Thomas Frampton

Climenko Fellow and Lecturer on Law

Harvard Law School
Griswold Hall 106 North Suite
Telephone (617) 496-4660
Fax (617) 495-5125
Email tframpton@law.harvard.edu
Affiliation for identification only

March 9, 2020

Office of Disciplinary Counsel

4000 S. Sherwood Forest Blvd., Suite 607
Baton Rouge, Louisiana 70816

To Whom It May Concern:

Undersigned counsel, on behalf of his client Lerone Lewis, writes concerning

possible violations of the Louisiana Rules of Professional Conduct by three Louisiana
attorneys (Scott Vincent, Kyle Daly, and Leon Cannizzaro). This letter sets forth the basic
procedural history of Mr. Lewis’s criminal case, and then highlights ways in which each
attorney’s conduct may have violated the Rules of Professional Conduct. A writ application
seeking review of the Fourth Circuit Court of Appeals’ recent denial of Mr. Lewis’s appeal is
currently pending before the Louisiana Supreme Court.

I. Procedural History

Mr. Lewis was charged with aggravated battery by the Orleans Parish District
Attorney on December 5, 2017 in Case No. 538-804 “K”. His first trial ended in a hung jury.
Mr. Lewis’s second trial began on October 17, 2018. Over Mr. Lewis’s multiple
objections (and the State’s acquiescence), the trial court declared a mistrial after the jury
was empaneled and sworn. The trial court was evidently unaware that jeopardy attaches in
a criminal case once the jury is empaneled and sworn. But see Martinez v. Illinois, 134 S.Ct.
2070, 2072 (2014) (“Our cases have repeatedly stated the bright-line rule that ‘jeopardy
attaches when the jury is empaneled and sworn.’”) (citing Crist v. Bretz, 437 U.S. 28, 35
(1978)).
On October 18, 2018, the District Attorney elected to try Mr. Lewis a third time.
Before trial, the trial court ruled that a key witness was “unavailable” (and, hence, the

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State could offer a transcript of her previous testimony in lieu of live testimony); the ruling
came after a perfunctory evidentiary hearing at which a single witness, with almost no
knowledge of the case, testified that he had been unable to locate the witness that morning
at a Baton Rouge address. The trial court also rejected Mr. Lewis’s double jeopardy claim
(explaining it acted properly in discharging the sworn jurors, some of whom were
empaneled on their final day of scheduled jury duty) and the third trial commenced. This
time, Mr. Lewis was convicted. The trial court eventually sentenced Mr. Lewis to 20 years
in prison as a “second offender.”
The Louisiana Appellate Project (LAP) was assigned to represent Mr. Lewis on
appeal. After both the LAP attorney and Scott Vincent (on behalf of Leon Cannizzaro) had
filed appellate briefs, undersigned counsel reviewed the pleadings. Counsel discovered that,
on behalf of District Attorney Cannizzaro, Mr. Vincent made at least two significant
misrepresentations: he repeatedly cited a non-existent statute (La. C. Cr. P. art. 1767) in
justifying the declaration of the mistrial, and he falsely claimed that testimony had been
adduced at an evidentiary hearing establishing that the missing witness was, in fact,
legally “unavailable.” See infra Part II.A.1. Dismayed at the representations contained in
the District Attorney’s brief—and that Mr. Lewis’s appointed appellate attorney had failed
to recognize these errors, file a Reply Brief, or request oral argument—undersigned counsel
volunteered to represent Mr. Lewis pro bono. The Fourth Circuit granted counsel
permission to enroll and to file a supplemental brief and granted his out-of-time request for
oral argument. Argument was heard on December 2, 2019, with Mr. Daly enrolling to
present oral argument in lieu of Mr. Vincent.
On December 16, 2019, shortly after oral argument but before any appellate ruling,
undersigned counsel met with Mr. Cannizzaro to discuss his representatives’ lack of candor
with the appellate court. See infra Part II.C.1. Counsel pleaded with Mr. Cannizzaro to
advise the Fourth Circuit that he did not stand by his representatives’ false statements of
fact and law. As discussed more fully below, Mr. Cannizzaro privately acknowledged the
false representations contained in his representative’s brief, but ultimately demurred.
On February 12, 2020, Mr. Lewis’s conviction was affirmed by the Fourth Circuit
Court of Appeal. The court did not rely on the fake statute cited by Mr. Vincent, but
adopted wholesale his false factual representations concerning the evidentiary hearing.
This letter follows.

II. Misconduct

A. Scott Vincent

1. Facts

Scott Vincent is an appellate specialist with the Orleans Parish District Attorney’s
office who was assigned to Mr. Lewis’s appeal. He authored a brief in Mr. Lewis’s case on
behalf of Mr. Cannizzaro, whose name appears on the cover page of the brief. In responding
to Mr. Lewis’s appeal, Mr. Vincent made the following misrepresentations, which went to
the very core of Mr. Lewis’s appellate claims:

• In response to Mr. Lewis’s Confrontation Clause claim (i.e., that the trial
court committed reversible error when it declared a key witness
“unavailable”), Mr. Vincent argued that the trial court ruled properly based

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 on evidence adduced at a pre-trial evidentiary hearing. Mr. Vincent claimed
that, at this hearing, multiple witnesses testified as to exhaustive,
unsuccessful efforts to locate the missing witness. Curiously, however, Mr.
Vincent’s brief failed to make any citations to the record to support these
claims. Such citations were impossible, because the actual evidentiary
hearing that occurred prior to the trial court’s ruling involved only one
witness, Thomas Ripp. Mr. Ripp testified (1) that earlier that very morning
he had made his “one and only attempt” to serve the witness at a bad
address provided to him by someone else; and (2) he knew nothing about
the case or the absent witness apart from that.

• In response to Mr. Vincent’s Double Jeopardy Clause claim, Mr. Vincent

repeatedly relied on La. C. Cr. P. art. 1767 to justify the trial court’s actions.
Specifically, Mr. Vincent claimed that La. C. Cr. P. art. 1767 allowed the
trial court to dismiss the jurors in Mr. Lewis’s second criminal trial prior
to the taking of evidence, such that the declaration of the mistrial on
October 17, 2018 was proper (and hence the third trial did not offend the
prohibition against Double Jeopardy). The problem with this argument is
that there is no such thing as La. C. Cr. P. art. 1767. This, of course, was
almost certainly known to a senior appellate attorney who has been
handling criminal appeals for years.

Although the Fourth Circuit made no reference to the fabricated statute when it
denied Mr. Lewis’s appeal, it relied heavily on Mr. Vincent’s incorrect factual account of the
evidentiary hearing. Based on Mr. Vincent’s representations, the Fourth Circuit decided
that Mr. Lewis’s Confrontation Clause rights had not been violated because the witness
was, indeed, “unavailable.”1 Below, I summarize the evidence that was actually adduced;
the evidence Mr. Vincent falsely stated was adduced; and the final ruling of the Fourth
Circuit.

1. The Evidentiary Hearing

The State called one witness, Thomas Ripp, a sheriff’s office employee assigned to
the District Attorney’s office. Trial Tr. (Oct. 17, 2018) at 124:11-124:12. Mr. Ripp testified
that at 12:52PM that afternoon, he had gone to 1536 Lake Calais Court in Baton Rouge,
Louisiana. Id. at 124:17-23. It was a bad address: the occupant (a woman who identified
herself as Ms. Miles) had never heard of Ms. Fowler and had no idea if Ms. Fowler had ever
lived at that address. Id. at 124:26-124:32. Ms. Miles had lived at the address since
February 2018. Id. Mr. Ripp had no idea why the State thought Ms. Fowler might be found
at that address: “They handed me the subpoena at eleven o’clock today and they told me to
go to that address and attempt to service. I don’t know where the address actually came
from.” Id. at 125:1-125:4. He said he “think[s]” that “they” told him the address came from a

1 The Fourth Circuit additionally concluded that any Confrontation Clause violation
was likely “harmless,” a position not even Mr. Vincent urged in briefing. As explained in
Mr. Lewis’s pending writ application before the Louisiana Supreme Court, such a
conclusion is possible only if the appellate court did not actually review the trial transcript
in Mr. Lewis’s case—which appears to be what occurred.
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“TLO”; neither the witness nor the assistant district attorney questioning the witness had
any idea what the letters “TLO” stand for. Id. at 124:4-19. On cross-examination, Mr. Ripp
admitted that his efforts that morning constituted his first involvement in Mr. Lewis’s case.
Id. at 126:7-126:9. As far as Mr. Ripp knew, no other investigators had sought to find Ms.
Fowler. Id. at 126:10-126:12. His effort to find Ms. Fowler at this address was the “one and
only attempt” to find her in person. Id. at 127:20. Mr. Ripp was the only witness called at
the evidentiary hearing. The trial court then ruled: “I’m going to allow it. Let’s get this trial
started.” Id. at 128:16-17. Mr. Lewis objected. Id. at 128:31.

2. Mr. Vincent’s Fourth Circuit Brief

Without citing to the record, Mr. Vincent told the Fourth Circuit that a very
different evidentiary hearing took place:
Prior to the presentation of opening statements on October 17, 2018, a hearing
was conducted outside the presence of the jury as to the efforts made by the
State to subpoena the witness [Ms. Fowler]. During the hearing, two District
Attorney investigators testified that each investigator attempted to serve Ms.
Fowler at her last two known addresses in Baton Rouge, the address at which
she was living at the time of the first trial, and her more recent address in
Patterson. The witness was not present at either address. The investigator
spoke to neighbors at the Baton Rouge address, who stated that Ms. Fowler
had moved but did not know her recent address. Neighbors at the Patterson
address were shown a photograph of Ms. Fowler but did not recognize her. The
investigator placed a copy of the subpoena inside the door at both residences.
At the conclusion of the hearing, the trial judge declared the witness
unavailable and admitted the transcript of her testimony from the prior trial.
State’s Fourth Cir. Br. at 6-7. In the five sentences describing the hearing, there are at least
seven significant misrepresentations: (1) two D.A. investigators did not testify; (2) the
testimony established a total of one in-person attempt to find Ms. Fowler at one location, not
multiple visits to multiple addresses by two individuals; (3) the residents at the Baton Rouge
address did not say that Ms. Fowler was ever their neighbor, nor that Ms. Fowler “had
moved”; (4) there was no testimony about a visit to a Patterson address, or any other Baton
Rouge address apart from 1536 Lake Calais Court; (5) there was no testimony that D.A.
investigators showed residents in Patterson a photograph of Ms. Fowler; (6) there was no
testimony that individuals in Patterson denied recognizing Ms. Fowler; and (7) there was no
testimony that a subpoena was left inside the door at either a Baton Rouge or Patterson
address.

3. The Fourth Circuit’s Opinion

The Fourth Circuit copied Mr. Vincent’s false account of the evidentiary hearing
verbatim, including all seven of the aforementioned misrepresentations, often using the
same combination of words in the same order. Here are the two documents presented side-
by-side:

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 FOURTH CIRCUIT OPINION (p. 8) MR. VINCENT’S BRIEF (p. 6-7)

Prior to opening statements, the district Prior to the presentation of opening

court conducted a hearing outside the
presence of the jury concerning the State’s
efforts to subpoena L.F.
According to the State,
two District Attorney investigators
attempted to serve a subpoena on L.F. for
the third trial. Service was attempted on
L.F. at her last two known addresses, one
in Baton Rouge and the other in Patterson,
but L.F. could not be located.
The investigators spoke to L.F.’s
neighbors at the Baton Rouge address and
were told she had moved away to an
unknown location. Neighbors at
the Patterson address were shown a
photograph of L.F., however, no one
recognized her. Investigators left
a copy of the subpoena at both addresses
.... At the conclusion
of the hearing, the district court declared
the witness unavailable and admitted the
transcript of her testimony.
statements on October 17, 2018, a hearing
was conducted outside the presence of the
jury as to the efforts made by the State to
subpoena [L.F]. During the hearing,
two District Attorney investigators
testified that each investigator attempted
to serve [L.F.] at her last two known
addresses in Baton Rouge, the address at
which she was living at the time of the first
trial, and her more recent address in
Patterson. The witness was not present at
either address. The investigator spoke to
neighbors at the Baton Rouge address, who
stated that [L.F.] had moved but did not
know her recent address. Neighbors at
the Patterson address were shown a
photograph of [L.F.] but did not recognize
her. The investigator placed
a copy of the subpoena inside the door at
both residences. At the conclusion
of the hearing, the trial judge declared the
witness unavailable and admitted the
transcript of her testimony from the prior
trial.

The Fourth Circuit later clarified in its opinion that the court was not merely reciting what
Mr. Vincent claimed had occurred at the evidentiary hearing, but actually endorsing Mr.
Vincent’s account as a true chronology of what happened at the hearing: “At the hearing
to determine whether L.F. should be declared unavailable, the District Attorney’s
investigators made clear that, despite their good faith efforts to subpoena L. F., they
were unable to locate her. Therefore, L.F. was ‘unavailable’ to testify.” State v. Lewis, No.
2019-KA-0448 (La. App. 4 Cir. 2/12/2020), p. 10 (emphasis added). There is no way the
Fourth Circuit would have made this error—crediting the testimony of multiple District
Attorney investigators—had it not been relying on Mr. Vincent’s false representations.

2. Relevant Rules of Professional Conduct

Rule 3.3(a) provides that a lawyer shall not knowingly “make a false statement of
fact or law to a tribunal or fail to correct a false statement of material fact or law previously
made to the tribunal by the lawyer.” Given the circumstances (i.e., Mr. Vincent’s years of
experience and the absence of citations to the Record in support of his false factual claims),
there is reason to believe Mr. Vincent’s misstatements were intentional. He made
misstatements of law (invoking a non-existent Code article); he made misstatements of fact

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(inventing large portions of an evidentiary hearing). Even if Mr. Vincent recklessly made
the aforementioned errors, he likely knowingly failed to correct these errors after the
misstatements were pointed out to him in subsequent court filings. At no time before the
Fourth Circuit’s ruling did Mr. Vincent file a motion to withdraw in this case, and under
Rule 3.3(c), “[t]he duties stated in [Rule 3.3](a) continue to the conclusion of the
proceeding[.]”
Rule 8.4(c) provides that it is professional misconduct for a lawyer to “engage in
conduct involving dishonesty, fraud, deceit or misrepresentation.” For the reasons stated
above, Mr. Vincent’s conduct may implicate this rule.
Rule 8.4(d) provides that it is professional misconduct for a lawyer to “engage in
conduct that is prejudicial to the administration of justice.” For the reasons stated above,
Mr. Vincent’s conduct may implicate this rule.
To the extent that any of the foregoing implicates “an arguable question of
professional duty,” and Mr. Vincent acted “in accordance with a supervisory lawyer’s
reasonable resolution” of that question, Mr. Vincent would not have violated Louisiana’s
Rules of Professional Conduct. Rule 5.2(b). As explained below, see infra Part II.C.1, Mr.
Cannizzaro stated on December 16, 2019 that he would personally consult with Mr. Vincent
regarding Mr. Lewis’s matter. Undersigned counsel has no knowledge regarding the extent
to which Mr. Vincent was “acting in accordance” with Mr. Cannizzaro’s instruction from
that point forward.

B. Kyle Daly

1. Facts

Shortly before oral argument on December 2, 2019, Mr. Daly filed a motion to enroll
to handle oral argument on Mr. Vincent’s behalf. Mr. Lewis opposed Mr. Daly’s motion to
enroll, highlighting the numerous “apparently deliberate misrepresentations” in Mr.
Vincent’s brief and arguing that “Mr. Vincent [should be] require[d] to appear and defend
his statements to this court.” The court granted Mr. Daly’s motion on the morning of oral
argument. He remained an attorney of record until the time of the Fourth Circuit’s ruling.
At no time before or after oral argument did Mr. Daly filed a “Notice of Error”
correcting misstatements in Mr. Vincent’s brief. When directly questioned by the Fourth
Circuit judges at oral argument, Mr. Daly vouched for Mr. Vincent, and provided general
assurances that there were no intentional misrepresentations in Mr. Vincent’s brief.

2. Relevant Rules of Professional Conduct

Rule 3.3(a) provides, in relevant part, that a lawyer shall not knowingly “fail to
correct a false statement of material fact or law previously made to the tribunal by the
lawyer.” To the extent that the misstatements of Mr. Vincent are attributable to Mr. Daly
by virtue of Mr. Daly enrolling and becoming counsel of record before oral argument, Mr.
Daly’s failure to correct these false statements could violate Rule 3.3.
Rule 5.1(c)(1) provides that a “lawyer shall be responsible for another lawyer’s
violation of the Rules of Professional Conduct if . . . the lawyer . . . with knowledge of the
specific conduct, ratifies the conduct involved.” Upon enrolling as counsel of record in Mr.
Lewis’s appeal before the Fourth Circuit, Mr. Daly’s conduct (including vouching for Mr.
Daly before the Fourth Circuit and failing to file a Notice of Error) may constitute
“ratif[ying]” the conduct of Mr. Vincent. Notably, Rule 5.1(a)(c)(1) applies to all “lawyer[s]”
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(without limitation), unlike Rule 5.1(a)(c)(2), which applies only to a lawyer who “is a
partner or has comparable managerial authority.”
Rule 8.3(a) requires lawyers to report Rule violations that “raise[] a question as to
[another] lawyer’s honesty, trustworthiness or fitness.” Despite working together with Mr.
Vincent on appellate matters, and despite serving as co-counsel with Mr. Vincent in Mr.
Lewis’s case, Mr. Daly has taken no steps to flag his colleague’s conduct for either the
tribunal or this body (to undersigned counsel’s knowledge). He has done so despite being
subjectively aware that Mr. Vincent’s brief contained misrepresentations.
Rule 8.4(c) provides that it is professional misconduct for a lawyer to “engage in
conduct involving dishonesty, fraud, deceit or misrepresentation.” Whether or not Mr.
Daly’s violated Rule 3.3(a), his failure to correct the record and/or to file a Notice of Error,
and his decision to defend the State’s meritless brief may qualify as “conduct involving
dishonesty . . . or misrepresentation.” For this reason, Mr. Daly may have violated Rule
8.4(c).
Rule 8.4(d) provides that it is professional misconduct for a lawyer to “engage in
conduct that is prejudicial to the administration of justice.” For the reasons stated above,
Mr. Daly may have violated Rule 8.4(c).

C. Leon Cannizzaro

1. Facts

Scott Vincent’s brief was filed on behalf of District Attorney Leon Cannizzaro, whose
name appears on the cover page of the brief. On December 16, 2019, undersigned counsel
met with Mr. Cannizzaro in his office at 609 S. White Street to ask him to correct the record
in Mr. Lewis’s case.
Mr. Cannizzaro stated that he was familiar with Mr. Lewis’s case, and had already
spoken with Mr. Daly “at length” about the matter. In the presence of undersigned counsel,
Mr. Cannizzaro reviewed a copy of Mr. Vincent’s brief, with Mr. Vincent’s false account of
the evidentiary hearing highlighted in yellow by undersigned counsel. Undersigned counsel
explained to Mr. Cannizzaro that Mr. Vincent’s account of the evidentiary hearing
concerning the absent witness was false. Counsel also explained that Mr. Vincent had
argued the trial court’s dismissal of the jury in Mr. Lewis’s trial was proper under the non-
existent La. C. Cr. P. art. 1767. Mr. Cannizzaro indicated he recognized the falsity of Mr.
Vincent’s representations, expressing puzzlement at the mention of Article 1767 and
consulting his Code of Criminal Procedure (to confirm that no such article existed).
Whereas at that very moment (before the Fourth Circuit) his representatives
defended against Mr. Lewis’s double jeopardy claim by invoking La. C. Cr. P. art. 1767, Mr.
Cannizzaro privately acknowledged that there was no such thing La. C. Cr. P. art. 1767.
Whereas (before the Fourth Circuit) his representatives defended the declaration of a
mistrial in Mr. Lewis’s second trial as prudent and proper, Mr. Cannizzaro stated that the
mistrial had come about because the trial judge “didn’t know what the fuck he was doing”;
he shared his belief that the trial court’s mistrial declaration occurred because “the judge
just got lazy like he normally does over there”; he described the trial court’s actions as
“pathetic” and “incompetent.”
Undersigned counsel asked Mr. Cannizzaro how he could express such views
privately, while simultaneously presenting a contrary (and incorrect) version of the facts
and law to the Fourth Circuit. Specifically, counsel begged: “I don’t understand why you
wouldn’t tell . . . the Fourth Circuit” what he had admitted privately. Undersigned counsel
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shared his belief that Mr. Cannizzaro had an ethical obligation to do so. And, at moments
during the meeting, Mr. Cannizzaro seemed prepared to take action. He assured counsel
that he would speak with his subordinates and if there was anything “that they cannot
justify as square with me,” he would rectify the problem and “change it.” He assured
counsel would address the matter.
But simultaneously, Mr. Cannizzaro shared his reluctance to make any sort of
representation to the Fourth Circuit: “I gotta fight as best I can to keep this guy off the
streets as long as I can.” Neither Mr. Cannizzaro nor his subordinates corrected the record
with the tribunal before or after the Fourth Circuit’s ruling on February 12, 2020.

2. Relevant Rules of Professional Conduct

Rule 3.3(a) provides, in relevant part, that a lawyer shall not knowingly “fail to
correct a false statement of material fact or law previously made to the tribunal by the
lawyer.” To the extent that the misstatements of Mr. Vincent are attributable to Mr.
Cannizzaro by virtue of (1) Mr. Cannizzaro’s name appearing on the brief, (2) Mr. Vincent
acting as Mr. Cannizzaro’s representative, and (3) Mr. Cannizzaro’s subjective knowledge of
the statements, Mr. Cannizzaro’s failure to correct these false statements may violate Rule
3.3.
Rule 5.1(a) provides that a lawyer who possess “managerial authority” comparable
to a partner in a law firm “shall make reasonable efforts to ensure that the firm has in
effect measures giving reasonable assurance that all lawyers in the firm conform to the
Rules of Professional Conduct.” Given Mr. Cannizzaro’s subjective knowledge of the facts of
Mr. Lewis’s case, and given the recent conduct of Mr. Vincent described in a separate letter
being submitted today, Mr. Cannizzaro’s conduct may implicate this provision.
Rule 5.1(b) provides that “a lawyer having direct supervisory authority over another
lawyer shall make reasonable efforts to ensure that the other lawyer conforms to the Rules
of Professional Conduct.” Given Mr. Cannizzaro’s subjective knowledge of the facts of Mr.
Lewis’s case, and given the recent conduct of Mr. Vincent described in a separate letter
being submitted today, Mr. Cannizzaro’s conduct may implicate this provision.
Rule 5.1(c)(1) provides that a “lawyer shall be responsible for another lawyer’s
violation of the Rules of Professional Conduct if . . . the lawyer . . . with knowledge of the
specific conduct, ratifies the conduct involved.” Mr. Cannizzaro’s failure to inform the
Fourth Circuit of those misrepresentations made in his name may constitute “ratif[ying]”
Mr. Vincent’s conduct. Rule 5.1(c)(2) provides that a “lawyer shall be responsible for
another lawyer’s violation of the Rules of Professional Conduct if . . . the lawyer . . . has
comparable managerial authority [to a partner] in a law firm in which the other lawyer
practices . . . and knows of the conduct at a time when its consequences can be avoided or
mitigated but fails to take reasonable remedial action.” In Mr. Lewis’s case, Mr. Cannizzaro
was aware of Mr. Vincent’s false account of the evidentiary hearing “at a time when its
consequences can be avoided or mitigated” (i.e., before the Fourth Circuit ruled), yet failed
to inform the tribunal of this information.
Rule 8.3(a) requires lawyers to report Rule violations that “raise[] a question as to
[another] lawyer’s honesty, trustworthiness or fitness.” Despite being the employer of
Messrs. Vincent and Daly, and despite being personally aware of their work on Mr. Lewis’s
case, Mr. Cannizzaro (to undersigned counsel’s knowledge) has taken no steps to flag his
colleagues’ misconduct for either the tribunal or this body.
Rule 8.4(c) provides that it is professional misconduct for a lawyer to “engage in
conduct involving dishonesty, fraud, deceit or misrepresentation.” Whether or not Mr.
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Cannizzaro violated Rule 3.3(a), his failure to correct the record and/or to file a Notice of
Error, and his decision to stand by the State’s meritless representations may constitute
“conduct involving dishonesty . . . or misrepresentation.” For this reason, Mr. Cannizzaro
may have violated Rule 8.4(c).
Rule 8.4(d) provides that it is professional misconduct for a lawyer to “engage in
conduct that is prejudicial to the administration of justice.” For the reasons stated above,
Mr. Cannizzaro may have violated this Rule.

***
This case aptly demonstrates why candor to the tribunal is so critical: overburdened
appointed counsel (and perhaps overburdened judges) can’t always catch false statements
contained in prosecutors’ briefs. Defendants may spend decades in prison, contrary to the
law, when this occurs. Please do not hesitate to contact me if there is additional information
that I can provide.

Sincerely,

Thomas Frampton

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