Subject: RE: Fulani and Tax Financed Campaigns
From: "Trevor Potter" <TP@Capdale.com>
Date: 4/19/2006, 8:34 AM
To: "Bauer, Bob \(Perkins Coie\)" <RBauer@perkinscoie.com>, "Smith, Brad" <BSmith@law.capital.edu>, election-law@majordomo.lls.edu

<x-charset utf-8>
We seem to be ships passing in the night on this one. I am suggesting that decisions on funding of the Presidential campaign system be held to the same standards as every other funding decision, and not be singled out for "check-off " treatment. Congress adopted the current system by majority vote, and there have been unsuccesful legislative attempts over the years to change it. Congress can already be held accountable for these votes. I don't know what percentage of the population supports foreign aid, or all sorts of other programs, because we don't have an annual referendum on them on our tax forms. I believe uniquely subjecting the Presidential public funding system to this check off approach was a design flaw in the system Congress adopted.
 
The concern Bob raises with majoritarian line and rule drawing is a serious one for a democracy, and why I have generally worked for non-partisan or independent decision makers in the context of state election officers and, more recently, redistricting. See www.campaignlegalcenter.org/attachments/1460.pdf (need for independent redistricting commissions). I think the same arguments apply to the FEC, which should be comprised not of partisan appointees representing their political backers, but of persons as independent as possible from partisan interests. However, my recollection is that Bob has generally disfavored such approaches, arguing that is it wrong, and perhaps impossible, to take politics out of these processes.
 
 
-----Original Message----- 
From: Bauer, Bob (Perkins Coie) [mailto:RBauer@perkinscoie.com] 
Sent: Wed 4/19/2006 11:12 AM 
To: Trevor Potter; Smith, Brad; election-law@majordomo.lls.edu 
Cc: 
Subject: RE: Fulani and Tax Financed Campaigns



	It seemsto me, Trevor, that you are not addressing the question I
	raised: are some rules different from others, in that we would expect
	those fundamental to electoral choice to be determined with broader,
	clearer public support. When Congress approves NEA funding, it must at
	least answer to the public: and if a majority in the Congress support
	this funding, then it presumably reflects some sort of majority
	judgment.  Here, however, we have some 9% of the population electing to
	participate in--and by doing so, to perpetuate--a program with
	signficant impact on the election of our national leaders, with the
	other 90% declining to support it.
	
	A variant of the disinclination to see these rules as a class apart is
	the current state of campaign finance legislation, in which one party
	rams it down the throat of the other.  51% is enough to change the
	decisional rules, and, it now appears, with some frequency.
	
	Over time, sooner rather than later, this will erode the credibility of
	this kind of lawmaking.  It is acceptable for many kinds of decisions:
	it is not clear at all that it will be so for this kind. Many will find
	that this state of affairs goes well beyond the limits of the principle:
	"to the winner, goes the spoils."
	
	-----Original Message-----
	From: Trevor Potter [mailto:TP@Capdale.com]
	Sent: Wednesday, April 19, 2006 11:01 AM
	To: Bauer, Bob (Perkins Coie); Smith, Brad;
	election-law@majordomo.lls.edu
	Subject: RE: Fulani and Tax Financed Campaigns
	
	
	
	Two quick responses to Bob's comments: if the proposal for a referendum
	system on government spending is a valid one, then why should it not
	apply to other budget items? I'd like to see a minimum percentage of
	popular support for a whole range of government spending decisions. No
	doubt my list will differ from Bob's, but it shouldn't be too difficult
	to design a tax form that catagorizes programs to check levels of
	popular support. Insufficient support for....Iraq; Amtrack; sugar
	subsidies, the NEA, ...no funding. Direct democracy at work!
	
	My point is not that such a sytem would be workable or desirable, of
	course, but rather that it is unfair to cite low check off levels as
	proof determinative that the public funding system should be ended,
	given that is not the test we apply to any other public funding
	decision.
	
	Second, my description of taxpayers as "frazzled" comes from purely
	personal experience--I'm glad Bob has a cool, calm, cheerful frame of
	mind when completing his tax returns, but frazzled certainly better
	describes my temperment this year....maybe even others.
	
	Trevor Potter
	
	
	
	        -----Original Message-----
	        From: Bauer, Bob (Perkins Coie) [mailto:RBauer@perkinscoie.com]
	        Sent: Wed 4/19/2006 10:42 AM
	        To: Trevor Potter; Smith, Brad; election-law@majordomo.lls.edu
	        Cc:
	        Subject: RE: Fulani and Tax Financed Campaigns
	       
	       
	
	
	
	        I am splicing my comment into this point in the string, because
	I am
	        quite struck by the suggestion that the taxpayers annually put
	to this
	        choice are "frazzled."  The suggestion Trevor makes, as I see
	it, is
	        that they are too harried to make the choice reflectively or
	        sensibly--even though this is likely the least of their hard
	decisions
	        or stresses in making out a return.  And this suggestion seems
	to borden
	        on an argument, often heard from the reform side of the
	regulatory
	        debate, that those who make the rules understand their benefits
	better
	        than those subject to the rules. Where the rules are ones
	controlling
	        political choice--determining how elections are funded--this is
	a
	        disconcerting view of how such rules should be made. Rules of
	this kind
	        are entirely different in character from other legislative
	choices that
	        may indeed support forms of speech and activity offensive to
	some--as in
	        Trevor's example of the cost of financing Air Force One,
	incurred to
	        enable the President to give speeches that some might disagree
	with.
	        Yes, they might disagree with those speeches, but the law
	providing the
	        money for plane is rather different in nature from the law
	providing
	        money for the very election of its First Passenger.
	       
	       
	        Brad Smith is right that money is money, and so even if the
	money is
	        only provided by those choosing to check it off, it is then used
	by the
	        Government with major consequences for the conduct of
	Presidential
	        politics affecting the 91% who did not wish to check-off dollars
	for
	        this "system".  So it cannot be said that this is a purely
	"voluntary"
	        program: it is not at all "voluntary" to the extent that once
	the money
	        is received, even from a small percentage of the population, it
	is used
	        to influence strategic choices and other aspects of the
	campaigns in
	        which the entire citizenry has a stake.
	       
	       
	        A simple amendment, recognizing this fact and putting the
	program to the
	        test, would be this: providing that the money will not be spent
	if less
	        than a specified percentage of the population participates.
	This would
	        take into account widespread refusal to fund the program.  The
	money, if
	        not used, could be returned to the taxpayers.
	       
	       
	       
	       
	       
	        -----Original Message-----
	        From: owner-election-law_gl@majordomo.lls.edu
	        [mailto:owner-election-law_gl@majordomo.lls.edu] On Behalf Of
	Trevor
	        Potter
	        Sent: Tuesday, April 18, 2006 11:04 PM
	        To: Smith, Brad; election-law@majordomo.lls.edu
	        Subject: RE: Fulani and Tax Financed Campaigns
	       
	       
	       
	        Polls also show that "most americans" believe foreign aid is a
	waste of
	        money too-but we don't hold an annual referendum on it. One can
	easily
	        draw the conclusion that the mistake here is not funding
	Presidential
	        campaigns, but rather putting that spending decision--and no
	other-up to
	        a check-off poll by frazzled taxpayers every year. If it is
	worth doing,
	        then it is worth funding the same way we fund other government
	spending,
	        much of which our elected representatives believe is worth doing
	even
	        though it might not survive a direct popula vote.
	        Trevor potter
	       
	         -----Original Message-----
	        From:   Smith, Brad [mailto:BSmith@law.capital.edu]
	        Sent:   Tue Apr 18 22:57:49 2006
	        To:     election-law@majordomo.lls.edu
	        Subject:        RE: Fulani and Tax Financed Campaigns
	       
	        It doesn't.  This is not some all or nothing matter.  People can
	and
	        should make distinctions and defend the programs that they want
	        government to spend money on.  Most Americans - if we believe
	the polls,
	        and if we put any stock in the fact that most Americans do not
	choose to
	        earmark funds to the presidential fund - do not favor this
	subsidy.  One
	        reason may be that they don't think their dollars should go to
	fund
	        certain views.  And Trevor is quite right - that is also a
	reason many
	        Americans oppose many other government subsidies.   Trevor
	totally
	        misses the point - to take his argument seriously would mean
	that no one
	        can object to any of the items Trevor raises below - and
	countless
	        others - so long as we fund campaigns with tax money.  If that's
	the
	        argument for tax financing - that there is someone somewhere who
	objects
	        to everything on which the government spends money (at least if
	it can
	        be called speech) - well, what more needs to be said?
	       
	        Look, this isn't some difficult, all-encompassing theory, as
	Eugene and
	        Trevor seem to want to make it.  This is a simple argument - we
	have
	        better things to spend money on.  Again, most Americans seem to
	agree
	        with this practical, common-sense, good government argument.
	       
	        Bradley A. Smith
	        Professor of Law
	        Capital University Law School
	        Columbus, OH
	       
	        ________________________________
	       
	        From: owner-election-law_gl@majordomo.lls.edu on behalf of
	Trevor Potter
	        Sent: Tue 4/18/2006 7:51 PM
	        To: Volokh, Eugene; election-law@majordomo.lls.edu
	        Subject: RE: Fulani and Tax Financed Campaigns
	       
	       
	       
	       
	        Brad says:
	       
	        "Given that this leads to funding for many candidates that
	Americans
	        think ought not
	        > be funded by government ....the question is whether or not tax
	funding
	        of
	        > campaigns is good policy and a good use of tax dollars."
	       
	        Isn't this argument equally true of the zillion other ways that
	        government spends money that some individual taxpayers think it
	should
	        not?  NEA funding of performance art, or academic research into
	writings
	        about human sexuality, or funding for religious institutions for
	        abstinence teaching, or the President's travels on Air Force One
	to give
	        campaign speeches: all of these are government funded speech
	        controversial to some. Surely there are endless examples of the
	        government funding speech which someone would find an
	objectionable use
	        of his or her tax dollars--how does the Presidential funding
	system
	        differ substantively from those?
	       
	        Trevor Potter
	       
	        -----Original Message-----
	        From: owner-election-law_gl@majordomo.lls.edu
	        [mailto:owner-election-law_gl@majordomo.lls.edu] On Behalf Of
	Volokh,
	        Eugene
	        Sent: Tuesday, April 18, 2006 7:14 PM
	        To: election-law@majordomo.lls.edu
	        Subject: RE: Fulani and Tax Financed Campaigns
	       
	       
	                I think there's much to Brad's argument, but let me
	press him a
	        bit on this.  The income tax deductions given for contributions
	to
	        501(c)(3) organizations (as well as other tax exemptions for
	nonprofits)
	        are -- from an economic perspective, and often from a
	constitutional
	        perspective -- tantamount to subsidies; through them the
	taxpayers
	        subsidize a wide range of speakers and actors, including many
	that
	        express views we disagree with.  Lenora Fulani could set up a
	501(c)(3)
	        to convey harsh, even anti-Semitic, criticisms of Israel, and
	our tax
	        money would essentially help subsidize it.
	       
	                Likewise, the media mail postage rate (and the old
	second-class
	        rate) is, I think, something of a subsidy.  So are university
	funding
	        programs for student groups (see Rosenberger).  So are school
	choice
	        programs in which the funds can be used at a wide range of
	schools,
	        including ones that teach opinions that many disagree with.
	       
	                To what extent should the possibility that some users of
	funds
	        -- some 501(c)(3)'s, some media mailers, some student groups,
	some
	        schools that get school choice funds -- will use them to spread
	        reprehensible ideas lead us to reject the entire funding
	program?  The
	        argument is actually often made as to school choice programs
	("If we
	        have school choice funding, some jihadist or KKK or Nation of
	Islam
	        school could use taxpayer money to teach their awful views to
	        children"); I find it unpersuasive there, especially if it seems
	likely
	        that only a tiny fraction of the beneficiaries will express such
	        far-outside-the-mainstream views.  It could equally well be made
	against
	        the charitable tax exemption (at least as applied to educational
	        organizations), against the media mailing privileges, against
	funding of
	        student groups, and so on.  Are we persuaded by such arguments
	there? If
	        not, then why should we persuaded by them as to taxpayer
	financing of
	        campaigns?
	       
	                Eugene
	       
	        > -----Original Message-----
	        > From: owner-election-law_gl@majordomo.lls.edu
	        > [mailto:owner-election-law_gl@majordomo.lls.edu] On Behalf Of
	        > Smith, Brad
	        > Sent: Tuesday, April 18, 2006 2:55 PM
	        > To: election-law@majordomo.lls.edu
	        > Subject: RE: Fulani and Tax Financed Campaigns
	        >
	        >
	        > It seems to me that people have totally missed any point of
	        > my article if they think I was suggesting that Lenora Fulani
	        > should be disqualified from federal funds for her
	        > anti-Semitic remarks (Michael Richardson's comments aside, I
	        > don't know how else one would describe them), or that it at
	        > all matters if she made these comments in the context of
	        > running for president or not.
	        >
	        > Fulani met the legal requirements for funds, and should get
	        > them.  There is no point at which the government should
	        > discriminate in tax funding campaigns on the basis of the
	        > candidate's views, articulated or not.  Given that this leads
	        > to funding for many candidates that Americans think ought not
	        > be funded by government (and given many other problems with
	        > tax funding, including the view of many that it doesn't
	        > seriously address either the equality or the corruption
	        > problem, especially as the latter is defined in Austin and
	        > McConnell), the question is whether or not tax funding of
	        > campaigns is good policy and a good use of tax dollars.  My
	        > guess is that most academics think yes; polling data
	        > indicates that most Americans think no.
	        >
	        > Bradley A. Smith
	        > Professor of Law
	        > Capital University
	        > Columbus, OH
	        >
	        >
	        > ________________________________
	        >
	        > From: owner-election-law_gl@majordomo.lls.edu on behalf of
	        > Bryan Mercurio
	        > Sent: Tue 4/18/2006 3:37 PM
	        > To: election-law@majordomo.lls.edu
	        > Subject: RE: Brad Smith column is inaccurate
	        >
	        >
	        >
	        >
	        > Hear Hear.
	        >
	        > Getting back to the initial point though, my question would
	        > be what if the person may have made such statement in the
	        > past and later disavowed themselves of that position (for
	        > instance, KKK, Neo-Nazi, bigot, etc)? The point being, I
	        > suppose, is where do you draw the line when prohibited
	        > certain persons from receiving federal funds. Seems like a
	        > fine line, and one which can be manipulated or abused.
	        >
	        > Bryan
	        >
	        >
	        >
	        >
	        >
	        > -----Original Message-----
	        > From: owner-election-law_gl@majordomo.lls.edu on behalf of
	        > Volokh, Eugene
	        > Sent: Tue 4/18/2006 2:05 PM
	        > To: election-law@majordomo.lls.edu
	        > Subject: RE: Brad Smith column is inaccurate
	        >
	        >         Well, when a country that is the most democratic in
	        > the Middle East, and that provides some of the strongest
	        > (albeit imperfect) protections for ethnic minorities of any
	        > country in the Middle East, is singled out for accusation as
	        > "mass murderers" -- when none of the neighboring countries
	        > that have engaged in comparable or greater killing or
	        > oppression of minority group members are -- one wonders
	        > whether the objection is just because of the country's
	        > alleged sins, or because the sinners are Jews rather than
	Arabs.
	        >
	        >         Eugene
	        >
	        > > -----Original Message-----
	        > > From: owner-election-law_gl@majordomo.lls.edu
	        > > [mailto:owner-election-law_gl@majordomo.lls.edu] On Behalf
	Of Bryan
	        > > Mercurio
	        > > Sent: Tuesday, April 18, 2006 7:22 AM
	        > > To: Michael Richardson; election-law@majordomo.lls.edu
	        > > Subject: RE: Brad Smith column is inaccurate
	        > >
	        > >
	        > > Michael, the comments are still offensive and not becoming a
	        > > politician or any upstanding member of society. I think you
	fail to
	        > > understand the close association between Israel and the
	        > Jewish faith.
	        > >
	        > > Fulani went far beyond merely expressing 'distaste' for the
	Israeli
	        > > military and any post-comment rationalisation does not
	change the
	        > > meaning of the words/statement.
	        > >
	        > > This still does not answer your first question, which I do
	think is
	        > > interesting.
	        > >
	        > > Bryan Mercurio
	        > >
	        > >
	        > > -----Original Message-----
	        > > From: owner-election-law_gl@majordomo.lls.edu on behalf of
	Michael
	        > > Richardson
	        > > Sent: Tue 4/18/2006 9:17 AM
	        > > To: VOLOKH@law.ucla.edu; election-law@majordomo.lls.edu
	        > > Subject: RE: Brad Smith column is inaccurate
	        > >
	        > > Greetings!
	        > >
	        > >
	        > >
	        > > My appreciation to Eugene Volokh for his sleuthing on the
	        > context of
	        > > the sentence fragment that hangs like a cloud over the
	electoral
	        > > efforts of Lenora Fulani.  Professor Hasen will probably
	        > have to pull
	        > > the plug on this discussion thread as the "near urban myth
	        > status" of
	        > > the fragment makes this a never-ending story.  However, I
	will take
	        > > one last bite at the apple and risk getting tarred with the
	        > brush used
	        > > on Fulani.
	        > >
	        > > 1)  No one has responded to my observation that the disputed
	        > > commentary was outside the scope of a political campaign
	        > and outside a
	        > > federally funded election contest which is where the
	immediate
	        > > discussion began.
	        > >
	        > > 2)  Now that we know the context for the sentence fragment
	        > was a play
	        > > review, by Fulani, of a play about Zionism written and
	        > produced by her
	        > > Jewish mentor Fred Newman I believe the anti-semitic charge
	fails.
	        > >
	        > > 3) The "sell their souls" comment, in the context of a play
	        > review is
	        > > not an extreme statement but represents the poetic license
	        > often found
	        > > in performance reviews by many reviewers.
	        > >
	        > > 4)  The "to function as mass murders of people of color"
	comment is
	        > > not directed at people of Jewish faith, as the sentence
	fragment so
	        > > often quoted would lead one to believe. Rather, if you
	examine the
	        > > construction of the full sentence, it is a commentary on
	        > the actions
	        > > of a country, Israel.  In other words, political commentary
	on a
	        > > nation-state.
	        > >
	        > > One may not agree with Fulani's distaste for Israeli
	militarism but
	        > > the charge of "anti-semitism" is overreaching.
	        > >
	        > > Michael Richardson
	        > >
	        > >
	        > >       ________________________________
	        > >
	        > >       From: "Volokh, Eugene" <VOLOKH@law.ucla.edu>
	        > >       To: <election-law@majordomo.lls.edu>
	        > >       Subject: RE: Brad Smith column is inaccurate
	        > >       Date: Mon, 17 Apr 2006 15:10:10 -0700
	        > >
	       
	        > >
	       
	        > >           I'm a big believer in trying to slay urban myths,
	but
	        > > shouldn't the labeling as an "urban myth" or as a "near
	urban myth"
	        > > follow discovery of the context, rather than preceding it?
	        > > 
	       
	        > >           Here is the best source I could find, based on a
	quick
	        > > google search, though I'd love to see more, of course. It's
	        > a column
	        > > by Ed Koch, and it purports to quote a response he got from
	Lenora
	        > > Fulani on this very point; unless Koch is misquoting
	Fulani's
	        > > response, the response does not seem particularly
	exculpatory.
	        > > 
	       
	        > > 
	       
	        > > 
	       
	        >
	http://www.newsmax.com/archives/articles/2005/4/19/162942.shtml
	        > > 
	       
	        > >       Lenora Fulani is once again in the news. Last year,
	        > Abe Foxman,
	        > > national director of the Anti-Defamation League, wrote a
	letter
	        > > published in The New York Times. Mr. Foxman wrote, "Ms.
	Fulani has
	        > > stated that Jews 'had to sell their souls to acquire Israel
	and are
	        > > required to do the dirtiest work of capitalism - to
	        > function as mass
	        > > murderers of people of color - in order to keep it.'"
	        > >
	        > >               I was shocked at Ms. Fulani's clearly
	anti-Semitic
	        > > statement and wrote to the chair of the Independence Party,
	        > stating in
	        > > part:
	        > >
	        > >       "A Daily News article of December 7 written by Lisa
	Colangelo
	        > > states, 'Party representatives have said the quotes were
	        > taken out of
	        > > context.' I would appreciate knowing the proper context of
	Dr.
	        > > Fulani's remarks referred to by 'party representatives.' I
	cannot
	        > > conceive of any context in which Ms. Fulani's comments could
	be
	        > > perceived as other than anti-Semitic, but perhaps there was
	        > a unique
	        > > context which gave the remarks a benign rather than a
	malignant
	        > > meaning."
	        > >
	        > >               On December 16, 2004, Dr. Fulani wrote, "The
	        > context of
	        > > the remark quoted by Mr. Foxman in his April 20, 2004 letter
	to the
	        > > New York Times is a theatre review I wrote in 1989. The
	        > play, No Room
	        > > for Zion, was written by Fred Newman and was produced that
	        > year at the
	        > > Castillo Theatre. The play was part memoir, part political
	        > critique of
	        > > the Jewish experience in the post-war period. My review
	dealt
	        > > specifically with the issue of nationalism and its dangers.
	In this
	        > > case I was remarking on how black America should learn from
	the
	        > > tragedies experienced by Jewish people. I wrote:
	        > >
	        > >               'As I sat and listened I saw more deeply in
	Fred's
	        > > teaching the historical pitfalls of nationalism. After all,
	        > according
	        > > to nationalistic ideology, the Jewish people have gotten
	        > the ultimate
	        > > - land, in the form of a nation state. The fact is,
	        > however, that they
	        > > had to sell their souls to acquire Israel and are required
	        > to do the
	        > > dirtiest work of capitalism - to function as mass murderers
	        > of people
	        > > of color - in order to keep it.'
	        > >
	        > >               "Because my comment was about the play and,
	more
	        > > importantly, because the production was an expression of
	Newman's
	        > > views which have significantly shaped my own, I asked him
	        > to write to
	        > > you to provide the larger historical and intellectual
	'context' in
	        > > which both the play and my review were written. I have
	enclosed his
	        > > letter, which I hope will shed further light on the issue at
	hand."
	        > >
	        > >               Newman's letter stated: "'The dirtiest work of
	        > > capitalism - to which Dr. Fulani referred in her article -
	'to
	        > > function as mass murders of people of color' is to act as
	        > its garrison
	        > > state in an increasingly hostile and unstable Arab and
	        > Muslim world.
	        > > The language is harsh. The reality, as we now see, is even
	more
	        > > harsh."
	        > >
	        > >               Mr. Newman closed with "Perhaps this brings us
	to a
	        > > bottom line. It may be that my views - the views of a
	leftist - are
	        > > distasteful to you and that you would choose to criticize
	        > me for them.
	        > > That, of course, is your prerogative." ...
	        > >
	        > >                
	       
	        > > ________________________________
	        > >
	        > > See if you've won, play MSN Search and Win
	        > > <http://g.msn.com/8HMAENUS/2752??PS=47575>
	        > >
	        > >
	        > >
	        > >
	        > >
	        >
	        >
	        >
	        >
	        >
	        >
	        >
	        >
	        >
	        >
	        >
	       
	       
	       
	       
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	        <- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
	->
	        To ensure compliance with requirements imposed by the IRS,
	        we inform you that, unless specifically indicated otherwise,
	        any tax advice contained in this communication (including any
	        attachments) was not intended or written to be used, and
	        cannot be used, for the purpose of (i) avoiding tax-related
	        penalties under the Internal Revenue Code, or (ii)  promoting,
	        marketing, or recommending to another party any tax-related
	        matter addressed herein.
	       
	        This message is for the use of the intended recipient only.  It
	is
	        from a law firm and may contain information that is privileged
	and
	        confidential.  If you are not the intended recipient any
	disclosure,
	        copying, future distribution, or use of this communication is
	        prohibited.  If you have received this communication in error,
	please
	        advise us by return e-mail, or if you have received this
	communication
	        by fax advise us by telephone and delete/destroy the document.
	       
	       
	       
	       
	       
	        NOTICE: This communication may contain privileged or other
	confidential information. If you have received it in error, please
	advise the sender by reply email and immediately delete the message and
	any attachments without copying or disclosing the contents. Thank you.
	       
	       
	       
	
	
	<- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ->
	To ensure compliance with requirements imposed by the IRS,
	we inform you that, unless specifically indicated otherwise,
	any tax advice contained in this communication (including any
	attachments) was not intended or written to be used, and
	cannot be used, for the purpose of (i) avoiding tax-related
	penalties under the Internal Revenue Code, or (ii)  promoting,
	marketing, or recommending to another party any tax-related
	matter addressed herein.
	
	This message is for the use of the intended recipient only.  It is
	from a law firm and may contain information that is privileged and
	confidential.  If you are not the intended recipient any disclosure,
	copying, future distribution, or use of this communication is
	prohibited.  If you have received this communication in error, please
	advise us by return e-mail, or if you have received this communication
	by fax advise us by telephone and delete/destroy the document.
	
	
	
	


<- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ->
To ensure compliance with requirements imposed by the IRS, 
we inform you that, unless specifically indicated otherwise, 
any tax advice contained in this communication (including any 
attachments) was not intended or written to be used, and 
cannot be used, for the purpose of (i) avoiding tax-related 
penalties under the Internal Revenue Code, or (ii)  promoting, 
marketing, or recommending to another party any tax-related 
matter addressed herein. 
 
This message is for the use of the intended recipient only.  It is
from a law firm and may contain information that is privileged and
confidential.  If you are not the intended recipient any disclosure,
copying, future distribution, or use of this communication is
prohibited.  If you have received this communication in error, please
advise us by return e-mail, or if you have received this communication
by fax advise us by telephone and delete/destroy the document.
 

</x-charset>