasurer
Samuel J. Bernstein Community Liaison
Volume
Volume
Volume
Volume48, 30,
Number
49, 3
48, Number
Number
Number 344 May/June 2019
July/August
May/June
July/August 2019
2021
2020 Treasurer Secretary Committee Co-Chairs
Jennifer
K. OrlandoL. Lawrence
Simón Mara E. Kent
Immediate Past President Robert F. Magill, Jr.
Jinan M. Hamood & Stephanie E. Garris
Secretary
Co-Presidents,
M. Sharkey New Lawyers Judiciary
Section Committee Co-Chairs
Features
Features
Features
Katherine
Alexander W. Hermanowski, Scott Shalini
E. Munzel, Shalini Nangia,
Nangia
& Katherine
Immediate Past M. Sharkey
President Jinan M. Hamood
Dispute Resolution: Know What You Want Mark W. Directors
Jane at Large
Personal Jurisdiction: New Limitations and
Important Choices forRight
Michigan No-Fault
andMarijuana
How Select theUse Process.
can still .............................6
be Illegal in Michigan post Kyeena Slater New Lawyers Section Co-Presidents
theInsurance
Car Consent-by-Registration
in 2020 Workaround .........6
..............................................................6 Executive Director Fawn C. Armstrong
When
Proposal Avoiding Probate
1 Passageof. Contingent Does
. . . . . . . . . . .Fee Not
. . . .Avoid
.............6
The Economics
Family Law Issues in the Time of COVID-19 ..............................8 Ashley A. Londy
a Mess:
Proceed Pitfalls and
with Caution – Why StrategiesState when
Equalized Value may Local Members of the State Bar of Michigan
Plaintiff
Rights and Employment
Obligations UnderCases ...............................8
the Designations
Planning
not be Your with Beneficiary
Client’s Friend . . . . . . . . . . .................10
............ 7 Board of Commissioners
Collaborative Divorce: Here to Stay!
Families First Coronavirus Response Act ...................................10 Executive Director
and Ladybird Deeds...........................................8
Shared Neutrality
Mediator
Michigan’sDriveway .Agreements
New Initial Disclosure . . . . .........................11
. . . . . . Rule .................. 9 Kyeena
AndrewG. SlaterIII - Commissioner at Large
F. Fink,
Erane C. Washington - District G
in No-Fault Cases ...................................................................12 Res Ipsa Loquitur Editor
Departments
Departments LocalA.Members
Teresa Killeen of the State Bar of Michigan
Asked & Answered.............................................4 Representative Assembly - 22nd Circuit
Departments
Asked & Answered ............................................4
President’s Message..........................................5
Local Member of the State Bar of Michigan
Departments
President’s
President’s Message
Message .........................................5
..................................................................5
New Members.................................................12
New Members & Member Notes .....................12
Board ofD.Commissioners
Jonathan
Mark W. Jane
Hon. Erane
Erane
Goslow
C. Washington - District G
C. Washington
Elizabeth C. Jolliffe - District G
Asked
Asked & Answered
Answered ............................. 4
....................................................................4 Elizabeth A. Kitchen-Troop
President’s Message . . . . . . . . . . . . . . . . . . . . . . . . . .16. . 5
In Memoriam ......................................................................... Local Members of the State Bar of Michigan
John W. Reiser, III
Advertiser
New Members
Advertiser . . . . . .Index
. . . . . . . . . . . . . . . . . . . . . . . . .16. . 12 Representative Assembly - 22nd Circuit
. . . . . . . . Index
New Members ........................................................................
Classifieds . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Mark W. Jane
Jonathan
Res Ipsa D. Editor
Goslow John W. Reiser, III
Andrews Hooper Pavlik PLC...............................2 Elizabeth
Mark C. Jolliffe
W. Jane Marla A. Linderman
Alex Milshteyn Real Estate Associates ...............2 Teresa Killeen
Arbitration & Mediation Services.....................12 Elizabeth A. Jolliffe
Kitchen-Troop
Advertiser
Andrews Hooper Pavlik Index PLC ..............................2
C.
Advertiser Index
Modern
MasseyHooper
Andrews
Court
& Associates
Reporting
Pavlik PLC
& Video, LLC...............7
Valuation Services ............9
.......................................................2
Elizabeth A. Kitchen-Troop
Office
Alex Evolution...............................................10
Milshteyn Real................................................9
Estate Associates . . . . . . . . . . . . . . 2 Local Member of the State Bar of Michigan Young
Office
Weber’s Evolution
Inn ..............................................................................2 Official Notice
Weber’s Inn.......................................................2 Lawyers Section Executive Council
Andrews
Weber’s Hooper Pavlik PLC . . . . . . . . . . . . . . . . . . . . 2
Inn &....................................................12 Items for publication and questions concerning editorial content should be di-
Yeo & Yeo CPAs Business Consultants ..................................14 Amy
rectedS.
to Krieg
the Editor, Teresa Killeen, WCBA, 101 E. Huron, P.O. Box 8645, Ann
Massey
Yeo & &YeoAssociates
CPAs & Valuation
Business Services Consultants . . . . .............7
. . . . . . . 12 Arbor, MI 48107, killeent@washtenaw.org Inquiries concerning advertising
Office Evolution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Official Notice
should be directed to Kyeena G. Slater, Executive Director, 101 E. Huron, 1st
Items
Floor,forP.O.
publication and questions
Box 8645, Ann Arbor, concerning
MI 48107, editorial
Phone:content should be directed
734-994-4912, fax to the
734-
Weber’s Inn . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Editor, Teresa email:
663-2430, Killeen, slaterk@washtenaw.org.
WCBA, 101 E. Huron, P.O. Box 8645, Ann Arbor, MI 48107,
killeent@washtenaw.org
The magazine Res Ipsa Inquiries concerning
Loquitur advertising
is published should be by
bi-monthly directed to Kyeena G.
the Washtenaw
Slater,
County Executive Director, 101101
Bar Association, E. Huron, 1stFloor,
E. Huron, 1stP.O.
Floor,BoxP.O.
8645, Ann8645,
Box Arbor, Ann
MI 48107,
Arbor,
MI 48107.
Phone: Teresa Killeen,
734-994-4912, Editor. email: slaterk@washtenaw.org.The magazine
fax 734-663-2430,
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and advertisements that appear in the Res Ipsa Loquitur do not necessarily reflect the
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Res
ResIpsaIpsa
Loquitur
Loquitur 33
Res Ipsa Loquitur 3
Asked
&
Answered
Thomas
Hon. TracyC.
VanManchester
den Bergh
I have lived in Ypsilanti since 1947 and am married to Mary (Fitzharris) Manchester whom I met while we were
Judge Tracy Van
students den Bergh
at Eastern was elected
Michigan by the voters
University. We have of Washtenaw
four children County in 2020
and nine and took theIbench
grandchildren. on January
received my law 1, 2021.
degree
Before practicing law, Judge Van den Bergh first earned her Bachelor’s and Master’s degrees in social work
from the University of Michigan Law School, graduating in 1968, passing the Michigan Bar exam and beginning from New York
practiceAs
University. inaYpsilanti that same
clinical social workeryear.
andIMental
can beHealth
reached at tom@mackmanlaw.com.
Director, she diagnosed and treated children, adults, and families
struggling with substance abuse and mental health issues. Judge Van den Bergh subsequently earned her Juris Doctor from
Did you
Michigan Statealways
Collegeknow
of Law,you wantedinto
graduating thebetopan5%attorney?
of her class.Where
did you get your law degree? Anything else interesting? Describe a perfect day off.
As an
I hadattorney, Judge
no idea Van Iden
what Berghto
wanted handled
do to cases
makeinaaliving
broad number
when Iofgotpractice areas,
A day while
with myfocusing
wife ononahigh-conflict
Top 100 golf litigation and serving
course.
particularly vulnerableI individuals
out of college. was selling andreal
families.
estatePrior to being
while seated on
in college andthe circuit court, she served in the office of the Michigan Attorney General,
where she managed
thought complex
that would be litigation in the Health,I took
a good possibility. Education, and Family
the LSAT as a Services
WhatDivision.
are some For of
eight years,
your she also provided
favorite places thatcomprehensive
you have vis-
legallark and to
services didover
well. I applied
1,000 to Harvard,
disadvantaged WashtenawDuke andresidents
County Michigan. ited?
as a staff, and later a supervising attorney at Legal Services of South Central
Michigan
Michigan accepted
(LSSCM). me, so
At LSSCM, sheI went there forserved
simultaneously my legal
as a Field InstructorAlaska
education. (unbelievable);
for Eastern London
Michigan University’s (historical);
School Paris (romantic);
of Social Work.
I come from a family of lawyers on my father’s side so it must and Ireland (Mary’s roots).
be
Did youin the
always blood.
know you wanted to be an attorney? In the past I was an advocate for one position, so being a judge is quite
What are your favorite local hangouts?
About what age did you decide to pursue law school?
What jobs did you have before you became an attorney? different. Sidetrack Now,inmy biggestTown;
Depot challenge is trying toGrill
Common figureinoutChelsea;
which sideand
is
No.IIcaddied
am the firstforlawyer
three in years, was aand
my family truck
did driver for to
not decide a produce telling the truth when
go to law com- Gratzi’s in Ann Arbor I am faced with very different stories and no third-
pany
school one
until I wassummer,
31, afterworked melting
I had already scrap metal
been practicing as a and pouring party information.
clinical
social worker. My work as a social worker motivated me to go to lawfactory When you have a little extra money, where do you like to
molten steel into ingots one summer, worked in a GM
one summer, and sold real estate. spend
Tell us ait?
little about your family.
school so I could address related issues in the legal system.
Family, golf and travel.
What area of the law do you like the best and why? I have been married for 26 years to my husband Larry. Our daughter
I don’t
Where did“like”
you get any yourparticular area more
undergraduate What isdo21you
than others. I started out Isabelle
degree? and like to do ready
just getting in your spare time?
to graduate Hobbies?
from University of
as a general practitioner and followed the demand. Right now, Vermont. Lots of golf,
We a fair
share amount
our home of travel,
with three grandchildren’s
bullmastiffs, a eventsaand
dachshund,
NewI mostly
York University.
do small estate planning, probate and real estate, and horse, family andgatherings.
two rescued parrots.
am trying to work less than full time.
What would your second career choice have been if being an Why do you choose to be a member of the WCBA? What
Tell usdidn’t
attorney a little
workaboutout?your family. Do yougreatest
is the travel much?
benefit Where
you are
have some of your
enjoyed asfavorite
a member? places?
My wife, Mary, is retired from teaching elementary, reading My WCBA represents an outstanding group of lawyers
family and I love to travel. Some of my favorite places are Costa and Rica,
pro-
Physician.
and special education. I have two sons who are lawyers, but Australia, vides professional
and Africa. Iand
lovesocial focus forthat
going anywhere manyI canofseethose lawyers.
animals in their
don’t practice; my third son is an investment advisor with Ed- natural My greatest benefit has been the resources made available by
environment.
wardofJones;
Words wisdom andtomy passdaughter
on to new teaches
lawyers?middle school language the WCBA.
Or most
arts. We
valuable have
lesson nine grandchildren,
learned in life? the oldest being a pre-med
student in the Lymon-Briggs honors college at Michigan State. What person, living or dead, real or fictional, would you
If you
Wedospend
not like the work
a great youofare
deal doing,
time change it.
involved in And, if you
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returning a child to the care of their custodial parent.
44 May/June2019
May/June 2021
The Washtenaw County Bar Association – chine. On July 1st, Mark Jane will step up as President. I look for-
Greetings
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