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No More Trauma

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Karen Bespalov
Karen Bespalov

Cause Unknown - Ed Dowd

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Cause Unknown - Ed Dowd

That is, until you consider the illegals who are crossing over the open borders by the millions. My contention is that the DoD plans to recruit illegals to run the munitions factories, because otherwise the United States has near-zero ability to run the industrial manufacturing necessary to sustain any real war effort with Russia or China.

Mike Adams serves as the founding editor of and the lab science director of an internationally accredited (ISO 17025) analytical laboratory known as CWC Labs. There, he was awarded a Certificate of Excellence for achieving extremely high accuracy in the analysis of toxic elements in unknown water samples using ICP-MS instrumentation. Adams is also highly proficient in running liquid chromatography, ion chromatography and mass spectrometry time-of-flight analytical instrumentation. He has also achieved numerous laboratory breakthroughs in the programming of automated liquid handling robots for sample preparation and external standards prep.

The second cause of action in one sense constitutes the heart of the lawsuit brought by Kramer and Dowd, and it will for that reason be considered first. That cause of action charges that the defendants libelled the plaintiffs in an article "Ordeal at McNeil" written by Drinkhall and published by the Wall Street Journal on April 11, 1979. Briefly summarized, the article reported that Kramer and Dowd had developed and implemented an unethical plan to force Samuel Ray Calabrese, a convicted felon with reputed organized crime connections, to cooperate with the government against other alleged organized crime figures, in particular one Morris Shenker, a Las Vegas casino owner.

Defendants acknowledge that they are unable to move for summary judgment on the issues of truth and malice with respect to this cause of action, and they do not do so. Rather, their motion proceeds on the theory that the second cause of action should be dismissed because under California law[4] the publisher of allegedly libelous material must be afforded an opportunity for a retraction as a prerequisite to a defamation action an opportunity which allegedly was not afforded here.[5]

Defendants have advanced basically two reasons in support of their contention that California should be regarded as having the most compelling governmental interest with respect to "Ordeal at McNeil." In their original brief, they argued that this is so because the article was principally researched, investigated, and written in California;[8] in their reply brief, the emphasis was changed to the assertion that California law is paramount because Kramer lived and worked there prior to the publication of the articles which gave rise to this lawsuit.[9] Neither claim is persuasive.

Kramer spent twelve of the last fourteen years in Washington, D.C., and almost all of his professional ties and contacts were and are here. He received his legal education at George Washington University, and he is a member of the District of Columbia Bar.[11] Prior to his transfer to San Francisco, he had been working for many years for the U.S. Department of Justice in its Washington headquarters. The article concerned his activities while he held a position with that Department, and it was essentially his professional reputation with the Department at the seat of government that was damaged by the article. Kramer's superiors were located in the District of Columbia, and they were the persons who raised questions concerning his conduct as a consequence of the article, investigated him, and called him to account for his alleged behavior.[12] After the articles were published, Kramer was not able to remain with the Department of Justice, and he resigned. Because of his professional ties to the District of Columbia, his job opportunities were here, and he returned to and is now practicing law in Washington.

The first cause of action charges a conspiracy between Drinkhall and Calabrese to *1213 defame plaintiffs by means of "Ordeal at McNeil." The motion for summary judgment with respect to this claim is predicated upon the proposition that the evidence is not adequate to prove the existence of such a conspiracy.

Plaintiffs do not deny that their evidence in support of this cause of action does not differ materially from that which they would cite to sustain the second claim discussed in Part I supra, but they suggest that this evidence supports both their individual claims of libel against Drinkhall and Calabrese and their conspiracy claim against both of these individuals. In this regard, it is their basic contention that the origin of the libelous material was Calabrese and, in fact, they attempt to demonstrate in rather elaborate fashion that Calabrese must have been the source[19] because the information could not have come from anyone else. Not only is that factual premise to the conspiracy claim far-fetched and not established even for summary judgment purposes,[20] but there are also more fundamental obstacles to a survival of the conspiracy claim.

Although there is little, if any, law on this issue, the Court has concluded that proof of cooperation between two individuals who have a common purpose to produce a news story does not represent a sufficient basis for an actionable conspiracy. Their activities do not become actionable as a conspiracy merely because of one of the collaborators has a purpose to improve his image by spreading false information and the other a purpose to improve his opportunities *1214 for advancement by unethical practices including a reckless disregard of the truth. These purposes and the implementing actions may, to be sure, entitle the offended party to a judgment and damages for libel against each of the individuals. But with respect to a separate action for conspiracy against both, what is required in this sensitive First Amendment area[24] is proof not merely of separate and distinct improper purposes by each, proof not merely of a joint purpose to publish, but specific evidence of a joint purpose to defame.

It must also be noted that the conspiracy claim has no legitimate practical meaning in this lawsuit. Dow Jones Company, the only defendant with funds to pay a substantial judgment, is not named in that claim. Calabrese, who is named, is not likely to have the means to pay such a judgment. As for Drinkhall, it is conceded by plaintiffs that they would not be entitled to double recovery against him, that is, a recovery both on the second cause of action and on the first.[26] And proof of a conspiracy may be admitted into evidence, if otherwise relevant, whether or not it is separately charged,[27] so that plaintiffs will not be prejudiced in an evidentiary sense by a dismissal of the first cause of action. It is difficult to escape the suspicion in light of these facts that the conspiracy claim is being pressed, not for any proper litigation purpose, but in order to imply to the jury that there is a tie-in between the Wall Street Journal and Calabrese, a convicted mobster, and thus to prejudice the jury against the newspaper and its personnel. 041b061a72


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