OPINION
PER CURIAM.
This is a disciplinary proceeding against an attorney, James F. Vollintine. Vollin-tine is accused of professional misconduct, consisting of statements that he made in letters to two federal officials. We conclude that Vollintine’s conduct was improper, and sufficiently serious to require public censure by this court.
The proceeding against Vollintine was initiated by the Alaska Bar Association, following receipt of a complaint from Jack M. Allen, Regional Solicitor for the United States Department of the Interior. Allen complained of statements contained in a letter from Vollintine to George Gustafson, Townsite Trustee for the Bureau of Land Management, copies of which had been sent to Allen and others. [Appendix A] The letter was dated December 2, 1980.
At the time that he wrote the letter, Vollintine represented the plaintiffs in a federal quiet title and ejectment action, involving a dispute over lands in and around certain Alaska Native villages. See Alek-nagik Natives Ltd. v. Andrus, 648 F.2d 496 (9th Cir.1980). The defendants in that action included the Secretary of the Interior, Gustafson and others.
In his letter, Vollintine accused Gustafson and another B.L.M. official of “perjury,” asserted that the Secretary of the Interior had committed fraud, alleged that Allen was “cheating and lying” in briefs filed in federal court, and complained of other forms of wrongdoing on the part of federal officials. He warned that Gustafson and Allen might find themselves “criminally liable” and “personally liable in tort,” stating: “If [you] . .. and Allen think you are going to walk away from this townsite matter unscathed, you are wrong.”
In a second letter, dated February 5, 1981, Vollintine wrote to James Watt, Secretary of the Interior. [Appendix B] Vol-lintine criticized Gustafson, Allen and Curt McVee, another department official, stating [757]*757that McVee “is a complete incompetent, ... responsible for screwing up land titles in Alaska, ... a blatant racist, ... [and a person who] constantly creates friction between [Alaska] Natives and non-Natives.” Allen was also labelled “an incompetent” and “a pathological liar,” and was said to have “the reputation of supporting any position of the local B.L.M. office no matter how deceitful or contrary to law.” Gustaf-son, Allen and McVee were all described as “lifer parasites” who should be replaced.
The Disciplinary Board of the Alaska Bar Association,1 adopting a Hearing Committee recommendation, concluded that Vollin-tine was guilty of unprofessional conduct worthy of public censure. [Appendix C] Specifically, the Board found that his actions violated Disciplinary Rules 1-102(A)(5), 7-102(A)(l), and 7-105(A), of the Code of Professional Responsibility. The matter was then submitted to this court, pursuant to Rule II — 15(j), Alaska Bar Rules.
JURISDICTIONAL ISSUES
Vollintine raises three “jurisdictional” issues, contending: (1) that the Hearing Committee was improperly constituted because of the method of the selection of its members; (2) that he is not subject to discipline under the Alaska Bar Rules in this instance, because his alleged misconduct related to matters within the jurisdiction of a federal tribunal; and (3) that Allen, one of those about whom he wrote, is not admitted to practice in Alaska and, therefore, was not entitled to the same treatment due opposing counsel. We have reviewed each of these arguments and conclude that they are entirely without merit.2
FREEDOM OF SPEECH
Likewise, we reject Vollintine’s claim that the imposition of discipline in this instance violates his right of free speech.
In Gregoire v. National Bank of Alaska, 418 P.2d 27, 48 (Alaska 1967), this court administered a public reprimand when an attorney “employed abusive and intemperate language in his brief and ... accused the trial court and opposing counsel of unethical and underhanded conduct.” Here, the situation is much the same.3 We subscribe to the view stated by Justice Stewart, in his concurring opinion in In Re Sawyer, 360 U.S. 622, 79 S.Ct. 1376, 3 L.Ed.2d 1473 (1959):
[A] lawyer belongs to a profession with inherited standards of propriety and hon- or, which experience has shown necessary in a calling dedicated to the accomplishment of justice. He who would follow that calling must conform to those standards.
Obedience to ethical precepts may require abstention from what in other circumstances might be constitutionally protected speech.
[758]*758360 U.S. at 646-47, 79 S.Ct. at 1388, 3 L.Ed.2d at 1489.4
DUE PROCESS
Vollintine also complains that the Disciplinary Rules under which he was cited are overbroad and void for vagueness. The Bar Association argues that those rules incorporate a “reasonable attorney” standard, which gave Vollintine adequate notice of the type of conduct prohibited. See Committee on Professional Ethics v. Durham, 279 N.W.2d 280 (Iowa 1979) (DR 1-102(A)(6) held not void for vagueness).
The Code of Professional Responsibility is necessarily written in broad terms. It would be extremely difficult, if not impossible, to develop standards specifically detailing all forms of attorney misconduct. Although capable of broad interpretation, we believe the meaning of the Disciplinary Rules cited in this case is sufficiently clear to satisfy the requirements of due process.
ETHICAL VIOLATIONS
The Disciplinary Board, as did the Hearing Committee, found that Vollintine’s letter of December 2,1980, violated Disciplinary Rule 7-105(A): “A lawyer shall not ... threaten to present criminal charges solely to obtain an advantage in a civil matter.” This finding, we believe, is supported by the record.
The threat of criminal charges is implicit in the language used. Moreover, we can perceive of no purpose for the letter other than to influence the B.L.M.’s handling of a non-Native application for land in the Village of Aleknagik, the rejection of which would provide an advantage to Vollintine’s clients. Such conduct, we believe, was well within the purview of DR 7-105(A).5
Vollintine was also found to have violated Disciplinary Rule 1-102(A)(5): “A lawyer shall not ... [ejngage in conduct that is prejudicial to the administration of justice.” Again, we believe this finding is supported by the record.
There can be little question that his letters served only to make an already difficult situation worse. The natural consequence of those letters would be to cause an even greater deterioration in the relationship between his clients and their opponents. Regardless of the merits of his position, or that of his clients, a lawyer’s use of such tactics is necessarily prejudicial to the orderly administration of justice. Among the Ethical Considerations found in the Code of Professional Responsibility, we find guidance in the statement: “Haranguing and offensive tactics by lawyers interfere with the orderly administration of justice and have no proper place in our legal system.” EC 7 — 37, Code of Professional Responsibility. Although this particular Ethical Consideration is located in another part of the Code of Professional Responsibility, it states a fundamental principle applicable to all parts of the Code.6
Finally, Vollintine was found to have violated Disciplinary Rule 7-102(A)(l): “A lawyer shall not ... take ... action on behalf of his client, when he knows or when it is obvious that such action would serve merely to harass or maliciously injure another.” This finding was based upon the Disciplinary Board’s conclusion that
he knew or should have known that [his] action would serve merely to harass or maliciously injure another, Jack Allen. The action referred to includes the underlining of inflammatory words; the wide dissemination of the letter of December 2, 1980, and the writing of the letter dated February 5, 1981, not copied to Mr. [759]*759Allen, both of which would serve to maliciously injure Mr. Allen. [Appendix C at 5]
It is clear that the letters, despite Vollin-tine’s assertions to the contrary, were written on behalf of his clients. Moreover, it should be obvious to any lawyer that intemperate statements of the sort contained in Vollintine’s letters can serve no real purpose but to harass the objects of his wrath. While the letters themselves might have served some greater purpose, the inclusion of those statements did not. Again, we find Vollintine’s conduct to be well within the purview of the applicable Disciplinary Rule, DR 7-102(A)(l).
James F. Vollintine is hereby censured for violation of the above mentioned provisions of the Code of Professional Responsibility.7
APPENDIX A
James F. Vollintine
ATTORNEY AT LAW
420 “L” Street, Suite 405
Anchorage, Alaska 99501
907-276-8144
December 2, 1980
George Gustafson, Townsite Trustee
Bureau of Land Management
United States Department of the Interior
701 “C” Street, Box 13
Anchorage, Alaska 99513
Re: Aleknagik Townsite, USS 4873
Dear Mr. Gustafson:
Enclosed is my entry of appearance as attorney of record for Aleknagik village in all matters regarding the Aleknagik town-site. This means that in the future you must send me copies of all correspondence, etc. that you send to any individual or entity concerning the Aleknagik townsite.
As you know, Roland Moody has applied for Lots 7 and 8, Block 8, Tract A, Alekna-gik Townsite. According to the application filed with your office, he moved a 14 X 16 house on the land on April 6, 1980. He claims that he cleared the land in 1970 but Mr. Ilutsik of Aleknagik says that such is untrue.
Mr. Moody moved the building onto the land at a time when there was an outstanding injunction issued by the Ninth Circuit Court of Appeals on June 22, 1979 which directed the Department of the Interior to prevent occupancy claims within the Alek-nagik townsite. Jack Allen wrote to Mr. Moody on May 8, 1980 informing him that he may be in trespass. Mr. Allen, however, has not followed up on the matter. On November 18, 1980 he wrote to Wassillie Ilutsik and advised him that no action would be taken against Mr. Moody until you further investigated his claim, and until your jurisdiction has been clearly established by the courts in the Aleknagik and Klawock cases. Mr. Allen, therefore, is knowingly violating the Ninth Circuit’s order.
There are other reasons why Mr. Moody’s claim to the land must fail. One major reason is that non-Natives are not entitled to rights in Native townsites. Yourself and the BLM have long been illegally administering the Alaska townsite laws by attempting to authorize non-Native occupancy claims in Native villages.
Another reason that Mr. Moody’s claim is invalid is that the Interior Board of Land Appeals ruled on January 17, 1980 that the repeal of the townsite laws on October 21, 1976 closed Alaska townsites to occupancy claims as of that date. See Royal Harris, 45 IBLA 87 (1980). Since Mr. Moody did [760]*760not have any improvements on the land as of October 21, 1976, his claim must fail.
Finally, the Ninth Circuit ruled in the Aleknagik case that there is a substantial probability that the vacant land in the Aleknagik townsite was withdrawn under ANCSA for Native selection. This too would bar Mr. Moody’s claim.
The other day when I was in your office some representatives from the State of Alaska were there inquiring about obtaining land or a right-of-way within the Alek-nagik townsite. You are hereby reminded that on June 22, 1979 the Ninth Circuit closed the Aleknagik, Ekwok and Nondal-ton villages to any sort of occupancy claims and directed the Department to prevent entries, and to notify members of the public that the townsites are closed. Enclosed is a copy of that order.
I advise yourself, the BLM and Mr. Allen to tread softly with these Native townsites. As you know, it is our position that the Secretary fraudulently determined that townsites in Native villages are “valid existing rights” under ANCSA. Then he opened them up to the general public under your screwy, unpublished policy of holding subdivided areas for Natives and unsubdi-vided areas for non-Natives. I have your’s and McVee’s deposition and I believe that I can establish that both of you committed perjury in testifying under oath about these townsites. In fact, there is absolutely no question that you committed perjury in stating in an affidavit before the 9th Circuit that “44 townsites were subdivided after ANCSA.” Jack Allen is cheating and lying in briefs before the 9th Circuit in a desperate attempt to justify the Department’s townsite policies and save his neck in the Alaeknagik case. He is merely buying time. Allen has lied to me all along in this townsite case. Yourself, McYee and Allen may well find yourselves criminally liable in this matter. In addition, your blatant violation of Native rights under ANCSA and the townsite laws may make all three of you personally liable in tort for intentional violation of the Natives’ 5th Amendment rights. What a monstrous act the BLM committed in keeping these townsites from Native selection, then opening them up to the general public in a negligent, haphazard way, without any consideration for the law, the villages’ rights, or land use policy, etc. You have completely gummed up land titles in Native townsites. The Interior Department has Jack Allen to lie in Court for it, but that can only last so long. Allen is attempting to blame everything on the Court, but, as you will see, the Courts will finally straighten this matter out. If yourself, McYee, and Allen think you are going to walk away from this townsite matter unscathed, you are wrong.
Please take prompt action on Mr. Moody’s application so we can get this matter over with. Be sure to give us adequate notice as to when you will be in Aleknagik so we can have representatives attend your meeting with Mr. Moody.
Sincerely yours,
/s/ James Vollintine James F. Vollintine
JFV:ksl
cc: Wassillie Ilutsik
Tom Hawkins
Jack Allen
AFN
Curt McVee
Bob Arnold
Secretary of the Interior
APPENDIX B
907-276-6144
February 5, 1981
Honorable James Watt
18th & “C” Street, N.W.
Washington, D.C. 20240
[761]*761Re: John M. Allen, Alaska Regional Solicitor Curtis V. McVee, BLM State Director
Dear Mr. Watt:
Please accept my congratulations on your appointment as Secretary of the Interior. I am a life-long Alaskan and have been practicing law here since 1974. Approximately 50% of my work involves representing Alaska Native interests before the Department of the Interior. I appreciate your statements that you will attempt to cleanse the Department of as much mismanagement, waste and fraud as possible.
In my opinion, you should fire or relocate Messrs. Allen and McVee. McVee has been the State Director for about 10 years, and Acting State Director before then. He is a complete incompetent and is responsible for screwing up land titles in Alaska. In addition, he is a blatant racist. Under his leadership the BLM kept 98 native villages open to entry by the general public under the townsite laws, in violation of the 1971 Alaska Native Claims Settlement Act and the 1926 Alaska Native Townsite Act. The Department was badly burned on this issue in Aleknagik, et a1. v. Andrus, No. 2896 (9th Cir.) April 7, 1980. McVee constantly creates friction between Natives and non-Natives. Some BLM employees have informed me that he is even more hard-line against the Natives than is the Washington office.
Jack Allen has been the Regional Solicitor since 1975. He is not only an incompetent, but also a pathological liar. He has the reputation of supporting any position of the local BLM office no matter how deceitful or contrary to law. As a result, he has created a lot of problems and has absolutely no credibility with anyone in Alaska, not even the Interior Department.
Since the Department has such massive responsibilities in Alaska, I am hopeful that you will take a sharp look at the Interior affairs up here. In addition to McVee and Allen, Sue Wolf, BLM adjudication, and George Gustafson, townsite trustee, should also get the axe. Only by ridding the Department of these lifer parasites can true policy changes take place. I believe you would do the Country a great service by dismissing or transferring these individuals. Thank you.
/s/James Vollintine James F. Vollintine
APPENDIX C
BEFORE THE ALASKA BAR ASSOCIATION
In the Disciplinary Matter ) Involving ) ) JAMES F. VOLLINTINE, ) ) Respondent. ) _)
ABA File No. 80-140
REPORT OF THE DISCIPLINARY BOARD OF THE ALASKA BAR ASSOCIATION
Following oral argument on May 18, 1982, the Disciplinary Board of the Alaska Bar Association, consisting of Andrew J. Kleihfeld, Harold M. Brown, William B. Ro-zell, Hugh G. Wade and Elizabeth P. Kennedy met and made the following decision:
The Board accepts the introduction of the Hearing Committee Report.
FINDINGS OF FACT
1. Respondent James F. Vollintine is, and at all times relevant to this proceeding has been, an attorney at law admitted to practice in the State of Alaska and a member of the Alaska Bar Association.
2. During the period commencing on or about September, 1977, and continuing through the date of the hearing, Respondent represented nine native entities in litigation against the Secretary of Interior, George E.M. Gustafson and others, such litigation being hereinafter referred to as the Aleknagik case.
3. Jack Allen is an attorney admitted to practice in the District of Columbia but not a member of the Alaska Bar Association.
4. George Gustafson is the Townsite Trustee for the Bureau of Land Management.
[762]*7625. Jack Allen, as Regional Solicitor, represents George Gustafson, Curt McVee and the Secretary of the Interior as his clients and in that capacity was acknowledged by Respondent to be the principal author of the briefs filed on behalf of the government in the Aleknagik case and otherwise primarily responsible for the litigation. (Exhibit B) Court proceedings related to that litigation are, however, generally handled by the U.S. Attorney.
6. Respondent prepared a letter dated December 2,1980, a copy of which is Exhibit A to the Petition, to George Gustafson concerning matters which related to the Aleknagik case and the enforcement of an interim injunction prohibiting new entries onto the Aleknagik Townsite. In that letter, Respondent alleged that Mr. Allen had been “cheating” and “lying” in briefs, that the Secretary of Interior had fraudulently determined townsites were valid existing rights under ÁNCSA, that Curt McVee, State Director, and Mr. Gustafson had committed “perjury,” and that Respondent believed he could prove such perjury. The referenced letter emphasized, as above, the quoted words.
7. The referenced December 2, 1980 letter, in addition to stating Respondent’s belief that he could prove Gustafson committed perjury, advises that there is no question but that Gustafson committed perjury in an identified affidavit, that Mr. Gustaf-son and others may find themselves criminally liable and that Gustafson is wrong if he believes he will walk away from “this townsite matter” unscathed. The letter, in its final paragraph requests Gustafson to take prompt action on a disputed townsite application by Mr. Moody, a non-native, with the inference that the application should be rejected. (This language was understood by both Mr. Allen and Mr. Gustaf-son to be a threat of criminal prosecution, although not one that in fact concerned them. The purpose of the threat was understood by Mr. Allen to be generally to get the Department of the Interior to do what Respondent wanted them to with regard to the townsite matter and to produce the immediate ejectment of Mr. Moody.)
8. Copies of the referenced December 2 letter were sent to two individuals who were representatives of Respondent’s clients, Mr. Allen, Curt McVee, Bob Arnold (Associate State Director with the Department of Interior, in charge of ANCSA), the Secretary of the Interior and the Alaska Federation of Natives.
9. Respondent’s December 2, 1980 letter was cross copied to the Alaska Federation of Natives, although it was not a party to the case and had not participated at all in the case. The February 5, 1981 letter to the Secretary of Interior was not cross copied to Mr. Allen. These choices were intended to maximize extraneous political pressure to achieve the end Respondent sought, and to interfere with Mr. Allen’s opportunity to present the merits of his side of the case.
10. Respondent stated that those copies of the letter directed to employees of the Department of Interior, including Mr. Allen, were for the purpose of letting the people in the Department of the Interior know what a “liar and cheat” Mr. Allen was and to make Mr. Allen mad, or at least with the awareness that the letter would make Mr. Allen mad, because Respondent felt Allen “deserved it.” Respondent said that the copies to the Respondent’s clients and the AFN were intended to let people know “what kind of fraud, lying and cheating” were going on.
11. Respondent testified at the hearing that he considered amending his complaint in the Aleknagik case to allege a tort action against the four subject Interior Department personnel and that he told Mr. Allen in a conversation that he was “playing with fire and we (plaintiffs) could take his house if he didn’t watch his step.” The Committee found this type of communication inappropriate and reflective of Respondent’s intent to harass Mr. Allen.
12. Mr. Gustafson’s reaction to the December 2, 1980, letter was that Mr. Vollin-tine had “slipped a cog” or was drunk. Mr. Allen testified that after receipt of the letter he considered Mr. Vollintine “unbal[763]*763anced.” As a result of the letter Mr. Allen felt he could no longer deal directly with Respondent and any possibility of productive settlement negotiations with regard to the pending case were substantially diminished.
13. Respondent authored the letter dated February 5,1981, to James Watt, Secretary of Interior (Exhibit B to Petition) in which he alleges that McVee is a “blatant racist,” Jack Allen is “incompetent” and a “pathological liar,” and that Gustafson and Sue Wolf are “lifer parasites.” Although Mr. Allen was not copied with that letter, Respondent anticipated that a copy of the letter would eventually be made available to Mr. Allen.
14. Respondent had a subjective belief that the statements he made were true.
15. Respondent admitted during argument of counsel at the hearing before the Disciplinary Board of the Alaska Bar Association:
(a) although Respondent had prior dealings with Mr. Gustafson on other matters, the Moody entry application was the first non-native application passed upon by Mr. Gustafson with regard to the Aleknagik Townsite.
(b) at no time did Respondent move for an order holding either Mr. Allen or Gustaf-son or both in contempt for violating the terms of the Ninth Circuit injunction.
16. There is no evidence that Respondent attempted to determine if disciplinary action could be filed against Mr. Allen in any jurisdiction.
17. The facts adduced before the Area Hearing Committee and those apparent from the various documents filed and arguments made by the parties reflect an inability of Respondent to deal rationally with the subject matter on the persons involved in the decision making process. Respondent was unable or unwilling to deal with the problem in a rational or emotionally detached manner.
18. The only regret expressed by Respondent with regard to the statements and actions taken was to the effect that if he had known it would come to this he would have implied the same illegal activities but in a more carefully phrased manner. Respondent’s stated that he was engaged in “trench warfare” and that his intemperate behavior should be excused.
Based on the above Findings of Fact, The Disciplinary Board makes the following
CONCLUSIONS OF LAW
1. Respondent’s letters of December 2, 1980 and February 5, 1981, are not privileged communications.
2. Respondent has committed misconduct in violation of Disciplinary Rule 7-105(A) by threatening in his letter of December 2, 1980, to present criminal charges (perjury charges) against George Gustafson, a defendant in pending litigation, solely to obtain an advantage in that litigation— prompt and favorable resolution of the Moody townsite application in a manner that would result in Mr. Moody’s ejectment from the property. In particular, the Board finds thát the language “I advise yourself, the BLM and Mr. Allen to tread softly with these Native townsites ... Yourself, McVee and Allen may well find yourselves criminally liable in this matter ... If yourself, McVee and Allen think you are going to walk away from this townsite matter unscathed, you are wrong.” and “Please take prompt action on Mr. Moody’s application... ” indicative of the threat and request for favorable treatment.
3. Respondent has committed misconduct in violation of Disciplinary Rule 7-102(A)(1) by taking action on behalf of a client, Aleknagik plaintiffs, that he knew or should have known that such action would serve merely to harass or maliciously injure another, Jack Allen. The action referred to includes the underlining of inflammatory words; the wide dissemination of the letter of December 2,1980, and the writing of the letter dated February 5, 1981 not copied to Mr. Allen, both of which would serve to harass or maliciously injure Mr. Allen.
4. Respondent has committed misconduct in violation of Disciplinary Rule 1-[764]*764102(A)(5) by engaging in conduct that is prejudicial to the administration of justice. He failed to place the question of Mr. Allen’s or the Interior Department’s conduct before the court in a contempt proceeding or before any disciplinary board and instead copied the letter of December 2,1980, to the Alaska Federation of Natives, not a party to the case, and did not copy the letter of February 5, 1981, to Mr. Allen, in an attempt to maximize extraneous political pressure and to interfere with Mr. Allen’s ability to handle the merits of his side of the case.
5. The Board members are mindful of possible First Amendment rights in this case. They have read the case of Hirschkop v. Snead, 594 F.2d 356 (4th Circuit, 1979) in which the court states:
Drawing on many prior decisions, Mr. Justice Powell formulated a two-step test in Porcunier v. Martinez, 416 U.S. 396, 413, 94 S.Ct. 1800, 40 L.Ed.2d 224 (1974), for determining the constitutionality of governmental restrictions of speech: First, the regulation ... in question must further an important or substantial governmental interest unrelated to the suppression of expression ... Second, the limitation of First Amendment freedoms must be no greater than is necessary or essential to the protection of the particular governmental interest involved, (at 363)
The Board finds that there is a substantial governmental interest in promoting the administration of justice, and that the decision reached herein does not violate the standard of Proeunier.
RECOMMENDED DISCIPLINE
The Hearing Committee made the following recommendation:
The Committee has been advised that Respondent has not previously been subjected to any disciplinary actions and therefore first considered utilization of a private reprimand pursuant to Alaska Bar Rule 12(d). Several factors weigh strongly against that form of discipline, the most important of which is the fact that Respondent would be unaffected by that form of discipline because ... it would not serve in any way to cause Respondent to appreciate the nature of his conduct. That reasoning is based primarily upon Respondent’s testimony and observations of his demeanor during the hearing.
Respondent’s deportment at the hearing and his testimony continued a consistent pattern, vis-a-vis the correspondence of December 2,1980, and he in fact expressed his view that the correspondence complained of was not proper. He has failed throughout to recognize any impropriety insofar as the correspondence is concerned. His utterances at the hearing clearly indicated a lack of perspective and judgment, and he freely offered opinions as to the lack of good faith of opposing parties, their attorney and the trial judge. These individuals were generally termed by Respondent to be either racist or actively hostile to interests of natives. Publication of this type of correspondence or utterance severly damages the public’s perception of the judicial system. As an attorney, Respondent should be aware of proper forums that are available for presenting grievances of this type and he has failed to utilize them.
It further appears, in view of Gregoire v. National Bank of Alaska, 413 P.2d 7, 43-44 (Alaska 1966) which involved attorney comments in court pleadings which were for less vituperous than those involved in the present case; that such misconduct, even in the absence of threatened criminal action, is a serious violation of ethical standards deserving of public censure by the court.
The Board hereby adopts the recommendation of the Hearing Committee for public censure in light of the severity of the misconduct under the Gregoire standard, and because the Board feels that in this particular case, such discipline is necessary.
DATED this 24 day of June. 1982.
/s/ Harold M. Brown HAROLD M. BROWN, Chair
/s/ William B. Rozell WILLIAM B. ROZELL
[765]*765/s/ Elizabeth Page Kennedy ELIZABETH P. KENNEDY, Recorder