I wonder if the Fox News lawyer Daniel Webb listened to my voicemail or checked out my email and blog before he settled with Dominion Voting System
Chrystia Freeland<Chrystia.Freeland@fin.gc.ca> | Wed, Apr 19, 2023 at 1:40 AM |
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Monday, 17 April 2023
More than money at stake as Fox News goes to trial over presidential election coverage
Will a $787M US hit change Fox News? Don't bet a dime on it
Rupert Murdoch won't abandon his 50-year-old business model over one defamation case
"We're not here to pass ourselves off as intellectuals," the Australian mogul told a U.S. reporter soon after his 1973 purchase of the San Antonio Express-News.
"We're here to give the public what they want."
He gave them fact-twisting sensationalism and pearl-clutching tales of crime and immorality. The paper's managing editor would wander through the newsroom and sing out, "This isn't journalism. This is show biz," said a profile in Texas Monthly in 1976.
That profile ended with an observation: "A horrifying fact, for those whose hearts throb with civic loyalty, is that Murdoch's formula is working."
It worked so well that Murdoch wound up as possibly the most prominent media owner on Earth, with just one property, Fox News, dominating U.S. cable-news ratings and holding unparalleled influence in American conservatism.
Dominion lawyers embrace on Tuesday after the company and Fox settled the defamation lawsuit, in Wilmington, Del. (Mark Makela/Reuters)
That credo has now led to an unprecedented punishment.
In the aftermath of the 2020 U.S. election, the stars of his network, and its executives, were obsessed, according to court records, with not disappointing the audience, and they avoided declaring the simple truth that Joe Biden won.
The result is a costly golden anniversary for Murdoch's half-century career as a U.S. media proprietor: $787.5 million. (All figures in U.S. funds.)
That's the amount Fox News and its parent Fox Corporation have agreed to pay a Canadian-founded voting-machine company, Dominion Voting Systems, in a last-minute attempt to avoid an embarrassing defamation trial.
Fox News also admitted in a statement to making false claims about those voting machines, over a period of weeks when some network figures peddled wild conspiracy theories.
Fox
News founder Rupert Murdoch arrived from Australia in 1973 with a
mantra that has guided his life as a media baron: 'We’re here to give
the public what they want.' (Mike Segar/Reuters)
"[This] represents vindication," said Dominion lawyer Justin Nelson.
"The truth matters. Lies have consequences."
Within limits. Fox hasn't actually apologized, barely mentioned the settlement on its airwaves, and in a statement boasted about its high journalistic standards. The lawyer, Nelson, cautioned that disinformation remains an existential threat to democratic self-governance and conceded this litigation will not solve all problems.
The settlement, in perspective
Basic numeric literacy emphasizes this point.
Anyone expecting Fox News to turn on a dime and start pushing back when Donald Trump continues to claim he won the 2020 election might want to check the math.
Yes, $787.5 million is a lot of money, nearly half what Dominion was suing for. And the losses could get worse with an even bigger suit by another voting-machine company.
Dominion lawyers outside a Delaware courthouse on Tuesday suggested more suits were forthcoming, with one cryptically adding: "We'll see you at the next one."
What
Fox truly fears: At a Trump rally in Georgia weeks after the 2020
election, seen here, his supporters booed a Fox News journalist and
cheered smaller conservative rival networks. (Jonathan Ernst/Reuters)
But let's put that $787.5 million settlement figure in context.
It corresponds to approximately four per cent of the annual revenues of Fox News' parent company, which was trending toward $18 billion this year according to the most recent quarterly earnings.
It's not even equivalent to one rocky day on the stock market. Certainly not when the network has angered Donald Trump.
Dominion was preparing to argue in court that Fox News knowingly peddled lies for money. If the audience wanted election lies, that's what it would deliver.
That intent is illustrated in some exchanges Dominion submitted to the court.
The
now-settled case centred on the weeks before the Jan. 6 attack on the
U.S. Capitol, when right-wing outlets like Fox News repeatedly pushed
the lie that Trump had won the election. (Leah Millis/Reuters)
Falling stock prices
Star host Tucker Carlson at one point suggested a reporter should be fired for fact-checking Trump's claims: "It's measurably hurting the company. [Our] stock price is down," he said in a text conversation with co-workers, according to court documents.
It's true.
In just one day, after a Trump tweet, Fox Corp. stock plummeted as much as six per cent, and as much as 12 per cent over a multi-day period in late 2020, after Trump tweeted complaints about the network's insufficient loyalty and said he'd switch to rival Newsmax.
That 12 per cent dip is worth more than $2 billion, based on the Fox Corporation's current market valuation.
In other words: being on the outs with Trump is a far bigger threat, in sheer dollar terms, than whatever Dominion was awarded.
Fox News feared losing his supporters as viewers, court documents have shown. And you could see them drifting away at the time, even in scenes at a Trump rally right after the 2020 election.
Trump supporters in Georgia screamed at a Fox News crew. They were angry Fox had declared Biden won the state of Arizona, and the election.
A protester demonstrates against Fox News, outside the Delaware Superior Court on Tuesday. (Mark Makela/Reuters)
Another man walked past the media pen at the rally and turned to the journalists to shout the name of a Fox News rival, Right Side Broadcasting Network.
People also stood to get pictures taken with Scott Presler, a more ardent election denialist and frequent commentator on another rival network, One American News.
The audience, in late 2020, was ready to move on, said Dylan Byers, a longtime media writer and founding partner at the news site Puck.
"[Murdoch] fed the lies, he fed the conspiracies, he fed the partisan vitriol — now it's gotten to a point, in Frankenstein fashion, where he is almost at the mercy of what he's created," Byers told the Bulwark podcast.
"If he doesn't continue to give them what they want… he fears losing his audience," he said, adding that what the audience wants "is becoming crazier and crazier, and more and more conspiratorial."
Fox News has managed, in reaching a settlement, to avoid having its senior staff appear on a witness stand.
They were on the verge of being grilled by Dominion lawyers who argued the network knowingly, repeatedly, maliciously and intentionally lied about voting machines.
Tucker
Carlson publicly praises Trump. But in 2020, in private emails, he
called him a 'demonic' force and said he couldn't wait to stop covering
him. (Brendan McDermid/Reuters)
'What a disaster'
That last detail — intent — is key. In order to protect a free press from being harassed and sued into oblivion, the U.S. Supreme Court declared in 1964 that a successful libel suit requires evidence the journalist acted with malice, aware of a falsehood.
Dominion's legal submissions include emails where Murdoch referred to Trump lawyer Rudy Giuliani's conspiracy-mongering about those machines as "stupid," "damaging" and "terrible."
Fox News' own internal research department, called "the Brainroom," called claims about Dominion machines unfounded or 100 per cent false.
Carlson said Trump adviser Sidney Powell is a "crazy person" and "cruel and reckless" for her "totally shocking" lies which gave Trump supporters, he said, false hope he might remain president.
Another primetime star, Laura Ingraham, called Powell "a complete nut." Host Dana Perino said she was losing sleep over the "nonsense" being churned out on the network.
This
ad led to modern U.S. libel law. It's a fundraising request for Martin
Luther King's legal defence, appearing in the New York Times in 1960. It
contained factual errors. The paper was successfully sued but the U.S.
Supreme Court overturned the suit, declaring the errors were made
without malice. The Dominion suit alleged Fox lied intentionally. (U.S. National Archives)
The network allegedly warned its staff: Don't say these things on the air.
Emails submitted to the court show company executives imploring its reporters to avoid saying things that might offend the audience.
One former Fox News star took a shot at the company for abandoning the most elemental journalistic principles.
Bill O'Reilly said the network had allowed the pursuit of profits to override its responsibility to report honestly. He contrasted that with his own willingness, on his website, to conclude Trump had lost the election, even if, he said, it cost him over 1,000 premium subscribers.
He predicted the network will survive but will face a painful series of lawsuits.
"What a disaster," he wrote. "The nightmare will continue."
In a sense, the case already felt a bit dated, even before it was set to begin.
According to preliminary evidence, Carlson wrote texts saying that he hates Trump, and he called him a "demonic" force in American life.
For months, Trump was virtually banned from Fox News, as Murdoch made clear his preference that Trump might disappear.
But it's almost election time again. Trump is front-runner for the Republican nomination. And there he was again last week, interviewed on Fox's top-rated show.
And there was the top-rated host, Carlson, praising Trump. Calling him moderate, sensible and wise. He avoided pushing back, interjecting or contradicting his subject, like most interviewers would.
In the end, it's what his public wants.
ABOUT THE AUTHOR
Oldest Comments
Tarl Cabbot
Will a $787M US hit change Fox News?
Not a tiny bit.
It is the cost of doing business
carol e. kudla
Reply to Tarl Cabbot
bad business
David Amos
Reply to Tarl Cabbot
I wonder if the Fox News lawyer Daniel Webb listened to
my voicemail or checked out my email and blog before he settled with
Dominion Voting System
Tarl Cabbot
Reply to David Amos
Does it matter?
They can't tell the truth.
You can purchase their testimony though. I'm sure they'll tell you anything.
David Amos
Reply to Tarl CabbotMethinks you should read my blog N'esy Pas?
Tarl Cabbot
Reply to David Amos
Non David Amos
Reply to Tarl Cabbot
Mais Pourquoi?
Tarl Cabbot
Will a $787M US hit change Fox News?
The real question is .. .
Will the maga base upchuck?
Tarl Cabbot
Reply to Tarl Cabbot
Good question.
Sane people can only hope.
David Amos
Reply to Tarl CabbotDo sane people talk to themselves in public?
carol e. kudla
misinformation and lies are big business. just like phony wars, embargoes, arms deals etc. etc. you can't fix arrogance.
David Amos
Reply to carol e. kudla
C'est Vrai
More
Robert Morris
Fox News has been getting away with this
nonsense for years........telling lies is not news.......and there are
consequences.......this puts other pseudo-news sources on
notice......hopefully Rebel and Sun Media are listening......
Bob Smith
Steve Brockhouse
Reply to Bob Smith
Why should it. There is nothing major that needs to be changed.
Brian Larmer
Reply to Bob Smith
What, pray tell, does that have to do with the article?
David Amos
Hard telling not knowing when one is not permitted to read his comment
Rudy Sorel
To say nothing of all the CNN lawsuits……lesson learned?
Brian Larmer
Reply to Rudy Sorel Hmmm, deflection much?
Rudy Sorel
Reply to Brian Larmer
Not at all. They have all been sued for misinformation……surely you agree?
My point - has the lesson been learned?
Brian Larmer
Reply to Rudy Sorel
Just as I figured. Deflection.
David Amos
Reply to Rudy Sorel
Methinks the lesson will be learned on or about the 12th of Never N'esy Pas?
Jeremie Xavier
Their consumer base doesn’t care about facts and truth.
They only want to confirm what they already believe. No video, audio or
written proof that Fox News hosts are l y ing to them would ever change
their mind.
Murdoch said it loud and clear that they’re only interested in Mr $ “Green”.
It’s an absolute disgrace!
David Amos
Reply to Jeremie Xavier So which media outfit holds the moral high ground while reporting the news about politicians?
William Perry
Fox News settled and will pay $787.5 million to Dominion.
Meanwhile the Republican's are almost all for Trump because his popularity is rising according to MSNBC.
Most of Trump's MAGA followers are still with him regardless.
The old saying is still true, "If you enjoy being lied to then buy the National Enquirer." And now Fox News has earned their lessons ....but have they? Maybe the $787.5 million is just the cost of doing business
Tarl Cabbot
Reply to William Perry
Trump is finished. I am convinced of that. He is swamped with legal problems.
(swamped . . . lol the irony)
William Perry
Reply to Tarl Cabbot
His lawyers will cry First Amendment. It ain't over till the orange fat man sings in his cell.
David Amos
Reply to William PerryIt ain't over until the Fat Lady sings about
the results of two upcoming federal elections on both sides of the
Medicine Line in the not too distant future
On 4/17/23, David Amos <david.raymond.amos333@gmail.
> Deja Vu Anyone???
>
> https://davidraymondamos3.
>
> Monday, 17 April 2023
>
> More than money at stake as Fox News goes to trial over presidential
> election coverage
>
> https://www.winston.com/en/
>
>
> Dan Webb Discusses Defamation Lawsuit Against Fox News in The New York
> Times
> Dec 7, 2022
>
> Winston & Strawn Co-Executive Chairman Dan Webb discussed his
> representation of Fox News in connection with Dominion Voting System’s
> ongoing defamation lawsuit against the network in The New York Times.
>
> Since the lawsuit was filed in March 2021, Fox News has stated that
> they are protected under the First Amendment and cannot be held liable
> for reporting news of Donald Trump’s voter fraud allegations.
>
> “This does not appear to be a case that’s going to settle — but
> anything can happen,” said Dan. “There are some very fundamental First
> Amendment issues here, and those haven’t changed.”
>
> He noted that while he intended to show that the fraud allegations
> were not entirely false, he would not pretend that the allegations of
> voter fraud in the 2020 election were true. “The president’s
> allegations were not correct,” he said, adding that he planned “to
> show the jury that those security concerns were there and were real
> and added plausibility to the president’s allegations.”
>
> Dan Webb
> Partner Chicago
> +1 312-558-5856
> dwebb@winston.com
>
> Deja Vu Anyone???
>
> https://davidraymondamos3.
>
> Monday, 17 April 2023
>
> More than money at stake as Fox News goes to trial over presidential
> election coverage
>
> https://www.winston.com/en/
>
>
> Dan Webb Discusses Defamation Lawsuit Against Fox News in The New York
> Times
> Dec 7, 2022
>
> Winston & Strawn Co-Executive Chairman Dan Webb discussed his
> representation of Fox News in connection with Dominion Voting System’s
> ongoing defamation lawsuit against the network in The New York Times.
>
> Since the lawsuit was filed in March 2021, Fox News has stated that
> they are protected under the First Amendment and cannot be held liable
> for reporting news of Donald Trump’s voter fraud allegations.
>
> “This does not appear to be a case that’s going to settle — but
> anything can happen,” said Dan. “There are some very fundamental First
> Amendment issues here, and those haven’t changed.”
>
> He noted that while he intended to show that the fraud allegations
> were not entirely false, he would not pretend that the allegations of
> voter fraud in the 2020 election were true. “The president’s
> allegations were not correct,” he said, adding that he planned “to
> show the jury that those security concerns were there and were real
> and added plausibility to the president’s allegations.”
>
> Dan Webb
> Partner Chicago
> +1 312-558-5856
> dwebb@winston.com
>
Dominion Voting Systems and Fox reach last-minute settlement in $1.6B defamation lawsuit
Dominion sued in 2021, contending its business was ruined by false vote-rigging claims
Fox Corporation and Fox News reached a $787.5-million US settlement in a defamation lawsuit by Dominion Voting Systems on Tuesday, averting a high-profile trial that would have put one of the world's top media companies in the crosshairs over its coverage of false vote-rigging claims in the 2020 U.S. election.
The resolution, whose terms were not immediately disclosed, was announced at the 11th hour, with a 12-person jury selected this morning and the case poised to kick off with opening statements this afternoon. Dominion had sought $1.6 billion US in damages in the lawsuit filed in 2021, with Delaware Superior Court Judge Eric Davis presiding over the case in Wilmington.
Dominion said Fox had admitted to telling lies about the company.
"Lies have consequences," Dominion lawyer Justin Nelson in a news conference outside the courthouse after the announcement.
Fox issued a statement saying it does "acknowledge the court's rulings finding certain claims about Dominion to be false. This settlement reflects Fox's continued commitment to the highest journalistic standards.
"We are hopeful that our decision to resolve this dispute with Dominion amicably, instead of the acrimony of a divisive trial, allows the country to move forward from these issues," Fox said.
Dominion lawyers declined to answer questions about whether Fox News would apologize publicly or make reforms.
This
artist sketch depicts Dominion Voting Systems attorney Justin Nelson,
standing left, and Fox News attorney Daniel Webb, standing at right,
speaking to Judge Eric Davis before finishing jury selection in Delaware
Superior Court on Tuesday. (Elizabeth Williams/The Associated Press)
The deal spares Fox the peril of having some of its best-known figures called to the witness stand and subjected to potentially withering questioning, from executives like Rupert Murdoch, the 92-year-old media mogul who serves as Fox Corp. chairman and CEO Suzanne Scott, as well as on-air hosts including Tucker Carlson, Sean Hannity and Jeanine Pirro.
The decision to settle also followed a ruling by the judge that Fox could not invoke free speech protections under the U.S. Constitution in its defence.
At issue in the lawsuit was whether Fox was liable for airing the false claims that Denver-based Dominion's ballot-counting machines were used to manipulate the 2020 U.S. election in favour of Democrat Joe Biden over Republican Donald Trump. Dominion argued that these on-air claims caused the company "enormous and irreparable economic harm."
Fox News is the most-watched U.S. cable news network, according to media research firm Nielsen.
Jurors were scheduled to hear opening arguments in the case Tuesday afternoon. But they and the judge didn't return to the courtroom as scheduled. Lawyers spent time chatting and on their phones as they and members of the media waited for someone to announce what was happening.
A headline about then-president Donald Trump is displayed outside Fox News studios in New York City on Nov. 28, 2018. (Mark Lennihan/The Associated Press)
The primary question for jurors was to be whether Fox knowingly spread false information or recklessly disregarded the truth, the standard of "actual malice" that Dominion must show to prevail in a defamation case. Based on a slew of internal communications, Dominion alleged that Fox staff, from newsroom employees all the way up to Murdoch, knew the statements were false but continued to air them out of fear of losing viewers to media competitors on the right.
Dominion in 2021 sued Fox Corp. and Fox News, contending that its business was ruined by the false vote-rigging claims that were aired by the influential American cable news outlet known for its roster of conservative commentators.
Dominion was originally founded in Toronto by John Poulos and James Hoover.
Rupert
Murdoch, the chairman of Fox Corp., was expected to testify during the
trial, along with a procession of Fox executives and on-air hosts. (Mary Altaffer/The Associated Press)
Another suit
The stakes are even higher considering that another U.S. voting technology company, Smartmatic, is pursuing its own defamation lawsuit against Fox seeking $2.7 billion US in damages in a New York state court.
Fox Corp. shareholders are demanding company records that may show whether directors and executives properly oversaw the Fox News coverage of Trump's election-rigging claims, sources told Reuters, in what could be a prelude to lawsuits seeking to make directors liable for costs.
WATCH | Fox News readies for court: 
Fox has called Dominion's damages claim unrealistic and based on flawed economic modelling. An expert report commissioned by Dominion attributed scores of lost contracts to Fox's coverage, though much of the report remains under seal.
Fox claimed in a filing on Sunday that Dominion had agreed to knock off more than $500 million US from its damages claim. A Dominion spokesperson disputed that claim and said its damages claim remained unchanged.
Fox Corp. reported nearly $14 billion US in annual revenue last year.
Dominion has said defamatory statements about it aired on Fox shows including Sunday Morning Futures, Lou Dobbs Tonight and Justice with Judge Jeanine.
Dominion also has cited evidence that some hosts and producers thought the guests spreading the false statements, including former Trump attorneys Rudy Giuliani and Sidney Powell, could not back up their allegations.
Fox had argued that coverage of the vote-rigging claims was inherently newsworthy and protected by the U.S. Constitution's First Amendment guarantee of press freedom.
With files from CBC's Katie Simpson
RE More than money at stake as Fox News goes to trial over presidential election coverage
David Amos<david.raymond.amos333@gmail.com> | Mon, Apr 17, 2023 at 12:09 PM |
| To: dwebb@winston.com, sshackelford@susmangodfrey.com, dbrook@susmangodfrey.com, newsroom@globeandmail.com, elizabeth.thompson@cbc.ca, justin.ling@vice.com, Jean-Yves.Duclos@parl.gc.ca, stephen.kimber@ukings.ca, oldmaison@yahoo.com, jbosnitch@gmail.com, andre <andre@jafaust.com>, jfetzer@d.umn.edu, kirtl001@umn.edu, pm@pm.gc.ca, Katie.Telford@pmo-cpm.gc.ca, djtjr@trumporg.com, Donald.J.Trump@donaldtrump.com, JUSTWEB@novascotia.ca, "Jacques.Poitras" <Jacques.Poitras@cbc.ca>, "Robert. Jones" <Robert.Jones@cbc.ca>, Frank.McKenna@td.com, "pierre.poilievre" <pierre.poilievre@parl.gc.ca>, jacqueline.thomsen@thomsonreuters.com, adurkee@forbes.com | |
| Cc: motomaniac333 <motomaniac333@gmail.com>, Bill.Blair@parl.gc.ca, paulpalango <paulpalango@protonmail.com>, "robert.frater" <robert.frater@justice.gc.ca>, postur@for.stjr.is, "fin.minfinance-financemin.fin" <fin.minfinance-financemin.fin@canada.ca>, David.Akin@globalnews.ca, mcu@justice.gc.ca, keith.ward@justice.gc.ca, "jan.jensen" <jan.jensen@justice.gc.ca>, "Kevin.leahy" <Kevin.leahy@rcmp-grc.gc.ca> | |
Deja Vu Anyone??? https://davidraymondamos3. Monday, 17 April 2023 More than money at stake as Fox News goes to trial over presidential election coverage | |
More than money at stake as Fox News goes to trial over presidential election coverage
Voting machine company suing for $1.6B after doubt spread about election result
Starting this week in a courtroom in Delaware, Fox News executives and stars will have to answer for their role in spreading doubt about the 2020 presidential election and creating the gaping wound that remains in America's democracy.
Jurors hearing the $1.6-billion lawsuit filed against Fox by Dominion Voting Systems must answer a specific question: Did Fox defame the voting machine company by airing bogus stories alleging that the election was rigged against then-president Donald Trump, even as many at the network privately doubted the false claims being pushed by Trump and his allies?
Yet the broader context looms large. The trial will test press freedom and the reputation of conservatives' favourite news source. It will also illuminate the flow of misinformation that helped spark the Jan. 6, 2021, insurrection at the U.S. Capitol and continues to fuel Trump's hopes to regain power in 2024.
Fox News stars Tucker Carlson and Sean Hannity, along with founder Rupert Murdoch, are among the people expected to testify over the next few weeks.
Late Sunday night, the Delaware judge overseeing the trial announced he was delaying the start until Tuesday. He did not cite a reason. The trial had been scheduled to start Monday morning with jury selection and opening statements.
"This is Christmas Eve for defamation scholars," said RonNell Andersen Jones, a University of Utah law professor.
Fox
News commentator Sean Hannity is shown in New York on March 16. A trial
in Dominion Voting Systems' defamation lawsuit against Fox for airing
bogus allegations of fraud in the 2020 election is set to begin on
Monday in Delaware. Hannity is expected to testify. (Evan Agostini/Invision/The Associated Press)
Some Fox staff privately disbelieved Trump's claims
If the trial were a sporting event, Fox News would be taking the field on a losing streak, with key players injured and having just alienated the referee. Pretrial court rulings and embarrassing revelations about its biggest names have Fox on its heels.
Court papers released over the past two months show Fox executives, producers and personalities privately disbelieved Trump's claims of a fraudulent election. But Dominion says Fox News was afraid of alienating its audience with the truth — particularly after many viewers were angered by the network's decision to declare Democrat Joe Biden the winner in Arizona on election night in November 2020.
Some rulings by Delaware Superior Court Judge Eric Davis, who is hearing the case, have eased Dominion's path. In a summary judgment, Davis said it was "CRYSTAL clear" that fraud allegations against the company were false. That means trial time won't have to be spent disproving them at a time when millions of Republicans continue to doubt the 2020 results.
Davis said it is also clear that Dominion's reputation was damaged, but it will be up a jury to decide whether Fox acted with "actual malice" — the legal standard — and, if so, what that's worth financially.
Fox witnesses will likely testify that they thought the allegations against Dominion were newsworthy, but Davis made it clear that's not a defence against defamation — and he will make sure the jury knows that.
New York law protects news outlets from defamation for expressions of opinion. But Davis methodically went through 20 different times on Fox when allegations against Dominion were discussed, ruling that all of them were fully or partly considered statements of fact, and fair game for a potential libel finding.
Did Fox knowingly air false claims?
"A lawsuit is a little bit like hitting a home run," said Cary Coglianese, a law professor at the University of Pennsylvania. "You have to go through all of the bases to get there."
The judge's rulings "basically give Dominion a spot at third base, and all they have to do is come home to win it," he said.
Both Fox and Dominion are incorporated in Delaware, although Fox News is headquartered in New York and Dominion is based in Denver. Dominion was originally founded in Toronto by John Poulos and James Hoover.
Fox angered Davis this past week when the judge said the network's lawyers delayed producing evidence and were not forthcoming in revealing Murdoch's role at Fox News.
WATCH | Fox says its coverage is protected by 1st Amendment free speech rights:
It's not clear whether that will affect the trial. But it's generally not wise to have a judge wonder at the outset of a trial whether your side is telling the truth, particularly when truth is the central point of the case, said the University of Utah's Jones.
The suit essentially comes down to whether Dominion can prove Fox acted with actual malice by putting something on the air knowing that it knew was false or acting with a "reckless disregard" for whether it was true.
Dominion can point to many examples where Fox figures didn't believe the charges being made by Trump allies such as Sidney Powell and Rudolph Giuliani. But Fox says many of those disbelievers were not in a position to decide when to air those allegations.
"We think it's essential for them to connect those dots," Fox lawyer Erin Murphy said.
The jury will determine whether a powerful figure like Murdoch — who testified in a deposition that he didn't believe the election-fraud charges — had the influence to keep the accusations off the air.
"Credibility is always important in any trial in any case. But it's going to be really important in this case," said Jane Kirtley, director of the Silha Center for the Study of Media Ethics and the Law at the University of Minnesota.
Kirtley is concerned that the suit may eventually advance to the U.S. Supreme Court, which could use it as a pretext to weaken the actual malice standard that was set in a 1964 decision in New York Times Co. v. Sullivan. That, she feels, would be disastrous for journalists.
LISTEN | Dominion election lawsuit could become the 'civil lawsuit of the century': 
In
the background of the January 6th Committee hearings, a $1.6 billion
defamation lawsuit against Fox News is ballooning into a very big deal.
Dominion Voting Systems accuses Fox of pushing false claims of election
fraud that cast Dominion as the villain. This week, former attorney
general William Barr was subpoenaed by the court — a sign that things
are heading in “a very serious direction,” according to Erik Wemple, a
columnist and media critic for The Washington Post.
Dominion's lawsuit is being closely watched by another voting-technology company with a separate but similar case against Fox News. Florida-based Smartmatic has looked to some rulings and evidence in the Dominion case to try to enhance its own $2.7-billion defamation lawsuit in New York. The Smartmatic case isn't yet ready for trial but has survived Fox News's effort to get it tossed out.
Many experts are surprised Fox and Dominion have not reached an out-of-court settlement, though they can at any time. There's presumably a wide financial gulf. In court papers, Fox contends the $1.6-billion damages claim is a wild overestimate.
Dominion's motivation may also be to inflict maximum embarrassment on Fox with the peek into the network's internal communications following the election. Text messages from January 2021 revealed Tucker Carlson telling a friend that he passionately hated Trump and couldn't wait to move on.
Dominion may also seek an apology
How Fox viewers are reacting is an open question. Fox has placed a near-total ban on discussing the lawsuit on its TV network or website.
"The real potential danger is if Fox viewers get the sense that they've been lied to. There's a real downside there," said Charlie Sykes, founder of the Bulwark website and an MSNBC contributor.
Dominion
Voting ballot-counting machines are shown at a Torrance County
warehouse during election equipment testing with local candidates and
partisan officers in Estancia, N.M., on Sept. 29, 2022. (Andres Leighton/The Associated Press)
There's little indication that the case has changed Fox's editorial direction or cut into its viewership. Fox has embraced Trump once again in recent weeks following the former president's indictment by a Manhattan grand jury, and Carlson presented an alternate history of the Capitol riot, based on tapes given to him by U.S. House Speaker Kevin McCarthy.
Just because Fox hasn't discussed the Dominion lawsuit on the air doesn't mean its fans are unaware of it, said Tim Graham, director of media analysis at the conservative watchdog Media Research Center.
"There's a certain amount of tribal reaction to this," Graham said. "When all of the other networks are thrilling to revealing text messages and emails, they see this as the latest attempt by the liberal media to undermine Fox News. There's going to be a rally-around-Rupert effect."
The trial is expected to last into late May.
Dan Webb Discusses Defamation Lawsuit Against Fox News in The New York Times
Dec 7, 2022
Winston & Strawn Co-Executive Chairman Dan Webb discussed his representation of Fox News in connection with Dominion Voting System’s ongoing defamation lawsuit against the network in The New York Times.
Since the lawsuit was filed in March 2021, Fox News has stated that they are protected under the First Amendment and cannot be held liable for reporting news of Donald Trump’s voter fraud allegations.
“This does not appear to be a case that’s going to settle — but anything can happen,” said Dan. “There are some very fundamental First Amendment issues here, and those haven’t changed.”
He noted that while he intended to show that the fraud allegations were not entirely false, he would not pretend that the allegations of voter fraud in the 2020 election were true. “The president’s allegations were not correct,” he said, adding that he planned “to show the jury that those security concerns were there and were real and added plausibility to the president’s allegations.”
dwebb@winston.com
Judge rebukes Fox attorneys ahead of defamation trial: 'Omission is a lie'
The Fox News studios and headquarters in New York on March 21.
At Wednesday's pre-trial hearings in the billion-dollar Fox defamation lawsuit, the Delaware judge overseeing the case declared he would sanction Fox News and launch an investigation into Fox's apparent repeated failures to disclose information, including about the role of Fox founder Rupert Murdoch.
The trial, one of the most significant defamation cases in many years, is set to begin on Monday. Dominion Voting Systems, one of the leading makers of voting equipment, sued the conservative cable outlet in 2021 after it aired numerous false statements by guests and hosts baselessly claiming that the company somehow rigged voting machines to help Joe Biden steal the election from then-President Donald Trump.
Numerous post-election lawsuits and audits confirmed that Biden's win was legitimate and no evidence has surfaced that Dominion's machines altered the vote.
Delaware Superior Court Judge Eric Davis sternly warned Fox and its legal team that its veracity was in doubt in his courtroom.
"I need people to tell me the truth," Davis said as he dressed down the network's attorneys. "And, by the way, omission is a lie."
Last week, Davis ruled that Dominion had already proved the contested statements' falsity and that the jury won't have to weigh their validity; instead, the judge will instruct them that the statements are false and defamatory.
Abby Grossberg, a Fox producer who is suing the network, recently revealed the existence of audiotapes of Fox host Maria Bartiromo talking to Trump campaign lawyers Rudy Giuliani and Sidney Powell, who had fanned wild conspiracy theories about Dominion on the air. Fox had not turned over the audio to Dominion's lawyers.
"As counsel explained to the Court, FOX produced the supplemental information from Ms. Grossberg when we first learned it," a Fox News spokesperson said in a statement.
Wednesday's actions by the judge follow a bombshell courtroom disclosure Tuesday that Rupert Murdoch is formally designated as executive chairman of Fox News in addition to serving as the chair of its parent company Fox Corp.
Judge Davis on Tuesday said Fox lawyers previously had "represented to him more than once" that Murdoch was not an officer for the subsidiary cable network. The issue holds great import for the media magnate and the parent company as its lawyers argue he had no influence over Fox's broadcasts amplifying the lies about Dominion.
Tuesday, in the Delaware Chancery Court, a shareholder sued Murdoch and four other members of Fox Corp's board, alleging that they had abdicated their responsibility to protect its most important asset's reputation. Instead, the shareholder alleged, echoing Dominion's allegations, that Fox had sought to appease Trump supporters with false broadcasts.
The judge publicly mused whether he could have made earlier judicial decisions differently.
"People need to understand. Don't play games with this stuff," Davis said, directing his frustrations toward Fox's attorneys.
Fox says Murdoch's role with the news side of the company was public knowledge via filings over several years with the Securities and Exchange Commission.
Dominion attorney Davida Brook also cited a story broken by NPR earlier this week: NPR disclosed that Fox's chief political anchor, Bret Baier, had unsuccessfully lobbied from late November 2020 to January 2021 to host an hour-long special debunking election fraud myths for its viewers. According to five sources, Baier never received an anchor. (A Fox executive, speaking on condition of anonymity, say it was a "nascent" idea that became irrelevant after the Jan. 6, 2021, attack on the U.S. Capitol. All attention turned to the Biden transition, the executive said.)
Dominion's attorneys on Wednesday urged Judge Davis to respond to the apparent misstatements about Murdoch's role. They suggested the court either strip apart Dominion's claims against Fox News and Fox Corp so they are two separate lawsuits, or instruct the jury in a forthcoming trial to take an "adverse inference" because of the confusion over Murdoch's role.
Such an inference could lead the jury to believe that Fox had purposely kept information hidden from the court.
Dominion attorney Justin Nelson argued that his team had "been litigating on a false premise," and consequently missing out on information during earlier stages of the lawsuit because of apparent misunderstandings of Murdoch's role.
"There's no way to fix it on the eve of trial," Nelson said.
Responding to the claims, Fox's chief attorney, Dan Webb, said no one at Fox had intentionally withheld information. He also said any assertion that Dominion didn't know about Murdoch's role with Fox was unbelievable, because the company's attorneys had asked Murdoch about his Fox News role during a deposition.
Furthermore, Webb argued, Murdoch's role is largely irrelevant because there is not "a shred of evidence" showing he managed operations at the network during the wake of the 2020 presidential election.
Still, Dominion's attorneys also claimed that a failure to share all relevant evidence in the case extends beyond Rupert Murdoch.
Citing the separate lawsuit against Fox filed last month by former producer Grossberg, Dominion attorney Brook also said there were thousands of message sent to or from Bartiromo's personal email account that weren't provided to Dominion in a timely manner.
The comments prompted clear discomfort from Davis. Such unease appeared to cause a bout of sarcasm from the judge when he said unprovoked to a Fox attorney that Bartiromo is "clearly neutral."
"I'm sorry," the attorney said, confused. "She's clearly neutral," the judge repeated.
"I'm being sarcastic," he said after a pause.
Moving forward, Davis announced he would appoint a so-called "special master" to investigate Fox's apparent failure to share all information. Davis also allowed Dominion to re-depose some witnesses from Fox, including Bartiromo, at Fox's expense.
Davis did not indicate a timeline for the special master's investigation.
Correction April 12, 2023
The headline on an earlier version of this story said "Fox attorneys under investigation for lying in court on brink of blockbuster trial." The investigation has not yet begun and the headline has been changed.
Dominion Voting Sues Former Trump Lawyer, Seeking More Than $1.3 Billion In Damages
Sidney Powell, right, speaks next to former New York Mayor Rudy Giuliani in November in Washington.
The elections company Dominion Voting Systems, which has been at the center of many of President Trump's conspiracy narratives about the 2020 election, filed suit Friday against one of the loudest amplifiers of those false stories.
The company sued Sidney Powell, a lawyer who previously worked for the Trump campaign and who has spent much of the past two months claiming Dominion rigged the election and was somehow tied to the Venezuelan regime of the late Hugo Chavez.
None of those claims are true. Dominion was founded in Toronto and is now headquartered in Denver; its machines have been used in American elections for more than a decade. Chavez died in 2013.
The lawsuit was filed in the U.S. District Court for the District of Columbia, and in it Dominion asks for more than $1.3 billion in damages. Powell's "viral disinformation campaign" has destroyed the value of the business, the lawsuit says.
Existential threat
Election experts have wondered whether the company would be able to survive after the onslaught of accusations by the Trump campaign.
To get contracts needed to stay afloat, a voting company needs to be able to convince local governments its systems are trustworthy — but that becomes a herculean task if a large chunk of voters in those communities are consuming misinformation.
Even if the allegations appear ridiculous, the company's fate still is complicated if Republican elected officials become torn about engaging with a vendor that Trump and his supporters have tarred.
Powell has more than 1 million followers on Twitter alone, and the 124-page lawsuit filed by Dominion is almost entirely filled with her various conspiracies about election fraud.
"When you run out of gas in this industry, it's either because you run out of cash or you run out of reputation," Joe Kiniry, who runs the voting technology company Free & Fair, said in an interview last month about Dominion. "And that's when things go bankrupt. ... Or things get acquired."
Dominion says it expects to lose $200 million in profits over the coming five years as a result of Powell's post-election claims.
"We're filing this lawsuit because 300 families have staked their livelihoods on this company," Dominion CEO John Poulos said on Friday. "Words don't describe the effect. Lives have been upended."
The lawsuit also notes that as a result of the claims Powell and others have made, election officials and Dominion employees have been the subject of harassment and death threats.
"We're going to blow your f***ing building up," one person said in a voicemail left on the Dominion main office line, according to the suit.
One employee, Eric Coomer, spoke to Colorado Public Radio from an undisclosed location last month after he was forced to leave his home due to the threats.
"I actually am in fear for my safety," Coomer said. "I'm in fear for my family's safety. These are real, tangible things coming out of these baseless accusations."
Coomer, who is Dominion's head of product strategy and security, also filed suit last month against a number of pro-Trump figures, including Powell.
Dominion said Friday that the company may file future lawsuits as well against conservative media outlets and even potentially Trump himself.
"We have not ruled anyone out," said Tom Clare, an attorney representing Dominion. "We are looking very deliberately at the statements and actions of everyone."
Read Friday's lawsuit below:
September 28, 2022 6:17 PM ADT
Judge tosses Sidney Powell's counterclaims in Dominion defamation case
Attorney
Sidney Powell speaks at a press conference on election results in
Alpharetta, Georgia, U.S., December 2, 2020. REUTERS/Elijah Nouvelage(Reuters) - A Washington, D.C., federal judge on Wednesday dismissed claims by conservative lawyer Sidney Powell that Dominion Voting Systems Inc abused the legal system by bringing a $1.3 billion defamation lawsuit against her.
Dominion sued Powell in January 2021, alleging she falsely claimed the voting machine company rigged the 2020 election against former President Donald Trump. Powell countersued last year, claiming Dominion filed the lawsuit "to punish and make an example" of her.
U.S. District Judge Carl Nichols threw out Powell's claims in a brief order. He said that filing a lawsuit alone is not an "abuse of process," as Powell asserted.
Powell and her attorney did not immediately respond to a request for comment.
"We are pleased to see this process moving forward to hold Sidney Powell accountable," a Dominion spokesperson told Reuters.
Nichols last year rejected efforts by Powell and fellow Trump allies Rudy Giuliani and Mike Lindell to dismiss Dominion's defamation claims. Each of them is named in separate Dominion lawsuits.
Dominion has also sued Fox News Network and other conservative news outlets, alleging they gave a platform to false statements about its role in the 2020 election. Fox News is fighting the lawsuit and has called the claims "baseless."
Powell is separately facing ethics charges from legal regulators in Texas, who allege that lawsuits she filed seeking to overturn the 2020 election results were "frivolous."
The case is US Dominion Inc v. Powell, U.S. District Court for the District of Columbia, No. 21-cv-00040.
For Dominion: Thomas Clare of Clare & Locke; and Stephen Shackelford of Susman Godfrey
For Powell: Marc Casarino of Kennedys Law
Read more:
Trump allies including Giuliani lose bid to dismiss Dominion vote machine lawsuits
Fox News parent must face defamation lawsuit over election coverage
Our Standards: The Thomson Reuters Trust Principles.
Judge Tosses Out Sidney Powell’s Countersuit Against Dominion Voting Systems
Far-right attorney Sidney Powell’s attempt to thwart Dominion Voting Systems’ defamation lawsuit against her failed in court Wednesday, as a federal judge rejected her counterclaim against the company’s lawsuit, which takes issue with false claims about election fraud Powell spread about Dominion’s voting machines.
Former Trump attorney Sidney Powell beams for the cameras as she leaves the Federal Court in ... [+]
Key Facts
U.S. District Judge Carl Nichols granted Dominion’s motion to dismiss Powell’s counterclaim, which asked the court to award her $10 million in damages and hold a jury trial in addition to declaring Dominion’s defamation claims unsuccessful.
The counterclaim alleged Dominion had committed “abuse of process” by bringing its $1.3 billion defamation lawsuit last year, because it “brought this case to punish and make an example of” Powell as a “public-relations campaign” to cover up the allegations about its voting machines.
Nichols, who was appointed by former President Donald Trump, ruled there was no abuse of process because that would require showing “a perversion of the judicial process,” which Powell didn’t prove.
Powell’s counterclaim “fails to link her abuse-of-process claim to any act that Dominion has taken, other than filing and pursuing its lawsuit,” Nichols wrote, siding with Dominion’s argument when it asked the judge to dismiss the counterclaim.
Nichols previously dismissed a similar counterclaim MyPillow CEO Mike Lindell made against Dominion in its defamation lawsuit against him, noting Wednesday that he was dismissing Powell’s request “for substantially similar reasons.”
Powell has not yet responded to a request for comment.
Chief Critic
“Dominion’s actions were and are characterized by improper motive, willful, wanton and malicious conduct, and were intentionally designed to injure Ms. Powell and the other Defendants,” Powell’s counterclaim alleged.
What To Watch For
Dominion’s case against Powell, along with other lawsuits the company brought against attorney Rudy Giuliani and MyPillow CEO Mike Lindell, won’t go to trial until late 2023 or early 2024, based on a schedule Nichols set. The exact trial date won’t be known until at least July.
Key Background
Powell was the main Trump ally to push claims after the 2020 election tying election fraud to Dominion’s voting machines—which there is no evidence to support. Dominion filed suit against her in January 2021 for defamation, alleging she defamed the company by promoting a “false preconceived narrative.” Nichols denied Powell’s motion to dismiss the case in August 2021, ruling Dominion had sufficient grounds to argue she made her fraud claims “knowing that they were false or with reckless disregard for the truth.” After filing its first lawsuit against Powell, Dominion and rival voting company Smartmatic—which has also sued Powell—have gone on to file approximately a dozen lawsuits against individuals and companies who pushed false claims about their machines, including Fox News and several of its anchors, Newsmax, OANN and former Overstock CEO Patrick Byrne. Powell and the other plaintiffs who have been sued have largely remained defiant about their election fraud claims, and Powell continued to assert her claims about the company’s machines in her countersuit.
Further Reading
Dominion Voting Sues Sidney Powell For Defamation Over Election Conspiracy—And Others May Be Next (Forbes)
I am a New York-based senior reporter covering breaking news at Forbes. I previously covered politics and news for Vanity Fair and Mic, and as a theater critic I serve as a member of the New York Outer Critics Circle. Follow me on Twitter @alisond64 or get in touch at adurkee@forbes.com.
Fwd: ATTN Sidney Powell et al I just called your office in Texas and many of your associates within the Dec 11th filings
David Amos<motomaniac333@gmail.com> | Fri, Dec 25, 2020 at 2:14 AM | ||||||||||
| To: afoster@az.gov, bwjohnson@swlaw.com, cahler@swlaw.com, dflint@swlaw.com, ijoyce@swlaw.com, governorsoffice@michigan.gov, ccarr@law.ga.gov, dnessel@michigan.gov, kenneth.paxton@oag.texas.gov, EversInfo@wisconsin.gov, attorneygeneral@doj.nh.gov, kauljl@doj.state.wi.us, press@usdoj.gov, stateofcorruptionnh1 <stateofcorruptionnh1@gmail.com>, DSakowich@hearst.com, "Boston.Mail" <Boston.Mail@ic.fbi.gov>, "ed.pilkington" <ed.pilkington@guardian.co.uk>, editor <editor@wikileaks.org>, premier <premier@ontario.ca>, premier <premier@gnb.ca>, "andrea.anderson-mason" <andrea.anderson-mason@gnb.ca>, attorneygeneral <attorneygeneral@ontario.ca>, awilder@azleg.gov, MarkFinchem@me.com, NBarto@azleg.gov, ADanneman@perkinscoie.com, SGonski@perkinscoie.com, MElias@perkinscoie.com, BSpiva@perkinscoie.com, JDevaney@perkinscoie.com, JGeise@perkinscoie.com, LHill@perkinscoie.com, HerreraR@ballardspahr.com, ArellanoD@ballardspahr.com, kellyjtownsend@yahoo.com, liddyt@mcao.maricopa.gov, craigere@mcao.maricopa.gov, vigilj@mcao.maricopa.gov, brancoj@mcao.maricopa.gov, laruej@mcao.maricopa.gov, ca-civilmailbox@mcao.maricopa.gov, rdesai@cblawyers.com, agaona@cblawyers.com, kyost@cblawyers.com, jnelson@susmangodfrey.com, smorrissey@susmangodfrey.com, sshackelford@susmangodfrey.com, dbrook@susmangodfrey.com, michael.c.herron@dartmouth.edu, jrodden@stanford.edu, sda@gov.harvard.edu, king-assist@iq.harvard.edu, King@harvard.edu | |||||||||||
| Cc: David Amos <david.raymond.amos333@gmail.com>, 1AP.admin@protonmail.com, govcorrespcrm@pa.gov, jshapiro@attorneygeneral.gov, Alexander.Kolodin@kolodinlaw.com, CViskovic@kolodinlaw.com | |||||||||||
---------- Forwarded message ---------- From: David Amos <david.raymond.amos333@gmail. Date: Thu, 24 Dec 2020 16:27:43 -0400 Subject: Fwd: ATTN Sidney Powell et al I just called your office in Texas and many of your associates within the Dec 11th filings To: sidney@federalappeals.com, howard@kleinhendler.com, lwood@fightback.law, attorneystefanielambert@gmail. eldridge@millercanfield.com, dshare@bsdd.com, erosenberg@lawyerscommittee. grille@michigan.gov, dbressack@finkbressack.com, aap43@hotmail.com, megurewitz@gmail.com, James@jamesfetzer.com, info@lionelmedia.com, liveneedtoknow@gmail.com, tips@steeltruth.com, media@steeltruth.com, press@deepcapture.com, bbachrach <bbachrach@bachrachlaw.net>, Norman Traversy <traversy.n@gmail.com> Cc: motomaniac333 <motomaniac333@gmail.com>, "ron.klain" <ron.klain@revolution.com>, bgaier@finance-commerce.com, fin.financepublic- info@thomasmoresociety.org, info@rleighfrostlaw.com, cferrara@thomasmoresociety.org mjnew@nationalreview.com, info@aul.org, pr@cato.org, "robert.frater" <robert.frater@justice.gc.ca>, keith.ward@justice.gc.ca, "jan.jensen" <jan.jensen@justice.gc.ca>, cxiong@startribune.com ---------- Forwarded message ---------- From: Ministerial Correspondence Unit - Justice Canada <mcu@justice.gc.ca> Date: Thu, 24 Dec 2020 19:07:58 +0000 Subject: Automatic Reply To: David Amos <motomaniac333@gmail.com> Thank you for writing to the Honourable David Lametti, Minister of Justice and Attorney General of Canada. Due to the volume of correspondence addressed to the Minister, please note that there may be a delay in processing your email. Rest assured that your message will be carefully reviewed. We do not respond to correspondence that contains offensive language. ------------------- Merci d'avoir écrit à l'honorable David Lametti, ministre de la Justice et procureur général du Canada. En raison du volume de correspondance adressée au ministre, veuillez prendre note qu'il pourrait y avoir un retard dans le traitement de votre courriel. Nous tenons à vous assurer que votre message sera lu avec soin. Nous ne répondons pas à la correspondance contenant un langage offensant. ---------- Forwarded message ---------- From: Bill.Blair@parl.gc.ca Date: Thu, 24 Dec 2020 19:08:11 +0000 Subject: Automatic reply: FWD ATTN Sidney Powell et al I just called your office in Texas and many of your associates within the Dec 11th filings To: motomaniac333@gmail.com Thank you very much for reaching out to the Office of the Hon. Bill Blair, Member of Parliament for Scarborough Southwest. Please be advised that as a health and safety precaution, our constituency office will not be holding in-person meetings until further notice. We will continue to provide service during our regular office hours, both over the phone and via email. Due to the high volume of emails and calls we are receiving, our office prioritizes requests on the basis of urgency and in relation to our role in serving the constituents of Scarborough Southwest. If you are not a constituent of Scarborough Southwest, please reach out to your local of Member of Parliament for assistance. To find your local MP, visit: https://www.ourcommons.ca/ Moreover, at this time, we ask that you please only call our office if your case is extremely urgent. We are experiencing an extremely high volume of calls, and will better be able to serve you through email. Should you have any questions related to COVID-19, please see: www.canada.ca/coronavirus<http Thank you again for your message, and we will get back to you as soon as possible. Best, MP Staff to the Hon. Bill Blair Parliament Hill: 613-995-0284 Constituency Office: 416-261-8613 bill.blair@parl.gc.ca<mailto:b ** Merci beaucoup d'avoir pris contact avec le bureau de l'Honorable Bill Blair, D?put? de Scarborough-Sud-Ouest. Veuillez noter que par mesure de pr?caution en mati?re de sant? et de s?curit?, notre bureau de circonscription ne tiendra pas de r?unions en personne jusqu'? nouvel ordre. Nous continuerons ? fournir des services pendant nos heures de bureau habituelles, tant par t?l?phone que par courrier ?lectronique. En raison du volume ?lev? de courriels que nous recevons, notre bureau classe les demandes par ordre de priorit? en fonction de leur urgence et de notre r?le dans le service aux ?lecteurs de Scarborough Sud-Ouest. Si vous n'?tes pas un ?lecteur de Scarborough Sud-Ouest, veuillez contacter votre d?put? local pour obtenir de l'aide. Pour trouver votre d?put? local, visitez le site:https://www.noscommunes. En outre, nous vous demandons de ne t?l?phoner ? notre bureau que si votre cas est extr?mement urgent. Nous recevons un volume d'appels extr?mement ?lev? et nous serons mieux ? m?me de vous servir par courrier ?lectronique. Si vous avez des questions concernant COVID-19, veuillez consulter le site : http://www.canada.ca/le- Merci encore pour votre message, et nous vous r?pondrons d?s que possible. Cordialement, Personnel du D?put? de l'Honorable Bill Blair Colline du Parlement : 613-995-0284 Bureau de Circonscription : 416-261-8613 bill.blair@parl.gc.ca<mailto:b < mailto:bill.blair@parl.gc.ca> ---------- Forwarded message ---------- From: Newsroom <newsroom@globeandmail.com> Date: Thu, 24 Dec 2020 19:11:47 +0000 Subject: Automatic reply: FWD ATTN Sidney Powell et al I just called your office in Texas and many of your associates within the Dec 11th filings To: David Amos <motomaniac333@gmail.com> Thank you for contacting The Globe and Mail. If your matter pertains to newspaper delivery or you require technical support, please contact our Customer Service department at 1-800-387-5400 or send an email to customerservice@globeandmail. If you are reporting a factual error please forward your email to publiceditor@globeandmail.com< Letters to the Editor can be sent to letters@globeandmail.com This is the correct email address for requests for news coverage and press releases. Below is a true copy of my latest email It was sent today to Sidney Powell byway of her webpage format The lawyers found below will get regular email just like I have done with you people (I already called them all and spoke to some and left messages with the rest) Perhaps all you lawyers should check my work from years ago and call me back ASAP??? https://www.scribd.com/doc/ On 12/13/20, Pam Stavropoulos <pstavropoulos@iprimus.com.au> wrote: > Thank you David! > > Really appreciate wide dissemination of these concerns as you clearly > recognise. > > Regards, > > Pam S. > > -----Original Message----- > From: David Raymond Amos <pstavropoulos@iprimus.com.au> > Sent: Monday, 14 December 2020 2:16 PM > To: pstavropoulos@iprimus.com.au > Subject: Contact Form submission from > http://pamstavropoulos.com.au/ > > Sender's name: David Raymond Amos > E-mail: David.Raymond.Amos333@gmail. > Phone: 506 434 8433 > > Message: ---------- Forwarded message ---------- > From: David Amos > Date: Sun, 13 Dec 2020 23:14:01 -0400 > Subject: ATTN Yanis Varoufakis and Pam Stavropoulos I just tweeted about > your concerns about Julian Assange and global economy etc > To: y.varoufakis@parliament.gr > Cc: motomaniac333 > > Yanis Varoufakis > Web Site: > https://www.yanisvaroufakis.eu > Email: > y.varoufakis@parliament.gr > Address: > Parliament Mansion (Megaro Voulis), GR10021 > Athens / Tel. +30 2103707568 / Fax +30 2103707570. > > Check out the attachment for USA litigation over 18 years ago > > > Please notice that the webcasts and transcripts of this hearing went > missing not long before the economy crashed in 2008 Find the letter > fom Spitzer to me on page 12 within the document I offer as > "Integrity-Yea-Right" and ask yourself why Assaage has never metioned > me In fact I bet that you folks won't either > > https://www.banking.senate. > > Review of Current Investigations and Regulatory Actions Regarding the > Mutual Fund Industry > > Date: Thursday, November 20, 2003 > > Witness Panel 1 > > Mr. Stephen M. Cutler > Director - Division of Enforcement > Securities and Exchange Commission > Cutler - November 20, 2003 > Mr. Robert Glauber > Chairman and CEO > National Association of Securities Dealers > Glauber - November 20, 2003 > Eliot Spitzer > Attorney General > State of New York > Spitzer - November 20, 2003 > > > > Yanis Varoufakis > @yanisvaroufakis > · > > Law and Disorder: The case of Julian Assange - DiEM25 > The conviction of Julian Assange would signify a new dystopian > landscape in which all investigative journalism risks prosecution. > diem25.org > > David Raymond Amos > @DavidRaymondAm1 > · > 1h > Perhaps you and I should have a long talk ASAP? > > FYI this old pdf file is the tip of the iceberg of things that Bolton > and Assange have known about yours truly for many years > > https://www.scribd.com/doc/ > > David Raymond Amos > @DavidRaymondAm1 > · > 41m > The first link I offer in the blog Greece is among the many that > received hundreds of documents byway of registered US Mail as I > returned home to run for public office 6 more times while suing the > Queen > > > http://davidraymondamos3. > > Notice Assange and Trumps lawyer's email before they became famous? > > > http://thedavidamosrant. > > From: Birgitta Jonsdottir > Date: Wed, 8 Dec 2010 07:14:02 +0000 > Subject: Re: Bon Soir Birgitta according to my records this is the > first email I ever sent you > To: David Amos > > dear Dave > i have got your email and will read through the links as soon as i > find some time keep up the good fight in the meantime > > thank you for bearing with me > i am literary drowning in requests to look into all sorts of matters > and at the same time working 150% work at the parliament and > the creation of a political movement and being a responsible parent:) > plus all the matters in relation to immi > > with oceans of joy > birgitta > > Better to be hated for what you are than to be loved for what you are > not. > > Andre Gide > > Birgitta Jonsdottir > Birkimelur 8, 107 Reykjavik, Iceland, tel: 354 692 8884 > http://this.is/birgitta – http://joyb.blogspot.com - > http://www.facebook.com/ > >>>> From: "Julian Assange)" editor@wikileaks.org >>>> To: david.raymond.amos@gmail.com >>>> Sent: Sunday, March 07, 2010 3:15 PM >>>> Subject: Al Jazeera on Iceland's plan for a press safe haven >>>> >>>> FYI: Al-Jazeera's take on Iceland's proposed media safe haven >>>> http://www.youtube.com/watch? >>>> >>>> More info http://immi.is/ >>>> >>>> Julian Assange Editor WikiLeaks http://wikileaks.org/ >>>> >>>> From: "David Amos" david.raymond.amos@gmail.com >>>> To: "Julian Assange)" editor@wikileaks.org >>>> Cc: "Dan Fitzgerald" danf@danf.net; "Byrne. G" Byrne.G@parl.gc.ca >>>> Sent: Sunday, March 07, 2010 8:35 PM >>>> Subject: Re: Al Jazeera on Iceland's new plan Thanx Here is >>>> something >>>> about Iceland and Banksters Al Jazeera would enjoy >>>> >>>> Checkout this old pdf file from 2005 at about page two or three >>>> >>>> http://www.scribd.com/doc/ >>>> >>>> Then read on and chuckle >>>> >>>> From: postur@fjr.stjr.is >>>> Date: Tue, 3 Mar 2009 >>>> Subject: Re: RE: Iceland and Bankers etc I must ask the obvious >>>> question. Why have you people ignored me for three years? >>>> To: David Amos david.raymond.amos@gmail.com >>>> >>>> Dear David Amos >>>> >>>> Unfortunately there has been a considerable delay in responding to >>>> incoming letters due to heavy workload and many inquiries to our >>>> office. >>>> >>>> We appreciate the issue raised in your letter. We have set up a web >>>> site www.iceland.org where we have gathered various practical >>>> information regarding the economic crisis in Iceland. >>>> >>>> Greetings from the Ministry of Finance. >>>> >>>> Tilvísun í mál: FJR08100024 >>>> >>>> From: postur@for.stjr.is >>>> Date: Wed, 8 Oct 2008 >>>> Subject: Regarding your enquiry to the Prime Ministry of Iceland >>>> To: David Amos david.raymond.amos@gmail.com >>>> >>>> David Raymond Amos >>>> >>>> Your enquiry has been received by the Prime Ministry of Iceland and >>>> waits attendance. >>>> >>>> Thank you. >>>> >>>> From: David Amos david.raymond.amos@gmail.com >>>> Date: Wed, 8 Oct 2008 >>>> Subject: I just called to remind the Speaker, the Bankers and the >>>> Icelanders that I still exist EH Mrs Mrechant, Bob Rae and Iggy? >>>> To: Milliken.P@parl.gc.ca, sjs@althingi.is, emb.ottawa@mfa.is, >>>> rmellish@pattersonlaw.ca, irisbirgisdottir@yahoo.ca, >>>> marie@mariemorneau.com, dfranklin@franklinlegal.com, >>>> egilla@althingi.is, william.turner@exsultate.ca >>>> Cc: Rae.B@parl.gc.ca, Ignatieff.M@parl.gc.ca, lebrem@sen.parl.gc.ca, >>>> merchp@sen.parl.gc.ca, coolsa@sen.parl.gc.ca, olived@sen.parl.gc.ca >>>> >>>> All of you should review the documents and CD that came with this >>>> letter ASAP EH? >>>> >>>> http://www.scribd.com/doc/ >>>> >>>> http://www.scribd.com/doc/ >>>> >>>> http://www.scribd.com/doc/ >>>> >>>> Perhaps Geir Haarde and Steingrimur Sigfusson should call me back >>>> >>>> Veritas Vincit >>>> David Raymond Amos >>>> >>>> The Reykjavík Grapevine >>>> Hafnarstræti 15 >>>> 101 Reykjavík >>>> Iceland >>>> grapevine@grapevine.is >>>> +354-540-3600 > > http://davidraymondamos3. > > Wednesday, 2 August 2017 > > Attn Andrey Dvornikov, tel. (+7) 499 244 32 54 RE Nikki Haley meeting > with Vasily Nebeznya.Russia's new ambassador to the United Nations, > This was the pdf file attached to the email found below > > https://www.scribd.com/ > > > > ---------- Original message ---------- > From: "MAY, Theresa" theresa.may.mp@parliament.uk > Date: Wed, 2 Aug 2017 12:12:24 +0000 > Subject: Automatic reply: Attn Andrey Dvornikov, tel. (+7) 499 244 32 > 54 RE Nikki Haley meeting with Vasily Nebeznya.Russia's new ambassador > to the United Nations, > To: David Amos motomaniac333@gmail.com > > If your email is to the Prime Minister, please re-send to the No 10 > website: > www.gov.uk/government/ > > http://www.gov.uk/government/ > > > If you are a constituent of the Prime Minister, please re-send to: > sharkeyj@parliament.uk > > UK Parliament Disclaimer: This e-mail is confidential to the intended > recipient. If you have received it in error, please notify the sender > and delete it from your system. Any unauthorised use, disclosure, or > copying is not permitted. This e-mail has been checked for viruses, > but no liability is accepted for any damage caused by any virus > transmitted by this e-mail. This e-mail address is not secure, is not > encrypted and should not be used for sensitive data. > > ---------- Original message ---------- > From: "Finance Public / Finance Publique (FIN)" > fin.financepublic- > Date: Wed, 2 Aug 2017 12:12:16 +0000 > Subject: RE: Attn Andrey Dvornikov, tel. (+7) 499 244 32 54 RE Nikki > Haley meeting with Vasily Nebeznya.Russia's new ambassador to the > United Nations, > To: David Amos motomaniac333@gmail.com > > The Department of Finance acknowledges receipt of your electronic > correspondence. Please be assured that we appreciate receiving your > comments. > > Le ministère des Finances accuse réception de votre correspondance > électronique. Soyez assuré(e) que nous apprécions recevoir vos > commentaires. > > > ---------- Original message ---------- > From: David Amos > Date: Tue, 14 Feb 2017 10:51:14 -0400 > Subject: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I > just got off the phone with your lawyer Mr Cohen (646-853-0114) Why > does he lie to me after all this time??? > To: president , mdcohen212@gmail.com, pm , > Pierre-Luc.Dusseault@parl.gc. > B.English@ministers.govt.nz, Malcolm.Turnbull.MP@aph.gov.au > pminvites@pmc.gov.au, mayt@parliament.uk, press , "Andrew.Bailey" , > fin.financepublic- > "CNN.Viewer.Communications. > Cc: David Amos , elizabeth.thompson@cbc.ca, "justin.ling@vice.com, > elizabeththompson" , djtjr , "Bill.Morneau" , postur , > stephen.kimber@ukings.ca, "steve.murphy" , "Jacques.Poitras" , > oldmaison , andre > > ---------- Original message ---------- > From: Michael Cohen > Date: Tue, 14 Feb 2017 14:15:14 +0000 > Subject: Automatic reply: RE FATCA ATTN Pierre-Luc.Dusseault I just > called and left a message for you > To: David Amos > > Effective January 20, 2017, I have accepted the role as personal > counsel to President Donald J. Trump. All future emails should be > directed to mdcohen212@gmail.com and all future calls should be > directed to 646-853-0114. > ______________________________ > This communication is from The Trump Organization or an affiliate > thereof and is not sent on behalf of any other individual or entity. > This email may contain information that is confidential and/or > proprietary. Such information may not be read, disclosed, used, > copied, distributed or disseminated except (1) for use by the intended > recipient or (2) as expressly authorized by the sender. If you have > received this communication in error, please immediately delete it and > promptly notify the sender. E-mail transmission cannot be guaranteed > to be received, secure or error-free as emails could be intercepted, > corrupted, lost, destroyed, arrive late, incomplete, contain viruses > or otherwise. The Trump Organization and its affiliates do not > guarantee that all emails will be read and do not accept liability for > any errors or omissions in emails. Any views or opinions presented in > any email are solely those of the author and do not necessarily > represent those of The Trump Organization or any of its > affiliates.Nothing in this communication is intended to operate as an > electronic signature under applicable law. > > ---------- Original message ---------- > From: "Finance Public / Finance Publique (FIN)" > > Date: Fri, 10 Feb 2017 22:05:00 +0000 > Subject: RE: Yo President Trump RE the Federal Court of Canada File No > T-1557-15 lets see how the media people do with news that is NOT FAKE > To: David Amos > > The Department of Finance acknowledges receipt of your electronic > correspondence. Please be assured that we appreciate receiving your > comments. > > Le ministère des Finances accuse réception de votre correspondance > électronique. Soyez assuré(e) que nous apprécions recevoir vos > commentaires. > > > > ---------- Original message ---------- > From: Kevin Leahy > Date: Fri, 28 Jun 2019 12:38:43 -0400 > Subject: Re: RE The call from the Boston cop Robert Ridge (857 259 > 9083) on behalf of the VERY corrupt Yankee DA Rachael Rollins > To: David Amos > > French will follow > > Thank you for your email. > > For inquiries regarding EMRO’s Office, please address your email to > acting EMRO Sebastien Brillon at sebastien.brillon@rcmp-grc.gc. > > For inquiries regarding CO NHQ Office, please address your email to > acting CO Farquharson, David at David.Farquharson@rcmp-grc.gc. > > All PPS related correspondence should be sent to my PPS account at > kevin.leahy@pps-spp@parl.gc.ca > ------------------------------ > Merci pour votre courriel. > > Pour toute question concernant le Bureau de l'EMRO, veuillez adresser > vos courriels à l’Officier responsable des Relations > employeur-employés par intérim Sébastien Brillon à l'adresse suivante > sebastien.brillon@rcmp-grc.gc. > > Pour toute question concernant le bureau du Commandant de la > Direction générale, veuillez adresser vos courriels au Commandant de > la Direction générale par intérim Farquharson, David à l'adresse > suivante David.Farquharson@rcmp-grc.gc. > > Toute correspondance relative au Service De Protection Parlementaire > doit être envoyée à mon compte de PPS à l'adresse suivante > kevin.leahy@pps-spp@parl.gc.ca > > > Kevin Leahy > Chief Superintendent/Surintendant principal > Director, Parliamentary Protective Service > Directeur , Service de protection parlementaire > T 613-996-5048 > Kevin.leahy@rcmp-grc.gc.ca > > CONFIDENTIALITY NOTICE: This email and any attachments are > confidential and may contain protected information. It is intended > only for the individual or entity named in the message. If you are not > the intended recipient, or the agent responsible to deliver the > message that this email contains to the intended recipient, you should > not disseminate, distribute or copy this email, nor disclose or use in > any manner the information that it contains. Please notify the sender > immediately if you have received this email by mistake and delete it. > AVIS DE CONFIDENTIALITÉ: Le présent courriel et tout fichier qui y est > joint sont confidentiels et peuvent contenir des renseignements > protégés. Il est strictement réservé à l’usage du destinataire prévu. > Si vous n’êtes pas le destinataire prévu, ou le mandataire chargé de > lui transmettre le message que ce courriel contient, vous ne devez ni > le diffuser, le distribuer ou le copier, ni divulguer ou utiliser à > quelque fin que ce soit les renseignements qu’il contient. Veuillez > aviser immédiatement l’expéditeur si vous avez reçu ce courriel par > erreur et supprimez-le. > > > > > > ---------- Original message ---------- > From: Premier of Ontario | Premier ministre de l’Ontario > Date: Fri, 28 Jun 2019 16:38:41 +0000 > Subject: Automatic reply: RE The call from the Boston cop Robert Ridge > (857 259 9083) on behalf of the VERY corrupt Yankee DA Rachael Rollins > To: David Amos > > Thank you for your email. Your thoughts, comments and input are greatly > valued. > > You can be assured that all emails and letters are carefully read, > reviewed and taken into consideration. > > There may be occasions when, given the issues you have raised and the > need to address them effectively, we will forward a copy of your > correspondence to the appropriate government official. Accordingly, a > response may take several business days. > > Thanks again for your email. > ______ > > Merci pour votre courriel. Nous vous sommes très reconnaissants de > nous avoir fait part de vos idées, commentaires et observations. > > Nous tenons à vous assurer que nous lisons attentivement et prenons en > considération tous les courriels et lettres que nous recevons. > > Dans certains cas, nous transmettrons votre message au ministère > responsable afin que les questions soulevées puissent être traitées de > la manière la plus efficace possible. En conséquence, plusieurs jours > ouvrables pourraient s’écouler avant que nous puissions vous répondre. > > Merci encore pour votre courriel. > > > > > > > > >> ---------- Original message ---------- >> From: David Amos >> Date: Wed, 26 Jun 2019 16:15:59 -0400 >> Subject: Hey Ralph Goodale perhaps you and the RCMP should call the >> Yankees Governor Charlie Baker, his lawyer Bob Ross, Rachael Rollins >> and this cop Robert Ridge (857 259 9083) ASAP EH Mr Primme Minister >> Trudeau the Younger and Donald Trump Jr? >> To: pm@pm.gc.ca, Katie.Telford@pmo-cpm.gc.ca, >> Ian.Shugart@pco-bcp.gc.ca, djtjr@trumporg.com, >> Donald.J.Trump@donaldtrump.com >> Frank.McKenna@td.com, barbara.massey@rcmp-grc.gc.ca, >> Douglas.Johnson@rcmp-grc.gc.ca >> washington.field@ic.fbi.gov, Brenda.Lucki@rcmp-grc.gc.ca, >> gov.press@state.ma.us, bob.ross@state.ma.us, jfurey@nbpower.com, >> jfetzer@d.umn.edu, Newsroom@globeandmail.com, sfine@globeandmail.com, >> .Poitras@cbc.ca, steve.murphy@ctv.ca, David.Akin@globalnews.ca, >> Dale.Morgan@rcmp-grc.gc.ca, news@kingscorecord.com, >> news@dailygleaner.com, oldmaison@yahoo.com, jbosnitch@gmail.com, >> andre@jafaust.com> >> Cc: david.raymond.amos333@gmail. >> wharrison@nbpower.com, David.Lametti@parl.gc.ca, mcu@justice.gc.ca, >> Jody.Wilson-Raybould@parl.gc. >> ---------- Original message ---------- From: "Finance Public / Finance Publique (FIN)" Date: Tue, 14 Feb 2017 14:52:33 +0000 Subject: RE: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I just got off the phone with your lawyer Mr Cohen (646-853-0114) Why does he lie to me after all this time??? To: David Amos The Department of Finance acknowledges receipt of your electronic correspondence. Please be assured that we appreciate receiving your comments. Le ministère des Finances accuse réception de votre correspondance électronique. Soyez assuré(e) que nous apprécions recevoir vos commentaires. ---------- Original message ---------- From: Póstur FOR Date: Tue, 14 Feb 2017 14:51:41 +0000 Subject: Re: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I just got off the phone with your lawyer Mr Cohen (646-853-0114) Why does he lie to me after all this time??? To: David Amos Erindi þitt hefur verið móttekið / Your request has been received Kveðja / Best regards Forsætisráðuneytið / Prime Minister's Office ---------- Original message ---------- From: "B English (MIN)" Date: Tue, 14 Feb 2017 14:51:29 +0000 Subject: Automated response from the office of Hon Bill English To: David Amos Thank you for your email to the Prime Minister. This is an automated response. Please be assured that any matters you raise in your email will be noted; however, not all messages will receive an individual response. Yours sincerely The Office of the Prime Minister ---------- Original message ---------- From: PmInvites Date: Tue, 14 Feb 2017 14:52:50 +0000 Subject: PM Invites To: David Amos Thank you for your invitation/meeting request to the Prime Minister, the Hon Malcolm Turnbull MP. Your invitation will be considered in light of the Prime Minister's existing commitments. We will be in touch with you as soon as possible to formally advise the progress of your invitation/meeting request. Yours sincerely Prime Minister's Office ______________________________ IMPORTANT: This message, and any attachments to it, contains information that is confidential and may also be the subject of legal professional or other privilege. If you are not the intended recipient of this message, you must not review, copy, disseminate or disclose its contents to any other party or take action in reliance of any material contained within it. If you have received this message in error, please notify the sender immediately by return email informing them of the mistake and delete all copies of the message from your computer system. ---------- Original message ---------- From: "Turnbull, Malcolm (MP)" Date: Tue, 14 Feb 2017 14:51:35 +0000 Subject: Automatic reply: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I just got off the phone with your lawyer Mr Cohen (646-853-0114) Why does he lie to me after all this time??? To: David Amos ***Please be advised that this email address is no longer in use*** Thank you for taking the time to write to me. Feedback from the people we represent is always extremely valuable for members of parliament, and especially valuable to me as Prime Minister. However as you can imagine I receive a very large, sometimes dauntingly large, amount of correspondence and it is important that we do everything we can to respond to it as quickly and effectively as possible. So to help us best direct your enquiry and respond to it, please complete this contact form. If you have written a detailed message in your email, just cut and paste it into the contact form and complete the details requested. If you would like to invite me or Lucy to an event, please forward the invitation to pminvites@pmc.gov.au. If you are a Wentworth constituent, please make us aware of this and my electorate office team in Edgecliff will be in touch. Regards, Malcolm Turnbull Prime Minister ---------- Original message ---------- From: David Amos Date: Tue, 14 Feb 2017 10:51:14 -0400 Subject: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I just got off the phone with your lawyer Mr Cohen (646-853-0114) Why does he lie to me after all this time??? To: president , mdcohen212@gmail.com, pm , Pierre-Luc.Dusseault@parl.gc. B.English@ministers.govt.nz, Malcolm.Turnbull.MP@aph.gov.au pminvites@pmc.gov.au, mayt@parliament.uk, press , "Andrew.Bailey" , fin.financepublic- "CNN.Viewer.Communications. Cc: David Amos , elizabeth.thompson@cbc.ca, "justin.ling@vice.com, elizabeththompson" , djtjr , "Bill.Morneau" , postur , stephen.kimber@ukings.ca, "steve.murphy" , "Jacques.Poitras" , oldmaison , andre > ---------- Original message ---------- > From: David Amos <motomaniac333@gmail.com> > Date: Wed, 26 Jun 2019 16:15:59 -0400 > Subject: Hey Ralph Goodale perhaps you and the RCMP should call the > Yankees Governor Charlie Baker, his lawyer Bob Ross, Rachael Rollins > and this cop Robert Ridge (857 259 9083) ASAP EH Mr Primme Minister > Trudeau the Younger and Donald Trump Jr? > To: pm@pm.gc.ca, Katie.Telford@pmo-cpm.gc.ca, > Ian.Shugart@pco-bcp.gc.ca, djtjr@trumporg.com, > Donald.J.Trump@donaldtrump.com > Frank.McKenna@td.com, barbara.massey@rcmp-grc.gc.ca, > Douglas.Johnson@rcmp-grc.gc.ca > washington.field@ic.fbi.gov, Brenda.Lucki@rcmp-grc.gc.ca, > gov.press@state.ma.us, bob.ross@state.ma.us, jfurey@nbpower.com, > jfetzer@d.umn.edu, Newsroom@globeandmail.com, sfine@globeandmail.com, > .Poitras@cbc.ca, steve.murphy@ctv.ca, David.Akin@globalnews.ca, > Dale.Morgan@rcmp-grc.gc.ca, news@kingscorecord.com, > news@dailygleaner.com, oldmaison@yahoo.com, jbosnitch@gmail.com, > andre@jafaust.com> > Cc: david.raymond.amos333@gmail. > wharrison@nbpower.com, David.Lametti@parl.gc.ca, mcu@justice.gc.ca, > Jody.Wilson-Raybould@parl.gc. > >>> From: Justice Website <JUSTWEB@novascotia.ca> >>> Date: Mon, 18 Sep 2017 14:21:11 +0000 >>> Subject: Emails to Department of Justice and Province of Nova Scotia >>> To: "motomaniac333@gmail.com" <motomaniac333@gmail.com> >>> >>> Mr. Amos, >>> We acknowledge receipt of your recent emails to the Deputy Minister of >>> Justice and lawyers within the Legal Services Division of the >>> Department of Justice respecting a possible claim against the Province >>> of Nova Scotia. Service of any documents respecting a legal claim >>> against the Province of Nova Scotia may be served on the Attorney >>> General at 1690 Hollis Street, Halifax, NS. Please note that we will >>> not be responding to further emails on this matter. >>> >>> Department of Justice >>> >>> On 8/3/17, David Amos <motomaniac333@gmail.com> wrote: >>> >>>> If want something very serious to download and laugh at as well Please >>>> Enjoy and share real wiretap tapes of the mob >>>> >>>> http://thedavidamosrant. >>>> ilian.html >>>> >>>>> http://www.cbc.ca/news/world/ >>>>> >>>>> As the CBC etc yap about Yankee wiretaps and whistleblowers I must >>>>> ask them the obvious question AIN'T THEY FORGETTING SOMETHING???? >>>>> >>>>> http://www.youtube.com/watch? >>>>> >>>>> What the hell does the media think my Yankee lawyer served upon the >>>>> USDOJ right after I ran for and seat in the 39th Parliament baseball >>>>> cards? >>>>> >>>>> http://archive.org/details/ >>>>> 6 >>>>> >>>>> http://davidamos.blogspot.ca/ >>>>> >>>>> http://www.archive.org/ >>>>> >>>>> http://archive.org/details/ >>>>> >>>>> FEDERAL EXPRES February 7, 2006 >>>>> Senator Arlen Specter >>>>> United States Senate >>>>> Committee on the Judiciary >>>>> 224 Dirksen Senate Office Building >>>>> Washington, DC 20510 >>>>> >>>>> Dear Mr. Specter: >>>>> >>>>> I have been asked to forward the enclosed tapes to you from a man >>>>> named, David Amos, a Canadian citizen, in connection with the matters >>>>> raised in the attached letter. >>>>> >>>>> Mr. Amos has represented to me that these are illegal FBI wire tap >>>>> tapes. >>>>> >>>>> I believe Mr. Amos has been in contact with you about this previously. >>>>> >>>>> Very truly yours, >>>>> Barry A. Bachrach >>>>> Direct telephone: (508) 926-3403 >>>>> Direct facsimile: (508) 929-3003 >>>>> Email: bbachrach@bowditch.com >>>>> >>>> >>> >>>> ---------- Forwarded message ---------- >>>> From: David Amos motomaniac333@gmail.com >>>> Date: Mon, 12 Jun 2017 09:32:09 -0400 >>>> Subject: Attn Integrity Commissioner Alexandre Deschênes, Q.C., >>>> To: coi@gnb.ca >>>> Cc: david.raymond.amos@gmail.com >>>> >>>> Good Day Sir >>>> >>>> After I heard you speak on CBC I called your office again and managed >>>> to speak to one of your staff for the first time >>>> >>>> Please find attached the documents I promised to send to the lady who >>>> answered the phone this morning. Please notice that not after the Sgt >>>> at Arms took the documents destined to your office his pal Tanker >>>> Malley barred me in writing with an "English" only document. >>>> >>>> These are the hearings and the dockets in Federal Court that I >>>> suggested that you study closely. >>>> >>>> This is the docket in Federal Court >>>> >>>> http://cas-cdc-www02.cas-satj. >>>> >>>> These are digital recordings of the last three hearings >>>> >>>> Dec 14th https://archive.org/details/ >>>> >>>> January 11th, 2016 https://archive.org/details/ >>>> >>>> April 3rd, 2017 >>>> >>>> https://archive.org/details/ >>>> >>>> >>>> This is the docket in the Federal Court of Appeal >>>> >>>> http://cas-cdc-www02.cas-satj. >>>> >>>> >>>> The only hearing thus far >>>> >>>> May 24th, 2017 >>>> >>>> https://archive.org/details/ >>>> >>>> >>>> This Judge understnds the meaning of the word Integrity >>>> >>>> Date: 20151223 >>>> >>>> Docket: T-1557-15 >>>> >>>> Fredericton, New Brunswick, December 23, 2015 >>>> >>>> PRESENT: The Honourable Mr. Justice Bell >>>> >>>> BETWEEN: >>>> >>>> DAVID RAYMOND AMOS >>>> >>>> Plaintiff >>>> >>>> and >>>> >>>> HER MAJESTY THE QUEEN >>>> >>>> Defendant >>>> >>>> ORDER >>>> >>>> (Delivered orally from the Bench in Fredericton, New Brunswick, on >>>> December 14, 2015) >>>> >>>> The Plaintiff seeks an appeal de novo, by way of motion pursuant to >>>> the Federal Courts Rules (SOR/98-106), from an Order made on November >>>> 12, 2015, in which Prothonotary Morneau struck the Statement of Claim >>>> in its entirety. >>>> >>>> At the outset of the hearing, the Plaintiff brought to my attention a >>>> letter dated September 10, 2004, which he sent to me, in my then >>>> capacity as Past President of the New Brunswick Branch of the Canadian >>>> Bar Association, and the then President of the Branch, Kathleen Quigg, >>>> (now a Justice of the New Brunswick Court of Appeal). In that letter >>>> he stated: >>>> >>>> As for your past President, Mr. Bell, may I suggest that you check the >>>> work of Frank McKenna before I sue your entire law firm including you. >>>> You are your brother’s keeper. >>>> >>>> Frank McKenna is the former Premier of New Brunswick and a former >>>> colleague of mine at the law firm of McInnes Cooper. In addition to >>>> expressing an intention to sue me, the Plaintiff refers to a number of >>>> people in his Motion Record who he appears to contend may be witnesses >>>> or potential parties to be added. Those individuals who are known to >>>> me personally, include, but are not limited to the former Prime >>>> Minister of Canada, The Right Honourable Stephen Harper; former >>>> Attorney General of Canada and now a Justice of the Manitoba Court of >>>> Queen’s Bench, Vic Toews; former member of Parliament Rob Moore; >>>> former Director of Policing Services, the late Grant Garneau; former >>>> Chief of the Fredericton Police Force, Barry McKnight; former Staff >>>> Sergeant Danny Copp; my former colleagues on the New Brunswick Court >>>> of Appeal, Justices Bradley V. Green and Kathleen Quigg, and, retired >>>> Assistant Commissioner Wayne Lang of the Royal Canadian Mounted >>>> Police. >>>> >>>> In the circumstances, given the threat in 2004 to sue me in my >>>> personal capacity and my past and present relationship with many >>>> potential witnesses and/or potential parties to the litigation, I am >>>> of the view there would be a reasonable apprehension of bias should I >>>> hear this motion. See Justice de Grandpré’s dissenting judgment in >>>> Committee for Justice and Liberty et al v National Energy Board et al, >>>> [1978] 1 SCR 369 at p 394 for the applicable test regarding >>>> allegations of bias. In the circumstances, although neither party has >>>> requested I recuse myself, I consider it appropriate that I do so. >>>> >>>> >>>> AS A RESULT OF MY RECUSAL, THIS COURT ORDERS that the Administrator of >>>> the Court schedule another date for the hearing of the motion. There >>>> is no order as to costs. >>>> >>>> “B. Richard Bell” >>>> Judge >>>> >>>> >>>> Below after the CBC article about your concerns (I made one comment >>>> already) you will find the text of just two of many emails I had sent >>>> to your office over the years since I first visited it in 2006. >>>> >>>> I noticed that on July 30, 2009, he was appointed to the the Court >>>> Martial Appeal Court of Canada Perhaps you should scroll to the >>>> bottom of this email ASAP and read the entire Paragraph 83 of my >>>> lawsuit now before the Federal Court of Canada? >>>> >>>> "FYI This is the text of the lawsuit that should interest Trudeau the >>>> most >>>> >>>> >>>> ---------- Original message ---------- >>>> From: justin.trudeau.a1@parl.gc.ca >>>> Date: Thu, Oct 22, 2015 at 8:18 PM >>>> Subject: Réponse automatique : RE My complaint against the CROWN in >>>> Federal Court Attn David Hansen and Peter MacKay If you planning to >>>> submit a motion for a publication ban on my complaint trust that you >>>> dudes are way past too late >>>> To: david.raymond.amos@gmail.com >>>> >>>> Veuillez noter que j'ai changé de courriel. Vous pouvez me rejoindre à >>>> lalanthier@hotmail.com >>>> >>>> Pour rejoindre le bureau de M. Trudeau veuillez envoyer un courriel à >>>> tommy.desfosses@parl.gc.ca >>>> >>>> Please note that I changed email address, you can reach me at >>>> lalanthier@hotmail.com >>>> >>>> To reach the office of Mr. Trudeau please send an email to >>>> tommy.desfosses@parl.gc.ca >>>> >>>> Thank you, >>>> >>>> Merci , >>>> >>>> >>>> http://davidraymondamos3. >>>> >>>> >>>> 83. The Plaintiff states that now that Canada is involved in more war >>>> in Iraq again it did not serve Canadian interests and reputation to >>>> allow Barry Winters to publish the following words three times over >>>> five years after he began his bragging: >>>> >>>> January 13, 2015 >>>> This Is Just AS Relevant Now As When I wrote It During The Debate >>>> >>>> December 8, 2014 >>>> Why Canada Stood Tall! >>>> >>>> Friday, October 3, 2014 >>>> Little David Amos’ “True History Of War” Canadian Airstrikes And >>>> Stupid Justin Trudeau >>>> >>>> Canada’s and Canadians free ride is over. Canada can no longer hide >>>> behind Amerka’s and NATO’s skirts. >>>> >>>> When I was still in Canadian Forces then Prime Minister Jean Chretien >>>> actually committed the Canadian Army to deploy in the second campaign >>>> in Iraq, the Coalition of the Willing. This was against or contrary to >>>> the wisdom or advice of those of us Canadian officers that were >>>> involved in the initial planning phases of that operation. There were >>>> significant concern in our planning cell, and NDHQ about of the dearth >>>> of concern for operational guidance, direction, and forces for >>>> operations after the initial occupation of Iraq. At the “last minute” >>>> Prime Minister Chretien and the Liberal government changed its mind. >>>> The Canadian government told our amerkan cousins that we would not >>>> deploy combat troops for the Iraq campaign, but would deploy a >>>> Canadian Battle Group to Afghanistan, enabling our amerkan cousins to >>>> redeploy troops from there to Iraq. The PMO’s thinking that it was >>>> less costly to deploy Canadian Forces to Afghanistan than Iraq. But >>>> alas no one seems to remind the Liberals of Prime Minister Chretien’s >>>> then grossly incorrect assumption. Notwithstanding Jean Chretien’s >>>> incompetence and stupidity, the Canadian Army was heroic, >>>> professional, punched well above it’s weight, and the PPCLI Battle >>>> Group, is credited with “saving Afghanistan” during the Panjway >>>> campaign of 2006. >>>> >>>> What Justin Trudeau and the Liberals don’t tell you now, is that then >>>> Liberal Prime Minister Jean Chretien committed, and deployed the >>>> Canadian army to Canada’s longest “war” without the advice, consent, >>>> support, or vote of the Canadian Parliament. >>>> >>>> What David Amos and the rest of the ignorant, uneducated, and babbling >>>> chattering classes are too addled to understand is the deployment of >>>> less than 75 special operations troops, and what is known by planners >>>> as a “six pac cell” of fighter aircraft is NOT the same as a >>>> deployment of a Battle Group, nor a “war” make. >>>> >>>> The Canadian Government or The Crown unlike our amerkan cousins have >>>> the “constitutional authority” to commit the Canadian nation to war. >>>> That has been recently clearly articulated to the Canadian public by >>>> constitutional scholar Phillippe Legasse. What Parliament can do is >>>> remove “confidence” in The Crown’s Government in a “vote of >>>> non-confidence.” That could not happen to the Chretien Government >>>> regarding deployment to Afghanistan, and it won’t happen in this >>>> instance with the conservative majority in The Commons regarding a >>>> limited Canadian deployment to the Middle East. >>>> >>>> President George Bush was quite correct after 911 and the terror >>>> attacks in New York; that the Taliban “occupied” and “failed state” >>>> Afghanistan was the source of logistical support, command and control, >>>> and training for the Al Quaeda war of terror against the world. The >>>> initial defeat, and removal from control of Afghanistan was vital and >>>> >>>> P.S. Whereas this CBC article is about your opinion of the actions of >>>> the latest Minister Of Health trust that Mr Boudreau and the CBC have >>>> had my files for many years and the last thing they are is ethical. >>>> Ask his friends Mr Murphy and the RCMP if you don't believe me. >>>> >>>> Subject: >>>> Date: Tue, 30 Jan 2007 12:02:35 -0400 >>>> From: "Murphy, Michael B. \(DH/MS\)" MichaelB.Murphy@gnb.ca >>>> To: motomaniac_02186@yahoo.com >>>> >>>> January 30, 2007 >>>> >>>> WITHOUT PREJUDICE >>>> >>>> Mr. David Amos >>>> >>>> Dear Mr. Amos: >>>> >>>> This will acknowledge receipt of a copy of your e-mail of December 29, >>>> 2006 to Corporal Warren McBeath of the RCMP. >>>> >>>> Because of the nature of the allegations made in your message, I have >>>> taken the measure of forwarding a copy to Assistant Commissioner Steve >>>> Graham of the RCMP “J” Division in Fredericton. >>>> >>>> Sincerely, >>>> >>>> Honourable Michael B. Murphy >>>> Minister of Health >>>> >>>> CM/cb >>>> >>>> >>>> Warren McBeath warren.mcbeath@rcmp-grc.gc.ca wrote: >>>> >>>> Date: Fri, 29 Dec 2006 17:34:53 -0500 >>>> From: "Warren McBeath" warren.mcbeath@rcmp-grc.gc.ca >>>> To: kilgoursite@ca.inter.net, MichaelB.Murphy@gnb.ca, >>>> nada.sarkis@gnb.ca, wally.stiles@gnb.ca, dwatch@web.net, >>>> motomaniac_02186@yahoo.com >>>> CC: ottawa@chuckstrahl.com, riding@chuckstrahl.com,John. >>>> Oda.B@parl.gc.ca,"Bev BUSSON" bev.busson@rcmp-grc.gc.ca, >>>> "Paul Dube" PAUL.DUBE@rcmp-grc.gc.ca >>>> Subject: Re: Remember me Kilgour? Landslide Annie McLellan has >>>> forgotten me but the crooks within the RCMP have not >>>> >>>> Dear Mr. Amos, >>>> >>>> Thank you for your follow up e-mail to me today. I was on days off >>>> over the holidays and returned to work this evening. Rest assured I >>>> was not ignoring or procrastinating to respond to your concerns. >>>> >>>> As your attachment sent today refers from Premier Graham, our position >>>> is clear on your dead calf issue: Our forensic labs do not process >>>> testing on animals in cases such as yours, they are referred to the >>>> Atlantic Veterinary College in Charlottetown who can provide these >>>> services. If you do not choose to utilize their expertise in this >>>> instance, then that is your decision and nothing more can be done. >>>> >>>> As for your other concerns regarding the US Government, false >>>> imprisonment and Federal Court Dates in the US, etc... it is clear >>>> that Federal authorities are aware of your concerns both in Canada >>>> the US. These issues do not fall into the purvue of Detachment >>>> and policing in Petitcodiac, NB. >>>> >>>> It was indeed an interesting and informative conversation we had on >>>> December 23rd, and I wish you well in all of your future endeavors. >>>> >>>> Sincerely, >>>> >>>> Warren McBeath, Cpl. >>>> GRC Caledonia RCMP >>>> Traffic Services NCO >>>> Ph: (506) 387-2222 >>>> Fax: (506) 387-4622 >>>> E-mail warren.mcbeath@rcmp-grc.gc.ca >>>> >>>> >>>> >>>> Alexandre Deschênes, Q.C., >>>> Office of the Integrity Commissioner >>>> Edgecombe House, 736 King Street >>>> Fredericton, N.B. CANADA E3B 5H1 >>>> tel.: 506-457-7890 >>>> fax: 506-444-5224 >>>> e-mail:coi@gnb.ca >>>> >>> >>> ---------- Forwarded message ---------- >>> >>> http://davidraymondamos3. >>> >>> >>> Sunday, 19 November 2017 >>> Federal Court of Appeal Finally Makes The BIG Decision And Publishes >>> It Now The Crooks Cannot Take Back Ticket To Try Put My Matter Before >>> The Supreme Court >>> >>> https://decisions.fct-cf.gc. >>> >>> >>> Federal Court of Appeal Decisions >>> >>> Amos v. Canada >>> Court (s) Database >>> >>> Federal Court of Appeal Decisions >>> Date >>> >>> 2017-10-30 >>> Neutral citation >>> >>> 2017 FCA 213 >>> File numbers >>> >>> A-48-16 >>> Date: 20171030 >>> >>> Docket: A-48-16 >>> Citation: 2017 FCA 213 >>> CORAM: >>> >>> WEBB J.A. >>> NEAR J.A. >>> GLEASON J.A. >>> >>> >>> BETWEEN: >>> DAVID RAYMOND AMOS >>> Respondent on the cross-appeal >>> (and formally Appellant) >>> and >>> HER MAJESTY THE QUEEN >>> Appellant on the cross-appeal >>> (and formerly Respondent) >>> Heard at Fredericton, New Brunswick, on May 24, 2017. >>> Judgment delivered at Ottawa, Ontario, on October 30, 2017. >>> REASONS FOR JUDGMENT BY: >>> >>> THE COURT >>> >>> >>> >>> Date: 20171030 >>> >>> Docket: A-48-16 >>> Citation: 2017 FCA 213 >>> CORAM: >>> >>> WEBB J.A. >>> NEAR J.A. >>> GLEASON J.A. >>> >>> >>> BETWEEN: >>> DAVID RAYMOND AMOS >>> Respondent on the cross-appeal >>> (and formally Appellant) >>> and >>> HER MAJESTY THE QUEEN >>> Appellant on the cross-appeal >>> (and formerly Respondent) >>> REASONS FOR JUDGMENT BY THE COURT >>> >>> I. Introduction >>> >>> [1] On September 16, 2015, David Raymond Amos (Mr. Amos) >>> filed a 53-page Statement of Claim (the Claim) in Federal Court >>> against Her Majesty the Queen (the Crown). Mr. Amos claims $11 million >>> in damages and a public apology from the Prime Minister and Provincial >>> Premiers for being illegally barred from accessing parliamentary >>> properties and seeks a declaration from the Minister of Public Safety >>> that the Canadian Government will no longer allow the Royal Canadian >>> Mounted Police (RCMP) and Canadian Forces to harass him and his clan >>> (Claim at para. 96). >>> >>> [2] On November 12, 2015 (Docket T-1557-15), by way of a >>> motion brought by the Crown, a prothonotary of the Federal Court (the >>> Prothonotary) struck the Claim in its entirety, without leave to >>> amend, on the basis that it was plain and obvious that the Claim >>> disclosed no reasonable claim, the Claim was fundamentally vexatious, >>> and the Claim could not be salvaged by way of further amendment (the >>> Prothontary’s Order). >>> >>> >>> [3] On January 25, 2016 (2016 FC 93), by way of Mr. >>> Amos’ appeal from the Prothonotary’s Order, a judge of the Federal >>> Court (the Judge), reviewing the matter de novo, struck all of Mr. >>> Amos’ claims for relief with the exception of the claim for damages >>> for being barred by the RCMP from the New Brunswick legislature in >>> 2004 (the Federal Court Judgment). >>> >>> >>> [4] Mr. Amos appealed and the Crown cross-appealed the >>> Federal Court Judgment. Further to the issuance of a Notice of Status >>> Review, Mr. Amos’ appeal was dismissed for delay on December 19, 2016. >>> As such, the only matter before this Court is the Crown’s >>> cross-appeal. >>> >>> >>> II. Preliminary Matter >>> >>> [5] Mr. Amos, in his memorandum of fact and law in >>> relation to the cross-appeal that was filed with this Court on March >>> 6, 2017, indicated that several judges of this Court, including two of >>> the judges of this panel, had a conflict of interest in this appeal. >>> This was the first time that he identified the judges whom he believed >>> had a conflict of interest in a document that was filed with this >>> Court. In his notice of appeal he had alluded to a conflict with >>> several judges but did not name those judges. >>> >>> [6] Mr. Amos was of the view that he did not have to >>> identify the judges in any document filed with this Court because he >>> had identified the judges in various documents that had been filed >>> with the Federal Court. In his view the Federal Court and the Federal >>> Court of Appeal are the same court and therefore any document filed in >>> the Federal Court would be filed in this Court. This view is based on >>> subsections 5(4) and 5.1(4) of the Federal Courts Act, R.S.C., 1985, >>> c. F-7: >>> >>> >>> 5(4) Every judge of the Federal Court is, by virtue of his or her >>> office, a judge of the Federal Court of Appeal and has all the >>> jurisdiction, power and authority of a judge of the Federal Court of >>> Appeal. >>> […] >>> >>> 5(4) Les juges de la Cour fédérale sont d’office juges de la Cour >>> d’appel fédérale et ont la même compétence et les mêmes pouvoirs que >>> les juges de la Cour d’appel fédérale. >>> […] >>> 5.1(4) Every judge of the Federal Court of Appeal is, by virtue of >>> that office, a judge of the Federal Court and has all the >>> jurisdiction, power and authority of a judge of the Federal Court. >>> >>> 5.1(4) Les juges de la Cour d’appel fédérale sont d’office juges de la >>> Cour fédérale et ont la même compétence et les mêmes pouvoirs que les >>> juges de la Cour fédérale. >>> >>> >>> [7] However, these subsections only provide that the >>> judges of the Federal Court are also judges of this Court (and vice >>> versa). It does not mean that there is only one court. If the Federal >>> Court and this Court were one Court, there would be no need for this >>> section. >>> [8] Sections 3 and 4 of the Federal Courts Act provide >>> that: >>> 3 The division of the Federal Court of Canada called the Federal Court >>> — Appeal Division is continued under the name “Federal Court of >>> Appeal” in English and “Cour d’appel fédérale” in French. It is >>> continued as an additional court of law, equity and admiralty in and >>> for Canada, for the better administration of the laws of Canada and as >>> a superior court of record having civil and criminal jurisdiction. >>> >>> 3 La Section d’appel, aussi appelée la Cour d’appel ou la Cour d’appel >>> fédérale, est maintenue et dénommée « Cour d’appel fédérale » en >>> français et « Federal Court of Appeal » en anglais. Elle est maintenue >>> à titre de tribunal additionnel de droit, d’equity et d’amirauté du >>> Canada, propre à améliorer l’application du droit canadien, et >>> continue d’être une cour supérieure d’archives ayant compétence en >>> matière civile et pénale. >>> 4 The division of the Federal Court of Canada called the Federal Court >>> — Trial Division is continued under the name “Federal Court” in >>> English and “Cour fédérale” in French. It is continued as an >>> additional court of law, equity and admiralty in and for Canada, for >>> the better administration of the laws of Canada and as a superior >>> court of record having civil and criminal jurisdiction. >>> >>> 4 La section de la Cour fédérale du Canada, appelée la Section de >>> première instance de la Cour fédérale, est maintenue et dénommée « >>> Cour fédérale » en français et « Federal Court » en anglais. Elle est >>> maintenue à titre de tribunal additionnel de droit, d’equity et >>> d’amirauté du Canada, propre à améliorer l’application du droit >>> canadien, et continue d’être une cour supérieure d’archives ayant >>> compétence en matière civile et pénale. >>> >>> >>> [9] Sections 3 and 4 of the Federal Courts Act create >>> two separate courts – this Court (section 3) and the Federal Court >>> (section 4). If, as Mr. Amos suggests, documents filed in the Federal >>> Court were automatically also filed in this Court, then there would no >>> need for the parties to prepare and file appeal books as required by >>> Rules 343 to 345 of the Federal Courts Rules, SOR/98-106 in relation >>> to any appeal from a decision of the Federal Court. The requirement to >>> file an appeal book with this Court in relation to an appeal from a >>> decision of the Federal Court makes it clear that the only documents >>> that will be before this Court are the documents that are part of that >>> appeal book. >>> >>> >>> [10] Therefore, the memorandum of fact and law filed on >>> March 6, 2017 is the first document, filed with this Court, in which >>> Mr. Amos identified the particular judges that he submits have a >>> conflict in any matter related to him. >>> >>> >>> [11] On April 3, 2017, Mr. Amos attempted to bring a motion >>> before the Federal Court seeking an order “affirming or denying the >>> conflict of interest he has” with a number of judges of the Federal >>> Court. A judge of the Federal Court issued a direction noting that if >>> Mr. Amos was seeking this order in relation to judges of the Federal >>> Court of Appeal, it was beyond the jurisdiction of the Federal Court. >>> Mr. Amos raised the Federal Court motion at the hearing of this >>> cross-appeal. The Federal Court motion is not a motion before this >>> Court and, as such, the submissions filed before the Federal Court >>> will not be entertained. As well, since this was a motion brought >>> before the Federal Court (and not this Court), any documents filed in >>> relation to that motion are not part of the record of this Court. >>> >>> >>> [12] During the hearing of the appeal Mr. Amos alleged that >>> the third member of this panel also had a conflict of interest and >>> submitted some documents that, in his view, supported his claim of a >>> conflict. Mr. Amos, following the hearing of his appeal, was also >>> afforded the opportunity to provide a brief summary of the conflict >>> that he was alleging and to file additional documents that, in his >>> view, supported his allegations. Mr. Amos submitted several pages of >>> documents in relation to the alleged conflicts. He organized the >>> documents by submitting a copy of the biography of the particular >>> judge and then, immediately following that biography, by including >>> copies of the documents that, in his view, supported his claim that >>> such judge had a conflict. >>> >>> >>> [13] The nature of the alleged conflict of Justice Webb is >>> that before he was appointed as a Judge of the Tax Court of Canada in >>> 2006, he was a partner with the law firm Patterson Law, and before >>> that with Patterson Palmer in Nova Scotia. Mr. Amos submitted that he >>> had a number of disputes with Patterson Palmer and Patterson Law and >>> therefore Justice Webb has a conflict simply because he was a partner >>> of these firms. Mr. Amos is not alleging that Justice Webb was >>> personally involved in or had any knowledge of any matter in which Mr. >>> Amos was involved with Justice Webb’s former law firm – only that he >>> was a member of such firm. >>> >>> >>> [14] During his oral submissions at the hearing of his >>> appeal Mr. Amos, in relation to the alleged conflict for Justice Webb, >>> focused on dealings between himself and a particular lawyer at >>> Patterson Law. However, none of the documents submitted by Mr. Amos at >>> the hearing or subsequently related to any dealings with this >>> particular lawyer nor is it clear when Mr. Amos was dealing with this >>> lawyer. In particular, it is far from clear whether such dealings were >>> after the time that Justice Webb was appointed as a Judge of the Tax >>> Court of Canada over 10 years ago. >>> >>> >>> [15] The documents that he submitted in relation to the >>> alleged conflict for Justice Webb largely relate to dealings between >>> Byron Prior and the St. John’s Newfoundland and Labrador office of >>> Patterson Palmer, which is not in the same province where Justice Webb >>> practiced law. The only document that indicates any dealing between >>> Mr. Amos and Patterson Palmer is a copy of an affidavit of Stephen May >>> who was a partner in the St. John’s NL office of Patterson Palmer. The >>> affidavit is dated January 24, 2005 and refers to a number of e-mails >>> that were sent by Mr. Amos to Stephen May. Mr. Amos also included a >>> letter that is addressed to four individuals, one of whom is John >>> Crosbie who was counsel to the St. John’s NL office of Patterson >>> Palmer. The letter is dated September 2, 2004 and is addressed to >>> “John Crosbie, c/o Greg G. Byrne, Suite 502, 570 Queen Street, >>> Fredericton, NB E3B 5E3”. In this letter Mr. Amos alludes to a >>> possible lawsuit against Patterson Palmer. >>> [16] Mr. Amos’ position is that simply because Justice Webb >>> was a lawyer with Patterson Palmer, he now has a conflict. In Wewaykum >>> Indian Band v. Her Majesty the Queen, 2003 SCC 45, [2003] 2 S.C.R. >>> 259, the Supreme Court of Canada noted that disqualification of a >>> judge is to be determined based on whether there is a reasonable >>> apprehension of bias: >>> 60 In Canadian law, one standard has now emerged as the >>> criterion for disqualification. The criterion, as expressed by de >>> Grandpré J. in Committee for Justice and Liberty v. National Energy >>> Board, …[[1978] 1 S.C.R. 369, 68 D.L.R. (3d) 716], at p. 394, is the >>> reasonable apprehension of bias: >>> … the apprehension of bias must be a reasonable one, held by >>> reasonable and right minded persons, applying themselves to the >>> question and obtaining thereon the required information. In the words >>> of the Court of Appeal, that test is "what would an informed person, >>> viewing the matter realistically and practically -- and having thought >>> the matter through -- conclude. Would he think that it is more likely >>> than not that [the decision-maker], whether consciously or >>> unconsciously, would not decide fairly." >>> >>> [17] The issue to be determined is whether an informed >>> person, viewing the matter realistically and practically, and having >>> thought the matter through, would conclude that Mr. Amos’ allegations >>> give rise to a reasonable apprehension of bias. As this Court has >>> previously remarked, “there is a strong presumption that judges will >>> administer justice impartially” and this presumption will not be >>> rebutted in the absence of “convincing evidence” of bias (Collins v. >>> Canada, 2011 FCA 140 at para. 7, [2011] 4 C.T.C. 157 [Collins]. See >>> also R. v. S. (R.D.), [1997] 3 S.C.R. 484 at para. 32, 151 D.L.R. >>> (4th) 193). >>> >>> [18] The Ontario Court of Appeal in Rando Drugs Ltd. v. >>> Scott, 2007 ONCA 553, 86 O.R. (3d) 653 (leave to appeal to the Supreme >>> Court of Canada refused, 32285 (August 1, 2007)), addressed the >>> particular issue of whether a judge is disqualified from hearing a >>> case simply because he had been a member of a law firm that was >>> involved in the litigation that was now before that judge. The Ontario >>> Court of Appeal determined that the judge was not disqualified if the >>> judge had no involvement with the person or the matter when he was a >>> lawyer. The Ontario Court of Appeal also explained that the rules for >>> determining whether a judge is disqualified are different from the >>> rules to determine whether a lawyer has a conflict: >>> 27 Thus, disqualification is not the natural corollary to a >>> finding that a trial judge has had some involvement in a case over >>> which he or she is now presiding. Where the judge had no involvement, >>> as here, it cannot be said that the judge is disqualified. >>> >>> >>> 28 The point can rightly be made that had Mr. Patterson been >>> asked to represent the appellant as counsel before his appointment to >>> the bench, the conflict rules would likely have prevented him from >>> taking the case because his firm had formerly represented one of the >>> defendants in the case. Thus, it is argued how is it that as a trial >>> judge Patterson J. can hear the case? This issue was considered by the >>> Court of Appeal (Civil Division) in Locabail (U.K.) Ltd. v. Bayfield >>> Properties Ltd., [2000] Q.B. 451. The court held, at para. 58, that >>> there is no inflexible rule governing the disqualification of a judge >>> and that, "[e]verything depends on the circumstances." >>> >>> >>> 29 It seems to me that what appears at first sight to be an >>> inconsistency in application of rules can be explained by the >>> different contexts and in particular, the strong presumption of >>> judicial impartiality that applies in the context of disqualification >>> of a judge. There is no such presumption in cases of allegations of >>> conflict of interest against a lawyer because of a firm's previous >>> involvement in the case. To the contrary, as explained by Sopinka J. >>> in MacDonald Estate v. Martin (1990), 77 D.L.R. (4th) 249 (S.C.C.), >>> for sound policy reasons there is a presumption of a disqualifying >>> interest that can rarely be overcome. In particular, a conclusory >>> statement from the lawyer that he or she had no confidential >>> information about the case will never be sufficient. The case is the >>> opposite where the allegation of bias is made against a trial judge. >>> His or her statement that he or she knew nothing about the case and >>> had no involvement in it will ordinarily be accepted at face value >>> unless there is good reason to doubt it: see Locabail, at para. 19. >>> >>> >>> 30 That brings me then to consider the particular circumstances >>> of this case and whether there are serious grounds to find a >>> disqualifying conflict of interest in this case. In my view, there are >>> two significant factors that justify the trial judge's decision not to >>> recuse himself. The first is his statement, which all parties accept, >>> that he knew nothing of the case when it was in his former firm and >>> that he had nothing to do with it. The second is the long passage of >>> time. As was said in Wewaykum, at para. 85: >>> To us, one significant factor stands out, and must inform >>> the perspective of the reasonable person assessing the impact of this >>> involvement on Binnie J.'s impartiality in the appeals. That factor is >>> the passage of time. Most arguments for disqualification rest on >>> circumstances that are either contemporaneous to the decision-making, >>> or that occurred within a short time prior to the decision-making. >>> 31 There are other factors that inform the issue. The Wilson >>> Walker firm no longer acted for any of the parties by the time of >>> trial. More importantly, at the time of the motion, Patterson J. had >>> been a judge for six years and thus had not had a relationship with >>> his former firm for a considerable period of time. >>> >>> >>> 32 In my view, a reasonable person, viewing the matter >>> realistically would conclude that the trial judge could deal fairly >>> and impartially with this case. I take this view principally because >>> of the long passage of time and the trial judge's lack of involvement >>> in or knowledge of the case when the Wilson Walker firm had carriage. >>> In these circumstances it cannot be reasonably contended that the >>> trial judge could not remain impartial in the case. The mere fact that >>> his name appears on the letterhead of some correspondence from over a >>> decade ago would not lead a reasonable person to believe that he would >>> either consciously or unconsciously favour his former firm's former >>> client. It is simply not realistic to think that a judge would throw >>> off his mantle of impartiality, ignore his oath of office and favour a >>> client - about whom he knew nothing - of a firm that he left six years >>> earlier and that no longer acts for the client, in a case involving >>> events from over a decade ago. >>> (emphasis added) >>> >>> [19] Justice Webb had no involvement with any matter >>> involving Mr. Amos while he was a member of Patterson Palmer or >>> Patterson Law, nor does Mr. Amos suggest that he did. Mr. Amos made it >>> clear during the hearing of this matter that the only reason for the >>> alleged conflict for Justice Webb was that he was a member of >>> Patterson Law and Patterson Palmer. This is simply not enough for >>> Justice Webb to be disqualified. Any involvement of Mr. Amos with >>> Patterson Law while Justice Webb was a member of that firm would have >>> had to occur over 10 years ago and even longer for the time when he >>> was a member of Patterson Palmer. In addition to the lack of any >>> involvement on his part with any matter or dispute that Mr. Amos had >>> with Patterson Law or Patterson Palmer (which in and of itself is >>> sufficient to dispose of this matter), the length of time since >>> Justice Webb was a member of Patterson Law or Patterson Palmer would >>> also result in the same finding – that there is no conflict in Justice >>> Webb hearing this appeal. >>> >>> [20] Similarly in R. v. Bagot, 2000 MBCA 30, 145 Man. R. >>> (2d) 260, the Manitoba Court of Appeal found that there was no >>> reasonable apprehension of bias when a judge, who had been a member of >>> the law firm that had been retained by the accused, had no involvement >>> with the accused while he was a lawyer with that firm. >>> >>> [21] In Del Zotto v. Minister of National Revenue, [2000] 4 >>> F.C. 321, 257 N.R. 96, this court did find that there would be a >>> reasonable apprehension of bias where a judge, who while he was a >>> lawyer, had recorded time on a matter involving the same person who >>> was before that judge. However, this case can be distinguished as >>> Justice Webb did not have any time recorded on any files involving Mr. >>> Amos while he was a lawyer with Patterson Palmer or Patterson Law. >>> >>> [22] Mr. Amos also included with his submissions a CD. He >>> stated in his affidavit dated June 26, 2017 that there is a “true copy >>> of an American police surveillance wiretap entitled 139” on this CD. >>> He has also indicated that he has “provided a true copy of the CD >>> entitled 139 to many American and Canadian law enforcement authorities >>> and not one of the police forces or officers of the court are willing >>> to investigate it”. Since he has indicated that this is an “American >>> police surveillance wiretap”, this is a matter for the American law >>> enforcement authorities and cannot create, as Mr. Amos suggests, a >>> conflict of interest for any judge to whom he provides a copy. >>> >>> [23] As a result, there is no conflict or reasonable >>> apprehension of bias for Justice Webb and therefore, no reason for him >>> to recuse himself. >>> >>> [24] Mr. Amos alleged that Justice Near’s past professional >>> experience with the government created a “quasi-conflict” in deciding >>> the cross-appeal. Mr. Amos provided no details and Justice Near >>> confirmed that he had no prior knowledge of the matters alleged in the >>> Claim. Justice Near sees no reason to recuse himself. >>> >>> [25] Insofar as it is possible to glean the basis for Mr. >>> Amos’ allegations against Justice Gleason, it appears that he alleges >>> that she is incapable of hearing this appeal because he says he wrote >>> a letter to Brian Mulroney and Jean Chrétien in 2004. At that time, >>> both Justice Gleason and Mr. Mulroney were partners in the law firm >>> Ogilvy Renault, LLP. The letter in question, which is rude and angry, >>> begins with “Hey you two Evil Old Smiling Bastards” and “Re: me suing >>> you and your little dogs too”. There is no indication that the letter >>> was ever responded to or that a law suit was ever commenced by Mr. >>> Amos against Mr. Mulroney. In the circumstances, there is no reason >>> for Justice Gleason to recuse herself as the letter in question does >>> not give rise to a reasonable apprehension of bias. >>> >>> >>> III. Issue >>> >>> [26] The issue on the cross-appeal is as follows: Did the >>> Judge err in setting aside the Prothonotary’s Order striking the Claim >>> in its entirety without leave to amend and in determining that Mr. >>> Amos’ allegation that the RCMP barred him from the New Brunswick >>> legislature in 2004 was capable of supporting a cause of action? >>> >>> IV. Analysis >>> >>> A. Standard of Review >>> >>> [27] Following the Judge’s decision to set aside the >>> Prothonotary’s Order, this Court revisited the standard of review to >>> be applied to discretionary decisions of prothonotaries and decisions >>> made by judges on appeals of prothonotaries’ decisions in Hospira >>> Healthcare Corp. v. Kennedy Institute of Rheumatology, 2016 FCA 215, >>> 402 D.L.R. (4th) 497 [Hospira]. In Hospira, a five-member panel of >>> this Court replaced the Aqua-Gem standard of review with that >>> articulated in Housen v. Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235 >>> [Housen]. As a result, it is no longer appropriate for the Federal >>> Court to conduct a de novo review of a discretionary order made by a >>> prothonotary in regard to questions vital to the final issue of the >>> case. Rather, a Federal Court judge can only intervene on appeal if >>> the prothonotary made an error of law or a palpable and overriding >>> error in determining a question of fact or question of mixed fact and >>> law (Hospira at para. 79). Further, this Court can only interfere with >>> a Federal Court judge’s review of a prothonotary’s discretionary order >>> if the judge made an error of law or palpable and overriding error in >>> determining a question of fact or question of mixed fact and law >>> (Hospira at paras. 82-83). >>> >>> [28] In the case at bar, the Judge substituted his own >>> assessment of Mr. Amos’ Claim for that of the Prothonotary. This Court >>> must look to the Prothonotary’s Order to determine whether the Judge >>> erred in law or made a palpable and overriding error in choosing to >>> interfere. >>> >>> >>> B. Did the Judge err in interfering with the >>> Prothonotary’s Order? >>> >>> [29] The Prothontoary’s Order accepted the following >>> paragraphs from the Crown’s submissions as the basis for striking the >>> Claim in its entirety without leave to amend: >>> >>> 17. Within the 96 paragraph Statement of Claim, the Plaintiff >>> addresses his complaint in paragraphs 14-24, inclusive. All but four >>> of those paragraphs are dedicated to an incident that occurred in 2006 >>> in and around the legislature in New Brunswick. The jurisdiction of >>> the Federal Court does not extend to Her Majesty the Queen in right of >>> the Provinces. In any event, the Plaintiff hasn’t named the Province >>> or provincial actors as parties to this action. The incident alleged >>> does not give rise to a justiciable cause of action in this Court. >>> (…) >>> >>> >>> 21. The few paragraphs that directly address the Defendant >>> provide no details as to the individuals involved or the location of >>> the alleged incidents or other details sufficient to allow the >>> Defendant to respond. As a result, it is difficult or impossible to >>> determine the causes of action the Plaintiff is attempting to advance. >>> A generous reading of the Statement of Claim allows the Defendant to >>> only speculate as to the true and/or intended cause of action. At >>> best, the Plaintiff’s action may possibly be summarized as: he >>> suspects he is barred from the House of Commons. >>> [footnotes omitted]. >>> >>> >>> [30] The Judge determined that he could not strike the Claim >>> on the same jurisdictional basis as the Prothonotary. The Judge noted >>> that the Federal Court has jurisdiction over claims based on the >>> liability of Federal Crown servants like the RCMP and that the actors >>> who barred Mr. Amos from the New Brunswick legislature in 2004 >>> included the RCMP (Federal Court Judgment at para. 23). In considering >>> the viability of these allegations de novo, the Judge identified >>> paragraph 14 of the Claim as containing “some precision” as it >>> identifies the date of the event and a RCMP officer acting as >>> Aide-de-Camp to the Lieutenant Governor (Federal Court Judgment at >>> para. 27). >>> >>> >>> [31] The Judge noted that the 2004 event could support a >>> cause of action in the tort of misfeasance in public office and >>> identified the elements of the tort as excerpted from Meigs v. Canada, >>> 2013 FC 389, 431 F.T.R. 111: >>> >>> >>> [13] As in both the cases of Odhavji Estate v Woodhouse, 2003 SCC >>> 69 [Odhavji] and Lewis v Canada, 2012 FC 1514 [Lewis], I must >>> determine whether the plaintiffs’ statement of claim pleads each >>> element of the alleged tort of misfeasance in public office: >>> >>> a) The public officer must have engaged in deliberate and unlawful >>> conduct in his or her capacity as public officer; >>> >>> b) The public officer must have been aware both that his or her >>> conduct was unlawful and that it was likely to harm the plaintiff; and >>> >>> c) There must be an element of bad faith or dishonesty by the public >>> officer and knowledge of harm alone is insufficient to conclude that a >>> public officer acted in bad faith or dishonestly. >>> Odhavji, above, at paras 23, 24 and 28 >>> (Federal Court Judgment at para. 28). >>> >>> [32] The Judge determined that Mr. Amos disclosed sufficient >>> material facts to meet the elements of the tort of misfeasance in >>> public office because the actors, who barred him from the New >>> Brunswick legislature in 2004, including the RCMP, did so for >>> “political reasons” (Federal Court Judgment at para. 29). >>> >>> [33] This Court’s discussion of the sufficiency of pleadings >>> in Merchant Law Group v. Canada (Revenue Agency), 2010 FCA 184, 321 >>> D.L.R (4th) 301 is particularly apt: >>> >>> …When pleading bad faith or abuse of power, it is not enough to >>> assert, baldly, conclusory phrases such as “deliberately or >>> negligently,” “callous disregard,” or “by fraud and theft did steal”. >>> “The bare assertion of a conclusion upon which the court is called >>> upon to pronounce is not an allegation of material fact”. Making bald, >>> conclusory allegations without any evidentiary foundation is an abuse >>> of process… >>> >>> To this, I would add that the tort of misfeasance in public office >>> requires a particular state of mind of a public officer in carrying >>> out the impunged action, i.e., deliberate conduct which the public >>> officer knows to be inconsistent with the obligations of his or her >>> office. For this tort, particularization of the allegations is >>> mandatory. Rule 181 specifically requires particularization of >>> allegations of “breach of trust,” “wilful default,” “state of mind of >>> a person,” “malice” or “fraudulent intention.” >>> (at paras. 34-35, citations omitted). >>> >>> [34] Applying the Housen standard of review to the >>> Prothonotary’s Order, we are of the view that the Judge interfered >>> absent a legal or palpable and overriding error. >>> >>> [35] The Prothonotary determined that Mr. Amos’ Claim >>> disclosed no reasonable claim and was fundamentally vexatious on the >>> basis of jurisdictional concerns and the absence of material facts to >>> ground a cause of action. Paragraph 14 of the Claim, which addresses >>> the 2004 event, pleads no material facts as to how the RCMP officer >>> engaged in deliberate and unlawful conduct, knew that his or her >>> conduct was unlawful and likely to harm Mr. Amos, and acted in bad >>> faith. While the Claim alleges elsewhere that Mr. Amos was barred from >>> the New Brunswick legislature for political and/or malicious reasons, >>> these allegations are not particularized and are directed against >>> non-federal actors, such as the Sergeant-at-Arms of the Legislative >>> Assembly of New Brunswick and the Fredericton Police Force. As such, >>> the Judge erred in determining that Mr. Amos’ allegation that the RCMP >>> barred him from the New Brunswick legislature in 2004 was capable of >>> supporting a cause of action. >>> >>> [36] In our view, the Claim is made up entirely of bare >>> allegations, devoid of any detail, such that it discloses no >>> reasonable cause of action within the jurisdiction of the Federal >>> Courts. Therefore, the Judge erred in interfering to set aside the >>> Prothonotary’s Order striking the claim in its entirety. Further, we >>> find that the Prothonotary made no error in denying leave to amend. >>> The deficiencies in Mr. Amos’ pleadings are so extensive such that >>> amendment could not cure them (see Collins at para. 26). >>> >>> V. Conclusion >>> [37] For the foregoing reasons, we would allow the Crown’s >>> cross-appeal, with costs, setting aside the Federal Court Judgment, >>> dated January 25, 2016 and restoring the Prothonotary’s Order, dated >>> November 12, 2015, which struck Mr. Amos’ Claim in its entirety >>> without leave to amend. >>> "Wyman W. Webb" >>> J.A. >>> "David G. Near" >>> J.A. >>> "Mary J.L. Gleason" >>> J.A. >>> >>> >>> >>> FEDERAL COURT OF APPEAL >>> NAMES OF COUNSEL AND SOLICITORS OF RECORD >>> >>> A CROSS-APPEAL FROM AN ORDER OF THE HONOURABLE JUSTICE SOUTHCOTT DATED >>> JANUARY 25, 2016; DOCKET NUMBER T-1557-15. >>> DOCKET: >>> >>> A-48-16 >>> >>> >>> >>> STYLE OF CAUSE: >>> >>> DAVID RAYMOND AMOS v. HER MAJESTY THE QUEEN >>> >>> >>> >>> PLACE OF HEARING: >>> >>> Fredericton, >>> New Brunswick >>> >>> DATE OF HEARING: >>> >>> May 24, 2017 >>> >>> REASONS FOR JUDGMENT OF THE COURT BY: >>> >>> WEBB J.A. >>> NEAR J.A. >>> GLEASON J.A. >>> >>> DATED: >>> >>> October 30, 2017 >>> >>> APPEARANCES: >>> David Raymond Amos >>> >>> >>> For The Appellant / respondent on cross-appeal >>> (on his own behalf) >>> >>> Jan Jensen >>> >>> >>> For The Respondent / appELLANT ON CROSS-APPEAL >>> >>> SOLICITORS OF RECORD: >>> Nathalie G. Drouin >>> Deputy Attorney General of Canada >>> >>> For The Respondent / APPELLANT ON CROSS-APPEAL >>> >>> > SIDNEY POWELL Sidney Powell, P.C. 2911 Turtle Creek Blvd., Suite 300 Dallas, Texas 75219 (517) 763-7499 sidney@federalappeals.com HOWARD KLEINHENDLER Counsel of Record Howard Kleinhendler Esquire 369 Lexington Avenue, 12th Floor New York, New York 10017 (917) 793-1188 howard@kleinhendler.com L. LIN WOOD L. LIN WOOD, P.C. P.O. Box 52584 Atlanta, GA 30305-0584 (404) 891-1402 lwood@fightback.law Of Counsel JULIA Z. HALLER BRANDON JOHNSON EMILY P. NEWMAN SIDNEY POWELL STEFANIE LAMBERT JUNTTILA Attorneys for Plaintiffs/Petitioners 500 Griswold Street, Suite 2340 Detroit, MI 48226 (248) 270-6689 attorneystefanielambert@gmail. SCOTT R. ELDRIDGE Attorney at Law Miller, Canfield, One Michigan Avenue Suite 900 Lansing, MI 48933-1609 517-483-4918 Email: eldridge@millercanfield.com DANIEL M. SHARE EUGENE DRIKER STEPHEN E. GLAZEK Attorney at Law Barris, Sott, Denn & Driker, PLLC 333 West Fort Street; 12th Floor Detroit, MI 48226 313-965-9725 Email: dshare@bsdd.com EZRA D. ROSENBERG Lawyers' Committee for Civil Rights Under Law 1500 K Street, NW; Suite 900 Washington, DC 20005 202-662-8345 Email: erosenberg@lawyerscommittee. JON GREENBAUM Lawyers' Committee for Civil Rights Under Law District Of Columbia 1500 K Street NW Ste 9th Floor Washington, DC 20005 202-662-8315 Email: jgreenbaum@lawyerscommittee. ERIK A. GRILL HEATHER S. MEINGAST Michigan Department of Attorney General Civil Litigation, Employment & Elections Division PO Box 30736 Lansing, MI 48909 517-335-7659 Email: grille@michigan.gov DARRYL BRESSACK DAVID H. FINK and NATHAN J. FINK Attorneys as Law 38500 Woodward Avenue; Suite 350 Bloomfield Hills, MI 48304 248-971-2500 Email: dbressack@finkbressack.com ANDREW A. PATERSON, JR. Attorney at Law 46350 Grand River Ave. Novi, MI 48374 248 568-9712 Email: aap43@hotmail.com MARY ELLEN GUREWITZ Attorney at Law Cummings & Cummings Law PLLC 423 North Main Street; Suite 200 Royal Oak, MI 48067 313-204-6979 Email: megurewitz@gmail.com THOMAS MORE SOCIETY 309 W. Washington Street Suite 1250 Chicago, IL 60606 ph: 312.782.1680 f: 312.782.1887 “Personal prejudice and financial greed are the two great evils that threaten courts of law, and once they get the upper hand they immediately hamstring society, by destroying all justice.” ― Thomas More, Utopia.” Michael McHale, Counsel Michael McHale received a B.A. in Journalism and History from the University of Nebraska-Lincoln with high distinction in 2009, and a J.D. from the University of Nebraska College of Law with distinction in 2012. Prior to joining TMS, Michael served as general counsel and policy analyst for the Nebraska Catholic Conference, where he testified before several committees of the Nebraska Legislature defending the constitutionality of school vouchers, tax-credit scholarships, and Nebraska’s parental consent statute for abortion-seeking minors. From 2018 to 2019, he clerked for the Honorable L. Steven Grasz on the United States Court of Appeals for the Eighth Circuit. Michael is a Blackstone Legal Fellow with Alliance Defending Freedom. His writings on the rights to life and religious freedom have appeared in the Witherspoon Institute’s online journal, Public Discourse, along with the Omaha World-Herald and the Lincoln Journal Star. He has also completed pre-theology studies as a seminarian at St. Gregory the Great Seminary, where he studied philosophy and natural law. Biography of Michael McHale, Counsel Biography of Christopher Ferrara, Special Counsel Christopher Ferrara is a Roman Catholic attorney, pro-life activist, and journalist. He founded the American Catholic Lawyers Association in 1990. He joined the Thomas More Society in 2020, and concentrates his legal work on pro-life defense, religious liberty cases, unjust laws that attack Catholic institutions, and that infringe on parental rights. Mr. Ferrara graduated from Fordham Law in 1977 and practices out of a satellite office in the New York metropolitan area. Mr. Ferrara is a widely published author on Catholic Church affairs. Mr. Ferrara is married and has six children. CHRISTOPHER A. FERRARA, ESQ. (Bar No. 51198) 148-29 Cross Island Parkway Whitestone, Queens, New York 11357 Telephone: (718) 357-1040 973 703 0907 cferrara@thomasmoresociety.org Special Counsel to the Thomas More Society https://minnlawyer.com/2020/ Bill Gaier President and Publisher 612-584-1537 Republicans sue to stop Wisconsin vote certification By: The Associated Press November 25, 2020 MADISON, Wis. — Republicans filed a lawsuit Tuesday asking the Wisconsin Supreme Court to block certification of the presidential election results even as a recount over President-elect Joe Biden’s win over President Donald Trump is ongoing. The lawsuit echoes many of the same arguments Trump is making in trying, unsuccessfully, to have tens of thousands of ballots discounted during the recount. It also seeks to give the power to name presidential electors to the Republican-controlled Legislature. Wisconsin state law allows the political parties to pick electors, which was done in October. Once the election results are certified, which is scheduled to be done Dec. 1, those pre-determined electors will cast their ballots for the winner on Dec. 14. “The litigation filed this afternoon seeks to disenfranchise every Wisconsinite who voted in this year’s presidential election,” said Democratic Attorney General Josh Kaul. “The Wisconsin Department of Justice will ensure that Wisconsin’s presidential electors are selected based on the will of the more than 3 million Wisconsin voters who cast a ballot.” The lawsuit also rehashes a claim that a federal court rejected in September that Facebook CEO Mark Zuckerberg tried to “illegally circumvent Wisconsin absentee voting laws” through grants awarded by a nonprofit center he funds. At least 10 cases have been filed across the country seeking to halt certification in parts or all of key battleground states, including lawsuits brought by the Trump campaign in Michigan and Pennsylvania. So far none have been successful. The Wisconsin lawsuit was filed by attorney Erick Kaardal, a former Minnesota Republican Party official who also represented rapper Kanye West in his unsuccessful lawsuit attempting to get on the ballot in Wisconsin. Kaardal represents a conservative group called the Wisconsin Voters Alliance and a host of Republican voters. Kaardal also filed an unsuccessful federal lawsuit in Wisconsin that attempted to block $6.3 million from being awarded to five heavily Democratic cities from the nonprofit Center for Technology and Civic Life, which is primarily funded by Zuckerberg and his wife. A judge tossed the lawsuit that argued the money amounted to bribery to bolster Democratic turnout in Green Bay, Kenosha, Madison, Milwaukee and Racine. Many of the same arguments alleging the money was illegally awarded and therefore the election results should be nullified are being made in the new lawsuit in state court. Other claims mirror those by Trump’s campaign. Those claims allege absentee ballots should not have been counted where election officials filled in missing information on the certification envelope that contains the ballot and that voters who identified as “indefinitely confined” were lying to avoid the state’s photo ID law. The Wisconsin Elections Commission advises clerks that they can fill in missing information on the ballot envelopes, such as the address of a witness. That’s been the practice for years, and it’s never been challenged. Biden won Wisconsin by 20,608 votes, but the lawsuit claims that more than 156,000 ballots should be tossed out. info@thomasmoresociety.org Federal Court Says New York Governor Cuomo is Wrong to Limit Worship Services Governor Cuomo and Mayor DeBlasio (Photo by Drew Angerer/Getty Images) New York Governor Andrew Cuomo is wrong to limit worship services yet condone mass protests, according to a federal judge. After telling Thomas More Society attorneys in a June 18, 2020 hearing that he was “troubled by” the government’s responses, Senior U.S. District Judge Gary L. Sharpe issued a preliminary injunction on June 26, 2020, prohibiting Governor Cuomo, his Attorney General Letitia James, and New York City Mayor Bill de Blasio from ordering or enforcing COVID-19 prompted restrictions on outdoor religious worship gatherings. Christopher Ferrara “This decision is an important step toward inhibiting the suddenly emerging trend of exercising absolute monarchy on pretext of public health. What this kind of regime really meant in practice is freedom for me, but not for thee,” said Thomas More Society Special Counsel Christopher Ferrara. Thomas More Society Special Counsel Christopher Ferrara remarked, “We are pleased that Judge Sharpe was able to see through the sham of Governor Cuomo’s ‘Social Distancing Protocol’ which went right out the window as soon as he and Mayor de Blasio saw a mass protest movement they favored taking to the streets by the thousands. Suddenly, the limit on ‘mass gatherings’ was no longer necessary to ‘save lives.’ Yet they were continuing to ban high school graduations and other outdoor gatherings exceeding a mere 25 people. This decision is an important step toward inhibiting the suddenly emerging trend of exercising absolute monarchy on pretext of public health. What this kind of regime really meant in practice is freedom for me, but not for thee.” Sharpe’s order noted that, “it is not the judiciary’s role to second guess the likes of Governor Cuomo or Mayor de Blasio when it comes to decisions they make in such troubling times, that is, until those decisions result in the curtailment of fundamental rights without compelling justification.” In awarding the injunction, the court noted that “nonessential businesses” that enjoy a 50% capacity limitation are not justifiably different than houses of worship. Sharpe remarked that offices, retails stores, salons, and restaurants – all now permitted to open at 50% capacity indoors – all involve the congregation of people for a length of time. He stated, “These secular businesses/activities threaten defendants’ interest in slowing the spread of COVID-19 to a similar or greater degree than those of plaintiffs’, and demonstrate that the 25% indoor capacity limitation on houses of worship is underinclusive and triggers strict scrutiny review.” The judge pointed out, “Another case of individualized exemption seems even more obvious.” Governor Cuomo has now specifically authorized outdoor, in-person graduation ceremonies of no more than 150 people. This is an express exemption from the ten- or twenty-five-person outdoor limits that apply to other situations. Yet, “There is nothing materially different about a graduation ceremony and a religious gathering such that defendants’ justifications for a difference in treatment can be found compelling.” Sharpe took New York City to task, stating that de Blasio’s simultaneous pro-protest/anti-religious gathering messages “clearly undermine the legitimacy” of his argument that selective enforcement of the challenged laws with respect to mass race protests is a matter of public safety. “Governor Cuomo and Mayor de Blasio could have just as easily discouraged protests, short of condemning their message, in the name of public health and exercised discretion to suspend enforcement for public safety reasons instead of encouraging what they knew was a flagrant disregard of the outdoor limits and social distancing rules,” wrote Sharpe. “They could have also been silent. But by acting as they did, Governor Cuomo and Mayor de Blasio sent a clear message that mass protests are deserving of preferential treatment.” As a result of the federal order, Governor Cuomo, Attorney General James, and Mayor de Blasio are “enjoined and restrained from enforcing any indoor gathering limitations” against the involved houses of worship “greater than imposed for Phase 2 industries,” provided that participants follow the prescribed social distancing. They are also forbidden from “enforcing any limitation for outdoor gatherings provided that participants in such gatherings follow social distancing requirements as set forth in the applicable executive orders and guidance.” Cuomo, James, and de Blasio were sued by two Catholic priests from upstate New York and a trio of Orthodox Jewish congregants from Brooklyn for violations of their civil rights by prejudicial orders and selective enforcement. The federal lawsuit, filed June 10, 2020, in United States District Court for the Northern District of New York, charged the governor, attorney general, and mayor with violating the plaintiffs’ rights to free exercise of religion, freedom of speech, assembly and expressive association, and due process, under the First and Fourteenth Amendments to the U.S. Constitution. Governor Cuomo was also accused of violating New York state law and the New York State Constitution. Ferrara explained the lawsuit: “In an unprecedented abuse of power, Governor Cuomo and Mayor de Blasio have exploited the COVID-19 pandemic to create, over the past three months, a veritable dictatorship by means of a complex web of executive orders. The orders have imposed and selectively enforced ‘social distancing’ under a ‘lockdown’ of virtually every aspect of life for New York state residents on the pretext of ‘public health,’ but with numerous exceptions. The permissible activities, not based on the science of viral contagion, but rather determined according to personal value judgments, have included mass demonstrations of thousands of people – gatherings of which the governor and mayor have approved and the mayor participated in. Cuomo and de Blasio, along with James, have enforced the gubernatorial ‘lockdown’ by threat of criminal prosecution and actual prosecution, including $1,000 fines for the recently created offense of violating Cuomo’s ‘Social Distancing Protocol’.” Ferrara added, “These mass protest gatherings, taking place during the COVID-19 stay-at-home lockdown orders, have been not only allowed but praised by both the governor of New York and mayor of New York City, even though massive property damage and death have resulted. This, when the government’s primary purpose is to protect the people it governs.” Read United States District Court for the Northern District of New York Judge Gary L. Sharpe’s Memorandum-Decision and Order, issued June 26, 2020, in response to the Thomas More Society’s complaint, filed on behalf of Rev. Steven Soos, Rev. Nicholas Stamos, Daniel Schonbrun, Elchanan Perr, and Mayer Mayerfeld, in Rev. Steven Soos, et al v. Andrew M. Cuomo, et al, here. https://minnlawyer.com/2020/ Minnesota churches join legal challenges to virus rules By: The Associated Press August 14, 2020 Churches in Minnesota and California, backed by a conservative legal group, filed lawsuits this week against the governors of their states challenging restrictions imposed due to the coronavirus outbreak that they contend are violations of religious liberty. They’re the latest in a long series of legal challenges, many of them in California, pitting clerics and houses of worship who believe they should be exempt from certain restrictions on public gatherings against governors who insist the measures are needed to rein in the pandemic. Most of the suits have been rebuffed; some have succeeded. In Minnesota, a lawsuit was filed Thursday in federal court challenging Gov. Tim Walz’s executive orders requiring 6-foot social distancing and the wearing of face masks at worship services. “Gov. Walz, a former teacher, gets an F in religious liberties,” said Erick Kaardal, special counsel for the Thomas More Society. “Other states, including Texas, Illinois and Ohio, have excluded churches from COVID-19 mask mandates.” Minnesota Attorney General Keith Ellison reiterated his defense of Walz’s order, saying it was legally and constitutionally sound. Teddy Tschann, spokesperson for Walz, said the governor was within his authority taking the action and added that all Walz’s actions have been grounded in the desire to keep Minnesotans safe. Walz had been embroiled in a battle with Roman Catholic and Lutheran Church-Missouri Synod congregations across Minnesota over restrictions he placed on gatherings of more than 10 people. He relented and said they could hold services at 25% of capacity if certain conditions were met after they made it clear they planned to defy the order. Earlier this month a pastor in Palmetto, Florida, filed a suit challenging Manatee County’s mask mandate. The Rev. Joel Tillis of Suncoast Baptist Church said the order shouldn’t extend to houses of worship because it hinders prayer. The Thomas More Society, which specializes in litigation on religious issues, filed a lawsuit Wednesday in California Superior Court against Gov. Gavin Newsom and other officials. It seeks to prevent the enforcement of “unconstitutional and onerous coronavirus pandemic regulations” against Grace Community Church in the Los Angeles neighborhood of Sun Valley. The pastor, John MacArthur, has been holding services in recent weeks attended by throngs of worshippers in defiance of state and county limits on gatherings. “We will obey God rather than men,” MacArthur said in a message to his congregation. “He will be on our side.” MacArthur was greeted with applause Sunday when he welcomed worshippers to his church’s “peaceful protest.” One of the two Thomas More lawyers representing MacArthur and his church is Jenna Ellis, who also is a senior legal adviser to President Donald Trump’s reelection campaign. “California’s edicts demanding an indefinite shutdown have gone now far past rational or reasonable and are firmly in the territory of tyranny and discrimination,” Ellis said. “This isn’t about health. It’s about blatantly targeting churches.” The lawsuit contends that restrictions on large gatherings should not be enforced at churches because they were not enforced on large demonstrations against racism and police brutality. Officials in California, where COVID-19 cases have been surging in recent weeks, say strict restrictions remain necessary in Los Angeles County and other counties that are on a state monitoring list for high rates of new infections. Los Angeles County filed a lawsuit against the church Thursday seeking to have in-door, in-person worship services stopped. The lawsuit also seeks to have the church comply with health order requirements, including the use of face covers and physical distancing at outdoor services. Attorney General Xavier Becerra’s office referred a request for comment to Newsom’s office, as the new lawsuit addresses the governor’s executive order. Spokesmen for Newsom did not immediately respond to a request for comment. Across the country the vast majority of churches have cooperated with health authorities and successfully protected their congregations. Yet from the earliest phases of the pandemic, and continuing to this day, some worship services and other religious activities have been identified as sources of local outbreaks. A few churches have been openly defiant, including one in California’s Ventura County which held indoor worship services Sunday despite a judge’s temporary restraining order. Pastor Rob McCoy of Godspeak Calvary Chapel in Newbury Park had vowed to continue in-person services even though the order cited “an immediate threat to public health and safety.” On Tuesday a different judge declined a county request to order the immediate closure of the church, and scheduled a hearing for Aug. 21. Earlier this year the U.S. Supreme Court upheld state COVID-19 restrictions on religious gatherings in a suit filed by South Bay United Pentecostal Church in Chula Vista, California. Religious plaintiffs have prevailed in some litigation, however. In June a federal judge blocked New York state from enforcing restrictions on indoor religious gatherings to 25% capacity when other types of gatherings were limited to 50%. The plaintiffs, represented by the Thomas More Society, were two Catholic priests from Upstate New York and three Orthodox Jewish congregants from Brooklyn. They argued that the restrictions violated their First Amendment rights to practice their religion. The society also claimed a victory in May when Illinois Gov. J.B. Pritzker withdrew certain pandemic-related mandates on houses of worship. In the new Minnesota case, the plaintiffs were Protestant churches in the towns of Alexandria, Buffalo and Crosby, along with their pastors. “Our people are commanded to meet together in fellowship,” Eric Anderson, pastor of Life Spring Church in Crosby, said at a news conference Thursday. “They can’t fellowship with masks on their faces.” Kaardal, the Thomas Moore lawyer, argued that Walz’s executive order usurped the legislature’s lawmaking powers. https://www.youtube.com/watch? 12-21-20 Guardians of Free Speech; Flynn Family Stands with 1st Amendment Praetorians 8,941 views Streamed live on Dec 21, 2020 Ann Vandersteel 1st Amendment Praetorian Special Guest: Robert Patrick Lewis https://twitter.com/1st_ 1AP.admin@protonmail.com https://www.1apraetorian.com/ https://www.1apraetorian.com/ Resounding Endorsements! 1. General Flynn Endorsement: https://twitter.com/GenFlynn/ 2. Joe Flynn Endorsement: https://twitter.com/ 3. Joe Flynn Endorsement : https://twitter.com/ 1AP.admin@protonmail.com Anni L. Foster (#023643) General Counsel Office of Arizona Governor Douglas A. Ducey 1700 West Washington Street Phoenix, Arizona 85007 Telephone: 602-542-4331 E-Mail: afoster@az.gov Brett W. Johnson (#021527) Colin P. Ahler (#023879) Derek C. Flint (#034392) Ian R. Joyce (#035806) SNELL & WILMER L.L.P. One Arizona Center 400 E. Van Buren, Suite 1900 Phoenix, Arizona 85004-2202 Telephone: 602.382.6000 Facsimile: 602.382.6070 E-Mail: bwjohnson@swlaw.com cahler@swlaw.com dflint@swlaw.com ijoyce@swlaw.com Attorneys for Defendant Douglas Brian Kemp Office of the Governor 206 Washington Street Suite 203, State Capitol Atlanta, GA 30334 Tel: (404) 656-1776 Email: governorsoffice@michigan.gov Christopher M. Carr Office of the Attorney General 40 Capitol Square, SW Atlanta, GA 30334 Tel: (404) 458-3600 Email: ccarr@law.ga.gov Gretchen Whitmer Office of the Governor P.O. Box 30013 Lansing, MI 48909 Tel: 517-373-3400 Email: governorsoffice@michigan.gov Dana Nessel G. Mennen Williams Building 525 W. Ottawa Street P.O. Box 30212 Lansing, MI 48909 Tel: 517-373-1110 Email: dnessel@michigan.gov Ken Paxton Attorney General of Texas Brent Webster First Assistant Attorney General of Texas Lawrence Joseph Special Counsel to the Attorney General of Texas Office of the Attorney General P.O. Box 12548 (MC 059) Austin, TX 78711-2548 kenneth.paxton@oag.texas.gov (512) 936-1414 Anthony S. Evers Office of the Governor 115 East, State Capitol Madison WI 53702 Tel: (414) 227-4344 Email: EversInfo@wisconsin.gov Joshua L. Kaul Wisconsin Department of Justice 17 West Main Street, P.O. Box 7857 Madison, WI 53707-7857 Tel: (608) 287-4202 Email: kauljl@doj.state.wi.us Tom Wolf Office of the Governor 508 Main Capitol Building Harrisburg, PA 17120 Tel: 717-787-2500 Email: govcorrespcrm@pa.gov Josh Shapiro Office of Attorney General Strawberry Square Harrisburg, PA 17120 Tel.: 717.787.3391 Email: jshapiro@attorneygeneral.gov Alexander Michael del Rey Kolodin, AZ Bar No. 030826 Alexander.Kolodin@KolodinLaw. Christopher Viskovic, AZ Bar No. 0358601 CViskovic@KolodinLaw.com KOLODIN LAW GROUP PLLC 3443 N. Central Ave. Ste. 1009 Phoenix, AZ 85012 Telephone: (602) 730-2985 Facsimile: (602) 801-2539 Andrew Wilder Director of Communications Republican Majority Caucus (602) 926-5299 awilder@azleg.gov Representative Mark Finchem, LD-11 P.O. Box 69344 Oro Valley, AZ 85737 (520) 808-7340 MarkFinchem@me.com Nancy K. Barto 5450 East. Deer Valley Dr. #2196 Phoenix, Arizona 85054 602-926-5766 (office) 480-513-3750 (home) 602-370-8262 (direct) NBarto@azleg.gov Alexis E. Danneman (Bar No. 030478) Sarah R. Gonski (Bar No. 032567) PERKINS COIE LLP 2901 North Central Avenue, Suite 2000 Phoenix, Arizona 85012-2788 Telephone: (602) 351-8000 Facsimile: (602) 648-7000 ADanneman@perkinscoie.com SGonski@perkinscoie.com Marc E. Elias* Bruce V. Spiva* John Devaney* John M. Geise** PERKINS COIE LLP 700 Thirteenth Street NW, Suite 600 Washington, D.C. 20005-3960 Telephone: (202) 654-6200 Facsimile: (202) 654-6211 MElias@perkinscoie.com BSpiva@perkinscoie.com JDevaney@perkinscoie.com JGeise@perkinscoie.com Laura Hill* PERKINS COIE LLP 1201 Third Avenue, Suite 4900 Seattle, WA 98101-3099 Telephone: (206) 359-3349 Facsimile: (206) 359-4349 LHill@perkinscoie.com Roy Herrera (Bar No. 032901) Daniel A. Arellano (Bar No. 032304) BALLARD SPAHR LLP 1 East Washington Street, Suite 2300 Phoenix, Arizona 85004-2555 Telephone: 602.798.5400 Facsimile: 602.798.5595 HerreraR@ballardspahr.com ArellanoD@ballardspahr.com Senator Kelly Townsend: a. Senator in the AZ legislature b. Maricopa County c. kellyjtownsend@yahoo.com ALLISTER ADEL MARICOPA COUNTY ATTORNEY Thomas P. Liddy (019384) Emily Craiger (021728) Joseph I. Vigil (018677) Joseph J. Branco (031474) Joseph E. LaRue (031348) Deputy County Attorneys liddyt@mcao.maricopa.gov craigere@mcao.maricopa.gov vigilj@mcao.maricopa.gov brancoj@mcao.maricopa.gov laruej@mcao.maricopa.gov CIVIL SERVICES DIVISION 225 West Madison Street Phoenix, Arizona 85003 Telephone (602) 506-8541 Facsimile (602) 506-4317 ca-civilmailbox@mcao.maricopa. Attorneys for Maricopa County Defendants Roopali H. Desai (024295) D. Andrew Gaona (028414) Kristen Yost (034052) COPPERSMITH BROCKELMAN PLC 2800 North Central Avenue, Suite 1900 Phoenix, AZ 85004 T: (602) 381-5478 rdesai@cblawyers.com agaona@cblawyers.com kyost@cblawyers.com Justin A. Nelson (admitted pro hac vice) SUSMAN GODFREY L.L.P. 1000 Louisiana, Suite 5100 Houston, TX 77002-5096 T: (713) 651-9366 jnelson@susmangodfrey.com Stephen E. Morrissey (admitted pro hac vice) SUSMAN GODFREY L.L.P. 1201 Third Avenue, Suite 3800 Seattle, WA 98101-3000 T: (206) 516-3880 smorrissey@susmangodfrey.com Stephen Shackelford (admitted pro hac vice) SUSMAN GODFREY L.L.P. 1301 Avenue of the Americas, 32nd Floor New York, NY 10019-6023 T: (212) 336-8330 sshackelford@susmangodfrey.com Davida Brook (admitted pro hac vice) SUSMAN GODFREY L.L.P. 1900 Avenue of the Stars, Suite 1400 Los Angeles, CA 90067 T: (310) 789-3100 dbrook@susmangodfrey.com Michael C. Herron Dartmouth College Department of Government 6108 Silsby Hall Hanover, NH 03755-3547 Homepage: http://www.dartmouth.edu/˜ Phone: +1 (603) 646-2693 Mobile: +1 (603) 359-9731 Email: michael.c.herron@dartmouth.edu Jonathan Rodden Stanford University Department of Political Science Encina Hall Central 616 Serra Street Stanford, CA 94305 Phone: (650) 723-5219 Fax: (650) 723-1808 Email: jrodden@stanford.edu STEPHEN DANIEL ANSOLABEHERE Department of Government Harvard University 1737 Cambridge Street Cambridge, MA 02138 sda@gov.harvard.edu Gary King Institute for Quantitative Social Science Harvard University 1737 Cambridge Street Cambridge, Massachusetts 02138 GaryKing.org Direct: (617) 500-7570 King@Harvard.edu Assistant: (617) 495-9271 king-assist@iq.harvard.edu Re: Please resend
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