Eight United States Senators Implore NCAA to Adopt ‘Uniform Policy’ on Sexual Assault

On the heels of the NCAA’s Board of Governor’s recent policy announcement requiring college coaches, athletics administrators and student-athletes to be educated in sexual violence prevention, eight United States Senators have forwarded a letter to the NCAA’s Commission to Combat Campus Sexual Violence.

The letter from Richard Blumenthal, Robert Casey, Jr., Al Franken, Kirsten Gillibrand, Margaret Hassan, Jeffrey Merkley, Patty Murray, and Ron Wyden

requests that the NCAA develop a “uniform policy” to formally address all prospective and current student-athletes possessing a history of sexual violence to protect all students, regardless of what college they attend.

The Senators’ letter addressed the “alarming rate” of sexual violence on college campuses.

While they recognized the challenges that NCAA member conferences and colleges face to balance student-athlete accountability, they emphasized ensuring that all students are safe on campus.

The letter acknowledged the specific steps taken by the Pac-12 conference and the University of Oregon to restrict transfer student-athletes from receiving athletic aid and participating as a student-athlete if they are unable to re-enroll at the previous school they attended because of prior misconduct while attending that prior school.

The Senators also commended Indiana University for creating a policy that makes all potential student-athletes subject to a policy that makes any athlete who previously had been convicted or pled guilty to a sexual violence felony or been held responsible for sexual violence by any university’s formal discipline policy ineligible for any athletic aid and intercollegiate competition. The Indiana University policy is believed to be the first Power Five conference school enactment to formerly ban student-athletes for sexual violence.

The NCAA has not issued a formal public response to the Senators’ letter.

 

New Sexual Violence Prevention Education Policy Adopted by National Collegiate Athletic Association

Coaches, athletics administrators, and student-athletes must be educated in sexual violence prevention under a policy adopted by the National Collegiate Athletic Association (NCAA) Board of Governors on August 8, 2017.

The new policy provides that annually, every member institution’s president or chancellor, athletic director, and Title IX coordinator will be required to attest that the school’s:

  • Athletic department is “knowledgeable about, integrated in, and compliant with institutional policies and processes regarding sexual violence prevention and proper adjudication and resolution of acts of sexual violence”;
  • Policies and procedures are distributed to all student-athletes; and
  • Policies and procedures are readily available in the athletics department.

The new policy, however, does not impose any requirements with respect to bans or restrictions on the participation in athletics of individuals accused of, or found responsible for, violations of policies against sexual violence. Institutions continue to have discretion with respect to those determinations.

NCAA member institutions should review their training and awareness programs to ensure that all members of the athletics department, including staff and student-athletes, are educated about sexual violence prevention, bystander intervention, the institution’s procedures for filing and adjudicating complaints of sexual violence, and the resources available to support and assist those who have been affected by sexual violence. Athletic departments should consider including the institution’s policies and procedures relating to sexual violence in their student-athlete handbooks.

Jackson Lewis attorneys are available to assist you in evaluating, designing, and delivering training programs to meet the new requirements.

NCAA’s Statement on Student-Athlete Side Hustle Raises Questions

University of Central Florida Kicker Donald De La Haye has been deemed ineligible because of compensation he earned from his YouTube videos. UCF submitted a waiver on behalf of De La Haye requesting that he remain eligible while continuing to create videos. The waiver was granted, but with conditions. The NCAA’s conditions were that De La Haye could not monetize any videos that referenced his status as a student-athlete or depict his football skill or ability. De La Haye declined these conditions and was ruled ineligible.

On July 31, 2017, the NCAA issued a statement on the De La Haye decision that may have significant implications for the “student-athlete” debate:

Although Donald De La Haye has chosen not to compete any longer as a UCF student-athlete, he could have continued playing football for the university and earn money from non-athletic YouTube videos, based on a waiver the NCAA granted July 14

 

Contrary to misperceptions, making a YouTube video – and even making money off of it – is not a violation of an NCAA rule. Further, years ago the membership gave NCAA staff the ability to review situations like these on a case-by-case basis, consistent with previous actions.

After the national office received the waiver request from UCF July 12, that process was used to confirm that De La Haye could monetize his video activity as long as it was not based on his athletics, reputation, prestige or ability.

Although these issues are evaluated on a case-by-case basis, the NCAA has effectively indicated that student-athletes may make money off of “non-athletic” YouTube videos. This creates more questions than answers. What constitutes a “non-athletic” YouTube video? When is it based on an athlete’s “reputation” or “prestige”? Is a higher-profile student-athlete more restricted than other student-athletes because of a built-in “reputation” or “prestige”?

Consider this hypothetical: If during his time at the University of Florida Tim Tebow created a YouTube page devoted to various topics, including his values, work ethic, and religious beliefs, would he be able to monetize it? At the time, he was the most famous student-athlete in the country and his YouTube page would be popular, in part, because of his “reputation” and “prestige.” What if the content has nothing to do with his role as a student-athlete? What if the content is tangentially related to his approach to athletics or his life as a student-athlete?

Notwithstanding its statement, the NCAA’s bylaws still prohibit accepting pay to promote commercial products or services, being paid “at a rate higher than the going rate” based on athletic ability, reputation, fame or “personal following,” See e.g., NCAA Bylaws 12.4, 12.5.

Under the bylaws, it would be difficult to quantify whether an athlete is paid “at a rate higher than the going rate” based on remuneration from a YouTube video.

Is it because of the athlete’s fame? Personal following? If it is, can the NCAA quantify the “higher rate”? Is the student-athlete entitled to the potential compensation he would receive if not for his fame? It is virtually impossible to make this determination. The NCAA will have to evaluate whether a video “deserves” the attention it receives. Does Donald De Lay Haye have almost 100,000 followers because he was the Kicker for UCF? Do these followers need to be surveyed? Even under the NCAA’s bylaws, it is a slippery slope to start making determinations as to whether student-athletes are monetarizing their status as college athletes under similar circumstances.

The question now is whether student-athletes will take advantage of the possibilities presented by the NCAA’s statement. They may be able to carefully market themselves to earn compensation while maintaining eligibility. Another question is how these principles will apply to other mediums in which student-athletes can be compensated for “non-athletic” endeavors.

Finally, what happens if a school does not seek a waiver as UCF did with De La Haye? And, what if they do not seek a waiver based on the NCAA’s statement in this situation? What is clear, however, is that the NCAA and colleges will continue to face these issues.

 

 

 

Former Big League Pitcher Awarded More than $1.5 Million for Wrongful Termination

A New Jersey jury in the Superior Court of New Jersey for Camden County has awarded former Major League Baseball pitcher Mitchell Williams $1,565,333 in a wrongful termination action he filed against MLB Network, Inc. Mitchell Williams v. The MLB Network, Inc., et al., No. L-3675-14.

Williams, nicknamed “Wild Thing,” played professional baseball from 1986 until 1997, and was an All-Star in 1989. Over the course of his career, Williams played for the Philadelphia Phillies, the Texas Rangers, the Chicago Cubs, the Houston Astros, the Kansas City Royals, and the California Angels. In 2009, Williams became a major league baseball studio analyst for MLB Network. In 2011, Williams signed a new five-year contract (with an option for a sixth year) with MLB Network, but his employment was terminated in 2014.

In September 2014, Williams sued MLB Network and Gawker Media Group Inc., alleging that Gawker erroneously reported that, during a May 2014 Little League baseball tournament, Williams cursed out a child while coaching his 10-year-old son’s Little League team, ordered one of his son’s teammates to hit the opposing pitcher with a beanball, and was ejected from the game for arguing and cursing.

Williams’ action further alleged that, following the erroneous Gawker reports, MLB Network: (1) issued public statements that suggested Williams had admitted to the reported misconduct at the Little League tournament; (2) forced Williams to take a 30-day leave of absence from MLB Network; (3) threatened to terminate Williams’ employment unless he signed an amendment to his contract agreeing not to coach or attend any of his children’s Little League baseball games, go to therapy, and get approval before posting any pictures on Facebook; and (4) terminated Williams employment when refused to sign the amendment. Williams claimed that, as a result of MLB Network’s and Gawker’s conduct, he also lost jobs with MLB.com, Sports Network, and Fox Sports.

The case went to trial in June 2017. After an 11-day trial, the jury rejected MLB Network’s claim that Williams had violated a “morals clause” in his contract. The jury found that MLB Network wrongfully terminated Williams, and breached his contract, when it fired him based on the Gawker stories. The jury then awarded Williams $1,565,333 in damages. Gawker Media Group Inc. filed for bankruptcy, and was dismissed from the case, in 2016.

This case serves as a reminder that employers should act cautiously and carefully before taking adverse employment action against an employee based on negative reports from third-parties. When possible, employers should conduct their own follow-up investigations, and assure themselves of the accuracy of any negative reports, before relying on them.

As Williams v. The MLB Network makes clear, if the third-party’s report is inaccurate, the employer may end up paying the price.

The attorneys at Jackson Lewis routinely work with employers conducting internal investigations and reviews. If you have any questions regarding these issues, do not hesitate to contact Jackson Lewis.

 

Pacific Pro League To Provide Amateur Football Alternative, Glimpse Of Value Of College Athletes

NFL agent Don Yee, longtime representative of Tom Brady, and a list of football notables including ESPN’s Adam Schefter and two-time Super Bowl winning coach Mike Shanahan intend to form the Pacific Pro Football League (“PPFL”) with four teams in the Southern California region and commence league play in the summer of 2018. Not seeking to compete with the NFL,

the burgeoning league seeks to create a new feeder-system to help develop the next generation of NFL stars.

The PPFL, in theory, aims to compete with amateur football organizations, such as the NCAA, National Junior College Athletic Association (“NJCAA”), California Community College Athletic Association (“CCCAA”), and National Association of Intercollegiate Athletics (“NAIA”), rather than the NFL.

The PPFL will only be open to football players who are up to three years removed from high school. This means the PPFL’s eligibility age restrictions coincide with the NFL’s current restrictions which mandate that players must be three years removed from high school graduation or 21 years old in order to be eligible for league competition. Currently, the 18-21 age group of football players competes almost entirely in amateur football. High-profile student-athletes enroll almost exclusively in “Power Five” or “autonomy” institutions, and those who fail to academically qualify for Division I or otherwise render themselves ineligible compete in varsity competition for junior college or NAIA institutions.

In recent litigation involving the NCAA and the NFL Players Association (NFLPA), the NCAA has faced legal challenges to its amateurism model. The NCAA and NFLPA have had the NFL’s age restrictions challenged in court. The principle at the crux of these lawsuits is that high-profile student-athletes in football are economically valuable and deserve to be compensated fairly. Media narratives have hammered home this sentiment, as the NCAA often has been cast as an entity that has exploited high-profile football student-athletes for economic gain.

In theory, the PPFL will test both the economic value of football players who are disqualified from being compensated as NFL players, and the economic value of participation in NCAA, NAIA, and junior college athletics.

Should the PPFL attract high-profile football players as it hopes, some of the questions raised in recent litigation regarding the actual value of high profile college football players will be answered. Consumer interest in the PPFL may demonstrate if consumers are drawn to college football because of the institutions or the spectacle of amateur competition, or if consumers are interested because of the quality and appeal of the players themselves.

Additionally, whether high-profile players choose to join the PPFL will demonstrate the value of participation in college athletics. The PPFL intends to pay all of its players around $50,000 annually and provide vocational and internship opportunities, workers’ compensation packages, and insurance coverage. Whether these are enough to lure the most elite football players away from Power 5 programs remains to be seen, but it could be argued that the value of scholarship, cost-of-attendance, insurance, training, coaching, disability insurance, and additional benefits that Division I programs are able to offer appears to be of equal or greater economic value.

Perhaps the PPFL’s most significant competitor for talent will be the junior college associations and the NAIA. In basketball, some elite prospects who did not qualify academically for Division I competition have decided to turn to international professional leagues or the National Basketball Association Development League (NBDL). If an NBDL-like alternative exists for football, what option will future non-qualifiers choose?

 

National College Players Association Urges Prospective Student-Athletes To Negotiate Scholarship Terms With Colleges

The College Athletes Players Association (CAPA) and Executive Director Ramogi Huma’s (Huma) efforts to unionize the Northwestern University football team failed when the National Labor Relations Board refused to rule on the legal ability of these student athletes to form a union. Huma has now shifted his focus to working with the National College Players Association (NCPA) in an effort to impact the relationship between student-athletes and colleges with the creation of the College Athlete Protection Guarantee (Guarantee) and the College Athlete Protection Agreement (Agreement).

The Guarantee and the Agreement were recently introduced at the National Basketball Players Association’s camp held at the University of Virginia for the top 100 rising high school senior basketball players. The Guarantee encourages these highly recruited basketball recruits and other student-athletes who are being recruited to play college sports to use their leverage to request and negotiate issues like their right to secure medical treatment and insurance beyond the years of collegiate athletic eligibility and to seek an automatic scholarship release if they decide to transfer to another university.

The Guarantee claims that student athletes can secure additional protections and benefits that could be worth over $100,000 more than minimum scholarships without breaking any NCAA rules. The Guarantee encourages transparency on protections and benefits because Huma claims coaches often break verbal promises and stated,

“Coaches themselves don’t rely on verbal promises from their college and neither should you.”

Huma further asserts, “..this will change things. This is a good place to start. It opens a Pandora’s Box.”

The Agreement, already vetted by NCAA experts according to Huma, can be used instead of the National Letter of Intent (“NLI”) or in conjunction with the NLI. The additional protections and benefits that Huma and the NCPA encourage student athletes to seek are:

  • Guaranteed multi-year scholarships that cannot be terminated
  • Summer school scholarships
  • Degree completion scholarships to provide continued financial support to complete undergraduate degrees if athletic eligibility has expired
  • Stipend and reimbursement money in excess of NCAA “full” scholarship coverage
  • Medical expense coverage for 100% of all premiums and sports-related expenses, including deductibles and copays
  • Transfer releases
  • Disability Insurance

Tom Nevius, a former NCAA associate director of enforcement, has been serving as an advisor to Huma and the NCPA suggested,

“This has a chance to be successful if you find a coach or a school who is interested in bringing in a top prospect.”

 

 

 

Visa Options For Athletes

In these days of “extreme vetting,” entering the United States as a business visitor (B visa or Visa Waiver status, with an ESTA approval) can have its hazards – especially for athletes who need to enter the United States quickly and have no time to spare. [Link to blog on extreme vetting: http://www.globalimmigrationblog.com/2017/05/state-department-proposes-supplemental-questions-for-visa-applicants/ ]

Earlier this year, three Belgian Olympians of Moroccan descent heading to the 2017 Taekwondo U.S. Open in Las Vegas had their ESTA status denied as they attempted to board a plane. [Link to article: https://www.moroccoworldnews.com/2017/02/207237/belgian-athletes-moroccan-descent-refused-entry-united-states/ ]

In February, a Canadian-born student-athlete of Moroccan descent travelling with his team was denied entry at the Vermont border crossing. [Link to article: http://www.cbc.ca/news/canada/montreal/another-canadian-citizen-refused-entry-united-states-border-1.3976230 ]

Enhanced security screening is not the only issue. The Trump Administration also wants to ensure that individuals are not circumventing immigration processes and inappropriately entering in visitor status.

For a professional athlete to enter successfully as a business visitor:

  • The entry must be for a specific, limited time (up to 90 days for Visa Waiver and up to 180 days for B-1/B-2 entries);
  • The individual must have sufficient funds to cover expenses during the stay;
  • The individual must prove ties abroad and have a residence outside of the U.S. he or she has no intention of abandoning; and
  • Except in limited circumstances, the foreign national should receive no U.S. remuneration (other than reasonable expenses).

Prize money is an exception to the “no U.S. remuneration” rule. According the Foreign Affairs Manual, “professional athletes such as golfers and auto racers, who receive no salary or payment other than prize money for . . . participation in a tournament or sporting event” may enter in business visitor status. The same holds true for athletes or team members who seek to enter to compete with another sports team, provided:

  • The foreign athlete or team have their principal place of business or activity in a foreign country;
  • The income of the foreign-based team and the salary of its players are principally accrued in a foreign country; and
  • The foreign-based sports team is a member of an international sports league or the sporting activities involved have an international dimension. [Link to FAM: https://fam.state.gov/fam/09FAM/09FAM040202.html ]

An athlete also can enter as a business visitor to try out for a professional team and individuals who are a “normal and necessary component of the athlete’s entourage,” such as caddies or racing car mechanics, may enter as visitors (and continue to be paid by the athlete), as long as the individual is:

  • Customarily employed by the athlete (not just hired for the particular U.S. tournament or tour); and
  • The athlete is receiving no payment other than possible prize money.

Athletes entering the U.S. for a tournament, but who also have valuable U.S. endorsement deals, should consider applying for a P visa to avoid having the remuneration they receive for the endorsements not fit the “prize money” exception.

To qualify for a P visa, the athlete must provide proof of having an “internationally recognized reputation in the sport.”

USCIS statistics released in response to a FOIA request reveal that in 2016, the California Service Center had an 88% approval rate for P visas and the Vermont Service Center had a 90% approval rate. Both California and Vermont had about a 22% Request for Evidence rate. (Vermont Premium Processing had a slightly lower 17% rate.) In California, the after-RFE-approval rate was 46% for regular processing and 65% for premium processing. In Vermont, the after-RFE-approval rate was 28% for regular processing and 75% for premium processing.

The USCIS announced that, as of May 20, petitions for P status for beneficiaries who will be working or training in the popular training states of Florida, Georgia, or North Carolina must be filed with the California Service Center, instead of Vermont. P major league sports-related petitions, however, will continue be filed with the Vermont Service Center. [Link to USCIS announcement: https://www.uscis.gov/news/alerts/new-direct-filing-addresses-l-o-and-p-nonimmigrant-petitions-beneficiaries-florida-georgia-and-north-carolina ]

For more information on how to apply for P-1 status or an other immigration questions, please reach out to your Jackson Lewis attorney.

 

NCAA Baseball Coach Fired After Only One Season Following Scholarship Controversy

Alabama baseball coach Greg Goff was fired after one season at the helm of the Crimson Tide baseball program after a disappointing 19-34-1 overall record and a 5-24-1 record against Southeastern Conference competition.

However, despite the team’s poor performance and lowest overall win total since 1980, it is believed that Coach Goff’s reported decision to try to revoke scholarships for several of his players was the catalyst that led to his termination. Non-renewing or reducing the Alabama baseball student-athletes athletics scholarships on the basis of athletics performance would have likely violated current NCAA bylaws.

Coach Goff had allegedly informed as many as 10 returning scholarship players during exit meetings following the end of the season that their athletic scholarships would not be renewed for the next school year.

In 2015, NCAA autonomy schools (frequently referred to as members of the Power 5 conferences and Notre Dame) voted to impose a more restrictive version of the longstanding NCAA bylaw which allows Division I schools the freedom to non-renew or reduce its student-athlete’s scholarships for athletics-based reasons.

While non-autonomy schools who have not voluntarily chosen to opt-in to the 2015 autonomy rule are still free to terminate or reduce scholarships in the manner that Coach Goff allegedly threatened, Alabama is subject to the more restrictive rule which prevents such an action. 

A number of NCAA bylaws should be reviewed and considered in the context of potential scholarship reductions or cancellation.

Autonomy and non-autonomy institutions are similarly bound by NCAA restrictions that prevent the institutions from reducing or terminating an award for athletics-based reasons during the term of the scholarship award.

Certain NCAA bylaws only apply to autonomy schools and non-autonomy schools that elect to follow the rule.

NCAA Bylaw 15.3.5.2 is an example of such a bylaw. 

It only applies to autonomy schools (like Alabama) and non-autonomy schools who have elected to follow the autonomy rule. This bylaw restricts those institutions from reducing scholarship amounts during the period of the scholarship award for athletics-based reasons.  

It states:

Institutional financial aid based in any degree on athletics ability may not be reduced or canceled during the period of its award:

(a) On the basis of a student-athlete’s athletics ability, performance or contribution to a team’s success;

(b) Because of an injury, illness, or physical or mental medical condition (except as permitted pursuant to Bylaw 15.3.5.1); or

(c) For any other athletics reason.

As mentioned above, while autonomy and non-autonomy schools are similarly restricted from the non-renewal or reduction of scholarships for athletics-based reasons during the term of the scholarship award, there is no specific prohibition of the non-renewal or reduction of a student-athletes scholarship for athletics-based reasons after the period of the scholarship award for non-autonomy institutions who have not opted into the autonomy rule.

Conversely, NCAA Bylaw 15.3.5.3 restricts autonomy institutions and non-autonomy schools who have elected to follow the autonomy rule from reducing scholarship amounts of student-athletes who received a scholarship in their initial year of enrollment at the institution for athletics-based reasons after the period of the scholarship award and specifically states:

If a student athlete receives athletically related financial aid in the academic year of his or her initial full-time enrollment at the certifying institution, the following factors shall not be considered in the reduction or nonrenewal of such aid for the following academic year or years of the student-athlete’s five-year period of eligibility:

(a) A student-athlete’s athletics ability, performance or contribution to a team’s success (e.g., financial aid contingent upon specified performance or playing a specific position);

(b) An injury, illness, or physical or mental medical condition; or

(c) Any other athletics reason.

Newly appointed Alabama Athletic Director Greg Byrne commented on the termination of Goff, “As with any situation, the University of Alabama will follow NCAA guidelines.” He further reinforced the school’s intentions when he announced, “We are not revoking scholarships.”

Coach Goff, who received a five year, $2.25 million contract last June, will reportedly receive the payment for the remaining four years of his agreement as the termination was without cause.

 

 

 

 

 

 

Jackson Lewis Attorneys Speaking at the Sports Lawyers Association’s Conference in Denver

Jackson Lewis attorneys Gregg Clifton and Paul Kelly, leaders of our Collegiate and Professional Sports Practice Group, will be guest panelists at the Sports Lawyers Association’s 43rd Annual Conference in Denver from May 18-20.  Gregg is speaking on the panel “TMZ Posted What!? Sports Crisis Management in the Age of Social Media” and Paul on “Current Legal Issues in Player Health.” Catch both of these presentations on Friday, May 19.

If you’re in attendance, be sure to stop by our booth and ask our experts about various topics in sports law including immigration, TitleIX, and NCAA compliance. #SLAC17

If you didn’t make it to the conference and would like to talk to any of our collegiate and professional sports experts, reach out to the Jackson Lewis attorney with whom you usually work and they can connect you.

 

Former NHL Player Receives Probation For Drug Offense

Former NHL player Kevin Stevens avoided a federal prison sentence following a hearing this week in U.S. District Court in Boston.  Stevens, who played in the NHL for 16 years (1987-2002), including  parts of 11 seasons with the Pittsburgh Penguins, also starred at Boston College and for the 1988 U.S. Olympic team.  In the early 1990s, Stevens was considered one of the most dominant power forwards in the game, playing on a line with Mario Lemieux and scoring over 40 goals in four consecutive seasons.

 Stevens was charged in May, 2016 with conspiracy to possess with intent to distribute the addictive painkiller, oxycodone.  The criminal charges resulted from wiretaps and surveillance activity by the FBI and Massachusetts State Police into drug activity in the South Shore region of Massachusetts, which has been especially hard hit by the opioid crisis sweeping the nation. 

 Jackson Lewis helped to guide Stevens’ through the criminal justice process, in which he elected to plead guilty and accept responsibility for his actions.  As more fully detailed in a sentencing memorandum filed with the Court, it was argued that Stevens’ involvement with addictive painkillers resulted from a devastating on-ice injury that he suffered during a Stanley Cup playoff game in May, 1993.  Stevens was knocked unconscious while checking an opposing player and fell defenselessly face-first to the ice, resulting in multiple broken facial bones and a severe concussion.  The injury required extensive surgery, the insertion of several metal plates, and over 150 stiches.  To deal with the intense pain, Stevens was prescribed powerful painkillers, including Percocet, Vicodin and Oxycodone.  Unfortunately, he developed an addiction to the drugs, which he battled for the next 25 years.  It was the grip of this addiction which led Stevens to continue to seek out painkillers and eventually become the subject of an ongoing investigation by law enforcement.

Despite facing up to two years of incarceration, U.S. District Judge George O’Toole accepted the defense recommendation and imposed a probationary sentence and a $10,000 fine.  Judge O’Toole was impressed with Stevens’ progress since his arrest, and his demonstrated commitment to sobriety over the past year.  The Judge also commented that he believed that Stevens could be an effective advocate to young people concerning the dangers of drug use and addictive painkillers, and thus could make a contribution which might help solve the ongoing opioid crisis.  Following the hearing, counsel for Stevens’ commented: “the sentence imposed today reflects the proper balance between punishment for criminal activity and a recognition that the conduct at issue resulted from a combination of head trauma and a resulting addiction to painkillers.  Kevin Stevens has made great progress with his sobriety since his arrest in this case, and I am confident that will continue.”  Stevens was represented by Paul Kelly and John Commisso of Jackson Lewis (Boston).

 

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