neurodiversity weblog

Clifford J. Shoemaker, Shoemaker & Associates, 9711 Meadowlark Road, Vienna, Virginia was ordered to show cause why he should not be sanctioned under Fed. R. Civ. P. 11 with respect to a subpoena duces tecum served on a non-party to a case then
pending in the Eastern District of Virginia. 1 The time allotted to Shoemaker to show cause expired but he was subsequently given additional time.

Background

Clifford Shoemaker, Esq. was counsel to the plaintiff in the underlying case. In the underlying case the claim was that the plaintiff-child developed neuro-developmental disorders from high mercury exposure as a result of exposure to defendant’s medicine in utero. Shoemaker is a 1973 law school graduate who indicates on his website that he has focused his attention on an alleged mercury-created autism epidemic. He claims to have “tried cases in federal district courts all over the country.”

Ms. Seidel was a non-party to the Sykes’ suit. Ms. Seidel maintains a website, www.neurodiversity.com, on which she posts articles she and others have written about the controversy about whether mercury has or has not created an autism epidemic.

Shortly after posting an article on several fees Mr. Shoemaker obtained in various Vaccine Injury Compensation Program claims, Shoemaker served Ms. Seidel with the subpoena at issue.

The subpoena, as Ms. Seidel correctly summarizes:

commands production of “all documents pertaining to the setup, financing, running, research, maintaining the website
http://www.neurodiversity.com” – including but not limited to material mentioning the plaintiffs – and the names of all persons “helping, paying or facilitating in any fashion” my endeavors. The subpoena demands copies of all of my communications concerning any issue which is included on my website, including communications with representatives of the federal government, the pharmaceutical industry, advocacy groups, non-governmental organizations, political action groups, profit or non-profit entities, journals, editorial boards, scientific boards, academic boards, medical licensing boards, any “religious groups (Muslim or otherwise), or individuals with religious affiliations,” and any other “concerned individuals.”

The subpoena is very broad. Ms. Seidel filed a timely and well-prepared motion to quash. Shoemaker interposed no objection. The record provides no information as to whether Shoemaker provided notice of the subpoenaed deposition to counsel for defendants.

I quashed the subpoena and ordered Mr. Shoemaker to show cause why he should not be sanctioned under Fed. R. Civ. P. 11. He has responded to that Order. Ms. Seidel has responded to his response.

Discussion

(T)he risks attendant to the misuse of the subpoena power are great . . .. “Moreover, the injury resulting from attorney misuse of the subpoena power is not limited to the harm it inflicts upon the parties. Rather, misuse of the subpoena power also compromises the integrity of the court’s processes.”

(citation omitted). Spencer v. Steinman, 1999 WL 33957391, *2 (E.D.Pa.). Fed. R. Civ. P. 45(a)(1) requires an attorney to take steps to avoid imposing an undue burden or expense on a subpoenaed non-party. Fed. R. Civ. P. 11(b) requires an attorney who signs or later advocates a court paper to refrain from presenting it for any improper purpose such as to harass.

The subpoena which I have attached to this order is breathtakingly broad. Mr. Shoemaker made no attempt to avoid imposing an undue burden or expense on Ms. Seidel. To the contrary, I find that he sought to burden her by requiring production of every scrap of paper related to autism, her web site, her tax returns, and her communications with the government. He improperly imposes a requirement to create documents, e.g., a list of “names of persons helping, paying or facilitating . . . these endeavors.” The documentation sought is exhaustive.

Shoemaker seeks to justify the subpoena by allegations that Seidel is not “a mere mother of an autistic child and housewife,” but a co-conspirator under 42 U.S.C. §1985 with her husband or “the defendant (Bayer) or by some organization dedicated to harassing this plaintiff (Ms. Sykes) and her witness . . .” Shoemaker’s claim that Ms. Seidel was the “leader of a conspiracy to obstruct justice . . .” is unsupported by any facts. It is clear that she has openly and extensively exercised her First Amendment right to speak out on the issue. Shoemaker certainly has the right to disagree with her, but he has no right to misuse the process to abuse her.

Shoemaker has not offered a shred of evidence to support his speculations. He has, he says, had his suspicions aroused because she has so much information. Clearly he is unfamiliar with the extent of the information which a highly-competent librarian like Ms. Seidel can, and did, accumulate. If Shoemaker wanted to know if Ms. Seidel was in part supported by or provided information by Bayer, he could have inquired of Bayer or limited the Seidel subpoena to that information. Instead he issued the subpoena calling for production of documents and a deposition on the day before he stipulated to dismiss the underlying suit with prejudice. His failure to withdraw the subpoena when he clearly knew that suit was over is telling about his motives. His efforts to vilify and demean Ms. Seidel are unwarranted and unseemly.

Clearly the litigants are passionate about the causative issues surrounding autism. Nothing in this order is intended to indicate that this court has any view as to who is right on the autism issues. What the court does have views about is the impropriety of misuse of a subpoena. 2 Shoemaker could make an argument for discovery from Seidel to attempt to establish that his defendants improperly used her and her web site to impact witnesses in the underlying case. That might meet Rule 26‘s smell test. However, he has no right: (1) to serve a grossly overly broad subpoena intended to harass; (2) to go on a “fishing trip” for anything to support a new suit for defamation or for a §1985(3) conspiracy; and (3) to fail his duties under Rule 45(c)(1). Most of the documents sought have no arguable relevance to the underlying case and were not likely to lead to admissible evidence.

If Ms. Sykes or the Geiers believe they have a cause of action against Ms. Seidel, they have an avenue to pursue such a claim. What they and Shoemaker can not do is abuse the subpoena power in the Sykes v. Bayer case.

I find that Clifford Shoemaker violated Fed. R. Civ. P. 11(b)(1) and Rule 45(c)(1). The 11(b)(1) violation may also violate Virginia’s Rules of Professional Conduct which provide in part:

(1) Preamble: A lawyer should use the law’s procedures only for legitimate purposes and not to harass or intimidate others.

(2) Rule 3.1: A lawyer shall not assert or controvert an issue therein unless there is a basis for doing so which is not frivolous . . .

Comment [1]. The advocate has a duty to use legal procedure for the fullest benefit of the client’s cause, but also a duty not to abuse legal procedure. (emphasis added).

Clifford J. Shoemaker’s action is an abuse of legal process, a waste of judicial resources and an unnecessary waste of the time and expense to the purported deponent.

The Clerk of Court is directed to forward a certified copy of this order, the motion to quash, the show cause order, and the response of Shoemaker and Seidel to the appropriate professional conduct committee of the Virginia State Bar in order that it may be made aware of Clifford J. Shoemaker’s conduct and so that those authorities may take whatever action they deem appropriate.

As a sanction from this court, Clifford J. Shoemaker is ordered to attend within three months, a continuing legal education program on ethics and on the discovery rules in the Federal Rules of Civil Procedure. He is ordered to file a certification of completion of the programs.

SO ORDERED.

James R. Muirhead
United States Magistrate Judge

June 23, 2008

Footnotes

1. The case, Sykes v. Bayer Pharmaceuticals Corporation, et al., 3:07 cv 660 (E.d. Va. 2007) was dismissed with prejudice upon a voluntary stipulation of dismissal.

2. Shoemaker also issued a simultaneous abusive subpoena to a Massachusetts physician with views contrary to his effort.

A Whale of an Expert · 22 days ago

Participants in the ongoing debate about autism and vaccines know Whale.to as a treasure-trove of litigation-inspired “science,” conspiracism, health-care hysteria, and bizarre and grandiose fantasies, where immunization initiatives are envisioned as tools of covert genocide and their supporters as enablers of “medical mind control.”

The site features the full text of the Protocols of the Elders of Zion, a notorious anti-Semitic forgery in which vaccinations are viewed as an essential element of a dastardly Jewish plot to:

utterly exhaust humanity with dissension… even by the use of torture; by starvation; by the inoculation of disease; by want, so that the goyim see no other course open to them than to take refuge in our complete sovereignty in money and in all else.

Whale.to also hosts the anti-Catholic diatribe, Maniacal World Control Through the Jesuit Order, in which author Rick Martin asserts that Mafioso Carlo Gambino “was murdered with a vaccination, with a flu shot.”

Among the gems of speculation that have been published on Whale.to is this astonishing theory of autism causation from The Illuminati Formula Used to Create an Undetectable Total Mind Controlled Slave:

[O]ccasionally the child while in the womb when traumatized by the Moon Child rituals, retreats into its mind like a cocoon, and develops autism… The programmers are not able to reach such children, and essentially all were discarded into mental hospitals or used in rituals, until about 20 years ago when more and more of them were allowed to survive in public… [T]he increase in autistic children is believed by the authors to be the result of increased trauma-based mind control.

It is hardly surprising that those promoting a causal link between vaccinations and every medical condition imaginable (regardless of whether any reputable studies support their claims) should resort to citing to Whale.to to bolster their arguments. Its proprietor, John Scudamore, has assiduously accumulated every scrap of information and speculation he could find that validates his belief that vaccines are a scourge of modern medicine, inflicted upon the hapless masses by a shadowy elite bent on world domination.

It was considerably more surprising, however, to discover a recent Vaccine Injury Compensation Program decision — Jane Doe/16 v. HHS (No. 06-670V, June 2, 2008, unpublished) — that documents the introduction into evidence of material from Whale.to in a vaccine injury proceeding. In Jane Doe/16 v. HHS, attorney Thomas Gallagher, Esq. (who represents petitioners in 96 pending VICP claims, including many autism claims) enlisted the assistance of New Mexico otolaryngologist Dr. Frederick Fiber in the hope of persuading the court that an influenza vaccine caused his client’s hearing loss.

In her decision, Special Master Denise Vowell describes Dr. Fiber’s career as an ear, nose and throat specialist, and his opinion that the influenza vaccine “caused an inflammatory process to occur damaging the inner right ear resulting in a permanent hearing loss” — an opinion “not well elucidated” in either his one-page expert opinion or his testimony, and not supported by the petitioner’s medical records. She noted that Dr. Fiber was ill-prepared for the telephonic hearing, that on cross examination he was unable to locate an article he had discussed during direct examination only moments before, and that he attempted to testify about an internet search he was conducting at the same time that he was testifying. She recalled that his testimony largely consisted of “yes” or “no” responses to Mr. Gallagher’s leading questions — a tactic that, while not prohibited in Vaccine Act proceedings (which are not bound by the Federal Rules of Evidence) nonetheless served to detract from the persuasive value of his testimony.

She then described the scientific literature Dr. Fiber offered as the basis for his “expertise”:

In support of Dr. Fiber’s opinion on causation, petitioner filed three medical journal articles, a website printout, and a vaccine information sheet… Doctor Fiber testified that he first became aware of a connection between hearing loss and influenza vaccines based on the reported experiences of one of his patients. He did not provide details regarding the timing between this patient’s vaccinations and the patient’s hearing difficulties, the results of any audiological testing, or the apparently reversible nature of the patient’s hearing loss and vertigo. He based his opinion that the influenza vaccine could cause hearing problems on Pet. Ex. 13, a document entitled “International Vaccination Newsletter.” This is a document Dr. Fiber “found on the internet.” The URL found in the lower left hand corner of the document indicates that it is a printout from a website found at http://www.whale.to.

This website (last visited May 1, 2008) describes its mission as “mostly a medical politics and anti-vaccination site, the Big Brother and (his) Mind Control sections were included to show the wood from the (medical) trees and to see where Tyranny (eg wars, famine, atheism, poverty, droughts, killer hurricanes, drugs, crime, most disease fear, etc) really comes from, causing most folk to think God doesn’t exist! ‘Whale’ is a tribute to our larger brained mammals.” It appears from the configuration of the website, that Pet. Ex. 13 is not a medical journal article published elsewhere and merely linked to this website, as the article contains no medical journal citation or pagination.

Pet. Ex. 13 itself does not list an author. Respondent’s Trial Exhibit 1 is a printout from the same website, that identifies the author as Dr. Kris Gaublomme, a Belgian medical doctor and homeopath, who asserts that:

The vaccination lobby shamelessly takes all the children of this world as hostages to still their greed for money and power. They relentlessly abuse our compassion for the weaker and our concern about health to promote their giga-business. No matter what. No matter how many more vaccine victims will suffer death or side-effects. No matter how many financial resources this strategy devours at the expense of essential social investments like housing and employment. No matter what. Shocking!

The “International Vaccination Newsletter” consists of two parts. The first is a polemic asserting that influenza vaccines do not prevent influenza. The second contains summaries of case reports of post-vaccination illnesses. The decades-old references are apparently European medical journal case reports…

The Special Master explored the depth of the expert’s expertise.

…Doctor Fiber also testified about two other case reports briefly mentioned in Pet. Ex. 13… Doctor Fiber testified that he did not read the underlying case reports mentioned in the website article and had no further details concerning those cases…

On cross examination, Dr. Fiber acknowledged that he found no medical literature, other than the International Vaccine Newsletter, linking the influenza vaccine to sudden hearing loss. The peer-reviewed medical literature related to hearing loss and vaccines all concerned vaccines other than the influenza vaccine. He agreed that Pet. Ex. 14, a Food and Drug Administration information sheet on the Fluzone influenza vaccine, did not mention audiological problems as a possible adverse event temporally or causally associated with the vaccine.

Regarding the evidentiary standards applied in vaccine-injury claims, she observed:

The special master determines the reliability and plausibility of the expert medical opinions offered and the credibility of the experts offering them. Not all evidence carries equal weight with a trier of fact. A medical opinion on causation may be based on factually incorrect medical histories or it may be offered by someone without the necessary training, education, or experience to offer a reliable opinion. An expert’s opinion may be unpersuasive for a variety of reasons.

Courts, whether they deal with vaccine injuries, medical malpractice claims, toxic torts, or accident reconstruction, must base their decisions on reliable evidence. Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 594-96 (1993). Daubert provides a useful framework for evaluating scientific evidence in Vaccine Act cases. Terran v. Sec’y, HHS, 41 Fed. Cl. 330, 336 (1998), aff’d 195 F.3d 1302, 1316 (Fed. Cir. 1999), cert. denied, Terran v. Shalala, 531 U.S. 812 (2000). See also, Ryman v. Sec’y, HHS, 65 Fed. Cl. 35, 40 (2005) (special master performs gatekeeping function when he “determines whether a particular petitioner’s expert medical testimony supporting biologic probability may be admitted or credited or otherwise relied upon”)…

The Special Master offered a dispassionate evaluation of the expert testimony offered at the hearing, and the reliability of the sources from which Dr. Fiber derived his opinions.

…Doctor Fiber’s testimony that the influenza vaccine triggered an autoimmune hypersensitivity reaction supplies petitioner’s medical theory. Whether it is a reliable medical theory is another matter entirely. An on-line search of medical databases, such as PubMed and Medscape, is qualitatively different from an open-source search. The former will yield results related to indexed and peer-reviewed medical literature; the latter may access sources with questionable reliability.

Petitioners Exhibit 13 itself is of questionable reliability. It appears that the author is a frequent contributor to a website that bills itself as “antivaccine” and there is no evidence that it is a peer-reviewed publication. It is clear that a petitioner cannot be required to supply confirmation of medical plausibility by submitting peer reviewed medical literature. Stated differently, medical literature of any type may not be required as a condition precedent to finding vaccine causation. See Althen, 418 F.3d at 1279, 1281 (discussing the Federal Circuit’s rejection of the Stevens test, which required such evidence as a condition precedent to finding causation). However, when medical literature is submitted as evidence, the type of medical literature submitted may be weighed and evaluated in determining what weight should be accorded to that evidence. The Supreme Court has noted:

[S]ubmission to the scrutiny of the scientific community is a component of “good science,” in part because it increases the likelihood that substantive flaws in methodology will be detected. The fact of publication (or lack thereof) in a peer reviewed journal thus will be a relevant, though not dispositive, consideration in assessing the scientific validity of a particular technique or methodology on which an opinion is premised.

Daubert, 509 U.S. at 593-94. When an expert places reliance on documents such as Pet. Ex. 13, the weight that may be accorded that expert’s opinion is not enhanced.

She concluded that there was a dearth of reliable evidence linking the petitioner’s influenza vaccination to her hearing loss, leaving “a post hoc, ergo propter hoc, analysis that is insufficient to establish causation.”

A Meme in the Air

It is likely that when she was preparing her opinion, Special Master Vowell was unaware that a new eponymous law, apposite to the evidence presented by Dr. Fiber during the hearing in Jane Doe/16 v. HHS, had been coined that very week. On May 24, the U.K. Guardian reported that Dr. Edzard Ernst, Professor of Complementary Medicine at the University of Exeter, had harshly criticized Boots the Chemists, the U.K.‘s largest chain of pharmacies, for its lucrative trade in ineffective and questionably-labeled homeopathic remedies. Outraged by Dr. Ernst’s remarks, commenter “Principled” described skeptics of homeopathy as people who “blithely ignore the obvious destruction of life and intelligence as we know it,” maintained that “medical ‘science’ [is] probably the globes biggest killer and maimer of humanity,” and referred his readers to numerous sources, among them a political polemic on Whale.to.

The Guardian discussion attracted the attention of the denizens of Ben Goldacre’s Bad Science Forum, including U.K. skeptic Rich Scopie. Upon encountering the citation to Whale.to, Mr. Scopie quipped:

In any discussion involving science or medicine, citing Whale.to as a credible source loses you the argument immediately…

…and gets you laughed out of the room.

The adage was dubbed Scopie’s Law and heralded by the anonymous Dr* T, who linked from his blog to a newly created Wikipedia page about it. That page was eventually enhanced with a citation to an Evidence of Harm newsgroup post by the unabashed antivaccinationist Sheri Nakken, who made the uncorroborated claim that David Kirby relied heavily on Whale.to while researching his vaccine-injury plaintiffs’ potboiler, Evidence of Harm.

In short order, the Wikipedia page was deemed nonsensical vandalism and was therefore nominated a candidate for speedy deletion. The corpse of the page now moulders in Google’s cache.

For better or worse, the Special Masters of the U.S. Court of Federal Claims will not learn of Scopie’s Law from Wikipedia — that is, unless the neologism becomes notable enough for some weary Wiki-woo-fighters to determine that it merits reinclusion in the online encyclopedia, alongside Godwin’s Law and Hanlon’s Razor. The possibility is not far-fetched, given the frequent controversies over the use of Whale.to as a source in Wikipedia articles.

Although Scopie’s Law was not explicitly invoked in the Jane Doe/16 v. HHS entitlement decision, another opportunity will soon arise to enshrine the principle in the judicial corpus — that is, when Thomas Gallagher, Esq. submits to the U.S. Court of Federal Claims the bill for his legal services, and for the scientific expertise of Frederick Fiber, M.D., Whale.to Ph.D.

Vaccine Court Chronicles · 34 days ago

An evolving series of articles about vaccine-injury and thimerosal litigation in the civil courts, the Vaccine Injury Compensation Program and Omnibus Autism Proceeding, and the attorneys and “experts” who promote speculative, marginally supported hypotheses of disability causation.

Doe v. Ortho-Clinical Diagnostics

Plaintiffs’ Gambit Failed, July 11, 2006
The full text of Judge James Beaty’s ruling deeming inadmissible the expert testimony offered by Dr. Mark Geier, Prof. Boyd Haley and Prof. George Lucier, in a case alleging that autism was caused by thimerosal in Rho(D) immune globulin.

Sykes v. Glaxo SmithKline

A Plaintiff in the Pulpit, April 12, 2007
A letter to the United Methodist Church reviewing the “judicial advocacy” campaign of Rev. Lisa Sykes, lead plaintiff in Sykes v. Glaxo SmithKline (later Sykes v. Bayer), a case alleging that autism was caused by thimerosal in vaccines and Rho(D) immune globulin.

A Stubborn Case of Selective Altruism, May 15, 2007
A subsequent exchange of email with the United Methodist Church regarding their continuing support of Rev. Sykes’ position in thimerosal litigation.

Redfoot v. Ascher

A Case of Good Gatekeeping, September 7, 2007
Excerpts from pleadings in a case alleging that thimerosal in saline nasal spray caused a child to become autistic, and the court’s exclusion of expert testimony from Dr. Mark Geier, Dr. Boyd Haley, Dr. Jeffrey Bradstreet, Dr. George Lucier and Dr. Arthur Krigsman.

Omnibus Autism Proceeding

OAP: Contested Expertise & A New Test Case, September 8, 2007
About developments in OAP test cases Cedillo v. HHS and Hazelhurst v. HHS.

A Recusal Refusal, September 15, 2007
Excerpts from Special Master Patricia Campbell-Smith’s order in Doe v. HHS, warning petitioners about the dangers of relying upon the scholarship of frequently-offered petitioners’ expert Dr. Mark Geier.

Pulling for an Early Paycheck, September 18, 2007
A report on Judge Bohdan Futey’s ruling in Iannuzzi v. HHS, denying interim fee payments and payments for non-case-specific expenditures to Omnibus Autism Proceeding petitioners’ attorneys.

Blackwell v. Sigma-Aldrich

Too Daunting a Hurdle to Scale, December 30, 2007
Full text of Judge Stuart Berger’s ruling in a case alleging thimerosal causation of autism, deeming inadmissible the expert testimony offered by Dr. Mark Geier. Dr. Stephen Siebert, Dr. Elizabeth Mumper, Prof. Richard Deth, and Prof. Boyd Haley.

Blackwell Case Dismissed, February 20, 2008

Vaccine Injury Compensation Program History

The Autism-Vaccine Courtroom Knockout Team, January 23, 2008
A review of recent judicial rejections of testimony offered by expert witnesses central to the Omnibus Autism Proceeding, who promote the hypothesis that autism is a consequence of iatrogenic, vaccine-induced mercury poisoning.

A Brief Introduction to Vaccine Court, January 30, 2008
A summary of the Vaccine Injury Compensation Program.

Verdicts & Reversals, February 11, 2008
Synopses of six vaccine-injury lawsuits brought prior to the establishment of the Vaccine Injury Compensation Program: Toner v. Lederle, White v. Wyeth, Hurley v. Lederle, Abbott v. American Cyanamid, Jones v. Lederle, and Graham v. Wyeth.

The New Testimonial Arena, February 25, 2008
A review of decisions made during the early years of the Vaccine Injury Compensation Program in cases in which Dr. Mark Geier served as a petitioners’ expert witness.

Raising the Bar, March 5, 2008
A synopsis of Haim v. HHS, including excerpts from the decision discussing the relevance to Vaccine Injury Compensation Program proceedings of the Supreme Court’s then-new ruling in Daubert v. Merrell-Dow Pharmaceuticals regarding the admissibility of scientific evidence.

A Not-So-Hidden History, March 11, 2008
A review of VICP cases in which awards of compensation were made to individuals diagnosed with autism or related conditions after sustaining a verifiable vaccine injury.

The Commerce in Causation, March 24, 2008
A discussion of Poling v. HHS, economic incentives driving the promotion of marginal vaccine-causation hypotheses, and fee awards in VICP cases both meritorious and nonmeritorious.

A Whale of an Expert, June 13, 2008
Describing a recent VICP case in which the petitioner’s medical expert relied upon antivaccinationist material obtained from the conspiracist website http://www.whale.to.

Sykes v. Bayer (previously Sykes v. Glaxo SmithKline)

Sykes Saga Continues, February 18, 2008
A review of pleadings and developments in Sykes v. Bayer after the case was removed from Pennsylvania to Virginia.

Subpoenaed, April 3, 2008
In which the Sykes v. Bayer plaintiffs’ team retaliates against me for reporting on their lawsuit on Neurodiversity.com, and I respond.

In Distinguished Company, April 18, 2008
Summary and excerpts from Dr. Marie McCormick’s Motion to Quash the nonparty subpoena served against her in Sykes v. Bayer.

Quashed!, April 21, 2008
The New Hampshire court’s response to the Sykes v. Bayer plaintiffs’ subpoena against Kathleen Seidel.

Mercury Fades: Sykes v. Bayer Dismissed, May 2, 2008
About the abrupt dismissal with prejudice of Sykes v. Bayer in the midst of the discovery process.

Debate or Defamation?, May 8, 2008
Mr. Clifford Shoemaker’s preliminary response to the New Hampshire court’s Order to Show Cause why he should not be sanctioned for issuing a burdensome subpoena, followed by a review of the 2006 defamation lawsuit, Geier et al. v. HHS et al..

Welcome to My Conspiracy, May 18, 2008
In which the Sykes v. Bayer‘s plaintiffs offer their rationale for misusing their authority to issue a subpoena in that case.

McCormick Motion Moot, May 23, 2008
About the court’s termination of Dr. Marie McCormick’s Motion to Quash the subpoena issued against her in Sykes v. Bayer.

Pure Hearts & Empty Heads, May 27, 2008
Full text of Public Citizen’s response to the court’s Order to Show Cause regarding the subpoena served upon me in Sykes v. Bayer.

Sanctioned, June 23, 2008
Full text of Judge James Muirhead’s order sanctioning Mr. Clifford Shoemaker for abusing judicial process to intimidate and harass a critic.

neurodiversity weblog

Neurodiversity.com Autistic Spectrum Resources & Advocacy

Donations gratefully accepted via PayPal

Autism Books from Amazon

All Articles by Date & Subject

Sanctioned · 12 days ago

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE 1:08-MC-13

ORDER