17 March 2010

A Round Tuit (23)

A Round Tuit

When it comes to legal blogging, there seems to be no shortage of writing worth reading once one gets around to it.

What's that? You have no round tuit? My friend, you are fortunate indeed, for never before in human history have round tuits been so readily available. If you need one, Carbolic Smoke Ball Co. has them in stock.

While you place your order, I'll share a few posts which are worth your attention.


I recall that during finals in Political Science 101, there were more than a few of us humming the classic Schoolhouse Rock song "I'm Just a Bill" to ensure that we didn't forget any of the steps required to create a valid law:
Bill: I'm just a bill
Yes I'm only a bill,
And I got as far as Capitol Hill.
Well, now I'm stuck in committee
And I'll sit here and wait
While a few key Congressmen discuss and debate
Whether they should let me be a law.
How I hope and pray that they will,
But today I am still just a bill.

Boy: Listen to those congressmen arguing! Is all that discussion and debate about you?

Bill: Yeah, I'm one of the lucky ones. Most bills never even get this far. I hope they decide to report on me favourably, otherwise I may die.

Boy: Die?

Bill: Yeah, die in committee. Oooh, but it looks like I'm gonna live! Now I go to the House of Representatives, and they vote on me.

Boy: If they vote yes, what happens?

Bill: Then I go to the Senate and the whole thing starts all over again.

Boy: Oh no!

Bill: Oh yes!
It's somewhat disillusioning to discover all these years later that Schoolhouse Rock misled us and we didn't need to worry about all that voting crap. On the other hand, it's a relief to know that Bill wasn't really in any mortal danger — bills can become laws the usual way or, if the votes just aren't there, a quick rule change can "deem" them passed and ignore the fact that they weren't. Good for Bill; bad for the Constitution.

Now that Schoolhouse Rock no longer seems a reliable source of information concerning the limits the Constitution places on the legislative process, we're obliged to turn to academia for a sanity check — can the House of Representatives' leadership really do something like this without running afoul of the Constitution?

Professor Michael McConnell of Stanford thinks not:
It may be clever, but it is not constitutional. To become law—hence eligible for amendment via reconciliation—the Senate health-care bill must actually be signed into law. The Constitution speaks directly to how that is done. According to Article I, Section 7, in order for a "Bill" to "become a Law," it "shall have passed the House of Representatives and the Senate" and be "presented to the President of the United States" for signature or veto. Unless a bill actually has "passed" both Houses, it cannot be presented to the president and cannot become a law.

To be sure, each House of Congress has power to "determine the Rules of its Proceedings." Each house can thus determine how much debate to permit, whether to allow amendments from the floor, and even to require supermajority votes for some types of proceeding. But House and Senate rules cannot dispense with the bare-bones requirements of the Constitution. Under Article I, Section 7, passage of one bill cannot be deemed to be enactment of another.


These constitutional rules set forth in Article I are not mere exercises in formalism. They ensure the democratic accountability of our representatives. Under Section 7, no bill can become law unless it is put up for public vote by both houses of Congress, and under Section 5 "the Yeas and Nays of the Members of either House on any question . . . shall be entered on the Journal." These requirements enable the people to evaluate whether their representatives are promoting their interests and the public good. Democratic leaders have not announced whether they will pursue the Slaughter solution. But the very purpose of it is to enable members of the House to vote for something without appearing to do so. The Constitution was drafted to prevent that.
In the other corner is Professor Jack Balkin of Yale; Balkin thinks that the plan could be made Constitutional, but only if the political cover sought by the Democratic majority's leadership is abandoned:
There have to be two separate bills signed by the President: the first one is the original Senate bill, and the second one is the reconciliation bill. The House must pass the Senate bill and it must also pass the reconciliation bill. The House may do this on a single vote if the special rule that accompanies the reconciliation bill says that by passing the reconciliation bill the House agrees to pass the same text of the same bill that the Senate has passed. That is to say, the language of the special rule that accompanies the reconciliation bill must make the House take political responsibility for passing the same language as the Senate bill. The House must say that the House has consented to accept the text of the Senate bill as its own political act. At that point the President can sign the two bills, and it does not matter that the House has passed both through a special rule.


The structural constitutional reason for this requirement is that members of the House must not able to avoid political accountability for passing the same bill as the Senate. The point of bicameralism and presentment is that all three actors (House, Senate and President) must agree to the legislation, warts and all, so that all three can be held politically accountable for it. They cannot point fingers at the other actors and deny responsibility for the policy choices made. The House cannot say, "oh we didn't pass X; that was the Senate's decision." If the House doesn't accept the same language as its own, even if that language is then immediately changed in an accompanying bill, there is no law.

Speaker Pelosi is trying to give House members a way of saying they did not vote for the Senate bill, but my point is that however much she and they may be trying to do this rhetorically, she and they can't really do this politically and constitutionally. They have to take responsibility for what they are doing and the language of the bill has to say that they are taking responsibility. This is the point of Article I, section 7.
A number of legal bloggers wondered whether the Congressional rule shenanigans would be a justiciable controversy; Congressional leaders and the Obama Administration probably hope that it isn't, if for no other reason than the fact that relations between the Judicial Branch and the Executive are more than a little tense at the moment. David Lat connected the dots for us this week — from Chief Justice Roberts' flubbing of the Presidential Oath at the Inauguration to the President's criticism of the Court's Citizens United decision during the State of the Union Address to a recent exchange of comments by Roberts and a White House spokesman concerning the State of the Union Address criticism. Ashby Jones discussed the Chief Justice's comments, made at a law school address:
Responding to a question, according to the [Associated Press], Roberts said anyone was free to criticize the court.

“So I have no problems with that,” he said. “On the other hand, there is the issue of the setting, the circumstances and the decorum.

“The image of having the members of one branch of government standing up, literally surrounding the Supreme Court, cheering and hollering while the court — according the requirements of protocol — has to sit there expressionless, I think is very troubling.”

According to the story, Roberts pushed forward, wondering if the justices should continue the tradition of attending the speech. “I’m not sure why we’re there.” Justice Antonin Scalia seems to agree with Roberts — he no longer attends the speech.
If Article I is about to be... um, Slaughtered, Amendment I's prospects might have seen a slight uptick recently. Marc Randazza hailed the introduction of "The Citizen Participation Act", a federal equivalent to the anti-SLAPP laws on the books in several states:
About half of the states have some form of legislation against this, but only California and Oregon have anti-SLAPP statutes that are worth a damn. Flori-duh’s is so watered down that it may as well only apply when a Unicorn shits on the Defendant’s lawn. However, in California and Oregon, if a Plaintiff files a lawsuit that implicates the Defendant’s First Amendment rights, the Defendant can file a “special motion to strike.” Then, the Plaintiff will need to show that his suit is not just a baseless and harassing claim. If the Plaintiff can’t do that, then the case is dismissed and the Plaintiff has to pay the Defendant’s attorneys fees.

Congressman Cohen’s bill is very similar to the California law... and provides the right kind of remedies.


I can not stress how important a bill like this is.
At the Popehat blog, Ken is generally a strong proponent of anti-SLAPP protections, but he has some reservations about the recently-introduced federal bill:
Let’s get this straight from the start: I’m in favor of anti-SLAPP statutes and vigorous legal protections for free speech. I’m just not convinced that federalizing libel law is the right way to go about it.


But here’s where the Citizen Participation Act really creates a dramatic change. It lets defendants in state court remove lawsuits to federal court in order to file an anti-SLAPP motion. In other words, it creates an entirely new basis for federal jurisdiction:
(a) IN GENERAL.—A civil action commenced in a State court against any person who asserts as a defense the immunity provided for in section 3 of this Act, or asserts that the action arises from an act in furtherance of the constitutional right of petition or free speech, may be removed by the defendant to the district court of the United States for the district and division embracing the place wherein it is pending.
Now, the statute provides that the case gets remanded to state court after the federal court rules upon the motion. But still, this is a huge addition to federal jurisdiction. It amounts to federalizing a substantial amount of defamation law and defamation cases. It would create an immense additional burden on federal dockets — and bear in mind that the competitive advantage of federal court is the comparatively lighter dockets allow for more individualized attention. Federal judges, I guarantee you, will hate it. Finally, it would pit free speech against federalism. It sends the signal that state judges can’t be trusted to rule upon First Amendment or privilege issues — and encourages state court hostility towards such issues. It mandates not just a respect for constitutional rights, but a very specific procedural vehicle for pursuing them. It effectively makes federal courts the sole arbiter of freedom of petition defenses and most freedom of speech defenses in civil actions, and lets the states off the hook for defending those rights.

Do I like a vigorous defense for free speech? Absolutely. Do I think that on balance federal courts do a better job of it than state courts? In most circuits, yes. But that’s still not a good reason to federalize all First Amendment litigation.
Ken's co-blogger, Patrick, highlighted one state, Rhode Island, which isn't doing a great job of protecting free speech rights; that state has introduced a bill which would prohibit the sale of videogames rated "Mature" or "Adults Only" to people under the age of eighteen:
Another rason the bill is problematic, that is to say unconstitutional, is that it makes the ESRB, a voluntary trade association with no governing power whatsoever, the sole arbiter of what is and is not a crime in Rhode Island. Just because some prude at ESRB considers Headshot II: the Columbine Simulator offensive, doesn’t make it obscene. Rhode Island would not only be violating the First Amendment; It would be unconstitutionally delegating sovereign power to a private corporation.

Just how misguided is this bill, constitutionally speaking? It’s so unconstitutional that even Jack Thompson, the disbarred crank Florida lawyer famous for his anti-videogame crusades... agrees with me....


Rhode Island’s Senate has achieved what we thought could never be done: They’ve made Jack Thompson look like a thoughtful and judicious defender of free speech.
Free speech is faring a bit better this week elsewhere in the Northeast; Eric Turkewitz reported that the restrictive attorney advertising rules in New York have been struck down:
The new rules had barred, among other things, testimonials from clients relating to pending matters, portrayals of judges or fictitious law firms, attention-getting techniques unrelated to attorney competence, and trade names or nicknames that imply an ability to get results. I had previously criticized some of those rules on First Amendment grounds.

The lower court had dumped those rules. The only part of the lower court's decision that changes is the prohibition on portrayals of fictitious law firms, and that is just a minor modification.


It's a big victory for the First Amendment. But with that will also come more lawyer tasteless ads that embarrass the profession.
Scott Greenfield shared Turkewitz' satisfaction that free speech has prevailed (for now), as well as his apprehension about the depths to which advertising attorneys are likely to sink:
[A]s I believe that flagrant marketing is distasteful and unprofessional, bad for the profession and part of our race for the bottom, that doesn't mean that I support legal restrictions or prohibitions. The former is bad. The latter is worse....


The missing link is lawyers ourselves. I can't envision any set of restrictions on lawyer marketing that won't, coincidentally or not, be so overbroad as to include speech that lies outside and is entitled to protection, whether full or limited as commercial speech. I don't want my free speech restricted because your tacky and disgraceful marketing effort makes people's stomachs turn.

The Circuit has given lawyers a second chance. Here's the deal. Stop the race to the bottom, the next effort to be even more outrageous, more ridiculous, more unprofessional and undignified, than anyone before you. Stop trying to find some new way, some brighter light, some trickier claim, to make you stand out more than the next guy. Stop it, and chances are very good that the state will not seek to recreate restrictions on lawyer free speech that will chill the rights of the rest of us.
In another post, Greenfield wondered why Justice Clarence Thomas has been, for more than four years now, so reticent to exercise his right to free speech during oral arguments:
It's unfathomable to me that he would choose to sit on the bench in silence. The sheer monotony seems unbearable, the droning of sound from advocates where there's no personal involvement, no exchange, no activity. Despite the efforts of anyone arguing their cause, not every case is fascinating nor every argument compelling.


There is nothing worse for an appellate advocate than to face a silent bench. Oral argument is the opportunity to hear the challenges to your cause and face your weakest point. While some believe that no one wins a case at argument, or that judges have already decided who wins and loses before argument rolls around, I don't buy it. Let them try to shoot down my point, and let me have the opportunity to make my case. Give me that chance to persuade you. That's what oral argument is all about. If you don't try to knock me down, I don't know what issues the judges are concerned with and can't address them. Silence is death.

The other justices on the Supreme Court are not at all reluctant to ask questions, to challenge, even to ridicule, the arguments of advocates. These questions are what advocates live for, to face them squarely and respond. Without knowing what negatives lurk in the judges mind, we can't confront them, change their minds. We can't win over anyone who remains silent. We may not win them over anyway, but at least questions give us a chance.
Once the robes come off, though, it seems that he's more willing to talk. Jess Bravin noted that Justice Thomas was amongst the many famous folk who responded to inquiries from an author posing as a ten-years-old child; asked about his favorite McDonald's food, Thomas replied, "I like the Egg McMuffin. Actually, I like almost everything there." Does this account for his silence on the bench? Perhaps he just doesn't want to speak with his mouth full. Justice Thomas' wife, Ginni, has no trouble speaking her mind; this week, she formed a nonprofit conservative lobbying and political-organizing group, Liberty Central. Ashby Jones reported that her efforts have generated some criticism:
[P]artly spurred by recent press coverage, a debate has broken out about the propriety of a justice’s spouse diving headlong into a political movement.

A central question, it seems: could Virginia Thomas’s work present a conflict of interest for her husband?

Sue Hamblen, Liberty Central’s national coordinator, told the WaPo that Virginia Thomas met with ethics officials for the federal courts and was told her work “was in no way a conflict of interest.” Hamblen added that the group does not intend to make endorsements in political campaigns but that it will issue “scorecards” ranking candidates on conservative issues. The group is reportedly not aligned with the conservative “tea party” groups.

This isn’t Thomas’s first foray into activism. She has worked for former House Republican leader Richard A. Armey (Tex.), the Heritage Foundation and the U.S. Chamber of Commerce. She most recently worked in Washington for Hillsdale College, a small liberal arts school in Michigan.
Kashmir Hill offered a snapshot of the professional lives of other "Supreme Spouses"; by and large, they're a professional lot and unlikely to cause trouble, though I'd keep an eye on Justice Stephen Breyer's wife, who's a member of the British aristocracy. Returning to Ginni Thomas, Eugene Volokh wrote that her political organizing is hardly something to be worked-up over:
What we have here is the inevitable result of the growing equality of women, the resulting growing tendency of lawyers to marry lawyers (and lawyers are disproportionately likely to go into politics), and the general tendency of people to marry others like them. It makes sense that many judges these days are women whose husbands are of the profession, social class, and cast of mind that makes them want to go into politics. It makes sense that many male judges have wives who are likewise likely to be interested in politics. And of course since spouses are supposed to help each other (and much such help is entirely legitimate), the success of one may yield more opportunities for the other.

Nor does this strike me as particularly pernicious or dangerous: Judges have plenty of political and ideological predispositions that they bring to the job from their earlier lives, and of course they have judicial philosophies that often make them in sync with particular political groups. That too is inevitable, and the fact that a spouse (or a child) has a high-profile political position doesn’t add much, I think, to those existing predispositions. In particular, I don’t think that the desire to remove any such mild additional influence of the judges justifies limiting the lives of the judge’s spouses and children. Virginia Thomas, like Ramona Ripston [wife of a Ninth Circuit Judge and, until recently, head of the Southern California ACLU], should be free to go where her beliefs and talents take her, without having her spouse’s job cripple those ambitions.


There's a lot of ink (well, pixels) spilled each week in the legal blogosphere concerning clients — how to get them, how not to get them, how to keep them, how to serve them, how to bill them, what not to do for them, and so on (and on, and on, and on). One thing I can't recall seeing discussed before this week is the question why some attorneys who, frankly, aren't very good are very good at attracting clients; not that you'd necessarily want them as your clients, but what makes those clients tick? Brian Tannebaum, in conversation with Lee Rosen, touches on something — some of these attorneys are exceptionally good at communicating to their clients that they care about their clients' outcomes, regardless the fact that, unbeknownst to those clients (and perhaps the attorneys themselves), they're ill-equipped to accomplish successful outcomes regularly. He continues:
This is a fascinating issue. We all know that clients hire lawyers for the strangest reasons. Something, one thing the lawyer says or does can determine the client's happiness with the lawyer. In the criminal practice we all experience the difference in the client who barely shakes your hand when you win his case, and the client who hugs you after you lose his case and before he's shipped off to jail.

From a client's perspective, the definition of a "crappy" lawyer is completely different from that "within" the profession.

Lee asks the important question:

It all makes me wonder whether she’s really a crappy lawyer or whether I have ideas about what’s important that might be irrelevant. Who sets the standard for crappy? Lawyers or clients? Maybe my idea of crappy doesn’t really matter?

As mob hitman Jules Winnfield observed in Pulp Fiction, "Personality goes a long way." Scott Greenfield can accept that perhaps the path to easy economic success in private practice is to focus on personality rather than competence, but he's not recommending it:
This makes for a brutally painful choice. It also explains why the internet is replete with lawyers trying desperately to appear to be "caring and concerned and empathetic" rather than skilled. After all, what good is being competent if no one retains you?

There is, however, an alternative way to view this. While there will always be lawyers whose business is built solely on their likability, despite their either being incompetent or engaging in conduct that pleases the client but destroys their professional credibility, there are also practices built on outcome and effort. Granted, it requires a better, more knowledgeable clientèle to appreciate skill over empathy and long telephone calls, but they are out there and have more mature expectations of counsel.


It's up to each of us to decide what type of lawyer we want to be. The question seems to come down to whether it's more important to get the clients' money by meeting the clients' likability needs or to provide the client with great legal service. The irony is the client may well love us more if we're better friends and worse lawyers.
Mike Cernovich writes that people who've become involved in the legal system — both civil and criminal — are generally not completely "normal" and they want an attorney who'll not just give them a chance at prevailing but will also validate their quirkiness:
Most people in the system have issues.

Most clients want to feel the love. They want validated. They expect you to answer their calls to discuss the same issues over and over again. They expect you to file every motion their reading of USA Today has told them is relevant.

Most lawyers resent this. "Didn't we discuss this already?" "That motion won't work." "No, I'm not going to tell the judge he's biased. I have a reputation to uphold." "How dare these clients tell me how to do my job?!"

Yet tapping into a client's need for constant validation is profitable.
If personality trumps competence, that's a shame for both the legal profession and our clients. If you're still keen to develop and demonstrate competence, however, B.W. Barnett passes along some great guidance this week for criminal defense attorneys who hope to sway a prosecutor to give "special treatment" to a deserving client:
Is there is way you can help the prosecutor see that your client deserves special consideration? Absolutely.

Now, keep in mind, this doesn’t apply to all of your clients. Like it or not, the defendant who has been to state jail is not going to get the same open-mindedness from the prosecutor as the first time offender. That should be obvious. Maybe your client does have some history, but has really turned her life around. This was just a stupid mistake. Is the fact that your client is a first-time offender always going to get that special deal or is the fact that your client has a criminal history always going to preclude such a deal? Nope. What you need to do is…

Go the extra mile. Prepare a folder with mitigating information. Yes, a folder. Prepare it as if you were turning it in to a professor. Why? Can’t you just tell the prosecutor the information? You may think that he probably wouldn’t have time to really look at a folder anyway… Wrong. Remember, you, the defense attorney, portray the image of your client to the prosecution. Portray it in a professional manner. And a folder full of mitigating information about your client will grab his attention.

What do you put in the folder? Anything that demonstrates your client’s redeeming qualities: letters of recommendation, transcripts, proof of employment, recent accomplishments, anything. The sky is the limit.


Provide hard copies of mitigation to the prosecutor. And, if you’re going to do that, do it right. Don’t throw a bunch of letters together into a 33 cent folder. Do it right. Keep that mindset of a college project that’s going to be graded. After all, your client is, in some way, being graded. Go for the A+!
Barnett's Texas-centric Liberty and Justice for Y'all blog received an A+ recently from fellow bloggers Scott Henson, Mark Bennett, and Scott Greenfield; Greenfield was even prompted to wonder:
Whether it's the water or the barbecue, I can't say, but once again, Texas leads the way in criminal defense blawgs with the newest kid on the block, Liberty & Justice For Y'all.


What's notable about L&J4Y is the absence of any self-promotion in the background. When I first read through the blawg, I had no idea who was doing the writing. Brandon has since added in a bit of background info so at least we knew who to praise or yell at, as the case may be. This is all about the law, with no ulterior motives.

Odds n Ends Shop

The legal blogosphere may be kicking harder in Texas, but it seems to be at least alive and kicking everywhere else as well, according to Kevin O'Keefe, whose LexBlog group has completed another "State of the AmLaw 200 Blogosphere" report. This isn't to say that the legal blogosphere isn't subject to ebbs and flows as bloggers — a thoughtful and self-critical bunch by nature — assess and reassess, as two noted bloggers did this week. Prompted by a comment by Bob Ambrogi, Venkat Balasubramani, who blogs at Spam Notes and guest-blogs regularly at Eric Goldman's blog, wondered whether the broadening of his legal interests over the past three-and-a-half years of blogging suggest that he should "make a clean break" from his focused personal blog and start a different one; he weighs the pros and cons in a thoughtful post. Coming full circle, Bob Ambrogi took to heart Balasubramani's discussion (prompted by his own comment) and added his own thoughts about shuttering his venerable LawSites blog in favor of a new one which covers the breadth of his interests:
The question for both of us is: Does it make sense to make a clean break from one blog and start anew with another? For both Venkat and me, the question is complicated by the fact that our blogs have achieved some degree of recognition and regular readerships. My blog has even won some awards, including twice being named one of the ABA Journal's Blawg 100.


What was most striking to me about Venkat's post was his comment that this question "literally weighed me down." I know precisely how he feels. It seems almost silly to spend so much time pondering the fate of a blog. Perhaps it shows that both Venkat and I remain passionate about blogging, if uncertain about our blogs.
Also considering the future — of the entire legal profession — is Richard Susskind. Dan Hull recommended a recent interview of Susskind conducted by Mike McIlwrath for his International Dispute Negotiation series (part one and part two). Hull wrote:
As clients and the profession continue to change before our eyes, only a few have made it a full-time job to think through the fallout and discuss solutions. Susskind is a expert on legal technology who, in the mid-1980s, studied and took a post-graduate degree in computers and law. In the next 25 years, he wrote, lectured, and authored two other books, as well as countless columns on law for The Times of London.

Much of his work concerns the effects technology is having on corporate law practice globally. A popular speaker these days, Susskind teaches in Glasgow and London and, since 1998, has been IT Adviser to the Lord Chief Justice of England.

"More for less" as the new regime. Susskind has long predicted IT-driven changes in the relationships between in-house departments and firms. How work will get done, and paid for, Susskind has argued, is about to change, radically and in the long term. Moreover, those changes, while threatening at first, are likely to make lawyering more enjoyable--or at least more fun for the handful of us drones who actually like it anyway.
If you're looking for more from Susskind, don't miss his excellent interview with Mike Semple Piggot in the Inside Track podcast series (transcript).

Ron Coleman has said it before and he'll say it again — entrepreneurs shouldn't put the cart before the horse by rushing to register their trademarks:
For well over nine out of ten new businesses, the odds of your idea sinking or swimming on the strength of a trademark are slim indeed, and slim too is the war chest most entrepreneurs bring to the battle of free enterprise. Prove to yourself and the world that you have a business plan, a product or service that people want, the ability to deliver it and to scale it up, the capitalization to fertilize all that and the smile of Providence on your efforts. If in the process you develop something worth protecting as a trademark, that mark has already been storing up goodwill and secondary meaning and is enforceable as against infringers under state law and Section 43(a) of the Lanham Act. If it would be a good, business-justifiable use of what is still early-stage capital to register your trademark at this point, by all means do it.
Coleman continues to discuss what makes and doesn't make a trademarks case, something which tends to be overlooked amidst all the intellectual property rhetoric flying about.

Rick Horowitz explained his long and winding road from information technology management in a large company to the practice of law and told of the night which "doomed [him] to the practice of criminal defense". Enjoy the whole thing.

Sadly, I must leave you this week, but at least I'm telling you this myself rather than ducking-out and having my attorney let you know with a carefully-worded letter. According to Kevin Underhill, actor Barry Williams was less Greg Brady than Johnny Bravo recently:
Elizabeth Kennedy, the 31-year-old ex-girlfriend of 55-year-old ex-Greg-Brady Barry Williams, told RadarOnline recently that he broke up with her via attorney. On December 11, 2009, Kennedy claims,
[Barry] told me he was going down to the car to get his cellphone and instead he let his lawyer in. And so I was out on the patio and the next thing I know -- I look up and there's Joan Daniels [Williams' lawyer]. And she tells me that I have 10 minutes to put my shoes on, hand over my keys and get out of the house.
I think this proves that Mike Cernovich was right — endlessly validating your clients' narcissism is the road to riches. I'll see you all later... I just need to go down to my car to get my cellphone.

Header pictures used in this post were obtained from (top to bottom) Carbolic Smoke Ball Co., the American Bar Association, the University of Minnesota Bio-Medical Library, and Paris Odds n Ends Thrift Store.

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