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Home > Analysis > Vance Caps Career: Steinhardt Gives Up $70 Million in Antiquities
Vance Caps Career: Steinhardt Gives Up $70 Million in Antiquities
DA's Office Takes Heat for Prioritizing Returns from Bogdanos Investigations … and Kapoor is still in Tamil Nadu Jail
DA Cyrus Vance, Assitant DA Matthew Bogdanos, and members of the antiquities trafficking unit with seized objects at a press event celebrating their achievements. Credit Office of New York District Attorney.
Kate Fitz Gibbon - January 19, 2022
Ivory Plaque for furniture, period of King Sargon I (721-725 BCE) allegedly from Nimrud, returned to Iraq from Steinhardt collection, photo DANY.
The legacy of retiring NY District Attorney Cyrus Vance and the future of his anti-antiquities unit, headed by Assistant District Attorney Matthew Bogdanos, is a hot topic in New York.
In December 2021, the antiquities trafficking unit settled its case against 80 year old billionaire, hedge-fund pioneer and philanthropist Michael Steinhardt. Steinhardt agreed to the seizure of 180 antiquities and their return to foreign countries – and to give up antiquities collecting for his lifetime.
The antiquities unit is controversial, in part due to the resources it drains from more direct New York concerns. At the end of his tenure, Vance was already being criticized for having spent nearly $715 million of the District Attorney Office's funds from asset forfeiture cases, mostly garnered from banks, on a variety of criminal justice programs, leaving a paltry $31 million for the new DA.
Gold Bowl, allegedly from Nimrud, returned to Iraq from Steinhardt collection, photo DANY.
Vance's alignment with the international antiquities unit was seen by some as beyond his usual responsibilities – others concluded that he relished the national press from art cases. Some in the press have been asking how sending seized assets to foreign countries hostile to U.S. interests benefited New Yorkers.
The new Manhattan District Attorney, Alvin Bragg, says that he wants to focus first on the needs of his New York constituents. He has pledged to be more transparent than his predecessor, to pull back on prosecuting certain offenses, pursue alternatives to incarceration, and to solicit constituent involvement in allocating spending. One of Bragg's first actions this January, however, was to return a number of seized antiquities to diplomats from Iraq and Libya.
The antiquities trafficking unit.
DA Vance described the unit's activities in the Steinhardt case Statement of Facts:
"For more than a decade, this Office has conducted extensive criminal investigations into international antiquities trafficking networks that plunder priceless cultural heritage and traffic antiquities into and through New York… These investigations have resulted in the convictions of 11 traffickers and their co-conspirators; the indictment and pending extradition of another 6 traffickers; the seizure of more than 3600 antiquities valued at more than $200 million. As a result, this Office has returned more than 1500 antiquities to the victims of this pillaging—two dozen countries and individuals—around the globe."
President George W. Bush with recipients of the 2005 National Humanities Medals, Nov. 10, 2005, Colonel Bogdanos stands to the right of the President. White House photo Eric Draper.
Vance's point man on antiquities trafficking, Assistant District Attorney Matthew Bogdanos had been chasing unscrupulous art thieves for more than a decade before Vance created the special antiquities unit in 2018. A U.S. Marine Corps Reserve Colonel, he had been recalled to active duty after 9/11. He led multi-agency task forces seeking terrorists in Afghanistan and Iraq. Colonel Bogdanos was stationed in Iraq when the Baghdad Museum was looted. He immediately turned to investigating the theft, spending months tracking down and recovering many of its lost objects. He received a National Humanities Medal in 2005 for his services and on his return, wrote a well-received book on his work to recapture the museum's collections.[1]
Bogdanos is known for his colorful statements about his work; a number of these, together with some surprising admissions – appeared in a recent profile on Bogdanos by investigative reporter Ariel Sabar in The Atlantic magazine, The Tomb Raiders of the Upper East Side. Bogdanos admits that on his return to the US, he invented a job for himself that then existed only in his imagination.[2]
Bogdanos had written in a NY Times Opinion piece:
"…the patina of gentility we usually associate with the world of antiquities has always rested atop a solid core of criminal activity… I will return to the Manhattan district attorney's office early next year and head the city's first task force dedicated to investigating and prosecuting antiquities theft and trafficking. We intend to expose those who engage in the illegal trade for what they are: criminals."[3]
Sabar commented that "a high-ranking official in the Morgenthau administration" told him the antiquities unit "was completely a figment of his own imagination and his self-aggrandizing personality."[4]
Still, a decade before the special antiquities unit was officially created, Bogdanos was working closely with Agent Brent Easter of Homeland Security Investigations to publicize the evils of the antiquities trade – and to pursue rogue antiquities dealer Subhash Kapoor.
Kapoor inventory group with some distinctive fakes, screenshot from Homeland Security Investigations video.
Subhash Kapoor, formerly a small time dealer of minor objects, appears to have filled the gap left in the Indian antiquities trade after the arrest of Vaman Ghiya in Jaipur in 2003.[5] The case against Kapoor has been ongoing for the last decade in both India and the United States, and has resulted in the return of the largest number of Indian ancient sculptures and other antiquities to India of any investigation.
In 1974, Kapoor, the son of an Indian antique dealer, immigrated to the US, and established a gallery, Art of the Past, selling manuscripts, miniatures, and other Indian antiques. According to Indian law enforcement, around 2005, Kapoor began smuggling ancient sculptures in bronze and stone taken from temple sites in the Indian state of Tamil Nadu. A number of temple robbers arrested in the Tamil Nadu region implicated Kapoor as the eventual recipient of their stolen goods via a chain of local dealers.
Outside of India, investigations into Kapoor's gallery by the office of the New York District Attorney (DANY) were prompted by information shared by his Singapore-based former partner on the Internet in 2010-2011. Then, in October 2011, India's Central Bureau of Investigation (CBI) issued a Red Corner Notice through Interpol; Kapoor was detained at Frankfurt airport, then extradited to India to be held at a prison in Chennai, Tamil Nadu State.
In July 2012, the DANY issued an arrest warrant for Kapoor, charging him with possession of stolen property. Kapoor's sister, Sareen was arrested and charged with criminal possession of stolen property valued at more than U.S. $1million. Altogether, HSI raided 12 warehouses of Kapoor's and seized 2,622 miscellaneous artifacts. Hundreds of these artifacts have since been returned to the Government of India. The charges against Kapoor subsequently prompted the voluntary return by U.S. and international museums and private collectors of objects either sold or donated to them by Kapoor.[6]
In India, the case against Kapoor has proceeded very slowly. Although he was arrested in 2012, the first hearing was held five years after he was jailed, in 2016. He is reported to have trouble with fellow inmates, attacked for wasting water at the common tap when washing his clothes.
Sri Lankan bronzes returned from Kapoor investigation. Photo HSI.
On July 7, 2019, a 285-page criminal complaint and arrest warrant was issued against Kapoor by the DANY, charging him with grand larceny, conspiracy, and numerous counts of criminal possession of stolen property.[7] Seven other individuals were also charged in the same warrant with conspiracy and/or criminal possession of stolen property. It is expected that when his Indian case ends, Subhash Kapoor will be extradited from India and the details of his role in the smuggling of international cultural property will be brought to light.
The Kapoor case gave Bogdanos and Easter the opportunity to develop a Robin Hood/Raiders of the Lost Ark narrative in the press. In 2012, Easter received an Investigator/Prosecutor of the Year Award from HSI NY for Operation Mummy's Curse, which "successfully uncovered and dismantled a cultural-property and money-laundering network based in New York." Easter was featured in a 2015 short film, The Real-Life Indiana Jones, ESPN Films, on the Kapoor case, alternately hunting down suspect shipments via computer and condoling with grieving Indian villagers.
At the same time, wrote Sabar in The Atlantic, Bogdanos ensured that his Iraq exploits would not be forgotten in a series of "speeches, interviews, and op-eds…" often at museum and academic venues, "promoting the notion that Iraqi insurgents were using the antiquities trade as a major revenue source—"a cash cow"—for terrorism."
Bogdanos' and others' claims that there was a billion or even multi-billion dollar illegal trade in antiquities and that the trade was funding terrorists was debunked in a major analysis by the RAND Corporation, Tracking and Disrupting the Illicit Antiquities Trade with Open-Source Data.
Veiled Head of a Female," 350 BCE, returned to Libya by new DA Bragg. Photo DANY.
The RAND study identified Bogdanos as among the cultural property activists, bloggers and journalists who have greatly exaggerated the problem of illegal trade. In fact, the RAND report named Bogdanos as a primary source of the widespread but inaccurate belief that antiquities trafficking is linked to trafficking in drugs and weapons.[8]
Not long ago, Bogdanos characterized antiquities dealers as both indifferent to the serious harm looting causes and belonging to "a socio-economic strata that you and I can never hope to attain, with their limousines waiting at the curb and with their bespoke suits."[9] The description showed a surprising misunderstanding of the working of the antiquities trade, given Bogdanos' sharp intelligence and familiarity with it.
Of course, criminals should be caught and punished for breaking the law, but Bogdanos' cases aren't limited to wrongdoers. Many have involved identifying artworks whose provenance records are unavailable outside law enforcement or objects that were exported long ago from foreign countries and have since passed through the hands of good faith owners.[10] Art dealer associations such as CINOA, the International Association of Dealers in Ancient Art and the UK based Antiquities Dealers' Association work hard to do due diligence and adhere to ethical standards.
Bogdanos' sling about "bespoke suits and limousines" was also well off the mark. There are a few very well-heeled dealers (you can count them on one hand). Data on the antiquities market shows that it is the smallest and least valuable section of the global art trade and that most qualify as micro-businesses.[11]
Proto-Corinthian owl figure, 6th C BCE, seized from Steinhardt Collection. Photo DANY.
Bogdanos' antiquities unit could also be more cautious in its claims about the value of seized antiquities. According to Sabar's article in The Atlantic, "Bogdanos and his agents have impounded more than 3,600 antiquities, valued at some $200 million."
Certainly, some of Kapoor's sales of important Indian bronzes stolen from temples in Tamil Nadu were of high value. However, the DANY's $100 million dollar list of the items seized from Kapoor appears "greatly inflated."[12] The Homeland Security Investigations images of the raid on Kapoor's storage spaces showed numerous objects so obviously fake that museum and other experts who reviewed the footage found it impossible that anyone could take them seriously.[13] Even Indian diplomats have acknowledged as much. It seems that when Kapoor attempted to deceive US Customs by calling his shipments 'garden statuary,' he was sometimes not far off the mark. This lack of expert information at the DANY has hopefully been corrected over time.
In 2018, the antiquities trafficking unit was finally officially established: DA Cyrus Vance allocated $2.2 million to it, covering salaries for five years. When the new unit was created, its agenda was clear. Ads placed for 'antiquities analysts' stated that the bureau needed staff to provide "critical analysis of records for use in criminal prosecution against trafficking participants such as looters/thieves, smugglers, financiers, shippers, gallery owners, restorers, on-line sites, conservators, auction houses, [and] museum curators…".[14]
Steinhardt: A major case completed on the eve of Cyrus Vance's retirement.
The DANY's antiquities trafficking unit also had targets already in its sights.[15] On January 5, 2018, Bogdanos' team delivered warrants and seized six objects from the Phoenix Ancient Art gallery and the same day, DANY staff and Homeland Security Investigations agent spent six hours cataloging artworks at the home of Michael Steinhardt. Three years later, after exhaustive research and investigation into sometimes decades of transfers of objects, the District Attorney's office delivered its results In the Matter of a Grand Jury Investigation into a Private New York Antiquities Collector.
Larnax, chest for human remains from Crete, 1400-1200 BCE. Seized from Steinhardt Collection. Photo DANY.
The Steinhardt case ended with the surrender of 180 objects in early December 2021 from among the approximately 1000 objects he acquired since 1987. The DANY and Steinhardt signed a non-prosecution agreement (the "Agreement")[16] ending a grand jury probe of Steinhardt and any criminal charges against him. The Agreement also compelled the eighty-year-old billionaire to swear off antiquities collecting for his lifetime.[17]
During the course of the investigation, Bogdanos obtained 17 search warrants for Steinhardt's antiquities, documents, and digital media. The DANY concluded that 180 of the antiquities in Steinhardt's possession constituted stolen property under New York law because they were "looted and unlawfully removed from their respective countries."[18] Some of the objects that will be returned to foreign countries are of spectacular quality, including a magnificent silver and gold rhyton formerly on loan to the Metropolitan Museum that will go to Turkey.
In the Agreement, Steinhardt maintains he did not commit any crimes in buying, selling or dealing in antiquities, while the DA's office "maintains that the evidence would establish at trial that Steinhardt bought, sold, and otherwise dealt in antiquities and that he knew, or should have ascertained by reasonable inquiry, that the antiquities listed in Exhibit A were stolen." The lengthy Agreement and Statement of Facts reiterate lists and descriptions of individual objects and their presumed origins, the chain of dealers and collectors that Steinhardt's acquisitions followed, and the cultural property laws in the countries concerned.[19]
Under the Agreement, Steinhardt will:
Give up all title to the 180 antiquities and waive all claims against DANY, Homeland Security and any others involved in the seizures;
Turn over to the DA three pieces now missing from the 180 if they are found;
Not acquire any more antiquities (defined as artifacts created before 1500 CE) for the remainder of his life; and
Make no public statement contradicting the provisions of the agreement and obtain DANY permission before making any statement except factual statements in future litigation to which DANY is not a party.[20]
The Ercolano Fresco of the infant Hercules slaying a serpent. Seized from Steinhardt Collection. Photo DANY.
According to the DANY, there was not sufficient evidence of illegality to warrant seizure of other objects owned by Steinhardt.[21] Provided that he does not violate any of the above terms, the District Attorney's office agreed not to prosecute Steinhardt for any crimes "arising out of his current or prior acquisition, possession, sale, and tax treatment of antiquities." Regarding Steinhardt's remaining antiquities collection, numbering approximately 800 pieces, the Agreement states that "DANY takes no position on the legality of the remaining antiquities currently in Steinhardt's possession, but will not legally challenge the transfer, sale, gift, or bequest of those remaining antiquities."[22] The Agreement is binding on Steinhardt and the DANY but has no effect on the actions of any other federal, state, or local law enforcement agencies.
Among objects recently seized from American museums: the antiquities collection of a former federal prosecutor.
Other recent announcements of antiquities seizures and returns by the DANY have garnered less press attention, but may have a greater impact on the public, both in New York and elsewhere across the country.
Collector William D. Walsh, a former assistant U.S. attorney who ran narcotic investigations into NY's waterfront. He was responsible for indicting Vito Genovese, the leader of the Genovese crime family. Later CEO of a venture capital firm, he donated $10 mil. to Fordham's library together with his antiquities collection.
Two hundred ancient objects were returned by the District Attorney to Italy in mid-December 2021. Almost half came from the collection of Fordham University's Museum of Greek, Etruscan and Roman Art in the Bronx. The museum, which is open free to the public, served as a teaching collection for students and academic researchers. It lost more than one third of its entire collection in the seizure by the DA's office, including a number of magnificent ceramic vessels. The antiquities had been donated by William D. Walsh, and his wife Jane. Walsh was a Fordham alumnus and himself a former federal prosecutor in NY. The antiquities were displayed in a 4,000 sq ft. section of the Walsh Family Library on the campus, so that books and other reference materials related to the objects were readily accessible to students.
Jennifer Udell, Curator of University Art and the Fordham Museum of Greek, Etruscan, and Roman Art, has described the seizure and return of 99 objects as in the best interest of the museum and the students of the university, giving students insight into "how issues relating to provenance legislation unfold". In her statement written prior to the return, Dr Udell expressed her hope that after the judge in the case signed a turnover order giving Italy legal possession, Italian authorities would consider the museum's request to have them back on loan.[23] So far, that has not happened.
Other objects that were returned to Italy in December came from museums outside New York: the Cleveland Museum of Art, the Getty Museum in Los Angeles, and the San Antonio Museum of Art in Texas all turned over objects. One returned sculpture was seized from a shipment of antiques purchased in Belgium for the home of Kim Kardashian. The total value of the 200 returned objects was $10 million, an average value of $50,000.
Volute krater, Fordham University Museum, Gift of William D. and Jane Walsh. Credit Fordham University.
Many of the objects were identified as "stolen" because they had been purchased by the Walshes or other collectors from a single Italian art dealer, Eduardo Almagià, a Princeton graduate who lived and did business in New York up until 2003. Almagià is presently living in Italy. Any crimes committed there are too old to be prosecuted under Italian law.
In a phone interview from Italy, Almagià told the NY Times' Tom Mashberg:
"I sold things from Italy, definitely yes. There are objects in U.S. museums that are undoubtedly stolen from excavations but when they are not objects of the greatest importance, I think they should remain there so they can be appreciated by American visitors…" "There are thousands of items that travel around the world without papers, and they are only asking for papers now, and in the past they never had such requirements," … "So much money is being spent to persecute dealers when it can be used to repair Italian museums, where so many similar items are already at risk…."
In one thing at least, Almagià is correct. Italy is the second lowest spender in the EU on culture and there are currently millions of uncataloged and unconserved objects in Italian museums.[24]
Aggressive DANY policies and proceedings.
The DANY has been by far the most aggressive prosecutor of alleged antiquities crimes in the United States, taking on numerous cases that federal authorities in the same jurisdiction have not pursued, whether for lack of interest, lack of evidence, or the amount of time that has passed since the alleged crime took place.
Fragment of a wall frieze from Persepolis, owned for fifty years by the Montreal Museum of Fine Arts, sold to its insurer, and later seized in New York, then returned to Iran in 2018. Photo: Montreal Museum of Fine Arts.
Assistant DA Bogdanos has repeatedly made explicit, both in the Steinhardt Statement of Facts and Agreement and in his correspondence with claimant countries[25] that his position is,
"To prove a suspected crime, all investigations and prosecutions – whether for antiquities trafficking or murder – may also rely on circumstantial evidence. Indeed, New York State criminal law draws no distinction between the weight or importance of direct versus circumstantial evidence in proving a crime."[26]
What constitutes "sufficient evidence" to show that an object is stolen, in Bogdanos' view? The Steinhardt Statement of Facts identifies factors the DANY considers indicative of crime. A false statement on an import or export document, for example, is actual, not circumstantial evidence of criminal wrongdoing. People familiar with the art market might not agree that the factors listed by Bogdanos (except #4, depending on the date exported) are indicative of illegality.
According to the Statement of Facts, the "circumstantial evidence" indicating that an object is looted/stolen may include:
The first documented possessor of the object is a known or convicted smuggler or trafficker of antiquities
A documented photograph of the object depicts it in a dirty or broken state
An object is dirty or encrusted
The find spot or how it was discovered is known or stated in correspondence
The object was at some time intentionally broken
An unprovenanced antiquity appears on the international art market for the first time immediately after civil unrest or war in its country of origin
There is confirmed and specific looting of similar objects at the same time
The objects are part of a previously unknown hoard
The object has a false or opaque provenance[27]
Major investment in time and resources.
Among the outside contributors to the Steinhardt case was Christos Tsirogiannis, a forensic archaeologist and dedicated antiquities hunter, who incidentally, had access to the Italian police files that U.S. museums and auction houses were denied. He recently spoke to the Greek Reporter about his work identifying 36 objects in the Steinhardt case. Tsirogiannis described his identification of Steinhardt's fragmentary Kouros statue valued at about $14 million as "by far a personal best in my career." Tsirogiannis also told reporter Tasos Kokkinidis that he was disappointed that not a single official in a source country had contacted him "to express thanks or gratitude." "As usual, everyone wants to take a piece of credit from my work that they don't deserve," he said. Tsirogiannis also said that the DANY had two more cases "of the same level" ready to break on which he also worked and identified objects.
Persepolis, area of stolen relief, circa 1933.
The DANY has pursued quite a number of antiquities cases both before and after the anti-trafficking unit was officially organized. Others include:
The lightning-fast conviction of Japanese art dealer Tatsuzo Kaku under a plea agreement forfeiting a Bhuddapada statue from Pakistan in 2016.
Two Indian stone statues from the collection of Dr. Avijit Lahiri and his wife Dr. Bratatihi Lahiri were seized by the DANY from Christie's NY in 2016.
New York art dealer Nancy Weiner plead guilty in October 2021 to charges of conspiracy and possession of stolen property filed in 2016 for trafficking objects obtained from Subash Kapoor and Douglas Latchford.
In 2017, the DANY seized a piece of mosaic flooring from the New York home of European antiques dealer, Helen Fioratti, said to have come from the flooring of one of Caligula's ships, that had been in her home for 45 years.
Also in 2017, a small piece of a Persepolis frieze valued at $1.2M was seized from a NY art fair and eventually returned to Iran. The theft from Persepolis occurred sometime between 1930 and 1933 and the fragment had been in a Canadian museum for decades.
In 2018, a Head of Alexander was seized from the Safani Gallery that had circulated in known private collections for a least 80 years. The gallery contested the seizure, noting Italy's complete lack of evidence for its theft. A federal court recently held that Italy was protected from Safani's lawsuit by foreign sovereign immunity. The case is still pending; the statue's ownership remains unresolved.
The Metropolitan Museum in New York agreed to return a gilded coffin to Egypt in 2019 after DANY research indicated it was sold by means of a forged Egyptian export license.
DANY's policies questioned in NY press.
Head of Alexander the Great as Helios, God of the Sun, c. 300 BCE, courtesy Safani Gallery, Inc.
Recently, Vance and Bogdanos have been castigated in the press for harassing museums and collectors in headline-worthy antiquities cases instead of serving the interests of average New Yorkers. An article in the New York Sun, What Was Cy Vance Doing While Murders Were Soaring on His Watch? was particularly critical of Vance's anti-antiquities trafficking campaign, noting that the murder rate in Manhattan had nearly tripled since 2018, "while Vance concentrated on the former president's old tax returns — and playing amateur archaeologist in the arcane world of classical antiquities."
Noting that the DANY had undertaken joint investigations with law-enforcement authorities in 11 countries: Bulgaria, Egypt, Greece, Iraq, Israel, Italy, Jordan, Lebanon, Libya, Syria, and Turkey, Stoll wrote:
"If the chemical weapons-using regime in Syria, the Iranian client state in Lebanon, the Hashemite King of Jordan, or the friendlier governments in Israel, Italy, or Egypt want to chase antiques being held by the Metropolitan Museum of Art, or in the hands of private American collectors — well, good luck to them. The statues will not be any safer, or more accessible to scholars, in the hands of the government of the Ba'athist dictator Bashar al-Assad or of Turkey's Islamist strongman Erdogan than they were at the Metropolitan Museum or under private American ownership."
He continued, "The ideology undergirding the investigation — with Vance's talk of "the rights of peoples to their own sacred treasures" — leads to the great museums of New York and London being emptied. What about the rights of peoples not to be gunned down on a Manhattan street corner?"
NY market damaged.
The DANY's antiquities unit does appear to focus more on ancient art long in the market than on looting today. New cases are much rarer now because dealers and buyers now want to know more about an object's history.
The antiquities unit appears to have backed off from trying to send offenders to jail. Investigative reporter Ariel Sabar wrote in his Atlantic profile that "proving mens rea, a suspect's guilty mind, has been harder than Bogdanos imagined." Bogdanos told him that, "he's had to reconcile himself to extremely light sentences for some culprits in exchange for testimony against the worst offenders, most of whom have yet to face justice."
Buddhapada sculpture, footprints of the Buddha. Seized from Japanese art dealer Tatsuzo Taku in 2016.
Whether dealers or collectors go to jail or not, Bogdanos' willingness to seize objects that he deemed stolen but art dealers and collectors assumed to be legitimate has been enough to seriously damage the antiquities trade in New York, once the largest market in the world and host to the most popular and best attended public fairs for ancient and ethnographic art. If an object is seized, it is both a serious financial loss and a blow to the dealer's reputation.
Foreign dealers are now wary of bringing objects for sale to New York. Sotheby's ended its antiquities auctions in NY in 2016 and Christie's are much reduced. According to reporter Sabar, a study reported that the number of ancient art gallery storefronts in Manhattan had shrunk from a dozen to three, with some dealers operating only by appointment. There do not appear to be any new or younger antiquities dealers in New York.
Steinhardt's seized antiquities were originally sourced primarily from dealers who have long ago retired. The Steinhardt Statement of Facts states that 169 of the 180 Seized Antiquities prior to his actual acquisition were "trafficked by a total of 12 different criminal smuggling networks" controlled by Giacomo Medici, Giovanni Franco Becchina, Edoardo Almagià, Robin Symes, Robert Hecht, Eugene Alexander, Fritz and Harry Bürki, Gil Chaya, Rafi Brown, Pasquale Camera, George Ortiz, and Noriyoshi Horiuchi.
None of these alleged foreign "controllers of criminal networks" are incarcerated and some have never been charged with crimes. Any cases against them for trafficking in their own countries ended long ago, many without convictions. Italy drops ongoing court cases if they do not end within a certain number of years. The alleged illicit activities took place decades ago and most of the individuals listed are now in their late 70s or 80s – or dead.
Unquestionably, there are many objects that have circulated in the antiquities market that were exported without government permits and in violation of source countries' laws – their laws on paper, at any rate. Equally unquestionably, objects now deemed 'stolen' entered the U.S. legally for decades, but under the Customs rules of the time, were not considered unlawful simply on the basis of foreign export laws. All U.S. Customs asked for for legal importation was accurate descriptions of age and country of origin.
One question for New Yorkers and other Americans today is – should antiquities policy be based on national priorities and defined under federal laws – or should a Manhattan District Attorney's Office with its own agenda be directing it?
[1] Matthew Bogdanos, Thieves of Baghdad: One Marine's Passion to Recover the World's Greatest Stolen Treasures, Macmillan, October 26, 2005. Bogdanos managed the successful return of numerous antiquities to the Iraq Museum.
[2] Although then DA Morgenthau had allowed him to pursue antiquities as part of his work, he had never asked for or gotten approval for a task force. Asked why he'd said this by Sabar, he replied, "You know how when you want something to happen, you say it as if it's true?" His bosses at that time told Sabar that Bogdanos never presented a viable case. Ariel Sabar, The Tomb Raiders of the Upper East Side, The Atlantic, November 23, 2021, https://www.theatlantic.com/magazine/archive/2021/12/bogdanos-antiquities-new-york/620525/.
[3] Matthew Bogdanos, The Terrorist in the Art Gallery, NY Times, December 10, 2005, https://www.nytimes.com/2005/12/10/opinion/the-terrorist-in-the-art-gallery.html. See also Jason Edward Kaufman, US colonel to lead antiquities anti-theft unit, The Art Newspaper, 31 December, 2005, https://www.theartnewspaper.com/2006/01/01/us-colonel-to-lead-antiquities-anti-theft-unit.
[5] According to police cases filed against Ghiya in his home state of Rajasthan, he illicitly traded in antique sculptures for thirty years, sending some 700 statues to auction via Geneva before finally being arrested in June 2003. Ghiya's initial conviction was reversed in 2014 by the High Court of Judicature for Rajasthan at Jaipur Bench. In a separate judgement the same day in Vaman Narain Ghiya vs. State of Rajasthan, the High Court of Judicature for Rajasthan overturned Ghiya's remaining earlier convictions for dishonestly receiving stolen property and habitually dealing in stolen property. Much of the evidence produced at the original trial was held by the High Court to be either inadmissible for lack of proper documentation or to be hearsay. See State of Rajasthan vs. Vaman Narain Ghiya & Anr., (2014) (India) para. 12, https://indiankanoon.org/doc/152498913/. (DB Criminal Appeal No.809/2012, Against The Judgment Dated 20.11.2008 Passed By The Additional Sessions Judge (Fast Track) No.1, Jaipur City, Jaipur IN Sessions Case No..76/2006(141/2003), Judgment January 15, 2014). See Fitz Gibbon Law LLC, Global Art and Heritage Law Series India, Committee for Cultural Policy, 2020, pp 46-48, CCP-Global-Art-and-Heritage-Law-Series-India.pdf.
[6] Fitz Gibbon Law LLC, Global Art and Heritage Law Series India, Committee for Cultural Policy, 2020, pp 49-50, CCP-Global-Art-and-Heritage-Law-Series-India.pdf.
[7] Sarah Cascone, New York Files Charges Against Disgraced Art Dealer Subhash Kapoor in $145 Million Smuggling Ring, Artnet News, July 11, 2019, https://news.artnet.com/art-world/new-york-files-charges-145-million-art-smuggling-ring-1598293
[8] Other sources of claims regarding the size of the antiquities market and its association with terrorism included ATHAR Project's Katie Paul and the Antiquities Coalition. See Matthew Sargent, James V. Marrone, Alexandra Evans, Bilyana Lilly, Erik Nemeth, Stephen Dalzell, Tracking and Disrupting the Illicit Antiquities Trade with Open-Source Data, RAND Corporation, "The authors [Ed. of a Foreign policy article] quote Danti, who observed that "[t]here is frequently overlap in the smuggling and sale of weapons and antiquities. The two illicit trades, he said, tend to share similar routes, shipments, and dealers." Although this assumption is widely held among antiquities researchers, there is little evidence to support this conclusion. Most citations supporting this claim refer to a single original source, U.S. Marine Corps Reserve Colonel Matthew Bogdanos's experiences during the Iraqi Civil War. In fact, evidence from the postings on this channel suggest that there is little overlap of these markets in online platforms." page 49-50; and "An article in the Wall Street Journal included estimates from Michael Danti, an archaeologist and academic director of ASOR CHI, placing the value of the Islamic State's antiquities trafficking in the "low tens of millions" annually, while a French security official placed the figure at $100 million. Lehr, of the Antiquities Coalition, estimated that "[c]oming out of Syria, it is $2 billion" and "[w]ith Egypt, it is probably $3–10 billion, globally it has to be a much more significant number." Id, page 11; and "Our aggregate data suggest that the market for all antiquities, both licit and illicit, is on the order of, at most, a few hundred million dollars annually rather than the billions of dollars claimed in some other estimates … We believe that, going forward, scholars arguing that the illicit market is larger than we suggest here will need to more clearly articulate the means through which these goods are sold." Id. at page 84-85.
[9] Ben Lewis, What distinguishes an art criminal from a regular crook?, The Art Newspaper, 27 September 2021, https://www.theartnewspaper.com/2021/09/27/what-distinguishes-an-art-criminal-from-a-regular-crook.
[10] Italy continues to deny access to information on stolen objects to museums as well as to auction houses and the legitimate art trade, despite the Association of Art Museum Directors, dealer organizations, and auction houses having sought this officially for more than a decade. See Statement of the Association of Art Museum Directors Concerning the Proposed Extension of the Memorandum of Understanding between the Government of the United States of America and the Government of the Republic of Italy Concerning the Imposition of Import Restrictions on Categories of Archaeological Material Representing the Pre-Classical, Classical, and Imperial Roman Periods of Italy, as Amended, Meeting of the Cultural Property Advisory Committee, April 8, 2015, p 10, https://aamd.org/sites/default/files/key-issue/FINAL%20AAMD%20PRESENTATION%202015.pdf
[11] For multiple sources, see Kate Fitz Gibbon, Trade Delivers Reality Check to Money-Laundering Regulators, Cultural Property News, October 30, 2021, https://culturalpropertynews.org/trade-delivers-reality-check-to-money-laundering-regulators/.
[12] Letter from Dr. Stanislaw Czuma, June 2016.
[13] See also The Real Life Indiana Jones, FiveThirtyEight, ESPN Films, a Signals documentary produced and directed by Jason Kohn. This is confirmed in part by Cite to Indian embassy statement about leaving fakes behind.
[14] For hiring information, see https://dany.applicantstack.com/x/detail/a2i2x0xwuww4/aaac
[15] It appears that the DA just happened to be looking into a specific artifact, which led it to Steinhardt, not the other way around. "In February 2017, while investigating a multi-million-dollar marble archaic bull's head (the "Bull's Head") stolen from the archaeological site of Eshmun in Lebanon during the Lebanese Civil War, this Office determined that the Bull's Head had been purchased by Steinhardt who subsequently loaned it to the Metropolitan Museum of Art (the "Met")." In the Matter of a Grand Jury Investigation into a Private New York Antiquities Collector, Statement of Facts (hereafter Statement of Facts), Supreme Court New York County, filed December 6, 2021, p 2, https://images.law.com/contrib/content/uploads/documents/292/102693/2021-12-06-Steinhardt-Statement-of-Facts-w-Attachments-Filed.pdf.
[16] In the Matter of a Grand Jury Investigation into a Private New York Antiquities Collector, Agreement (hereafter Agreement), Supreme Court New York County, filed December 6, 2021, https://images.law.com/contrib/content/uploads/documents/292/102693/2021-12-06-Steinhardt-Complete-Agreement-w-Exhibits-Filed.pdf
[17] See Agreement, 4 d., p 2.
[18] Id. at 1.
[19] Note: One dealer who supplied objects to Steinhardt, Svyatoslav Konkin, told the International Association of Dealers in Ancient Art that the Statement of Facts and Agreement contained inaccuracies regarding the provenance and customs entries of objects he sold to Steinhardt. IADAA Newsletter December 2021, January 4, 2022, states, "[the Statement of Facts] also states: "Although Konkin claimed in a letter to Steinhardt that the Gold Bowl "has clear history which goes back at least up to 1970 and earlier, no verifiable provenance prior to Konkin's 2019 arrival into the United States has ever been identified." The DA's media release claims that the bowl was looted from Iraq during its occupation by ISIS, the implication being that this funded terrorism. Konkin says none of this is true and describes the DA's claims as "fantasy"."
https://iadaa.org/wp-content/uploads/2022/01/12-IADAA-Newsletter-December-2021.pdf.
[20] Agreement, 4a-e, p 1-3.
[21] Statement of Facts, p 3.
[22] Agreement, 5b, p 3.
[23] Jennifer Udell, Fordham Museum Helps Resolve Trafficking Case, Fordham Library News, September 1, 2021. https://librarynews.blog.fordham.edu/2021/09/01/fordham-museum-helps-resolve-art-trafficking-case/
[24] Barbie Latza Nadeau, Italy's Incompetence is Creating New Ruins, Daily Beast, June 04, 2019.
[25] In a letter dated May 29, 2019 to Dr. Khaled El-Enany, Minister of Antiquities of the Arab Republic of Egypt, Bogdanos says, regarding unprovenanced antiquities, "To prove a suspected crime, investigations and prosecutions may also rely on circumstantial evidence. Indeed, New York State criminal law draws no distinction between the weight or importance of direct versus circumstantial evidence in proving a crime. Circumstantial evidence in the case of suspected looted antiquities may include, but is not limited to, the sudden appearance of an object on the market after a source country has been looted of that specific type of object, the first documented photograph of the object depicting it in a dirty or broken state, the existence of inconsistent or demonstrably false provenance for the object, or that the first documented possessor of the object is a smuggler or trafficker of stolen antiquities. Standing alone, any one of these facts may not be sufficient to warrant criminal prosecution. But, when taken together with other evidence, and what may reasonably be inferred from the evidence, such facts are always material, usually probative, and often dispositive." p 3-4. Bogdanos' correspondence indicates that even if criminal intent is lacking and a NY owner or seller of an object may not be aware of a source nation's claim of superior title, civil seizure is justified when there is evidence that an object left an art-source nation after passage of a national patrimony law.
[26] See for example, Agreement, pp 7-8.
[27] Statement of Facts, pp 8-12.
[28] For years, the Italian police have held photographs from the files of members of a previous generation of art dealers who were charged with selling illicitly exported or looted objects. The police have given access to these files to a few academics and researchers as well as other police agencies, who use them to track down artworks when they show up decades later, often after having passed through many hands. See https://culturalpropertynews.org/tsirogiannis-master-of-the-blame-game-goes-after-frieze-masters/
[29] See Statement of the Association of Art Museum Directors Concerning the Proposed Extension of the Memorandum of Understanding between the Government of the United States of America and the Government of the Republic of Italy Concerning the Imposition of Import Restrictions on Categories of Archaeological Material Representing the Pre-Classical, Classical, and Imperial Roman Periods of Italy, as Amended, April 8, 2015, p 5, https://aamd.org/sites/default/files/key-issue/FINAL%20AAMD%20PRESENTATION%202015.pdf.

redpajama_set_name: RedPajamaCommonCrawl


Discussion in 'General discussion' started by SLICKTOP, Sep 7, 2018.
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Welcome back! Looks pretty good - what does she need doing?
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Q: How to set up local DNS server with conditional forwarding? I'm trying to set up a DNS server that will forward some but not all lookups to Google's 8.8.8.8 DNS server, mapping a few specific domain names to other IP addresses (of my choosing) instead.  I have been trying this with both dnsmasq and BIND, but the configuration files are very confusing to me for both.

A: This is an old question, but I add an answer in case someone comes across this, and is looking for a solution. On Windows the conditional forwarding can be set up by using a commercial Simple DNS Plus program. It offers DNS forwarding by domain name, plus a catch-all.
On Linux/Mac you can use bind (named). See this answer for details.

redpajama_set_name: RedPajamaStackExchange


Top grade material based on Klingerit but reinforced with wire mesh for demanding and extreme services. Specially suitable and recommended for conditions of fluctuating temperature and presssure, i.e. when steam hammers might occur or in automotive application. Composed of SBR binder and high grade chrysotile asbestos. Delivered with graphited surface.
*Note: Maximum temperature and pressure capabilities do not necessarily operate together for all gasket thickness and service conditions.


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This card is really a 2-for-1 sale on great names but Mark Funderburk is getting out shined by the sheer awesomeness that is the name Billy Joe Robidoux.
The name just rolls off the tongue. And it's a shame that his career didn't quite live up to the greatness of his name.
Thanks to Reader Kevin for sending me this card in a trade.


Turf Athletic Club is a brand new athletic training facility with 15,000 sq feet of space. Approx 5000 sq feet of astroturf. Features include functional training cages, boxing ring + heavy bag area, bodybuilding area, dance studio, cycling studio and full-scale cardio area. TAC offers high-quality amenities such as a locker room and a full-service juice bar. They also sell meal plans out of the juice bar. Whatever your fitness needs from personal training, physiotherapy, massage, group fitness classes as well as fitness consultations; they have it. Need more space; rent out our back turf for team training.
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Home | Politics | Sudan: Tens of thousands of protesters demand civil rule
On Sunday, June 30, tens of thousands of Sudanese protesters took to the streets to demand civil rule. The demonstrations, which were organized by the Alliance for Freedom and Change, took place all over the country.
Three months after al-Bashir, Sudanese protesters are demanding civil rule
In the cities of Khartoum, Omdurman, Port Sudan, Al-obeid, Madani, and Kassala, Sudanese men and women cried revolutionary flags, while waving their flags.
After months of protesting against Omar al-Bashir's 30-years tyrannical rule, the people of Sudan are indeed still protesting across the country: they are demanding civil rule, or "civil power", as they cried during the demonstrations. When al-Bashir resigned on April 11, it is indeed the Transitional Military Council that took over. Since then, Sudan has been witnessing a constant state of unrest: More than 100 people have lost their lives following a deadly crackdown on pro-democracy protesters that took place on June 3. Hundreds of others have been injured while thousands have been displaced.
"No one has given a mandate to the Military Council, everyone is against the council," shouted a demonstrator.
Prior to the demonstrations, the Rapid Support Forces (RSF) paramilitaries were deployed across Khartoum in machine gun vans. It is important to note that the RSFs were accused by demonstrators, NGOs and activists of being responsible for the violence that has erupted.
A few hours before Sunday's demonstrations, the European Union declared that it was "the duty of the MIlitary Council to ensure the safety of all and to refrain from any use of violence against demonstrators," while Amnesty International announced that "the military council must not allow the country to slide towards more repression."
Although intensive security measures have been taken, ten demonstrators have reportedly lost their lives during yesterday's rallies.
Selassie Alitash
is a journalist and a researcher that has recently joined Afrika News' writers team. Born in Ethiopia, she pursued her studies in one of the most prestigious schools of journalism in England, LSJ. Very active on the civil society, she assisted the organization of several workshops that explores the human rights and political situation in Ethiopia. Selassie has covered a number of events in her homeland. Inspired by arts, she offers another vision through her articles. She is a member of an African writer collective that helps raising the voice of Africa in the independent Media.
Elephant poaching might be declining in Africa according a new study
June 6, 2017 , By Moez Bhar
South Africa: ongoing Gupta leaks Scandal
South Africa is currently going through a critical time. A no-confidence vote is being planned regarding Jacob Zuma since he is implicated in a series of corruption scandals. Meanwhile, more scandals and leaks are emerging including the Gupta leaks. Police Units investigate Gupta leaks The South African elite police unit started an inquiry on June […]
April 4, 2016 , By Ynug Anabel
Is Burundi finally accepting U.N. police on its soil?
After months of negotiations and ups and downs, Burundi has finally accepted the solution suggested by United Nations security council: Burundian Foreign Affairs Minister Alain Nyamitwe has recently announced that his country is "fine" with U.N. Police deployment. The U.N. security council request came to ease 12 months of political violence that has erupted after President Pierre […]
January 25, 2019 , By Nassoumi Nyang
Ethiopia acquits more than 13,000 political prisoners
In the last six months, more than 13,000 Ethiopians who were previously convicted or charged with terrorism and treason were acquitted, according to the state media. Another reform from Prime Minister Abiy Ahmed Back in July, the Ethiopian parliament passed a law allowing the people who were charged with "treason crime against the constitutional order […]


When members schedule a mission, they can watch the live feed from the telescope online and capture images of what the telescope sees, Paolucci said. M27 by Slooh Space Camera Credit: A look at where near-Earth asteroid LZ1 will appear in the sky on the evening of June 14, In , the Slooh. It won't be that big or bright again until You can see it low in Please improve this by adding secondary or tertiary sources.
Please discuss this slooh space camera on the article's talk page. If skies are clear, individuals can view the conjunction by looking at the Moon and finding the brightest "star" in the sky next to the Moon, which will be Jupiter. SinceSlooh community members have operated the observatory's robotic telescopes for 4, consecutive nights observations are weather permittingcollecting over 5 million images of unique objects in the skyaccording to Slooh.
Comet Garradd by Slooh Slioh Camera. It was not the first robotic telescope, but it was the first that offered "live" viewing through a telescope via the web.
The Lagoon Nebula also known as Messier 8 or M8 and as NGC was captured by a Slooh Space member, an online night sky observing service that slloh users to observe the sky using telescopes around the world. Slooh Space Camera M27 was captured by an amateur astronomer, Marc Dubner, using the Slooh Space Camera, an online night sky observing service that slooh space camera users to observe the sky using telescopes around the world.
A screenshot of the skywatching website Slooh, which broadcast the June 15, total slooh space camera eclipse live via the Internet for free in partnership with the Internet company Google. Mars by Slooh Space Camera. Previously, her work sloho been published in Nature World News.
Articles lacking reliable s;ace from October All articles lacking reliable references Wikipedia introduction cleanup from October All pages needing cleanup Articles covered by WikiProject Wikify from October All articles covered by WikiProject Wikify Articles with slooy maintenance issues Articles containing potentially dated statements from April All articles containing potentially dated statements.
Read more Click here to reset your password. China's caemra space program achieved a lunar milestone on Thursday: Views Read Edit View history. Slooh Space Camera This coronal mass ejection was spaxe by an amateur astronomer using the Slooh Space Camera, an online night sky observing service that allows users to sloh the sky using telescopes around slooh space camera world. This image of the Running Man nebula was captured by an amateur astronomer, Nick Evetts, using the Slooh Space Camera, an online night sky observing service that allows users to observe the sky using telescopes around the world.
Hubble's Variable Nebula by Slooh Cam. M27 by Slooh Space Camera. A still image of what the aurora show will look like through the Slooh Space Camera during the live webcast. Slooh Space Camera Supernova SN fe in M in Ursa Major was captured by an amateur astronomer, Samuel Dupree, using the Slooh Space Camera, an online night sky observing slooh space camera that allows users to observe the sky using telescopes around the world.
This photo of the Running Man nebula, or NGCwas taken by an amateur astronomer, Dave Larkin, using the Slooh Space Camera, an online night sky observing service that allows users to observe the sky using telescopes around the world.
T'was the Night after Christmas and all through the house, not a creature was stirring This photo of Jupiter taken by a Slooh Space Camera telescope in the Canary Islands, shows the face of Jupiter and location of its moons 19 hours after a bright impact flash slooh space camera spotted by amateur astronomers on Sept.
Slooh Space Camera M8 was captured by an amateur astronomer, Dave Lrkn, using the Slooh Space Camera, an online night sky observing service that allows users to observe the sky using telescopes around the world. One dome is optimized for planetary views e.
Crab Nebula by Slooh Space Camera. The Minor Planet Center. Unlike Google Sky which features images from the Hubble Space TelescopeSlooh can take new images of the sky canera its telescopes.
Jupiter will pass million miles from Earth late Monday, its closest approach since Slooh Space Camera Slooh space camera photo of the Running Man nebula, or NGCwas taken by an amateur astronomer, Dave Larkin, using the Slooh Space Camera, an online night sky observing service that allows users to observe the sky using telescopes around the world.
Slooh Space Camera Jupiter and four moons were captured by amateur astronomer Nirmal Paul using the Slooh Space Camera, an online night sky observing service that allows users to observe the sky using telescopes around the world.
M27 by Slooh Space Camera Credit: They all get to watch, take photos and interact while the telescope is moving throughout the night. This view from the Slooh Space Camera shows the amazing start of the transit of Venus across the sun upper left as it begins slooh space camera cross the solar disk on June 5, Pleiades by Slooh's T1 Telescope. Slooh space camera to track near-earth asteroid Apophis as it passes by Earth January 8, Phys.


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New devices could mean safer skies
By Daniel B. Wood Staff writer of The Christian Science Monitor
Sunday's collision of an Aeromexico airliner and a small plane has spotlighted longstanding attempts to develop in-flight electronic technology that would help warn pilots of the approach of other aircraft they might not see from their cockpits. The systems, which work independently of ground-based systems, warn pilots both audibly and visibly of collision danger and recommend escape maneuvers.
The number of reported near-collisions in the United States was 777 in 1985, up 188 over the previous year. The rise is partly attributed to improved FAA procedures for collecting such reports.
The accident has brought renewed charges that technological, bureaucratic, and funding hurdles have slowed testing and adoption of collision-avoidance devices.
James Pope, a former Federal Aviation Administration ombudsman, and Patricia Goldman, vice-chairwoman of the National Transportation Safety Board, have long accused the FAA of dragging its feet on technology which they say could have been in use for at least 10 years.
A system developed by Honeywell Corporation and known as ``ACAS'' (Airborne Collision Avoidance System) was given a favorable rating by the FAA after extensive tests from 1972 to 1976.
But according to FAA spokesman John Leyden, such systems were prohibitively expensive ($50,000 to $100,000) for general aviators. Since they would be useless unless every aircraft carried one, Mr. Leyden says, the FAA decided to look for alternatives.
Another system, known as TCAS (Traffic Alert and Collision Avoidance System) and manufactured by Allied Bendix and Dalmo Victor, was developed as early as 1974. It was tested on Piedmont Airlines planes in 1981. TCAS was certified for use in the air, and prototypes were to be tested in commerical flights on Boeing 727 aircraft owned by Piedmont Airlines last June.
Contacted after the Los Angeles collision, a company spokesman said the testing was to begin ``certainly sometime this month'' but gave no reason for the delay.
The TCAS series of devices bases its warning on signals already emitted by a piece of standard airplane equipment known as a ``transponder,'' says Mr. Leyden. Transponders emit identifying signals that appear as blips on radar screens watched by airport traffic controllers.
Transponders have different capabilities, and different TCAS series models have different capabilities. And therein lies another controversy.
John Mazor, spokesman for the Air Line Pilots Association, has said airlines would rather use the current ``TCAS-2'' which audibly and visually warns pilots when a threatening aircraft is 40 seconds away. If the approach is within 25 seconds, a siren sounds and a voice warns to climb or descend.
But pilots want a more sophisticated model that gives not only vertical escape routes, but horizontal ones as well. They say the current model being tested is too limited and too dangerous under crowded conditions. The Air Transport Association, which represents most major airlines, says the airlines want a system that can accommodate more-sophisticated versions as they are devised.
All models, from the ACAS to the TCAS-1, TCAS-2, and TCAS-3, are subject to the possibility of computer error, according to Leyden, with devices giving false alarms in highly congested areas.
``It is a very complex problem of computer logic, especially when the air gets crowded,'' says Leyden. ``And that's exactly when they are needed most.'' The devices work well in controlled lab experiments or in out-of-the way airports, Leyden notes, adding, ``People don't understand how complex the problem is. We've been working on it for 20 years, and there is still no satisfactory system out there that works.''
While Piedmont Airlines gears up to test its TCAS-2 models this month, asking pilots and ground crews for feedback via questionnaires, the FAA is testing the TCAS3 -- with horizontal escape routes -- in Atlantic City and Los Angeles. The most advanced models, based on this test, will be delivered for more testing by next February.
If they prove effective, the $75,000-to-$100,000 devices could become common features in commercial airline cockpits by the end of the decade, says Joe Fee, manager of the TCAS project at the FAA.
An FAA official said the agency's budget for testing and running of collision-avoidance systems was $10 million for the current fiscal year and will go down to $7.3 million in fiscal 1987. The amount budgeted up to now, he said, has been $60 million to $70 million.
Malaysia Airlines Flight MH370: Are planes vulnerable to cyber-attack?
Malaysia Airlines Flight 370: Timing points to meticulous planning, say pilots
Tablets at takeoff: FAA eases rules on devices, but please, hold the calls.


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The Nature and Constitutionality of Stalking Laws
Robert A. Guy, Jr.
In 1989, an obsessed fan shot and killed actress Rebecca Schaeffer at the front gate of her Los Angeles apartment.' Soon thereafter, in unrelated incidents, five Orange County women were slain at the hands of their intimate partners. All of the killings shared two common attributes: the killers had stalked their victims incessantly, and the justice system had been unable to intervene.
Suddenly conscious of the inadequacy of current law, the California legislature responded in 1990 by creating the nation's first stalking law." The statute criminalizes the repeated harassment or following of an- other person in conjunction with a threat. California is enforcing the law aggressively.'
Thirty states have followed California's move and enacted stalking laws.' The brutal killing of at least one woman in each state usually has prompted the passage of these laws. Many of the statutes are identical to the California law, but a few differ substantially in both scope and language. Some target repeated harassment;" others target only literal stalking, such as following and surveillance." Some require a threat," others only conduct.' Further differences abound.
No stalking statute has faced a constitutional challenge at the appellate level.' Yet, since their inception, the statutes have been the source of much controversy. Civil libertarians claim that stalking laws contravene the Constitution by making criminal and innocent behavior indistinguishable and by infringing on First Amendment rights. Others criticize the statutes as a politically safe shortcut that legislators have adopted to address a pervasive crisis too complex for a single law. In October 1992, Congress recognized the need for comprehensive stalking legislation that will pass constitutional muster, and it enacted a law charging the National Institute of Justice with the duty of drafting a model stalking law.' The Institute has one year from the law's enactment to research and develop the model law, which will serve as a guide for states wishing to enact stalking legislation or to solidify their current stalking laws.' Meanwhile, states continue to enact and enforce their own stalking laws.
This Note will analyze the language and scope of stalking laws and various aspects of their constitutionality. Part II discusses the nature of stalking behavior and the past failures of the legal system to address it adequately. Part III analyzes stalking laws that various states have enacted, focusing on the California, Florida, and Connecticut statutes as representative examples. In Part IV, this Note addresses potential constitutional challenges to stalking statutes. First, it analyzes whether the statutes violate substantive due process by creating criminal liability before the stalker has demonstrated culpability. It concludes that the statutes are constitutional under this aspect of substantive due process. Second, it addresses the constitutionality of stalking laws under the void for vagueness doctrine, concluding that some stalking statutes are unconstitutionally vague while others survive vagueness scrutiny. Part V proposes a model stalking statute that circumvents many of the vagueness problems present in current stalking laws. This Note concludes in Part VI with a call for states to enact comprehensive, effective stalking laws that meet constitutional requirements.
Robert A. Guy, Jr., The Nature and Constitutionality of Stalking Laws, 46 Vanderbilt Law Review 991 (1993)
Criminal Law Commons


Hover to see how Factors connect to Non-symbolic Number. Then click connected Factors to explore strategies related to multiple Factors.
We are all born with an intuitive sense of quantity. This Non-symbolic Number understanding helps students explore the concept of number by estimating, comparing, and combining sets of visuals, such as dots. Typically, students understand Non-symbolic Number before they develop an understanding of what number words and numbers themselves (Symbolic Number) represent.


How is this "warp" effect on the preview images on this site made?
Here, on this site, are often preview images shown beside the questions which are warped and with an background shadow.
How is this effect achieved? PHP?
To generate the initial screenshot of the page we use the same technology we built for Litmus. It renders the URL in a browser and captures a screenshot. This takes just a few seconds.


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There Are Several Ways to Earn Money by Playing Video Games
Megan Nel
Tutor/Teacher | Sports Lover | Cooking at No Deposit Bonus
The fact that you've selected our No Deposit Bonus option is very much appreciated. In this personal blog of mine, I share stories about my time spent gambling and exploring the web. My contributions also include suggestions, endorsements, and anecdotes.
Latest posts by Megan Nel (see all)
Another State in the United States of America is Considering Legalizing Sports Betting in 2020 - September 12, 2022
Parents have traditionally considered their children's involvement in video gaming to be a waste of time. On the other side, in the 2010s, gaming steadily evolved into a money-making company that can be extremely beneficial for individuals if they play their cards well. Furthermore, there are several additional methods to make money by playing video games, and the number of chances is always expanding. A study of many of the options that are currently receiving the most attention will now follow.
Trading Digital Goods
The concept of in-game item trading was not pioneered by massively multiplayer online role-playing games, sometimes known as MMORPGs; rather, these games are usually attributed with popularizing the practice. RuneScape is the best example of a massively multiplayer online role-playing game (MMORPG) that has attracted a large number of players due to its item classes. Players can mine for the gold in this game, which leads to the accumulation of experience points.
Players who want to benefit from their time spent playing RuneScape may do so by selling their gold deposits on websites like RPGStash.com. Brandon Fisher, commonly known as Moltrinex, is the guy who has made the most money from his RuneScape adventures, selling his acquired RuneScape gold for a total of $1.57 million. Fisher goes under the alias Moltrinex on the internet.
Online Gameplay
Twitch's forefather is television. It was founded in 2007, and it enabled anyone to broadcast live. Regrettably, in its early years, it was largely utilized by unscrupulous individuals who illegally broadcast athletic events over it. The gaming section was renamed Twitch in 2011, and the introduction of that platform heralded the start of a gaming industry revolution.
According to Dot Esports, some of today's most successful streamers earn nearly $1,000 per minute of content produced on their channels. New streamers should anticipate making half that amount in their first year of operation. xQc is a well-known streamer that attracts anywhere from 30,000 to 50,000 viewers each day on average. According to reports, he has made about $9 million in revenue from his Twitch activities, which include sponsorships and subscriptions.
People who play chance games online have discovered that they may make a lot of money by broadcasting their gambling sessions publicly. Rosenstein is a prime example. Gamblers are also lured to these because top-paying casinos are beginning to integrate bonus rounds on slot machines that are fashioned like video games and provide massive prizes if the player successfully completes a certain aim. For further information on the issue, look into the different ways you may make money playing video games.
Participating in Various Online Competitions
It is not essential to compete in organized events on a desktop computer or console in order to partake in online competitions. No. That will be included in the subheading that follows this one in the list. Mobile gaming apps like 21 Blitz and Pool Payday, which are available for both Android and iOS users, feature multiplayer tournaments with cash rewards that can be redeemed using a variety of payment methods, including PayPal and ApplePay. These are specialized pieces of software that offer an easy gameplay experience as well as small rewards, frequently in the $30 level, to the champions of various tournaments.
Participating in Competitive Gaming Leagues and Other Live Events
According to the technology consultancy firm Activate, more than 250 million people worldwide will watch eSports contests in 2021. According to the most recent statistics, the average audience for eSports competitions now consistently outnumbers the viewership figures generated by traditional professional leagues such as the NBA and MLB. The video games Counter-Strike: Global Offensive, League of Legends, Dota 2, and FIFA are the most often played in the highest level of eSports competitions. However, the World Championship and International are the competitions that garner the most attention from viewers.
The most money ever won in the history of eSports was $7.2 million by Johan "N0tail" Sunstein, who won the majority of his money playing Dota 2. Full-time gamers typically earn between $4,000 and $5,000 each month. Sponsorships are an important part of this sector and the financial success of professional gamers.
Make videos of the entire procedure
Walkthrough videos are instructional videos that demonstrate how to play a specific game in a step-by-step manner. On the other hand, there are some individuals who enjoy watching movies solely for the purpose of obtaining the entertainment value that they offer and have no interest in the educational content that movies offer.
Gamblers have the opportunity to generate income by publishing online videos that instruct others on how to successfully play a variety of games. Although it might appear to be an unusual method to obtain funds, doing so in this way is entirely possible. One of the most subscribed-to channels on YouTube is called FightinCowboy, and it has more than a million followers. The majority of the content that can be found on this channel is comprised of walkthroughs, and several of the videos have received more than one million views each. The proprietor of YouTube makes more than one hundred thousand dollars annually from advertisements on YouTube thanks to a number of different analysis technologies.
Play Analysis
The process of quality control and inspection is an indispensable part of the introduction of any new product. This is especially true in the hypercritical society that we live in today, where the number of possibilities in any given subject is extremely large and almost everyone is hypercritical. T
The gaming industry is subject to a significant amount of pressure from customers. The reason for this is that historically speaking, video games have a long tradition of being made available to the general public while still containing bugs. As a direct consequence of this, companies operating in this sector place a premium on meeting delivery deadlines without compromising the quality of their products. They are able to achieve this goal by employing people to provide feedback on video games.
Professionals in the gaming quality assurance industry can make up to $15 per hour by working for platforms such as iGameLab, VMC, UserTesting, Beta Bound, and Beta Family.
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Everyone loves to go Christmas shopping and buy nice presents for the people they love. However, nobody likes the financial problems that come from spending too much during the holidays. Just because it is the holiday season does not mean you have to shop last minute and buy expensive gifts. Buying presents without breaking the bank is possible! Here are a few tips on how to shop smart during the holiday season.
The first thing you will need to do is start planning out the holiday budget. Make a list of everyone you will be shopping for this year. Once you have the list made, figure out how much you can afford to spend on everyone and write down that amount next to each name. You can also make a note of all the affordable gift ideas for each person. This way you will know what to buy and how much to spend.
Open up a holiday savings account as soon as you can and put a little money from each paycheck into the account. You can do this all year round or at the end of the summer, this all depends on how much you are going to need to put on the side. Are you having trouble opening a savings account for any reason? Do it the old fashion way and place the holiday money into a jar or piggy bank!
Do you see a gift on sale you want to pick up months before the holiday season even begins? Don't wait until November, get it now! This way when the holiday season begins, you will have a head start on your budgeting and hitting the sales. Keep track of how much money you spend and what you buy. Keep a look out for sales and deals all year round, because you never know what you will find!
You may not like to deal with the crowds and lines of Christmas sales, but this is something you should do anyway! There are many retailers who will have great sales and door busters throughout the holiday season. Getting up early and dealing with the crowds will be worth it when you find an eighty dollar gift on sale for only twenty dollars!
Just because it's December 26th does not mean you have to end your holiday shopping. Plenty of stores will be having after Christmas sales. Find something you want to give to someone next Christmas? Get it now while it is on sale and just store it until next year! Be sure to make a list of everything you buy, how much you spend and who you shop for. This way there will not be any confusion when the next holiday season begins!
If you keep these tips in mind and shop smart, then you can buy the gifts you want for your loved ones without going broke!
This guest post was written by Jack Sibilia who has been working the finance industry for over 5 years. He recommends going online to Kanetix.ca to compare quotes from multiple insurers to get the cheapest insurance rate.


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When I talk about stock images, one of the questions I'm often asked is "why not just use Creative Commons images?" After all, it's a very attractive concept. There are a lot of great photographers out there taking a lot of great photographs, and hey, with the right Creative Commons license, they're free! Free! Who doesn't want free?
Well, I'm all for free. I love free. Very few people on the planet, in fact, are cheaper than I am. I am so cheap that even when I have money to spend, I will check Freecycle, Craigslist, second hand hand shops and thrift stores before I buy new. But I will not use Creative Commons for images.
The reason I do not use Creative Commons images is that the licensing is broken - completely, totally, inexorably broken - in all of its implementations around images.
Flickr, for example, provides members with a way to select a default Creative Commons license for all photos they upload. The license photographers choose most often to allow their images to be used by other people is, by far, the Creative Commons Attribution, Non-Commercial, Share-Alike license.
I understand that I cannot, for example, sell prints of someone else's Creative Commons image, which is fair enough. And I understand that I can't use it on MegaConglomorate Inc's home page, wrap it around their product packaging, or print it in their corporate brochure. All of that is part and parcel of common understanding for the term "commercial."
But what if I want to use an image on MegaConglomorate Inc's blog in a post? They are commercial, but the blog is not. Is that commercial use?
Or what if I want to put these images on my personal blog, and I run ads there - either from individual companies or through the ubiquitous Google Ad Sense. After all, I am making money, even if it's pennies a day. Is that commercial?
My husband says no. I say yes. Nobody knows.
Almost everyone who uses Creative Commons puts this requirement in their license. Virtually nobody, however, actually specifies the manner in which they would like to be attributed. Believe me, I have looked. I have tracked down photographer's home pages via their flickr streams on many occasions, and on exactly none of them have I ever found a Creative Commons guideline or attribution statement. Ever.
Which rather begs the question: if no manner of attribution is specified, is attribution still required? And if it is still required, what constitutes sufficient attribution when none is defined? A flickr name? A real name? A link? A URL?
Nobody knows. Creative Commons itself doesn't tell me, although they are helpful enough to let me know that in addition to crediting (or not) the original creator, I also have to provide the URL of the Creative Commons license the image is licensed under.
You are free to to Remix — to adapt the work.
Sometimes the freedom to create what's call a derivative work is included in the license, and sometimes it isn't. When it isn't, it's a pain because guess what? Derivative work isn't defined. Is cropping "adaptive?" Can I put text over it? Can I turn a colour image into a black and white image, or colour in a single rose in a black and white image?
Far more worrying, however, is when the rights to create a derivative work are granted. Under the Creative Commons license agreement, the "moral rights" of the original creator are retained. This means that if the creator doesn't like the way in which I have "re-mixed" his or her work, they can demand that I remove it. And if the creator considers my derivation to be derogatory, he or she can take legal action against me.
These are just some of the numerous Creative Commons headaches I really do not want.
I choose, instead, to pay for licensed images from stock image sites. While purchasing stock images isn't without potential issues, particularly around copyright, I've decided that the relationship is a lot cleaner and the annoyances are a lot fewer.
I do not have to credit the creator, nor do I have to send traffic from my site to any other in order to use an image. I can do anything I like to the images I purchase, including using them in ways the photographer may find patently offensive. I can use them for commercial, non-commercial, and questionably commercial projects, sites and clients without worrying that I'm breaking an agreement. And if I want to put them on a product that will be sold, there's a system in place that allows me to do that clearly and immediately with zero confusion.
Is it more expensive than free? Sure. But I get what I pay for.
Can I use Creative Commons material in stock work?
Bad Behavior has blocked 63692 access attempts in the last 7 days.


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Sen. Karpisek Rips Ad Hoc Committee Opposition to Shared Parenting Bill
October 3, 2013 by Robert Franklin, Esq.
Nebraska State Bar Association President Marsha Fangmeyer continues to come under withering fire for her frankly inconsistent and apparently false statements about LB22, the bill that would require judges to maximize parenting time for each parent in a child custody matter or explain why he/she didn't do so. Fangmeyer's been playing fast and loose with the facts about LB22 all year. Her latest barrage of disinformation came in statements here by her and other opponents of children's rights to real relationships with their fathers (Star Herald, 9/25/13).
I roasted Fangmeyer and the Star Herald reporting on LB22 here and emailed the paper's editor, Steve Frederick about my concerns. The article, written by Maunette Loeks, amounts to little more than a tissue of lies, half-truths and exceptionally poor reporting. Loeks swallowed the NSBA's misrepresentations about LB22 hook line and sinker. She never once bothered to pick up the telephone and call, for example, Nebraska Senator Russ Karpisek, who's a sponsor of the bill or Sen. Galen Hadley, who's its author. Neither did she call Dr. Les Veskrna who's as knowledgeable about the bill as anyone. Any of those gentlemen could have set her straight on the facts of LB22 which are utterly at odds with the claims of Marsha Fangmeyer, et al. Failing that, Loeks could have simply gone to the website for the Nebraska Legislature, clicked her mouse a couple of times and read the bill for herself. Such basic acts of journalism were beyond her, with the predictable result that her article served as a mouthpiece for opponents of LB22.
That might not be so bad if Fangmeyer, Snyder and Mueller had told the truth about the bill, but they didn't. The NSBA's spin on LB22 is that it either requires or "begins with" a presumption of 50/50 parenting time for mothers and fathers. It does no such thing. Truly, take five minutes out of your day and read the bill. There is not one word that in any way suggests such a thing. That leads to the unavoidable conclusion that either (a) Fangmeyer, et al haven't read the bill or (b) they're openly lying about it. Either is bad, but the latter is an outrageous attempt to sway public opinion, not on the basis of principled opposition, but on misrepresentations about the clear terms of the bill. As I've said before, if you have to resort to lies, your position isn't very strong.
Having become a mouthpiece for Marsha Fangmeyer's unprincipled opposition to LB22, it's come to my attention that the Star Herald plans a follow-up article that will more accurately reflect the facts about the bill.
But there's more; with Marsha Fangmeyer, there's always more. LB22 was originally filed earlier this year and assigned to the Judiciary Committee. Of course family lawyers in Nebraska, as in other states, see the prospect of fathers and children having real relationships post-divorce to be the dawn of the Apocalypse, so they swung into action opposing the bill. But, as I wrote about here, they didn't stop with simple opposition to the bill; they took a more comprehensive approach. They appointed an ad hoc committee whose purpose it is to study current child custody law and, of course LB22.
The transparent point of the ad hoc committee is to give opponents of shared parenting the ability to say "Look, we're not the ones opposed to LB22. The committee examined the bill and rejected it." It's classic buck-passing while providing Fangmeyer a fig leaf of respectability.
All that of course is why Fangmeyer has been touting the committee to the skies. She's instructed committee members to "keep an open mind and listen" about all aspects of shared parenting.
Nonsense. That's for public consumption only. What's going on behind the scenes (or sometimes right out in public) is that the ad hoc committee has no intention of keeping an open mind. After all, as it was originally configured, Fangmeyer's fig leaf committee had precisely zero members who supported shared parenting out of a total membership of 34. Someone apparently pointed out to them that that made the actual purpose of the committee all too clear, i.e. to rubberstamp bar opposition to LB22.
So a grand total of two proponents of shared parenting were added. Talk about a fig leaf.
As if that weren't enough, one of the members of the committee is divorce lawyer Paul Snyder who was quoted last week by the Star Herald thus:
"This new proposed legislation, if enacted, I think, is going to take us back 30 or 40 years. A presumption that both parents should have 50-50 (custody) is a presumption that they are both fit and proper, that they both have been actively involved and those presumptions are hardly ever true. Hardly ever true," Snyder said.
He said that the presumption that parents should have shared custody "starts out in la-la land."
Now, I won't go into all the many ways in which those statements are just so much claptrap. Again, the 50-50 presumption is simply false. No such presumption appears in LB22 or anywhere else in Nebraska family law, so Snyder's assertion is utterly at odds with the truth, a fact I suspect he knows.
But more important is the fact that Snyder's one of those ad hoc committee members who's supposed to "keep an open mind and listen." He's doing anything but, which once again reveals the true purpose behind the committee's formation in the first place.
Which brings us to the fact that LB 22 proponent and co-sponsor, Senator Russ Karpisek is none too pleased about the NSBA's, Fangmeyer's and the committee's blatant misrepresentations about the bill or the committee's role in squelching it. As this article reveals, he wrote a letter to the Chairman of the Judiciary Committee, Senator Brad Ashford, in which he excoriates the ad hoc committee for being exactly what I said it is – a Trojan horse for the bar's opposition to shared parenting (Lincoln Journal Star, 10/2/13). Here's some of what Sen. Karpisek said:
I cannot tell you how disappointed and upset I was when I saw a recent article from the Scottsbluff Star Herald newspaper with the headline: "NSBA opposing Parenting Act changes." In the article, a Scottsbluff attorney who is a member of the NSBA's House of Delegates and is on the Parenting Ad Hoc Committee appears to have already made up his mind by saying that the bill's assumption that parents should have shared custody "starts out in la-la land." I guess he didn't get the memo from President Fangmeyer directing him to "keep an open mind and listen."
The main thing that I find offensive in this article is that "officials" with the NSBA allege that the motivation behind the bill has to do with reducing child support and not focusing on the best interests of the child. I would like to know which NSBA official said that because it shows a complete lack of understanding regarding the issues that LB 22 was intended to address. In fact, I would argue that in the current system, some parents already fight for custody because of the child support that follows. I think you would see more amicable custody arrangements if the child support could somehow be uncoupled from custodial rights. But until that happens, we are left trying to make the current system fairer. As for the best interests of the child, I agree that if a parent is deemed by the court to be unfit, that should negatively impact that parent's custodial rights. But I also believe that when possible, having both parents involved in a child's life is in that child's best interest, and that should be where the discussion of custodial rights begins…
However, I do not have the same faith in the NSBA's Parenting Ad Hoc Committee. Based on the comments by unnamed NSBA "officials," it would appear that the Parenting Ad Hoc Committee is simply a vehicle to be used by the NSBA to legitimize its preconceived conclusions – in other words, to simply "prove" what it already believes.
At this point, it's hard for the NSBA to blow it any worse. They've lied repeatedly about LB22; they've been caught stacking the ad hoc committee with anti-shared parenting stalwarts; they've offended elected representatives who see the committee for exactly what it is; and the committee is scarred with numerous ethical and legal violations like conflicts of interest and failure to hold open meetings. If they'd set out to pass LB22, they could hardly have done better.
But there's still more. On September 30th, there was a hearing before the Nebraska Supreme Court to de-integrate the state bar. The bar now is an integrated one which means membership, and the dues that go with it, are mandatory. NSBA lobbying against LB22 has gotten so blatant that a proceeding was begun to de-integrate the bar, i.e. make membership voluntary. The experience of other de-integrated bars is that de-integration reduces bar income by about 60%.
And then or course there's the pesky matter of that lawsuit against the NSBA based on its lobbying activities that seem to violate members First Amendment rights.
How many times can Marsha Fangmeyer shoot herself and the bar in the foot?
The National Parents Organization is a Shared Parenting Organization
The National Parents Organization is a non-profit that educates the public, families, educators, and legislators about the importance of shared parenting and how it can reduce conflict in children, parents, and extended families. Want to get involved? Here's how:
Together, we can drive home the family, child development, social and national benefits of shared parenting. Thank you for your activism.


Palo Santo, sometimes called 'Holy Wood', is a natural wood known for centuries by the Incas and other indigenous cultures as a spiritual remedy. Burnt much like a sage smudge, its used to purify and cleanse misfortune and calamity.
Sold as individual sticks. These sticks are 80mm - 100mm long.


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Q: Scaling the time axis of an interpolated function (as in a solution from NDSolve) I'm wondering how I can change the units of the x (time) axis when plotting a solution from NDSolve.  I have obtained three solutions to a system of differential equations, all of which exist over the time scale [0 s, 1 ms].  However, I'm really only interested in the range [0 s, 5 ns].
To avoid having (x 10^-9) appended to every value along the x-axis when I plot these three functions (since the equations are solved in terms of seconds, not nanoseconds), I'd like to somehow scale the time axis to read 0, 1, 2, 3 ... (ns).  It's fairly easy when working with symbolically specified functions- just multiply t by some constant wherever it appears in the function.  However, this isn't possible here, since the solutions to the system are interpolated functions returned by NDSolve.  Is there any efficient way to achieve this?

A: E.G. (f is an interpolation function):
Plot[f[x], {x, 0, 30}, PlotRange -> All,  AxesLabel -> {"Seconds", "Value"}]
Plot[f[x/1000], {x, 0, 2000}, AxesLabel -> {"Milliseconds", "Value"}]