It perhaps should surprise few that the civil cases would be as peculiar as was the criminal case. First came Duke's peculiar (and unsuccessful) motion demanding that the judge shut down the dukelawsuit.com website—even though the website only had links to case events and documents, while Duke itself hosted a website containing President Brodhead's official statement linking the plaintiffs to racism and the legacy of rape.
Then came Linwood Wilson—acting as his own attorney—calling on the court to disqualify Bill Thomas from the case. The act seemed less like a legal maneuver than payback for the fact that Thomas consistently and effectively stood up for due process during Mike Nifong's 2006 reign of terror.
Now comes the latest filing of Duke and
Duke's lead attorney, Jamie Gorelick, claims that the University should be trusted to preserve all relevant documentation, and that having attorneys for both sides get together to begin the process at this stage would be premature. First, she says, she wants the court to rule on the motion to dismiss.
Indeed, it seems as if Gorelick wants to delay the start of discovery for a considerable period of time. The Duke brief states,
The task of arriving at an efficient discovery plan is complicated by the fact that there are three other pending cases in this District that would be affected by a decision to commence discovery now in this case. Coordination among the many parties involved in these multiple lawsuits and their counsel will be necessary and challenging, given the volume of potential witnesses and issues that are common to all the matters.
Any discovery plan in this action should be fashioned in a manner that will accommodate, but not unnecessarily duplicate, discovery needs in the other cases. The most efficient and sensible way to achieve this aim is to proceed with discovery after all the motions to dismiss in the pending cases have been resolved by the Court, whereupon the parties in the various cases can assess which claims against which parties remain to be litigated and can then develop a coordinated discovery plan.
In other words, Duke wants the University to receive a free pass on discovery issues not only until the motions to dismiss in this case and the Ekstrand lawsuit are ruled upon—but until the court also deals with the motion to dismiss in the lawsuit filed by the three falsely accused players against Durham. Duke, of course, is not even a party to this lawsuit.
Even more oddly, the Duke brief cites two cases that appear to undermine its argument. First, Gorelick approvingly quotes Tschirn v. Kurzweg to bolster her claim that "under these circumstances, where discovery may prove superfluous and unnecessary costs of early discovery may be avoided, proceeding with discovery only after resolution of the motions to dismiss is warranted. Yet Tschirn, as her own citation notes, granted "the defendants’ motion for stay of all discovery pending ruling on motion to dismiss and completion of Rule 26(f) conference." [emphasis added]
The lacrosse players, of course, had filed a motion explicitly requesting . . . a Rule 26(f) conference, in which Duke thus far has refused to participate. (The players' motion is entitled, "MOTION TO REQUIRE DEFENDANTS TO PARTICIPATE IN THE MANDATORY RULE 26(F) DISCOVERY CONFERENCE.") How a case justifying deferring all discovery pending completion of a Rule 26(f) conference is relevant to Duke's claim that it doesn't have to participate in a Rule 26(f) conference at this stage Gorelick doesn't reveal.
Gorelick concedes that case law for a defendant to unilaterally refuse to participate in a 26(f) conference is murky, but the Duke brief cites another case Hall v. Witteman, which lays out guidelines for "staying discovery pending resolution of dispositive motions or motions to dismiss."
Hall holds that “it is appropriate for a court to stay discovery until a pending dispositive motion is decided … where the case is likely to be finally concluded as a result of the ruling thereon; where the facts sought through uncompleted discovery would not affect the resolution of the motion; or where discovery on all issues of the broad complaint would be wasteful.” [emphasis added]
*In evaluating a motion to dismiss, the judge must assume that all facts in the motion are true. But--as the Duke and Durham motions to dismiss repeatedly pointed out--the judge need not assume that legal conclusions (such as an allegation of conspiracy) are true. Such a claim is a critical component of the Ekstrand lawsuit. Both the Duke and Durham responses allege that the facts presented did not support the conspiracy claim. But would facts sought through discovery colster it?
Take the most vulnerable of the Duke defendants, Tara Levicy. Among other items relating to Levicy is the Gottlieb brief, which essentially blames the entire initiation of the case on the former SANE-nurse-in-training. Is it really Duke's position that nothing in a deposition of Levicy (which would surely include the heretofore wholly unrevealed questions of how much her supervisors knew about her performance, and what she said in a June conference with Nifong) would "not affect" the motion to dismiss, regarding the conspiracy claim?
Or take the e-mails of the senior administrators of the Brodhead administration, especially those penned by guilt-presuming Larry Moneta. Is it really Duke's position that an examination of Moneta's files, or a deposition of Moneta himself, would "not affect" the motion to dismiss, regarding the conspiracy claim?
Update: A reader points out another anomaly in the Duke response. Gorelick demands that discovery (and, indeed, even convening a 26(f) conference) must be deferred until all motions to dismiss (including the motion to dismiss the suit filed by the three falsely accused players) are decided. But that motion, which solely involves non-Duke actors, raises legal issues (namely immunity and qualified immunity) that are wholly irrelevant to the unindicted players' suit against Duke. What possible rationale, then, exists for Duke to avoid even scheduling a discovery conference while a judge evaluates various constitutional claims that have nothing to do with any issue at hand in the lawsuit against Duke?
*--corrected and clarified
Does anybody seriously believe that the discovery will be truthful?
Emails and documents have been deleted and justice will be obstructed every way possible. Of course, this would be a criminal act, but that old Clinton hack Gorelick sure knows how to do this, and everybody knows the ethics of Duke (and DPD).
Luckily, the IQ level of the people at Duke Dept of Useless Gang88 Studies is close to zero so who knows, maybe some documents can still be found.
I hope they go directly to server backups and try to find something there.
Does anybody know when the motions are scheduled to be acted upon? I'm real curious to see this play out now. Specifically, I'd bet that a bunch of evidence has already been "misplaced".
I am surprised that Gorelick did not tell us that since the Duke defendants would lie all during discovery, that there should be no discovery. Her reasoning would be that discovery would be nothing but a pack of lies, anyway, told by her clients.
To be honest, Gorelick simply is saying nonsense but making sure that the Democrat judge in this case knows that unless he plays ball with her, he can forget any promotions in a Democratic administration. These filings are political, not legal, in nature.
It is not an easy matter to destroy electronic evidence. This is a hot topic in federal court and is the subject of virtually endless discussion. Put simply, thought, dedicated attorneys supported by appropriate technical people can determine if evidence has been destroyed or altered. Most emails are so easily replicated, and electronic communication creates so many trails, that people who try to alter the record are almost always caught, if the other side is dedicated. When caught, and you can look up the Morgan Stanley case, the loss can be in the billions. Moreover, the attorneys personally need to attest that evidence has not been destroyed and some very big name firms have been hammered, and attorneys careers destroyed, when this deception is uncovered. If you are interested, you can look up the Qualcomm case in San Diego. So, not only is it difficult or impossible to conceal the destruction of electronic evidence, attorneys (selfish as they are and I am one) will not put themselves personally on the line for a client in those circumstances.
On a broader point, I do not believe I have seen the name Haditha mentioned on this site. [I am sure it probably has been, but I have not seen it.] It is becoming clearer and clearer that Haditha was another case where the media ran with a story without skepticism and smeared a group of US Marines.
With the prosecution going 0-7 with one case pending, it is looking very familiar to those here. He is Michelle Makin's take on that case:
A SMEAR IMPLODES
Just another reminder to be skeptical about what one reads in the press.
All I know is that this wall of silence that Duke University and rest of the defendants are putting up is sickening.
The reason Lawyers delay proceedings is because they know their clients have little or no chance of winning in court. In addition, defendants attornies in this case know that thorough and honest discovery is going to reveal criminal acts on the part of some of the defendants. Oldest lawyer tactic on the planet. If you have a guilty client keep him/her out of jail as long as possible. And milk 'em for all the legal fees you can.
"It is not an easy matter to destroy electronic evidence. This is a hot topic in federal court and is the subject of virtually endless discussion."
I'm somewhat familiar with the discovery process. Here, we have group of professional liars who will certainly try to (continue) destroy evidence. Then, we have ethically challenged (Clinton-affiliated) attorneys who will do the same (several high profile attorneys have been busted in recent years: this is what many attorneys do for living).
First, the friendly attorney asks if (gang88/duke/dpd) happen to have any relevant emails and documents. If they reveal some emails, then the attorney copies the emails to his USB stick. Next, the friendly attorney study the content and then give it to the judge (who happen to be a friendly judge, perhaps hoping for a nomination by the next Dem administration). The judge probably rules that this is enough for discovery (since no evidence of obstruction of justice etc).
Hopefully, every gang88 has to testify under oath about the emails and (given their limited IQ), perhaps somebody says something stupid which reveals something and the judge is forced to ask for further discovery.
Jamie Gorelick proves once again that she is little more than a shyster with political connections. That Duke is using her as lead attorney doesn't say much about their smarts.
This is a charade.
Gorelick and company know it.
They also know the attorneys for the lacrosse players know it.
Any judge presiding over the case knows it.
This is a perfect illustration why I despise the law profession for the most part.
It's all a game and it will be played out like an awkward tap dance with Duke and Durham attempting to tell everyone that what we all know happened....didn't happen.
Outgoing Durham City Manager Baker is now trying to play games with the city attorneys. No doubt, he's trying to provide some cover for himself as he takes his new position.
This case calls for a no-nonsense judge who is as sick and tired of this charade as those of us are who have observed it for almost 3 years.
The Diva is just too impatient for all these games!
Delicious irony in the association of the phrase "Blue wall of silence" with this case. First the players (falsely), then Duke (truly).
Very high level of legal anaylsis. Hope and trust that someone from the players' legal team is actively monitoring DIW.
Contrary to an earlier poster, it is quite easy to destroy evidence when one is not held accountable. We already have seen how the Durham police destroyed the tapes from the first night -- after they specifically were requested in court by the defense.
The DPD then destroyed the tapes and Judge Ronald Stephens said nothing and placed no sanctions on them. True, it is a crime to destroy evidence, but in North Carolina, the authorities and entities like Duke pretty much are a law unto themselves.
The four pm poster is wrong about destruction of evidence, and his post proves it. We know the durham police destroyed the tapes. In federal court, based on a number of recent decisions, that means you are defaulted. The same is true of electronic evidence. There are literally scores of recent cases crushing defendants who failed to preserve electronic evidence. Huge and powerful defendants and law firms have felt this brutal sting.
You can claim that the state courts won't honor the law, but the federal courts have been consistent since the new rules are passed.
Moreover, as I noted, the lawyers are now personally accountable for the destruction. The point of the change is to make sure that the lawyers police the clients or withdraw. No succesful lawyer is going to trash their career for a dirtbag client who is wiping servers clean.
As I noted, read the Qualcom case from San Diego. Qualcom wiped out e mails and Qualcom and its in house and outside counsel are punished with fines and sanctions.
Defer and delay discovery? You would think Gorelick is paid by the hour or something.
In the end, Duke will do anything (or, failing that, pay any amount of money) to avoid releasing the administrative emails. The professors' emails will merely confirm what we already know, but the administrators' correspondence (and the Board of Trustees' even more so) would be dynamite.
It is funny as hell that Duke hired Gorelicker to represent them. It's kind of like James and Susan McDougall hiring Hillary Clinton to represent them.
Is there someone following this blog that can speak with authority on the technical aspects of the email destruction/retrieval issue. The previous discussion covers the surface. Is there a technical explanation of how the plaintiffs and their attorneys can be certain that discovery is complete.
It would seem that the most damning items will be revealed in the correspondence of the administration. How will the players' attorneys get at those items?
Early on in this matter, Duke's lawyers had to send out 'document freeze' memos to all who had potentially discoverable evidence. That memo would have included electronic files. Duke will likely be required to provide disk images from tens or hundreds of PCs, e-mail servers, etc. Evidence of destruction will be devastating b/c spoliage, as destruction of evidence is known, may lead to the ultimate sanction of a finding of liability against the party guilty of spoliation - leaving only a question of damages.
This is indeed one of the hottest issues in litigation at present. Duke's lawyers have their collective work cut out for them b/c they will have to turn it all over, but first they will have to look at the files themselves. Duke will spend hundreds of thousands of dollars complying with discovery requirements.
In addition, all individual defendants will have to turn over computers and their ISPs will be subpoenaed. This is going to be an enormous discovery case. And I'm quite certain that there will be e-mails among professors and admininstrators which will astound.
The Duke strategy is to delay and stonewall every attempt to get the facts out.
Who is paying the astronomical legal fees? If it is almost $800,000 so far for Durham, it must be much higher for Duke. Is it coming from tuition, donations, or the endowment?
Does anyone doubt for a minute that the mayor of Durham and other key council members were not meeting with Brodhead and members of Duke's administration---Burness, more than likely---to sway and interject a list of "their needs" in the Spring of 2006?
Just like this case which has been documented below, the people who run Durham have always operated this way.
If Duke were to tell the truth, they made every move---mostly against the lacrosse players---under the direction of Durham city officials.
The attorneys for the lacrosse players in this latest suit can look to this as an example.
As Patrick Baker is leaving his position of city manager to be a city attorney---LOL! LOL!---he's shifting employees around in what appears to be a cover for what occurred in 2006.
Durham is simply a corrupt place. It's in stone.
Council member should step aside for interfering
Cora Cole-McFadden should resign from the Durham City Council. She violated a city policy that barred companies from meeting with council members before a contract was awarded.
Cole-McFadden reportedly met with MV Transportation officials before the DATA bus contract was awarded to complain that Durham's MV management team did not have a black person on it. It has been reported in court that she insisted that the company have a more diverse leadership team in Durham.
The company gave in to this unethical demand and fired Tom Hartley, Durham's DATA general manager who is white, and replaced him with a black person. This is not being diverse, but racial discrimination at its worst.
A court arbitrator found that Cole-McFadden's improper backroom-meeting with MV officials was a cause for Hartley's termination and awarded him back pay and benefits. How much did this cost Durham taxpayers?
Citizens expect city business to be open, fair and free of improper influence by council members. Why haven't the other council members or mayor spoken in public against how this whole affair was handled? If this is business as usual for the City Council, it is no wonder our taxes increase at such alarming rates.
June 19, 2008
Here's some hilarious news about Governor Easley's trip to Italy.
This is the stooge who appointed Mike Nifong as the Durham DA.....and then ran from him when he got into trouble.
This is the guy who strongly supported Hillary Clinton until it became clear that she and Billy Jeff were not going to be able to bully the super-delegates.
This is the guy who graduated from NCCU's law school.
What a loser.
If Duke has done nothing wrong, they don't even need lawyers; they certainly don't need to avoid discovery.
DEFERRING DISCOVERY sounds similar to the contortions Richard Nixon put us through as he tried to keep the transcripts of those audio tapes for falling into the hands of journalists.
Perhaps 'Tricky Dick' Brodhead will follow the lead of 'Tricky Dick' Nixon and announce that Duke has assembled a summary of e-mails and other documents concerning the hoax in beautiful blue binders for all of us to review and feel good about.
Do we not ever learn from the mistakes of others?
Stu Daddy just made me aware of the spirited discussion on the Chronicle comment thread in response to 88 Lee Baker's recent appointment.
Some might wish to participate.
Below is another exchange "reharmonizer" had with someone who posted on Liestoppers.
The only reason I even bother with such a groveling wuss is to keep illuminating the mindset that permeates the Duke faculty.
He has repeatedly tried to put on a show (acted out badly) of being objective.
Just look at his sarcastic and sickening comment attempting to make fun of the situation.
I have put all of "reharmonizer's" words in bold relief. This man and his little limp hit-job website remind me of a screaming mouse begging to get attention.
Well, thanks to KC's high profile he has had a bit of attention.......and he shows himself to be a mere Gang of 88 mascot.
Lacking the balls to just come right out and admit that he is just like them.
I suppose he thinks he can harmonize his way out of it.
Oh those poor teenagers. First bored, then terrified, then ripped off. Sounds like Duke needs to invest in some nannies.
Robert Zimmerman | June 19, 2008 at 4:14 am
Sydney Carton went onto the Liestopper’s forum to complain about my flippant response.....
"I pasted an extremely short rebuttal with some generally under utilized facts over at Reharmonize.His reply speaks for itself.Like the original 88ers he never retracts just does another softshoe act and moves by.The fact that this whole thing is a hoax fromthe word go doesn’t bother him at all."
So Sydney, guess what? Before you write a rebuttal, you’re supposed to read and understand the text you’re rebutting. What you wrote is not a rebuttal, it’s a pathetic attempt to explain away the bad behavior of one group of people by dwelling on the bad behavior of another group.
Besides the point I made in the post about the difference between hiring a person and buying a thing, here are a few ways that we seem to disagree: (1) I think Duke students are adults–it seems that you don’t; (2) I think it’s reasonable to expect more self-control and responsibility from Duke students than we’d expect from a substance-abusing stripper/prostitute–apparently you’re happy to square them off in a race for the bottom; (3) Though they’re naive greenhorns to you, I think it’s also reasonable to expect Duke students to know what they’re doing when they call a sleazy service to send a woman they’ve never met over to their house to take off her clothes.
If it makes you feel better and more secure to infantilize the lacrosse team and snort piously about the strippers who victimized them, go right ahead. For that matter, humor yourself into thinking you’re rebutting something, just don’t expect me to go along with the charade.
Duke’s counsel is not prepared to discuss all aspects of e discovery in a 26(f) conference. So they seek delay. The lawyer’s face sanctions if they violate their “Zubulake Duty”. Phoenix Four, Inc. v. Strategic Resources Corp.
The Zubulake Duty
To do this, counsel must become fully familiar with her client’s document retention policies, as well as the client’s data retention architecture. This will invariably involve speaking with information technology personnel, who can explain system-wide backup procedures and the actual (as opposed to theoretical) implementation of the firm’s recycling policy. It will also involve communicating with the “key players” in the litigation, in order to understand how they stored information. Zubulake v. UBS
There are several issues related to authentication of data exchange.
One deals with the authentication of the historic evidence that was exchanged among the participants. This is what will make very interesting reading.
Another is the authentication of the evidence after it is collected and presented at trial. One, for example, may involve exchanges between Duke Administrators and the DPD over the past couple of years. The later would involve electronic evidence access after it was secured as evidence.
One must be able to demonstrate the authenticity of the participants of the exchanges AND ensure that the content has not been manipulated. Authenticated parties may be exchanging data that has, or will be manipulated.
Most, if not all, authentication procedures are dependent upon a central authority that does not likely interoperate among data silos. Given the disparate parties involved, it is not likely high level authentication was utilized.
For example just because institutional “X” has state-of-the-art authentication controls, does not mean that institution “Y” has the same standard of care. It would not be a surprise to learn that none of the participants utilize a high level of authentication. A fully deployed PKI system is cumbersome and expensive to maintain from an administrative perspective. Universities typically will not be using state-of-the-art authentication.
There are issues related to non-repudiation, sanitization, etc. Can you prove that the person whom says they did NOT originate the message did in fact do so? Did the person who gained access properly or illegally see all of the content or only select portions?
Fundamentally, IT security is network-centric. The authentication procedures are separated from the content. This, even when properly deployed creates several significant issues.
Was the content of the exchange modified at rest, before or after an authenticated session was established or terminated?
Was the content manipulated during an authenticated session (man-in-the-middle or man-in-the-browser styled attack)?
Was the content modified after it was archived (authentication procedures not in place)?
Was the content modified by a trusted/properly authenticated insider (rogue insider)?
Can an audit trail be established that connects each authenticated user to the content over the life-cycle of the content?
Each of these issues, assume that some level of user authentication was involved.
The same issues become important after the electronic evidence bag is created and sealed. Who has access, what are their credentials, when did they access the evidence, and did their access alter any of the evidence?
The reason why the Feds are cracking down on electronic file destruction is because it is difficult if not impossible to prove the aforementioned in an unimpeachable fashion.
Think about the ramifications of the aforementioned and the recent Supreme Court ruling regarding enemy combatants the next time a terror plot is uncovered.
I think you meant to write "bolster it."
"But would facts sought through discovery colster it?"
For the e discovery issue, for those who are interested, there are thousands of thousands of pages written on this topic. It is currently the nightmare for young lawyers, who are attending multiple seminars on this topic.
But, for simplicty sake, here is how it works. Every large organization now has an IT (computer) department that tracks all servers, laptops etc. Duke has one. And that group of computer geeks have "datamaps" of all those computers. Practically speaking, you can't hide the datamap, too many people know about it and the people in charge (the computer people) are not going to lie under oath for something that is easily verifiable. also, for example, if you left off the server that had duke hospitals emails, you should be able to figure out it was missing.
Once you know the datamap, you now have the right to go in and inspect every server to see if it has been altered. Moreover, the attorney must vouch for the datamap and the server locations, and so now he or she has skin the game.
Your own IT people can go to each server and inspect it to see if it has been changed or altered. They can also inspect the backup tapes.
When you have a large complex system, sophisticated IT people can find out if one server was altered. Keep in mind, the dirtbags dont' know how to to a succesful secret alteration, they would need the IT department, which is unlikely to do it and then lie about it under oath. Even if they do, they have to get every single copy of every single email or else they are busted and then they also have to conceal the fact that the servers, all of them, were wiped clean.
What the Plaintiffs will do is load the emails onto software which can track and correlate the emails. So, if they missed one copy of one email or file, the software would pick it up and then, since person a message to person b was found on person's b email and not persons a, person a is busted for destruction of evidence. When you multiply this issue by the tens of thousands, if not hundreds of thousands or millions of emails you can see how impossible it is to make sure that the destruction of evidence can be done in secret. Many high profile consulting firms are specializing in just this analysis.
Also, the attorney would have to agree to go down with the client. Say what want about high profile attorneys and their ethics, but they don't want to be disbarred. It is not an excuse to say that you did not know about missing emails or destroyued servers, you have to police your client. That is one point of the new rules in federal court--the atorney is at risk. So, to hide the evidence you would not only have to succesfully alter the existing electronic data, and have the IT department lie about it, and hope that the Plaintiffs would not catch it with their software, but you would have to have your selfish, rich, attorney sign on to your self-destruct mission.
Could it happen? Sure, it could. But the record is not good in federal court for those who would try--federal judges have absolutely crushed the cheaters.
The biggest issue is the cost, of course. If you are a poorly funded plaintiff, and have not taken the seminars and don't have the right software, you might be unable to figure out whether you have all the emails. Howeveer, if you are well funded, you can higher the best and the brightest and then take the depositions of all the IT people. In that situation, the odds of succesfully hiding electronic evidence are slim to none.
Now, you need the Judge to enforce the rules. But federal court is not durham municipal court.
I think that the Defendants know all this. They know that they are going to be turning over horrible damaging stuff and they can't stop it. So, that is why they filed this motion.
As I said earlier, this is a hot topic. No one has all the answers but you can be sure of one thing. In the old days, you could just rip up paper copies and nobody would know. Nowadays, destroying electronic evidence carries high risk and high cost.
Zimmerman is the Duke lacrosse Whack-a-Mole. He randomly pops up at blogs and begins his plaintive ranting.... "Notice me. Someone. Anyone. Please notice me."... before he is summarily bludgeoned.
My main problem with Zimmerman is the simple fact that he appeared on the scene about eighteen months AFTER the lacrosse incident. Zimmerman didn't make so much as a peep when the battles were being fought even though he was physically on Duke's campus. What a profile in courage!
Long after Cooper declared that RCD were "innocent" of all charges Rip Van Winkle Zimmerman suddenly woke up and amazingly decided to battle KC.
Do us all a favor, Zimmerman. Go back to sleep.
It seems that the Duke strategy is two fold.
1. Delay the inevitable damage of discovery as long as possible
2. Raise the PR costs to the plaintiffs so that they will seek a settlement.
The Duke wall of silence is the only refuge for Broadhead. He found a high priced gunslinger to execute the plan but his alone is the accountability.
Once actual discovery starts, the game is over. Look for more efforts to slime the players.
Is Gorelick a Communist?
Also, check this: Editorial: Milberg settlement should be only the beginning
Politically connected well-known attorneys have been doing this for years (Milberg et al had direct connection to Jamie Gorelick via White House dealings). If nationally known attorneys with direct links to White House are doing this (and go to jail), does anybody seriously believe that they were the only ones?
Destructing evidence, bribing judges and doing political favors is what many attorneys do. Yes, in theory you can go to jail, but the chances are slim (especially if the political climate favors you).
Similarly, Duke/Gang88/DPD people are ethically challenged pathological liars who are ready to lie under oath and destroy evidence. They will use the race card if threatened and no judge (who wants appointment to higher office) will ever go after them.
Also, if you just happen to delete emails before "imminent threat of trial" it is not a crime, and certainly.
And will the Group of 88’s professorial wall of silence crumble? Will even one of these professors, who so gleefully rushed to judgment last spring, now retract their signatures from the document?
This question remains to be answered. What say the administration of the school who accused the LAX players of putting up a wall of silence. Seems to me the wall rests within the walls of the so-called hallowed institution. Maybe the inmates from the "institution" need to do some listening.
Any advice for your clients counselor?
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