Wikipedia:Articles for deletion/Louis Joseph Posner

The following discussion is an archived debate of the proposed deletion of the article below. Please do not modify it. Subsequent comments should be made on the appropriate discussion page (such as the article's talk page or in a deletion review). No further edits should be made to this page.

The result was no consensus. The discussion centred on whether the subject meets the general notability guidelines, and there is a strong case made that he does but this has not resulted in a consensus among the participants. While I have disregarded the struck comments by sockpuppets, I cannot help but agree that they have resulted in a very messy discussion and may have put off some editors from sharing their opinions. As I don't believe that a relisting would be likely to overcome these issues I am closing this as no consensus without prejudice to a new nomination if anyone wants, although I'd personally prefer at least a few days before that happens. Thryduulf (talk) 15:24, 4 January 2014 (UTC)[reply]

Louis Joseph Posner

Louis Joseph Posner (edit | talk | history | protect | delete | links | watch | logs | views) – (View log · Stats)
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Don't see that this meets notability guidelines and don't see coverage as significant. There's a negative BLP aspect as well. User who has spent hundreds of edits on the thing wants badly to delete it. May be this is the same user that created the thing with a new nick. Too much editorial water under the bridge for G7 and I don't see a prior AfD for G4. A7 is out too, so here we go! Dlohcierekim 15:43, 27 December 2013 (UTC)[reply]

Comment See Cullen's delete rationale. He put's it quite well. Dlohcierekim 01:35, 1 January 2014 (UTC)[reply]

**Comment.The Article was previously deleted under "Speedy Deletion" as an unambiguous advertising which only promotes a person, and by virtue of the creator of the original article User:lawline who was banned in January 2011. See Talk Page for User:lawline, that stated:

==Speedy deletion nomination of Louis Joseph Posner==

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A tag has been placed on Louis Joseph Posner, requesting that it be speedily deleted from Wikipedia. This has been done under section G11 of the criteria for speedy deletion, because the page seems to be unambiguous advertising which only promotes a company, product, group, service or person and would need to be fundamentally rewritten in order to become encyclopedic. Please read the guidelines on spam and Wikipedia:FAQ/Organizations for more information.User:What88 15:53, 27 December 2013 (UTC)[reply]
Speedy deletion is not AfD Why not let the AfD play out? And could you please remove the copy paste from the talk page? It is unsightly and not germaine. Simply stating the previous CSD nomination suffices. Dlohcierekim 16:13, 27 December 2013 (UTC)[reply]
Agreed, let the AfD play out.User:What88 17:46, 27 December 2013 (UTC)[reply]
  • Keep Meets WP:GNG in the strictest sense. Posner is probably most recently remembered for his disbarment following a guilty plea to promoting prostitution, as well as a suit by NYPD to fight enforcement of an order to disburse seized/forfeited monies to Posner to fund his criminal defense (he had also been indicted money laundering, and falsifying business records related to a Voter March bank account). [1] (and other sources) In 1993, Posner was also noted for lawsuits against the Central Synagogue Nursery School (both state and federal) which failed, as well as a lawsuit against the New York Law Publishing Company for a satirical cartoon and article criticizing him for those lawsuits. (source not available online, but see Posner v. N.Y.L. Pub. Co., 644 N.Y.S.2d 227 (App. Div. 1996)). Another possible source of notability (though substantially less significant) is his involvement in Voter March. As to the negative BLP aspect, while some respect for the subject's wishes might be in order if he wanted to remain private, that's not the case here; we've got at least one person here trying to promote this individual's political advocacy pursuits. It's not our job to either promote this person or say nothing at all. —/Mendaliv//Δ's/ 16:17, 27 December 2013 (UTC)[reply]

***Comment. The New York State indictment is an accusatory instrument, not a criminal conviction. "A person accused of a crime is innocent until proven guilty and convicted by a court. For persons who are relatively unknown, editors must give serious consideration to not including any material..." WP:BLPCRIME. Posner was never convicted of any money laundering or falsifying business records charges. The misdemeanor charge for falsifying business records simply said that when Posner opened a bank account for Voter March that he indicated that this "not-for-profit" corporation was a "for profit" corporation. (See, Posner v. The City of New York, et.al., Docket No. CV 4859 (JMF)(SDNY 2013), Plaintiff's Memorandum of Law in Opposition to Defendant's Motion for Summary Judgment: Falsifying Business Records in the Second Degree: Voter March, Ltd., pp. 9-10, by Jacobs & Hazan, LLP, Attorneys, May 3, 2013; published by Jonathan S. Gould, Esq. at Scribd.com [[2]]). This is a very minor charge and not notable. Posner was never charged or convicted for any crimes in any federal court.Luckydan89 (talk) 03:19, 30 December 2013 (UTC) [reply]

    • Found the NYLJ article on microfiche. It's a first-page article, that continues on the 6th page of the same issue, for a total of 10 paragraphs, and featuring a cartoon of a silhouette attempting to block a doorway with an enormous $12M bill, with a child's face peeking out from underneath. The Superior Court decision was also printed at page 28 of the same issue. While admittedly, the incident itself just about fits the definition of a tempest in a teacup, it was the subject of non-trivial coverage, and is separated enough from the strip joint case that I would argue that BLP1E does not apply to this subject. In short, we're at least past WP:GNG and WP:BLP1E. I agree, there may be some "respect for the subject" arguments, but I would suggest that we not consider these persuasive. We don't go out and delete the article on Ken Lay or Jeff Skilling because they're embarrassing to the subjects or their relatives. And I think we're being extremely generous in the Posner article for not going into depth in terms of the verifiable information mentioned in some of the articles, such as Posner's admission to "interviewing" talent for his strip club. Anyway, I would further argue that What88 has no real standing to invoke a "subject requested" delete on the part of Posner as there's no indication he shares any kind of privity with the subject. —/Mendaliv//Δ's/ 02:26, 28 December 2013 (UTC)[reply]

***Comment. Your analogy of Posner to Ken Lay and Jeff Skilling, the major players in the huge Enron scandal, is “over the top.” Enron involved one of the largest “white collar” crimes in the history of the United States.Luckydan89 (talk) 19:50, 29 December 2013 (UTC) [reply]

  • Strong Delete As primary author of the Article on Posner, I had researched law cases related to his work as an attorney, and had indicated the following:
Posner was co-counsel for a defendant in the U.S. Securities and Exchange Commission (SEC) insider trading case involving Motel 6 in the U.S. District Court, S.D.N.Y.,[1] and related class action suit.[2] Posner also represented the plaintiff in Ox v. Union Central Life, a U.S. District Court case involving wrongful rescission of a disability insurance policy, which was reported in Westlaw, Lexis, Mealey's Litigation Reporter and the American Disabilities Reporter.[3]
On December 19, 2013, User:Mendaliv removed these cases as "unremarkable small-time positions in unremarkable small-time cases; WP:UNDUE still applies to this guy"
I had also come across the cases involving Central Synagogue and the New York Law Journal which are about 20 years old. Both cases were ultimately dismissed, and accordingly, there is nothing notable about a lawyer losing a case. Further, in that the cases involved a minor child with a disability, I was concerned with the sensitivity of the subject and possible violations of WP:BLP.
The article is in violation of WP:BLP and WP:BLPCRIME and should be deleted for that reason alone. The article makes reference to sensationalist articles in the tabloid, the NY Post. A person is presumed innocent unless convicted of the crime charged; the Article improperly makes reference to money laundering charges which Posner was never convicted of. Wikipedia is not a tabloid and must exercise caution on any article involving a living person, and must refrain from being sensationalist, judgmental, accusatory, retaliatory and malicious.
Further, there is nothing in this article meets notability standards at WP:GNG. The only possibly notable items are Posner's former involvement with the HLD Club and VoterMarch. However, there are separate articles on both the HLD Club and VoterMarch, and the article on Posner is merely duplicative of these articles. User:What88 17:44, 27 December 2013 (UTC)[reply]
    • Comment. WP:BLPCRIME and WP:BLP are red herrings. Posner’s arrest, plea, conviction and disbarment were not only covered by the NY tabloid media (NY Post, Daily News) but by more sedate outlets such as the New York Times and the ABA Journal. Posner pleaded guilty and is a convicted felon. The events are well-sourced, and the article here does not sensationalize them. It should also be noted that What88, who now argues so strenuously for the deletion, had previously contended that this subject was in fact notable, here. JohnInDC (talk) 17:58, 27 December 2013 (UTC)[reply]
As the creator of the Article on Posner, my initial position was that the subject was notable. However, after numerous comments and edits from other Users and Editors who have questioned the notability of the subject, I have changed course. I now agree with the nominator User:Dlohcierekim that the Article should be deleted as not notable and that there is a negative Biography of a Living Person aspect, as well. WP:BLP and WP:BLPCRIME are not red herrings, but serious concerns. There are millions of people in this country who have been convicted of crimes, including felonies, and that does not make them notable. WP:BLP states that "Biographies of living persons ("BLP"s) must be written conservatively and with regard for the subject's privacy. Wikipedia is an encyclopedia, not a tabloid: it is not Wikipedia's job to be sensationalist...; the possibility of harm to living subjects must always be considered when exercising editorial judgment." WP:BLPCRIME states that "A person accused of a crime is presumed innocent until proven guilty and convicted by a court of law. For people who are relatively unknown, editors must give serious consideration to not including material in any article suggesting that the person has committed, or is accused of committing, a crime unless a conviction is secured." The Article on Posner states that Posner was arrested for money laundering. However, Posner was never convicted of money laundering and a person is presumed innocent unless found guilty of that charge. The Article also makes reference to three articles from the tabloid, NY Post, which mention Posner's wife by name. Mrs. Posner was never convicted of crime and is presumed innocent. The NY Post tabloids referenced in the Article are sensationalist and refer to Posner as Lap Dance King, Big Daddy Lou, pimp, and other pejorative and degrading terms. Where we have a biography of a living person that is clearly not notable, and we also have serious violations of WP:BLP and WP:BLPCRIME, we have a professional and ethical responsibility to delete this article. As the creator of the Article, deference should be given to my "strong delete."
If he is not notable the article should be deleted in its entirety. If he is notable then it is almost certainly because of these events, reports of which seem to be the most thoroughly pertinent 3d party material about the subject that seems to exist; and if the article is kept then it may not exclude those events. Keep or delete, BLP and BLPCRIME do not inform the determination. JohnInDC (talk) 19:55, 27 December 2013 (UTC)[reply]
WP:DEL specifically states "Reasons for deletion include, but are not limited to, the following: 8. Articles whose subjects fail to meet the relevant notability guideline (WP:N, WP:BIO, and so forth); and 9. Articles that breach Wikipedia's policy on biographies of living persons." Accordingly, WP:BLP and WP:BLPCRIME do inform the decision to keep or delete.User:What88 20:17, 27 December 2013 (UTC)[reply]
      • Also. What88 should delete one of his two "Strong Deletes" above. JohnInDC (talk) 18:01, 27 December 2013 (UTC)[reply]
Noted and done, only one "Strong Delete".User:What88 18:32, 27 December 2013 (UTC)[reply]
Note: This debate has been included in the list of New York-related deletion discussions. • Gene93k (talk) 18:14, 27 December 2013 (UTC)[reply]
Note: This debate has been included in the list of Businesspeople-related deletion discussions. • Gene93k (talk) 18:14, 27 December 2013 (UTC)[reply]
I don't know. I think, anything that alerts a reviewing admin to the circumstance would be sufficient, whether it's an annotation or collapsed text or - well, I don't know what. A strikethrough of the "vote" with a note explaining why; leaving the next in place? In any case once someone is aware that What88 has a distinct POV here, and casually abuses Wikipedia accounts to advance that POV, they can decide how to interpret his comments. JohnInDC (talk) 03:01, 28 December 2013 (UTC)[reply]
I can tell you that I give 0 weight to his rationale. Not to be incivil but, none. I would not touch his edit though. It only takes a moment to understand his story. Dlohcierekim 03:08, 28 December 2013 (UTC)[reply]

**Comment Agreed, it would be improper to alter the edit of What88; and What88's comments and arguments should be given full consideration in this discussion of Articles of Deletion. Luckydan89 (talk) 19:58, 29 December 2013 (UTC) [reply]

      • Proposition. A CU has determined that Luckydan cannot be distinguished from other Lawline socks. Wikipedia:Sockpuppet investigations/Lawline. While I am content to leave first sock What88's comments in place, absent objection I intend to strike through second sock Luckydan89's further postings. It's already generous to permit a confirmed sock to express himself once; twice is too much. JohnInDC (talk) 15:36, 30 December 2013 (UTC)[reply]

*Delete Posner is not notable to the standards of Wikipedia. His conviction for promoting prostitution in connection with a local strip club is not a serious crime. Prostitution is a victimless crime and is legal in most of Nevada and in many countries in the western world. Posner never served a jail sentence. It is ridiculous to compare Posner to Ken Lay or Jeff Skilling, the major players in the huge Enron scandal who served lengthy prison sentences. Posner's only arguably notable contribution was as founder of VoterMarch. However, most of that work dates back to 2001 and is already covered adequately in the Wikipdia article. I also see no reason to discount or disregard What88's vote as that vote was cast prior to his/her being blocked. However, if you were to take the position that What88's vote should be discounted, then you need to discount the article written about Posner by what88 and that then serves as a further basis for deletion of this article.Luckydan89 (talk) 09:55, 28 December 2013 (UTC)[reply]

***Comment I have had an account with Wikipedia since 2008. My User page indicates college student. This is the only account that I have with Wikipedia. This sockpuppet investigation is ridiculous and is being used as a personal attack against my credibility and my input in this Article for Deletion. Luckydan89 (talk) 19:29, 29 December 2013 (UTC)[reply]

  • Redirect To VoterMarch, and merge a minimum non-weighty subset of the biographical information there. If we remove the VoterMarch part, this is just a wholly negative BLP where the subject is notable only for a crime that got coverage mostly in the NY tabloid circuit. §FreeRangeFrogcroak 17:34, 31 December 2013 (UTC)[reply]
    • Respectfully disagree. The crime Posner is notable for goes beyond the tabloid circuit (see the NY Times article, as well as the kerfuffle involving the disbursal of seized funds), and Posner himself goes beyond BLP1E given his involvement in the failed lawsuits (state and federal) against the Central Synagogue Nursery School (which were covered by the N.Y.L.J. and others). If anything, the Voter March stuff should be trimmed back substantially, though probably not omitted entirely. —/Mendaliv//Δ's/ 19:09, 31 December 2013 (UTC)[reply]
      • Comment. I am writing on behalf of Louis J. Posner requesting that this Biography of a Living Person WP:BLP in Wikipedia be deleted in its entirety. WP:BLPCOMPLAIN I have been advised in writing by Mr. Posner who is the subject of this Biography of a Living Person that he requested that this Article be deleted. WP:BLPREQUESTDELETE Mr. Posner is clearly not a public figure. WP:NOTPUBLICFIGURE and he does not satisfy Wikipedia's notability guidelines. WP:FAILN Posner was a relatively unknown New York City attorney from 1990 until his disbarment in 2010. Mr.Posner had co-founded the grassroots activist organization called Voter March in 2000, which is listed in Wikipedia as VoterMarch. Posner also owned a strip club that was closed down by law enforcement in 2008. There is no reason to have a separate Wikipedia article devoted just to Louis Posner. At best, Mr. Posner is a subject notable for only one event. WP:BLP1E The article on Louis Posner states that he was arrested for money laundering, but all of these charges were dismissed. Posner pleaded guilty to a single count of promoting prostitution related to the strip club, and was given probation, and he did not serve a prison sentence. Mr. Posner was never charged with or convicted of any crimes in any federal court. WP:BLPCRIME The Wikipedia article on Louis Posner makes reference to various articles from the tabloid newspaper, NY Post which are disparaging and sensationalist WP:BLPGOSSIP. These articles also mention his wife by name who was arrested for money laundering and promoting prostitution. All charges against Mrs. Posner were dismissed and her criminal record has been sealed to protect her privacy.WP:BLPNAME Denver982 (talk) 20:10, 31 December 2013 (UTC)[reply]
Hi Lawline, I'mm sure you now the way to WP:OTRS Dlohcierekim 20:09, 31 December 2013 (UTC)[reply]
Would've taken all of five minutes to come out and say you were in contact with the subject and request some action on his behalf instead of dicking around for weeks. This is why New York led the way when it introduced code pleading (I suggest reading up on how pleading worked at common law, by the way; even in the medieval era, you kept the facts really close to your chest... it's quite interesting). While I oppose OTRS taking action on this article, I wholly support your taking it there. —/Mendaliv//Δ's/ 20:29, 31 December 2013 (UTC)[reply]
If this were legit, then it would be up to the subject or their rep to contact OTRS. This is yet another bizarre twist in a strange game. It amazes me that a person new to WIkipedia would come directly to the BLP notice board and to this discussion. The simple thing would be to go to OTRS directly. The office would figure it all out and make a decision. Dlohcierekim 20:45, 31 December 2013 (UTC)[reply]
  • Delete per FreeRangeFrog. VoterMarch can cover his relevance to the organization, the rest is a minor crime story. Gamaliel (talk) 21:00, 31 December 2013 (UTC)[reply]
  • Delete per our guideline at WP:PERP which says that the crime has to be "a well-documented historic event. Generally, historic significance is indicated by sustained coverage of the event in reliable secondary sources which persists beyond contemporaneous news coverage." This bust of a lap dance club fails that standard by a country mile, and all the other "scandals" and tabloid hollering are trivial. Cullen328 Let's discuss it 22:20, 31 December 2013 (UTC)[reply]
    • This is more than a vice raid of a strip joint that happened to sweep up an attorney. The coverage on just this incident started with the bust and has continued until as late as February in the Post, and appears to have resulted in Posner's CPA getting pulled back in September. There were several court cases on multiple issues stemming from this, each of which was the subject of significant coverage, including one case where the NYPD appealed a trial court's ruling that they had to disburse seized funds to Posner to spend on his defense. Yes, this case was in the tabloids. Is that alone reason to delete? Hell no. This got mainstream and industry coverage as well, and is by far not the only thing Posner's remembered for (the Central Synagogue cases and Voter March; so we're past BLP1E).
      Anyway, if we're going to delete and redirect, this should probably point to a more appropriate target. I would suggest Jewish Book Council, which gives a Louis Posner Memorial Award among its National Jewish Book Awards annually, and is much more consistently mentioned in the press than this guy (though it's still admittedly niche). —/Mendaliv//Δ's/ 00:40, 1 January 2014 (UTC)[reply]
      • I would disagree with the redirect - the prize is named for "Louis Posner", not "Louis Joseph Posner". §FreeRangeFrogcroak 20:27, 1 January 2014 (UTC)[reply]
      • If this perp is notable then every single convicted murderer in human history is notable. But they aren't. Are you actually claiming that the fact that a felon who got probation also had his CPA pulled somehow adds to his "notability"? Being one of several that founded a very marginally notable activist group does not make someone notable, nor does involvement in a trivial lawsuit or two. That's what many non-notable lawyers do - sue people and lose. Or sometimes win. And their number is legion. Passing local press coverage does not make such routine shenanigans notable. As for redirecting to the article for an entirely innocent organization, no way. Cullen328 Let's discuss it 01:27, 1 January 2014 (UTC)[reply]
        • I'm just following the guidelines you cited. There's been continuing coverage and the incident has continued to develop and be covered in the news. International newswires are the antithesis of local coverage, by the way. As well as much of the legal industry coverage I've mentioned. If you're correct that specious lawsuits by unremarkable attorneys is the norm, then the coverage of multiple Lou Posner stories by legal industry periodicals would suggest there is something a bit less unremarkable about this character. Frankly, I would argue that this individual has a diverse enough background of coverage that PERP is inapplicable: how exactly do you square the Voter March and Central Synagogue coverage with that? You can't just dismiss it as unremarkable and unrelated: that might fly if we were talking about WP:UNDUE, but we're talking about notability. —/Mendaliv//Δ's/ 05:19, 1 January 2014 (UTC)[reply]
        • The case dragged on for a couple of years, and the run-of-the-mill news coverage dragged on for a couple of years. So what? Newspapers love crime stories involving sex and strippers. Continuing coverage after the dragged out proceedings? Zero. These crimes are utterly non-notable and of no historical significance whatsoever. Cullen328 Let's discuss it 08:51, 1 January 2014 (UTC)[reply]
  • Delete Several items are simply of no value -- such as being an editor of a HS publication. He appears to have been a political activist who then managed to get caught in a separate felony and disbarred. He might meet GNG, but my reading is that he fails. I do find it interesting that he might have used his activism to launder money, though. Collect (talk) 16:46, 1 January 2014 (UTC)[reply]
    • The industry coverage of the Central Synagogue suit that preceded the felony arrest/conviction by over 10 years? —/Mendaliv//Δ's/ 23:51, 1 January 2014 (UTC)[reply]
      • Let's see, Mendaliv: a lawyer filed a lawsuit and lost. A publication mocked the lawsuit, so inconsequential that it isn't even mentioned in the Central Synagogue article. The litigious lawyer sued the publication and lost. You are arguing that makes him notable? I don't think so. I think it is run of the mill lawyer crap, even if it happened in Manhattan. Cullen328 Let's discuss it 07:16, 3 January 2014 (UTC)[reply]
        • Not correct, first of all, and a mischaracterization of my position secondly. Posner filed a state lawsuit, then a federal lawsuit, and got benchslapped when he tried to up the damages in his suit under state law. The New York Law Journal (a major daily legal industry periodical) reported on it, giving it a front page story, where it included a mildly humorous cartoon. The story itself was a fairly straightforward, non-polemical retelling of the lawsuit itself. NYLJ also reprinted the entire Supreme Court bench opinion in the back pages. And the only reason I found that article was because the subsequent libel suit referenced it; NYLJ isn't well indexed, at least not in a manner available to me. The mere non-presence of the incident at the Wikipedia article on the Central Synagogue is a non sequitur; first, Wikipedia is not complete, and secondly, the argument fallaciously conflates WP:DUE with WP:N in suggesting that what's not relevant to one topic is irrelevant to all topics.
          Moreover, I do not argue that the Central Synagogue incident alone makes Posner notable. I argue that it is one episode of "significant coverage" in "reliable sources" that are "independent of the subject" that, when taken along with the coverage for the strip joint bust—which includes a lengthy piece in the New York Times in addition to the substantial number (20+) of lower-quality sources—and the coverage for Voter March, you have a textbook case of a subject meeting WP:GNG and WP:BIO. WP:PERP alone does not suffice because we're talking about more than a criminal event—we're talking about civil suits and political advocacy that are independent of the initial subject (even presuming Voter March were related to the strip club activities in some ways, it does not follow that the two are inseparable from a topical standpoint).
          Finally, your arguments here make several unfortunate mischaracterizations as to the nature of lawyering and life in New York City that, respectfully, should re not be granted weight, and are (in light of the substantial coverage of the legal events) simply incorrect. That lawyers can be litigious should not be a matter of consideration here. —/Mendaliv//Δ's/ 07:41, 3 January 2014 (UTC)or lawyers, we all know[reply]
          • I am not mischaracterizing your position but rather offering my evaluation of the notability of the topic. You think it's notable; I don't. How, pray tell, did I mischaracterize life in New York City? By mentioning Manhattan? As for lawyers, we all know that many are exemplary and some are scoundrels. You make many valid points. To me, none of them add up to notability per WP:PERP. You disagree, as is your right. Why don't we let the closing administrator decide, as we've both probably already made our best cases? Cullen328 Let's discuss it 08:13, 3 January 2014 (UTC)[reply]
  • Comment Due to the rampant socking and bad-faith attempted manipulation of the AfD process, perhaps this should be closed as "no consensus" and a new one opened so that a "clean" discussion minus the above distractions can be carried out? --Eggishorn (talk) (contrib) 03:11, 3 January 2014 (UTC)[reply]
I don't know. We should probably collapse Lawline's socks. Ignoring him, I think the closing admin can come to a conclusion. Dlohcierekim 03:17, 3 January 2014 (UTC)[reply]
I don't think there's enough contamination of the discussion that a new AfD is needed. But I do think it should be noted that huge blocks of text tend to hinder new participants from voicing their opinions. —/Mendaliv//Δ's/ 06:54, 3 January 2014 (UTC)[reply]
The above discussion is preserved as an archive of the debate. Please do not modify it. Subsequent comments should be made on the appropriate discussion page.
  1. ^ SECURITIES AND EXCHANGE COMMISSION Washington, D.C. | LITIGATION RELEASE NO. 17624 / July 22, 2002 | Motel 6 SEC Litigation
  2. ^ Redtail Leasing v. Thrasher (In re Motel 6 Sec. Litig.), 1997 U.S. Dist. LEXIS 3909, Fed. Sec. L. Rep. (CCH) P99454, RICO Bus. Disp. Guide P9255 (S.D.N.Y. Apr. 1, 1997)
  3. ^ Ox v. Union Cent. Life Ins. Co., 1995 U.S. Dist. LEXIS 15997, 5 Am. Disabilities Cas. (BNA) 24, 13 Am. Disabilities Dec. 232 (S.D.N.Y. 1995)
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