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We oppose American's motion because it would require us to violate the Antitrust Civil Process Act, to violate an order entered by the United States District Court of the Eastern District of Michigan, and also to divulge to American confidential materials that Plaintiff has obtained from American's competitors in connection with its on-going law enforcement investigations involving suspected anticompetitive conduct of other air carriers in hubs other than DFW -- the only hub at issue in this case.
American seeks disclosure of two general categories of documents. First, American seeks documents obtained by the United States pursuant to Civil Investigative Demand ("CID") in connection with its investigations of other carriers in the domestic airline industry. To support its claim for these documents, American argues erroneously that the United States has failed to produce to American the one category of documents that all parties agree should be produced to American: all documents obtained by the United States during its investigation into American's suspected predatory conduct (the "American predation investigation"). American's claims for the documents from investigations of carriers other than American fail for the following reasons:
Second, American contends that the United States should have disclosed to American documents obtained from American's competitors in discovery in the United States v. Northwest Airlines Corp. and Continental Airlines, Inc. ("NW/CO") action, pending in the United States District Court for the Eastern District of Michigan. While American may be able to obtain such documents from their owners (and the United States would not object), American's attempt to obtain these documents by this motion must be rejected because:
In short, the United States has produced to American all of the responsive, non-privileged documents and information in its possession that it is legally empowered to produce. Moreover, the United States has taken steps to make information that it is not legally empowered to produce available to American in this case through the issuance of subpoenas for the information in this case. Plaintiff is simply not required to violate a federal statute and an Order of another District Court, especially when it has taken steps to ensure that American's legitimate discovery demands are met. American's Motion should be denied.
The requests contained in American's Second Set of Document Requests are so broad that they implicate virtually every document the United States has ever obtained, whether or not relevant to this case, in connection with any law enforcement investigation that it has conducted in the domestic airline industry. For context, therefore, we explain briefly the general nature of the United States' law enforcement activities in the domestic airline industry.
The Division is charged with conducting law enforcement investigations into suspected anticompetitive conduct in a variety of industries, including the domestic airline industry. American has been involved, either as a subject or a third party participant, in several such investigations over the years, as have other domestic air carriers. These investigations have ranged in subject matter from the suspected monopolistic conduct of a particular domestic air carrier (as is alleged against American in this case) to suspected anticompetitive combinations (either by alliance or merger or otherwise) of domestic air carriers (as is alleged in the NW/CO case) to other types of suspected anticompetitive conduct in a variety of geographic markets by a variety of different domestic air carriers. If an investigation reveals that law enforcement action against anticompetitive conduct is warranted, the Assistant Attorney General in charge of the Division may make the decision to file a lawsuit.
The Division's monopolization investigations are typically focused on conduct by a particular air carrier in particular geographic markets. The investigation into American's suspected predatory conduct, for example, examined American's conduct at American's Dallas/Ft. Worth hub. As a general rule, therefore, documents and information obtained in investigations involving the conduct of other carriers in other hubs are not relevant to this case. To be sure, the Division's different investigations into the domestic airline industry may touch on similar questions relating to the structure of markets in the domestic airline industry, but they do not involve common legal issues except in the limited sense that they all involve airlines.
Most of the documents and information that the Division receives during the course of a civil investigation are produced in response to a Civil Investigative Demand ("CID") issued pursuant to the Antitrust Civil Process Act, 15 U.S.C. § 1311 et seq. (the "Act"). Material produced in response to a CID can include documents, interrogatory answers and transcripts of oral testimony. 15 U.S.C. §1312. All material produced in response to a CID is protected from disclosure by 15 U.S.C. § 1313(c), which prevents the Division from disclosing information obtained pursuant to a CID except in limited circumstances. 15 U.S.C. § 1313(c) provides, in relevant part:
Except as otherwise provided in this section, while in the possession of the custodian, no documentary material, answers to interrogatories, or transcripts of oral testimony, or copies thereof, so produced shall be available for examination, without the consent of the person who produced such material, answers, or transcripts, and in the case of any product of discovery produced pursuant to an express demand for such material, of the person from whom the discovery was obtained, by any individual other than a duly authorized official, employee, or agent of the Department of Justice. (Emphasis supplied.)
The statutory protection for information obtained by the Division pursuant to CID is vital to not only the protection of the confidential information produced by CID recipients, but also the ability of the Division to perform its law enforcement duties. (Nannes Decl., ¶ 15.)
As noted above, the Act allows disclosure of CID material in very limited circumstances, e.g., when the producing party consents or in response to a request by Congress. The Act also provides for disclosure of CID materials in connection with litigation:
Whenever any attorney of the Department of Justice has been designated to appear before any court, grand jury, or Federal administrative agency in any case or proceeding, the custodian of any documentary material, answers to interrogatories, or transcripts of oral testimony may deliver to such attorney such material, answers or transcripts for official use in connection with any such case, grand jury, or proceeding as such attorney determines to be required. Upon the completion of any such case, grand jury, or proceeding, such attorney shall return to the custodian any such material, answers, or transcripts so delivered which have not passed into the control of such court, grand jury, or agency through the introduction thereof into the record of such case or proceeding.
15 U.S.C. §1313(d). The United States District Court for the District of Columbia addressed the problem of reconciling "the confidentiality provision of §1313(c)(3) with the provision of §1313(d)(1) authorizing the government to use CID material in a suit subsequent to the investigation that yielded the CID material" in United States v. AT&T, 86 F.R.D. 603, 647-48 (D.C. 1980).(1) While noting that "a literal reading of the two provisions admits of the construction that the Government could keep the material in custody until the point in the trial when it is needed, and then simply offer the material in evidence," the court determined that a "more just interpretation of the statute would require that the privilege elapse not simply when the Government might offer CID material at trial, but at such earlier point as would give defendants fair opportunity to study it and thus meet it at trial." Id. at 648. The court rejected the notion that "all material collected by the Government would be discoverable, even if the Government made no use of it . . . ;" the Court thus established the "use" standard that has been followed by the United States in this case. Id.
In AT&T, the District Court found that, while "mere perusal" of protected material by the government does not terminate the statutory protection against disclosure, direct "use" of the documents in the pretrial stage terminates the protection and requires the government to produce both the material it "used" and any "material that throws light on the material to be produced." Id. With respect to the "direct use" standard, Judge Greene held that:
[f]or this purpose, 'direct use' means offering the material in evidence at trial, listing it in a pretrial order as material to be introduced in evidence, showing it to a witness in preparing the witness' testimony at a pretrial deposition or at trial, using it to impeach a witness at pretrial deposition or at trial, formulating interrogatories, demands for admission, or questions to be propounded at a deposition, or similar use.
Id. at 647. The Division has followed the AT&T decision in its production of CID materials in this case.
Thus, during the course of the law enforcement investigations conducted by the Division, the Division may seek, typically pursuant to CID, production of highly sensitive, confidential business information from both subjects of the investigations and third parties (usually competitors or customers). In order for the Division to continue to be in a position to obtain such information from such persons without having to resort to enforcement of its CIDs by a Court, CID recipients must have confidence that the confidential information that they provide the Division will be protected from disclosure to their competitors, suppliers, or customers to the fullest extent possible under the law.
Finally, the documents in the possession of the United States because it is currently investigating possible predation by other domestic air carriers are also protected from disclosure by the law enforcement investigatory files privilege. The law enforcement investigatory files privilege applies to investigatory files compiled for law enforcement purposes and is intended to protect ongoing investigative efforts. Black v. Sheraton Corp. of America, 564 F.2d 531 (D.C. Cir. 1977)(privilege is based on harm to law enforcement efforts that might arise from public disclosure of investigatory files); National Union Fire Insurance Co. of Pittsburgh, PA v. FDIC, 1995 WL 104835 (D. Kan. 1995) (privilege applied where potential interference with an ongoing investigation from disclosure of documents outweighed plaintiff's interest in discovering them).(2) The policies behind this privilege, which is vital to the ability of the Division to carry out its law enforcement mandate, reinforce the confidential nature of CID material.
Upon receipt of American's First Set of Document Requests, the United States identified CID materials that it had received in connection with its investigation of American's predatory conduct at DFW that led to the filing of this complaint. All such materials (interrogatories, documentary materials and transcripts of CID depositions) were therefore produced to American in response to its First Set of Document Requests. (French Decl., ¶ 5.)(3)
In response to American's Second Set of Document Requests, Plaintiff has also produced to American all CID materials obtained by the United States in other ongoing investigations where the trial staff in this case has made direct use of any of those materials in the pre-trial or trial stages of this litigation.(4) These CID materials were produced because of a determination that they constituted "related material held by the custodian that throws light on the material to be introduced." AT&T, 86 F.R.D. at 648. This determination is not, as American claims,(5) inconsistent with the position Plaintiff has taken with respect to the documents at issue in this Motion.
American appears to be confused as to what Plaintiff has and has not produced. Thus, American argues that Plaintiff produced 15 CIDs issued in connection with an ongoing predation investigation of carriers other than American, but "in response to Request No. 26, which called for the production of any documents produced in connection with those CID's, the DOJ produced nothing." (Opp. Memo., at 13-14 (emphasis supplied).) In fact, as Plaintiff has previously informed American, Plaintiff has produced all of the materials obtained pursuant to the 15 CIDs that American references in its Memorandum. (French Decl., ¶¶ 4-5.)(6) What Plaintiff has not produced, however, is copies of three other CIDs issued to the subjects of the Division's ongoing investigation of possible predation by two other carriers in other geographic markets and copies of the materials produced in response to those CIDs.(7)
American argues that Plaintiff has artificially defined the "American predation investigation" so as to avoid producing to American documents Plaintiff obtained pursuant to CID in connection with an omnibus predatory conduct investigation that American believes exists. Whether the investigation into predation in the airline industry is characterized as a single investigation or as separate investigations of conduct by various air carriers in various markets, the fact remains that the United States based its suit against American only on the evidence gathered in its investigation of American and not on evidence gathered in its investigation of conduct by other airlines in other markets.
As has been explained repeatedly to American,(8) the Division originally opened a preliminary inquiry ("PI") solely to investigate American's conduct in city pairs emanating from DFW. The form memorandum requesting PI authority identifies only American as a potential defendant and identifies as the geographic markets to be investigated only city pair markets emanating from Dallas/Ft. Worth, Texas. (Nannes Decl., ¶ 7.) When the Department later decided to investigate other carriers in different geographic markets, "add-on" clearance was obtained from the Federal Trade Commission.(9) (Id. at ¶ 9.) The investigation of those other carriers have involved different hubs and different conduct, than the investigation of American. (Conrath Decl., ¶ 9.)
Finally, we note that the materials obtained during the ongoing investigation of predatory conduct by other carriers is of marginal, if any, relevance to this case. This case is not going to be about conduct by other carriers at their hubs, but instead will be about American's conduct at its Dallas/Ft. Worth hub. Nor does Plaintiff anticipate using in this case any of the information that the Antitrust Division obtained in connection with its now closed investigation into travel agency overrides.(10) Whatever the merits of American's claims for production of these documents, their relevance to this case is dubious at best.
American contends the United States, by its reference to fifty-three (53) depositions taken in past investigations of the airline industry, conceded that the transcripts of such depositions should be produced in this case. American obtained the number 53 from Appendix D to the government's Rule 26(a) Initial Disclosures. (French Decl., ¶ 5, Ex. 2.) In the Rule 26(f) conference, American insisted that the United States search all investigatory files involving barriers to entry at any hub in preparing its Rule 26(a) Initial Disclosures. The United States attempted to satisfy American's overbroad request by disclosing persons and materials identified in searching files other than the predation investigation files and noted its doubts as to the relevance of the persons and materials identified in those appendices to this case.(11) That disclosure was neither an admission of relevance nor an admission that the transcripts were used in connection with this action.
All of the deposition transcripts listed in Appendix D of the United States Rule 26(a) Initial Disclosures were of depositions taken pursuant to the CID statute. Eight of the depositions were taken in connection with an investigation, closed in 1996, of whether Delta's acquisition of certain slots at New York's La Guardia Airport was anticompetitive; and thirty-one were taken in connection with an investigation, also closed in 1996, into whether agreements between travel agencies and certain air carriers for paying market-share based commission overrides to the travel agents were unreasonable restraints of trade. (French Decl., ¶ 9.) To the extent that those transcripts contained information called for by the Court's February 7, 2000, order, that information has been produced. The remaining depositions were taken in the Division's investigation of Northwest's purchase of a controlling interest in Continental Airlines and are protected by both the CID statute and the NW/CO protective order. These depositions were not covered by the Court's February 7, 2000, order because the NW/CO investigation was not a monopolization investigation. None of the fifty-three deposition transcripts referenced by American have been used by the Division in connection with this case, except to the extent that they were reviewed in order to comply with the Court's February 7, 2000, order. Id.
The documents that American seeks from the Division's open investigative files relating to possible predation by other carriers are not only protected from disclosure by 15 U.S.C. § 1313(c), as discussed above, but also by the law enforcement investigatory files privilege.(12) The files of this open investigation contain confidential business information of American's competitors, and reveal information about the carriers that the Division is investigating. The files also contain internal memoranda describing the status of those matters, the disclosure of which could prematurely reveal the government's theories. In its response to Defendants' document requests 3, 4, 24, 25 and 26, the government objected to the production of certain documents, and asserted the law enforcement investigatory privilege.(13) (French Decl., Ex. 1)
Defendants argue, erroneously, that the government was required, at the time it first asserted the privilege to defendants, to provide an affidavit from the agency head specifying the particular information for which the privilege is asserted, and explaining why the privilege applies. The proper time for the government to submit such an affidavit is when the matter is brought before the court, in this case, by a motion to compel. Cf. In re Sealed Case, 121 F.3d 729, 741 (D.C. Cir. 1997)(White House was not obliged to "formally invoke its [executive] privileges in advance of the motion to compel;" the fact that it said, in response to a subpoena, that it "believed the withheld documents were privileged," was sufficient; In re Consolidated Litigation Concerning International Harvester's Disposition of Wisconsin Steel, 1987 WL 20408, at *7 (N.D. Ill. Nov. 20, 1987)(rejecting the assertion that agency head's affidavit must be submitted when the privilege is first invoked); Abramson v. United States, 39 Fed. Cl. 290, 294 n.3 (1997) ("procedural requirements generally are satisfied through the production of a declaration or affidavit by the agency head . . . in response to a motion to compel."); SEC v. Downe, 1994 WL 23141, *5 (S.D.N.Y. Jan. 27, 1994)(government meets its obligation regarding affidavit by filing it with its opposition to motion to compel).
Cases cited by defendants do not provide otherwise. In National Union Fire Insurance Co. of Pittsburgh, PA v. FDIC, 1995 WL 104835 (D. Kan. 1995), the FDIC sought a protective order against production of certain documents, claiming the law enforcement investigatory privilege. The court found that the agency head's declaration was sufficient to assert the privilege. In Pontarelli Limousine, Inc. v. City of Chicago, 652 F. Supp. 1428 (N.D. Ill 1987), the United States filed a motion to quash two subpoenas, but did not provide the requisite detailed declaration from an agency head. That case has no bearing on the instant case in which the United States has provided a detailed declaration to the court. Tuite v. Henry, 98 F.3d 1411 (D.C. Cir. 1996), which defendants cite to enumerate the factors the court must consider in determining the applicability of the privilege, is in fact procedurally similar to this case. In that case, the Department of Justice filed its detailed declaration in response to a motion to compel. According to the Tuite v. Henry court,
Common sense and the purpose of the rule dictate that the "subject to" language of Rule 45(c)(2)(B) does not mandate that the full description required by Rule 45 (d)(2) be provided at the time the initial objection is asserted.
Id. at 1416.
Defendants have now filed a motion asking this Court to compel production of all documents relating to any of the Division's predation investigations, including its open and ongoing investigations.(14) The United States is therefore providing the Declarations of A. Douglas Melamed, Acting Assistant Attorney General in charge of the Antitrust Division, and of John M. Nannes, Deputy Assistant Attorney General, which describe the materials over which the privilege is asserted and explain why the privilege applies.
The attached declarations also explain how disclosure of information from the Division's open investigative files relating to possible predation by carriers other than American with respect to hubs other than DFW, particularly while still pending, could have an adverse effect on the progress of those matters and on any future attempts by the Division to initiate litigation against the airlines under investigation.
The United States agrees with defendants that the Court should consider the following factors when deciding whether to compel disclosure of material protected by the law enforcement investigatory privilege:
(1) the extent to which disclosure will thwart governmental processes by discouraging citizens from giving the government information; (2) the impact upon persons who have given information of having their identities disclosed; (3) the degree to which governmental self-evaluation and consequent program improvement will be chilled by disclosure; (4) whether the information sought is factual data or evaluative summary; (5) whether the party seeking the discovery is an actual or potential defendant in any criminal proceeding either pending or reasonably likely to follow from the incident in question; (6) whether the --- investigation has been completed; (7) whether any intradepartmental disciplinary proceedings have arisen or may arise from the investigation; (8) whether the plaintiff's suit is non-frivolous and brought in good faith; (9) whether the information sought is available through other discovery or from other sources; and (10) the importance of the information sought to the [other side's] case.
National Union Fire Insurance of Pittsburgh v. FDIC, 1995 WL 104835 (D. Kan. 1995) (Appendix, Ex. A)(quoting Everitt v. Brezzel, 750 F. Supp. 1063, 1066-67 (D. Colo. 1990).
The relevant factors can be balanced upon the following considerations. The Division is continuing to investigate possible predation by air carriers other than American. As long as the Division is continuing to investigate, disclosure of material from the investigative files could discourage potential witnesses from coming forward with information. To the extent that the United States believed that the balancing of the factors referenced above required disclosure of particular documents to American, it has already disclosed those documents (e.g., the CIDs issued to low-cost carriers and all materials submitted in response to those CIDs, where the United States has made or intends to make direct use in this case of any CID materials produced by the particular low-cost carrier.) The fact that the United States disclosed these documents without forcing American to file a motion to compel should not be taken as a waiver of its right to assert the privilege as to any documents contained in its open investigative files. See In re Sealed Case, 121 F.2d 729, 741 (D.C. Cir. 1997)(holding that release of a particular document only waives governmental privileges as to the document and not all related materials.) Under American's view, the law enforcement investigatory files privilege would essentially terminate whenever the Division files a lawsuit in the same industry in which it continues to investigate potential violations of the antitrust laws. Such an interpretation simply cannot be correct.
The United States has not produced documents addressed to or received from the subjects of its ongoing predation investigation of other carriers, including CIDs issued to those subjects and materials it received in response to CIDs. American's argument that the privilege should not apply because "[t]he vast majority of documents the DOJ is withholding were produced by large corporations who are already protected by the procedures set forth in the Protective Order entered by this Court," seems to be directed at this information. We know of no law that makes investigations involving "large corporations" any less entitled to the protection afforded by the privilege than investigations involving individuals or small corporations. Nor do we know of any law that renders application of the law enforcement investigatory files privilege moot in the face of a Protective Order. Similarly, American's claim that the privilege should not apply because it is seeking "purely factual material" ignores the fact that the material it seeks was provided by subjects of an ongoing investigation in response to a process which guarantees a high degree of confidentiality to the material provided. Production of CID materials and related correspondence from an open investigation in this case could jeopardize the Division's ability to provide the confidentiality assurances necessary to conduct future investigations in this industry.
While one of the government's rationales for refusing to disclose this information is based in part on its recognition that premature disclosure could potentially prejudice the rights of those parties under investigation, 40 Op. A.G. 45 (1941), the government's primary interest here is to protect its on-going ability to conduct its law enforcement activities. Black v. Sheraton Corp., 564 F.2d 531, 541 (D.C. Cir. 1977)("law enforcement operations cannot be effective if conducted in full public view . . . .") Disclosure of information provided either voluntarily or in response to compulsory process by parties to ongoing investigations could deter those parties from continuing to cooperate in our ongoing investigations, and could frustrate future settlement negotiations.
A major balancing factor is whether the information sought is available through other discovery or from other sources. In this instance, the Court should consider the fact that American has issued subpoenas to every major domestic air carrier. Those subpoenas request all documents provided by each major carrier to the Department of Justice since January 1, 1994, "relating to alleged, actual, or proposed conduct by any U.S. airline, . . . ." Carriers that received CIDs in connection with the Division's ongoing investigations of their conduct at their hubs may choose to raise an objection to American's subpoena to the extent that the request is overly broad and not reasonably calculated to lead to the discovery of admissible evidence in this case (which involves American's conduct at DFW), an objection which could not have been raised in response to a CID issued in an investigation involving the CID recipient's conduct at its own hubs. Such discovery requests are the proper way to proceed. Upon balancing the potential harm to the Division's ongoing and future investigations against American's need to obtain these documents from the Division's investigative files, American's motion to compel should be denied.
As set forth above, the NW/CO case was filed on October 23, 1998 to challenge Northwest's purchase of a controlling interest in Continental. Unlike this case, NW/CO does not involve claims of monopolization or attempted monopolization of a hub by either Northwest or Continental in violation of Section 2 of the Sherman Act, 15 U.S.C. § 2, but instead was brought under Section 7 of the Clayton Act, 15 U.S.C. § 18, and Section 1 of the Sherman Act, 15 U.S.C. § 1. (Conrath Decl., Ex. 1). The subject matter of the NW/CO case and this case are thus completely unrelated.
Nonetheless, American presses for the documents that have been produced to the United States through discovery in the NW/CO case.(15) The United States has no objection to American obtaining these documents in any of several appropriate ways. American could subpoena the documents directly from their owners.(16) Or American could seek the permission of the owners for the United States to provide the documents to American.(17) Or American could seek to modify the Protective Order that prevents the United States from turning over the documents.(18) The United States' only objection is to American's demand that it turn over these documents in a way that violates the Protective Order of another District Court.
As Plaintiff has informed American repeatedly, the Protective Order entered by Judge Hood in the NW/CO case prohibits the disclosure to American of documents designated as either confidential or highly confidential pursuant to that Order.(19) American is fully familiar with the Protective Order entered by Judge Hood because American itself was served with a subpoena in NW/CO. Indeed, in order to protect American's confidential information in documents that it produced in NW/CO, American's counsel participated in a May 3, 1999, hearing on the United States' motion for entry of the NW/CO Protective Order. (Conrath Decl., Ex.3).
Paragraph 2 of the NW/CO Protective Order states, in pertinent part:
Disclosure of Confidential or Highly Confidential material to any person pursuant to this Order shall be solely for the purposes of the preparation, hearing, trial, and any appeal of this action, and for no other purpose whatsoever, provided, however, that the Department of Justice, subject to taking appropriate steps to preserve the confidentiality of such material, may disclose material designated as confidential or Highly Confidential to employees of the Executive Branch outside the Department of Justice, and may use such information for any valid law enforcement purpose pursuant to 15 U.S.C. § 1 et seq.; 15 U.S.C. § 1311-14 et seq.; 15 U.S.C. § 12 et seq.; or any other applicable law. (Emphasis supplied).
In other words, Judge Hood specifically created a structure that balanced the confidentiality expectations of the airlines that produced materials in the NW/CO case and the legitimate needs of the United States to use the NW/CO materials for "any valid law enforcement purpose." The terms of the NW/CO Protective Order cannot be mistaken -- the United States may not disclose materials subject to the NW/CO Protective Order outside of the context of NW/CO except to members of the Executive Branch. NW/CO Protective Order, ¶ 2. While Plaintiff has no desire to prevent American from gaining access to the NW/CO materials, Plaintiff does not find in the NW/CO Protective Order any exception to the language of Paragraph 2 that would permit it to disclose materials protected by the NW/CO Protective Order absent an Order from Judge Hood modifying the terms of Paragraph 2.
American nevertheless has stubbornly held to the position that the United States can comply with Judge Hood's Order essentially by complying with the terms of the September 14, 1999, Protective Order ("Stipulated Protective Order") entered in this case. American thus claims that the United States, upon receiving American's Second Set of Document Requests, should have notified all persons that had produced documents in NW/CO potentially responsive to American's overly-broad discovery requests that a request concerning their documents had been received,(20) giving those persons 21 days to either designate whether documents were confidential or to petition the Court for an order limiting disclosure of that information.(21) The NW/CO Protective Order, however, simply does not permit the United States to proceed as American prefers.(22)
The United States believes that the proper forum for deciding issues relating to the correct interpretation of the NW/CO Protective Order (which, unlike the Stipulated Protective Order, did not result from an agreement between the parties but was entered by the Court over Northwest's objections) is before the Court that entered that Order. Proceeding in such a manner would permit the parties whose documents American seeks to state their views on the discoverability of these documents before the documents are produced.
The United States has taken steps to make any the few NW/CO documents that it has used in this case available to American. Plaintiff has thus issued subpoenas in this case for those NW/CO documents that it has used,(23) thereby providing American with notice that the documents had been used and ensuring that American would receive copies of the documents in discovery in this case. American has already received six of the seven documents so used. French Decl., ¶ 11.CONCLUSION
For the aforementioned reasons, Defendants' motion should be denied.
Respectfully submitted,
1. American discusses the AT&T opinion in its brief, but also suggests that the guidelines in that case are not binding in this case. During the meet-and-confer process, the United States asked whether American believes some other standard applies in this case, but American has not suggested a standard that it believes is more appropriate. (Conrath Decl., ¶ 7).
2. A true and correct copy of the National Union Fire Insurance case is attached to the Appendix in Support of Plaintiff's Opposition to American's Motion to Compel Documents Responsive to American's First and Second Sets of Document Requests ("Appendix") as Ex. A.
3. The United States has not produced publicly available documents nor documents received from American.
4. The United States will continue to produce CID materials in accordance with the AT&T holding, as use is made of those documents.
5. See Memorandum of Law in Support of Defendants' Motion to Compel Documents Responsive to American's First and Second Sets of Document Requests ("AA Memo."), at 16 n.14.
6. The documents at issue (CID materials obtained by the United States from three low-cost airlines) were also responsive to other requests in Defendants' Second Set of Document Requests (including Request No. 3 and Request No. 4). Like other documents responsive to multiple requests, these documents were not labeled to correspond with any particular request.
7. The CIDs, correspondence relating to them, and other correspondence relating to the ongoing investigation have been withheld on the basis of the law enforcement investigatory files privilege, further explained below. As for the materials obtained in response to those CIDs, the United States will continue to supplement its production of documents responsive to Defendants' discovery request if use is made of those documents.
8. See Conrath Decl., Ex. 5 (February 16, 2000 letter to Edward Soto, Esq., from Craig Conrath).
9. It is not unusual for the Division to investigate multiple possible violations with the same matter number, and for those investigations to lead to the filing of different cases. (Conrath Decl., ¶ 9.)
10. Plaintiff has already produced copies of the CIDs, correspondence relating to the CIDs, and information supplied orally to the Division in connection with that investigation.
11. The United States stated in its disclosure that American's interpretation of Rule 26 seemed "designed to encourage overbroad disclosure, as the United States has contacted representatives from almost every domestic airline, numerous airports, and many travel-related businesses in the course of its prior investigations in this industry." (French Decl., Ex. 2.)
12. The only documents being withheld solely in reliance on the law enforcement investigative files privilege are the CIDs issued to the carriers being investigation inthe Division's ongoing investigation and correspondence between those carriers and the United States.
13. The United States also asserted the deliberative process privilege as to any document request calling for internal, pre-decisional memoranda. We do not understand Defendants' pending motion to be seeking such documents.
14. Mr. Nannes' affidavit does not address the government's four other open investigations of possible anticompetitive conduct by domestic carriers. The United States has not produced documents from those investigations, three of which involve suspected anticompetitive combinations and one of which involves possible violation of a consent decree entered in United States v. ATP, 1994 WL 502091 (D.D.C. Aug. 10, 1994).
15. In the pre-complaint investigation of Northwest and Continental, the United States received documents from Northwest, Continental and third parties pursuant to CIDs. Since filing its complaint in the Northwest/Continental litigation, the United States has received more documents pursuant to discovery subpoenas. Parties and non-parties were given an opportunity to designate document produced prior to the complaint in accordance with the protective order. The vast majority of the documents produced both pre and post complaint have been designated as confidential or highly confidential pursuant to the NW/CO protective order.
16. Indeed, American has done so, and has provoked at least one relevance objection from the documents' owner. American has issued subpoenas to all of the airlines that produced documents in NW/CO seeking all documents produced to the United States, and most (if not all) of these airlines have objected to the production of the totality of these documents to American (See, e.g., French Decl., Ex.3).
17. The United States suggested such an approach to American. See Conrath Decl., Ex. 4).
18. The United States informed American that it would not object to such a modification request. See Conrath Decl., Ex. 4.
19. The United States did inform American, in its Rule 26(a)(1) Initial Disclosures, that it possessed documents from the NW/CO investigation, but it would not be producing those documents due to the Protective Order in place in the NW/CO case. Obviously, the United States cannot waive the rights of third parties.
20. Alternatively, under American's view, the United States should have reviewed all documents produced in NW/CO to determine whether they were potentially responsive to American's discovery request and then notified the original producers.
21. Contrary to American's claims, the United States has never told American that it would invoke the "notice" procedures suggested by American. Once American made clear in the meet-and-confer process that it expected the United States to proceed by invoking the "notice" procedures, we agreed to confer with the Division staff working on the NW/CO case regarding whether the process was consistent with Judge Hood's Protective Order. The response we received to that inquiry was a resounding "no." (Conrath Decl., ¶5)
22. Indeed, such disclosure could result in other airlines' NW/CO documents receiving less protection from disclosure to American's business executives than American's counsel sought -- and obtained -- for its own documents in the NW/CO proceeding. (See Conrath Decl., Ex. 3 and 4).
23. The United States found only six documents in the documents produced by Delta in response to a NW/CO subpoena that it believes are in any way relevant to this case, and only one document produced by Midwest Express has been used by the United States in this case.


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BBC Somali 1800
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happened to me that while I was writing this piece that
the US Ambassador to Kenya Mr.
William Bellamy, was quoted as saying "Our
view is that the transitional government has, potentially,
the means to secure its own country,". Though
Ambassador Bellamy was careful to say the United States
did not oppose the AU plan yet he make it clear that "There
is a risk they could be a magnet for instability"
in his last Talking Point DISARMEMENT
IN STYLE Mr. M. M. Afrah supported voluntarily countrywide
disarmament in style but with conditions of course. Unlike
Ambassador Bellamy, M. M. Afrah witnessed first hand the
carnage between UN troops and Somalia Militia, and very
much opposed deployment of Ethiopian or Somali-Ethiopian
troops that are currently in training camps, according
to intelligence reports.
these two experts and the International
Crisis Group findings with other intellectuals make
it clear that Ethiopian involvement in Somalia is like
adding gas to a fire that is already burning wildly. I
also wonder why the Ethiopians are very keen to send their
soldiers in Somalia where there is more harm in their
presence than good?. Why don't they let the AU troops
do the initial security work so that President Abdullahi
Yusuf and his Prime Minister Ali M. Gheddi will start
nation rebuilding and reconciliation, which is what they
were elected for in the first place.
is clear that neither President Yusuf nor Ethiopians want
fresh start for Somalia crisis rather have another hidden
agendas, which will devastate the whole of East Africa.
Mr. Afrah pointed out the President, the Prime Minister
and parliamentarians must read the mood of the people
before taking any step that might cause another bloodshed
and anarchy.
| Latest
News | Reuters
News | A.
Press News| Washington
Post |Contact
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text:
VOTE The Most Stunning Elizabeth Perkins Photos
Photos of Elizabeth Perkins, recognized as one of Hollywood's hottest women. She's known to many for co-starring alongside Tom Hanks in the 1988 classic Big, or as Ceila Hodes in Showtime's cult TV hit Weeds or to younger viewers as Elaine on How To Live With Your Parents (For the Rest of Your Life), but there's more to Perkins than those gigantic roles. Yes, she was nominated for two Golden Globes for her work on Weeds, but she's established herself as a versatile actress on both film and TV. No matter how you slice it, Perkins is one of the most talented and beautiful actresses in Hollywood today. In honor of one of the greatest ladies in Hollywood, here are the best Elizabeth Perkins pictures, videos and GIFs, ranked by hotness.These Elizabeth Perkins pics were taken from a variety of different sources, including numerous promotional and magazine photoshoots. Together, they form a curated image gallery containing all the hottest Elizabeth Perkins images available from around the Web. While there are many sexy Elizabeth Perkins photos, these are the hottest around.There are only a few girls in movies and TV as pretty and fun to watch as Elizabeth Perkins.


text:
rlemkin wrote:Dry hopped with 1g/l of Dana a few days back and pH has settled around 3.25 (dry hopping raises the pH and should also inhibit the Lactobacillus from taking it lower). Initial impressions are very positive. I really need to check the gravity now as I'd be bottling it if it wasn't for the Brett.
brugen wrote:rlemkin,
I'm planning on making a 30l batch of your Berlinner Weisse. How many Lacto Planatarium tablets do you think that would need?
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text:
Cape Agulhas Lighthouse
About Cape Agulhas Lighthouse
This Lighthouse is the second-oldest still operating and was built in 1848. The treacherous seas and dangerous coastline claimed many vessels which were reason enough for erecting it. The focal plane of the light is 31 metres (102 ft.) above high water and the range is 30 nautical miles (56 km; 35 mi). It rotates, giving off one white flash every five seconds.


text:
7:30 AMAdd to Calendar
About this Event
Run for the Trees 5k run/walk is a unique point to point event. The last mile is on the tree-canopied, wilderness dirt road of Genius Drive. This privately owned glimpse of old Florida is opened to the public only once a year, for this event. All finishers receive a young tree! Event capacity is set at 1,800.
• Unique course
• Finisher's receive a tree sapling
• Commemorative T-Shirt
• Hydrapouch® (cup-free race)
• Chip timed race
Saturday, April 27, 2019
7:30 am 5k (3.1 miles)
8:45 am: Kids Run
9:00 am: Awards Presentation @ Showalter Field
Showalter Field
2525 Cady Way
Winter Park, FL 32792
There is no spectator area at the finish line, runners will be shuttled by bus back to Showalter Field.
$33 - Through April 13
$36 - April 14 - April 26
$40 - Race day at race site (if spots available)
17 & under / 65 & over through April 26: $10 OFF
Cannot be combined with any other discount.
Keeping Central Florida Fit is our mission. Walkers are encouraged to participate in all Track Shack races. The City of Winter Park encourages runners and walkers in this 5k to complete 3.1 miles within one hour. Participants who do not maintain that pace will be directed to the sidewalk by race officials.
Use Facebook to Leave a Comment on Run for the Trees Jeannette Genius McKean Memorial 5k - We'd love to hear from you!


text:
Having played the USMC a bunch of times I was used to how much firepower these guys could punch out, so I ran three regular squads with 3 BAR's each and a bunch of SMG's and two Engineer squads with one containing a flamer. On top of this I had a medium mortar, MMG, Sniper and a Sherman 105 with pintle HMG. The Japanese Army contained 3 lunge mine soldiers, 3 x 10 man veteran squads, 2 x Regular mixed weapon squads (including light mortars), a light mortar, ATR and a sniper.
We randomly rolled a scenario and came up with Point Defence, winning the dice roll I opted to defend as my thought was to whittle down the big vet squads as they charged across the table. The preparatory bombardment managed to put two pins on 5 out of 6 squads present and 3 of them would not be able to activate for the first 3 turns because of those pins #$@@!!
First turn and the Japaneses swept onto the table in a concerted push toward the USMC left flank, which at the time was lightly defended by a pinned squad and an MMG team. The Japanese used this turn to initiate a series of light mortar smoke bombardments which really opened my eyes (Ironic - J) as they cut off some LOS and I could see where it was going to go, block LOS to allow the assault squads close enough to strike. I did have one lucky mortar strike on a Japanese mixed weapon squad though, so a nice way for me to end the turn after failing to activate 4 units due to pins.
Turn 3 and more smoke comes in, it was so effective that many of my units could not draw LOS and
Were left sitting back having a Smoke and hoping for a breeze. By this time the Japanese units were within Rifle range, so my squads were able to pick a few off here and there, but against large squads of vets their fire was rather ineffective and pins against Japanese really do little. By the end of the second turn soldiers with lunge mines were getting close and would be able to strike against my M4 next turn.
Turn 4 and the USMC drew first dice, looking at the options the M4 crew figured it was all or nothing and advanced to close the range between them and the threats firing all guns as they went. The hull MMG ripped apart one lunge mine soldier whilst the HMG disintegrated the other, meanwhile the 105 howitzer locked onto another big vet squad and with pinpoint accuracy killed half of them. This was followed up by accurate fire from the USMC squads and the threat from the advancing Japanese was diminished to the strength of a gentle breeze rather then the tsunami a turn ago. In what was an extremely courageous move, one soldier with a lunge mine charged the M4 under the hail of bullets and disappeared in an instant as his mine detonated against the front armour. As the smoke cleared the crew checked all their bits and discovered that one of the tracks had dislodged and they were now a static pillbox (rolled a 1 for pen and a result of immobilised on the damage chart).
Turn 5 was just a matter of going through the motions with a final Banzai charge. With the remaining troops failing to dislodge the Marines the game was called. The USMC held all 3 points however they had been given a major scare and to see a massed banzai charge of Japanese coming up on a flank was really something to behold. Now, had I been able to utilise the 105 M4, things would have been different, however I still had one unit of veteran engineers with a flamer as a defence in depth should my flank objective have been threatened.
The use of smoke was amazing and when you have 3 mortars firing each turn it builds up so quickly and can really allow those Japanese squads to get close without taking any fire. It was only the second time my opponent had used the Japanese and it was a learning experience for both of us. A few more games under his belt and refining of the smoke and they will be a serious threat to any force.


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'I Am Not Your Negro' screening at South Norwalk Library
Photo: Alex Von Kleydorff / Hearst Connecticut Media
NORWALK — The South Norwalk Library will screen the critically acclaimed documentary "I Am Not Your Negro" at noon Saturday.
The film uses archival material and James Baldwin's words to examine race in America. Baldwin, born in Harlem in 1924, began writing at a young age and became famous for his insight into race, sexuality and class dynamics that often go unspoken.
After the screening, a panel including Clarence Bowden, of Calvary Baptist Church; Tristan Fields, of HELP Inc.; Sandra Stokes-Simms, of South Norwalk Electric and Water; Darius Williams, of Connecticut Coalition for Change; Derrell Wilson, of Connecticut State NAACP, and Angela Harrison will discuss the film.


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Cycling with Gul
20th May 2013
Gul is an Architect and she also lectures in architecture at Queens University, Belfast.
We joined Gul for a cycle from her home in Rathgar to University College Dublin where she does research at the Humanities Institute of Ireland. Along the way we talked about growing up in Turkey, living as an expat in the USA, The Netherlands and Ireland, and her special interest in the relationship between architecture and film. For more Cycling with... videos check out our blog and like us on facebook. You can also subscribe to our free newsletter.


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I used shades of citrasolv paper for the seagull body.
Then stencilled modelling paste over the surface to create texture, which I then sprayed with iridescent inks.
I sanded the surface, and drew some detail in ink.
I love your wooden panels Morag, and this is no exception. Beautiful.ReplyDelete
This and Summer Stag are wonderful pieces Morag. The layers of paint and texture you achieve always impresses me. And your little houses in a post further back...LOVE them.
I so love seeing the progress of your paintings. The way you use collage is fascinating to me. And the end result is beautiful as always ...ReplyDelete
Morag, all of the texture is enticing me to hop on a boat , visit Skye and see your art in person! Here most of our seagulls are pure white with grey wings and black wing tips. The others may have a black ring around their necks or even a black head. Beautiful birds, but annoying sounds.ReplyDelete
There is such texture here, what an interesting process. You've captured the free soaring feel wonderfully, your art is full of nature's gifts and beauty, wonderful!ReplyDelete
Wonderful! I love the textures and that iridescent ink is gorgeous! xReplyDelete
After reading that you have used Citrasolve papers I have been investigating this product. The effects are fantastic. I will have to experiment with this. You have used the papers so effectively in your work.ReplyDelete


text:
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Clinical Decision Making in Primary Open Angle Glaucoma (ELC67104)
Primary Open Angle Glaucoma (POAG) is the second leading cause of blindness in the world, the third leading cause of blindness in the United States, and the leading cause of blindness in African Americans. Glaucoma is the most common form of preventative blindness that optometrists commonly see. Given these statistics, all NECO graduates will certainly encounter glaucoma patients/suspects in their clinical practice, and in 49 out of the 50 states, they may be responsible for the diagnosis, treatment, and management of this condition. The current NECO curriculum covers POAG in a "spiraling" manner in which they receive an introduction to the disease during first year (ODP I), the condition is then re-visited during second year (ODP II and III), and then again during the third year (Advanced Ocular Disease). While, students obtain a basic glaucoma knowledge base over the course of 3 years, the learning is segmented. Students will benefit from one cohesive setting in which they can assimilate the knowledge they've gained thus far, add higher levels of information, apply this knowledge and begin to refine their clinical decision making skills using case-based presentations.
The course will incorporate turning point technology (aka "clicker questions") in order to enhance learning and retention.
This elective course will utilize case presentations and analysis, overview of advanced technologies used in diagnosing and managing POAG (with an emphasis on analysis and interpretation), and incorporation of evidence based medicine, in order to hone the students' decision making skills. The concept of structure and function will be explored. Glaucoma medications will be discussed from a clinical perspective. Emphasis is placed in the decision making process for the diagnosis and initiation of treatment. An analysis of risk: benefit ratio will be including in the discussion. This material will be presented in the context of glaucoma suspects, ocular hypertensives, and POAG patients. This course will give students exposure to how practitioners decide what treatment/management plan is best in cases for which there are multiple possibilities. It will prepare the third year student for the more independent decision making of a fourth year student, and teach them how to support their decisions with evidence.


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Boxing will make its return to NBT Bank Stadium on Friday. Over 12 bouts of non-stop action will be on display, ranging from 70 pounds up to 240-plus pounds. The event is the latest fundraising effort for Syracuse's Cops for Kids program, which serves at-risk youth at Ray Rinaldi's two youth centers. The program joins amateur boxing and the Syracuse Police Benevolence Association to help create a safe haven for at-risk youth who reside in the greater Syracuse region.
In the main event of the evening, X-Games gold medalist, BMX biking pioneer, MTV personality, and Subaru rally car racer Dave Mirra will step into the ring for the first time, as he laces up the gloves in this fundraising effort to help Syracuse's at-risk youth. Mirra is a a 1992 Chittenango High School graduate. When asked to compete in an exhibition bout Mirra, the consummate competitor, refused unless it was a full-out amateur boxing match. For this reason he will box an undefeated amateur boxer hailing from Elmira.
In the feature bout of the evening, Elmira's Chris Donahue will step in with the 2013 New York State Golden Gloves Champion Luis "Azucar" Vargas. The two fought in the fight of the night earlier this year in a regional competition, which gave Vargas the nod by decision. Vargas, who wowed fans last month with his third-round knockout of Watertown's Tariq McDonald, is looking to keep his knockout streak alive this Friday.
Finally, Syracuse's nationally ranked junior squad will be in action as it competes against teams from Utica, Rochester, Elmira, Cortland and Liverpool. Syracuse youth Jerimiah Jones, David Diaz, Joseph Pagan, Les Smith, Ray Shadreem, Paqui Vargas, Dan O'Hare, John Angotti and Steve Mossorro are all looking forward to their matchups. In case of rain, the bouts will be moved to the Westside Champions Center at 307 S. Geddes Street, in Syracuse.
Teams will be traveling from Utica, Rochester, Syracuse, Liverpool, Cortland, and Elmira for the event. Bouts begin at 6pm, and admission starts at just $15. For more info contact Ray Rinaldi at 315-382-5888 or Chris Burns at 315-295-0329.


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I must thank the publisher and author Iain Reading for sending me these books. Of course this has no way affected my opinion or review but free books are absolutely awesome! I am super excited to continue this series. Especially since the next one is apparently in Ireland and also features the Titanic! One of my many favourite things.
The Hunt For Hemingway's Ghost
SaveSaveTitle: Kitty Hawk and the Hunt for Hemingway's Ghost
Author: Iain Reading
Pages: 236
Stars: ★ ★ ★ ★ ★
Three Words: Mysterious, Adventurous, Enlightening
There was about a year between when I read the first book, The Curse of the Yukon Gold and this one, the second book. I had very much enjoyed the first instalment of Kitty Hawk. Actually no, I surprisingly really loved my adventure with Kitty. She brought me to Alaska in her De Havilland Beaver ( sea plane) and taught me much more than how to spot a humpback whale.
This is why I can't believe I didn't read Iain Reading's next book so soon! The Kitty Hawk Flying Detective Agency series has something for everyone!
Interestingly enough I started reading this book on a plane to Spain. So as Kitty sat in her pilot's seat flying over North America, I sat in my 14F aerlingus seat flying over the English Channel or Bay of Biscay or whatever it's called. It filled me with excitement and a longing to explore. There's an innocence about this book that makes me feel childish or somewhat foolish. When I was reading this books I felt I could do anything and go anywhere. My dreams suddenly seemed so much more achievable. I like that this book makes me feel young. Although don't get me wrong, this book isn't just a child's book. I was afraid it would be aimed for a lot younger readers but I think that it's so universal that anyone could read and love it.
|On the plane
Even though Hemingway isn't exactly the main point of this story I still loved how such a famous author was weaved into it. Any book that talks about authors or books just makes me feel more connected to it. I loved the history in this book and how vivid the adventure becomes.
I highly recommend anyone to read this book. If you love travelling as much as I do it's a fantastic way to learn about cultures. And if you love mystery it is almost like a modern day Nancy Drew. And if you love YA, it's not a typical YA but I still think you should read it!
The Icelandic Intrigue
Author: Iain Reading
Pages: 201
Stars: ★★★★
Three Words: Informative, Beautiful, Gripping
First off, I have to say, what a beautiful cover!! When I saw this I just fell in love! It looks like a painting. As they say a picture can paint a 1000 words and this one paints a million. I think it's the colours, the brush work and the fact that it's right in the middle of action, I can tell that something big is happening!
In this next story line, Kitty is continuing her round the world adventure and lands in Iceland. Although I Ireland is (relatively) near to Iceland I have never been there. By the end of this book though I felt like I had. The country is described so beautifully by Iain Reading. I also learned a HUGE amount about Icelandic culture. For instance, people don't have family names but instead make up their own second name by combining "daughter of/ son of " with one of their parent's names. It's so fascinating, I never knew this stuff before.
The action in this book got a lot more dramatic and definitely kept me gripped. The story feels like it's getting older as if aimed at an audience that is growing. I also really liked the environmental factor and learned so much about geographical things like volcanoes and geothermal energy.
However I felt like some things didn't fit together. The Russian guys are kind of random and I was still waiting to come full circle and find out that they were connected in some mad way. I was wondering about a mystery that wasn't even really a mystery. Perhaps I just missed this in the book and haven't realised some mega plot line ....
Anyhoo another element I very much loved was all the fables, the elves and the magic! And also how this tied in with story. Very cool!
I do like when a jigsaw fits nicely together and for the most part this book did. I encourage anyone with a yearning for knowledge and fun to read these books.


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Inspiring fifty has listed the 50 most Inspiring women in tech in the Netherlands 2017. According to inspiring fifty: "The Netherlands may be small, but the country has some serious technology talent". Amongst the 50 tech super women are listed three WiCS members: Melanie Rieback, Gina Doekhie and Anouk Vos.
Melanie Rieback – Co-Founder and CEO at Radically Open Security
Computer security and cybercrime, that's what Melanie has built her career around. Her company Radically Open Security is actually the world's first non-profit computer security consultancy company. 90% of their profit goes to a foundation that fights to keep the internet open and safe.
Gina Doekhie – Forensic IT Expert at Fox-IT
Gina is one of the IT experts who's out to make the online world a safer place. At Fox-IT, she advises socially responsible organisations like, governments and clients in the financial sector helped by her knowledge on Artificial Intelligence and Forensic Intelligence.
Anouk Vos – Founding Partner at Revnext
Anouk is one of the founders of Revnext. They advise governmental organizations and multinationals on cyber security. She's also president of the Women in Cyber Security Foundation, where she heads a growing international community of over 700 women who work in her field.
It is a special honor that three of our WiCS are mentioned at such a prestigious tech-women list.
'Too few women active in tech'
Janneke Niessen, initiator of the Inspiring Fifty list, created the Inspiring fifty list to showcase the amount of talented women in tech there already are, but also to inspire more women to join the techology field. In the Dutch newspaper 'Trouw' Niessen claims: "Young women do not choose the technology field, based on false and prejudiced knowledge".
Niessen hopes that one day the Inspiring fifty list won't be a necessity anymore. In the mean time she will keep on working towards a more diverse technology environment.
Here you can read the 'Trouw' article 'Techniek is nog te weinig een vrouwenbusiness' in Dutch.
The entire Inspiring fifty most inspiring women in tech list of 2017 . WiCS is already looking forward to the 2018 edition. Go women in tech!


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How to Make a Pillow with an Invisible Zipper while Drinking Mojitos & Giveaway
6 comments:
- Natalie said...
Did you paint that zebra print work table in the picture? I would LOVE to know how to do that.
- August 20, 2010 at 10:57 AM
- Nikki said...
I just bought the same fabric to make throw pillows! Got it in the mail yesterday. Now I'm thinking yellow piping might be a must. I'm not ambitious enough for zippers, but I am ambitious enough for mojitos!
- August 20, 2010 at 4:05 PM
Loved your video - you girls are talented and funny!! DO you think you could post a DIY blog on painting kitchen counters? I'd love to know how... thanks.
A Wallin
- August 21, 2010 at 10:20 PM
- Sabrina said...
OK I'm in instant fan. I love crafting, mojitos, and colors!! You girls maintained much better than I would have!
- August 22, 2010 at 11:48 AM
- Mel said...
Too much fun for two girls all at once :) Love it.
I would love it if you can share some really easy slip covers, especially for the back of chairs.
I can sew, barely, but I get so frustrated. Easy projects that are quick to do are my cup of tea.
- September 3, 2010 at 9:55 PM
i love the pillow and mojitos , good work girls
it was instructive and fun
- February 20, 2011 at 6:25 PM