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‘Michael L. Parson State of Missouri ‘Sarah HL Steelman ‘Govemor OFFICE OF ADMINISTRATION ‘Commissioner Post Office Box 809 Jefferson City, Missouri 65102 Phone: (573) 751-1851 Fax: (573) 751-1 June 14, 2018 Ross H. Garber Shipman & Goodwin ‘One Constitution Plaza Hartford, Connecticut 06103 Re: Invoice Nos. 536113, 537717, and 53748 Dear Mr. Garber: ‘The Office of Administration isin receipt of and has reviewed your invoices dated ‘April 30, May 30, and May 31, 2018 and totaling $64,096.86 While the Office of Administration has reviewed your engagement letter with the Office of the Governor (though not its attachment) and concluded that the Office of the Governor has authority to retain attorneys “necessary for the efficient conduct of [the] office” (Section 26.020, RSMo), we have determined that your invoices cannot be certified for payment because availabe information fails to demonstrate that this expenditure would bbe within the purpose of the General Assembly's appropriation. It appears that the primary beneficiary of the legal services that your firm rendered was the former Governor individually and that the services were not “necessary for the efficient conduct” of the Governor's Office, which at most received incidental benefits from these services. Very traly yours, Sh Hela Sarah H. Steelman ‘Commissioner

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