Giustibelli represented Copia Blake in a dissolution of marriage proceeding brought against Peter Birzon. After a breakdown in the attorney-client relationship between Giustibelli and her client, Blake, and oddly, Birzon as well, took to the Internet to post defamatory reviews of Giustibelli. In response, Giustibelli brought suit in a Florida state court against Blake and Birzon, pleading a count for libel. Blake’s and Birzon’s posted Internet reviews contained the following statements: This lawyer represented me in my divorce. She was combative and explosive and took my divorce to a level of anger which caused major suffering of my minor children. She insisted I was an emotionally abused wife who couldn’t make rational decisions which caused my case to drag on in the system for a year and a half so her FEES would continue to multiply!! She misrepresented her fees with regards to the contract I initially signed. The contract she submitted to the courts for her fees were 4 times her original quote and pages of the original had been exchanged to support her claims, only the signature page was the same. Shame on me that I did not have an original copy, but like an idiot, I trusted my lawyer. Don’t mistake sincerity for honesty because I assure you, that in this attorney’s case, they are NOT the same thing. She absolutely perpetuates the horrible image of attorneys who are only out for the money and themselves. Although I know this isn’t the case and there are some very good honest lawyers out there, Mrs. Giustibelli is simply not one of the “good ones.” Horrible horrible experience. Use anyone else, it would have to be a better result. No integrity. Will say one thing and do another. Her fees outweigh the truth. Altered her charges to 4 times the original quote with no explanation. Do not use her. Don’t mistake sincerity for honesty. In her case, they’re not at all the same. Will literally lie to your face if it means more money for her. Get someone else. Anyone else would do a superior effort for you. I accepted an initial VERY fair offer from my ex. Mrs. Giustibelli convinced me to “crush” him and that I could have permanent etc. Spent over a year and 4 times her original estimate to arrive at the same place we started at. Caused unnecessary chaos and fear with my kids, convinced me that my ex cheated which he didn’t, that he was hiding money which he wasn’t, and was mad at ME when I realized her fee circus had gone on long enough and finally said “stop.” Altered her fee structures, actually replaced original documents with others to support her charges and generally gave the kind of poor service you only hear about. I’m not a disgruntled ex-wife. I’m just the foolish person who believes that a person’s word should be backed by integrity. Not even remotely true in this case. I’ve had 2 prior attorneys and never ever have I seen ego and monies be so blatantly out of control………………………………………… Required: 1. What is the standard for the protection of free speech guaranteed by the First Amendment? 2. How did the standard apply to the statements posted online by Blake and Birzon? 3. The First Amendment normally protects statements of opinion, and this can be an effective defense against a charge of defamation. Does it seem reasonable to disregard this defense, however, if any assertion of fact within a statement of opinion is false? Explain.
> The state in which Sue resides requires that her dispute with Tipton be submitted to mediation or nonbinding arbitration. If the dispute is not resolved, or if either party disagrees with the decision of the mediator or arbitrator, will a court hear the
> West Bank is a state-chartered Iowa bank. West Bank issues bank cards to its customers. Customers use their bank cards in one of two ways: automatic teller machine withdrawals (ATM withdrawals) or point of sale purchases (POS purchases). Customers may al
> Cassandra Demery worked as a bookkeeper at Clinton Georg’s business, Freestyle, until Georg discovered that she had embezzled more than $200,000 and had failed to pay $240,000 in state and federal taxes owed by Freestyle. Georg fired Demery and said that
> Envision Printing, LLC sued Bernie Evans in a Georgia state court, alleging that he defaulted on a promissory note. Evans moved for summary judgment, asserting that he was not personally responsible for the debt because he had signed the promissory note
> Plaintiff, Gregory Mills, and defendant, Robert Chauvin, are two experienced attorneys who shared both a friendship and a professional/business relationship. Those longstanding relationships deteriorated and gave rise to this action. The parties formed a
> This appeal concerns real property owned by the defendant [Success, Inc.] and known as 520 Success Avenue property. That property is partially situated in Stratford and partially situated in Bridgeport Connecticut. The defendant executed a promissory not
> Tonya Bass signed a note with Mortgage Lenders Network USA, Inc., to borrow $139,988, repayable with interest in monthly installments of $810.75, to buy a house in Durham County, North Carolina. The note was transferred by stamped imprints to Emax Financ
> Barbara Bauman and twenty-one other residents of Argentina filed a suit in a federal district court in California against Daimler AG, a German company. They alleged that Mercedes-Benz (MB) Argentina, a subsidiary of Daimler, had collaborated with state s
> AAA North Jersey, Inc., contracted with Five Star Auto Service to perform towing and auto repair services for AAA. Terence Pershad, the driver of a tow truck for Five Star, responded to a call to AAA for assistance by the driver of a car involved in an a
> Tammy Herring and Stacy Bowman signed an agreement titled “Bill of Sale—Purchase Agreement” involving a horse named Toby. The agreement defined Herring as the “buyer” and Stacy and Gregory Bowman, who owned Summit Stables in Puyallup, Washington, as the “
> In 1987, Kerstin Lindholm of Greenwich, Connecticut, bought a silkscreen by Andy Warhol titled Red Elvis from Anders Malmberg, a Swedish art dealer, for $300,000. In 1998, Lindholm lent Red Elvis to the Guggenheim Museum in New York City for an exhibitio
> After World War II, several Nazis were convicted of “crimes against humanity” by an international court. Assuming that these convicted war criminals had not disobeyed any law of their country and had merely been following their government’s orders, what
> This is a contract dispute between plaintiff VLM Food Trading International, Inc., a Canadian agricultural supplier and Illinois Trading Company, an Illinois produce reseller. VLM sold frozen potatoes to Illinois Trading through nine separate transaction
> On May 24, 2010, plaintiffs Marc and Bree Kohel entered into a sales contract with defendant Bergen Auto Enterprises, L.L.C. d/b/a Wayne Mazda Inc. (Wayne Mazda), for the purchase of a used 2009 Mazda. Plaintiffs agreed to pay $26,430.22 for the Mazda an
> Carrianne Baird and the other sixty-one plaintiffs-appellants are former students in the registered nursing program of defendant-appellee, Owens Community College. The college lost its accreditation from the National League for Nursing Accreditation Comm
> Scott Harvard was a senior executive officer of Hampton Roads Bank shares, Inc. (HRB), headquartered in Virginia Beach, Virginia. Harvard’s employment contract included a “golden parachute”—a payment of approximately three times his average annual compens
> The plaintiff, Jacob & Youngs, Inc., was a builder that had contracted with George Kent to construct a country residence for him. A specification in the building contract required that “all wrought-iron pipe must be well galvanized, lap welded pipe of th
> In 1980, Dale Bozzio, Terry Bozzio, and Warren Cuccurullo founded the band Missing Persons. As the band’s front woman, Dale Bozzio personified the sound and the look of the new wave scene in 1980s Los Angeles. Capitol Records signed the band and the indi
> NYKCool A.B., based in Stockholm, Sweden, provides maritime transportation for hire. It is a subsidiary of NYK Reefers Limited, which operates as a subsidiary of Nippon Yusen Kabushiki Kaisha, one of the world’s largest shipping companies. NYKCool has a
> Edward Hosch entered into four loan agreements with Citicapital Commercial Corporation to finance the purchase of heavy construction equipment. A few months later, Citicapital merged into Citicorp Leasing, Inc., which was then renamed GE Capital Commercia
> Peter Fazio began talks with Cypress/GR Houston I, LP, to buy retail property whose main tenant was a Garden Ridge store. In performing a background investigation, Fazio and his agents became concerned about Garden Ridge’s financial health. Nevertheless,
> Russell and Sally Kiker own a house on 134.5 acres in Newton County Arkansas. On January 26, 2012, Mona Sloop contracted to purchase the house and the land for $850,000. The contract contained the following down payment provision: The nonrefundable down
> Vivian, owner of Wonder Goods Company, employs Xena as an administrative assistant. In Vivian’s absence, and without authority, Xena represents herself as Vivian and signs a promissory note in Vivian’s name. In what circumstance is Vivian liable on the n
> The case before this Court stems from a real estate transaction for a foreclosed car wash in Bellefontaine, Ohio. A court had appointed Patrick Shivley to be a receiver for the protection of the property, which was offered for sale by Huntington Bank. Cl
> Donald Trump and Michael Sexton formed Trump University, LLC—later known as Trump Entrepreneur Initiative, LLC (TEI)—to sell courses in real estate investing. To attract students, Trump made a promotional video. In it, he said, “We’re going to have profe
> On or about May 12, 2009, plaintiff Colleen M. Holmes signed and dated an Entry Form for the 2009 Susan G. Komen Race for the Cure (the Event) to be held on Saturday, June 13, 2009 [in St. Louis, Missouri]. The one-page entry form contained a section tit
> Cecil McNatt contracted with Jane Vestal to build Henderson Villa, an assisted living facility, in Henderson, Tennessee, for $1.4 million. Three days later, McNatt formed a joint venture with M. S. Burton Construction Company to build two assisted living
> S.L., a female sixteen-year-old minor, worked at a KFC Restaurant operated by PAK Foods Houston, LLC. PAK Foods’ policy was to resolve any dispute with an employee through arbitration. At the employer’s request, S.L. signed an acknowledgment of this poli
> Nike, Inc., designs, makes, and sells athletic footwear, including a line of shoes known as “Air Force 1.” Already, LLC, also designs and markets athletic footwear, including the “Sugar” and “Soulja Boy” lines. Nike filed a suit in a federal district cou
> USS–POSCO Industries (UPI) in Pittsburg, California, hired Floyd Case in 2007. He initially worked as an entry level Laborer and Side Trim Operator. As a condition of employment, Case joined Local 1440 of the United Steelworkers of America. UPI faced a s
> William E. Story, Sr., was the uncle of William E. Story II. In the presence of family members and others, the uncle promised to pay his nephew $5,000 ($76,000 in today’s dollars) if he would refrain from drinking, using tobacco, swearing, and playing ca
> Melinda Hinkal filed a suit in a Pennsylvania state court against personal trainer Gavin Pardoe and Gold’s Gym, Inc., alleging that she sustained a serious neck injury while using a piece of exercise equipment under. Pardoe’s direction at Gold’s Gym. Hin
> Basis Technology Corporation created software and provided technical services for a Japanese-language Web site belonging to Amazon.com, Inc. The agreement between the two companies allowed for separately negotiated contracts for additional services that
> Assume that you are part of a group of executives at a large software corporation. The company is considering whether to incorporate covenants not to compete into its employment contracts. You know that there are some issues with the enforceability of th
> W. O. Lucy, the plaintiff, filed a suit against A. H. and Ida Zehmer, the defendants, to compel the Zehmers to transfer title of their property, known as the Ferguson Farm, to the Lucys (W. O. and his wife) for $50,000, as the Zehmers had allegedly agree
> Actor Robert Wagner entered into an agreement with Spelling-Goldberg Productions (SGP) “relating to Charlie’s Angels (herein called the ‘series’).” The contract entitled Wagner Charlie’s Angels to 50 percent of the net profits that SGP received from broa
> Lou Sisuphan was the director of finance at a Toyota dealership. His responsibilities included managing the financing contracts for vehicle sales and working with lenders to obtain payments. Sisuphan complained repeatedly to management about the performa
> Defendant Cornell University in Ithaca, New York appointed plaintiff Leslie Weston to an associate professorship in 1998 for an initial term of five years. The 1998 offer letter described the position as being “with tenure,” but it stated that, although
> A federal district court jury convicted Mauricio Warner on all 50 counts of an indictment that charged him with obtaining individuals’ identities and using such identities to file over 5,000 false income tax returns resulting in millions of dollars in re
> Karen Schwarck was operating an Arctic Cat 660 snowmobile near Mackinac Island’s Grand Hotel in Michigan with her sister, Edith Bonno, as passenger. The sisters met their demise when the Arctic Cat went, in reverse, backward through a wooden fence and ov
> Maria Nucci filed a suit in a Florida state court against Target Corporation, alleging that she suffered an injury when she slipped and fell on a “foreign substance” on the floor of a Target store. Target filed a motion to compel an inspection of Nucci’s Fa
> David and John Textor both have companies which produce holograms used in the music industry. Shortly before the Billboard Music Awards show, it was announced that Textor’s company, Pulse Entertainment, would show a Michael Jackson hologram performance.
> Winstead filed his complaint in the United States District Court for the District of New Jersey, claiming that Jackson’s album/CD and film derived their contents from, and infringed the copyright of, his book. The District Court dismissed Winstead’s comp
> Brothers Jimmy and Larry Flynt owned “The Hustler Club,” a bar and nightclub in Cincinnati, Ohio. Larry opened Hustler clubs in other Ohio cities. Within a few years, he also began publishing Hustler, a sexually explicit magazine. Larry formed LFP IP, In
> It has been estimated that for every dollar spent cleaning up hazardous waste sites, administrative agencies spend seven dollars in overhead. (a) The first group will list and explain possible ways to trim these administrative costs. (b) The second group
> Drew VeRost was employed at a manufacturing facility in Buffalo, New York, owned by Nuttall Gear, LLC. While operating a forklift at Nuttall’s facility, VeRost climbed out of the seat and attempted to engage a lever on the vehicle. As he stood on the fro
> Wyeth, LLC—a subsidiary of Pfizer, Inc.—is an international pharmaceutical and health-care company with its corporate headquarters in Madison, New Jersey. Wyeth develops, makes, and markets medical therapies, clinical programs, nutritional supplements, p
> Delinda Taylor went to a Seattle Mariners baseball game at Safeco Field with her boyfriend and her two minor sons. Their seats were four rows up from the field along the right field foul line. They arrived more than an hour before the game so that they c
> Joseph Guido bought a parcel of land in Stillwater, New York, that contained nine rental houses. The houses shared a waste disposal system that was defective. Guido had a new septic system installed. When town officials discovered sewage on the property,
> Plaintiff Moseley is an employee of Defendant Pepco Energy Services, Inc. (“PES”). He has been employed by PES or its corporate predecessors for over twenty-five years. PES, a subsidiary of Defendant Pepco Holdings, Inc. (“PHI”), provides deregulated ene
> Bad Frog Brewery, Inc., makes and sells alcoholic beverages. Some of the beverages feature labels that display a drawing of a frog making the gesture generally known as “giving the finger.” Bad Frog’s authorized New York distributor, Renaissance Beer Com
> Rick Scott deposited $2 million into an escrow account maintained by a company owned by Salvatore Carpanzano. Immediately after the deposit was made, in violation of the escrow agreement, the funds were withdrawn. When Scott was unable to recover his mon
> Michael Thompson, a Muslim inmate incarcerated at Waupun Correctional Institution in Wisconsin, sued members of the prison staff for violating his right under the First Amendment to exercise his religion freely. The violation occurred, Thompson says, whe
> In the 1950s, the United States Supreme Court ruled that racial segregation imposed by the states in school systems and other public facilities violated the Constitution. Privately owned facilities were not affected until Congress passed the Civil Rights
> Maureen Droge was a flight attendant for United Air Lines, Inc. (UAL). After being assigned to work in Paris, France, she became pregnant. Because UAL does not allow its flight attendants to fly during their third trimester of pregnancy, Droge was placed
> Background and Facts Phillips Brothers, LP (limited partnership), Harry Simmons, and Ray Winstead were the owners of Kilby Brake Fisheries, LLC (limited liability company), a catfish farm in Mississippi. For nearly eight years, Winstead operated a hatche
> When a plaintiff alleges discrimination but offers no direct evidence of discrimination, the plaintiff bears the initial burden to establish a prima facie case of discrimination. This requires a showing that (1) the plaintiff is a member of a protected c
> Espresso Disposition Corporation 1 and Rowland Coffee Roasters, Inc. (collectively “Appellants”) seek review of the trial court’s order denying their motions to dismiss [Santana Sales & Marketing Group, Inc.’s (“Appellee’s”)] third amended complaint. App
> Jennifer Johnson was working as a finance analyst for Oxy USA, Inc., when Oxy changed the job’s requirements. To meet the new standards, Johnson took courses to become a certified public accountant. Oxy’s “Educational Assistance Policy” was to reimburse em
> Gucci America, Inc., a New York corporation headquartered in New York City, is part of Gucci Group, a global fashion firm with offices in China, France, Great Britain, Italy, and Japan. Gucci makes and sells high-quality luxury goods, including footwear, b
> Kelley Mala is a citizen of the United States Virgin Islands. He went for a cruise in his powerboat near St. Thomas, Virgin Islands. When his boat ran low on gas, he entered Crown Bay Marina to refuel. Mala tied the boat to one of Crown Bay’s eight fueli
> The United Effort Plan Trust “UEP Trust” or the “Trust” was formed in Utah by members of the Fundamentalist Church of Jesus Christ of Latter-Day Saints “FLDS Church”. The Trust members deeded their property to the UEP Trust to be managed by Church leader
> Asphalt & Concrete Services, Inc. (ACS), was working on a play pad at St. John Regional Catholic School in Frederick, Maryland. ACS project manager Blake Wood contacted William Johnson at Higher Power Trucking, LLC, to arrange for a dump truck to haul ma
> Some argue that the best way to stop patent trolls from taking advantage of the system would be to eliminate software patents completely and pass a law that makes software un patentable. Would this be fair to software and technology companies? Why or why
> Why might the new SEC pay-ratio disclosure rule cause certain businesses to eliminate low-wage workers?
> Angie Jolson is the chair of the board of directors of Artel, Inc., and Sam Douglas is the chair of the board of directors of Fox Express, Inc. Jolson and Douglas meet to consider the possibility of combining their corporations into a single corporate en
> Professional Products, Inc. (PPI), bought three pallets of computer wafers from Omneon Video Graphics. (A computer wafer is a thin, round slice of silicon from which microchips are made.) Omneon agreed to ship the wafers to the City University of New Yor
> How might the new SEC pay-ratio disclosure rule help shareholders?
> Gilbert Church owned a horse breeding farm managed by Herb Bagley. Advertisements for the breeding rights to one of Church Farm’s stallions, Imperial Guard, directed all inquiries to “Herb Bagley, Manager.” Vern and Gail Lundberg bred Thoroughbred horses
> Janell Arden is a purchasing agent–employee for the A&B Coal Supply partnership. Arden has authority to purchase the coal needed by A&B to satisfy he needs of its customers. While Arden is leaving a coal mine from which she has just purchased a large qua
> Paul and Julie Leonard’s two-story home in Pascagoula, Mississippi, is only twelve feet above sea level and fewer than two hundred yards from the Gulf of Mexico. In 1989, the Leonards bought a homeowners’ insurance policy from Jay Fletcher, an agent for
> American National Property and Casualty Co. issued an insurance policy to Robert Houston, insuring certain residential property and its contents against fire and other hazards. Twenty months later, Houston issued a quitclaim deed to the property to John
> Sherman Hemsley was a well-known actor from the 1970s. Most notably, he played George Jefferson on the television shows All in the Family and The Jeffersons. He was born to Arsena Chisolm and William Thornton. Thornton was married to another woman, and H
> Leo and Mary Deters owned Deters Tower Service, Inc., in Iowa. Deters Tower serviced television and radio towers and antennas in a multistate area. The firm obtained a commercial general liability policy issued by USF Insurance Co. to provide coverage fo
> Arthur and Diana Ebanks owned three properties in the Cayman Islands in joint tenancy. With respect to joint tenancies, Cayman law is the same as U.S. law. When the Ebanks divorced, the decree did not change the tenancy in which the properties were held.
> James Bubenik, a dentist, had two patients die while under sedation within six months. Bubenik had medical malpractice insurance with Medical Protective Co. (MPC). The families of both patients sued Bubenik for malpractice. A clause in Bubenik’s policy s
> In the 1990s, DuCoa, L.P., made choline chloride, a B-complex vitamin essential for the growth and development of animals. DuCoa, Bio products, Inc., and Chinook Group, Ltd., each had one-third of the U.S. market for choline chloride. To stabilize the ma
> The limited liability company (LLC) may be the best organizational form for most businesses. For a significant number of firms, however, the corporate form or some other form of organization may be better. (a) The first group will outline several reasons
> Elnora Maxey became the guardian of Sean Hall after his parents died. In 1996, Maxey died, and her will left the two houses in her estate to Hall. Julia Jordan became Hall’s new guardian, and when she died, her husband, John Jordan, became Hall’s guardia
> Go to Case Analysis 49.3, Montgomery County v. Bhatt. Read the excerpt, and answer the following questions. (a) Issue: What conflict, and between which parties, did this case highlight? (b) Rule of Law: On which specific requirement of what rule of law d
> Lockheed Martin Corporation owned an aluminum refinery in St. Croix, Virgin Islands, that produced hazardous waste. Lockheed sold the refinery to Glencore Ltd. Their contract provided that Glencore would indemnify Lockheed for “pre-closing” environmental
> After Dave Conley died of lung cancer, his widow filed for benefits under the Black Lung Benefits Act. To qualify for benefits under the act, she had to show that exposure to coal dust was a substantial contributing factor to her husband’s death. Conley
> Brian Cleary and Rita Burke filed a suit against cigarette maker Philip Morris USA, Inc., seeking class-action status for a claim of deceptive advertising. Cleary and Burke claimed that “light” cigarettes, such as Marlboro Lights, were advertised as safe
> Jason Crippen and Catharyn Campbell of Knoxville, Tennessee, were involved in a romantic relationship for many months. Their relationship culminated in an engagement on December 25, 2005, when Crippen placed an engagement ring on Campbell’s finger and si
> Christie’s Fine Art Storage Services Inc. (CFASS) is in the business of storing fine works of art at its warehouse in Brooklyn, New York. The warehouse is next to the East River in a flood zone. Boyd Sullivan owns works of art by Alberto Vargas, includin
> Knox Creek Coal Corporation operates coal mines in West Virginia. The U.S. Department of Labor charged Knox’s Tiller No. 1 Mine with “significant and substantial” (S&S) violations of the Federal Mine Safety and Health Act. According to the charges, inade
> In 2006, twenty’s even entities became limited partners in two hedge funds that had invested with Bernard Madoff and his investment firm. The partners’ investment adviser gave them various investment information, including a memorandum indicating that an
> Go to Case Analysis 45.1, Friends of Animals v. Clay. Read the excerpt and answer the following questions. (a) Issue: What regulation was at issue in this case? What activity does it regulate? (b) Rule of Law: What rule of statutory interpretation did th
> Nicole Tipton and Sadik Seferi owned and operated a restaurant in Iowa. Acting on a tip from the local police, agents of Immigration and Customs Enforcement executed search warrants at the restaurant and at an apartment where some restaurant workers live
> To ensure highway safety and protect driver health, Congress charged federal agencies with regulating the hours of service of commercial motor vehicle operators. Between 1940 and 2003, the regulations that applied to long-haul truck drivers were mostly u
> Richard Vanderbrook’s home in New Orleans, Louisiana, was insured through Unitrin Preferred Insurance Co. His policy excluded coverage for “flood, surface water, waves, tidal water, overflow of a body of water, or spray from any of these, whether or not
> The U.S. National Park Service (NPS) manages the Grand Canyon National Park in Arizona under a management plan that is subject to periodic review. In 2006, after nine years of background work and the completion of a comprehensive environmental impact sta
> A Question of Ethics—Fair Debt-Collection Practices. Barry Sussman graduated from law school, but also served time in prison for attempting to collect debts by posing as an FBI agent. He theorized that if a debt collection business collected only debts t
> McDonald’s Corp.’s Happy Meal® meal selection consists of an entrée, a small order of french fries, a small drink, and a toy. In the early 1990s, McDonald’s began to aim its Happy Meal marketing at children aged one to three. In 1995, McDonald’s began ma
> Go to Case Analysis 41.1 In re Trulia, Inc. Stockholder Litigation. Read the excerpt and answer the following questions. (a) Issue: On what basis did the plaintiffs in this case seek to enjoin the proposed merger? (b) Rule of Law: What is the standard fo
> A well-documented rise in global temperatures has coincided with a significant increase in the concentration of carbon dioxide in the atmosphere. Many scientists believe that the two trends are related, because when carbon dioxide is released into the at
> The Investment Company Act prohibits a mutual fund from engaging in certain transactions when there may be a conflict of interest between the manager of the fund and its shareholders. Under rules issued by the Securities and Exchange Commission (SEC), ho
> In New York City, 2406-12 Amsterdam Associates LLC brought an action in a New York state court against Alianza Dominicana and Alianza LLC to recover unpaid rent. The plaintiff asserted cause to pierce the corporate veil, alleging that Alianza Dominicana
> Dilean Reyes-Rivera was the president of Global Reach Trading (GRT), a corporation registered in Puerto Rico. His brother Jeffrey was the firm’s accountant. Along with GRT sales agents and other promoters, the brothers solicited funds from individuals by
> Three and a half years after Lauren and Warren Woodward were married, they were informed that Warren had leukemia. At the time, the couple had no children, and physicians told the Wood wards that the leukemia treatment might leave Warren sterile. The cou
