GREGORY CHANDLER ON CORRECTION OF MILITARY RECORDS

Most military or naval records contain some type of error. Sometime the error is small and of little consequence. At times, however, the error is large and of major consequence. At other times, still, there is simply a desire to correct errors.

Any individual with military records may apply to the appropriate service's Board for the Correction of Military Corrections. The heirs or attorney of one with military or naval records may also apply for correction of errors.

The Army, Air Force, and Coast Guard have separate boards. The Navy operates the board for both Navy personnel and members of the Marine Corps. An application to the Department of the Navy is often called the correction of Naval records.

Title 10, United States Code, Section 1552, is the federal statute governing the correction of military and naval records. This statute authorizes the Secretary of the service concerned to correct any military record when necessary to correct an error or injustice. The purpose of the statute was to relieve the Congress from consideration of private bills to correct errors or injustices in military records. The statute provides for the service secretaries to act through a board of appointed civilians in considering applications for correction of military records.

AFI 36-2603, Air Force Board for Correction of Military Records, implements the statute within the Air Force. Army Regulation 15-185 implements the statute within the Army. The Code of Federal Regulation; Title 33, Part 52 implements the statute within the Coast Guard. The Navy and Marine Corps implements the statute though Code of Federal Regulations; Title 32, Part 723.

One should seek alternatives before applying to correct a military record. One can look to see if there is a process that does not require board intervention. An appeal requesting upgrade of a discharge should normally be submitted to the service's Discharge Review Board under Department of Defense Directive (DoDD) 1332.28, Discharge Review Board (DRB) Procedures and Standards. The board will often return an application that has not sought relief through the appropriate administrative process. One should submit a request for correction of records no later than 3 years after you discover the error or injustice. The boards will often review the merits of untimely applications. If the applicant's delay is determined as meritorious, the timeliness is waived in the interest of justice.

I recall one case that I worked on in the years 2005 - 2006 time period. The applicant alleged that he and other African American soldiers were mistreated during World War II era. The applicant alleged that his mistreatment was racially motivated. The applicant, however, was able to correct his military records about 65 years after the wrong done to him.

The application for correcting military or naval records is done by submitting a DD Form 149. The DD Form 149 should be done with care. Attach copies of statements or records that support your case. It is not enough to provide the names of witnesses. The Board will usually not contact your witnesses to obtain statements. You should contact your witnesses to get their signed statements with your request. I often advise applicants to get the statements notarized.

The applicant's own statement is important. The applicant should explain what happened and why it is an error or injustice. Sometimes, one can hire an attorney for direct representation. Attorneys also represent applicants as ghostwriters. A ghostwriter is someone who prepares the documents and the applicant signs the written product.

Best of luck in the correction of records.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler -- Immigration Fraud Litigation

A case appealed to the Eleventh Circuit involving immigration fraud is United States v.

Ndiaye, 434 F. 3d 1270 (11th Cir. 2006). In a prosecution for immigration offenses and

Social Security fraud, the Court held it was only harmless error to allow cross-examination

of a defendant's character witnesses regarding a letter that the defendant sent to a female neighbor requesting a "get-together" while their respective spouses were at work. Some of

the circumstances surrounding the letter were unknown and, while the letter did perhaps

suggest that the defendant was not being entirely candid with his wife, it did not directly

relate to his truthfulness and honesty.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Third Party Subsequent Remedial Measures

Millennium Partners, L. P. v. Colmar Storage, LLC, 494 F. 3d 1293 (11th Cir. 2007)

Affirming a judgment for coffee traders on a bailment claim against a warehouseman for

damage to bags of coffee beans, the 11th Circuit held that there was no error in allowing the tenant who leased the warehouse after the defendant vacated the premises to testify that he required the landlord to install new basins, pumps, and drains, as Federal Rule of Evidence

407 does not apply to a remedial measure that was taken without the voluntary participation

of the defendant.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Police Officer Litigation

While working on a case involving alleged police misconduct, I came across an interesting

case. The case is United States v. Guidry, 456 F. 3d 493 (5th Cir. 2006). A police officer

was convicted for violating civil rights by sexually assaulting several women.

Affirming, the Court found no error in the admission under Federal Rule of Evidence Rule

413 that the defendant sexually assaulted another woman. The 5th Circuit held that the

plain language of Federal Rule of Evidence 413 allowed evidence of other offenses even

if the allegations did not result in a conviction.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Subsequent Remedial Measures

Many attorneys are aware that courts typically exclude evidence of subsequent remedial measures. A subsequent remedial measure is an act undertaken after the alleged harm or

injury that tends to make the alleged harm or injury less likely to happen again.

Under the Federal Rules of Evidence, Rule 407 speaks to subsequent remedial measures.

Most state courts, that have codified rules of evidence, have a rule of evidence that is similar

to Federal Rule of Evidence Rule 407.

An interesting case is Chlopek v. Federal Insurance Company, 499 F.3d 692 (7th Cir. 2007).

In this case, the Court affirmed a judgment for the defendants in a product liability action

arising from injuries allegedly caused by a device that delivers cooling therapy to

postoperative patients.

The Seventh Circuit found no trial court abuse of discretion in the exclusion of evidence that

the manufacturer changed the warning label some time after the plaintiff's injury. Although

the plaintiff argued that the change was not prompted by safety concerns, the Court noted

that Federal Rule of Evidence 407 does not speak to the motive for the change but only

whether it would have made the alleged harm or injury less likely to occur.

GREGORY CHANDLER, Attorney at Law

GREGORY CHANDLER ON CYBERATTACKS

All individuals should take substantial steps to prevent cyberattacks. By cyberattacks, I mean identity theft, financial fraud, and scams by way of computers.

Prevention of cyberattacks begins with a firewall, anti-malware software and automatic updates. Chances are that you have these installed on your computer. Modern computers and routers have firewalls built in. One should make sure that updates are installed on a regular basis.

Windows users: the built-in Windows Update system will notify you when updates, many of them critical for security purposes, become available.

Mac users: Apple automatically sends systems updates. Generally it is safe to accept the systems updates.

Wireless users: It is best to use the highest encryption available on your router, and the router's default username and password should be changed at least every six months.

Don't use simple passwords: For financial accounts do not use simple passwords. For example, do not use your last name or street name. Use unique numbers and special characters. Again, change the passwords at least every six months.

New security options: A new breed of website security adds an extra layer of protection beyond usernames and passwords by registering your computer's unique thumbprint when one logs in. The website is more confident if is you using the computer. If the site detects a computer you do not normally use, expect extra questions to prove your identity.

Credit cards: Many credit card issuers let you set limits on your credit card use. If a large charge or unusual charge is made, the credit card issuer can send you an alert by text message or e-mail. An alert notifies you about a suspicious transaction so you can respond accordingly.

Be alert: One should always be alert while on-line. Often one will receive information that claims to be from one's bank or another entity that one does business with. Most banks will not ask for personal information that the bank has already received from the customer. If in doubt about an e-mail, contact the bank or business.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Delay in Asserting Attorney-Client Privilege

I often write about the attorney-client privilege. In United States v. Ary, 518 F. 3d 775 (10th Cir. 2008), the appellate court affirmed convictions for fraud and stolen property offenses arising from transactions involving space artifacts, the Court found no error in a ruling that the defendant waived the attorney-client privilege and work product protection as to documents seized in a government search when he waited six weeks to assert protection after a Rule 16 discovery meeting. In a footnote, the Court suggested that is was "possible" that the defendant waived the privilege at the Rule 16 meeting itself, when he failed to raise any privilege claim despite the fact that the government provided an inventory of items seized in the search, which included the "black box" containing the allegedly privileged material.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Medical Doctor Litigation

Earlier this month, I was asked to consider submitting an article discussing the conviction of Conrad Murray, M. D. On November 7, 2011, Murray was found guilty of manslaughter in the death of Michael Jackson.

In my research, I came across an interesting case. The case is United States v. Bek, 493 F. 3d 790 (7th Cir. 2007) The United States Court of Appeals for the Seventh Circuit affirmed a conviction for prescribing drugs without a proper medical purpose. The Court rejected a defense argument that patient records had been erroneously admitted in violation of the physician-patient privilege. The Court noted that the controlling law in this federal prosecution was federal common law, which provides no physician-patient privilege.

The Seventh Circuit declined to adopt a physician-patient privilege in light of the United States Supreme Court's decision in Jafee v. Redmond, finding "no circuit authority in support of a physician-patient privilege even after Jafee" and seeing no reason to create such a privilege.

On another note, perhaps federal prosecutors will want to prosecute Dr. Murray on the theory of prescribing or using drugs without a proper medical purpose.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Review of Military Court-Martials

I reviewed an interesting case recently. The case is Loving v. Department of Defense, 550 F. 3d 32 (D. C. Cir. 2008): A soldier convicted of capital murder by a court-martial sued under the Freedom of Information Act (FOIA) seeking disclosure of memoranda prepared for the President in connection with his statutory review of the death sentence.

Affirming summary judgment for the defendants, the Court held that the disputed documents came within FOIA Exemption 5 for documents protected by privilege. Memorandum from the Army and Defense Secretaries to the President advising him on his review fell squarely within the presidential communications privilege because they directly involved the President and their confidentiality "ensures[s] that presidential decision-making is of the highest caliber, informed by honest advice and full knowledge."

The Judge Advocate General's recommendation, which was forwarded by the Army Secretary to the President, likewise fell withing the presidential communication privilege, because the President solicited and received it in a manner sufficient to bring it within the privilege.

The Court held that a memorandum from the Department of Defense Office of General Counsel to the Counsel for the President came within the deliberative process privilege. The plaintiff's interest did not constitute a public interest in disclosure surmounting the privilege, and there was no abuse of discretion in the Judge's decision not to conduct in camera review to determine whether the document contained segregable factual portions that might be disclosed.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Conspiracy Litigation

United States v. Parker, 553 F.3d 1309 (10th Cir. 2009)

In this case the Court affirmed a conviction for conspiracy to sell unsafe airplane engines with false documentation, finding no abuse of discretion when a defense character witness was asked on cross-examination if it would change his opinion of the defendant "if you found out he had been selling aircraft engines...that were unairworthy," since the questions "did not assume Parker was 'convicted of the

crimes alleged in his case.'"

GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Habit Evidence

Sims v. Great Am. Life Ins. Company, 469 F. 3d 870 (2006)

In an action against a life insurer who refused to pay on the ground that the insured committed suicide, the insurer attempted to prove the decedent's state of mind by showing that he was not wearing a seat belt (although he habitually did) at the time of his one-car accident. Affirming in part a judgment for the plaintiff, the Court held it was error (but harmless) to exclude the habit evidence. Because "the very nature of habit evidence is that it is done reflexively," the evidence would be probative on the question whether he failed to buckle up because he was suicidal or because he was intoxicated.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Physician-Patient Privilege

Most attorneys know that that their is a physician-patient privilege. However, many attorneys do not understand the limitations on the physician-patient privilege. An interesting case is United States v. Bek, 493 F.3d 790 (7th Cir. 2007).

The Court affirmed a conviction for prescribing drugs without a proper medical purpose, the Court rejected a defense argument that patient records had been erroneously admitted in violation of the physician-patient privilege. The controlling law in this federal prosecution was federal common law, which provides no physician-patient privilege. The Court declined to adopt a physician-patient privilege in light of the Supreme Court's decision in Jaffee v. Redmond, finding "no circuit authority in support of a physician-patient privilege even after Jaffee"

and seeing no reason to create such a privilege.

GREGORY CHANDLER, Attorney at Law

GREGORY CHANDLER ON CROSS-EXAMINATION HYPOTHETICALS

In cross-examinations, hypotheticals are sometimes used. In United States v. Kellogg, 510 F. 3d 188 (3d Cir. 2007) the Court affirmed a mail fraud conviction against the owner of an environmental laboratory who had been charged with falsely certifying that certain tests had been conducted. The Court found no abuse of discretion when a defense character witness was asked whether his opinion that the defendant was a

law-abiding citizen would be different if the witness knew that lab reports misstated the analytical tests used. The Court noted that a guilt-assuming hypothetical is irrelevant in testing a character witness' reputation testimony, but for opinion testimony "[s]uch evidence may aid in the jury's ultimate credibility determinations and in deciding how much weight to give to a defendant's character evidence."

While such a question "may prove problematic if it arises in circumstances that implicate the presumption of innocence or otherwise undermine due process,...there is nothing inherent in guilt-assuming hypotheticals, in the abstract, that makes them unfairly prejudicial, let alone so prejudicial as to constitute a per se violation of due process." One judge thought that the particular question asked was not sufficiently hypothetical.

GREGORY CHANDLER, Attorney at Law

GREGORY CHANDLER ON ATTORNEY TESTIMONY

United States v. Hyles, 479 F. 3d 958 (8th Cir. 2007) is a case concerning attorney testimony. In a murder-for-hire trial arising from the murder of a witness against the defendant in a state drug trial, the defendant called his former attorney from the underlying case and asked him about discussions between them. The Eight Circuit affirmed the conviction. The Court held that the defendant had waived his attorney-client privilege and could not assert it to bar the government from cross-examining the attorney.

GREGORY CHANDLER, Attorney at Law

GREGORY CHANDLER ON THE ENTRAPMENT DEFENSE

United States v. Franco, 484 F. 3d 347 (6th Cir. 2007) the Court affirmed a conviction for cocaine possession, the Court noted that when the defendant raised an entrapment defense he placed his character in issue, making specific instances of his conduct admissible. Because evidence of his prior drug trafficking crimes was admissible under Rules 404 (a) and 405 (b) rather than Rule 404 (b), the government was not required to provide notice of its intention to introduce the evidence.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Foundation to Testify

This is an interesting case dealing with the ability of a witness to testify on a subject. The case is United States v. Famania-Roche, 537 F.3d 71 (1st Cir. 2008). The Court

affirmed drug convictions, holding that a cooperating witness had sufficient personal knowledge of the inner workings of a drug conspiracy to testify that the defendant controlled a certain drug point and to describe quantities of drugs sold at different drug points on a weekly basis. The witness operated her own drug point, was present at the place where the conspirators gathered to discuss the drugs they sold at various drug points, and had personally seen the defendant sell drugs to customers she sent to him.

In a similar case, United States v. Munoz, 487 F. 3d 25 (1st Cir. 2007), the Court affirmed convictions of former bank executives for bank fraud, finding no abuse of discretion in permitting an officer of the affected bank to testify regarding board meetings nearly 20 years previously. Statements such as, "I don't recall that it was discussed. I believed that if it was discussed I would remember and it was not reflected in the minutes," provided a sufficient showing that the witness had enough recall to testify from his personal knowledge about information given to the board.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler -- Drug Distribution

In United States v. Cook, 454 F. 3d 938 (8th Cir. 2006), the trial judge in a cocaine distribution case granted the defendant's motion in limine to exclude evidence of four prior drug convictions. The U. S. Court of Appeals for the 8th Circuit affirmed the ruling on interlocutory appeal, using an abuse of discretion standard. The 8th Circuit rejected the government's unsupported suggestion that de novo review is appropriate because the appeal is an interlocutory appeal. The 8th Circuit reasoned that it saw no good reason why the standard of review should differ because the evidentiary ruling was made and appealed before trial.

GREGORY CHANDLER, Attorney at Law

GREGORY CHANDLER ON LEGAL OUTSOURCING

A reality that is here to stay is the fact that a substantial amount of legal work is being outsourced. Legal outsourcing is the practice of obtaining legal work from a law firm or legal support services company that is outside the United States of America. Legal work is being outsourced for the same reasons that U. S. businesses in other services and professions started outsourcing.


The various reason for legal outsourcing include lower costs and the avoidance of complying with the laws and regulations that exist in the U. S. Of course, legal work done in a foreign nation does not have to comply with, for example, government mandated wage laws.

Legal outsourcing took off in the late 1990s. The nations that do the most outsourcing for U. S. recipients are Canada, India, the Philippines, and Israel. India is the major player in terms of legal outsourcing. Legal outsourcing has a huge costs-savings advantage. Attorney work that may cost between $100.00 to $500.00 per hour in the U. S. will usually cost much less in a foreign nation.

In India, legal outsourcing represents an upscale movement in outsourcing. A decade ago, outsourced work in India consisted of low end call centers dealing with service functions. This work consisted of, for example, doing customer service work for a U. S. business. Legal outsourcing, however, involves more than just speaking over the telephone. Legal outsourcing involves engaging in sophisticated legal work.

Indian workers, who once helped with legal transcription, now offer services that include research, litigation support, document discovery and review, drafting of contracts and patent writing. The industry offers an attractive career path for many of the 300,000 Indians who enroll in law schools every year. India and the United States share a common law legal system and Indian lawyers are trained to conduct proceedings in English.

The United States legal profession has experienced great change during the past decade. The realities of the global market, such as legal outsourcing, will continue to change the legal profession.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler -- Handwriting Analysis

I have trained with the Federal Bureau of Investigation on questioned documents. Handwriting analysis is a major focus of questioned documents training.


Handwriting analysis is used to link a specimen of handwriting with a crime suspect by comparing the suspect's handwriting with, for example, the handwriting on a ransom note or other communication linked to a crime. The purpose is not to profile the writer but to determine if the same hand produced a document known to have been written by the suspect, called an exemplar or standard, and the document in question.


Handwriting analysts try to maintain a strict protocol with criminal suspects. The analysts do not show the suspect the questioned document. They do not tell the suspect how to spell certain words or how to use punctuation. The suspect is to use writing materials similar to those of the questioned document. The dictated text should in some respects match the content of the questioned document so that the spelling and handwriting of certain words and phrases can be compared. The text the suspect is to write out should be dictated at least three times. In addition, a witness should observe the procedure.

In either type of case--whether authenticating documents or investigating criminal suspects--handwriting analysts begin from the premise that while most people learn to write using a certain system, such as the Palmer or Zaner-Blosser system, they develop idiosyncrasies in the way they form letters and words. These idiosyncrasies become fixed and remain constant over time, even when the person is attempting to disguise her or his writing.


For comparison, analysts generally focus on four categories of factors that define a person's handwriting. The first is form: the shape of letters, their proportion, slant, lines, angles, retracing, connection, and curves. One writer, for example, might begin a "t" at the top and make a single straight line down, while another may begin at the bottom and form a loop. Similarly, a writer may form the vertical line of a "d" with an upstroke, then retrace downward to finish the letter, while another writer may form a loop rather than retracing. One person's capital "A" might be round and fat, another's thin and angular. One person's cross on a "t" may slope up, another's may be horizontal, any yet another's may slope downward. The second category is line quality, which results from the pressure exerted and the type of writing instrument and includes the continuity and flow of the writing. Thus, pauses can be discerned, and these pauses tend to take place in predictable patterns. The third category is arrangement, which includes spacing, alignment, formatting, and punctuation. Document examiners also look at a final category, content, which includes spelling, phrasing, grammar, sentence formation, and the like.

The central question is whether handwriting analysis is a valid forensic technique. It has been shown that even trained document examiners can be fooled. Nonetheless, for over three decades handwriting analysis has been regarded as valid and reliable evidence in court. The existence of such groups such as the American Society of Questioned Document Examiners suggest that a community of scientists generally accepted the premises and techniques of handwriting analysis. Further, the United States Secret Service maintain that their computer databases prove that among a large sample of writers, no two share the same combination of handwriting characteristics.


Since 1993, though, the admissibility of handwriting analysis has come under intense scrutiny. That year, the United States Supreme Court, in Daubert v. Merrell Dow Pharmaceuticals, created the stricter Daubert standard, which gives federal judges more discretion in admitting or excluding scientific testimony and evidence. Specifically, Daubert requires judges to determine whether a theory of technique has been tested, whether it has been submitted to peer review, whether standards exist for applying the technique, and what the error rate is. Under the stricter Daubert standard, virtually any forensic technique, including handwriting analysis and even such venerable tools as handwriting comparison, could be questioned and excluded.



One federal ruling dealt a severe blow to the admissibility of handwriting analysis. In United States v. Saelee, (162 F. Supp. 2d 1097, D. Alaska 2001) a federal court ruled that handwriting analysis had never been adequately tested. The court stated that serious questions exist about the reliability of methods currently in use. The court went on to say that the technique of comparing known writings with other writings appears to be entirely subjective and entirely lacking in controlling standards.


One drawback that I see in handwriting analysts is that most of the supposed handwriting analysts do not understand how to handle the professional forgers. The professional forger understands the training, methods, and background of handwriting analysts and acts on that knowledge to defeat handwriting analysts who are trained to deal with the general public. For example, consider cocaine distribution by teenagers will usually lack the sophistication of a professional drug cartel. The teenage drug dealers do not know the methods of law enforcement. The drug cartels do understand the methods of law enforcement. The professional drug dealers understanding of law enforcement makes them difficult to combat.


Like all experts or supposed experts, handwriting analysis often comes down to a battle of expert witnesses. The handwriting expert for one side will often lessen or completely cancel the handwriting expert for the other side.





GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Cocaine Modus Operandi

I write again about cocaine litigation. In United States v. Fanfan, 468 F. 3d 7 (1st Cir. 2006), the Court affirmed a conviction for conspiracy to distribute cocaine. The Court assumed that the conspiracy had been terminated by the arrest of most of its members, but held that even so a post-conspiracy transaction in which the defendant attempted to distribute cocaine was admissible to prove modus operandi and identity. The arrested conspirator had paged the defendant, the government recorded the call, the arrested conspirator ordered cocaine and met the defendant by prearrangement. The defendant had cocaine and cocaine base in his automobile. This evidence was especially important because only one witness could identify the defendant as the man who supplied drugs and this witness had a plea deal with the government.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler -- Bank Fraud

I do some consulting about alleged forgery and alleged fictitious documents.

An interesting case is United States v. Brown, 597 F. 3d 399 (D. C. Cir. 2010). The Court affirmed a conviction for bank fraud and passing fictitious financial instruments. The Court held it was an abuse of discretion (but harmless error) to admit evidence that the defendant failed to pay a $700 home inspection fee.

The government's suggestion that this bad act evidences the defendant's motive to get money is too far removed from the charged offenses and shows only his bad character in cheating an agent out of the home inspection fee.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler -- Rebuttal Evidence in Cocaine Litigation

In United States v. Mejia, 600 F. 3d 12 (1st Cir. 2010) the Court affirmed a conviction for conspiracy to distribute cocaine, finding no abuse of discretion in the admission of drug ledgers apparently in the defendant's handwriting, as the evidence tended to rebut his central defense that he was "merely present" at a drug deal and otherwise uninvolved in the charged conspiracy.


GREGORY CHANDLER, Attorney at Law

GREGORY CHANDLER ON WAL-MART LITIGATION

I came across the case of Van Bumble v. Wal-Mart, Inc. last week while doing some research. The U. S. Court of Appeals, Seventh Circuit affirmed the denial of motions for a new trial or additur in a couple's slip-and-fall action. The Court found no abuse of discretion in the exclusion of evidence of the plaintiff's financial situation, including the fact that the plaintiffs lacked medical insurance.

Although it was argued that the evidence was relevant to prove why the wife did not seek medical treatment for two years, the Court noted that Wal-Mart did not question why the wife did not seek treatment, so the evidence was irrelevant and would have been prejudicial on the damages issue.

The citation for this case is 407 F. 3d 823 (7th Cir. 2005).



GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Embezzlement Litigation

United States v. Weller, 238 F. 3d 1215 (10th Cir. 2001) is a case about embezzlement litigation. In a bank manager's trial for embezzlement, the prosecution introduced evidence that the defendant had an empty bank account and "maxed out" credit cards prior to the incident charged. The bank manager also had substantial cash in the weeks following the incident charged.

The Court found no abuse of discretion in admission of the evidence. Although ordinarily evidence of the defendant's poverty is inadmissible to show a motive for crime, a significant change in the defendant's financial status, as in this case, can be quite probative of the commission of a crime.


GREGORY CHANDLER, Attorney at Law

GREGORY CHANDLER--MAIL FRAUD

United States v. Ortland, 109 F. 3d 539 (9th Cir. 1997) is an interesting case about consciousness of guilt. The Court affirmed a conviction for mail fraud. The Court found no error in the exclusion of evidence offered by the defendant that one of his business partners had fled prosecution.

The Court had already rejected the idea that a co-defendant's flight is relevant to show the guilt of anyone other than the fleeing defendant in United States v. Candoli, 870 F. 2d 496, 501 (9th Cir. 1989). Similarly, flight does not tend to show that someone else is innocent, at least where there can easily be more than one guilty person, as in this case.


GREGORY CHANDLER, Attorney at Law

GREGORY CHANDLER -- FLEEING JUDGE

In United States v. Borders, 693 F. 2d 1318 (11th Cir. 1982) the Court affirmed the conviction of a defendant charged with involvement in an effort to bride a federal judge. The Court held that evidence of the judge fleeing once the judge learned of the defendant's arrest was admissible to prove the judge's involvement in a conspiracy with the defendant.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Income Tax Litigation

An interesting case I came about last week concerning income tax litigation. In United States v. Hairston, 819 F. 2d 971 (10th Cir. 1987) the Court affirmed convictions for willful failure to file tax returns, holding that the defendant's testimony concerning the impact that tax protests literature and seminars had on his understanding of tax law requirements was more probative than the literature itself and that there was no error in excluding the literature on the grounds that it might confuse the jury.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler -- 940 F. 2d 1518

The Federal Circuit, in reviewing a Vaccine Act proceeding, the Court noted that the incubation period of measles is the sort of well-known medical fact of which judicial notice may be taken. The case is Hines v. Secretary of Health & Human Services. The citation is 940 F. 2d 1518 (Fed. Cir. 1991)


GREGORY CHANDLER, Attorney at Law

Gregory Chandler--Suppression of Evidence

United States v. Maravilla, 907 F. 2d 216 (1st Cir. 1990) is a case dealing with the suppression of evidence. The Court affirmed convictions of former Customs officers for robbery-related offenses in connection with the murder of a money courier, holding that there was no abuse of discretion in admitting evidence a defendant had tried to have the barrel on his weapon changed. The effort to replace the barrel suggested an effort to eliminate features of the weapon that might have linked it with a bullet found in or near the victim's body, which suggested a consciousness of guilt. The Court also opined that there is no requirement that the prosecution introduce the much stronger evidence of the gun and the bullet, particularly since there was no showing the the government ever found a bullet.


GREGORY CHANDLER, Attorney at Law

GREGORY CHANDLER -- DRUG DISTRIBUTION LITIGATION

United States v. Roman, 728 F. 2d 846 (7th Cir. 1984) concerns inconsistent witnesses. The Court affirmed a conviction for conspiring to distribute LSD, rejecting an argument that it was error not to strike the testimony of two witnesses as being too inconsistent and confusing. The credibility of the witness, the court opined, was a question for the jury.


Gregory Chandler, Attorney at Law

Gregory Chandler--Cocaine Prosecution

An interesting case is United States v. Foster, 986 F. 2d 541 (D. C. Cir. 1993). The Court reversed a conviction for distributing crack cocaine because the defense had not been permitted to cross-examine officers about their ability to identify other persons they mentioned in connection with the alleged transaction. The answers to the questions would have made it more or less probable that the officers had correctly identified the defendant. The Court opined that relevancy objections should have been overruled. Under the rules of evidence, evidence is either relevant or not relevant. The Court opined that there is no such thing as "marginally relevant" evidence.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler -- Atlanta Bar Association 5K

The Atlanta Bar Association will present its 5K race and walk on Saturday, September 10, 2011. The race starts at 7:30 a.m.

The 5K is called "The Legal Runaround." Proceeds from the race will benefit the children of Atlanta police officers.

You may go to www.atlantabar.org for registration and more information.



Gregory Chandler, Attorney at Law

Gregory Chandler on Casey Anthony Trial

Casey Anthony was found NOT GUILTY today on the major counts.

Many silly attorneys debated for weeks about the trial. Most of these
incompetent attorneys took the view that Casey Anthony would be found guilty of some form of murder charge. The majority of these know nothings were way off base.

When thinking about what a jury verdict will be, it is best to view the case from the perspective of a juror rather than from the perspective of an attorney. It is the jurors who reach verdicts and not the attorneys.

The prosecution theory about Casey Anthony wanting to party and getting a tattoo was just plain silly from a juror's standpoint. Most people do not usually commit murder because she or he wants more party opportunities.

GREGORY CHANDLER, Attorney at Law July 5, 2011

Gregory Chandler -- Firearms Possession

An interesting case I reviewed last week. In United States v. Williams, 442 F. 3d 1259 the Court affirmed a conviction for felon firearm possession. The Court found no abuse of discretion when the trial judge took judicial notice that a violation of the statue statute under which the defendant had previously been convicted was a crime punishable by more than one year of imprisonment.


Gregory Chandler

Gregory Chandler -- Judicial Knowledge

A trial judge may not take personal knowledge based on the judge's personal experience. This is the appellate court's view in United States v. Berber-Tinoco, 510 F. 3d 1083. The Court affirmed a conviction for unlawful re-entry after deportation. The Court, however, held that the trial judge acted improperly when, in a suppression hearing, he interjected his own observation regarding the location of stop signs along a certain road near the border and the narrowness of the road. The trial judge also improperly relied on his personal knowledge that no speed limit was posted on a certain read near the border and that the speed limit was therefore 55 miles per hour.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Department of Defense Third Party Collection Program

The Third Party Collection Program was legislated by Congress in 1986. The Third Party Collection Program obligates Department of Defense Military Treatment Facilities to bill private health insurance carriers such as Blue Cross/Blue Shield, Mail Handlers, Aetna, etc., for the cost of medical care furnished to retirees and family members covered by their own health insurance policies. This includes all medical benefits such as inpatient care, outpatient care, and ancillary services such as pharmacy items.

The government bills the private health insurers. That is why the government uses the term "Third Party". Military Treatment Facilities can only collect for services covered by one's third party health insurance plan according to one's benefits with the plan.

By law, your insurance policy rates cannot go up or be canceled just because a claim is filed. Health insurance is not like automobile insurance because one's rates do not increase when a claim is filed.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Criminal Record

United States v. Rose, 522 F. 3d 710 (6th Cir. 2008) is an interesting case about when evidence of a criminal record may be admitted.

The Court affirmed a conviction for selling a firearm to a person with a criminal record and a known felon. The Court held that evidence that the defendant and the firearm buyer were in prison together was relevant to prove that the defendant knew the other man was a convicted felon. The probative value of the evidence significantly outweighed any prejudice that would arise from the jury's learning that the defendant had been imprisoned.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Litigation Costs

Catlin v. Tormey Bewley Corp. is a case of first impression in the Colorado courts. The Colorado Court of Appeals held that, under Colorado law, accrued interest on loans taken out by prevailing parties to finance their case may not be recovered as costs. To be awardable as costs, expenses must be necessarily incurred by reason of the litigation and for the proper preparation for trial. The Court reasoned that any necessity for a loan results primarily from the economic circumstance of the litigant, and only secondarily from what expenses the case requires, and a loan is not preparation for trial. Furthermore, Colorado law does not allow for interest on costs.

The case may be found at 2009 WL (WestLaw) 1477498


GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Atlanta Bar Association

The Atlanta Bar Association presents "LawJam: Battle of the Atlanta Lawyers' Bands."

In the competition, lawyers compete for the top spot in an American Idol style competition. Proceeds support youth programs in Atlanta and free legal services for low income citizens.

Tickets can be purchased through the Variety Playhouse. Please contact Sally Hogsette at
shogsette@atlantabarfoundation.org or (404) 521-0781 if you have any questions.

The Variety Playhouse is located at 1099 Euclid Avenue in Atlanta.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler - 301 F. 3d 240

Hitt v. Connell, 301 F. 3d 240 (5th Cir. 2002): In a civil rights action by a deputy constable who was discharged for his union activity, an associational right protected by the First Amendment, the Court found no abuse of discretion in admitting evidence that the supervisor took disciplinary action against other deputies for their union activities.

The evidence was admissible as proof of the supervisor's motive in firing the plaintiff and to impeach the supervisor's statements that he was "a union man" and had no animus against the union.


Gregory Chandler, Attorney at Law

Gregory Chandler - Illegal Immigrants

This is an interesting case concerning Federal Rule of Evidence 404(b). In United States v.
Saldivar, 710 F. 2d 699 (11th Cir. 1983), the Court held that evidence that a father and son charged with aiding and abetting the transportation of illegal immigrants had repeatedly paid for the transportation costs of aliens. Such conduct by the defendants was admissible as probative of knowledge.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Manslaughter

An interesting case is United States v. Leonard, 439 F. 3d 648 (10th Cir. 2006). The Court affirmed a conviction for involuntary manslaughter and assault arising from a head-on collision, the Court held that the defendant's prescription medication history was relevant and admissible to prove malice aforethought in a case in which the defendant consumed prescription drugs before the accident.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Check Fraud Scheme

United States v. Fraser, 448 F. 3d 833 (6th Cir. 2006) is a prosecution for a check fraud scheme. The federal government prosecutor introduced excerpts from a book the defendant had written that detailed a virtually identical scheme. The 6th Circuit affirmed the conviction. The Court held that there was no abuse of discretion in admitting the evidence as proof of the defendant's intent. However, it was plain error to give a limiting instruction that the evidence could be used to prove, "motive, opportunity, intent, preparation, plan, knowledge, identity or absence of mistake or accident," because there was no issue concerning motive, opportunity or identity. The error was harmless, however, because the other listed purposes overlapped with intent, there was no showing that consideration of the book permitted any unfair inferences concerning identity, motive, or opportunity, and the instruction carefully addressed avoiding the propensity inference.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler, 440 F. 3d 670

An interesting case is Alpha v. Hooper, 440 F. 3d 670 (5th Cir. 2006). The 5th Circuit affirmed summary judgment for the defendants in an action by relatives of a deceased motorist who alleged that excessive force was used when a deputy sheriff shot the motorist to death, the Court held that admitting evidence that the deceased motorist was under the influence of methamphetamine at the time of the shooting was not an abuse of discretion, because it corroborated the deputy's testimony about the events in dispute.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Military ID cards

Beginning June 1, 2011, Social Security numbers on military identification cards will be phased out. The effort is part of a larger plan to protect service members and other Department of Defense (DOD) identification card holders from identity theft.

Criminals use Social Security numbers to steal identities, allowing them to pillage resources, establish credit or to hijack credit cars, bank accounts or debit cards. Currently, the Social Security number is printed on the back of common access cards, and on the front of cards issued to dependants and retirees. Beginning in June 2011, when current cards expire, they will be replaced with new cards having a DOD identification number replacing the Social Security number. The DOD identification number is a unique 10-digit number that is assigned to every person with a direct relationship with the department. The new number also will be the service member's Geneva Convention identification number.

An 11-digit DOD benefits number also will appear on the cards of those people eligible for DOD benefits. The first nine digits are common to a sponsor. The last two digits will identify a specific person within the sponsor's family.

Social Security numbers embedded in the bar codes on the back of identification cards will remain there for the time being, and will be phased out beginning in 2012. The identification cards will be replaced as they expire. It will be approximately four years until all military identification cards are replaced with the DOD ID number.

The identity protection program began in 2008, when DOD started removing Social Security numbers from family member identification cards.



Gregory Chandler, Attorney at Law

Gregory Chandler - Drug litigation

I have done articles about United States v. Roe, 210 F. 3d 741 (7th Cir. 2000) in the past. In the appeal the 7th Circuit affirmed a conviction for conspiring to distribute cocaine, the court found no error in the admission of the defendant's 1989 conviction for the same offense. The defendant had introduced testimony from police officers that no drug paraphernalia was ever found at his house and no evidence of drug activity was ever found in his trash because the defendant never placed trash in front of his residence. The Court opined that the earlier conviction helped to explain why the defendant would not keep drug paraphernalia at his residence and why he did not put out trash in front of his residence for collection by municipal trash collection crews.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler - U. S. v. Garcia

In United States v. Garcia, 567 F. 3d 721 (5th Cir. 2009) the 5th Circuit affirmed marijuana trafficking and conspiracy convictions, finding no plain error in the admission of evidence regarding one defendant's cocaine trafficking and use, as it was relevant to issues of intent and knowledge. The Court also found no plain error in the trial judge's failure to instruct the jury on the limited purpose for which the evidence was admitted, commenting that "[f]or trials to function effectively, parties themselves must play an active role in creating the jury charge; the inclusion of 404(b) instructions is no exception."


GREGORY CHANDLER, Attorney at Law

Gregory Chandler - United States v. Brown

An interesting case from the Fifth Circuit. In United States v. Brown, 553 F. 3d 768 (5th Cir. 2008) two pharmacists were convicted of conspiring with physicians to distribute large quantities of pain medications under cover of false prescriptions written by the physicians. Affirming, the Court found no abuse of discretion in the admission of a state trooper's testimony that he had pulled over a motorist who was under the influence of drugs, and found 39 bottles of pain medications (none bearing the motorist's name) that had labels from a defendant's pharmacy and listed one of the conspiring physicians as the prescriber. The bottles, their labels, and the circumstances of their discovery spoke to the defendant pharmacist's prescription-filling practices.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler - U. S. v. Mahdi

In United States v. Mahdi, 598 F. 3d 883 (D. C. Cir. 2010) the Court affirmed drug trafficking convictions, finding no error in the prosecution's failure to give notice of intent to introduce evidence of certain offenses. Because the acts were intrinsic (i. e., part of crimes charged), no notice was required under Federal Rule of Evidence 404(b).

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Tax Evasion

In United States v. Marston, 517 F. 3d 996 (8th Cir. 2008) the 8th Circuit affirmed convictions for tax evasion, finding no abuse of discretion in excluding a videotape of a person whose teachings the defendant claimed to have relied on in deciding that certain income was not taxable. The videotape was created in year 2002, while the tax evasion the defendant was charged with took place in years 1999 to 2001, so it was irrelevant to the defendant's belief at the time of the charged acts.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Tax Fraud

United States v. Crockett, 435 F. 3d 1305 (10th Cir. 2006) is a case involving a prosecution for tax fraud. The trial judge refused to allow cross-examination of a witness about the tax advice she received from a third party. The prosecution objected that the cross-examination was beyond the scope of the direct examination.

Because the defense failed to reveal the content of the evidence he expected to adduce, the Court reviewed the ruling for plain error and found none.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler : United States v. Al-Moayad

United States v. Al-Moayad, 545 F. 3d 139 (2nd Cir. 2008)

In this case, the United States Court of Appeals, Second Circuit, vacated convictions for a conspiracy to provide material support to designated terrorist organizations (Hamas and Al-Qaeda). The Court held it was an abuse of discretion to admit extensive testimony about a bus bombing by Hamas and about an Al-Qaeda training camp. The defendants were not charged with planning or carrying out the bus bombing and no evidence connected them to that or any other terrorist act, and they never denied knowledge of Hamas' involvement in violent acts, so the evidence had "questionable probative value," which was substantially outweighed by the effect of the "blatant appeal to the jury's emotions and prejudices." The Court found that the testimony regarding the training camp was highly inflammatory and irrelevant, since there was no evidence tying the defendant against whom the evidence was offered to the camp.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Money-Laundering

United States v. Spriggs, 102 F. 3d 1245 (D. C. Cir. 1996) is a case involving money-laundering. The Court affirmed the conviction in a money-laundering prosecution. The appellate court held that the defendants had failed to make a timely objection to the testimony of a law enforcement officer called as an expert on money-laundering practices. The defendants made no objection when the testimony was given, and although they raised concerns about the testimony in a bench conference called at the behest of the prosecution partway through the officer's testimony, it was not until the following day that they moved to strike the testimony. The court, therefore,
conducted a plain error review and found none.

Gregory Chandler, Attorney at Law

Gregory Chandler - Maine Supreme Judicial Court

I came across an interesting case recently from Maine. Maine's DNA Data Base and Data Bank Act (Act), requires individuals convicted of certain serious felonies to submit a DNA sample for the data base. The Maine Supreme Judicial Court opines that the Act does not violate the prohibition against unreasonable search and seizure set forth in the federal and state constitutions.



In analyzing the issue, the Maine Supreme Judicial Court disagreed with the approach taken in
other courts, that the "special needs" exception to the warrant requirement applied, and instead applied a totality of the circumstances approach, by which the Court balanced the defendant's privacy interest against the state's interest.

The Court then noted that the defendant had a diminished expectation of privacy due to his prior conviction, which brought him within the ambit of the Act. The Court also reasoned that the extent of the intrusion was minimal, in that the DNA testing involved a cotton swab of the defendant's cheek. Moreover, the Act provided safeguards with respect to release of the DNA information. Finally, the Court noted that the state had a substantial interest in deterring recidivism, solving crimes, and absolving the innocent.

The case is State v. Hutchinson. The Maine case may be found at Westlaw 1152002.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Supreme Court of Wisconsin

This is a bizarre case. The Supreme Court of Wisconsin held that the presence of the trial judge's mother on a jury violated a criminal defendant's constitutional right to be tried by an impartial jury, and a new trial was required. The Court held that the trial judge's mother was objectively biased, as the familial relationship constituted an interest in the case extraneous to the evidence because a reasonable person would not have been able to set aside the relationship when discharging juror duties. Further, the presence of the judge's mother on the jury could have had an effect on trial proceedings or jury deliberations. Finally the presence of the judge's mother on the jury was inconsistent with the jury's function as a check upon the power of the judge.

It is hoped that the new trial is with a different trial judge.

State v. Tody, 2009 Wisconsin 31; 764 N. W. 2d 737

Gregory Chandler, Attorney at Law

Gregory Chandler on Ubiquinol

Those wanting more information on Ubiquinol, the nutrition supplement, please visit:


www.ubiquinol.org/


Gregory Chandler, Attorney at Law

Gregory Chandler on Lien Resolution Group

TEXAS FEDERAL COURT PROTECTS SETTLEMENT FUNDS
PLACED IN SPECIAL NEEDS TRUST

In ACS Recovery Service v. Griffin, No. 6:09-cv0512, (March 23, 2011), the Federal Court,
Eastern District, Texas (Tyler Division) adopted the magistrate's recommendation and dismissed this reimbursement claim in the amount of $50,076.19 because the tort recovery of $300,000 had been placed in a Special Needs Trust. Even though the trustee was a named
defendant in this action, the tort recovery was never in the possession of the ERISA participant's possession. This decision relies upon Great West Life v. Knudson.

Call 800-888-1743 or e-mail Brett Newman at bnewman@plaintiffsolutionsupdate.com

GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Federal Healthcare Law

There are some creative means used to attack the federal healthcare reform law. The body of law is officially known as the Patient Protection and Affordable Care Act ("Act"). Those who attack the law often call it "Obamacare."

In a federal district court in New Jersey, an uninsured patient's alleged that he would have to purchase qualifying insurance or be subject to penalty. The court opinion states that the uninsured patient's claims were conjectural and speculative. Therefore the patient lacked standing to bring an action challenging the Act. Although the Act was certain in that it would take effect in the future, there was a real possibility that the patient would not have to pay for insurance, because he could obtain insurance through his employer. The patient's income may also mean that he may not have to purchase health insurance. Moreover, the uninsured patient was not suffering any immediate injury caused by the Act.

The case is: New Jersey Physicians, Inc. v. Obama, 2010 Westlaw 5060597

GREGORY CHANDLER, Attorney at Law

Gregory Chandler on Hospital Law

Greetings:

An interesting case.

The Pennsylvania Medical Care Availability and Reduction of Error Fund (Mcare) was not required to provide professional liability coverage to a hospital for a claim brought by a psychiatric unit patient following an injury the patient allegedly suffered at the hands of another of the hospital's patients. The psychiatric unit patient sustained an injury as the result of a tort by a fellow patient, and not by a health care provider. The fact that there might have been a secondary tort committed by the hospital with regard to supervising the fellow patient was of no matter because he, not the hospital or its agents, was the instrumentality that caused the psychiatric unit patent's injury.

The case is Polyclinic Medical Center v. Medical Care Availability, 2001 WL 9270 (Pennsylvania)

Gregory Chandler, Attorney at Law

Happy Cinco De Mayo from Gregory Chandler

I wish you all a happy Cinco De Mayo.


GREGORY CHANDLER, Attorney at Law

Gregory Chandler - Wisconsin Courts

Greetings:

While drafting a brief for a pro bono case in Kansas, I came across an interesting case out of Wisconsin.

The opinion reads that the use of a jackhammer to remove a portion of the concrete floor in a landlord's garage while executing a search warrant during a murder investigation in which the tenant was a suspect did not render the search unreasonable under the Fourth Amendment. Although the use of a diamond or carbide-bladed saw would have resulted in less damage to the garage floor, the use of the jackhammer was reasonable in order to gather blood samples from beneath the concrete.

The case is Johnson v. Manitowoc County, 2011 WL 814996 (C.A. 7-Wis.)

GREGORY CHANDLER, Attorney at Law

Gregory Chandler on the Texas Journal of Oil, Gas, and Energy Law

The Texas Journal of Oil, Gas, and Energy Law recently announced the creation of the Texas Energy Blog. The blog will address issues of interest to practitioners in the field and facilitate discussion among the energy law community. One can visit www.tjogel.org/blog to view and comment on current entries. Submissions from practitioners are welcome. Daniel Moriarty can be contacted at blog@tjogel.org for information.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler, Attorney, on 101st Airborne Legal Warriors

Greetings:

Our next meeting is tentatively set for 9 September 2011 to 11 September 2011 at the Hale Koa Hotel in Honolulu, Hawaii. The Hale Koa Hotel, Armed Forces Recreation Center may be contacted at 1-800-367-6027. Members may also contact Hilton Hotel reservations for rooms.

Final plans will be made prior to 31 May 2011.

Gregory Chandler

Gregory Chandler, May 1, 2011

Gregory Chandler

Gregory Chandler, Attorney at Law, on Atlanta Airport Litigation

In July 2010, Corey Airport Services was awarded $17.5 million. The federal jury found that the City of Atlanta (Georgia), Clear Channel, and Barbara Fouch, Clear Channel's minority partner, conspired to deprive Corey Airport Services of its equal protection rights while bidding for the advertising contract at Hartsfield-Jackson Atlanta International Airport in year 2002.

The City of Atlanta, Clear Channel and Fouch will share the compensatory damages of $8.5 million equally. Clear Channel was assessed $8.5 million dollars in punitive damages. Fouch was assessed $500,000 in punitive damages.

The case, which was filed in 2004, concerned how the City of Atlanta procures contracts for advertising at the world's busiest airport. Clear Channel and Fouch were first awarded the contract in 1980. Until 1997, the contract stipulated that the City receive 50% of airport advertising revenues. The contract expired, but Clear Channel and Fouch maintained the advertising concession on a month-to-month basis from that point forward. Until 2007, they were paying the 1980 rental rate of 50% revenue.

At the start of trial, Clear Channel and Fouch owed the city $15.6 million in unpaid rental fees due to the month-to-month holdover provision of the advertising contract.

GREGORY CHANDLER, Attorney at Law

Gregory Chandler, Attorney at Law, on Patient Advocates

Training on Patient Advocacy will take place from September 7 to September 13, 2011. The Location is Tucson, Arizona. The fee for the training is $4,600.00.

For more information telephone: (520) 743-7008. You may also get information from:

http://www.patientadvocates.com/


GREGORY CHANDLER, Attorney at Law