Whether a public official can be criminally liable for honest services fraud when lacking a formal agency or fiduciary relationship with the government entity allegedly influenced

in this case and prepare a petition that fully and concisely addresses the important issues raised by the decision below. The legal issues in this case directly implicate this Court’s substantial honest services fraud jurisprudence, and preparing the petition will require careful study of these numerous precedents to fully present the issues in a manner that will be most helpful to the Court. In addition, the undersigned counsel have substantial professional commitments, including a merits brief due to t