Government & Politics

BREAKING NEWS: Hollywood And Broadway Declare War On The Presidency, Elections, Democracy, Decency And Civility. NOW What?

/ Jack Marshall / 92 Comments

“I’m just going to say one thing. Fuck Trump! It’s no longer ‘Down with Trump.’ It’s ‘fuck Trump!’”

—Actor Robert De Niro on live TV at the Tonys last night.

Then he pumped both fists in the air, as a large contingent of the crowd of Broadway glitterati at Radio City Music Hall stood and gave him a standing ovation, endorsing the gutter insult.

I believe such un-American conduct creates an ethical obligation on the part of fair and reasonable American to demonstrate their contempt and opposition, in as strong and decisive a manner possible.

What that means is beyond my ability to suggest right now. I don’t like to write when I am angry, and I am angry. But this must not stand.

Yesterday, commenting on the unethical Tony Awards scheduling  of De Niro, who has used other appearances to make vulgar, hateful, ad hominem attacks on the President, I wrote in part,

“If you invite Robert De Niro, you are deliberately announcing that your event is going to be politically divisive and include an attack, probably uncivil, on the President—and while he will be engaged in crucial international negotiations. The President has nothing to do with the Tonys, nor does politics—the main contenders for top musicals are “SpongeBob” and “Mean Girls,” for heaven’s sakes—nor does De Niro, who is just one more movie star being used by Broadway to attract a larger TV audience.”

Naturally, CBS allowed this to go forward, because it was in search of ratings for the perpetually viewer-starved awards show. The network either knew or should have known that this meant that it would be broadcasting some kind of ugly episode. The network was accused of  conspiring with Janet Jackson to flash her breast during the supposedly family-friendly Super Bowl half-time show—you know, back in those halcyon days when games didn’t include NFL players symbolically calling the US. racist as a prelude?—and swore that it had no idea anything inappropriate was going to happen. Well, it can’t make that claim now about De Niro. De Niro’s outburst is like the breast-bearing if Jackson had been flashing at every public appearance. CBS knew he was going to insult the President. It wanted him to insult the President. Continue reading →

Sunday Morning Ethics Warm-Up, 6/10/18: Tony, Bob, Woody, And Charles

/ Jack Marshall / 15 Comments

Good morning!

1. Tonys Ethics. I’ll be skipping the Tonys again this year, and if I wasn’t already in the habit of doing so, the fact that Robert De Niro was being promoted as a presenter would have done the trick. Inviting De Niro is one more example of show business anti-Trump aggression. The actor has been unrestrained in making ugly, profane, vulgar attacks on the President in inappropriate venues. True, he hasn’t called the President a cock-holster or a cunt  yet, but that’s about the only mitigation.

Here was his public rant  in January at another awards event:

“This fucking idiot is the President. It’s The Emperor’s New Clothes – the guy is a fucking fool. The publication of the Pentagon Papers was a proud moment for American journalism. The Times and the Post challenged the government over critical First Amendment issues. And the press prevailed. Our government today, with the propping-up of our baby-in-chief – the jerkoff-in-chief I call him – has put the press under siege, trying to discredit it through outrageous attacks and lies.’

Here is De Niro just last week at a student writing award ceremony:

“Our country is lead by a president who believes he can make up his own truth. And we have a word for that — bull shit!  So what about the truth? What does the truth even mean today? I mean, if you’re Donald Trump it doesn’t mean anything,”

If you invite Robert De Niro, you are deliberately announcing that your event is going to be politically divisive and include an attack, probably uncivil, on the President—and while he will be engaged in crucial international negotiations. The President has nothing to do with the Tonys, nor does politics—the main contenders for top musicals are “SpongeBob” and “Mean Girls,” for heaven’s sakes—nor does De Niro, who is just one more movie star being used by Broadway to attract a larger TV audience.

2. Tales of  #MeToo. What would you do with John Lasseter? Disney just fired him, thus risking  diminished  brilliance of future Pixar projects, meaning less happiness, less enjoyment, fewer immortal film classics, and, of course, fewer profits. He was jettisoned because—I can’t believe I’m writing this—he has a habit of hugging people, it was unwelcome, and the hugging became alleged sexual harassment because it was unappreciated by some or many female employees.

Lasseter is a Disney-style genius, the creative force behind “Toy Story,” “Cars,”  “Frozen,” “Saving Nemo” and many other wonderful works of art and popular entertainment. He was the chief creative officer of Pixar Animation Studios, which he helped found, and the separate Walt Disney Animation studio.  This appears to be his problem, from the Times story:

“A self-described Peter Pan, Mr. Lasseter has long been known for his jolly public persona and tendency to greet anyone in his proximity — subordinates, stars, fans, reporters — with lengthy bear hugs. In 2011, The Wall Street Journal published a photo slide show of his frequent squeezes, saying he had handed out at least 48 of them in one day at the office.”

On one ethics hand, it certainly seems like a waste to lose a major artist over innocent hugging (if it was innocent, as some accounts maintain)  and the sexual harassment is still officially “alleged.” On the other hand, as someone who hates hugging and always has, I regard Lasseter’s “innocent” habit as something that could easily create a hostile work environment.

It is unconsented touching, pure and simple. If an employee was made to think that the only way he or she could work at Pixar, he or she had to be prepared to be hugged daily, then that’s workplace abuse. No, it’s not as abusive as what Bill Clinton, Matt Lauer, Harvey Weinstein, James Levine, Kevin Spacey or Charlie Rose subjected subordinates to, but that’s  just Rationalization #22 talking: “It’s not the worst thing.” As to the natural inclination, expressed by my wife this morning, to lament, “The man’s a genius and they are willing to lose his talents over hugging?,” there is no getting around it: that’s the King’s Pass.

I do not understand why this was not addressed before it got to this stage, unless Lasseter really has a screw loose. What could be so hard about, “John, stop hugging people at work. A lot of people don’t like it. Do it again, and you’re gone”?

In the end, Lasseter has nobody to blame but himself.

3. Krauthammer’s farewell. As you may have already read, Fox News pundit and longtime conservative columnist Charles Krauthammer penned a graceful and dignified public letter to announce that his death is imminent. He wrote,

I have been uncharacteristically silent these past 10 months. I had thought that silence would soon be coming to an end, but I’m afraid I must tell you now that fate has decided on a different course for me.

In August of last year, I underwent surgery to remove a cancerous tumor in my abdomen. That operation was thought to have been a success, but it caused a cascade of secondary complications — which I have been fighting in hospital ever since. It was a long and hard fight with many setbacks, but I was steadily, if slowly, overcoming each obstacle along the way and gradually making my way back to health.

However, recent tests have revealed that the cancer has returned. There was no sign of it as recently as a month ago, which means it is aggressive and spreading rapidly. My doctors tell me their best estimate is that I have only a few weeks left to live. This is the final verdict. My fight is over.

I wish to thank my doctors and caregivers, whose efforts have been magnificent. My dear friends, who have given me a lifetime of memories and whose support has sustained me through these difficult months. And all of my partners at The Washington Post, Fox News, and Crown Publishing.

Lastly, I thank my colleagues, my readers, and my viewers, who have made my career possible and given consequence to my life’s work. I believe that the pursuit of truth and right ideas through honest debate and rigorous argument is a noble undertaking. I am grateful to have played a small role in the conversations that have helped guide this extraordinary nation’s destiny.

I leave this life with no regrets. It was a wonderful life — full and complete with the great loves and great endeavors that make it worth living. I am sad to leave, but I leave with the knowledge that I lived the life that I intended.

Observations:

  • The final line is as ethical an attitude to aspire to at the end of one’s like as I can imagine. It is also a remarkable thing for Krauthammer to say, as someone who was put in a wheelchair permanently by an accident in his twenties.
  • “I believe that the pursuit of truth and right ideas through honest debate and rigorous argument is a noble undertaking.”  Perfectly stated.
  • The last thing I remember about Krauthammer was his commentary after the first GOP candidates debate in 2015. He was disgusted with Donald Trump, and proclaimed that his candidacy had been exposed as a fraud and “not ready for prime time.”  Trump’s hopes of winning the nomination were dead, he said—and I heartily agreed.

 

From The Ethics Alarms “These Really Are Terrible Human Beings” Files: Unethical Quote Of The Month: Bill Maher

/ Jack Marshall / 26 Comments

“One way you get rid of Trump is a crashing economy, so please bring on the recession. Sorry if that hurts people, but it’s either root for a recession or lose your democracy.”

—-HBO’s Bill Maher, on his show “Real Time”…as his audience applauded, as usual.

Did any conservative, Republican or pundit root for the nation’s failure under Obama? The closest would be Rush Limbaugh’s infamous declaration that he wanted the new President to fail, which was more unpatriotic than I could tolerate, but even Rush didn’t go so far as to wish for the nation itself to be thrown into crisis. Maher is a repulsive individual, but he is not alone. We already discussed here how many members of the media appear to be rooting for the North Korean talks to fail. Other progressives openly wish for the President’s death: I could name some right here who have told me that in person. Lawyers. Professionals. Wishing for the death of not just another human being, but the President of the United States.

The attendant hysteria, fear-mongering, monomania and values distortion that have spawned the “resistance” have also apparently created a human mutation with lethal potential. Never before have there been mainstream American citizens who not only wished ill on the nation and neighbors, but who got cheered for it. The mutants are a threat to society and to sanity. Do not pretend they aren’t.

They may not be traitors, but they think like traitors. Continue reading →

Weekend Ethics Warm-Up, 6/9/18: PART II, The Bee-Free Zone…Facebook Friends Behaving Badly, Stupid Pardon Tricks, More On The Dancing Doctor, And Another “Good Illegal Immigrant”

/ Jack Marshall / 19 Comments

Now that we have the unpleasantness of Samantha Bee out of the way, your gorge is safe. Well, sort of…

2. Short version: “Grow up!” If the long-time theater friend who just defriended me on Facebook is reading (yes, I know who you are), this is a message for all the people who can’t tolerate, or remain friends with, anyone who challenges their anti-Trump fanaticism by pointing out–nicely!– that they sound like lunatics. I know you assume that you are in the warm, comforting womb of a left-wing echo-chamber, but friends don’t let friends write stupid, or shouldn’t. You, let me remind you, stated in black and white that Al Franken was the best hope to defeat Trump in 2020 (See how nice I was? I didn’t even challenge that nonsense!) until Republicans secretly engineered his destruction. I wrote in response that this was tin foil hat stuff, which it is; that implicitly accusing Kristen Gillibrand of being in cahoots with the GOP  was bonkers, which is accurate, and that you should get help, which you should.

Your response was defriend me. Nice.

This has happened with about five theater friends, and in all cases over hysterical assertions that would be only acceptable from a 12-year-old. They, like you, are used to making ridiculous, hyper-partisan statements without being challenged, and regard a dissenting argument as a personal affront as well as the mark of Satan. You should not want to remain deluded, you should want to be called out when you write something idiotic, and you should not react with hostility to a friend who does so in good faith.

What I have learned about the resistance is that their logic, facts and debate skills are fatally flawed or absent. Their only defense against rebuttal is to censor it.

You really should not want to hang out with this crowd, my friend. Get well soon. I mean it.

And shame on you. I don’t deserve that.

3. Google is your friend, Mr. President. Yesterday, President Trump floated the idea of pardoning the late Muhammad Ali, who was famously convicted of draft-dodging during the Vietnam war. Ali, however, needs a pardon as much as I do. (Less, really, since he’s dead.) His conviction was overturned by the Supreme Court as unconstitutional. There is nothing to pardon him for.

This kind of thing is an unforced error that justifiably undermines trust in the President. It’s just inexcusably sloppy—typical, I concede, but sloppy. I don’t blame Trump for not knowing that Ali’s conviction had been reversed: I had forgotten that myself. Making impulsive statements based on flawed information and snap decisions, however, suggests that the President might take impulsive actions based on misunderstandings as well.

Well, he does that, too.

More on pardons: I have seen several news sources, including the New York Times, contrast President Trump’s political “celebrity” pardons with President Obama’s pardons of less high profile Americans. Fake news. At this point in his administration, how many pardons do you think Obama had issued?

None. Zero. Zilch. Continue reading →

Weekend Ethics Warm-Up, 6/9/18: PART I, Bee’s “Apology”

/ Jack Marshall / 18 Comments

Hi!

1  Bee gets an Eff. If I didn’t find Samantha Bee so loathsome and her transparent grab for headlines and attention by the cynical device of intentionally violating all standards of public civility and fairness, her on-air apology might warrant a full post here. “Where does it fall on the Apology Scale?,” I have been asked. She really does richly deserve to be shunned and ignored, however, not that she didn’t before. Her act is monotonous, obnoxious (Is there anything more revolting than someone who aggressively  presents themselves as smart and clever who obviously is neither?) and divisive. Like others, she exists to constantly reassure the “resistance” that they are justified in acting and talking like assholes because they lost an election.

Boy, they must need a lot of reassurance.

But since her apology on her show was an abomination (distinct from her apology on Twitter, which was a lie), I have to talk about it. What a crappy way to start a weekend. I’ll save time by commenting as we go. Yes, this is as long as a full post; it’s as long as a long full post. I know it’s silly, but even if it’s just a technicality, I refuse to give someone as contemptible as Samantha Bee more than Warm-Up status.

She said:

“You know, a lot of people were offended and angry that I used an epithet to describe the president’s daughter and adviser last week.”

In other words, “some people” were offended, not you, team member, because you LIKED me calling Ivanka a cunt, but we still have to deal with “those people,” who might be sponsors. Essentially Bee makes it clear immediately that this isn’t an apology  at all. The “you know” is a verbal shrug, and signals, “I don’t think this is a big deal, but I have to say something.”

This sentence, like the whole apology, is signature significance for a terrible human being. If she were my employee, I would stop her and say, “Start again.”

“It is a word I have used on the show many times..”

First rationalization in the second sentence! This is a subset of “Everybody does it”: “I do it all the time.”

“…hoping to reclaim it. This time, I used it as an insult. I crossed the line. I regret it and I do apologize for that. The problem is that many women have heard that word at the worst moments of their lives.”

Doubletalk. The word she used was “cunt.” It has never been anything but an ugly gutter word. What’s to “reclaim?” How it might have been used at other times is irrelevant, making this theme a flagrant act of misdirection, which is itself the theme of the whole phony “apology.” Imagine a male comic under fire for calling one of Obama’s daughters a “bitch”  saying “I have used that word many times–as a dog breeder, to describe swishy men, and in the phrase ‘son of a bitch’…” So what?

Bee’s bait-and-switch also cleverly reframes the issue. The offense was describing Ivanka Trump, on television, using a denigrating, misogynist word. Bee is now declaring that her offense was the rhetorical mistake of  misusing “cunt” as an insult. That was the line she crossed, according to her. Then: “The problem is that many women have heard that word at the worst moments of their lives.” Oh, the problem is when they heard it, not the use of the word itself.

Imagine a comic trying to weasel out of calling, say, Barack Obama a “nigger” making that argument in a parallel “apology.”

“A lot of them don’t want that word reclaimed. They want it gone, and I don’t blame them. I don’t want to inflict more pain on them.”

Wow—I hadn’t read this atrocity for a couple of days. It’s even worse than I thought.

Now Bee says the problem is that her using the word to denigrate the President’s daughter (who had done absolutely nothing to inspire such an attack) inflicted pain on other women—the good ones, you know. The ones who hate President Trump and his family.

“I want this show to be challenging and I want it to be honest, but I never intended it to hurt anyone, except Ted Cruz.”

Translation:  “You all know Ivanka IS  a cunt, but I didn’t want to hurt any other women by saying so, at least none who voted for Hillary.” Continue reading →

Wait: Does President Obama Consider THIS A Scandal? Because, You Know, It Is…

/ Jack Marshall / 11 Comments

Every time either ex-President Obama or one of his slavish acolytes—you know, journalists?—make the statement that his tenure was “scandal free,” honest Americans who have been paying attention grind their teeth down a few more millimeters.

Of course, Obama had plenty of scandals, serious ones—at least they would have been serious in any other administration. The fact that the news media chose to minimize them or ignore them doesn’t make them less scandalous…in fact, that’s a scandal itself.  To name one example that especially rankles me, the IRS, an Executive Branch Agency, eventually admitted that it used its power to meddle in the 2012 Presidential election, against Obama’s opponent. However, the formula of lying, covering up, stalling, and having allies in the press call everything negative under Obama a “nothingburger” carried the day. This was SOP for eight years.

When Obama personally lied—20 times? 30?— about how his signature health care plan would work (All together now: “If you like your plan…”), somehow this Nixon-Clinton level of intentional dishonesty was shrugged off as “the ends justify the means.” The fact is that it was a real, calculated, intentional lie used to trick the American people, not just a case of a President being wrong. Bush didn’t know that Iraq didn’t have WMD’s. Obama had to know what his own health care bill would do.

Blecchh!. I can taste the tooth powder!

This week, another genuine Obama scandal was uncovered that would have had Democrats seeking impeachment votes if it had occurred under Reagan or Bush. The Obama administration secretly gave Iran access to the U.S. financial system, defying the sanctions still in place after the 2015 nuclear deal, despite repeatedly telling Congress and the public that it would not and did not do anything of the sort.

What would you call that?

After striking its bone-headed, constitutionally-dubious nuclear deal with Iran, the Obama administration wanted to give Iran the promised access to its freshly unfrozen overseas reserves, including $5.7 billion stuck sitting in an Omani bank.  Iran wanted to convert the money into U.S. dollars and then euros, but that would require our giving the rogue nation access to the U.S. financial system. Obama officials had  promised Congress that Iran would never gain such access. As was the usual solution for Obama when law, the Constitution or established procedure stopped something he had decided in his Wisdom was Good and Just, Obama had his Treasury Department issue a license in February 2016 that would have allowed Iran to convert $5.7 billion it held at a bank in Oman into euros by exchanging them for U.S. dollars. The scheme failed, for the Omani bank blocked the transaction, but this is just moral luck, and does not make the secret end-around the sanctions less wrong.

The license issued to Iran’s Bank Muscat made lies of public statements from the Obama White House, the Treasury and the State Department denying that the administration was contemplating allowing Iran access to the U.S. financial system. After the nuclear deal was announced  in July 2015, Obama Treasury Secretary Jack Lew testified under oath—lying to Congress is still a scandal, unless Obama officials do it, and they did it a lot—that even with the sanctions relief, Iran “will continue to be denied access to the world’s largest financial and commercial market.” A month after that, another Treasury official, Adam Szubin, testified that  “Iran will be denied access to the world’s most important market and unable to deal in the world’s most important currency.”

“The Obama administration misled the American people and Congress because they were desperate to get a deal with Iran,” said Senator Rob Portman (R-Ohio).   Verdict: Fair and accurate. And what is the rebuttal by the Obama-ites?

Ooooh, lame. Lamer than usual, in fact. Continue reading →

“From The Ethics Alarms “Nah, There’s No Mainstream Media Bias!” Files: The Unethical Headline Of The Month

/ Jack Marshall / 7 Comments

Here is the headline in the print version of this New York Times story (which the Times headlines appropriately on-line):

Justice Department Acts Against Protections For People With Pre-existing Conditions

This is as pure an example of journalism deceit and a pernicious variety of fake news as I have encountered. An equivalent headline would be to describe  the ACLU petitioning to overturn a federal ban on “hate speech”  as “ACLU Acts Against Protections for Blacks, Gays and Muslims.”

The individual mandate was always unconstitutional as a penalty, and the Supreme Court was poised to overturn the Affordable Care Act on that basis, until Justice Roberts hit on the brilliant but perverse argument that even though the Obama administration and Democrats had insisted that the device wasn’t a tax in order to get the thing passed, it really was, so it was legal after all. Congress, however, repealed the “tax,” so now that pretense no longer works. The mandate is unconstitutional…again.

I know the Democratic approach to legislation and public policy is increasingly “the ends justify the means” and “the Constitution is just an archaic piece of paper,” but the fact is and has always been that the document is our nation’s (increasingly vulnerable) bulwark against tyranny, and it is the duty of the Justice Department and the courts to oppose unconstitutional, as in “illegal,” measures, even those that appear to solve difficult problems.

If a provision is unconstitutional, it doesn’t matter what benefits it may have. We cannot have a precedent that holds that the Constitution can be ignored for “good reasons.” No reason is good enough. That kind of thinking is how Japanese-Americans ended up in concentration camps under an iconic Democratic President, approved by a liberal Supreme Court.

The individual mandate, without the cover story that it is a tax, violates the Constitution. That’s all we need to know. The ability of insurance companies to cover pre-existing conditions under the ACA becomes impossible without it? Well, we’re just going to have to come up with a solution that isn’t unconstitutional, won’t we?

Deceiving the public into believing that upholding core constitutional principles is excessive and sinister when it blocks otherwise desirable policy initiatives is playing with fire. It makes the public civically ignorant. It places false emphasis on results rather than the rule of law.

It paves the road to totalitarianism.

How Does Any Administration Or Federal Agency Allow Someone This Incompetent To Represent It In Public?

/ Jack Marshall / 26 Comments

I am both puzzled and aghast, if not necessarily surprised.

From the moment candidate Trump pledged that his theoretical administration would employ “the best people,”  he has periodically shown that he or his subordinates mistake “the best people” with “mouth-breathing idiots,  fools, and irredeemable slime-balls” with disturbing regularity. There was Omarosa. There was Anthony Scaramucci. There was Steve Bannon, and pathetic Reince Priebus. There was, of course, Michael Flynn, and is Scott Pruitt. And that is before we even start thinking about Michael Cohen.

I really don’t understand this. For all his flaws…and as Lorenz Hart said in “Pal Joey”…

…one would assume that a successful businessman whose hit reality show was about hiring “the best people” would have some acumen in at least not hiring the worst people. And yet we still get examples like this…. Continue reading →

Afternoon Ethics Warm-up, 6/6/18: Special “Don’t Sue Me, These Are Just Opinions” Edition

/ Jack Marshall / 123 Comments

Good afternoon.

1. For the record...Ethics Alarms passed 9 million views this week. That’s not a lot in a bit less than 9 years by the mega-blog standards, but their aren’t many ethics blogs that do better, and maybe none. Admittedly, this is a little like being the most popular fan site for Clint Howard…

2. Now this IS a frivolous lawsuit...tomorrow I finally go to Boston to argue my motion to dismiss the vexatious defamation lawsuit against me by an Ethics Alarms commenter whose feelings I hurt in the process of throwing him off the site. If a lawyer brought this suit, I would have a rare claim against him for breaching Rule 3.1, prohibiting frivolous suits. No lawyer, however, would bring such a suit. There has to be a good faith belief that you can prevail, or change the law, but there is literally no support in the law of defamation for calling insults (yup, I insulted him), opinions, and conclusions based on fully-revealed information and data libel. Non-lawyers, however, don’t have to obey legal ethics rules, and, as in this case, don’t know what they are anywhere. Maybe after I’m through with all of this, I’ll post the whole complaint. Among its claims is that I graduated from Hampshire College, and that the Massachusetts court has jurisdiction because I’m a fan of the Boston Red Sox. I also, it claims, defamed the plaintiff by erroneously referring to him as an academic. To deal with this spiteful action, I have already expended several thousand dollars. Yes, it goes with the territory. I know.

3. Imagine, impugning the professionalism and impunity of the FBI! A drunk and irresponsible FBI agent  shot a man at a Denver bar over the weekend when his gun flew out of his pocket, hit the floor and discharged as he was executing an acrobatic maneuver on the dance floor. This, you will not be surprised to learn, is not compliant with FBI policy. Agents are considered on duty at all times. They can carry their weapon at all times too, but cannot endanger the public while doing so. They are also not permitted to act like clowns in public, or be drunk as proverbial skunks. The agent is Chase Bishop, 29, who works out of Washington D.C. No word yet if he is part of the Mueller investigation.

Conservative wag Glenn Reynold would headline this story, “Top. Men.” Maybe he already has. And if you don’t get the reference, your cultural literacy needs a tune-up. Continue reading →

A Brief #MeToo Related Note…

/ Jack Marshall / 9 Comments

“Judges have a special responsibility to promote appropriate behavior and report instances of misconduct by others, including other judges,”  states the executive summary of a report submitted to the Judicial Conference of the United States, referring to the workplace.

No, everybody has a special responsibility to promote appropriate behavior and report instances of misconduct by others—including judges, lawyers, artists, CEOs, managers, actors, journalists..all “others”) in the workplace.  Judges aren’t special. Anyone who allows a co-worker, a colleague, a superior, a manager or an officer to engage in workplace harassment without taking steps to expose it and end it is complicit in the victimization of the individuals harmed.

Someone ask Bill Clinton, who, hilariously, now says that he supports #MeToo, if he agrees with the above statement. How many people, do you think, had to fail their responsibility to promote appropriate conduct by him in the workplace, for him to obtain power and influence, and convert it to great wealth? Hundreds? Thousands? Tens of thousands? More?

Who else should we ask?

_________________________

Source: ABA Journal