“Some judges are below-average bosses, but some clerks are below-average employees. I know of some great judges (and great bosses) who had clerks who left midstream because the clerks themselves had problems that made them unsuitable for demanding positions. I think this is especially true now, when law students are being told that they should be coddled—not have to work very hard, not have to listen to opinions they dislike, etc.”
As I often like to do, I'll kick things off by posting a comment I received from a reader, in response to this observation:
"Clerks do quit, half of all judges are below-median employers (by definition), and the median is not necessarily that high."
The comment:
"Aren't federal judges as a group vastly different from employers writ large? Given the qualifications and background checks required of judges, you would think that they would be—in the aggregate, acknowledging outliers—far better bosses than the average supervisor in the average workplace."
A number of clerks quit Judge Irving R. Kaufman during his later years on the Second Circuit. Maybe one of his former clerks can provide a more precise accounting here. (He was also known to fire clerks for reasons having nothing to do with their competence -- I'm told he fired one clerk for coming in late after her dog had been hit by a car and she took the dog to the vet.)
I clerked for a judge on the Second Circuit in 1981-2. During that year, two clerks in Judge Irving Kaufman's chambers quit for what seemed to me, as an outsider, for good reasons. So I don't think it's all accurate to say, "clerks don't quit."
Clerks leaving early was exceedingly rare when I clerked in the 90s, even clerks who worked for judges that were later exposed, no pun intended, as serial clerk abusers. See, e.g, Kozinski. There was a practical reason. Quitting a one or two-year job commitment early was generally considered a black mark with law firms for obvious reasons But there was one judge on the Second Circuit whose clerks could quit without shame, and indeed rarely completely their tenure -- Judge Irving Kauffman. Judge Kaufman's abusive behavior was well known among law students and law firms so bailing from a Kaufman clerkship didn't carry the usual stigma.
I appreciate the conversation here, but I don't know how we'll ever get past some people saying it happens all the time, and others saying it doesn't — except if we can get a public access, FOIA-like law for the judiciary. This is something we're working on at Free Law project (where I'm director), but until we can ask the judiciary these kinds of questions, we're going to be grasping around in the dark.
In my day, Irving Kaufman of the 2nd Circuit was a notoriously bad judge to work for, and many law students who would otherwise have loved a 2nd Circuit gig avoided him. There were numerous stories of clerks quitting on him. I recall one classmate, whose grades probably would have foreclosed a clerkship anywhere near so prestigious, taking the gamble. My memory is that he ended up quitting mid-clerkship too.
I was a Boggs clerk and felt like family the entire time. A very nerdy family - but still extremely supportive and friendly. Of course that was the 90s when dinosaurs roamed free and we shepardized citations with a book.
The trial judge I clerked for in the mid eighties was an absolute delight. She really was a shining example of what you want on the bench (she passed recently) and I loved working with her. We were not federal, but the DC Superior Court, and there were some judges who did not have a pleasant temperament at all. I don’t know how anyone worked for them - and one in particular was not offered senior status when he retired because of it.
NAL, but I know stats. This letter suggests that clerks in general quit at a rate around 5%, maybe higher. Assume twice that to be conservative, and the chances that 2 clerks will leave their positions for random reasons is 1% (p1*p2), suggesting that the resignations in Judge Cannon's chambers were not random events.
I accepteda District Court clerkship mid-year to replace a clerk who quit. The strong bias against complaining about judges prevented anyone from telling me why she quit, but let’s just say it quickly became obvious. It was a terribly sexist and abusive environment in chambers. I stuck out my six months, but have never had anything to do with that judge again. Clerks quit.
I, fortunately, had a good clerkship experience in the very busy Southern District of Florida (late 1980's.) I am not aware of anyone quitting in during my time but I was clerk to the only judge stationed in West Palm Beach at the time. The Fort Lauderdale and Miami offices may have been different. Honestly, we were so busy that any kind of Southern District clerk gossip wasn't a priority. Perhaps some young lawyers simply aren't prepared for how much work the job requires and the serious responsibility one bears in it. I'm pretty sure I would have had the tough it out mentality had the position been unpleasant. I was fortunate to have wonderful co-clerks also.
I clerked for a terrific USDC Judge. Yes, I worked really hard but so did he. He was also a great teacher. But I have another question some here might answer. I quit Law Review. At the time, I was told no one quits law review and that I would be the first law review quitter in the history of the publication. Anyone else quit law review?
Also, I can't help but find the attitude expressed by many people (Sarah Isgur) of: well you want a clerkship you should be willing to sacrifice the privilege of getting to plan a plane trip somewhere etc a bit inconsistent.
Look, the perspective that says: this isn't charity, you want to get ahead you have to show a willingness to put in the hours is perfectly coherent and I respect it.
But if you take that seriously you can't then turn around and say, but we can't hold it against women (or parents generally) who choose to take off more time than is medically necessary to have children. That's a life choice you are making and there are guys (myself included) willing to be the house spouse so if it's all a no excuses which do you value more world than why isn't this part of that?
OTOH if you take the view that in a good society we shouldn't impose unnecessary hardships on people, that the tradeoff in cost to personal lives by demanding absurd levels of commitment (eg foregoing kids) often isn't worth the minor efficiency benefits of never being able to arrange time off ahead then that view needs to apply to everyone regardless of stage of life of whether it's kids they have to give up or going to their best friend's wedding or whatever.
I have to wonder how much of being willing to work the long hours isn't just about a line on the resume but a sense they are making a difference.
Even the lawyers I've heard speak about their clerkships with judges who they are at ideological odds with almost universally seem to regard those judges as fair minded, good people who are trying to reach the right results in good faith and value their input. Because, that's true of most judges (indeed most people if placed in that kind of role). Ultimately, there was alot of trust between the judge (or justice) and the clerks.
So, I wonder if what we are seeing is a result of a breakdown of that trust. If you either no longer feel you're trusted and valued by the judge (either because of ideology or stress driven abuse) or that you are doing a good thing I suspect that just the resume line might no longer be enough.
OTOH there is the more cynical explanation that what people really want is social status. Sure, high pay is often a measure of that but if you suddenly start having people go 'eww' rather than be impressed by your clerkship that could matter too.
But I have no first or secondhand experience so I'd love to hear what those who do think.
Here are a couple of (possibly convergent) Cannon narrative threads I'm researching. Not finished, but I'm sharing as a different angle of view that may help others connect dots, as they do for me:
Thread 1:
Try viewing Cannon’s actions through this lens: Cannon has reason to feel exceedingly indebted to Trump, not only for the lifetime appointment, but above and beyond for family and community considerations missed by most if not all legacy media biographical sketches. Her birth in Columbia is not consequential to her story. The nationalization of her maternal grandfather's thriving advertising business by Castro in 1960 is the pivotal point of her family narrative and may tie to Marco Rubio having reached out to her specifically with invitation to submit an application for the Ft Pierce bench in May 2019[13], which at that point had been (held?) vacant for two years after her predecessor[2][3] stepped down to assume senior status. Those two years were enough for Cannon to reach 12 years law practice experience, the minimum for ABA approval when nominated for the federal bench. A month or two before Rubio's offer Trump, through SOS Pompeo, reversed 24 years of restraint on portions of the Helms-Burton Act to open a narrow window allowing dispossessed Cuban exiles to sue for reparations against international companies granted use of those nationalized properties by Castro. Accordingly one group of 25 plaintiffs jointly filed suit against a Swiss cement company in Claflin v LafargeHolcim Ltd. That suit hit the docket of federal district Judge Kathleen Williams(Magistrate Alicia Otazo-Reyes), Southern District of Fla, Miami in Sept 2020[1]. On Nov 23 2020, just eleven days after Cannon's confirmation, a reassignment order moved 11 civil cases from Judge Williams' docket to Judge Canon, including Claflin v. LafargeHolcim. Just 7 months after that, in June 2021, the normally snail-paced Cannon presided over the settlement of that case in favor of plaintiffs. To my knowledge that case was the FIRST successful Castro-nationalized reparations case ever, probably sparking an all night street party on Calle Ocho, and making Judge Cannon something of a Cuban exile folk hero, and elevating her mother (who helped her grandfather organize anti-Castro movements) to top shelf exile community society. Who wouldn't be exceedingly grateful in her shoes?
Grandpa, to his dying day in 2015, nursed a visceral hatred against JFK for botching the Bay of Pigs invasion by not committing enough air support. In grandpa’s extended and closely-knit family Anti-Castro, Anti-Communist, and likely even Anti-Democrat vitriol would have been served for breakfast for generations. Even more so at the table of Cannon’s mother Mercedes, who was grandpa’s able lieutenant in organizing and supporting Anti-Castro movements in both South Florida and in the broad reach of the family’s pan-Latin-American advertising business[4]. If Cannon ends up presiding over a Trump conviction a sizable chunk of her extended family can be expected to wholly disown her.
Another factor: A Joe McCarthy level Communist-scare has been reanimated and MAGA-amplified in South Florida. If you doubt that please check out this guy that they dragged onstage at the 2020 Republican convention[7] . That Commie-under-every-bed Koolaid glass would have been by her plate at family gatherings, South-Florida-tailored Federalist Society seminars, and associated front group gatherings/seminars.
Would Cannon have just taken sips of that Koolaid in order to get along, or might she have eventually drunk deeply?
Those propaganda riddled free-vacation seminars at seaside and mountain resorts have been a mainstay of Koch-led billionaire donor networks' judicial influence campaigns and ultra-free-market-radicalization campaigns for at least 40 years, as in this Key West resort seminar receipt[8] and agenda[9] as noted in SDFLA Magistrate Alicia Otazo-Reyes’s 2020 financial disclosure.
Cannon prefers the mountain resort free-vacation seminar option (from the same dark money providers) as seen in her disclosures for 2021 and 2022[10].
I believe there are many more dots to connect on this thread. Still delving public record for more . . . . . .
Thread 2:
Cannon’s husband Josh(Joshua Stanley) Lorence spent 4 years working for alleged Colombo mob family soldier John Rosatti's BurgerFi quick-service-restaurant chain, building it up from 2 locations in Fla to 90 nationwide between 2011 and 2014. He was promoted to COO during 2014 though he was replaced by another COO by the end of that year. He moved on to become COO for Bobby's Burgers. When he started with Rosatti in 2011 Cannon was doing a private practice stint at Gibson & Dunn, DC, but she moved up to the next legal career plateau as an Assistant US Attorney at SDFL while he was still working for, and even getting promoted by, an alleged mafia family soldier. I've read her 2019 application for the bench and THAT fact was of course noticably absent. I need to see transcripts of Rubio's judicial appointment panel interviews, US Senate staff interviews, and Senate Confirmation Hearing. If anybody knows how to go about that, please advise.
There ought to be a social media or yacht-fanzine picture out there somewhere of Lorence and Cannon clicking champagne glasses with Rosatti on the deck of one of his oligarch class megayachts after a string of successful grand openings.
Rosatti and his alleged Colombo-soldier ally/yacht-pal John Staluppi are reported to have remained in Trump's orbit from their "Trump Limousine" collaboration and casino ties in the 80's up to the present day[6][11][12].
Josh Lorence's association with Rosatti was probably strickly business and innocent, but no stone unturned . . . . . .
In any case Rosatti would surely have met Aileen Cannon during those 4 years and would have been aware through even introductory conversation that she was an up and coming Assistant US Attorney in SDFLA, raising the possibility that he could have mentioned Cannon to Trump later, possibly noting her Cuban exile community creds, and then Trump tapped Rubio to check her out.
The scary part of this thread is that if she wavers from her Trump bias any resulting anonymous threats against her two teenage kids could take on heightened credibility in her mind.
Note: I'm just a retired engineer (with an affinity for deep-delve research), but ever since Dec 15 2020 when Trump refused to accept the legitimate Electors' filings from the previous day I have devoted as much time as I possibly can to researching just what the hell is happening to my country.
From a former clerk who’s now a Biglaw partner:
“Some judges are below-average bosses, but some clerks are below-average employees. I know of some great judges (and great bosses) who had clerks who left midstream because the clerks themselves had problems that made them unsuitable for demanding positions. I think this is especially true now, when law students are being told that they should be coddled—not have to work very hard, not have to listen to opinions they dislike, etc.”
As I often like to do, I'll kick things off by posting a comment I received from a reader, in response to this observation:
"Clerks do quit, half of all judges are below-median employers (by definition), and the median is not necessarily that high."
The comment:
"Aren't federal judges as a group vastly different from employers writ large? Given the qualifications and background checks required of judges, you would think that they would be—in the aggregate, acknowledging outliers—far better bosses than the average supervisor in the average workplace."
A number of clerks quit Judge Irving R. Kaufman during his later years on the Second Circuit. Maybe one of his former clerks can provide a more precise accounting here. (He was also known to fire clerks for reasons having nothing to do with their competence -- I'm told he fired one clerk for coming in late after her dog had been hit by a car and she took the dog to the vet.)
I clerked for a judge on the Second Circuit in 1981-2. During that year, two clerks in Judge Irving Kaufman's chambers quit for what seemed to me, as an outsider, for good reasons. So I don't think it's all accurate to say, "clerks don't quit."
Clerks leaving early was exceedingly rare when I clerked in the 90s, even clerks who worked for judges that were later exposed, no pun intended, as serial clerk abusers. See, e.g, Kozinski. There was a practical reason. Quitting a one or two-year job commitment early was generally considered a black mark with law firms for obvious reasons But there was one judge on the Second Circuit whose clerks could quit without shame, and indeed rarely completely their tenure -- Judge Irving Kauffman. Judge Kaufman's abusive behavior was well known among law students and law firms so bailing from a Kaufman clerkship didn't carry the usual stigma.
I appreciate the conversation here, but I don't know how we'll ever get past some people saying it happens all the time, and others saying it doesn't — except if we can get a public access, FOIA-like law for the judiciary. This is something we're working on at Free Law project (where I'm director), but until we can ask the judiciary these kinds of questions, we're going to be grasping around in the dark.
In my day, Irving Kaufman of the 2nd Circuit was a notoriously bad judge to work for, and many law students who would otherwise have loved a 2nd Circuit gig avoided him. There were numerous stories of clerks quitting on him. I recall one classmate, whose grades probably would have foreclosed a clerkship anywhere near so prestigious, taking the gamble. My memory is that he ended up quitting mid-clerkship too.
I was a Boggs clerk and felt like family the entire time. A very nerdy family - but still extremely supportive and friendly. Of course that was the 90s when dinosaurs roamed free and we shepardized citations with a book.
The trial judge I clerked for in the mid eighties was an absolute delight. She really was a shining example of what you want on the bench (she passed recently) and I loved working with her. We were not federal, but the DC Superior Court, and there were some judges who did not have a pleasant temperament at all. I don’t know how anyone worked for them - and one in particular was not offered senior status when he retired because of it.
NAL, but I know stats. This letter suggests that clerks in general quit at a rate around 5%, maybe higher. Assume twice that to be conservative, and the chances that 2 clerks will leave their positions for random reasons is 1% (p1*p2), suggesting that the resignations in Judge Cannon's chambers were not random events.
I accepteda District Court clerkship mid-year to replace a clerk who quit. The strong bias against complaining about judges prevented anyone from telling me why she quit, but let’s just say it quickly became obvious. It was a terribly sexist and abusive environment in chambers. I stuck out my six months, but have never had anything to do with that judge again. Clerks quit.
I, fortunately, had a good clerkship experience in the very busy Southern District of Florida (late 1980's.) I am not aware of anyone quitting in during my time but I was clerk to the only judge stationed in West Palm Beach at the time. The Fort Lauderdale and Miami offices may have been different. Honestly, we were so busy that any kind of Southern District clerk gossip wasn't a priority. Perhaps some young lawyers simply aren't prepared for how much work the job requires and the serious responsibility one bears in it. I'm pretty sure I would have had the tough it out mentality had the position been unpleasant. I was fortunate to have wonderful co-clerks also.
I clerked for a terrific USDC Judge. Yes, I worked really hard but so did he. He was also a great teacher. But I have another question some here might answer. I quit Law Review. At the time, I was told no one quits law review and that I would be the first law review quitter in the history of the publication. Anyone else quit law review?
Also, I can't help but find the attitude expressed by many people (Sarah Isgur) of: well you want a clerkship you should be willing to sacrifice the privilege of getting to plan a plane trip somewhere etc a bit inconsistent.
Look, the perspective that says: this isn't charity, you want to get ahead you have to show a willingness to put in the hours is perfectly coherent and I respect it.
But if you take that seriously you can't then turn around and say, but we can't hold it against women (or parents generally) who choose to take off more time than is medically necessary to have children. That's a life choice you are making and there are guys (myself included) willing to be the house spouse so if it's all a no excuses which do you value more world than why isn't this part of that?
OTOH if you take the view that in a good society we shouldn't impose unnecessary hardships on people, that the tradeoff in cost to personal lives by demanding absurd levels of commitment (eg foregoing kids) often isn't worth the minor efficiency benefits of never being able to arrange time off ahead then that view needs to apply to everyone regardless of stage of life of whether it's kids they have to give up or going to their best friend's wedding or whatever.
I have to wonder how much of being willing to work the long hours isn't just about a line on the resume but a sense they are making a difference.
Even the lawyers I've heard speak about their clerkships with judges who they are at ideological odds with almost universally seem to regard those judges as fair minded, good people who are trying to reach the right results in good faith and value their input. Because, that's true of most judges (indeed most people if placed in that kind of role). Ultimately, there was alot of trust between the judge (or justice) and the clerks.
So, I wonder if what we are seeing is a result of a breakdown of that trust. If you either no longer feel you're trusted and valued by the judge (either because of ideology or stress driven abuse) or that you are doing a good thing I suspect that just the resume line might no longer be enough.
OTOH there is the more cynical explanation that what people really want is social status. Sure, high pay is often a measure of that but if you suddenly start having people go 'eww' rather than be impressed by your clerkship that could matter too.
But I have no first or secondhand experience so I'd love to hear what those who do think.
Here are a couple of (possibly convergent) Cannon narrative threads I'm researching. Not finished, but I'm sharing as a different angle of view that may help others connect dots, as they do for me:
Thread 1:
Try viewing Cannon’s actions through this lens: Cannon has reason to feel exceedingly indebted to Trump, not only for the lifetime appointment, but above and beyond for family and community considerations missed by most if not all legacy media biographical sketches. Her birth in Columbia is not consequential to her story. The nationalization of her maternal grandfather's thriving advertising business by Castro in 1960 is the pivotal point of her family narrative and may tie to Marco Rubio having reached out to her specifically with invitation to submit an application for the Ft Pierce bench in May 2019[13], which at that point had been (held?) vacant for two years after her predecessor[2][3] stepped down to assume senior status. Those two years were enough for Cannon to reach 12 years law practice experience, the minimum for ABA approval when nominated for the federal bench. A month or two before Rubio's offer Trump, through SOS Pompeo, reversed 24 years of restraint on portions of the Helms-Burton Act to open a narrow window allowing dispossessed Cuban exiles to sue for reparations against international companies granted use of those nationalized properties by Castro. Accordingly one group of 25 plaintiffs jointly filed suit against a Swiss cement company in Claflin v LafargeHolcim Ltd. That suit hit the docket of federal district Judge Kathleen Williams(Magistrate Alicia Otazo-Reyes), Southern District of Fla, Miami in Sept 2020[1]. On Nov 23 2020, just eleven days after Cannon's confirmation, a reassignment order moved 11 civil cases from Judge Williams' docket to Judge Canon, including Claflin v. LafargeHolcim. Just 7 months after that, in June 2021, the normally snail-paced Cannon presided over the settlement of that case in favor of plaintiffs. To my knowledge that case was the FIRST successful Castro-nationalized reparations case ever, probably sparking an all night street party on Calle Ocho, and making Judge Cannon something of a Cuban exile folk hero, and elevating her mother (who helped her grandfather organize anti-Castro movements) to top shelf exile community society. Who wouldn't be exceedingly grateful in her shoes?
Grandpa, to his dying day in 2015, nursed a visceral hatred against JFK for botching the Bay of Pigs invasion by not committing enough air support. In grandpa’s extended and closely-knit family Anti-Castro, Anti-Communist, and likely even Anti-Democrat vitriol would have been served for breakfast for generations. Even more so at the table of Cannon’s mother Mercedes, who was grandpa’s able lieutenant in organizing and supporting Anti-Castro movements in both South Florida and in the broad reach of the family’s pan-Latin-American advertising business[4]. If Cannon ends up presiding over a Trump conviction a sizable chunk of her extended family can be expected to wholly disown her.
Another factor: A Joe McCarthy level Communist-scare has been reanimated and MAGA-amplified in South Florida. If you doubt that please check out this guy that they dragged onstage at the 2020 Republican convention[7] . That Commie-under-every-bed Koolaid glass would have been by her plate at family gatherings, South-Florida-tailored Federalist Society seminars, and associated front group gatherings/seminars.
Would Cannon have just taken sips of that Koolaid in order to get along, or might she have eventually drunk deeply?
Those propaganda riddled free-vacation seminars at seaside and mountain resorts have been a mainstay of Koch-led billionaire donor networks' judicial influence campaigns and ultra-free-market-radicalization campaigns for at least 40 years, as in this Key West resort seminar receipt[8] and agenda[9] as noted in SDFLA Magistrate Alicia Otazo-Reyes’s 2020 financial disclosure.
Cannon prefers the mountain resort free-vacation seminar option (from the same dark money providers) as seen in her disclosures for 2021 and 2022[10].
I believe there are many more dots to connect on this thread. Still delving public record for more . . . . . .
Thread 2:
Cannon’s husband Josh(Joshua Stanley) Lorence spent 4 years working for alleged Colombo mob family soldier John Rosatti's BurgerFi quick-service-restaurant chain, building it up from 2 locations in Fla to 90 nationwide between 2011 and 2014. He was promoted to COO during 2014 though he was replaced by another COO by the end of that year. He moved on to become COO for Bobby's Burgers. When he started with Rosatti in 2011 Cannon was doing a private practice stint at Gibson & Dunn, DC, but she moved up to the next legal career plateau as an Assistant US Attorney at SDFL while he was still working for, and even getting promoted by, an alleged mafia family soldier. I've read her 2019 application for the bench and THAT fact was of course noticably absent. I need to see transcripts of Rubio's judicial appointment panel interviews, US Senate staff interviews, and Senate Confirmation Hearing. If anybody knows how to go about that, please advise.
There ought to be a social media or yacht-fanzine picture out there somewhere of Lorence and Cannon clicking champagne glasses with Rosatti on the deck of one of his oligarch class megayachts after a string of successful grand openings.
Rosatti and his alleged Colombo-soldier ally/yacht-pal John Staluppi are reported to have remained in Trump's orbit from their "Trump Limousine" collaboration and casino ties in the 80's up to the present day[6][11][12].
Josh Lorence's association with Rosatti was probably strickly business and innocent, but no stone unturned . . . . . .
In any case Rosatti would surely have met Aileen Cannon during those 4 years and would have been aware through even introductory conversation that she was an up and coming Assistant US Attorney in SDFLA, raising the possibility that he could have mentioned Cannon to Trump later, possibly noting her Cuban exile community creds, and then Trump tapped Rubio to check her out.
The scary part of this thread is that if she wavers from her Trump bias any resulting anonymous threats against her two teenage kids could take on heightened credibility in her mind.
*****************************************************************************************************
Note: I'm just a retired engineer (with an affinity for deep-delve research), but ever since Dec 15 2020 when Trump refused to accept the legitimate Electors' filings from the previous day I have devoted as much time as I possibly can to researching just what the hell is happening to my country.
[1] https://www.courtlistener.com/docket/18433675/claflin-v-lafargeholcim-ltd/#entry-16
[2] https://en.wikipedia.org/wiki/Kenneth_Marra
[3] https://www.nytimes.com/interactive/2017/02/14/upshot/trump-poised-to-transform-american-courts.html
[4] https://www.dailymail.co.uk/news/article-12332547/How-JFKs-betrayal-Bay-Pigs-invasion-shaped-views-Trump-appointed-Judge-Aileen-Cannon-granddaughter-Cuban-exiles-rule-ex-presidents-Mar-Lago-documents-case.html
[5] https://thehill.com/homenews/campaign/547302-trump-hands-rubio-coveted-reelection-endorsement-in-florida/
[6] https://www.waynemadsenreport.com/articles/march-15-2024-trump-nominated-mobbedup-judge-aileen
[7] https://youtu.be/jJnShBMG3uY
[8] https://www.courtlistener.com/person/9177/disclosure/32357/alicia-otazo-reyes/
[9] https://masonlec.org/wp-content/uploads/2020/02/Introduction-to-Economics-Agenda-.pdf[
10] https://www.msn.com/en-ca/news/politics/what-aileen-cannon-s-financial-disclosures-reveal/ar-AA1eJXpw
[11]https://www.fivefamiliesnyc.com/p/current-leadership-of-five-families.html
[12]https://www.fivefamiliesnyc.com/2021/04
[13]https://www.politico.com/news/2022/09/06/judge-mar-a-lago-trump-00055082