On March 31, 2000, State Attorney General Philip T. McLaughlin issued a report entitled "In re: W. Stephen Thayer, III and Related Matters," which brought to light information raising concerns about the conduct of justices of the Supreme Court. The key to the investigation was an unsigned memo, attributed to Supreme Court Clerk Howard Zibel, which was delivered to the Attorney General by Brock’s personal lawyer. The Zibel memo detailed ethical violations by members of the Supreme Court witnessed by the author; which surrounded the conduct of Justice W. Steven T. Thayer III in the Feld’s Case and the appeal of Thayer v. Thayer (his own divorce) and resulted in the criminal investigation of Thayer, which resulted in Thayer resigning to avoid prosecution.