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Tuesday, December 29, 2009
Friday, November 20, 2009
Wednesday, November 4, 2009
Gibson, Dunn & Crutcher LLP
United States: A Renewed Emphasis On Upjohn Warnings
29 October 2009
Article by Lee Dunst Esq and Daniel Chirlin Esq
As white-collar government investigations and enforcement actions increase in the wake of the recent financial crisis, so too do the challenges for attorneys engaged in corporate internal investigations. Specifically, lawyers face potential conflict-of-interest issues in connection with these investigations and may run afoul of ethics rules and risk penalties by failing to take adequate steps to protect themselves.
For example, several recent cases have involved allegations of attorneys' failure to appropriately handle and disclose conflicts of interest when representing company employees in connection with internal investigations or inquiries from government regulators. As a result, there has been an increased focus on so-called Upjohn warnings (otherwise known as the "corporate Miranda") that company counsel provides to company employees in connection with these investigations. While these recent cases have more to say about traditional conflict-of-interest concerns than Upjohn warnings, it is important for practitioners to be mindful of the potential ethical pitfalls surrounding each.
The Upjohn Warning
The so-called Upjohn warning takes its name from the seminal Supreme Court case Upjohn Co. v. United States,1 in which the court held that communications between company counsel and employees of the company are privileged, but the privilege is owned by the company and not the individual employee. Thus, in an internal investigation, the company is the client and therefore controls privilege. The purpose of the warning is to remove any doubt that the lawyer speaking to the employee represents the company, and not the employee.
A typical Upjohn warning consists of an explanation that the lawyer represents the company, not the individual. Therefore, anything revealed during the course of the interview is only privileged as between the lawyer and the company. The employee has no control over whether the company decides to waive the privilege, which often may be done sometime in the future in the hope of obtaining cooperation credit from the government.2
Clearly then, this presents a potentially difficult situation for a practitioner. It is in the best interest of the company and outside counsel to encourage employees to be candid and forthcoming during the course of an investigation. However, at the same time, a proper Upjohn warning makes it clear that employees' statements are not within their own control, as the company has the right to waive the privilege and disclose these statements to the government, and thus could make employees less likely to reveal potentially incriminating facts.
Also, this creates the possibility that practitioners might give an unclear or incomplete Upjohn warning. Even experienced businesspeople may not appreciate the nuances of privilege, and the risk looms far greater with less sophisticated employees who are given an unclear Upjohn warning.
Two highly publicized cases from earlier this year highlight the issues facing attorneys conducting internal investigations, including the ethical challenges arising from interviews of company employees.
Broadcom: A Study in Potential Conflict Of Interest
In connection with the pending criminal case against senior management of Broadcom Corp., a law firm in Los Angeles suffered the ire of U.S. District Judge Cormac J. Carney for "breach[ing] its duty of loyalty" to its client, former Broadcom CFO William Reuhle.3 In April Judge Carney issued a scathing opinion on the ethics of multiple representations, finding that the law firm's actions created a conflict of interest that no Upjohn warning could salvage. As a result, Judge Carney suppressed Reuhle's statements and even went so far as to refer the law firm to the California State Bar for discipline.
Broadcom retained the firm in 2006, when the government began investigating the company in connection with its stock option practices. As a result, the law firm began conducting an internal investigation into alleged stock option backdating at Broadcom. At the same time, Broadcom was sued in two separate civil actions related to the same issues, and Reuhle was individually named in both actions, where the same law firm represented him for the first several months of the proceedings.
Simultaneously, as part of the internal investigation, the law firm interviewed Reuhle. At the beginning of the interview, Reuhle supposedly was told only that the investigation was being done "on behalf of Broadcom." Subsequently, and apparently without Reuhle's consent, Broadcom agreed to turn over his interview statements to the U.S. attorney, and Reuhle later was indicted on a variety of criminal charges in June 2008. Reuhle then filed a motion to suppress his statements made to company counsel, arguing that his rights under Upjohn had been violated.
In his April 1 decision Judge Carney lambasted the law firm for failing to provide a proper Upjohn warning to Reuhle, rejecting the suggestion that a statement that the interview was done "on behalf of Broadcom" was sufficient. The judge criticized the attorneys' failure to explain that they were representing Broadcom's interest in the interview, rather than Reuhle's, and that any information disclosed could be used by Broadcom or disclosed to the government.
Indeed, Judge Carney found that Reuhle had a very legitimate reason to believe that the law firm represented his personal interests, as the firm had been representing him in civil litigation related to the identical subject matter as the internal investigation. According to Judge Carney, California disciplinary rules mandate that any simultaneous representation presenting conflicting interests requires written consent by both parties — something the law firm apparently never obtained.4
The judge found that the law firm violated its duty of loyalty to Reuhle because:
It questioned him for the benefit of a separate client, Broadcom; and
It did not consult Reuhle before disclosing his statements to third parties, particularly the government.
According to Judge Carney, the firm should have informed Reuhle that it might be in his best interest to pursue separate counsel.
This recent decision presents the practitioner with several instructive lessons. First, it is essential that very early in any internal investigation, the attorney assesses where potential conflicts of interest might arise. This is particularly true when separate civil suits implicate company executives who may also be witnesses in connection with the internal investigation.
Second, if an attorney does decide to represent both the company and an individual employee, she should obtain a written conflict waiver. Notably, however, even a conflict waiver may not prevent a circumstance where the attorney is forced to resign from both representations, if the conflicts become irreconcilable.
Third, an Upjohn warning is not necessarily a replacement for a conflict waiver, even where the Upjohn warning is full and sufficient.
Finally, when interviewing a company employee, an attorney should always administer a full Upjohn warning and note the fact in writing contemporaneously or memorialize it soon thereafter. A watered-down Upjohn warning may not be sufficient, as demonstrated in the Broadcom case, as well another case from earlier this year.
Stanford Financial Group: Another Study In Potential Conflict of Interest
On the heels of the Bernard Madoff scandal, another alleged Ponzi scheme drama exploded in early 2009 in connection with Stanford Financial Group. According to public reports, the criminal and regulatory investigation into Stanford broke open several days after a New York lawyer made a "noisy withdrawal" from his representation of Stanford before the Securities and Exchange Commission. Specifically, the attorney withdrew his representation from the company and disaffirmed all his prior statements made to the SEC.
Shortly thereafter, Laura Pendergest-Holt, Stanford's former chief investment officer, sued the lawyer and his firm for malpractice involving an alleged breach of the fiduciary duty of loyalty.5 Although Pendergest-Holt later moved to dismiss the action without prejudice, the facts surrounding her malpractice claim again demonstrate the pitfalls for an attorney or law firm that simultaneously represents both a company and its executives.
According to the civil complaint, the lawyer accompanied Pendergest-Holt to her deposition at the SEC Feb. 10. Pendergest-Holt said she believed that the lawyer was her attorney and represented her in an individual capacity. The complaint recounts an alleged conversation at the deposition where the attorney told the SEC staff, "I represent her insofar as she is an officer or director of one of the Stanford affiliated companies." Receiving no further clarification, Pendergest-Holt claims to have believed that this attorney would represent her interests.
However, Pendergest-Holt alleges in her complaint that the attorney failed to serve her interests in several material respects:
He did not inform her of her Fifth Amendment right not to testify and instead allowed her to make statements to the SEC that subsequently led to her indictment on obstruction charges;
He failed to tell her that her conversations with him were not privileged, insofar as the company controlled the privilege;
He did not explain that conflicts of interest existed between Pendergest-Holt and Stanford that would not allow the attorney to simultaneously represent both parties; and
He never advised her that she should seek separate counsel.
If these allegations seem to echo the facts in the Broadcom case, it is because these problems may be far from unusual. If these two recent, highly publicized incidents are any indication, the pendulum may be swinging toward heightened scrutiny of conflicts of interest. As such, the days of the "watered-down" Upjohn warnings could be numbered.
The Days Ahead: Considerations For Practitioners
The possibility of future complications and consequences arising from incomplete or unclear Upjohn warnings prompts a number of practical lessons that can be drawn from these two recent cases. First, it is important to assess, very early on in any investigation, which parties will require separate counsel. That counsel should be provided to the company employee promptly, ideally before any substantive information is learned from the witness. Any confidences shared by a witness-client or prospective witness-client may present future conflict issues that could force an attorney to resign from representing both the witness and the company.6 Moreover, if during an interview with an unrepresented witness, a lawyer discovers that the witness has interests that conflict with the interests of the company, the ethics rules require the attorney to advise the witness to secure counsel.7
Second, if an attorney does decide to represent both an individual and the company, she would be prudent to obtain an informed written conflict waiver from each party.8 Even then, the lawyer must reasonably believe she can represent both parties' interests adequately. With that in mind, it is generally good practice to include in any conflict waiver (or retainer agreement), a provision that, in the face of a conflict, allows the attorney to resign from one representation in favor of the other.
Third, when conducting an interview with a company employee, company counsel should administer a complete Upjohn warning. Ideally, the interview preparation materials or some form of written protocol should outline the substance of the warning. Additionally, the administration of the warning should be documented contemporaneously in the interview notes, and it also should be noted that the witness acknowledged that he understood the warning. A properly administered (and memorialized) warning can save an attorney plenty of headaches down the road.
By example, a comprehensive Upjohn warning should include the following statements and explanations, in some form or another:
We represent the company, not you.
As part of our investigation, we need to gather information. We do so by speaking with employees. We gather this information for the purpose of providing legal advice to our client, the company. As such, this means that our conversation with you is protected by the attorney-client privilege.
However, the privilege is between the lawyers and the company, not you. The privilege is controlled by the company, and the company may decide to share any information it learns through this interview with third parties, including the government, without your permission or notice.
Finally, as an employee, we ask that you keep everything discussed here confidential. Please do not share this conversation with anyone, including other employees. This is what keeps the conversation privileged.
An interesting issue arises in the context of in-house representation. In-house counsel represents the company, as opposed to individual employees. The question is when do in-house attorneys need to provide an Upjohn warning to employees. Ultimately, the calculus is very similar to interviews conducted by outside counsel. Generally, the more substantive the interview, the more senior the witness or the more involvement of the employee in question, the greater likelihood that an Upjohn warning is necessary and prudent.
Finally, it is worth noting that while the recent Broadcom and Stanford cases may at first appear to be outliers, the problems they present are common and likely to face any practitioner who engages in an internal investigation and must provide Upjohn warnings when interviewing company employees. Moreover, as the current administration in Washington continues to turn up the heat on enforcement efforts, it is reasonable to expect that internal investigations will become more frequent and these issues surrounding potential conflicts of interest concerning company employees may become more prevalent. As such, it is incumbent upon attorneys to keep in mind the rules of the road concerning Upjohn warnings in order to avoid the ignominy of facing an ethics review board and to help prevent a company employee from unwittingly forfeiting his Fifth Amendment rights.
Monday, November 2, 2009
OKLAHOMA CITY -- City leaders worked to build support for the MAPS 3 plan with a rally at Lake Overholser on Sunday.
City leaders want to use a 1-cent sales tax to make improvement to rail lines, build a new downtown park and a convention center. The $40 million plan would also expand current trails to create the nation's longest trail system.
"If MAPS 3 passes, we are going to build a trail all the way around Lake Overholser, a trail all around Draper Lake and connect all three city lakes," said Trails Advisory Committee Chairman Hal McKnight.
"It will be fun. I will probably ride about five miles," said bicyclist Henry Amis, 8.
Organizers also want to include a $60 million project to improve the Oklahoma River and its white water course.
"The river venue, we can be one of the best, if not the best urban aquatic venue in the world," said Oklahoma City University rowing coach Mike Knopp.
The MAPS 3 proposal, if passed, would begin collecting a 1-cent sales tax in April and continue for nearly 8 years.
The Fraternal Order of Police said it opposes the plan, saying that hiring more officers should be a bigger priority. The group asked the Oklahoma City Council to use some of the money from the MAPS-3 plan to promote public safety.
The council is set to vote on the measure on Dec. 8.
Saturday, October 17, 2009
Two accountants who worked at Feed The Children say the charity owes $1.1 million to the state of Oklahoma in back taxes on purchases. They allege the chief financial officer wanted to cover it up.
Read more: http://newsok.com/feed-the-children-may-owe-oklahoma-1.1m/article/3409857#ixzz0UCBT2oNe
Friday, September 25, 2009
Friday, September 18, 2009
Study Questions Okla. School Performance
OKLAHOMA CITY -- A new study claimed that one in four Oklahoma high school students couldn't identify the first person to be President of the United States.
Thursday, September 17, 2009
Will someone be kept awake at night so much they will go crazy and assasinate someone? Well, we will know, won't we?
Wednesday, September 16, 2009
Sunday, September 13, 2009
Justice is justice. This is a fair and sensible article and to keep Democracy here in America, it should be followed. This is just a paragraph and you can go to the link HERE and read it all. -
They only want government to intervene when they suffer personally -- so let's yank their federal health insurance
By Joe Conason
Reaching out to his opponents, the president tried to emphasize that such empathy toward other human beings "is not a partisan feeling," but is instead an aspect of our national character. This kind of Americanism represents "our ability to stand in other people's shoes -- a recognition that we are all in this together; that when fortune turns against one of us, others are there to lend a helping hand ... and an acknowledgment that sometimes government has to step in to help deliver on that promise." .......
Monday, September 7, 2009
Sunday, August 30, 2009
Tuesday, August 18, 2009
In the store so many illegals were in the store driving baskets right in front of me and trying to get close enough to touch me. When I finished and ready to leave all the illegals rushed to the only check-out woman to go out. The nun was third one in the only checkout line.
I naturally went to the first empty line to lean and wait for those obnoxious, disrespectful, lawbreaking, bullies to get done so I could leave.
A lady came out to check and smiled at me and said she would check me out. I started over and the nun third in line tore out and came racing saying something nasty about it was HER turn and she worked for illegals and something about it was HER TURN, and I graciously let her go ahead. As she did she started talking about HER HISPANICS and me , and then started talking Spanish and looking at me hatefully.
Her Spanish and hateful tone and looks at me pissed me off and I told her maybe SHE don’t have no legal papers! Finally she paid and walked out. All the lawbreaking illegals surrounded the end of check-out lanes. Apparently they sent that one young illegal taller than my waist running over to me and hit my purse HARD and it hurt my back. Deliberately, clearly. I told him if he hit me again I would call the police. And don’t think I won’t.
Badly the truth must be this: the nun and the Catholic church are obviously breaking man’s laws. Like one, supporting the racist Mexican lawbreakers illegals who HATE Americans. And they must be the group that has had me stalked for so long.
Clearly this church accepts blood money. Laundering illegal’s money for selling illegal drugs. Yet they DO NOT want to support legalizing pot. Cause they don’t like paying taxes for their satanic business deals.
Religiously speaking they are viciously violating GOD’S laws and should have started expecting some of the worst rebuke from GOD they will experience.
They are hating their neighbors here in America. They have been hurting poor American citizens by making state and Federal government give money and programs to illegals that they have been denying poor, suffering, American citizens who it ONLY belongs to.
Although they still have lots of illegal drug profits they could have used for them.
Obviously these are Satanic people. I don’t have anything to do with Satanists! And clearly to me, any Catholic that gives any American citizen hell is a servant of Satan and deserves great punishment. Just wait ‘til GOD REBUKES them.
Tuesday, August 11, 2009
Thursday, April 2, 2009
Wednesday, March 11, 2009
Videos and links for your viewing pleasure:
Unfair competition! Favoritism!
Why don't I have the rights of a corporation?????
KOW YOUR RIGHTS!
Actually, if a 'corporate' license is given by the government....we own pieces of it ANYWAY!
Wednesday, February 18, 2009
Passive murder as I see it. To see someone kill another person and someone saw it happen but walking away without helping or going to find help and the person dies makes the witness just as guilty as the main murderer. And if our main purpose isn't to improve this life and help others the best we can then it makes Jesus's life and works a joke and that he lied and died. But I don't believe that was the message of his life. And the gift he left to us was humbleness...and few partake in the feast.
Of course we should strive always for perfection, but it was only reached once by one human and that was Christ. And yet he forgives us when we seek it. And that he can see into our hearts and makes lying to him impossible, it is called a 'grace' which makes possible the gift of humbleness. Not by works, but by faith that no man should boast....
These are a few of the things I wonder about.
Sunday, February 15, 2009
Tuesday, February 10, 2009
Offered by President Roosevelt inHis January 11, 1944, State of the Union Address
It is our duty now to begin to lay the plans and determine the strategy for the winning of a lasting peace and the establishment of an American standard of living higher than ever before known. We cannot be content, no matter how high that general standard of living may be, if some fraction of our people—whether it be one-third or one-fifth or one-tenth—is ill-fed, ill-clothed, ill-housed, and insecure.
This Republic had its beginning, and grew to its present strength, under the protection of certain inalienable political rights—among them the right of free speech, free press, free worship, trial by jury, freedom from unreasonable searches and seizures. They were our rights to life and liberty.
As our nation has grown in size and stature, however—as our industrial economy expanded—these political rights proved inadequate to assure us equality in the pursuit of happiness.
We have come to a clear realization of the fact that true individual freedom cannot exist without economic security and independence. “Necessitous men are not free men.” People who are hungry and out of a job are the stuff of which dictatorships are made.
In our day these economic truths have become accepted as self-evident. We have accepted, so to speak, a second Bill of Rights under which a new basis of security and prosperity can be established for all—regardless of station, race, or creed.
Among these are:
The right to a useful and remunerative job in the industries or shops or farms or mines of the nation;
The right to earn enough to provide adequate food and clothing and recreation;
The right of every farmer to raise and sell his products at a return which will give him and his family a decent living;
The right of every businessman, large and small, to trade in an atmosphere of freedom from unfair competition and domination by monopolies at home or abroad;
The right of every family to a decent home;
The right to adequate medical care and the opportunity to achieve and enjoy good health;
The right to adequate protection from the economic fears of old age, sickness, accident, and unemployment;
The right to a good education.
All of these rights spell security. And after this war is won we must be prepared to move forward, in the implementation of these rights, to new goals of human happiness and well-being.
America’s own rightful place in the world depends in large part upon how fully these and similar rights have been carried into practice for our citizens.
Sunday, February 8, 2009
Saturday, February 7, 2009
Tuesday, January 27, 2009
Thursday, January 15, 2009
Bank of America started as Bank of Italy
Amedeo Giannini, son of Italian immigrants to the US, started the Bank of America in a converted saloon in San Francisco at 9 am on Monday, 17 October 1904. On the first day, 28 deposits totalled $8,780.
When an earthquake struck in 1907, he ran his bank from a plank in the street. Word quickly spread about his service and by 1916 he had several branches. By 1929, the bank was strong enough to withstand the Great Depression stock crash. Giannini changed the name to Bank of America in 1928 and remained chairman until 1963.
The Bank of Italy in Italy was created in 1893 through the merger of 3 of the 6 banks at the time: Banca Nazionale nel Regno d'Italia and 2 Tuscan banks.
The Bank of England was founded by William Patterson after King William III of England found himself badly in need of funds to fight a war with France in 1694. Patterson provided the funds after the king agreed to order all the goldsmiths of London to stop issuing receipts as depositories for precious metals, forcing merchants to store their gold with the new bank. The Bank of England was finally authorised in 1946.
The Reichsbank of Germany was founded by Meyer Amschel Rothschild (1743-1812), who appointed his son Karl over the Bank of Naples, and his son Salomon over the Bank of Vienna. Later, his son Edmund presided over the Bank of Germany,and his son Nathan over the Bank of England.
By the time of the American Civil War (1861 - 1865) there were 1600 banks in the US, issuing about 7,000 different kinds of bank notes.
In 1861, the US Congress authorised "promissory notes," calling them "greenbacks" to contrast in colour with notes issued by private banks. The US Treasury held the impressive sum of $346,681,016. (Link)
In 1909, Amadeo Peter Giannini, a bold, farsighted businessman and founder of the San Francisco Bank of Italy, established the bank's first out-of-town branch in his native city of San José . Built at the corner of Lightston and Santa Clara Streets, San José's new Bank of Italy represented Giannini's first step towards his creation of one of the world's largest privately owned banks, the Bank of America.
Originally concerned over the inadequate banking service offered the Italian community at the turn of the century, Giannini founded the Bank of Italy in 1904. By 1930 the bank had grown to become nationally famous as the Bank of America. Beginning with San José's Bank of Italy branch and followed by his subsequent development of the first successful branch banking system in the United States, Giannini set the pace of banking in this country as well as hastening and strengthening the growth of California.
The Bank of America funded the reconstruction at History Park as a Bicentennial Project in 1977. All artifacts in the bank are from the Bank of America and were used in San José branches.
In 1958, it invented the bank credit card, the BankAmericard, which changed its name to VISA in 1975. A consortium of other California banks came up with Master Charge (now MasterCard) in order to compete with BankAmericard.
Following passage of the Bank Holding Company Act of 1967, BankAmerica Corp. was established for the purpose of owning Bank of America and its subsidiaries.
BankAmerica expanded outside California in 1983 with its acquisition of Seafirst Corp. of Seattle and its wholly owned banking subsidiary, Seattle-First National Bank. This happened when Seafirst was at risk of being seized by the federal government after becoming insolvent through a series of bad loans to the oil industry. However, BankAmerica continued to operate the banks as Seafirst rather than Bank of America until after the merger with NationsBank.
Bank of America was dealt huge losses in 1986 and 1987 due to bad loans in its Third World lending, particularly in Latin America. The company fired its CEO, Sam Armacost, although Armacost blamed the problems on his predecessor, A.W. (Tom) Clausen, who was then appointed to replace Armacost. The losses resulted in a huge decline of BankAmerica stock, making it vulnerable to a hostile takeover. First Interstate Bancorp of Los Angeles (which had been built from banks once owned by BofA), launched such a bid in the fall of 1986, although BankAmerica rebuffed it, mostly by selling its FinanceAmerica subsidiary to Chrysler and by selling the brokerage firm Charles Schwab and Co. back to Mr. Schwab. On the day of the stock market crash in 1987, BankAmerica was trading at $8 per share, although by 1992 it had rebounded mightily to become one of the biggest gainers of that half-decade.
In 2004, Bank of America Corp. acquired Boston, Massachusetts-based FleetBoston for $47 billion to solidify Bank of America's position as the bank with the largest FDIC rated deposit market share in the United States with $513 billion in deposits well ahead of the number 2 bank holding company, newly-merged J.P. Morgan Chase-Bank One with $353 billion in deposits and number 3 Wells Fargo & Co. with $228 billion. (Deposits as of June 30, 2003.) The combined Bank of America and Fleet have 5,700 branches serving 35 million customers in 29 states. After the merger with FleetBoston Financial, roughly 1 out of every 10 dollars on deposit in a commercial bank and savings and loan were deposits of Bank of America.
Although Bank of America Corp. and Bank of America and both much larger than their nearest rivals in terms of deposit share, other finacial services companies are larger on the basis of assets, profits, market capitalisation. (More at link)
It was not until the 1980s (Note from Rayelan: This is t he MAIN reason Reagan had to be elected no matter what they did to bring it about... even treason!!) with a change in federal banking legislation and regulation that Bank of America was again able to expand its domestic consumer banking activity outside of California.
In Los Angeles, immigrants who don't have credentials to work in the United States can still get a credit card, thanks to a pilot program run by Bank of America. The bank is hoping to tap a fast-growing market by offering credit cards to illegal immigrants without Social Security numbers.(At NPR-audio)
Bankrupcty administrators for a Parmalat subsidiary are suing Bank of America in federal court in Charlotte, contending the bank played a role in the food giant's insolvency.
Welcome to the machine. One of the three largest banks in the US by assets (along with Citigroup and JPMorgan Chase), Bank of America boasts the country's most extensive branch network, with more than 6,100 locations covering some 30 states from coast to coast. Its core services include consumer and small business banking, credit cards, and asset management. In early 2009 Bank of America paid some $50 billion in stock for Merrill Lynch, which was crippled by the ongoing credit crisis. The acquisition of the once-mighty investment bank known as "The Bull," which has an extensive retail brokerage network, beefs up Bank of America's wealth management, investment banking, and international business.
Key numbers for fiscal year ending December, 2007:
One year growth: 6.2%
Net income: $14,982.0M
Income growth: (29.1%)
HONG KONG (Reuters) - Bank of America Corp, coping with tough economic conditions, raised $2.83 billion by selling part of its stake in China Construction Bank Corp, and Hong Kong's richest tycoon sold a $500 million stake in rival Bank of China.
And the list just goes on and on and on....they must have also broken the anitrust laws a thousand times but I don't see any mention of it among their long list of crimes. So now I see who is financing the New World Order so that they may rule it with their iron fist.
And the list just goes on and on and on....they must have also broken the anitrust laws a thousand times but I don't see any mention of it among their long list of crimes. So now I see who is financing the New World Order so that they may rule it with their iron fist.
Tuesday, January 6, 2009
Also a video producer, DAVEOFJAY on YouTube channel has made a video refuting the lies of illegals. An articulate speaker, I'll let Dave explain it to you:
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