September 12, 2007 nº 539 - Vol. 5
“Amor Fati – “Love Your Fate”, which is in fact your life.”
Friedrich Nietzsche
In today's Grammatigalhas, a law student asks: "can you give me a primer on the American legal system to help with my research?" We like to oblige!
Japanese Prime Minister Steps Down
Shinzo Abe announced Wednesday he will resign as Japanese prime minister, as his weak leadership and declining popularity made his position untenable. The decision to resign came six weeks after his Liberal Democratic Party was heavily defeated in an upper house election, and his ruling coalition lost control of that chamber, making it impossible to govern effectively. His support rating had fallen to 30%. The first hurdle was the renewal of a law allowing Japan to provide military assistance to U.S.-led forces in Afghanistan. The opposition Democratic Party of Japan said it would vote this down in the upper house, making it hard for Japan to continue the operations and play an active role in its military alliance with the U.S. But even if Abe had found a way around this, it would have been difficult to carry out other legislation he had been considering, such as farm reform and financial deregulation.
Clinton Returns Money, Sets Precedent
In returning $850,000 to donors associated with a disgraced fundraiser, Sen. Hillary Rodham Clinton sets a significant new standard for how campaigns should respond in the face of potential scandal. Clinton's decision also underscores the price - financial and political - that her campaign is paying for failing to spot trouble with the fundraiser, Norman Hsu, even after receiving a warning. The campaign announced it would now conduct background checks on its fundraisers, an extraordinary and potentially time consuming step. By returning the money, Clinton also puts pressure on presidential rivals and other politicians with rainmakers who have dubious pasts or who have employed questionable fundraising tactics, including the campaigns of Barack Obama and John Edwards. Norman Hsu, who was arrested last week on a previous felony conviction. Questions remain about how Hsu raised the money.
Union files suit against US to stop immigration raids
A lawsuit to be filed by the United Food and Commercial Workers International Union alleges that federal officials unlawfully detained workers and violated their rights during raids of six Swift & Co. meatpacking plants in December. The Union seeks an injunction to stop federal officials from conducting what the union calls illegal workplace raids.
Best practices for Brazilian lawyers in cross-border transactions
Brazilian lawyers and law firms are increasing finding themselves representing Brazilian clients involved in transactions with foreign companies or investors. This experience has undoubtedly caused many practitioners to ask what are "best practices" when providing legal advice to Brazilian clients engaged in cross-border transactions with foreign companies or investors. International lawyer Robert Eugene DiPaolo, MD of the Fidelis Group,a law firmbased in New York and São Paulo, publishes today a consequential article on delivering effective legal services in international context. You can read the English version by clicking here. A Portuguese version of the article is in preparation and will be available shortly.
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1 - Gordon Brown rejects union demands for public sector pay increases. (Read more)
2 - Tories say supermarkets should be forced to charge for parking. (Read more)
3 - Chinese inflation rise fuels interest rate fears. (Read more)
4 - Lawyers for Sir Paul McCartney and Heather Mills top list of highest-profile solicitors. (Read more)
5 - MacCann: Fund could be blocked from paying legal costs. (Read more)
6 - 9/11 attack victims honored six years later. (Read more)
7 - OPEC considers oil output rise. (Read more)
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Chinese inflation at decade high
Chinese inflation has hit its second 10-year high in two months, led again by a further sharp rise in meat prices. China's rate of consumer price inflation hit 6.5% in the year to August, up from 5.6% in July. China's central bank has raised interest rates four times already this year to try to control inflation.
At Frankfurt Motor Show, weeding out Chinese knockoffs
European automakers are taking legal action against China's carmakers, saying the Chinese are making blatant copies of models from the west. A Chinese car model, similar to the Smart Fortwo, that many had expected to see at the Frankfurt motor show is conspicuous by its absence, following legal threats from DaimlerChrysler. But another model by the same Chinese firm Shuanghuan Automobile, which is said to be similar to a BMW M5, is on show.
Paulson says U.S. legislation on China trade could threaten economy
"When we look at taking unilateral actions aimed at another nation, this can have enormous repercussions to our economic well-being," the U.S. treasury secretary said in an interview.
Legal Meaning Is Not Everyday Meaning
Common Law
Body of law based on judicial decisions and precedent that has become the basis of the legal system in Great Britain and the United States (except in Louisiana, where civil law is the legal foundation). Many of the legal concepts in use today, including the law of contracts, are derived from common law.
Stare Decisis
Latin phrase meaning "to stand by the decisions." This legal doctrine under common law requires courts to rely on precedents, or previous decisions, when deciding disputes unless there is a compelling reason to reject those precedents. In most instances, this doctrine means that courts will decide disputes over insurance contracts the same way they have decided cases with similar facts and legal issues in the past.
Case Method
A system of instruction or study of law focused upon the analysis of court opinions rather than lectures and textbooks; the predominant method of teaching in U.S. law schools today. Langdell viewed the law as a science and believed that it should be studied as a science. Law, he said, consists of certain principles or doctrines. To have such a mastery of these as to be able to apply them with constant facility and certainty to the ever-tangled skein of human affairs, is what constitutes a true lawyer; and hence to acquire that mastery should be the business of every earnest student of law.
Casebook
A printed compilation of judicial decisions illustrating the application of particular principles of a specific field of law, such as torts, that is used in legal education to teach students under the case method system.
Everyday “Legal” Jargon
The American Legal System
Sources of Law
Constitutional Law is based on a formal document that defines broad powers. Federal constitutional law originates from the U.S. constitution. State constitutional law originates from the individual state constitutions.
Statutes and Ordinances are legislation passed on the federal, state, or local levels.
Common Law is based on the concept of precedence - on how the courts have interpreted the law. Under common law, the facts of a particular case are determined and compared to previous cases having similar facts in order to reach a decision by analogy. Common law applies mostly at the state level. It originated in the 13th century when royal judges began recording their decisions and the reasoning behind the decisions.
Administrative Law - federal, state, and local level. Administrative law is made by administrative agencies that define the intent of the legislative body that passed the law.
The sources of law have both vertical and horizontal dimensions. Vertical dimensions include federal authority, state authority, and concurrent authority. Federalism refers to this form of government, in which there is national and local authority. Federal authority covers laws related to patents, pensions and profit sharing, and labor issues. State authority covers business association, contracts, and trade secrets. Concurrent authority covers security law, tax law, and employment law. Note that employment law refers to non-union relationships; labor law refers to union relationships.
The horizontal dimension is related to the separation of power between the executive branch, which creates administrative law, the legislative branch, which creates statutes, and the judicial branch, which creates common law. The judicial system in the U.S. has a pyramid structure consisting of fewer higher level courts and more lower level courts:
-- Supreme Court --
--------- Appellate Courts ---------
-------------------- Trial Courts ---------------------
Actually, there are two pyramid structures - one for federal courts and one for state courts. State courts may use different terminology; for example, trial courts may be called courts of common plea, appellate courts may be called superior courts or commonwealth courts.
Classifications of Law
Substantive law vs. procedural law: Substantive law creates, defines, and regulates legal rights and obligations. Procedural law defines the rules that are used to enforce substantive law.
Common law vs. statutory law: Common law is defined by judges. Statutory law is passed by legislatures. For example, the Securities Act of 1933 is statutory law.
Criminal law vs. civil law: Criminal law is between private parties and society. Civil law is between private parties only.
Jurisdiction
Jurisdiction is the power of a court to hear a particular case. In order for a court to have jurisdiction, it must have both subject matter jurisdiction (the power to hear the type of claim being asserted) and personal jurisdiction (power over the person).
Subject Matter Jurisdiction
Article III of the U.S. constitution states that federal courts have only certain types of subject matter jurisdiction. To satisfy subject matter jurisdiction, a federal court must have either:
1. Federal question jurisdiction - federal courts have federal question jurisdiction in cases involving the federal constitution, federal statutes, or federal treaties.
2. Diversity jurisdiction - diversity jurisdiction requires both a) $75,000 or more at issue, and b) the parties must be residents of different states. Diversity jurisdiction applies for example, to a case in which a traveler passing through a different state from his/her home state is accused of a serious offense, and in which the plaintiff, attorneys, and judge may all be close friends.
3. suit by or against the U.S. government,
4. Miscellaneous - certain types of cases such as those related to patents, bankruptcy, admirality (maritime cases), trademarks and copyrights, etc.
Items 1) and 2) can be tried in either state or federal courts (concurrent state/federal jurisdiction). Items 3) and 4) may be heard only by federal courts.
Personal Jurisdiction
Types of personal jurisdiction:
1. in personam - court has power over a particular person - in personam applies if minimum contact is established. For non-residents of a state, a state court may still have jurisdiction if the person travels regularly to the state on business or has a post office box in the state. Each state has its own definition of what constitutes doing business in the state, as determined by common law.
2. in Rem - a court has power if a particular piece of property is in the state.
3. consent - when a contract specifies in which state any disputes are settled. The contract can specify a third state in which neither party does business.
Just because a case is heard by a particular state court does not mean that that state's laws apply. The states whose laws are used can be specified in the contract. One state's court can hear a case under another state's laws.
Lifecycle of a Lawsuit
In the beginning phase of a lawsuit, there is a complaint, followed by the defendant's answer in which he or she tries to counter everything in the claim. The defendant then may file a counterclaim. Counterclaims are lawsuits within a lawsuit in which the defendant files a claim against the plaintiff. There then may be a preliminary motion, of which the outcome can be dismissal due to no legal claim based on reading the complaint, or a summary judgment in which a decision can be based on the facts of the case that are not in dispute.
The middle phase of a lawsuit is the discovery phase, in which each side attempts to determine how strong their case is. The discovery phase consists of interrogatories, depositions, and admissions. By this point, most cases are settled.
The end phase of a lawsuit is the trial, beginning with a pre-trial conference in which the parties attempt to settle in front of a judge without going to court. The trial then proceeds with the evidence and then a judgment and possibly a post-judgment. The post-judgment may be that a new trial is necessary, such as in cases of mistrial.
The defendant usually has the right to one appeal within a certain period of time. An appeal is filed with the appellate court, there are briefs, oral arguments, and then a decision.
The judgment is enforced by first obtaining an execution that freezes the defendant's assets. The defendant is served and the assets are levied. The defendant, however, may choose to file for bankruptcy protection, in which case all creditors are stopped, including court judgments.
Remedies
There are two types of remedies: legal and equitable. Legal remedies are money-based and seek to financially compensate one for the damage that has occurred. Equitable remedies require a specific performance. Examples of equitable remedies are injunctions, restitution, and reformation. In cases where damages are difficult to quantify, equitable remedies may be more appropriate.
Legal Case Study
When attempting to understand how courts interpret the law, it is worthwhile to study past cases of similar legal issues. Past legal cases provide the opportunity to understand the law by studying well-argued positions from both sides. When studying a case, the following points should be identified:
Facts. One should identify which facts are important and which are not.
Issue. One should isolate the specific legal issue relevant to the case.
Court holding (ruling)
Reasoning (why the court decided as it did).
As If Your Life Depended On It… or How to get to Carnegie Hall? - Practice, practice
Spill the beans
Reveal information or a secret. An Americanism that may come from bean as US slang for 'head' (spill or let slip what is in one's head). More likely it comes from ‘know one's beans’ (know what's what); this is clearly related to the early 17th century English saying ‘know how many beans make five’, which has the same meaning. It is a short step from knowing one's beans to spilling them, i.e. telling what one knows.
Spoil the ship for a ha'porth of tar
Spoil something by economizing on a small detail. This was originally, from at least 1600, 'lose the sheep [often 'hog'] for a half-pennyworth of tar' - i.e. let the animal die for want of spending a trivial sum on tar to protect its sores or wounds from infection by flies. 'Ship' was the dialect pronunciation of 'sheep' over much of England, and non-country folk obviously assumed that the expression referred to a ship, the assumption being reinforced by the reference to tar, which was widely used on wooden ships to coat and preserve the timbers. To complete this transformation of a rustic expression into a nautical-sounding one, the rather extravagant and unconvincing idea of 'losing' an entire ship for the sale of a small economy was changed to 'spoiling' and the now familiar version emerged in the mid-19th century.
A person who is tarred with the same brush has the same faults as someone else being referred to. It is probable that this image also comes from the application of tar to animals, either for the purpose already described or to mark them out as members of the same flock.
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Menem proceso
Un juez argentino volvió a procesar al ex presidente Carlos Menem por su presunta responsabilidad en la venta ilegal de armas a Ecuador y Croacia durante su gobierno en la década de los años 90. El magistraod Rafael Caputo decidió embargar los bienes del ex mandatario por más de US$ 110 mlls.
China – Colombia
El ministro de Comercio, Industria y Turismo, Luis Guillermo Plata, emprendió gestiones en el gigante asiático, para agilizar la firma del Acuerdo de Promoción y Protección Recíproca de Inversiones y un protocolo fitosanitario y de sanidad animal que permita potenciar las exportaciones de productos agropecuarios colombianos al país oriental.
TLC
El Comité de Finanzas del Senado de EEUU inició este martes el debate del tratado de libre comercio con Lima. Su Presidente dijo que los objetivos laborales han sido logrados. Colombia aguarda su turno. Será después que Perú alcance u acuerdo.
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US marks sixth 9/11 anniversary
Americans have held a series of solemn ceremonies to mark six years since the 11 September 2001 attacks on the US. Church bells tolled at 0846 local time to mark the moment when the first Trade Center tower was hit. A new message purported to be from Bin Laden has been released to coincide with the anniversary. It is the sixth video released by al-Qaeda featuring the hijackers. Bush is to announce troop reductions in Iraq in a speech later this week, the White House says.
Estrada gets life for corruption
Philippine ex-leader Joseph Estrada is convicted and jailed for life for embezzling $80m while in office.
Five guilty in Chicago mob trial
A US jury has found four mobsters and an ex-policeman guilty of a criminal conspiracy that involved years of extortion and murder. The verdict in a Chicago court came at the end of what was billed as the biggest organized crime trial in years. The jury heard about 18 gangland murders, including two killings later depicted in the 1995 movie Casino.
EU gives up on 'metric Britain'
European Union commissioners have ruled that Britain can carry on using imperial measurements such as pints, pounds and miles. It follows years of wrangling between London and Brussels over metrication.
Dollar at record low against euro
The US dollar falls to a record against the euro ($1.388) as investors bet that interest rates will be cut next week.
Brazil bans imports from Mattel toys because of worldwide recalls
Brazil said Tuesday it has banned imports from toy maker Mattel Inc. until the government can evaluate whether the American company is fully abiding by local safety regulations. The decision went into effect Aug. 17, following Mattel's announcement it was recalling millions of Chinese-made toys over worries they were tainted with lead paint. The government only made its ruling public Tuesday in a statement on the Trade and Development Ministry's Web site.
Petrobras to invest US$4.9 billion in United States
Petrobras said Monday it will invest US$4.9 billion in the United States from 2008 to 2012, a third of its budget for overseas investments. Petrobras will continue to focus on the U.S. side of the Gulf of Mexico, Latin America and West Africa. The company will spend US$15 billion overseas out of the US$112 billion it has earmarked for investments in 2008 to 2012.
Lewis buys 7% Bear Stearns stake
Billionaire British investor Joseph Lewis has spent about $860m buying a 7% stake in struggling US investment bank Bear Stearns. The move is seen as a major boost for Bear Stearns, which has been one of the firms most affected by the crisis in the US sub-prime mortgage sector. Bear Stearns had to spend $1.6bn in June to bail out two of its funds exposed to sub-prime defaults. The firm's then co-president Warren Spector resigned at the time.
Texan 'gave millions to Saddam'
A Texan oil billionaire has gone on trial in the US accused of paying millions of dollars in kickbacks to Saddam Hussein's government. Oscar Wyatt, 83, is said to have given the money to Baghdad officials to illegally buy extra Iraqi oil under the United Nations' oil-for-food program. This scheme ran from 1996 to 2003 and allowed Iraq to finance humanitarian goods purchases through sales of oil.
Time magazine to appeal $106M damages award in Suharto defamation suit
Time magazine announced Tuesday that it plans to appeal an August 30 decision by the Supreme Court of Indonesia awarding former Indonesian President Haji Mohammad Suharto $106 million in damages in Suharto’s defamation suit against the publication. Suharto sued Time over a 1999 article that said Suharto had hidden billions of dollars in foreign banks. The Supreme Court overturned two lower court decisions against Suharto, ordering Time to pay damages and publish a formal apology in Indonesian newspapers and its own magazine. A lawyer for the magazine said that Time stands by the months of research conducted for the story, and that it will "take any legal measures available to defend freedom of the press." No further details of the appeal were given.
EU says Serbia deal dependant on cooperation with war crimes tribunal
The European Union said Monday that it will only sign a new pre-membership aid and economic deal with Serbia when that country has demonstrated its cooperation with the International Criminal Tribunal for the former Yugoslavia (ICTY) . Carla Del Ponte , the ICTY chief prosecutor, will submit a report in the next few weeks to the EU suggesting whether she believes Serbia is fully cooperating with the ICTY. Del Ponte has discouraged agreements between Serbia and the EU before based on Serbia's lack of progress in the capture and arrest of war crimes fugitive Ratko Mladic . Previous negotiations were put on hold for more than 13 months after Del Ponte determined Belgrade was not actively pursuing wanted fugitives.
Wiretaps 'foiled terror attacks'
The US director of intelligence has said wiretaps played a significant role in stopping bomb attacks by suspected Islamists in Germany last week. Michael McConnell told a Senate committee eavesdropping had revealed that the suspects had obtained explosive liquids.
He said Congress should not restrict the program.
Brazilian city begins implanting microchips in pit bulls to track them
Belo Horizonte, the capital of Minas Gerais state, has begun implanting microchips in pit bulls in an effort to track the dogs and punish the owners of pets involved in attacks.
Bolivia to require visas for U.S. tourists Dec. 1
Bolivia announced Tuesday it will require visas for U.S. tourists beginning Dec. 1, following through on a pledge to treat Americans much like they treat Bolivians entering the United States.
Federal judge tosses out NYC calorie posting rule for restaurants
A federal judge struck down a New York City rule Tuesday that required fast-food restaurants to post calorie counts on their menus, but he suggested that expanding the rule to include more restaurants could make it legal.
Extension of Microsoft antitrust pact requested
In an eleventh-hour request, a group of six states and the District yesterday asked a judge to extend the terms of Microsoft's antitrust settlement through 2012. Most of those provisions are scheduled to expire in November. Microsoft continues to have a stronghold on the two products, Windows and Internet Explorer, that almost all consumers use for accessing these Web services and applications,
Why Indians fight modernization
Recent attacks on Indian-owned and operated retail stores in several Indian states suggest that many Indians object as much to modernization as to globalization. As with the stymied Indo-America civilian nuclear cooperation agreement, the problem is more psychological than political. It has been dinned into Indians for decades that businessmen are crooked, that the generation of wealth is evil and that foreigners are out to loot and pillage the country. The mythology of the recent past painted the United States as the sinister "foreign hand" behind India's social, political and economic troubles. Salvation lay in socialism, virtuous austerity and nonalignment. That is why Prime Minister Manmohan Singh has been forced to put on hold the nuclear deal he reached with Bush. A former American ambassador to India, William Saxbe, put it into words in the 1970s: "When I call on cabinet ministers, the president, or governors, they all love to talk about their sons, sons-in-law and daughters in the U.S. and how well they're doing and how well they like things. The next day I read in the papers the very same people are denouncing the U.S. as a totally different kind of country."
Unmarried fathers in Ireland gain parental rights in landmark ruling
An unmarried father of twin boys must have his children returned to his custody from England, a Dublin judge ruled Tuesday in a landmark judgment for the parental rights of unmarried men.
Ethiopia rings in new Millennium
BBC News, Centrist newscaster, London, England
UN blue helmets help Congolese soldiers and families escape latest fighting
CongoPlanet.com, Independent online news aggregator
Opinion: A Ghanian take on homosexuality
GhanaWeb, Online news portal, Amsterdam, Netherlands
Uganda: Army Abuses Civilians in Plan to Secure Karamoja
Human Rights Watch (Africa), International news press releases
Fossett search party turns to Google
iafrica, Online news portal, Cape Town, South Africa
Body of missing man found in latrine
Independent Online, News portal, Cape Town, South Africa
Provinces spend millions on strike recovery
Mail & Guardian Online, Liberal, Johannesburg, South Africa
Journo hit on head, strangled
News24.com, Online news portal, Cape Town, South Africa
Wipro to open New Global Development Centre in Mexico
Brazil Sun, Independent online news aggregator
Who Dem responds to Chuck Fender Bahamas kidnap attempt
Caribbean News Portal, Online news aggregator
Brazil: Report on Past Atrocities a Key Step Forward
Human Rights Watch (Americas), International news press releases
El Salvador: Closing of Dumps Necessary But Not Sufficient
IPS Latin America, International cooperative of journalists, Rome, Italy
Golden hour - Bruce takes office in Jamaica today
Jamaica Gleaner, Independent daily, Kingston, Jamaica
Peru: Congressman Proposes to Suspend Safety and Emissions Inspections
Living in Peru, News portal, Lima, Peru
Historically speaking, the census represents us
The Globe and Mail, Centrist daily, Toronto, Canada
Canadians remember 9/11
Toronto Star, Liberal daily, Toronto, Canada
Some 121 hot spots detected in South Kalimantan
Antara News, News agency, Jakarta, Indonesia
9/11 Panel Chairmen Say U.S. Safer, But 'Not Safe Enough'
Chosun Ilbo, Conservative daily, Seoul, South Korea
Thai police deny arrest of 'KP'
India Express, News portal, Mumbai, India
Delhi cops continue to nag Khurana
India Times, Conservative daily, New Delhi, India
Living with the 'Sea of Japan'
Japan Times, Independent centrist, Tokyo, Japan
10.7p.c. or projects under 9MP have been completed
Malaysian Star, Online news portal, Selangor Darul Ehsan, Malaysia
Japan's PM tells coalition he will resign
New Zealand Herald, Conservative daily, Auckland, New Zealand
Indian state sacks 6,500 police constables
People's Daily Online, English-language, Beijing, China
Bec 'devastated' by orphanage claims
Sydney Morning Herald, Centrist daily, Sydney, Australia
UPA-Left panel to hold talks on implications of Hyde Act
The Hindu, Left-leaning daily, Chennai, India
Police 'too afraid of criticism'
BBC News, Centrist newscaster, London, England
Zambezi set for Arc prep
BreakingNews.ie, Online news portal, Cork, Ireland
Madeleine: Police seek special powers to seize 'mystery object'
Daily Mail, Conservative daily, London, England
Dutch newspaper selects SPSS predictive analytics solution
DMeurope, Online news portal, Amsterdam, Netherlands
Ellie Lawrenson's gran not guilty of manslaughter
icLiverpool, Online news portal, Liverpool, England
Turkish police find van packed with explosives
International Herald Tribune, Independent daily, Paris, France
New Czech novel inspired by story of paratroopers who eliminated Heydrich
Radio Prague, Online news portal, Prague, Czech Republic
Prosecutor Wants 'Mystery Object'
Sky News, Independent newscaster, Middlesex, England
Berlin Zookeeper Rumbles Crafty Cub: Knut Feigning Sore Paw to Get Attention
Spiegel International, Liberal newsmagazine, Hamburg, Germany
Bush poised to announce limited Iraq troop pullout
The Guardian, Liberal daily, London, England
China can ease market turmoil - WB
The Irish Times, Centrist daily, Dublin, Ireland
Comedian Jon Stewart to host Oscars
The Scotsman, Moderate daily, Edinburgh, Scotland
8m win after dad loses job
The Sun, Conservative tabloid, London, England
Bomb scare at Savoy Hotel was hoax
The Telegraph, Conservative daily, London, England
General gets rough ride as senators fight for high ground over election
Times Online, Conservative daily, London, England
Peres Can't Understand Why Arabs Attack Jews
Arutz Sheva, Online, right-wing, Tel Aviv, Israel
Turkish Police Foil Bombing in Capital
Asharq Al-Awsat, Pan-Arab daily, London, England
Australia's Howard stays on as party chief
Gulf News, Independent daily, Dubai, United Arab Emirates
N. Korea condemns Israel for invading Syrian airspace
Haaretz, Liberal daily, Tel Aviv, Israel
Bridging the Shia-Sunni Divide With Free Trade
IPS Middle East, International cooperative of journalists, Rome, Italy
Galfar IPO raises over $2 billion
Middle East North African Network, Online financial portal, Amman, Jordan
U.S. and Bin Laden Mark Sixth Anniversary of Sept. Attacks
Nahamet, Online news portal, Beirut, Lebanon
Israel hit Syria with 'quick strike' - US official
The Daily Star, Independent daily, Beirut, Lebanon
Female activists threaten to boycott coming elections
Yemen Times, Independent weekly, Sana'a, Yemen
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The messages that appear in this newsletter are for informational purposes only. They are not intended to be and should not be considered legal advice nor substitute for obtaining legal advice from competent, independent, legal counsel in the relevant jurisdiction.
Transmission of this information is not intended to create, and receipt does not constitute, an attorney-client relationship. The information contained on this list may or may not reflect the most current legal development.