I am an immigration lawyer with over 15 years experience in the field. Immigration law is one of the most complex and frustrating fields of law today. This blog is an attempt to shed some light on Immigration Law.
Wednesday, June 30, 2010
US Naturalized Citizen of the Day - Willem de Kooning
Willem de Kooning (April 24, 1904 – March 19, 1997) was a Dutch American abstract expressionist artist who was born in Rotterdam, the Netherlands.
In the post-World War II era, de Kooning painted in a style that came to be referred to as Abstract expressionism or Action painting, and was part of a group of artists that came to be known as the New York School. Other painters in this group included Jackson Pollock.
Interesting OP Ed on Anchor Babies
This Op Ed from the Chicago Tribune gives a very in depth perspective on Anchor Babies.
Monday, June 28, 2010
Not enough votes to pass CIR
This article states that there are not enough Democrats to pass Comprehensive immigration reform. If the Democrats won't pass it, the Republicans certainly will not. Wait until next year, yeah right.
Wednesday, June 23, 2010
US Naturalized Citizen of the Day- Alfred Hitchcock
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Sir Alfred Joseph Hitchcock was born on 13 August 1899 in London, England. He was an English filmmaker and producer who pioneered many techniques in the suspense and psychological thriller genres. His movies include Vertigo, The Birds, Dial M for Murder, Shadow of a Doubt, Rear Window , To Catch a Thief, and Psycho among many other classics.
Interesting Facts about H-1b Visas
The American Competitiveness and Workforce Improvement Act (ACWIA) imposes annual reporting requirements on USCIS concerning the countries of origin and occupations of, educational levels attained by, and compensation paid to, aliens who were issued visas orotherwise provided nonimmigrant status under section 101(a)(l5)(H)(i)(b) of the INA during theprevious fiscal year. To fulfill this requirement, USCIS submits the following report for Fiscal Year 2009, October I, 2008 - September 30, 2009.
Highlights
• The number of H-l B petitions filed decreased 15 percent from 288,764 in Fiscal Year 2008 to 246,647 in Fiscal Year 2009.
• The number of H-l B petitions approved decreased 22 percent from 276,252 in Fiscal
Year 2008 to 214,271 in Fiscal Year 2009.
• Approximately 48 percent of all H-IB petitions approved in Fiscal Year 2009 were for workers born in India.
• Two-thirds of H-l B petitions approved in Fiscal Year 2009 were for workers between the ages of25 and 34.
• Forty-one percent of H-I B petitions approved in Fiscal Year 2009 were for workers with a bachelor's degree, 40 percent had a master's degree, 13 percent had a doctorate, and 6 percent were for workers with a professional degree.
• About 41 percent ofH-IB petitions approved in Fiscal Year 2009 were for workers in
computer-related occupations.
• The median salary of beneficiaries of approved petitions increased to $64,000 in Fiscal Year 2009, $4,000 more than in Fiscal Year 2008.
Highlights
• The number of H-l B petitions filed decreased 15 percent from 288,764 in Fiscal Year 2008 to 246,647 in Fiscal Year 2009.
• The number of H-l B petitions approved decreased 22 percent from 276,252 in Fiscal
Year 2008 to 214,271 in Fiscal Year 2009.
• Approximately 48 percent of all H-IB petitions approved in Fiscal Year 2009 were for workers born in India.
• Two-thirds of H-l B petitions approved in Fiscal Year 2009 were for workers between the ages of25 and 34.
• Forty-one percent of H-I B petitions approved in Fiscal Year 2009 were for workers with a bachelor's degree, 40 percent had a master's degree, 13 percent had a doctorate, and 6 percent were for workers with a professional degree.
• About 41 percent ofH-IB petitions approved in Fiscal Year 2009 were for workers in
computer-related occupations.
• The median salary of beneficiaries of approved petitions increased to $64,000 in Fiscal Year 2009, $4,000 more than in Fiscal Year 2008.
What part of ILLEGAL Don't you understand?
This is a great article from the Atlantic that has a fantastic response to this question about illegal immigration.
"Balderas's real crime is neither sneaking across the border 15 years ago nor failing to fill out the right paperwork. Rather, his crime is belonging to a nationality that American policy makers have decided is over-represented in this country. And there's a significant constituency for this policy among American voters, some of whom simply believe that there are too many foreigners here. But this viewpoint has little to do with the rule of law. The rule of law doesn't demand that we punish children for the crimes of their parents, or that we punish people for crimes they committed decades ago. And if you demand stricter enforcement of the existing laws while vociferously opposing all proposals to expand the legal channels for coming to this country, then I hope you'll forgive me if I conclude that you don't actually care about people like Eric Balderas." Megan McCardle
"Balderas's real crime is neither sneaking across the border 15 years ago nor failing to fill out the right paperwork. Rather, his crime is belonging to a nationality that American policy makers have decided is over-represented in this country. And there's a significant constituency for this policy among American voters, some of whom simply believe that there are too many foreigners here. But this viewpoint has little to do with the rule of law. The rule of law doesn't demand that we punish children for the crimes of their parents, or that we punish people for crimes they committed decades ago. And if you demand stricter enforcement of the existing laws while vociferously opposing all proposals to expand the legal channels for coming to this country, then I hope you'll forgive me if I conclude that you don't actually care about people like Eric Balderas." Megan McCardle
Tuesday, June 22, 2010
Does Everyone who Gradutes Law School want to become an Immigration Lawyer?
Seems like and, and I ask Why????? This Denver Post article talks about as the immigration poluation grows, so does the interest in Immigration law. Does these young students want to change the world, or make a buck? I hope it is the former.
Securing our borders?
This is unreal leaked audio of a Canadian citizen confrontation with a CPB agent.
If these are the people they are picking on, I wonder how many drug smugglers and terrorists get through.
If these are the people they are picking on, I wonder how many drug smugglers and terrorists get through.
US Naturlaized citizen of the day- Paul Tillich
Paul Tillich was born on August 20, 1886 in Germany. He was a German-American theologian and Christian existentialist philosopher. Tillich was, along with his contemporaries Rudolf Bultmann (Germany), Karl Barth (Switzerland), and Reinhold Niebuhr (United States), one of the four most influential Protestant theologians of the 20th century
Sisters from Texas being deported to Serbia
Another Chilling story of Immigration system out of control. ICE will claim rules are rule, but where is the compassion? The is little reason ICE could not stipulate for a motion to reopen. Disgusting.
Monday, June 21, 2010
CIR is Dead
Just As I predicted, Comprehensive Immigration Reform is Dead. Politicians do not have the conviction to debate or pass immigration legistaltion. In the guise of fighting terrorism, Conservative activist have led the fight against illegal immigration. I think South Park said it best, people are afraid of immigration because " they'll take our jobs!"
Harvard Student spared Deportation
Richard I. Fleischer, an immigration attorney in Cincinnati Ohio with more than 30 years of experience in the Immigration Law filed send this story of a Harvard student who really would benefit from passage of the Dream Act
An undocumented Harvard University student whose detention by immigration authorities has drawn wide attention is no longer facing deportation to Mexico, officials said.
Eric Balderas, 19, was detained nearly two weeks ago after he tried to use a university ID card to board a plane from San Antonio to Boston. The detention sparked a buzz among student immigrant activists, many of whom thought Balderas's case might help advance the proposed DREAM act -- a federal bill that would allow illegal immigrants a pathway to citizenship through college enrollment or military service.
Mario Rodas, a friend of Balderas's, said Balderas was granted deferred action, which can be used to halt deportation based on a case's merits. U.S. Immigration and Customs Enforcement confirmed that the agency had decided not to pursue the deportation.
An undocumented Harvard University student whose detention by immigration authorities has drawn wide attention is no longer facing deportation to Mexico, officials said.
Eric Balderas, 19, was detained nearly two weeks ago after he tried to use a university ID card to board a plane from San Antonio to Boston. The detention sparked a buzz among student immigrant activists, many of whom thought Balderas's case might help advance the proposed DREAM act -- a federal bill that would allow illegal immigrants a pathway to citizenship through college enrollment or military service.
Mario Rodas, a friend of Balderas's, said Balderas was granted deferred action, which can be used to halt deportation based on a case's merits. U.S. Immigration and Customs Enforcement confirmed that the agency had decided not to pursue the deportation.
Friday, June 18, 2010
US Naturalized Citizen of the Day- Patrick Ewing
Patrick Aloysius Ewing was born August 5, 1962 in Kingston Jamaica. He was descibed as a Warrior. That is the one-word description often applied to Patrick Ewing. He was indefatigable and relentless in pursuit of an NBA championship despite being denied on an annual basis. Bold predictions did not always materialize and some took them as empty promises, while others as a will to succeed. One of the finest shooting centers to play, he left the game as the New York Knicks' all-time leader in nearly every significant category and the game's 13th all-time scorer with 24,815 points.
Need for Immigration Court Reform as Well
The average pending time for a case in the Immigration Courts is nearing 450 days. Back in the 1980s when I was an INS Trial Attorney, when one side needed a continuance on a case, it was rescheduled within a couple of weeks. Now, the waiting time to reschedule a case can be a year or more." Carl Shusterman, June 16, 2010.
Tuesday, June 15, 2010
New USCIS Form I-90
WASHINGTON - U.S. Citizenship and Immigration Services (USCIS) announced today that a new version of the Application to Replace Permanent Resident Card (Form I-90), is available on the USCIS website. The new version of the form is dated 8/10/09 and contains more user-friendly features.
Monday, June 14, 2010
Arizona Turning its attention to "Anchor Babies"
Interesting article about the "anchor baby" issue and Arizona.
"Anchor baby" is a term used by immigration reductionists in the United States to describe a child born in the U.S. to illegal aliens
"Anchor baby" is a term used by immigration reductionists in the United States to describe a child born in the U.S. to illegal aliens
Another Board Of Immigration Appeal Victory (BIA) for the Fleischer Immigration Law Group
The Fleischer Immigration Law Practice group of Cincinnati , Ohio recently won another Board of Immigration Appeals appeal. This time, the BIA reversed Cincinnati USCIS decision that a marriage was not bona fide. In its decision, The BIA agrred with attorney Neil Fleischer that there was no probative and substational evidence for the government to substantiate an INA204(c) claim. The BIA stated that a USCIS denial due to abandomenent can not substantiate an INA204(c) claim.
Client now has a chance to have I-130 properly adjudicated and will hopefully obtain permanent residence.
Client now has a chance to have I-130 properly adjudicated and will hopefully obtain permanent residence.
US naturlaized citizen of the day- Vladimir Nabokov
Friday, June 11, 2010
Support Spring Training in Florida, not Arizona
A petition to keep Spring Training teams, even the hated Chicago Cubs out of Arizona due to their Draconian immigration law.
Thursday, June 10, 2010
Naturalized US Citizen of the Day- Khaled Hosseini
Khaled Hosseini was born in Kabul, Afghanistan, in 1965. The Hosseinis sought and were granted political asylum in the United States. In September of 1980, Hosseini's family moved to San Jose, California. Hosseini graduated from high school in 1984 and enrolled at Santa Clara University where he earned a bachelor's degree in Biology in 1988. The following year, he entered the University of California-San Diego's School of Medicine, where he earned a Medical Degree in 1993. He completed his residency at Cedars-Sinai Hospital in Los Angeles. Hosseini was a practicing internist between 1996 and 2004.
Hosseini is best known as an author for his best seller. Kite Runner, was published and has since become an international bestseller, published in 48 countries. In 2006 he was named a goodwill envoy to UNHCR, the United Nations Refugee Agency. His second novel, A Thousand Splendid Suns was published in May of 2007. Currently, A Thousand Splendid Suns is published in 40 countries.
AILA response to proposed USCIS fee increase
WASHINGTON, DC – The American Immigration Lawyers Association (AILA) is dismayed with the announcement today that U.S. Citizenship and Immigration Services (USCIS) will seek an average 10% increase in immigration fees in order to close a projected $200-million deficit for 2010-11. According to USCIS, budget cuts of $160 million were not enough to offset the gap between the agency's projected $2.1 billion in revenue and $2.3 billion in costs.
“Many of the government expenses being underwritten by these fees are unrelated to the services for which fees are being paid. These are matters of public benefit, and should be funded by appropriations, not applicants," said AILA President Bernard Wolfsdorf. "While a 10% fee increase in and of itself may not seem high, this comes only 3 years after a 66% USCIS fee increase. Taken together, these increases bring many fees to excessive levels,” Wolfsdorf continued.
Wolfsdorf further expressed disappointment that the increased fees are not accompanied by any improvements in the quality or efficiency of USCIS decision-making. “To the contrary, we have seen a marked decrease in the quality and efficiency of adjudications since fees were raised in 2007,” said Wolfsdorf.
One positive aspect of the proposal is that it would not increase fees for citizenship applications. Those fees were hiked by 70% to $675 in 2007, an increase that immigrant-rights groups blamed for putting citizenship out of reach for many lower-wage immigrants.
“Many of the government expenses being underwritten by these fees are unrelated to the services for which fees are being paid. These are matters of public benefit, and should be funded by appropriations, not applicants," said AILA President Bernard Wolfsdorf. "While a 10% fee increase in and of itself may not seem high, this comes only 3 years after a 66% USCIS fee increase. Taken together, these increases bring many fees to excessive levels,” Wolfsdorf continued.
Wolfsdorf further expressed disappointment that the increased fees are not accompanied by any improvements in the quality or efficiency of USCIS decision-making. “To the contrary, we have seen a marked decrease in the quality and efficiency of adjudications since fees were raised in 2007,” said Wolfsdorf.
One positive aspect of the proposal is that it would not increase fees for citizenship applications. Those fees were hiked by 70% to $675 in 2007, an increase that immigrant-rights groups blamed for putting citizenship out of reach for many lower-wage immigrants.
Tuesday, June 8, 2010
Us Naturalized Citizen of the Day- Sergei Fedorov
Dream Act Possible This Year?
I have heard it before, but they are talking about it again.
“If you’re talking about the whole comprehensive reform, I think we can probably write it off before the elections at this point,” said Brent Wilkes,
“If you’re talking about the whole comprehensive reform, I think we can probably write it off before the elections at this point,” said Brent Wilkes,
Monday, June 7, 2010
Is Arizona Immigration law coming to Ohio?
Not even six weeks after Arizona Gov. Jan Brewer signed an illegal immigration bill into law, two Butler County politicians are pushing for a similar statute to allow police to arrest and detain illegal immigrants if they are stopped for traffic violations or arrested for crimes.
Gay Couple Reunited with Humanitarian Parole
Tim Coco and Genesio Oliveira married in 2005, among the throngs who wed after same-sex marriage became legal in Massachusetts. But for nearly three years, they lived apart — Coco in Haverhill and Oliveira in his native Brazil — because federal law does not recognize their union.
Friday, June 4, 2010
Former Soldier Denaturalized
A former member of the Bosnian Serb Army has left the United States to return to Serbia after a federal judge ordered his denaturalization based on
concealment during his application for U.S. citizenship that he served in the military during the Bosnian war, announced Assistant Attorney General Lanny
A. Breuer of the Criminal Division, U.S. Attorney Brian Albritton of the Middle District of Florida and Assistant Secretary John Morton of U.S. Immigration
and Customs Enforcement (ICE).
Jadranko Gostic, 47 , a former resident of St. Petersburg, Fla., departed the United States on June 1 , 2010. U.S. District Court Judge James Moody in
Tampa, Fla., ordered his denaturalization on May 26, 2010.
Gostic was indicted in December 2006 on one count of unlawful procurement of citizenship and one count of making false statements. In January 2010, a
civil complaint was filed against Gostic alleging illegal procurement of U.S. citizenship and requesting his denaturalization. Court documents allege that
Gostic served in the Zvornik Infantry Brigade of the Bosnian Serb Army from April 1992 until December 1995. According to court documents,
international tribunals have found that some units of the Zvornik Brigade engaged in war crimes and crimes against humanity , and that they participated in
the July 1995 action against the Srebrenica enclave during which some 8,000 Muslim men and boys were executed.
Gostic entered the United States in 1999, received lawful permanent residence status in 2002 and was naturalized in 2004. According to court documents,
at each stage of the immigration and naturalization process Gostic concealed his service in the Zvornik Brigade, even when specifically asked about his
prior military service.
Gostic agreed to admit to the allegations against him, to be denaturalized, to surrender his lawful permanent resident status and to depart the United
States. Gostic fulfilled the requirements of this agreement and departed the United States. As a result of his cooperation, the criminal charges against Gostic
will be dismissed.
This case was investigated by the ICE Tampa Special-Agent-in-Charge Office and was prosecuted by Senior Trial Attorney William Kenety in the Criminal
Division’s Human Rights and Special Prosecutions Section (HRSP) and Assistant U.S. Attorney Donald Hansen of the U.S. Attorney’s Office for the Middle
District of Florida.
The Criminal Division announced the formation of HRSP on March 30, 2010, as part of the U.S. government’s efforts to bring human rights v iolators to
justice and deny those violators safe haven in the United States. The new section represents a merger of the Criminal Division’s Domestic Security Section
(DSS) and the Office of Special Investigations (OSI).
concealment during his application for U.S. citizenship that he served in the military during the Bosnian war, announced Assistant Attorney General Lanny
A. Breuer of the Criminal Division, U.S. Attorney Brian Albritton of the Middle District of Florida and Assistant Secretary John Morton of U.S. Immigration
and Customs Enforcement (ICE).
Jadranko Gostic, 47 , a former resident of St. Petersburg, Fla., departed the United States on June 1 , 2010. U.S. District Court Judge James Moody in
Tampa, Fla., ordered his denaturalization on May 26, 2010.
Gostic was indicted in December 2006 on one count of unlawful procurement of citizenship and one count of making false statements. In January 2010, a
civil complaint was filed against Gostic alleging illegal procurement of U.S. citizenship and requesting his denaturalization. Court documents allege that
Gostic served in the Zvornik Infantry Brigade of the Bosnian Serb Army from April 1992 until December 1995. According to court documents,
international tribunals have found that some units of the Zvornik Brigade engaged in war crimes and crimes against humanity , and that they participated in
the July 1995 action against the Srebrenica enclave during which some 8,000 Muslim men and boys were executed.
Gostic entered the United States in 1999, received lawful permanent residence status in 2002 and was naturalized in 2004. According to court documents,
at each stage of the immigration and naturalization process Gostic concealed his service in the Zvornik Brigade, even when specifically asked about his
prior military service.
Gostic agreed to admit to the allegations against him, to be denaturalized, to surrender his lawful permanent resident status and to depart the United
States. Gostic fulfilled the requirements of this agreement and departed the United States. As a result of his cooperation, the criminal charges against Gostic
will be dismissed.
This case was investigated by the ICE Tampa Special-Agent-in-Charge Office and was prosecuted by Senior Trial Attorney William Kenety in the Criminal
Division’s Human Rights and Special Prosecutions Section (HRSP) and Assistant U.S. Attorney Donald Hansen of the U.S. Attorney’s Office for the Middle
District of Florida.
The Criminal Division announced the formation of HRSP on March 30, 2010, as part of the U.S. government’s efforts to bring human rights v iolators to
justice and deny those violators safe haven in the United States. The new section represents a merger of the Criminal Division’s Domestic Security Section
(DSS) and the Office of Special Investigations (OSI).
ICE arrests continue
ICE arrests 72 during 2-week operation targeting immigration
fugitives
CHICAGO - Local U.S. Immigration and Customs Enforcement (ICE) fugitive operations teams arrested 72
foreign nationals in the Chicago area during a two-week-long enforcement action targeting immigration
fugitives and criminal aliens.
The ICE operation, which ran May 10-14 and May 24-28, targeted immigration fugitives with outstanding
deportation orders, aliens with criminal records, and previously deported aliens.
Arrests were made in the following communities: Addison, Arlington Heights, Aurora, Bensenville,
Bloomingdale, Bolingbrook, Bridgeport, Bridgeview, Carol Stream, Carpentersville, Chicago, Darien,
DuPage County, Elgin, Glendale Heights, Hanover Park, Joliet, Lisle, Melrose Park, Mundelein, Naperville,
North Chicago, Oswego, Palatine, Palos Hills, Plainfield, River Grove, Rock Island, Round Lake,
Waukegan, Willow Springs, Hammond, Ind., and Merrillville, Ind.
Of the 72 arrested, 59 are fugitives with outstanding deportation orders. Immigration fugitives are aliens who
fail to appear for their immigration hearings, or who abscond after being ordered by a federal immigration
judge to leave the country.
The remaining 13 were arrested based on their prior criminal or immigration histories; some of their
convictions and arrests include: drug possession, domestic battery, drunken driving, retail theft, residential
burglary, and larceny. Seven of those arrested were previously deported aliens.
The arrestees, 65 men and seven women, represent the following countries: China, Colombia, Czech
Republic, Ecuador, El Salvador, Guatemala, Honduras, India, Israel, Jamaica, Lithuania, Macedonia,
Mexico, Peru, Poland, Russia and South Korea.
fugitives
CHICAGO - Local U.S. Immigration and Customs Enforcement (ICE) fugitive operations teams arrested 72
foreign nationals in the Chicago area during a two-week-long enforcement action targeting immigration
fugitives and criminal aliens.
The ICE operation, which ran May 10-14 and May 24-28, targeted immigration fugitives with outstanding
deportation orders, aliens with criminal records, and previously deported aliens.
Arrests were made in the following communities: Addison, Arlington Heights, Aurora, Bensenville,
Bloomingdale, Bolingbrook, Bridgeport, Bridgeview, Carol Stream, Carpentersville, Chicago, Darien,
DuPage County, Elgin, Glendale Heights, Hanover Park, Joliet, Lisle, Melrose Park, Mundelein, Naperville,
North Chicago, Oswego, Palatine, Palos Hills, Plainfield, River Grove, Rock Island, Round Lake,
Waukegan, Willow Springs, Hammond, Ind., and Merrillville, Ind.
Of the 72 arrested, 59 are fugitives with outstanding deportation orders. Immigration fugitives are aliens who
fail to appear for their immigration hearings, or who abscond after being ordered by a federal immigration
judge to leave the country.
The remaining 13 were arrested based on their prior criminal or immigration histories; some of their
convictions and arrests include: drug possession, domestic battery, drunken driving, retail theft, residential
burglary, and larceny. Seven of those arrested were previously deported aliens.
The arrestees, 65 men and seven women, represent the following countries: China, Colombia, Czech
Republic, Ecuador, El Salvador, Guatemala, Honduras, India, Israel, Jamaica, Lithuania, Macedonia,
Mexico, Peru, Poland, Russia and South Korea.
US Naturlaized Citizen of the Day - Ivan Lendl
Ivan Lendl (born March 7, 1960) is a former World No. 1 professional tennis player. Originally from Czechoslovakia, Lendl became a United States citizen. He was one of the game's most dominant players in the 1980s and remained a top competitor into the early 1990s. Lendl captured eight Grand Slam singles titles. He competed in 19 Grand Slam singles finals, a record for a man since surpassed by Roger Federer in 2009. He reached at least one Grand Slam final for 11 consecutive years, a record for a man since equaled by Pete Sampras.
CBP says Immigration problem on US / Mexico Border is not so bad.
By Richard Fleischer, an attorney with over 30 years experience in Immigration law, who practices in Cincinati, Ohio and throughout the United States writes that
US Customs and Border Protection (USCBP) report that the US-Mexico border is NOT as dangerous as politicians would like you to think. In fact, is is one of the safest parts of the US and getting safer.
http://www.huffingtonpost.com/2010/06/03/us-mexico-border-safety-a_n_598825.html
It's one of the safest parts of America, and it's getting safer. It's the U.S.-Mexico border, and even as politicians say more federal troops are needed to fight rising violence, government data obtained by The Associated Press show it actually isn't so dangerous after all. The top four big cities in America with the lowest rates of violent crime are all in border states: San Diego, Phoenix, El Paso and Austin, according to a new FBI report. And an in-house Customs and Border Protection report shows that Border Patrol agents face far less danger than street cops in most U.S. cities." Martha Mendoza, AP, June 3, 2010.
Query:
Will the TV pundits pick up on this or ignore it?
US Customs and Border Protection (USCBP) report that the US-Mexico border is NOT as dangerous as politicians would like you to think. In fact, is is one of the safest parts of the US and getting safer.
http://www.huffingtonpost.com/2010/06/03/us-mexico-border-safety-a_n_598825.html
It's one of the safest parts of America, and it's getting safer. It's the U.S.-Mexico border, and even as politicians say more federal troops are needed to fight rising violence, government data obtained by The Associated Press show it actually isn't so dangerous after all. The top four big cities in America with the lowest rates of violent crime are all in border states: San Diego, Phoenix, El Paso and Austin, according to a new FBI report. And an in-house Customs and Border Protection report shows that Border Patrol agents face far less danger than street cops in most U.S. cities." Martha Mendoza, AP, June 3, 2010.
Query:
Will the TV pundits pick up on this or ignore it?
Thursday, June 3, 2010
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