A.G. Schneiderman Announces $2.4M Settlement With Corinthian College Loan Provider

A.G. Schneiderman Announces $2.4M Settlement With Corinthian College Loan Provider syndicated from http://personalinjuryattorneyphiladelph.tumblr.com/

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About Eric Bolling’s $50 Million Defamation Suit – And the Ad Damnum Clause Loophole

Eric Bolling

News junkies know that yet another Fox News anchor has been shit-canned over allegations of sexual harassment, this time it being anchor Eric Bolling. Fox has “suspended” him for allegedly sending lewd texts and photos to colleagues.

But I’m not here to deal in the actual details, but rather, the $50 million suit he has filed against his accusers in New York state court, and the procedural quirk that allows him to make that claim despite New York’s apparent prohibition on doing it.

You see, Bolling’s attorney didn’t file a Summons with a Complaint, but rather, a Summons with Notice. To us New York lawyers, this is a very significant procedural issue. The brief document is here: EricBollingSummonsWithNotice

A Complaint has details in a defamation case, setting forth actual words that were written or uttered that are claimed to be false and injurious. This Summons with Notice crap, does not. It’s substance merely states:

The nature of this action is for damages and injunctive relief based on defamation arising from the defendant’s efforts to injure the plaintiff’s reputation through the intentional and/or highly reckless publication of actionable false and misleading statements about the plaintiff’s conduct and character. As a result of the defendant’s actions, the plaintiff has been substantially harmed.

While it is legal to start a suit this way, it is most certainly not the way lawyers practice.  He now has just 20 days to file the Complaint or risk dismissal.

But time wasn’t a barrier for any of this — he could have waited to draft a Complaint if it had merit — so why start suit in such a crappy fashion?

My theory:

There will be no real lawsuit to follow. This was rushed out the door to intimidate others from stepping forward. Put a big whopper of a number in the filing — in this case $50M — and people who may claim to have been harassed may simply say, I don’t need this crap.

Why would lawyers put sky high numbers in? To intimidate or to grab press, or both. There isn’t any other reason I can think of. When it is brought to the attention of judges, they simply strike it. But the damage has already been done.

But wait!  What about that mammoth $50M number? Regular readers know that I have railed against those who put ad damnum clauses into their pleadings. New York (thankfully) outlawed this practice for personal injury cases back in 2003 (and defamation constitutes personal injury). It used to apply only to medical malpractice cases, but in 2003 was changed to all personal injury cases. CPLR 3017(c) states:

In an action to recover damages for personal injuries or wrongful death, the complaint, counterclaim, cross-claim, interpleader complaint, and third-party complaint shall contain a prayer for general relief but shall not state the amount of damages to which the pleader deems himself entitled.

New York’s Grand Poobah of Procedure, the late Prof. David Siegel, thought a monetary sanction should  be levied. In his authoritative treatise on New York practice he wrote:

“Some cases have held that a violation of the CPLR 3017(c) pleading restriction can be cured with a mere amendment striking the reference to the demand, but the imposition of a money sanction in an appropriate sum might better implement this aspect of CPLR 3017.”

But Bolling’s lawyer may have discovered a loophole to grab that press.  Because CPLR 3017(c) doesn’t list Summons with Notice as one of the documents that prohibits the ad damnum clause. Here it is again with emphasis added:

In an action to recover damages for personal injuries or wrongful death, the complaint, counterclaim, cross-claim, interpleader complaint, and third-party complaint shall contain a prayer for general relief but shall not state the amount of damages to which the pleader deems himself entitled.

And yet, the Summons with Notice (CPLR 305) requires a prayer for relief (“shall contain”) except in medical malpractice cases:

(b) Summons and notice.  If the complaint is not served with the summons, the summons shall contain or have attached thereto a notice stating the nature of the action and the relief sought, and, except in an action for medical malpractice, the sum of money for which judgment may be taken in case of default.

So it appears that when CPLR 3017(c) was amended in 2003 to forbid the placing of a specific demand for relief in a Complaint, the Legislature forgot that CPLR 305 requires it in a Summons with Notice.

We lawyer types have a word for that discrepancy: Loophole. I doubt if Bolling’s lawyers knew it existed when they drafted this document, but there it is anyway. But when I sat down to write about the odd way this suit started, I certainly didn’t realize it. I came to critique the way this suit was started, and that’s I found.

A loophole.

And one that the Legislature should fix in the next legislative session by amending both CPLR 305(b) to add all personal injury suits to the actions that prohibit the demands for relief, and adding Summons with Notice to the list of documents that prohibit it in 3017(c).


About Eric Bolling’s $50 Million Defamation Suit – And the Ad Damnum Clause Loophole syndicated from http://personalinjuryattorneyphiladelph.tumblr.com/

From McCain’s Mouth to the Trial Lawyer’s Ear

John McCain, July 25, 2017

When Sen. John McCain made his return to the Senate this week after his brain cancer diagnosis, all ears were on what he was saying about Trump’s attempt to alter/change/abolish Obamacare.

But as I read his comments from the Senate floor something else entirely jumped off the page at me. His comments about political “adversaries.”

And that word adversary is put in quotes for a reason, for one must appreciate that today’s adversary is tomorrow’s ally. If people disagree 75% of the time, for example, it means that they agree 25% of the time and will sometimes want to work together.

He was referring to politicians, but the same holds true for divorcing parents, or in my case, trial lawyers.

His comments, with my bolding for where I think the importance lies:

The Senate, Mr. McCain said, has not “been overburdened by greatness lately; they aren’t producing much for the American people. Both sides have let this happen.”

In self-reproach, he added: “Sometimes I’ve let my passion rule my reason. Sometimes I made it harder to find common ground because of something harsh I said to a colleague.”

Lawyers, of course, are duty-bound to zealously advocate for clients. Sometimes, however, that zealousness and passion spills over to the personal when two folks argue and jockey over an issue. But reason dictates that no matter how hard you fight over an issue, that you can’t let the passion get in the way of the big picture.

For one day you might need to talk candidly to that legal adversary, as when it comes time to settle a case. How well have you served your client if, due to passion, you are unable to have that candid conversation with your adversary to settle because you got caught up with the passion over the smaller one?

While lawyers involved in litigation talk about winning and losing, what we are really doing is engaging in risk management. At some point, depending on the facts, it may  be in the client’s interest to take 80 cents on the dollar. Or 50. Or even 25. So too for the lawyer on the other side, recognizing that an all-or-none bet is not necessarily the risk that the client can afford to take.

Passion, as McCain notes, sometimes spills itself all over reason.  And that’s well worth trying to remember in the heat of a fight.

 


From McCain’s Mouth to the Trial Lawyer’s Ear syndicated from http://personalinjuryattorneyphiladelph.tumblr.com/

Different Kinds of Lawyers

Today is a tale of two lawyers. Actually, two different kinds of lawyers.

The first is the ambulance chaser. And no, I don’t mean the kind that literally go running to hospitals where they weren’t called. That may happen, but it’s rare.

No, I’m talking about the rarefied air of Supreme Court litigation — where a select few lawyers race to those whose cases have been accepted to scream that the lawyers that got you this far can’t do this high faultin’ stuff, hire me instead. To get the glory.

The other kind of lawyer is the one that does the grunt work, toiling in a press-free arena.

Those two types are now sharply juxtaposed with a post from intellectual property and free speech lawyer Ron Colman — see what I did with that link? –in his story on That Great Free First Amendment Thing.

Colman has been handling a case for years for an  rock group called The Slants, by their leader Simon Tam, who were denied a trademark for their band’s name because it was disparaging to Asians. Such was the law, as trademarks would not be issued for “immoral, deceptive, or scandalous matter; or matter which may disparage or falsely suggest a connection with persons, living or dead, institutions, beliefs, or national symbols, or bring them into contempt, or disrepute.”

Colman took In re Tam and argued that, if the group wanted to reclaim a weaponized racial slur — which the gay community has done with a variety of insults such as dykes and queers — why should the U.S. government stop them from doing so? The government should not be in the business of stopping disparagement.

This was a First Amendment issue and Colman picked up the ball and ran with it all the way to the Supreme Court. It’s the same issue that the Washington Redskins faced when their trademark was stripped from them for being disparaging.

And a funny thing happened when the court granted cert. The “Chasers” came out of the woodwork to try to snatch his years of toil (done for free) so that they could claim the glory. According to Colman, “The vultures were calling.  Circling.  They smelled fresh kill.”:

Experienced federal appellate lawyers knew very clearly what was happening before their eyes:  In re Tam was going to be a winner.  And now that, after six years of wretched anonymous work by others from the trademark registration application through the TTAB appeal, the panel appeal in the CAFC and the en banc appeal, the vultures wanted in on it…

I got calls.  Simon Tam got calls.  And they all went more or less like this:

You guys were simply delightful in the Federal Circuit, coming out of New Jersey and all that.  Charming country lawyers.  But now it’s you against the Solicitor General, the Justice Department.  And, really, the justices themselves.  They don’t like strangers, and they don’t like amateurs poking around at the First Amendment.  So you need us.

The Redskins lawyers told us it was time to hand over our case to them, because we couldn’t win it the way they could win it.  We could keep our names on the brief if we wanted, but it was time to get out of the way.  This could only be handled by Supreme Court Elite — the SCOTUS regulars, former SCOTUS clerks who knew how to play the justices the way no Jersey bumpkins ever could.

Colman was not amused. He told them to pound sand. And with the case now over with a resounding 8-0 victory last month, he gets to write about the vultures. And he does.

Which brings us to the second kind of lawyer, the one who toils in virtual anonymity. For Colman was also helping fellow blogger Patrick Frey, an assistant district attorney out in California who writes the conservative legal blog Patterico’s Pontifications.  He’s played along as part of a couple of my April Fool’s gags in years gone by.

Patterico blogged about the Speedway Bomber, Brett Kimberlin, charitably described by Eugene Volokh as a “colorful past convict and current assiduous litigant who has been suing various conservative bloggers.” And Kimberlin sued him in Maryland.

The problem was that Colman is a New York and Jersey guy, and he needed a Maryland attorney to assist. He tried hard to find a good-sized law firm, that could afford to do the pro bono work, to help. Crickets. Ken White at Popehat sent up the Popehat Signal to look for help. More crickets from the locals.

So Maryland employment lawyer Bruce Godfrey — see what I did there again? — stepped into the breach. He was not part of the big firm that was really needed because a lot of time would be needed, but big enough. And Godfrey came through in spades.

Because the case was just dismissed.

I’m not going to sit here and claim that I agree politically with Colman or Patterico or Godfrey on any particular political issue. Because that is not the point. The First Amendment doesn’t belong to the right or the left, it belongs to all of us. When the rights of one are curtailed then the rights of all of us are.

One only need look at places like Turkey, Russia, the Phillipines that have previously experienced some levels of freedom and democracy to see how easily such rights can be lost.

So a tip of my hat today to the three of them, for standing their ground and persevering. We are all better for the time and effort they have spent.

 


Different Kinds of Lawyers syndicated from http://personalinjuryattorneyphiladelph.tumblr.com/

July 4th, Medical Malpractice, and the Bill of Rights

John Trumbull’s famous painting of the Declaration’s presentation hangs today in the Capitol Rotunda. It is collectively owned by the citizens of the United States.

A few days ago I wrote about an abomination of a bill that the House of Representatives narrowly passed, posing as tort “reform” in medical malpractice cases.

It wasn’t really “reform” (which implies improvement), but rather, a bill that seizes power from the states, grants protections and immunities to negligent people for their conduct that injures others, and foists much of the costs for those injuries out of the private sector and onto the wallets of the taxpayers.

But it did something else too, and I saved that for today. It also pissed on the Bill of Rights, specifically the Seventh Amendment.

Part of the law restricts pain and suffering awards to $250,000, and it also pushes many state actions into federal court.

The “problem” is the Seventh. It is a problem for those that want to seize federal power. Everyone else calls it a protection. Because that is what the Bill of Rights is, a list of protections.

For those that may have forgotten, the Seventh reads as follows:

In Suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved, and no fact tried by a jury, shall be otherwise re-examined in any Court of the United States, than according to the rules of the common law.

So the Founders decided that any significant suit (with $20 being the arbitrary limit) shall have the right of trial by jury. Notice that there is arbitrary top limit?

Yet that is what a Republican majority of the House did — it imposed an arbitrary top limit that does not exist, thereby stripping away the constitutionally protected right to a trial by jury for the most seriously injured of people if this bill should become law.

That right to a jury trial goes way, way back to the Declaration of Independence for us. It is the reason that I refer to July 2nd as Jury Independence Day, because that is the day that the Declaration of Independence was voted on and passed by the Continental Congress. It was two days later, on the 4th, that the Declaration was signed, but John Adams thought that it was the second that would be the day “solemnized with Pomp and Parade, with Shows, Games, Sports, Guns, Bells, Bonfires, and Illuminations from one End of this Continent to the other from this Time forward forever more.”

I post on this subject each year, and the words that follow are an adaptation of those prior messages. And the Declaration of Independence is reproduced in full after that. I like to read it in full each year at this time.

————————-

The Declaration has, as its heart and soul, a discussion of how King George III seized too many powers. And the colonists believed — and were willing to risk their lives for the principles — that power should more justly reside with the people.

And so you will see, as but one example of “the long train of abuses and usurpations” charged against the British King that forms the Declaration’s bill of particulars, this:

For depriving us in many cases, of the benefit of Trial by Jury:

And in the subsequent Bill of Rights, there are three separate places where rights to a jury are established: In the Seventh Amendment (for civil trials), the Sixth Amendment (for criminal trials) and the Fifth Amendment (grand juries for capital or infamous crimes).

It is clear that the Founders wanted powers related to both civil and criminal fact-finding to reside with the people, and not with any head of state that may be subject to whim, politics or the pressures of the moment.

This tug-of-war over how much power should reside with government and how much with the people exists to this day. Speaking broadly, it is the conservatives who want to see a smaller, less powerful government and liberals a bigger and stronger one.

But oddly enough those principles seem to fall by the wayside in the discussion of tort “reform.” When it comes to that, some conservatives, for reasons that have never been explained to me, want to give various governmental protections and immunities to others so that wrongdoers can’t be effectively hauled before the court for accountability.

This abandonment of principle happens in the pursuit of …what?  I can’t even finish the sentence as I still can’t fathom it, despite having written now on the subject for so many years.

To those conservatives that read this blog, I urge you to re-read our Declaration (and Bill of Rights) and ask yourselves why it is that, for this issue, principles of smaller and less powerful government have fallen by the wayside in favor of granting governmental protections and immunities.

And now, without further ado, Mr. Jefferson and his fellow congressmen:
————————
IN CONGRESS, JULY 4, 1776
The unanimous Declaration of the thirteen united States of America

When in the Course of human events it becomes necessary for one people to dissolve the political bands which have connected them with another and to assume among the powers of the earth, the separate and equal station to which the Laws of Nature and of Nature’s God entitle them, a decent respect to the opinions of mankind requires that they should declare the causes which impel them to the separation.

We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness. — That to secure these rights, Governments are instituted among Men, deriving their just powers from the consent of the governed, — That whenever any Form of Government becomes destructive of these ends, it is the Right of the People to alter or to abolish it, and to institute new Government, laying its foundation on such principles and organizing its powers in such form, as to them shall seem most likely to effect their Safety and Happiness. Prudence, indeed, will dictate that Governments long established should not be changed for light and transient causes; and accordingly all experience hath shewn that mankind are more disposed to suffer, while evils are sufferable than to right themselves by abolishing the forms to which they are accustomed. But when a long train of abuses and usurpations, pursuing invariably the same Object evinces a design to reduce them under absolute Despotism, it is their right, it is their duty, to throw off such Government, and to provide new Guards for their future security. — Such has been the patient sufferance of these Colonies; and such is now the necessity which constrains them to alter their former Systems of Government. The history of the present King of Great Britain is a history of repeated injuries and usurpations, all having in direct object the establishment of an absolute Tyranny over these States. To prove this, let Facts be submitted to a candid world.

He has refused his Assent to Laws, the most wholesome and necessary for the public good.

He has forbidden his Governors to pass Laws of immediate and pressing importance, unless suspended in their operation till his Assent should be obtained; and when so suspended, he has utterly neglected to attend to them.

He has refused to pass other Laws for the accommodation of large districts of people, unless those people would relinquish the right of Representation in the Legislature, a right inestimable to them and formidable to tyrants only.

He has called together legislative bodies at places unusual, uncomfortable, and distant from the depository of their Public Records, for the sole purpose of fatiguing them into compliance with his measures.

He has dissolved Representative Houses repeatedly, for opposing with manly firmness his invasions on the rights of the people.

He has refused for a long time, after such dissolutions, to cause others to be elected, whereby the Legislative Powers, incapable of Annihilation, have returned to the People at large for their exercise; the State remaining in the mean time exposed to all the dangers of invasion from without, and convulsions within.

He has endeavoured to prevent the population of these States; for that purpose obstructing the Laws for Naturalization of Foreigners; refusing to pass others to encourage their migrations hither, and raising the conditions of new Appropriations of Lands.

He has obstructed the Administration of Justice by refusing his Assent to Laws for establishing Judiciary Powers.

He has made Judges dependent on his Will alone for the tenure of their offices, and the amount and payment of their salaries.

He has erected a multitude of New Offices, and sent hither swarms of Officers to harass our people and eat out their substance.

He has kept among us, in times of peace, Standing Armies without the Consent of our legislatures.

He has affected to render the Military independent of and superior to the Civil Power.

He has combined with others to subject us to a jurisdiction foreign to our constitution, and unacknowledged by our laws; giving his Assent to their Acts of pretended Legislation:

For quartering large bodies of armed troops among us:

For protecting them, by a mock Trial from punishment for any Murders which they should commit on the Inhabitants of these States:

For cutting off our Trade with all parts of the world:

For imposing Taxes on us without our Consent:

For depriving us in many cases, of the benefit of Trial by Jury:

For transporting us beyond Seas to be tried for pretended offences:

For abolishing the free System of English Laws in a neighbouring Province, establishing therein an Arbitrary government, and enlarging its Boundaries so as to render it at once an example and fit instrument for introducing the same absolute rule into these Colonies

For taking away our Charters, abolishing our most valuable Laws and altering fundamentally the Forms of our Governments:

For suspending our own Legislatures, and declaring themselves invested with power to legislate for us in all cases whatsoever.

He has abdicated Government here, by declaring us out of his Protection and waging War against us.

He has plundered our seas, ravaged our coasts, burnt our towns, and destroyed the lives of our people.

He is at this time transporting large Armies of foreign Mercenaries to compleat the works of death, desolation, and tyranny, already begun with circumstances of Cruelty & Perfidy scarcely paralleled in the most barbarous ages, and totally unworthy the Head of a civilized nation.

He has constrained our fellow Citizens taken Captive on the high Seas to bear Arms against their Country, to become the executioners of their friends and Brethren, or to fall themselves by their Hands.

He has excited domestic insurrections amongst us, and has endeavoured to bring on the inhabitants of our frontiers, the merciless Indian Savages whose known rule of warfare, is an undistinguished destruction of all ages, sexes and conditions.

In every stage of these Oppressions We have Petitioned for Redress in the most humble terms: Our repeated Petitions have been answered only by repeated injury. A Prince, whose character is thus marked by every act which may define a Tyrant, is unfit to be the ruler of a free people.

Nor have We been wanting in attentions to our British brethren. We have warned them from time to time of attempts by their legislature to extend an unwarrantable jurisdiction over us. We have reminded them of the circumstances of our emigration and settlement here. We have appealed to their native justice and magnanimity, and we have conjured them by the ties of our common kindred to disavow these usurpations, which would inevitably interrupt our connections and correspondence. They too have been deaf to the voice of justice and of consanguinity. We must, therefore, acquiesce in the necessity, which denounces our Separation, and hold them, as we hold the rest of mankind, Enemies in War, in Peace Friends.

We, therefore, the Representatives of the united States of America, in General Congress, Assembled, appealing to the Supreme Judge of the world for the rectitude of our intentions, do, in the Name, and by Authority of the good People of these Colonies, solemnly publish and declare, That these united Colonies are, and of Right ought to be Free and Independent States, that they are Absolved from all Allegiance to the British Crown, and that all political connection between them and the State of Great Britain, is and ought to be totally dissolved; and that as Free and Independent States, they have full Power to levy War, conclude Peace, contract Alliances, establish Commerce, and to do all other Acts and Things which Independent States may of right do. — And for the support of this Declaration, with a firm reliance on the protection of Divine Providence, we mutually pledge to each other our Lives, our Fortunes, and our sacred Honor.


July 4th, Medical Malpractice, and the Bill of Rights syndicated from http://personalinjuryattorneyphiladelph.tumblr.com/

GOP Surrenders Its Soul in Medical Malpractice Vote

Yes, a real case. Yes, the x-ray hangs in my office.

Yesterday the Republican Party gave up another piece of its soul when the House of Representatives voted to restrict the ability to bring medical malpractice cases nationwide. I wrote about this pending legislation back in March.

So let’s review some core conservative principles and see why I wrote that the party sold its soul:

First, the GOP claims to believe in states rights, and have been more than happy to hoist that banner to proclaim that the federal government should keep its nose out of state issues such as same-sex marriage. Local control is a big thing for conservatives. Huge.

By federalizing medical malpractice laws to slap an artificial, one-size-fits-all 250K cap on pain and suffering awards  — most clearly a statewide function — the GOP went 100% contrary to its conservative ideology.  This is the exact opposite of the limited government that the party claims to follow.

Second, the GOP likes to claim it is the party of personal responsibility, and never shies away from telling the downtrodden to pull themselves up by their own damn bootstraps. Here, the Republicans once again do a complete about face, and grant privileges and immunities to those that actually committed the wrongful acts. The GOP granting immunities for negligence? A 100% rejection of its own core philosophy.

Third, the GOP now saddles the public (and the injured) with costs that should be dealt with in the private sector. Serious injuries cause people to lose jobs and opportunities, saddles them with debts, and otherwise makes their lives miserable. They often will be forced onto public assistance and Medicaid.  Instead of the costs being paid by the tortfeasor, via their insurance policies, the costs would be paid with your tax dollars.  Kinda like socialism.

So there you have it, a complete abdication of conservative principles, in favor of a more powerful government with a socialistic policy of the taxpayer paying the costs caused by the doctors and hospitals.

This was called a “tort reform” bill. I would have called it the Big Government-Tortfeasors-Protection-Socialism-Act.


GOP Surrenders Its Soul in Medical Malpractice Vote syndicated from http://personalinjuryattorneyphiladelph.tumblr.com/

Canada Claims Global Jurisdiction Over Internet

I know what you’re thinking, the title of this piece must be a joke, right?

But not according to news reports regarding a decision out of Canada’s Supreme Court.  Here’s the lede from the Toronto Star:

Google is barred from displaying anywhere in the world the websites of a company accused of counterfeiting a Canadian technology company’s products, the Supreme Court of Canada has ruled.

In a 7-2 ruling that has broad implications for freedom of expression, the reach of courts to protect intellectual property and other rights, and for the operations of Internet-based businesses, the country’s top court upheld a sweeping injunction against Google’s ability to display commercial content that was at the heart of a court battle.

The very brief background is a claim that Datalink Technologies Gateways ripped off the technology of Equustek Solutions by  relabeling it. A fight ensued, resulting in a Canadian order that Google delist Datalink websites.

That all being Canadian law, I offer no opinion, especially since there’s a much bigger fish to fry.

And that fish is a whale, as the Supreme Court of Canada apparently wrote (I don’t have the decision yet) that Google must delist Datalink not only in Canada, but worldwide.

Let that sink in. A government tells Google to delist worldwide.

The lawyers for the winner think they have a big win:

The ruling is the “first global de-indexing order” and will be “extremely important” worldwide, because it gives a remedy against “gatekeepers” of information such as Google, or Internet service providers, said McCarthy Tetreault lawyer Barry Sookman, who acted for several intervenors representing publishers of literary and musical content.

You know who else will think this is “extremely important”? Every tinpot dictator in the world.

I understand Turkey’s president, Recep Tayyip Erdoğan, often doesn’t like what people write about him. And Vladimir Putin is reputed to have killed journalists.

So ruthless, thin-skinned autocrats that have no free speech in their countries can order Google to delist articles worldwide.

Essentially, Putin could demand that the price of doing business in Russia is for Google to delist any articles in the New York Times and Washington Post dealing with its attempts to interfere with our election.

All he needs is a court order from the courts he controls claiming lèse-majesté — it being defamatory to offend the ruler. Truth is irrelevant.

Again, let that sink in. The price of doing business worldwide is allowing dictators to control what we see on our own screens.


Canada Claims Global Jurisdiction Over Internet syndicated from http://personalinjuryattorneyphiladelph.tumblr.com/