Just as long as you’re not “impugning Parliament”…
November 6, 2009
Another part of Justice Dobson’s decision in Leigh (discussed below) revolves around the court’s anxiousness not to involve the courts in any impugning of Parliament. He rules that Ms Leigh can’t use Trevor Mallard’s attack on her in Parliament during Question Time to support her case.
There is good authority for this rule. One is the Bill of Rights 1688, which warns courts off calling into question anything that’s said in Parliament. Another is the principle of comity, a Gentlemen’s agreement between Parliament and the Courts not to muscle into each others’ territory. In defamation actions, then, the courts shouldn’t involve themselves in evaluating whether something said in the House is untrue or misleading or inspired by improper motives.
The point Ms Leigh wants to make is that the Briefing Paper (and the later oral briefing) were always likely to be drawn upon by the Minister in the House, and their very public and damaging republication in Parliament was thus a natural and probable consequence of the original (alleged) defamations – a republication for which the briefer should be held responsible, even though the Minister himself can’t be sued for what he said.
The judge said that this would inevitably invite the court to compare what the Minister said with what he was told. True. And if the Minister embellished what he was told, that comparison would inevitably involve critically analysing any defamatory meanings inherent in the Minister’s speech. I’m not sure the second part follows. You don’t have to characterise the embellishment as defamatory or otherwise, just separate it, ie identify which bits effectively repeat what he was told and which bits don’t. But perhaps it’s harder to separate meanings than I think. That may be another point on appeal, I guess.
Anyway, on to the amusing point. Here’s some of what the Minister said in Parliament:
Erin Leigh had repeated competence issues. She had to fix up the piece of work that she was employed to do six times after complaints from senior officials from a number of departments. As a result of that, someone had to come in and fix up that mess. Clare Curren was employed to do that…
Ministers have the right to insist on competent advice. That has been established for a long period of time. When something comes to them six times and is criticised by officials not only from the Ministry for the Environment but from other Government departments, I think that any reasonable chief executive would look for someone who could do the work. When there is someone available to try and fix up the mess who did climate change strategic work for the Australian Liberal Government, I can understand why the Ministry employed her…
[Erin Leigh], who is a sad person, who had six attempts at doing a piece of work, and who was replaced on that job…
It seems the Minister purported to understand the Briefing Paper in the way that the judge said it wasn’t capable of being interpreted. Perhaps the later oral briefing added some more juice to the allegations.
More amusingly: the judge can be read as being pretty scathing about the Minister’s comments. They “may be considered critical and demeaning of Ms Leigh”. The words in the Briefing Paper “do not provide a foundation” for the comments about competence; “nor does it warrant the comment” that Clare Curren had to fix up botched work.
Now, bear in mind that it’s possible that the oral briefing provided better foundation for the comments. And bear in mind that the judge is simply trying to explain why allowing Ms Leigh to use the republication in the House would force the court to evaluate any defamatory meanings in the Minister’s words. And bear in mind that it does seem likely that the Minister stretched what he’d been told to squeeze out maximum political benefit.
But, you know, the difference between this judgment, and another one that may impugn the Minister’s words, rather eludes me.
Topics: Defamation, Parliamentary privilege | 50 Comments »
Are too
November 4, 2009
Remember Erin Leigh? She was working on contract on a climate change communications strategy for the Ministry for the Environment when Clare Curren, another communications adviser, was appointed to oversee her work. Ms Leigh left. A political shitstorm blew up the following year. Was Ms Curren’s appointment politically motivated? Was it really about ideological disagreements with Ms Leigh?
The Minister (at that time, Trevor Mallard) called for a briefing paper from the Ministry about the circumstances of her departure. The briefing paper was fairly circumspect. It recounted the circumstances in a factual and dry manner. It noted that her work had been through “a series of six drafts in late April to early May 2006” and said:
Around about mid May 2006, the work Erin did apparently received consistent adverse comment from government departments, from senior officials and also from the Minister responsible for climate change (Hon David Parker). Clare Current was employed from 22 May 2006.
Erin Leigh has sued over these comments, alleging that they are defamatory.
Justice Robert Dobson has held that they were not. More precisely, he has held that they are not capable of bearing a defamatory meaning.
How did he reach this conclusion? It is, after all, an elementary principle of defamation law that you are liable if you pass on someone else’s criticism, even if you didn’t make it yourself. The judge didn’t disagree with that. But in the context of the circumstances in which Ms Leigh quit, he said, “the more natural inference is that her approach to the content was at odds with those others who commented adversely on it.” In other words, anyone would assume that the differences were ideological and wouldn’t think less of her.
Really? But doesn’t it at least suggest that she was unable to temper her own views so that her work – communications, after all – reflected the views of those of the senior officials who had employed her, and the other government departments, and the Minister? No, said the judge. She’s been rehired several times, and only left because of the “vote of no confidence implicit in another person being imposed to oversee the wording of her work”.
Um. Doesn’t that really make things worse? Can it really be said that no properly instructed juror could find that ordinary reasonable people would think less of Ms Leigh after reading this?
What about those six drafts? No-one could think the less of her for that, says the judge. Jury members with experience in a diverse array of situations might easily be satisfied “that anything from the wording of an advertising jingle to a politician’s speech, a commercial contract or a clergyman’s sermon might undergo six or more drafts without rendering the draftsperson unfit for that particular task.”
I’m not at all sure about that. And I’m even less sure about that when you put it together with the allegations of widespread criticism in the briefing paper.
The judge draws heavily on likely understanding of those who saw that paper against the background of the clash of principles that was being widely reported. In that context, he says, people wouldn’t immediately think less of her from the paper.
I can see where he’s coming from. And I’d like to think that judges and most lawyers wouldn’t draw adverse inferences against that background. But it’s a far cry from that to saying that those words are not capable of being construed by a juror as giving rise to a defamatory inference. I think this should have been left to the jury to make up its own mind.
I understand the ruling is going to the Court of Appeal. I’d expect it to be successful on that point. Which doesn’t mean Ms Leigh will win the case. Quite apart from what view a jury will take of the language in the briefing paper (and in a later oral briefing, which is also part of the defamation claim), it strikes me that there is a very strong case that a qualified privilege (if not absolute privilege) defence is available.
I should note that there are other issues in the decision that I haven’t addressed here. For one thing, he strikes out the parallel claim in negligence, and I rather suspect that aspect of the decision will survive appeal.
Topics: Defamation | 4 Comments »
Free speech by the numbers
November 4, 2009
In case you were wondering what the First Amendment was all about, US Court of Appeals judge and law and economics whizz Richard Posner has the answer: Ax – Bx = -(pH / (1 + d)n + O)x where the xs are subscripts denoting derivatives and relate to potential strictness of regulation; the n is a superscript/power; A is cost of regulation; B is the benefits of speech; pH is the probability of harm (the denominator is a discount for futurity); O is offensiveness.
More specifically, this is the optimum level of speech regulation. And you thought this free speech stuff was hard.
I read about this in the excellent collection of essays in Eternally Vigilant: Free Speech in the Modern Era (2002, University of Chicago Press) but he also eleborates on it in his seminal text Economic Analysis of Law.
Of course, this is really just a cost-benefit equation. My dirty secret: I have an undergraduate degree in economics. So I’m intrigued by the interface between law and economics, which I think brings a useful rigour to legal policy analysis and sometimes yields interesting insights. I’m also faintly appalled by the simplistic and mechanistic nature of some law-and-economists’ thinking, and often feel that their reasoning and assumptions (particularly about our response to incentives) seem far distant from the world I inhabit.
Read up on it if you like. A few interesting points, though. Posner is inclined to take offensiveness out of the equation altogether as a justification for regulating speech (that is, adding to its harms) because it is often the byproduct of speech that challenges important values and beliefs, and can pave the way for new ways of thinking. He argues that some types of regulation can sometimes actually promote speech. He accepts that it’s so difficult to quantify the costs and (in particular) the benefits of speech, so it’s hard to make his formula work.
I’m with him so far.
He also rejects political speech as a special category deserving of greater protection. He’d tolerate hate speech (“It is after all only a dogma, and recent dogma, that the races, sexes and so forth, are equal; and to punish people for challenging it seems as objectionable as punishing people for advocating communisim or laissez-faire.”) He accepts the that there are arguments in favour of campaign finance regulation, but thinks them overstated and outweighed by the disadvantages of regulation.
Not so sure about any of that.
Interestingly, Posner is no “marketplace of ideas” idealogue, and goes into some detail about the imperfections of the analogy. But in the end:
While markets in ideas do not come very close to the economist’s ideal of perfect competition, it is difficult to see how regulation can bring them any closer except in a few areas where objectivity in a strong sense can be achieved by agencies or courts [he thinks defamation comes in here] or where unregulated speech creates calamitous dangers. And looking back over the whole course of history we realize that the marketplace of ideas has been responsible for much of what we think of as civilization. The value of competition in ideas, coupled with the costs (including error costs) of effective regulation, provides some grounding for a legal approach that deems the benefits of free speech to be great, and thus requires proof of great cost… to justify restricting speech.
That’s pretty much where I come down too.
Topics: Electoral speech, Free speech theory | 50 Comments »
Bad English
October 29, 2009
Let me get this straight: TVNZ7 scripted this ad? What were they thinking?
I must say, my first response was the same as Graeme Edgeler’s: this might be an “election programme” under the Broadcasting Act. It’s an offence to broadcast a promo that “advocates support for a candidate or for a political party”. Interestingly, the other types of message that are outlawed mostly specifically relate to elections, but this one doesn’t. There’s an argument that a Bill-of-Rights-consistent reading would limit this to election-time ads. There’s another argument that this is simply promoting TVNZ7. There’s another argument that English is discussing policy not seeking support for National. But these all strike me as a stretch. If this became standard fare, no-one could seriously suggest that the law wasn’t being thoroughly subverted.
To me, the first 30 seconds of this promo are indistinguishable from a political ad: scripted, flattering, underscored by music, direct-to-camera delivery, full of spin. Under s70 of the Broadcasting Act, it’s an offence to permit such broadcasts (and, under normal crimimal law, to be a party to such an offence by encouraging and facilitating it… might this include Bill English?).
Interestingly, such ads aren’t required to show balance. So it might be an offence, but you couldn’t complain that it breached broadcasting standards.
On the other hand, if it doesn’t fall under the definition of an election programme, a broadcasting standards complaint would be problematic. What do you complain about? Lack of fairness to the other parties? They’re not mentioned or referred to, so the fairness standard doesn’t apply. Balance? That merely requires the broadcast of a range of viewpoints on controversial in the period of current interest. Impartiality? Possible, but the only mention of impartiality in the current TV code comes under the accuracy standard, and only applies to news programmes.
Quite apart from the legal side, this ad (and TVNZ’s unconvincing excuses) seem to me to display remarkably bad judgment.
And quite apart from that, how exactly does it demystify the financial crisis to learn that “we can beat the Aussies… it’s time to back ourselves and apply some old-fashioned kiwi can-do… Together us kiwis can do it”?
I’m more mystified than ever.
Besides, how it is Bill English’s “plain English” if it was scripted for him? And is “plain English” really plain if it’s ungrammatical?
Topics: Broadcasting Standards Authority, Media ethics | 46 Comments »
House of Lords supports dumping criminal libel
October 27, 2009
And about time. We’ve already got rid of it. Mind you, the Aussie state of Victoria, where I am right now, still recognises criminal libel – which includes defamation of dead people and defamation where’s there’s no publication to anyone but the person defamed – and the defences (except truth) aren’t clear. Who knew?
Looks like the UK will axe sedition, too. Also long overdue. And also something we’ve already done.
Topics: Defamation, Journalism and criminal law | No Comments »
Sure enough…
October 22, 2009
The Solicitor-General has applied for Vince Siemer to be held in contempt of court for breaching the court order that he remove from his website his article about a suppressed HC judgment. (This time, he has sensibly just gone for a three-month jail term, seeking to avoid the Bill of Rights right-to-jury issues that continue to plague his earlier contempt application). The hearing is today, though no-one seems to be reporting it.
No-one, that is, except indefatigable campaigner Penny Bright, who says she’s proudly distributing exactly the same suppressed material as Vince and is miffed because she hasn’t been charged with contempt too. It’s a question of equality before the law, she says.
Topics: Contempt of Court, Suppression orders | 54 Comments »
What’s wrong with trial by media?
October 21, 2009
I get irked by those who rail against “trial by media” as if it’s some general category of wrongdoing. Yes, some reporting of allegedly criminal conduct is unfair, inaccurate or unbalanced, and some may even prejudice an accused person’s right to a fair trial. In such cases, we should by all means criticise the reporting for those flaws. But in other cases, trial by media is exactly what the media is for.
I’ve just come across an Australian High Court injunction case (ABC v O’Neill [2006] 229 ALR 457) which, I’m pleased to note, makes just this point. The first-instance judge had awarded an interim injunction against the screening of a documentary, partly on the grounds that it amounted to trial by media. Here’s Gleeson CJ and Crennan J’s response:
First, it is not the fact that allegations of serious criminal conduct usually become known to the public only as a result of charges and subsequent conviction. On the contrary, the process often works in reverse: charges and subsequent conviction often result from the publication of allegations of serious criminal conduct. Subject to the law of contempt (and, of course, the law of defamation) media outlets are free to make, and frequently make, allegations which are directed towards, or which have the effect of, prompting action by the authorities. Condemnations of trial by media sometimes have a sound basis, but they cannot be allowed to obscure the reality that criminal charges are sometimes laid as a response to media exposure of alleged misconduct. The idea that the investigation and exposure of wrongdoing is, or ought to be, the exclusive province of the police and the criminal justice system, bears little relation to reality in Australia, or any other free society. There are heavily governed societies in which the police and other public authorities have the exclusive capacity to make, and pursue, allegations of misconduct; but not in ours. Indeed, in our society allegations of misconduct are sometimes made against the police and public officials.
Secondly, it may well be in the public interest that inaction on the part of the police and prosecuting authorities be called publicly into question. It is certainly in the public interest that it is open to be called into question. The facts of this case provide an example. At least according to the Hobart Mercury, the South Australian Commissioner of Police and the Tasmanian Commissioner of Police have formed different views on the respondent’s likely responsibility for a number of murders. These may reflect legitimate differences of opinion, but why should such differences not be a matter of public knowledge and discussion, bearing in mind the respondent’s existing conviction and custodial status?
Thirdly, if the expression “trial by media” means any public canvassing by the media, outside the reporting of court proceedings, of the merits of topics which could become, or are, the subject of civil or criminal litigation, then we are surrounded by it. The idea that the criminal justice system ought to be the exclusive forum for canvassing matters of criminal misbehaviour is contrary to the way our society functions in practice.
Fourthly, a complaint that what is going on is trial by media implies that there is some different, and better, way of dealing with the issues that have been raised. Unless it be suggested that the public interest is best served by silence on the subject of the respondent’s possible complicity in the disappearance of the Beaumont children, it is not easy to see what, in the circumstances, that might be. Crawford J was willing to accept that it was likely that it would be shown to be true that the respondent was suspected of being involved in the murders of the Beaumont children. The South Australian authorities appear to have no present intention of charging the respondent with those murders. The respondent is a convicted murderer, serving a life sentence. The Tasmanian Commissioner of Police has been reported as saying that the respondent has killed many children. The corollary of the respondent’s argument is that the public should not be allowed to hear of the suspicions. Any public revelation of those suspicions is likely to be stigmatised as trial by media. The alternative is silence. The third imputation alleged is that the respondent is a multiple murderer. He has confessed to a second killing. That is a matter of public interest. The authorities have never brought him to trial for that matter, perhaps because it would be a work of supererogation. If any media outlet publishes the fact of the respondent’s confession, then no doubt it can be said that the question of his guilt is being canvassed without all the protections and safeguards of the criminal trial process. That would be true. Yet it seems surprising that the public could never be told of the respondent’s confession.
It is difficult to resist the conclusion that, in their natural and proper concern for fairness to the respondent, the judges who decided the case in his favour have fallen into the error of treating the criminal trial process as the only proper context in which matters of the kind presently in question may be ventilated. More fundamentally, however, it is apparent that they failed to take proper account of the public interest in free communication of information and opinion, which is basic to the caution with which courts have approached the topic of prior restraint of allegedly defamatory matter.
PS It’s just been pointed out to me that Justice McGrath cites this passage in the Rogers case (para 114). Useful to have that on our books.
Topics: Defamation, General, Injunctions, Media ethics | 44 Comments »
Siemer in contempt again?
October 20, 2009
Yet another chapter is written in the Vince Siemer saga.
In this episode, Vince decides that a High Court order suppressing publication of a decision doesn’t apply to him. The decision concerned some pre-trial rulings in concerning the Uruwera defendants, so it’s pretty big deal. Justice Winkelmann suppressed the decision, it seems, out of concern that publication may prejudice the conduct of a fair trial. Finding material of interest in the decision, Vince publishes it on his website. In response to the Soliticitor-General’s demand that he remove it, he argues that the judge had no right to make the suppression order.
On October 9, the Solicitor-General obtained a court order requiring him to remove it. When I last checked, he hadn’t. Looks like he’s in contempt of court again.
The case illustrates once again Vince Siemer’s unerring knack for identifying deficiencies in our legal system, as well as his galactic talent for overblowing his case and infuriating the judiciary.
As usual with Vince, there was nothing straightforward about the case. He supplied a notice of opposition but said he’d be out of the country for the hearing and asked for it to be deferred. On the one hand, it really is important that criminal defendants (which is effectively what he is) be given a fair chance to make representations in their own defence. On the other hand, the court can’t be a hostage to Vince’s travel timetable – and it was, after all, considering the enforcement of a court order that was already in existence and being breached with every extra day that passed. In addition, Vince could have rustled up a lawyer to represent him.
Anyway, he sent in submissions. He said he had the right to publish under s14 of the Bill of Rights. The judge could only override this with “clear and compelling legal reasoning” – and the suppression order contained no reasoning at all. There could be no right for the judge to arbitrarily keep the public ignorant of what was happening in the courts, particularly given the public interest in the contents of the judgment. He said he’d published nothing that could jeopardise the right to a fair trial. The public release of factual Court judgments is inherently non-prejudicial, he argued.
As usual, Siemer badly overstates his legal claim. This made it easy for the judge to bat aside his submissions. The High Court certainly does have power to suppress its decisions when necessary in the interests of justice. This was confirmed recently in Paraha v Police [2008] NZAR 581, as the judge noted. The Bill of Rights doesn’t prevent this. What’s more, it’s not inherently non-prejudicial for Court judgments to be made available. Consider, for example, a judgment that rules some evidence of confession inadmissable because it was obtained by coercion. If the jury could learn of the confession through the media, that would plainly prejudice the trial. What’s more, Vince forgets that these restrictions are not permanent, but only apply until the trial is over. The public is not being barred from seeing this judgment forever.
But that’s not the end of the story. Because, as usual, in the middle of Vince’s outraged pontificating, there are some solid points, I think. He is effectively mounting a collateral challenge to the validity of the suppression order, and the judge treated it as such. There are some arguments he could have advanced that may have made the judge sweat more:
1. While the Bill of Rights cannot override the court’s power to make a suppression order in the interests of justice, it seems clear that the discretion to make such an order must be exercised consistently with the Bill of Rights – that is, only when it is demonstrably justified under s5. Would publication of the judgment really have jeopardised a fair trial? (I don’t know; I haven’t read it). In any event did the judge really need to suppress the whole decision to protect the fairness of the trial? Would a less restrictive order have sufficed?
2. Vince was probably wrong to say that his publication creates no prejudice. I think it probably does. But any prejudice is to the Crown, not the defendants. Is it in the interests of justice to prevent such prejudice? Probably so. But it would have been interesting to see the judge grapple with the dicta from Solicitor-General v W & H Publications Ltd [2003] NZLR 12, at para [27], where the Chief Justice and Morris J said:
It is not at all clear however that there is reciprocity of effect upon trial where publications are sympathetic to the accused, rather than adverse. The submission made by the Solicitor-General that sympathetic publicity about the accused is the “flip side” of adverse publicity, and equally prejudicial to the administration of justice, does not echo in experience. No doubt some such symmetry seems intuitively fair as between prosecution and defence. But the fairness to be considered is the fairness of the administration of justice.
3. In the Lewis case (remember the name suppression of the American billionaire caught bringing in drugs on his yacht?), the Court of Appeal said it was an error of law not to provide reasons for the suppression. There seems a fair argument that this ought to apply with equal force here. Vince did point out that no reasoning had been provided. The judge simply said that such suppressions were “made on a daily basis in the Courts throughout New Zealand, in the context of the determination of pre-trial hearings, or in the determination of appeals where a retrial is likely… on the basis that the publication of the material in whole or in part prior to trial, has the potential to prejudice the conduct of a fair trial”. I’m not convinced that such suppressions are quite that common. (Name suppressions are, but those are not usually made to avoid prejudice to a fair trial). Suppressing publication of the whole content of a decision involves an exercise of common law powers that go beyond the suppression that’s authorised by statute (which allows suppression of submissions and evidence)… the scope of various courts’ powers to prevent media reporting has in recent years been the subject of litigation, including the recent Paraha case above. In short, I can’t help wondering whether the judge (who incidentally is the next Chief Judge of the High Court) is being a bit blase about the suppression here, and the failure to explicitly justify it in s5 terms. For all that, as she does explain in this judgment, there may well be good reasons to suppress material in the judgment: if it discusses evidence that may well end up being ruled inadmissible, for example. Again, though: does this apply to the entire judgment?
Still, I doubt the result would have been different if these arguments had been made.
Next step: another application for a warrant to commit him for contempt?
Topics: Contempt of Court, NZ Bill of Rights Act, Suppression orders | 49 Comments »
Carter-Rucked
October 19, 2009
Heavy-hitting UK libel law firm Carter-Ruck has been getting some bad press lately. The Guardian reported that Carter-Ruck (famously referred to as “Carter-Fuck” by its nemesis Private Eye) had gagged it from reporting Parliamentary proceedings. What’s more, the gagged material related to a report concerning a toxic waste spill by giant oil company Trafigura. And what’s worse, the injunction itself was what’s become known as a “super injunction” meaning that not only are the press gagged from reporting the allegedly confidential material – they are also forbidden from revealing the existence of the injunction itself.
An outrageous attack on free speech, all have agreed. A possible contempt of Parliament, some have suggested.
I’ve taken a particular interest in this since, as some of you know, Carter-Ruck were kind enough to let me spend a couple of weeks with them recently in an observational capacity. I’m afraid I have no insider information about Trafigura though: during my time there, I had no involvement with the case and didn’t discuss it with anyone, and the furore erupted after I left.
Still, it did make me more inclined to seek out Carter-Ruck’s point of view. And it’s here, on their website.
Now, any reader of this blog will know that I’m not a fan of these super-injunctions (though I can conceive of very rare situations where the confidentiality interest itself may be destroyed by public knowledge of the existence of the proceedings). And I have concerns about the way injunctions can often readily be granted at an early stage of proceedings (though again, there are certainly some situations where this is the only way to protect legitimately confidential information). But the Guardian’s reporting – and the predictable shitstorm in the blogosphere – strike me as a bit ill-informed, if Carter-Ruck’s press release is to be believed (and I do).
One would have hoped that people wouldn’t need reminding of one particularly important fact: this injunction was not imposed by Carter-Ruck, it was granted by a judge. Any criticism of the existence and scope of the order ought to be directed, in the first instance, at Justice Maddison.
Second, it seems that a week after the injunction was first ordered, on an urgent and interim basis, the Guardian consented to its continuation pending resolution of the issue. That doesn’t mean that the Guardian accepted that the injunction was justified. But it does mean they weren’t fighting the stop-gap injunction, and accepted that it could stay until the matter could be properly argued.
Third, the injunction arose well before there was any question of the matter being raised in Parliament. It certainly wasn’t an attempt to gag Parliament, or Parliamentary reporting. It was an attempt to protect a confidential report. Carter-Ruck says that, if anyone had raised the possibility of Parliamentary coverage when the injunction was being formulated, they probably would have agreed to exclude it from the ambit of the injunction. (This is credible because it’s common to exclude material that’s in the public domain, and it’s hard to see how Carter-Ruck could have argued to keep it in the gag. What’s more, once it became a live issue, they took instructions from their clients and pretty quickly agreed to consent to its removal from the terms of the injunction).
Carter-Ruck has written to the Speaker of the House, trying to set the record straight and head off ill-informed comment by politicians and the media (good luck with that). They also noted the Parliamentary resolution that Parliament does not discuss active court proceedings. I’ve said before that Parliament should really only be leery of discussing active court proceedings in such way that they might be prejudiced. Still, isn’t it fair game for Carter-Ruck to point to Parliament’s own rules? As they say in their letter, “clearly, the question of whether this matter is sub judice is entirely a matter for your discretion…”
So what’s the Guardian’s headline? Carter-Ruck in new move to stop debate in Parliament.
Sheesh. What’s a poor Machiavellian Libel Bully to do?
Topics: Breach of confidence, Injunctions, Internet issues, Media ethics, Suppression orders | 45 Comments »
Holiday time
August 20, 2009
I’m off to Hong Kong, London and the South of Spain for six weeks or so. Then I’ll be based in Melbourne for a few weeks, beginning on October 10. Back in NZ late November. If you want to contact me, best to try claudiasteven@gmail.com, which I’ll try to check regularly.
Topics: General | 77 Comments »
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