We live in crazy times for businesses. Any crackpot with a computer and internet connection can say anything that they want about your business in an online review, on social media, etc. That’s the unfortunate reality for today’s private businesses. The crackpots may even attack the business owner personally. Even worse, there is little you can do to stop it and, in many cases, you can’t even get it removed (I won’t bore you with a treatise on prior restraints of free speech). But do not take a defeatist attitude. Like getting sued, poor online reviews are now just a part of being a successful business. Below are some ideas on how to deal with them.

If you operate your business in such a way as to avoid angering the crackpots, you will get less negative posts. If you treat everyone with the utmost respect and avoid pointless disputes, you will be ahead of the game. At the very least, if you communicate your policies, services, fees, etc. in as much detail as possible, you avoid surprises and avoid upsetting the crackpots. Doing so will also put you in a much better position to defend yourself, either in a court of law or the court of public opinion.

But no matter what, you will still get bad reviews from crackpots, from competitors posing as your customers, or even someone who just doesn’t like you or one of your employees. The more successful you are, the more you become a target. If the review is purely opinion from an actual customer, consider responding to the review in a professional, non-defensive way. Consider what you can learn from the feedback. That doesn’t mean that you have to agree with some or all of the review, each one must be assessed on its own merits. If you believe that the review was not written by a legitimate customer, you should say that as well, and also contact the review service (Yelp, Google+, etc.) to try to have it removed if possible.

If the review or post contains outright lies of factual statements, not just pure opinion (this can be a fine line), or if the review comes from one who is not a legitimate customer, you may have legal claims. You should consult with a lawyer to see if you have actionable claims and what your options are. These could include a lawyer’s letter to the offending crackpot, working with the review service to remove the review, or as a last resort, a lawsuit. Crackpots may think that they are anonymous and that they cannot be sued for writing false statements about a business on-line, but that is simply not true. A lawsuit should be your last resort, but if you are considering it, find an experienced business litigator and discuss your options. You should also consider a public relations professional to deal with the immediate impact on your business. In fact, public relations should be an ongoing part of your business planning.

The above is not meant to be legal advice, but is merely general information.

By Adam P. Whitney, 617.338.7000




You defend a discrimination claim aggressively all the way to trial. The plaintiff wins a technical victory and gets only a small award of damages. So small, that it seems like a win for you. You can live with that, right? But now here comes the employee’s attorney’s petition for fees and costs. If you think that the small award of damages would be a significant factor to determine the award for the attorney’s fees and costs, you would be wrong, at least in Massachusetts. A Massachusetts employer found that out recently, when an appeals court upheld an award of attorney’s fees and costs to the employee of over $100,000, even though the jury awarded the employee only $7,650 in damages. The case is reported as Diaz v. Jiten Hotel Management, Inc., No. 13-1444 (1st Cir. 2013) (this was the third trip to the appeals court for the case).


In fact, the attorneys’ fees and costs could have been much higher. The trial court reduced the amount considerably because the employee had pursued other claims that had no merit and were not successful. The trial court originally reduced the attorney’s fees award because the employee rejected a $75,000 settlement, which would have resulted in the employee’s attorney obtaining a $25,000 contingency fee. However, the appeals court reversed that ruling and stated that it was error to consider the employee’s refusal to settle.


On the most recent trip the appeals court, the court rejected the employer’s contention that the award of fees and costs of over $100,000 was so disproportional to the $7,650 damages award as to be an abuse of discretion. The appeals court rejected this contention and reasoned that, under Massachusetts law, fee shifting statutes are “designed to encourage attorneys to take these types of cases and are based on full compensation for the work performed.” It went on to note that these statutes are designed to encourage suits that will not result in a big fee award because the vindicate important rights.


Thus, the message in Massachusetts is clear. If an employee wins a discrimination suit against you, you could be on the hook for a large award of attorney’s fees and costs, even if the employee wins a very modest award, and even if the employee was unreasonable in rejecting your settlement demand.


What to do? There is no magic bullet. Consider an early settlement of a claim that may have some merit. Keep in mind that even if it is a claim that you may not subjectively believe in, that does not mean the case does not have settlement value. Cases that turn heavily on questions of fact can be decided against you, regardless of what the true facts may be. As Denzel Washington’s rogue cop character said in the movie Training Day, “it’s not what you know, it’s what you can prove.”


In this case, the employer did try to settle, and actually made a very generous (considering the jury award) offer of $75,000. Who knows why the employee rejected the offer. Ironically, the employee would have been much better of with the settlement (assuming a typical contingency fee agreement), but the employee’s attorney presumably ended up better off with the award. Mediation should be strongly considered in these situations. There is no shame in putting a wedge between the employee and her attorney at mediation if it results in a fair settlement to the employee. There may be other options to consider, including an Offer of Judgment. But full-fledged defense of the claim can backfire, because you spend more fees on your own counsel, but also run up the fees and costs of the employee’s attorney. Have a candid discussion with your attorney about how to defend any claim against your company, including the risks of an adverse judgment and an award of attorney’s fees and costs.


By Adam P. Whitney, 617.338.7000



I am re-posting this entry from two years ago, because it is the time of year when employers hold holiday parties or open houses. It’s easy to get caught up in the spirit(s) of the season and to overdo it on the alcohol. Are you putting your firm at risk if an employee or guest drinks too much and causes an auto accident and injures himself or a third person? It depends (that catch-all lawyer answer).

There are a variety of options for employee parties, from providing the liquor yourself at the company premises, having a professional caterer on the premises, renting a function hall, or going to a bar or restaurant. Some of these are safer options than others.

The safest option is a bar or restaurant where the employees and guests are buying their own drinks (the employer could hand out bonus cash that day). Even if the company is picking up the tab, the risk is still low. The crucial issue is control of the liquor. If the restaurant wait staff is in control of serving, your risk of liability for an accident is low. Employers do not have a general duty to act as big brother or sister to employees, especially after work hours. That doesn’t mean that a manager should be forcing shots on employees, as even this safe option has logical limits.

Also generally safe would be to hire a professional caterer either at a function hall or your place of business. But there are a few more guidelines to follow. First, make sure that the caterer is reputable and that the staff has experience serving alcohol. Make sure that the caterer obtains the permits. Make sure that the caterer is properly insured, and get an indemnity agreement from the caterer. Also, find out the plan of service. For example, you would not want employees and guests to have free access to liquor; they must order drinks from trained staff which has the authority to refuse drinks to someone underage or visibly intoxicated. You also should not ignore if drinking is getting excessive, such as drinking games organized by an employee. Check with your own insurance agent to see what coverage you have if you do get sued (speaking with your insurance professional is always a good idea).

The biggest risk is when the employer provides the alcohol and serves the alcohol. This fully opens the door to liability if you over serve someone who causes an accident. Although this may be a money-saving option, I would advise against it. It’s very easy for employees to get carried away at these events, and you don’t want to be in a position of either being the wet blanket or worry about liability.

Of course, you should remind employees ahead of time to be responsible and to designate a driver. Better yet, if the company could possibly provide drivers or promise to reimburse cab fare, that’s all the better all the better. In addition to preventing liability, you should of course care about the well-being of employees and innocent third parties. You don’t want to be sued, and you don’t want your company name in the paper because your employee killed someone after a wild party. Also think about the devastating effect on morale if something happened.

A topic for another day is the risk of sexual harassment at firm parties (or even “date rape”, as was alleged in one case). I hope I have not taken all of the fun out of the holiday season. As always, the above is general information, not legal advice.

By Adam P. Whitney 617.338.7000


Reflecting on Owning A Business

Posted: December 17, 2013 in Uncategorized




Fair warning, this is a self-indulgent off topic post. The end of the year is approaching, and I’m reflecting on my first nine months of starting my own law firm, which focuses on employment law and business litigation for private businesses.  Here’s what I have learned from nine months in business:



  1. You can’t do it without good clients. Make them happy and they’ll make you happy. I intentionally made this the first item.  I want to take this opportunity to thank my clients, most of whom read this blog. I literally could not have done it without you.

  2. You need trustworthy help. I’m talking about employees, colleagues, accountants, vendors, contractors, bankers, insurance agents, etc. Find good people to help you and return the favor by treating them fairly/paying them on time/referring them business/etc.

  3. Word of mouth is still the best marketing, at least for lawyers. I’ve done almost no marketing other than networking with colleagues (and, I suppose, writing this blog). 98% of my business comes from repeat business and referrals and other word of mouth.  I’ve been steadily busy since starting, and I hired two employees and expanded my office space and equipment.

  4. You must embrace the latest technology. Although there can be some time getting up to speed on new programs and ways of doing things, it’ll be well worth it in the long run. You may feel comfortable doing things the “old way,” but you will increasingly be at a disadvantage. Worse yet, people will laugh at you and make jokes about typewriters (we do this behind your back).

  5. Running a business is hard work. Of course I knew that before, because most of my clients are businesses.  But you don’t really appreciate all the important things that business owners must routinely do that take you away from your core functions – get insurance, do payroll, pay taxes, accounting, pay bills, pay fees and dues, manage employees, deal with vendors – there are dozens of things. Unfortunately, this blog has suffered at times due to all of these demands.

  6. Being a business owner is meaningful and rewarding. Private businesses keep the economy rolling and provide crucial services to the public. They don’t get bailouts or have teams of lobbyists in Congress. They operate both out of necessity to earn a living for the owners – capitalism at its purest – and because they love what they do. I’m proud to play a very small part in all that as a business owner, and by serving private businesses. It is also very rewarding to be “my own boss” and to do things the way I think that they should be done. I like to joke that “my boss is the best,” but I do hope that he gives me a few days off over the holidays.

By Adam P. Whitney, Law Office of Adam P. Whitney, 617.338.7000


This may seem obvious, but why do companies still do it? I’ll start with a few vents of my own of things that annoy me.

Jingles. I despise corny company jingles that are played repeatedly on the radio, tv and even Pandora. Although not technically a business, the worst offender is 1-877-kars-4kids. It may be a great cause, but why would I donate to you when your jingle grates me every ten minutes or so on the radio? Can’t you just talk to me without singing to me? It’s not just me, the jingle has been called the “most annoying sound in the world: http://www.youtube.com/watch?v=nEL8dGQj3I4. Google “I hate kars 4 kids” and you’ll see that many people are driven to drinking by the jingle.

Loyalty Cards. I Googled “I hate rewards cards” and had over 6 million hits, so I’m not alone. I credit Shaws for dropping these awful things. I will now shop there again. I won’t shop at CVS. Recently, Walgreens has gotten into the act, which is too bad because I like the new ‘greens in Downtown Boston. Doesn’t everyone hate to carry these cards (not to mention the invasion of privacy)? We are moving to simpler transactions, such as Level Up. Why do these stores compel us to dig through our wallets. And if you don’t carry them, you are being overcharged.

Maybe big businesses like CVS and Walgreens can get away with annoying their customers. Your private business probably cannot. As for service professionals, like lawyers, don’t nickel and dime your clients. Lawyers, for example, charge plenty per hour. Consider routine copies, faxes, phone calls and postage part of your overhead and not a profit center. And don’t talk down to your clients.

Do the opposite of annoying clients. Virtually all businesses would do well to be friendly and warm. This struck me this morning when I had my shoes shined at Colonial Shoe Repair near my office. The owner, Gret, introduced himself, asked my name and shook my hand. The shoe shine was great and at a fair price, but it was the personal attention that really sets Greg apart. I looked up the company, and not surprising Greg has a number of raving fans: http://www.yelp.com/biz/colonial-shoe-repair-boston

Is your business unwittingly biting the hands that feed it? Take a step back and try to put yourself in your client’s position. Ask your clients for feedback. Do random surveys. Ask what you are doing right or doing wrong. If you are just standing still and not listening and improving your product or services, your competitors will be passing you by.

By Adam P. Whitney



This sounds crazy, but hear me out. I’ve seen many private businesses suffer because they have excessive dead weight, or worse, on the staff. These people may be your good friends. If you work together in smaller private company, it is inevitable that you will become friendly with and deeply care about your employees. You may even have people working for you who are related by blood or marriage. You feel trapped and that you cannot fire such people.

It’s extremely hard, I know. But you are running a business. Act like Bill Belichick and take the emotion out of personnel decisions. If David in outside sales wasn’t your buddy from college, would it make sense to keep him employed when your business shifted focused to inside sales? Ask yourself another way. If David quit tomorrow, would you replace him? If you say “no,” you know the right thing to do. Even if you would replace his position, would you replace him with a carbon copy, or are you pretty sure you would do a lot better. That makes it an even tougher call, but if David is incompetent, he’s hurting your bottom line every day.

I’m not trying to sound like the grim reaper of employment law, but you should assess all of your employees at least once a year. Don’t fire people just because you think you could do a little better (if you are sure you could do a lot better, that’s different). You may be wrong about that, and you will destroy morale. But each position should make economic sense to your bottom line. If you keep an employee who should be terminated just because they are your friend, both your company and your friendship will ultimately suffer. You will inevitably be bitter toward that employee, even if it is subconscious, and start treating them differently. Things could get ugly on both sides. “Good deeds” never go unpunished in my world.

Isn’t it better to be up front with people and explain the economic realities of their position and the company? Most employees take being fired personally, but you have some control over that. Along with a real explanation, give them fair notice and whatever they need to transition to their next position. Consider giving some severance. Consider transferring them to another position or modifying their current position. But don’t keep your son-in-law on as a V.P. if he’s not earning his keep. You would be better off just gifting the money and not making other employees bitter. Believe me, employees know who the favorites are; they also know who the deadweight is, and they will definitely be bitter about it. They will respect you – maybe even applaud you – for making the tough/right decision.

By Adam P. Whitney


I written before about how an employer can be damned when supervisors have sex with employees: https://damnedif.com/category/sexual-harassment/.


But being obsessed and pursuing a relationship can be just as damning. Take the recently-reported case at the Massachusetts Commission Against Discrimination (“MCAD”) MCAD v. Illumina Media. The employer is on the hook (subject to potential appeals) for a sizable award because, the MCAD found, one of the company’s owners made repeated sexual advances to a female employee, even though she repeatedly rejected them. This was the case even though, the MCAD found, the female employee actively participated in a sexually charged workplace atmosphere, where sexual innuendo and horseplay were commonplace and people looked at pornographic images on the internet.


The case reads like a made-for-TV movie of the week. The female employee started at Illumina as a 24 year old. According the case report, the company owner was at first friendly, but soon started to make comments about his sexual prowess with much younger women, and then suggested that he and the victim were “on a date.” The employee thought that these comments were strange and inappropriate, and would often reply that “it’s not happening” or “it will never happen.” Undaunted, the owner continued his pursuit, according to the report, and escalated the behaviors by explicitly asking for sex on a number of occasions, which the employee refused. The actions went downhill from there, according to the report. You can find a link to the decision here: http://www.mass.gov/mcad/documents/MCAD%20&%20Brooke%20Anido%20vs%20Illumina%20Media%20LLC%20dba%20Illumina%20Records%20&%20Ronald%20Bellanti.pdf


It does not appear that Illumina strongly or effectively contested that the owner aggressively pursued a sexual relationship with the employee. The MCAD Hearing Officer found Illumina and the owner liable for quid quo pro sexual harassment (generally thought of as conditioning a job or employee benefits on succumbing to sexual advances) as well as for constructive discharge. The MCAD reasoned that by treating the employee differently after she rejected the owner’s sexual harassment, Illumina could be held liable for quid quo pro sexual harassment. The decision was upheld after an appeal to the Full Commission of the MCAD.


Illumina and the owner were ordered to pay $75,000 in emotional distress damages and nearly $10,000 in lost wages. These two figures are subject to 12% interest from the date of filing the Complaint, which was a staggering six years prior to the decision of the Full Commission. Thus, interest will run at about 71%, adding $60,000 to this figure. The defendants are also liable for the employee’s legal fees and costs of over $62,000. Assuming that Illumina spent a similar amount on legal fees, the total out of pocket for the company appears to be at least $270,000, barring any further appeal.


While the facts here appear to be fairly egregious, the case should serve as a warning to all employers. Owners and managers, as human beings, will inevitably be attracted to subordinate employees. If you are a company of any significant size, there is no doubt that there are such attractions occurring right now at your business. You need to train all of your managers on how to deal with these issues (a subject for another post), or you could be on the hook for $270,000 or much, much more. Mangers and owners can easily fall into the trap of thinking that a loose environment means that anything goes in the workplace. But this case proves that such thinking can lead to big trouble.


By Adam P. Whitney


Guest Post by Eve Pearce


The customer is always right. This sentence has become a motto for businesses small and large all over the world. However, it seems that not all companies believe in this simple statement any more. In fact, the large companies seem to be falling into the ego trap. They are too big to fail. They have enough customers, and therefore can afford to be unpleasant to the small minority who dare query an issue or problem with the service they receive. It is commonplace now for people to complain about time spent on the phone waiting for an answer from a generic, anonymous call center, only to be fobbed off and sent on their way. That is not customer service. That is customer disservice. The examples are many and varied, but we all have memories of poor treatment received from large companies.


Remember Your Internal Customers

It isn’t all about the commercial customer, however. When you run a business, your customers are represented by many different people. Don’t forget your internal customers. These are your employees, your colleagues, the people who work on casual contracts to complete smaller jobs less frequently. The internal customer is just as important as the one who pays for your service or products. Think about it. Without people to do the work for you, things would not get done. You would flounder around, struggling to do several hundred jobs at once, and you would fail miserably in your business venture. You need people that will work for you, with professionalism and willingness to help out when they are needed. It takes more than just financial incentive to keep these people happy. But it also doesn’t take much more effort to show some appreciation. You could try offering corporate gifts to your customers, and you can find a wonderful selection at websites including http://www.solo.co.uk/. Here you can purchase items that are personalized for the people you wish to reward, and you can find some excellent value offers to keep your costs low.


Give Them Something Pretty

People love to receive gifts. It doesn’t matter what they are. As a customer of other companies large and small, think about the last time you received a free item. How did it make you feel? What was it? You probably received a meager pen emblazoned with the company details of the business you were buying from. It didn’t matter. They gave you something for free, and that was fantastic! Yes, you are aware that these pens are not limited items, and that they are probably sent out in their thousands to all the other small-fry customers like yourself. But that’s not important. The company made an effort to show that they care. They gave you a small token of their appreciation for you, the individual, and they also cleverly ensured that you would not forget about them any time soon. Your pen will be very useful on a daily basis, and you will see their logo every time you pick it up.


Small Beginnings Lead to Big Business

Of course, it takes a little more than material items to keep people happy. But offering free gifts to your customers and employees certainly goes a long way towards keeping their attention focused on your business as opposed to someone else. We are a magpie nation. We like pretty items, we enjoy tactile products, and things that we can collect and admire. It is human nature to appreciate things that we create, and you can bring this simple psychology into your business plan. Perhaps you could keep a selection of gifts specifically for your customers. You could mix it up a little, and send out pens, pencils, notepads, mugs, or even larger items depending on the importance of the individual customer to yourself and your business. Let’s face it, we are here for the money. The more they pay, the more you appreciate them. So reflect that in the gift that you offer. But don’t forget your smaller, less well known customers. They could become very important to you one day, and you do not want to lose them to your competitors. Be nice, be generous, and remember, treat people in the same way that you wish to be treated. Kindness, understanding, and appreciation will go a long way when building good business relationships.

Guest Post by Eve Pearce

It is no secret that the modern day office is a fast-paced and often stressful place to be. The world never sleeps, we often work in 24-hour operations, and vacations seem few and far between. Men and women work together, often in direct competition, trying to prove themselves and their worth so that they can feel secure in their jobs. Sometimes they fall into easy friendships, and sometimes even a little more than that. Office romances are commonly reported around the world, but can they sometimes be detrimental to your business? Perhaps it is worth considering putting a policy in place that protects your business, should any of your employees become romantically involved. If you don’t, there is a high possibility that your staff members might begin to report sexual harassment or inappropriate behavior  as tempers rise and colleagues become irate with the behavior of those around them.

Office Politics Leading to Addiction Problems

Aside from office romances, there are lots of other stress factors that can lead people into dangerous territory. The news media is beginning to report more cases of employees succumbing to alcohol and drug addiction, often as a coping mechanism when the stress of their job becomes too much. This problem is widespread around the US and beyond, but fortunately there are lots of places and organisations where people can receive treatment, counselling and support to move on from their addictions and return their chaotic lives to some semblance of normality. One such area that is offering addiction treatment is in Florida. There are lots of Florida treatment centers offering services for rehabilitation, ranging from alcohol abuse to drug addiction, and even to more diverse and obscure addictions related to stress. You can find the right center for you personally, and decide whether to take part in a residential program, or something more casual.

Stress in the Workplace

Stress in the workplace has been downplayed for many years, and most employees are loath to admit when they are struggling with their workload. Some fear for the security of their jobs, while others simply worry that they will be seen as weak minded and might be ridiculed by their peers. The stress creeps in slowly at first. You might find yourself working late into the evening, often without realizing  as you frantically try to finish the tasks assigned for that day. You might find yourself bombarded with issues and problems in a short space of time, and as quickly as you resolve one, another two or three take its place. Your colleagues might appear to be dealing with the same sort of problems, so you don’t want to burden them further by asking for help. Or you feel that you have to complete the tasks and resolve the issues by yourself, or risk being held to account by your managers and supervisors.

It is events like these that can often lead people down the route towards addiction. Traditionally addiction is associated with drugs and alcohol, but during recent years there has been more information emerging about different addictions. Office employees in particular seem more susceptible to various addictive behaviors and hobbies, including shopping, gambling, and even pornography. These are things that can be kept hidden for many years, and only emerge when the addiction becomes too much for the individual to deal with. An obsessive shopper or gambler is likely to run up massive personal debts, sometimes risking the security of their home and vehicle in the process. Someone addicted to pornography risks either becoming a social recluse, or possibly worse if their peers discover their hidden activities. Any of these addictions can lead to problems in the workplace, as well as being brought about by such problems.

Business Owners Take Responsibility

Ultimately it is important for the business owner and management team to remain aware of the dangers of addiction. They have to remember to show support for their employees, and be willing to offer assistance for any who appear to be struggling or who take a lot of time off sick. There is usually a genuine reason for the poor performance of an employee, or even for a perceived attitude problem, and so it is more constructive for the management team to work through such issues with the individual, and find a way to resolve them, rather than simply dismissing the employee and moving on to the next. A business will operate far more productively when it is maintained by a happy, integrated and supported team of employees. 

Lawsuits happen. That’s true for any successful business, even if you take my litigation-avoidance advice in this blog. While you cannot prevent all lawsuits, there are steps you should take to minimize the damage and headache when the summons and complaint arrive at your office door. In fact, if you know that the lawsuit may be coming, you can do some of these things before you are served with the lawsuit.


First, train your office staff on how to deal with deputy sheriff’s and process servers who come calling. This may seem like a no-brainer, but companies get defaulted and pay large judgments because a receptionist put court papers in the circular file. You normally have only 20 days to respond to a lawsuit. Sometimes that time can be greatly reduced by a judge’s order, so it’s important that you get and read the documents right away. Conversely, if the suit papers are directed at an owner personally or an employee, there may not be any obligation to accept them, or to call the individual to the front to be served. Each situation is different, so discuss this with your lawyer.


Start making phone calls. You know I am going to tell you to call your lawyer asap. That’s not just self-serving. Your lawyer can advise you on what other steps to take. She can also quickly find out what is happening at the court by checking the docket, and can contact opposing counsel if need be. You should also notify your insurance carrier. You may have be pleasantly surprised to learn that you have some coverage. Keep in mind that your insurer may defend the case pursuant to a “reservation of rights.” This means it can try to disclaim coverage later, or it might only cover the costs of defense. In Massachusetts, this also means that you can pick your own lawyer rather than using the insurance carrier’s lawyer. Although some insurers are loathe to tell you this, when they defend under a reservation of rights in Massachusetts, you can pick your lawyer and the insurer will pay reasonable attorney’s fees.


Put your normal document destruction/retention policies on hold. You have an obligation to save relevant paper and electronic documents that may be related to the claims and defenses. In my experience, a missing document can be more problematic than an unfavorable document. The jury will always think that you intentionally destroyed a document and will, usually with the judge’s blessing, use it against you. It’s human nature to think that the missing document would be a lot more important than it really were if it were produced.


You and your attorney may want to start investigating the facts as soon as possible. There are certain strategies, within the bounds of ethics, to pin down certain witnesses before the other side obtains their depositions or otherwise speaks to them. I’m not going to give up all the tricks of the trade here.


Finally, come up with a strategy to defend the case. Lawsuits can sometimes be like a game of chess. If you and your attorney can think through the case from start to finish, predict your opponent’s moves, and plan your own moves and counter-moves, you’ll put yourself in a better position to win.

Don’t take a defeatist attitude.  Think of getting sued as part of the cost of doing business.  Approach it head on like any other business problem.  With some planning and some smarts, you may be able to minimize the distraction and damages.

By Adam P. Whitney