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Tulane University is in a unique position to influence the judiciary. First, the university and its affiliates provides memberships on its advisory boards to judges, politicians, and other distinguished citizens and their relatives. Second, its law school awards adjunct professorships and paid teaching trips to judges and other prominent jurists. Third, with the aid of state legislators, Tulane presents the families of judges and politicians with scholarships to the university, thereby creating indebtedness. Finally, Tulane is alma mater to many attorneys and judges who practice in the greater New Orleans Area. These relationships, shown schematically in the following figure, strengthen the bonds of loyalty to the university and convey to it numerous benefits. Tulane's scholarship scheme is described elsewhere.
Tulane's Methods of Influencing the Judiciary
Figures Based on 1996 Government DataBernofsky showed in a pair of letters published in Gambit Weekly that all four judges involved in the case of Schwarz v. Tulane were associated with the defendant university by one or more of the above links. Many judges assigned to Tulane cases have had, and continue to maintain, close ties to the university. The resulting judicial partisanship has contributed to Tulane's success in defending itself against lawsuits from its own employees. Until now, this unfair advantage has not been seriously challenged. In all, Bernofsky filed four lawsuits against Tulane in U.S. District Court for the Eastern District of Louisiana. These encompassed, as major causes of action, (i) race and age discrimination, (ii) non-payment of disability, (iii) retaliation, and (iv) defamation and slander [1]. The presiding judge in all cases was The Honorable Ginger Berrigan assisted, in most instances, by magistrate judges Lance M. Africk and Joseph C. Wilkinson, Jr. In the discussion that follows, Bernofsky outlines the relationship between these judges and Tulane. The facts leave little doubt that their judgments were compromised by partisanship. Reference
- Civil Actions No. 95-358, 98-1577, 98-1792, and 98-2102, respectively, in U.S. District Court for the Eastern District of Louisiana.
Judge Ginger Berrigan Conflict of Interest
Federal District Court Judge Ginger Berrigan is Adjunct Associate Professor of Law at Tulane University and taught the course, Trial Advocacy, during the 1995-96 academic year [1]. Since then, Judge Berrigan has maintained a professional association with Tulane through her continued participation in the Law School's Judicial Externship Program [2] and as a substitute instructor for the course, Federal Practice & Procedure: Trials [3], taught in 1998 by then 76-year-old Federal District Court Judge and Adjunct Professor Charles Schwartz, Jr. [4]. In 2000, Judge Berrigan received $5,500 from Tulane to teach a three-week seminar course in Greece [5]. In 1990, Judge Berrigan, then an attorney, was appointed to the Board of Directors of Tulane University's Amistad Research Center, a position she occupied through 1997 [6]. Judge Berrigan's indebtedness to Tulane appears to stem from her position at the Research Center, where she met fellow board member and its later president, Dr. Andrea Green Jefferson, whose husband, Congressman William J. Jefferson, helped nominate her to the Judiciary Committee for a federal judgeship in 1993 [7]. On April 14, 1994, Judge Berrigan's oath was administered by the Honorable Morey Sear, Chief Judge, U.S. District Court for the Eastern District of Louisiana, and Member, Board of Directors, Tulane Medical Center [8]. The following year, Tulane named Judge Berrigan to an adjunct professorship [9]. The Amistad Research Center is a Tulane affiliate [10] that occupies a wing of Tilton Memorial Hall on the campus of Tulane University [11]. Tulane not only furnishes the Research Center with a rent-free physical site, it initially contributed $12,000 in relocation costs and funded $200,000 in improvements [12]. Tulane also provides a budget of about $63,200 in 1986 dollars, adjusted annually for inflation and used for unrestricted operating expenses [12]. Two members of Amistad's Board of Directors are appointed by Tulane [13], and Amistad's Executive Director, Comptroller, and other key administrative personnel [14] are listed in Tulane's Faculty and Staff Directory [15]. The effort of Tulane's attorneys to characterize the Amistad Research Center as a wholly independent entity is a transparent attempt to minimize its contribution to Judge Berrigan's association with Tulane University. Congressman Jefferson is not confused about Amistad's Tulane affiliation. In 2001, his $1,200 contribution to the research center was sent directly to a Tulane Medical School office [16]. Finally, Judge Berrigan's colleague and fellow U.S. District Court Judge, Marcel Livaudais, Jr., is the father of the Tulane attorney who has been active in all of the above mentioned cases, Julie D. Livaudais, Counsel Of Record. Questionable Actions District Court Judge Berrigan may have abused her judicial discretion by: i) ignoring the fact that Bernofsky had received an Air Force grant two months prior to his termination, when having a grant was a major condition of employment, ii) accepting the allegedly perjured testimony of a former chairman in the face of contradictory evidence concerning the promise of tenure, iii) ruling that appointment letters signed by a Dean do not constitute a contract, iv) acceding to arguments offered by Tulane that were in sharp dispute with sworn testimony or documentary evidence, v) delaying trial for 14 months and then granting summary judgment for defendant after 9 months, thereby preventing an earlier appeal, and vi) failing to disclose her association with Tulane and then refusing to recuse herself. In Bernofsky's opinion, Judge Berrigan's preferential treatment of Tulane may have been influenced by her close ties to the defendant university. According to the Committee on Codes of Conduct of the Judicial Conference of the United States, a judge is permitted to engage in part-time teaching. However, " . . . the judge should not participate in any case in whch the school or its employees are parties." [17] Bernofsky was an employee at the time he filed his lawsuit on January 31, 1995, and his employment with Tulane did not end until April 21, 1995. Thus, from the outset, Judge Berrigan's acceptance of this case was in direct violation of the codes of judicial conduct established by the Administrative Office of the U.S. Courts. Moreover, judges are obligated to disclose all facts that might be grounds for disqualification. Under Canon 3 of the Code of Judicial Conduct, Judge Berrigan had a duty to disclose her association with Tulane before sitting in any case in which Tulane was a defendant. From January, 1995 onward, Judge Berrigan continuously violated this code in all of Bernofsky's lawsuits against Tulane where she presided and failed to make a disclosure. Inasmuch as Judge Berrigan recognized the requirement to disclose "any facts that might constitute a conflict" in her written response to the U.S. Senate during her judicial confirmation hearing, her deceptive conduct in these cases was clearly willful.
UNITED STATES SENATE QUESTIONNAIRE FOR JUDICIAL NOMINEESQuestion II (2): Explain how you will resolve any potential conflict of interest, including the procedure you will follow in determining these areas of concern.Ms. Berrigan:“I would fully disclose to all parties in the case of any facts that might constitute a conflict. I would refer the conflict issue to another judge if it cannot be resolved with parties.”January 27, 1994
From: Confirmation Hearings on Federal Appointments [18]Further evidence of Judge Berrigan's brazen disregard of recusal statutes and canons of judicial conduct is her insistence on presiding over Bernofsky's retaliation lawsuit while making preparations with Tulane colleagues and administrators to teach a Tulane course in Greece during the summer of 2000 [19]. Judge Berrigan's open relationship with the defendant has made any claim of impartiality untenable, and her actions support this view. On January 5, 2000, Judge Berrigan rescheduled Bernofsky's trial against Tulane University to May 15, 2000 despite the fact that the Pre-Trial Order had already been signed and a trial was to begin in two weeks. The delay provided Tulane a second opportunity to file a Motion for Summary Judgment, upon the receipt of which Judge Berrigan promptly ruled in Tulane's favor, thereby averting a trial on the merits. Motions for Judge Berrigan's Recusal Judge Berrigan's association with Tulane was the basis of Bernofsky's motion that she recuse herself from his current lawsuit against Tulane [20]. Judge Berrigan denied the motion [3]. The ruling was appealed [21], and the appellate court dismissed the appeal [22]. At this juncture, the attorneys representing Bernofsky withdrew [23], leading him to file pro-se complaints against the judge and to seek new counsel to continue the case.On Feb. 11, 1999, Bernofsky filed a "Complaint of Judicial Misconduct" against Judge Berrigan in the U.S. Court of Appeals for the 5th Circuit for her failure to disclose her association with the defendant university. This, too, was dismissed by the appellate court. On March 12, 1999, Bernofsky appealed the appellate court's dismissal order, but the order was affirmed. On June 14, 1999, Bernofsky filed a Petition for Writ of Mandamus to recuse Judge Berrigan. The Judge's response and Bernofsky's reply followed. In her response, Judge Berrigan did not dispute any of the allegations raised against her. On June 28, 1999, Tulane filed its response opposing Bernofsky's petition, and within days the appellate court ruled against Bernofsky's petition without opinion or explanation. On August 30, 1999, Bernofsky filed a new Petition for Writ of Mandamus in the United States Supreme Court to recuse Judge Berrigan. Tulane filed a response opposing the petition on September 28th, and on October 8, 1999, Bernofsky filed a Reply Brief refuting the misrepresentations made by Tulane in its Respondent's Brief in Opposition. On November 1, 1999, the Supreme Court declined to hear the petition for mandamus. In an effort to relieve litigant professors from this form of judicial abuse, Bernofsky has been urging members of the House and Senate Judiciary Committees to pass a law that would prevent partisan judges from violating the due process right of plaintiffs to an impartial tribunal, and he invites interested readers and agencies to assist in this process. On April 4, 2000, Bernofsky sent a letter to Judge Berrigan asking that she recuse herself from adjudicating his retaliation and defamation lawsuit against Tulane because she was teaching a course for Tulane in Greece that summer. Judge Berrigan subsequently acknowledged that she was paid by Tulane to teach that course, and Bernofsky's counsel filed a motion for her recusal and a new trial on this basis [24]. However, exposure of Judge Berrigan's blatant conflict of interest, which she neglected to disclose to Bernofsky or his counsel, did not keep her from ruling against Bernofsky's every cause of action and taxing him for Tulane's legal costs. On September 6, 2000, Judge Berrigan's rulings against Bernofsky were appealed to the U.S. Fifth Circuit Court of Appeals. Tulane filed its response on November 3, 2000, and on December 7, 2000, Bernofsky submitted his reply brief to the Appellate Court. Two of the three appellate judges who heard the appeal affirmed the judgment of the district court. However, Chief Judge Carolyn Dineen King dissented from the majority view and expressed the opinion that Judge Berrigan should have recused herself. Armed with Judge King's important dissent, Bernofsky attempted to obtain a rehearing with an en banc panel of Fifth Circuit judges. His petition was denied. On August 9, 2001, Bernofsky petitioned the U.S. Supreme Court for certiorari, and on October 19, 2001 replied to Tulane's brief opposing certiorari. On November 13, 2001, the justices denied certiorari. The Supreme Court's persistent refusal to hear Bernofsky's petitions gives credence to the proposition that the rule of politics supersedes the rule of law. References
- Tulane Law School Catalog, 1995-96, p. 104; "Administration & Faculty: 1995-96 Trial Advocacy Faculty," Tulane Law School [Online] Catalog.
- Tulane Law School Catalog, 1996-97, p. 107;
ibid., 1997-98, p. 103;
ibid., 1998-2000, p. 103.
- Minute Entry, Bernofsky v. Tulane, Civil Action No. 98-1792 c/w 98-2102, Docket No. 24, Nov. 23, 1998.
- Tulane Law School Catalog, 1998-2000,
p. 55 .
- Financial Disclosure Report for Calendar Year 2000, Judge Helen G. Berrigan.
- Almanac of the Federal Judiciary, 1995, 1996, & 1997, Vol. 1, 5th Circuit,
p. 3 .
- "Judicial nominee sailing along," The Times-Picayune, January 28, 1994,
p. A-9 .
- Amistad Reports, Vol. 8, No. 2, September, 1994.
- Tulane Law School Catalog, 1995-1996,
p. 104 .
- Gambit Weekly, July 21, 1998, p. 47;
Greater New Orleans White Pages, 1998-99, "Business,"p. 283 .
- The Amistad Log; 1990 Annual Report,
pp. 1-2 .
- The Amistad Log; 1990 Annual Report,
p. 22 .
- Defendant's Memorandum in Opposition to Plaintiff's Motion for Recusal, Civil Action No. 98-1792 c/w 98-2102, Docket No. 22, Nov. 9, 1998,
p. 4 .
- Amistad Research Center Home Page.
- Tulane [Online] X.500 Directory.
- "William J. Jefferson: 2002 Political Profile," http://www.opensecrets.org/politicans/, accessed May 8, 2004.
- Guide to Judiciary Policies and Procedures, Vol II (reissued 6/15/99), Chap. V, § 4.1(b) at
p. V-57 .
- Confirmation Hearings on Federal Appointments. Hearings Before the Committee on the Judiciary, United States Senate, One Hundred Third Congress, Second Session on Confirmations of Appointees to the Federal Judiciary, Part 2, Serial No. J-103-28, U.S. Government Printing Office, Washington, 1995,
p. 248 .
- "Ruling under fire as 'conflict of interest'; Ex-Tulane professor asks for review of suit dismissal," The Advocate, Baton Rouge, La., May 9, 2001,
p. 7-B .
- Motion for Recusal, Bernofsky v. Tulane, Civil Action No. 98-1792 c/w 98-2102, Docket No. 18, Oct. 15, 1998.
- Appeal, Bernofsky v. Tulane, Civil Action No. 98-1792 c/w 98-2102, Docket No. 26, Dec. 28, 1998.
- Bernofsky v. Tulane, Case No. 98-31417, U.S. Court of Appeals for the Fifth Circuit, dismissed Feb. 2, 1999, then hidden from public view.
- Motion to Withdraw as Counsel of Record with Incorporated Memorandum, Bernofsky v. Tulane, Civil Action No. 98-1792 c/w 98-2102, Docket No. 31, Feb. 8, 1999. Also, Minute Entry, Bernofsky v. Tulane, Civil Action No. 98-1792 c/w 98-2102, Docket No. 32, Feb. 8, 1999.
- Plaintiff's Motion and Incorporated Memorandum for Recusal and, In the Alternative, To Amend Judgment, and/or Motion for New Trial, Bernofsky v. Tulane, Civil Action No. 98-1792 c/w 98-2102, Docket No. 83, May 2, 2000.
Judge Joseph C. Wilkinson, Jr. Conflict of Interest
U.S. District Court Magistrate Judge Joseph C. Wilkinson, Jr. also has close links to Tulane and has frequently been involved in litigation involving Tulane as defendant. Cases include Ripoll v. Tulane, Izawa v. Tulane, Rubinstein v. Tulane, and Bernofsky v. Tulane [1]. Judge Wilkinson received his J.D. degree from Tulane and, from 1994 to the present, has been a part-time (adjunct) faculty member of Tulane's Law School, first as Assistant Professor (1994-96) and then as Associate Professor (1996-present) [2]. At Tulane, Judge Wilkinson teaches the course Federal Procedure & Practice: Trials in collaboration with Judge Charles Schwartz, Jr. and Chief Judge Morey L. Sear [3], another Tulane Law School graduate who holds an adjunct appointment at Tulane as Professor of Law. Judge Sear is also a long-term member of Tulane Medical Center's Board of Governors [4] and is Judge Wilkinson's superior in U.S. District Court. Judge Sear has been honored by Tulane with paid teaching trips to Italy and England in 1997 [5] and to England in 2000 for its Summer Program Abroad [6]. Because of the possibility that a judge may favor an institution with which he or she is professionally associated, it would seem prudent for Judge Wilkinson to have recused himself from participating in the above cases so as to avoid the appearance of a conflict of interest. In Bernofsky's opinion, Judge Wilkinson may be expecting his partisanship to be rewarded with more than just another academic promotion and display of his photograph in the Tulane Law School Catalog [7]. As a federal magistrate, Judge Wilkinson is a candidate for nomination to a vacancy in Federal District Court for the Eastern District of Louisiana, and he could receive Tulane's important endorsement. Recommendations to the White House for federal judgeships involve U.S. senators as key players [8], and it is significant that relatives of Louisiana's Senators Mary Landrieu [9], John Breaux [10], and former Senator J. Bennett Johnston [11] have been the beneficiaries of Tulane scholarships. Influence peddling in the form of gratuitous scholarships to politically-connected families and prestigious academic appointments to judges is a Tulane tradition that, in part, has helped to secure favorable treatment by the courts. Questionable Actions U.S. District Court Magistrate Judge Joseph C. Wilkinson, Jr. was assigned to oversee and approve the Pretrial Order, which was the plaintiff's responsibility to prepare. From the start, there were numerous disagreements and conflicts between Judge Wilkinson and Bernofsky's attorneys over the form and content of this document, which delayed the proceedings. Only after many revisions did the plaintiff finally receive Judge Wilkinson's approval of the Pretrial Order. In Bernofsky's opinion, the trivial nature of some of the required revisions suggests an intent to discourage and delay. Motion for Judge Wilkinson's Recusal In light of Judge Wilkinson's ties to Tulane, Bernofsky requested that he recuse himself from the plaintiff's current lawsuit against Tulane. Judge Wilkinson acknowledged a conflict of interest and recused himself [12], thereby establishing a basis of impropriety for his actions in Bernofsky's earlier lawsuit against Tulane [13]. Subsequently, Judge Wilkinson recused himself from another lawsuit in which Tulane was the defendant [14]. His disclosure statement in a further lawsuit against Tulane [15] suggests his recognition of judicial error in Bernofsky's lawsuits, where disclosure was withheld. References and Notes
- Civil Actions No. 97-2311, 96-2507, 95-3343, and 95-358, respectively, filed in Federal District Court for the Eastern District of Louisiana.
- Tulane Law School Catalog 1994-95, 1995-96, 1996-97, 1997-98, 1998-2000.
- Tulane Law School Registration Materials, Spring Semester, 1998. (Ed. Note: Judge Sear's term as Chief Judge ended March 1, 1999; The Times-Picayune, March 8, 1999,
p. B-1 .)
- Almanac of the Federal Judiciary, 1997, Vol. 1, 5th Circuit,
p. 2 .
- Community Rights Counsel (www.tripsforjudges.org). See also: "Group slams judicial trips," The Times-Picayune, Aug. 5, 2000,
p. A-1 .
- Tulane Law School Summer School Abroad 2000,
p. 12 . [Note: Judge Sear died September 6, 2004 at age 75. See: Susan Finch, "Judge in Brilab case dies; Sear handled manyhigh-profile trials," The Times-Picayune, New Orleans, September 7, 2004,p. B-1 .]
- Tulane Law School Catalog 1995-96, p. 102; Ibid., 1996-97,
p. 104 ; Ibid., 1997-98,p. 100 .
- The Times-Picayune, Mar. 12, 1994, p. B-1; Ibid., Sept. 30, 1998,
p. A-2 .
- Gary Landrieu, a cousin, received Tulane scholarships from 1976 to 1981 (The Times-Picayune, Oct. 15, 1995,
p. A-29 ), and Sherri Dazet Landrieu, a sister-in-law, received Tulane scholarships from 1983 to 1985 and 1986 to 1987 (ibid., July 25, 1995,p. A-1 ).
- John Breaux Jr., a son, received Tulane scholarships from 1986 to 1988 (The Times-Picayune, Oct. 15, 1995,
pp. A-18 andA-29 ).
- Norman Hunter Johnston, a son, received Tulane scholarships from 1978 to 1982 (The Times-Picayune, Oct. 15, 1995,
pp. A-25 andA-26 ), and Sarah Lee (Sally) Johnston, a daughter, received Tulane scholarships from 1983 to 1987 (ibid., Oct. 15, 1995,p. A-22 ).
- Minute Entry, Bernofsky, v. Tulane, Civil Action No. 98-1792, Docket No. 14, Sept. 23, 1998.
- Bernofsky v. Tulane University Medical School, 962 F.Supp. 895 (E.D.La. 1997).
- Minute Entry, Rubinstein v. Tulane, Civil Action No. 95-3343, Docket No. 154, Oct. 5, 1998.
- Minute Entry, Rubinstein v. Tulane, Civil Action No. 00-622, Docket No. 2, Mar. 3, 2000.
Judge Lance M. Africk Conflict of Interest
U.S. District Court Magistrate Judge Lance M. Africk presided over the settlement hearings of Bernofsky's 1995 lawsuit against Tulane for discriminatory discharge [1]. Judge Africk's spouse, Dr. Diane K. Africk, M.D., is an assistant professor of Psychiatry and Neurology at Tulane University School of Medicine and has held that position from 1989 [2] to the present [3]. At the first settlement conference, Judge Africk volunteered only that his wife had done a small part-time research project in a Tulane laboratory, and through that experience was able to impart to him an appreciation of the research process. That Judge Africk's wife was actually a paid employee of Tulane - a tenure-track faculty member working toward promotion - was discovered much later from independent sources. Judge Africk also failed to disclose that he was a financial supporter of Tulane University through the Africk Family Foundation [4], and that Dr. Africk made her own separate contributions [4], all apparent affirmations of loyalty. Questionable Actions At the first meeting of settlement negotiations, Judge Africk greeted Tulane's lead defense attorney, Julie D. Livaudais, by planting a kiss on her cheek in full view of the plaintiff, his wife, and his attorneys. Counselor Livaudais is the daughter of The Honorable Marcel Livaudais, Jr., a federal judge in U.S. District Court, a Tulane Law School graduate, and Judge Africk's superior at the time. During the settlement conferences, Bernofsky was primarily concerned with preserving his ongoing and newly-funded ($250,000) research program on the mechanism by which a common chlorinated environmental pollutant causes cancer in animals [5]. Tulane consistently refused to make any concession that would allow Bernofsky to continue his research program. Earlier, he had obtained another $250,000 grant for a sophisticated item of equipment (EPR spectrometer) needed for the conduct of these studies. With Judge Africk mediating, Tulane succeeded in rejecting any arrangement that would permit Bernofsky to salvage his research program. Judge Africk's Recusal After Bernofsky exposed Judge Africk's ties to Tulane, he eventually acknowledged a conflict of interest and recused himself from Bernofsky's 1998 lawsuit against Tulane for retaliation and defamation [6], thereby establishing a basis of impropriety for his actions in Bernofsky's earlier lawsuit against Tulane [7]. Judge Africk also recused himself from three other labor cases in which Tulane was the defendant [8]. However, the damage to Bernofsky had already been done. In Appreciation Tulane's largesse in funding trips for judges to resort locations was extended to include Judge Africk. Tulane's By the Bay conference, which offers continuing legal education (CLE) credits for attorneys, has for years been held at Mariott's Grand Hotel in Point Clear, Alabama. The venue is described as a "spectacularly beautiful resort on Mobile Bay," featuring golf, tennis, horseback riding, swimming, fishing, and a day camp for children. In 1999, the faculty included not only Judge Africk, but also Judges Morey L. Sear, Stanwood Duval and Jerry Brown - all from the U.S. District Court for the Eastern District of Louisiana - as well as Judge Henry A. Politz, of the U.S. Court of Appeals for the Fifth Circuit [9]. For a registration fee of $550 and room rate of $135 per night, lawyers could spend three days sharing experiences with the judges and receiving the benefit of their expertise on ethics. On Judicial Immunity In an opinion rendered June 3, 1997, Judge Africk embraced the view that, "a judge will not be deprived of immunity because the action he took was in error, was done maliciously, or was in excess of his authority. . . " [10]. This viewpoint elevates the doctrine of judicial immunity to the level of a divine right and not only comes perilously close to treading upon the Bill of Rights and Constitution but qualifies to be counted among the "long Train of Abuses and Usurpations" against which our forefathers rebelled [11]. Just Rewards Early in 2002, Judge Africk was nominated by President Bush for the federal bench of the United States District Court for the Eastern District of Louisiana [12]. Like a political chameleon, Judge Africk had changed political parties over the years from Republican to Democrat and back to Republican in accordance with the administration currently in power [13]. When questioned about why he switched his Democratic party affiliation during the Clinton years back to the Republican party after President Bush's election, Judge Africk replied, "I would like to think that the [nomination] choice was made on quality, temperament and integrity." [14] According to former U.S. Senator John Breaux, who supported his nomination, Africk's lifelong ambition was to become a federal judge [15]. Untroubled by Judge Africk's opportunistic party loyalty, failure to observe recusal law, and arrogant view of judicial immunity, the U.S. Senate voted unanimously on April 17, 2002 to elevate him to the U.S. District Court bench in New Orleans, a position that carries lifetime tenure [16]. Judge Africk's conduct thus exemplifies what it takes to succeed in America's present political environment; it also helps explain the rise of public cynicism toward the judicial/legal establishment. References and Notes
- Bernofsky v. Tulane University Medical School, 962 F.Supp. 895 (E.D.La. 1997).
- Tulane School of Medicine 1989-90 Catalog (compiled March 31, 1989),
p. 82 .
- "Faculty & Staff Listings," Tulane University Online Directory, 1998. See also "Faculty Directory, Human Genetics Program," www.som.tulane.edu/human_genetics/directory.html, accessed June 7, 2002.
- Friends and Benefactors, Capitol Campaign Committee, Tulane University Medical Center, Dec., 1996,
p. 6 .
- Ironically, Tulane's Department of Environmental Health Sciences sponsored a training program on "Attenuation of Chlorinated Solvents in Groundwater," held in New Orleans,
Jan. 12-13 , 1999.
- Minute Entry, Bernofsky v. Tulane, Civil Action No. 98-1792, Docket No. 2, June 23, 1998.
- Bernofsky v. Tulane University Medical School, 962 F.Supp. 895 (E.D.La. 1997).
- "Minute Entry," Rubinstein v. Tulane, Civil Action No. 95-3343, Docket No. 154, Oct. 5, 1998; "Minute Entry," Ripoll v. Tulane, Civil Action No. 97-2311, Docket No. 5, Dec. 3, 1997; "Minute Entry," Izawa v. Tulane, Civil Action No. 96-2507, Docket No. 26, Oct. 20, 1998.
- "Faculty," www.law.tulane.edu/cle/bythebays99/faculty.htm, accessed 6/26/01.
- See "Report and Recommendation," Cureaux v. Berrigan, Civil Action No. 97-1705, U.S. District Court, Eastern District of Louisiana, Docket Item 2, FN3.
- The Declaration of Independence, July 4, 1776.
- Bruce Alpert and Bill Walsh, "On the hill; News from the Louisiana delegation in the nation's capital; Judge tapped for federal bench," The Times-Picayune, Jan. 20, 2002,
p. A-6 .
- Voter registration records show that Africk switched from Republican to Democrat on December 16, 1992, following Bill Clinton's election, and from Democrat to Republican on December 14, 2000, after George Bush won the White House. See: Christopher Tidmore, "Inside Political Track," The Louisiana Weekly, New Orleans, December 31, 2001.
- Bruce Alpert and Bill Walsh, "On the hill; News from the Louisiana delegation in the nation's capital; Party affiliation is a split verdict," The Times-Picayune, Jan. 27, 2002,
p. A-6 .
- Michelle Krupa, "U.S. v. Green: Tough justice presides over case; Corruption trial opens in federal court today," The Times-Picayune, June 20, 2005,
p. A-1 .
- Bill Walsh, "Africk is confirmed as federal judge; Senate not troubled by party switches," The Times-Picayune, April 18, 2002,
p. A-11 .
Censure Judge Berrigan?
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