American Jewish Committee’s Gala

Harley S. Tropin, president of Kozyak Tropin & Throckmorton, received American Jewish Committee’s 2016 Judge Learned Hand Award at a gala dinner at Jungle Island. Hundreds of legal, business and community leaders attended the event and presentation of the award, which was established by AJC in 1964 to recognize leaders in the legal profession for their excellence and contributions to the practice of law.

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Historic U.S. cruise docks in Havana

By Annie Rose Ramos and Catherine E. Shoichet

Ana Garcia was crying and could hardly walk as she left the cruise ship that took her from Miami to Havana.

It had been more than 48 years since she stepped foot in the country where she was born.

“I’m just thinking of that day when we left (Cuba) and shaking like a leaf,” she said.

Garcia is one of about 700 passengers on the first cruise in decades to travel from the United States to Cuba. The Adonia, a ship on Carnival Corp.’s Fathom cruise line, docked Monday in Havana.

The ship’s arrival marks the first stop on a historic, seven-day voyage that signals closer ties between the United States and its communist-run neighbor.

As the ship arrived, crowds onboard started chanting, “Cuba! Cuba! Cuba!”

For Garcia, the city manager of North Miami Beach, Florida, pulling into the port was an emotional experience.

“I’m blessed to be here today,” she said, “and hoping for a better tomorrow for Cuba and my Cuban brothers and sisters.”

A warm welcome

 Large crowds waved to the boat from the shore as it approached Havana.

Bands and dancers greeted passengers at the port.

Cuban rum drinks awaited them as they made their way into Havana.

The seven-day cruise is scheduled to stop in three cities: Havana, Cienfuegos and Santiago de Cuba.

Ship left protesters in its wake

 The boat set sail from Miami on Sunday as salsa music played and protesters picketed nearby.

Standing beside Cuban and American flags, the cruise manager touted the journey as “the beginning of a new era.”

Not everyone was happy about the new route.

A small group of protesters gathered outside the port Sunday. And as the cruise ship was getting ready to leave Miami, police descended upon a nearby boat labeled Democracia, where demonstrators held a blue sign that said, “Castro why do you ask Cubans for a Visa to visit their own country?”

But passengers on the ship said they wanted to put politics aside.

As the boat sailed, a salsa band serenaded passengers on deck.

Jesse Mercado, a business owner from Los Angeles, was one of the first to hit the dance floor with his girlfriend, putting aside the small American and Cuban flags they had been waving at people on the shore as the ship passed by Miami’s South Beach.

He said he was looking forward to buying some of the island’s famed cigars, but he most likely wouldn’t try to bring them back to the United States, where an embargo on Cuban-made products still exists.

“I’ll probably smoke them all there (in Cuba),” he laughed.

Gary Carlson said controversy surrounding the cruise doesn’t add up.

“I’m not sure I really understand, because it’s time to put those things behind us,” he said. “Really the big issue is government to government, not people to people, and that’s what we’re excited about participating in.”

Cruise almost didn’t happen

 The voyage, the first U.S. cruise bound for Cuba in nearly 40 years, almost didn’t happen as scheduled.

Last month, controversy erupted over a Cuban law that prevented Cuban-born passengers from coming to the island on boats. The law stopped Fathom owner Carnival Corp. from selling tickets to Cuban passengers.

That move sparked a lawsuit from would-be Cuban passengers and an announcement by the cruise line that it wouldn’t sail unless Cuba changed its policies. Soon afterward, the Cuban government said it would scrap its longstanding ban on letting people born in Cuba come to the island by cruise ship.

But the two plaintiffs in the lawsuit aren’t on this week’s voyage, according to lawyer Javier Lopez, “not because they don’t want to be, but because the Cuban government requires people that were born in Cuba to jump through a whole bunch of other hurdles.”

Cruise officials said six of the passengers on the cruise are Cuban.

Beatriz Melendez is one of them.

The 52-year-old was 4 when she left Cuba with her sister and parents. Now she and her sister are taking the cruise to Cuba together.

“Is that where you had your birthday party when you were little?” Melendez asked her sister, pointing excitedly as the boat pulled into the Havana port Monday.

On Sunday, when the cruise ship left Miami, the sisters spotted a rainbow spanning the bright blue sky — a sign that the spirit of their parents was with them, Melendez said, as they began their journey back home.

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Who is left holding the bag for latent damage claims?

By David A. Samole

Increasingly, true reorganizations under Chapter 11 are the exception, not the rule, as corporate debtors utilize bankruptcy sales to maximize asset value and pay creditors. This trend blurs the line between reorganizations and liquidations, as many Chapter 11 filings repurpose the disposition of assets via goingconcern sales to purchasers without associated liabilities and interests, which attach to sale proceeds payable to administrative expenses, lienholders, unsecured creditors and equity.

The Bankruptcy Economy

Asset value is maximized by “free and clear” sale provisions set forth in Section 363(f) of the Bankruptcy Code — and the finality of such sales. These concepts are paramount to bankruptcy practitioners and the system alike, and drive a certain “bankruptcy economy” for ALL cases and sales, where debtors, creditors and purchasers rely on these concepts to market and close transactions at their highest value with the cleanest title available at law.

Bankruptcy transactions are governed by bankruptcy court sale orders, and many times, such sale orders are in furtherance of a confirmed Chapter 11 plan that can utilize certain transfer tax exemptions provided only in a Chapter 11 confirmation order, which again maximizes the net proceeds for a bankruptcy estate. And Chapter 11 plans ensure equal treatment of similarly situated creditors. As such, bankruptcy sale orders and plan confirmation work together for all constituents as part of this bankruptcy economy as:

  • The purchaser acquires the desired assets, clean title and seemingly unfettered insulation from prior liabilities associated with the assets and the selling company in an expedited manner governed by an open, judicial sale process;
  • The debtor/seller fulfills its fiduciary duty to creditors by maximizing the value of its assets and receives a discharge with respect to all claims and interests it includes in the bankruptcy, with those claims attaching to the proceeds and other estate property and funds; and
  • The creditors obtain the benefit of the assets being fully marketed and monetized at their highest remaining value promoting an improved overall distribution and equal treatment among similarly situated creditor groups.

Approved competitive bidding bankruptcy sales and confirmed plans are supposed to be a utilitarian-like situation for constituents involved in, or affected by, the bankruptcy proceedings. However, there is an untold and many times unaccounted group of “liabilities” that do not get (adequately) addressed as part of most bankruptcy proceedings: latent damage obligations.

Dormant Defects and Latent Damages

Latent damage claims are held by persons or companies that are affected by the repurposed asset with prepetition dormant defects, that only suffer their injury (or more precisely, only suffer their damages or connect their damages to the repurposed asset) post-confirmation. Bankruptcy cases have been able to address latent tort claims with Section 524(g) channeling injunctions and trusts in the asbestos case context, or otherwise establish future claims trusts in cases with massive “known” defects with un-manifested or unaccounted injuries and damages.

The majority of bankruptcy cases, however, do not involve nor merit Section 524(g) channeling injunctions or future claims trusts. As such, when latent damage claimants pursue litigation against the asset purchaser — who is reaping the profits and holding itself outas the owner of such asset — the purchaser and/or the debtor (hello, indemnification sale provisions) usually seek relief in the original bankruptcy court to enforce the discharge and/or other injunctions provided by a final, non-appealable confirmation order and/or sale order that otherwise was duly served on all known creditors by CM/ECF or regular mail processes, and many times served on all unknown creditors by court-approved publication notices in newspapers, industryspecific periodicals and other online mechanisms.

Undercard Issues of a 101(5) Claim

An undercard of threshold issues present themselves many times in these situations, but are affected by different facts or varying circuit-level holdings, such as whether the latent damage liability is even a claim under Section 101(5) of the Bankruptcy Code or when such claim is deemed to arise in a given circuit, which of course is a prerequisite for a claim to be deemed (and perhaps was) discharged by the confirmation order and/or sale order.

Similarly, different cases have varying facts about pre-existing knowledge of manufacturing defects by the debtor and/or asset purchaser (see recent ongoing postconfirmation bankruptcy litigation in GM pending in the Southern District of New York, In re Motors Liquidation Company, f/k/a General Motors Corp., Case No. 09-50026, (and now the U.S. Court of Appeals for the Second Circuit) or perhaps about the defective form and manner of the notice of the bankruptcy case, claims bar date, and confirmation order affecting notions of due process. See an interesting example of this from a case in which this author was involved a few years ago regarding cemetery improprieties, called Alderwoods Group, Inc. v. Garcia, et al., 420 B.R. 609 (Bankr.S.D.Fla. 2009)).

Again, these “other” issues can be dispositive by themselves in post confirmation litigation, for instance taking the example of successor liability claims and their dischargeability, or whether an asset purchaser can use a sale order or confirmation order as a shield to protect against its own misconduct with respect to the purchased assets.

On the one hand, there is a growing trend of bankruptcy courts determining that the “free and clear” language of Bankruptcy Code Section 363(f) may include successor liability claims among “interests in such property” immunizing the purchaser, and merely attaching to estate sale proceeds. However, on the other hand, courts are showing a similarly strong trend that a latent or future claim victim may pursue an asset purchaser for damages strictly rooted to the asset purchaser’s post confirmation (mis)conduct in handling a defective product in the marketplace, where the claim is NOT about successor liability for the debtor’s pre-confirmation conduct, but rather is a standalone claim against the asset purchaser only looking at its conduct after confirmation.

The current debate in the GM case now up on appeal is a very good example of just how hard itis to decipher a stand-alone claim when the post-confirmation misconduct by the asset purchaser is knowingly continuing a defective product line in the marketplace that was manufactured prepetition by the debtor and/or failing to timely recall that product or otherwise not adequately advising consumers about the risks involved with purchasing and continuing to use that product.

These undercard issues can fill up an entire article by themselves, including the effect on seeking punitive damages in the post-confirmation context (which is what really moves the needle in boardrooms), and will be left for another day, but usually these issues have a meaningful effect on such post-confirmation litigation.

Sale Immunity Versus Due Process

This is where two of the most fundamental, heavyweight concepts in bankruptcy law come to a head: the “free and clear” provisions of bankruptcy sales versus due process. In reconciling the bankruptcy sale objectives with the bedrock notions of due process, one should consider the famous bridges hypothetical from the Second Circuit:

Consider, for example, a company that builds bridges aroundthe world. It can estimate that of 10,000 bridges it builds, one will fail, causing 10 deaths. Having built 10,000 bridges, it becomes insolvent and files a petition in bankruptcy. Is there a “claim” on behalf of the 10 people who will be killed when they drive across the one bridge that will fail someday in the future? The potential victims are not only unidentified, but there is no way to identify them. Sheer fortuity will determine who will be on that one bridge when it crashes. What notice is to be given to these potential “claimants”?

In re Chateaugay Corp., 944 F.2d 997, 1003 (2d Cir.1991).

And while some people will think immediately about a future claims representative in the bridges-stype case with a large-scale known forthcoming damage claim without identified claimants, there are many middle-market cases or smaller, where having a future claims representative is not plausible or fiscally responsible to the known creditors in the case, or where the product itself is not inherently known to be the subject of forthcoming damage claims. Ultimately, the key question is what is considered due processfor a latent damage claimant who did not know of the defect at the time of the bankruptcy or was not hurt by the defect manifestation until after the bankruptcy?

Let us add to the bridges-type hypothetical a bankruptcy-related sale process as the best way to maximize the value of the debtor’s assets for creditors. With due process concerns present and inconsistent treatment of such liabilities in the post-confirmation litigation case law, then — even with tightly drafted 363(f) and 1141(c) provisions immunizing the purchaser and debtor from further liability — there remains the potential for purchasers to pay less for assets in bankruptcy because of uncertainty over liability. And existing creditors not only are affected by this potential lower purchase price, but unsecured creditors receiving ratable distributions in the Plan may receive disparate treatment compared with those unsecured latentdamage claimants seeking a dollarfor-dollar recovery against the asset purchaser. Disrupting asset value maximization and the equal creditor treatment continuum can become a recipe for disaster for all constituents in the bankruptcy economy, and has proven to be of great concern in bankruptcy jurisprudence.

However, as the district court in the Southern District of New York advised in a bankruptcy appellate capacity in In Re Grumman Olson Industries, Inc., 467 B.R. 694 (S.D.N.Y. (2012)), despite the strong policy and case law favoring enforcement of bankruptcy court sale/confirmation orders limiting the rights of injured parties, where parties either had no notice of the bankruptcy proceedings or, more importantly, no reason at the time to present an interest in the bankruptcy proceedings (even if they were generally aware of the bankruptcy proceedings) or to take any action in response to the threatened deprivation of their rights, enforcing sale/ confirmation orders in such instancewould violate due process and bankruptcy notice concerns. Id. at 705- 709 (internal citations omitted).

Ultimately, the Grumman Olson court surmised that “[c]ourts have rejected the premise that maximizing the value of the estate outweighs the due process rights of potential claimants.” Id. at 711.

Where Does This Leave the Bankruptcy Economy?

So, where does this leave the bankruptcy economy and the underbelly of future latent damage claimants? Plenty of cases thread the needle to foreclose certain successor liability claims, especially in mega-cases like GM, and there is still the host of undercard issues discussed earlier that many times answer the smaller questions disposing of the matter before reaching the ultimate larger discussion and conclusion reached in Grumman Olson. As such, there remains a discernible variance as to the consequences of latent damage claims in bankruptcy cases relative to enforcing injunctions in sale/confirmation orders.

In many instances, it is latent damage claimants who are left with restricted rights, if any, outside of bankruptcy, and are affected negatively by a process that did not involve them at all. In other cases, the specter of potential latent damage claims will affect the purchase price attained by the bankruptcy asset sale to the detriment of creditors and perhaps debtors. Then, of course, there are those cases where the asset purchaser will face lawsuits on their merits for successor liability-type actions or for standalone post-confirmation misconduct relative to the purchased defective assets despite premising its court approved purchase of such assets on immunizing themselves from liability with respect to the assets.

Accounting for Failure

Asset purchasers should be aware of the limits of “free and clear” language and discharge relief provided in bankruptcy orders no matter how tightly drafted or the breadth of indemnification provisions in transaction documents.

In situations with known defects surrounding the assets, asset purchasers — in addition to seeking broad Section 363(f) and indemnification language in bankruptcy orders and sale documents — may want to consider pushing for a future claims representative or a holdback reserve for any latent damage claims with such reserve being either on the estate or purchaser side. And while a competitive bid scenario may engender different terms and provisions on these points, inclusion of such items may affect notions of the “highest and best” bid. There is room here both for creativity and improving the treatment of latent damage claims, while maximizing the return to creditors.

Ultimately, despite Section 363(f) and 1141(c) relief, asset purchasers need to account for this additional risk component in their purchase price. In a normative world, case law or legislation would provide uniform treatment of latent damage claims in the post-confirmation/ post-sale setting.

One idea is for the United States Supreme Court to resolve the varying circuit standards as to when a Section 101(5) Claim arises for bankruptcy discharge purposes, but the differing state law standards for the accrual of latent damage claims may prove too difficult to overcome. Other cases focus on successor liability in the bankruptcy sale context but, as shown in GM, legal minds still cannot agree whether a given purchaser’s conduct with respect to a latent defective product falls within successor liability or a standalone, independent claim.

Finally, while constitutional due process relative to the treatment of latent damage claims in a bankruptcy sale order and confirmation order is guided by general due process pronouncements in Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950) and more specific discussions in cases like Grumman Olson and those referenced there finding that due process trumps 363(f), other casesretreat from that basic principle and peel back due process with notions of proving prejudice, overcoming mootness, and other similar issues.

More settled law and legislation on the treatment of latent damage claims in the post-confirmation/ post-sale context would engender a more predictive analysis and level playing field for asset purchasers and hopefully a uniform treatment of latent damage claims in sale orders and confirmation orders. However, the current uncertainty involved as to the treatment of latent damage claims in bankruptcy cases (which can be fact-specific) may actually work in favor of some asset purchasers who are more risk-tolerant and better understand the bankruptcy terrain than competitors in their marketplace, which yet again contributes favorably to the existing bankruptcy economy sustaining the lifeblood of debtors and creditor recovery alike.

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Cuba travel lawsuit against Carnival withdrawn

In the wake of a reversal in a Cuban policy that prevented those born in Cuba from taking cruises to the island, a class-action lawsuit against Carnival Cruises and its Fathom line was pulled Thursday.

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Cuban-Born Travelers Drop Suit After Carnival Axes Ban

By Nathan Hale

Law360, Miami (April 28, 2016, 5:35 PM ET) — Two Cuban-born Americans accusing Carnival Corp. of civil rights violations for barring Cuban-born consumers from its new cruises to the once off-limits country dropped their proposed class action Thursday, citing recent changes in Carnival’s booking policy and Cuban law.

The Miami-based cruise operator, the world’s largest, had acted quickly to resolve the controversy following the suit’s filing on April 12 by Francisco Marty and Amparo Sanchez and a wave of intense public criticism, including from U.S. Secretary of State John Kerry, Miami-Dade County Mayor Carlos Gimenez and other local officials over its decision to adopt a Cuban policy of not allowing people born in the country to travel there by ship.

The complaint alleged that Carnival and its new unit Fathom Travel Ltd. Corp. violated the Civil Rights Act by adopting Cuba’s policy of not allowing people born in the country to travel there by ship, prohibiting the consumers from boarding the first American cruise line to go to the island in more than 50 years.

Carnival said April 18 that it was opening its booking process to all passengers in anticipation of being able to work out a change before the scheduled May 1 commencement of sailings on Carnival’s Fathom line. The company also said that it would delay the departure if an acceptable resolution were not achieved in time.

Last Friday, the Cuban government, through the state-run newspaper Granma, and Carnival said that the prohibition had been lifted for passengers and crews of cruise ships and merchant vessels.

In their notice of dismissal Thursday, the plaintiffs also noted that Carnival has pledged to help Cuban-born Americans with special visa and passport requirements.

“We filed our case with one, simple goal: to end discrimination against Cuban-born Americans who were being denied cruises to Cuba based on their place of birth,” plaintiffs counsel Tucker Ronzetti of Kozyak Tropin & Throckmorton LLP said in a statement Thursday.

Ronzetti added, “With our goal accomplished, we are dismissing our case. We look forward to all U.S. citizens, Cuban-born or otherwise, now equally enjoying cruises to Cuba.”

A spokesman for Carnival echoed those sentiments, saying, “We are pleased with the outcome, and extremely excited about Sunday’s historic launch as the first U.S. cruise line to sail to Cuba in more than 50 years.”

Carnival had announced in July that it would begin cruises to Cuba from the Port of Miami in May as part of a new “social-impact travel” brand now that the U.S. government has given the company approval to take travelers to the island nation. Last month, Carnival became the first cruise line to be approved by Cuba.

The first cruise is scheduled to depart Miami on May 1 with stops planned in Havana, Cienfuegos and Santiago de Cuba before a return to Miami.

On Thursday, Marty issued an impassioned statement of his own, explaining his reasons for filing the suit and what it meant to him to see it help strike down the apparent discrimination.

“I fled Cuba because there was no respect for the rule of law. I went back and fought to liberate my native land, and I was unable to do so. As a Cuban-American I am proud to call the United States my country and my home. When I was denied passage by Carnival to my native land, I was shocked that such an action could be taken by a company that calls the Miami Port its home,” Marty said.

He said he never doubted the suit would succeed, because the rule of law always wins in the U.S.

“What I did not expect was that my case would change the law of a country,” Marty said. “I once landed on the beaches of Cuba to fight for its liberty — I did this with a rifle. I was not successful. I engaged Cuba again by sea, this time armed with the law, and I won.”

Sanchez and Marty are represented by Thomas A. Tucker Ronzetti, Javier A. Lopez and Stephanie Moncada Gomez of Kozyak Tropin & Throckmorton LLP and Robert W. Rodriguez of Robert W. Rodriguez PA.

Carnival and Fathom are represented by Stuart Harold Singer, Luis Eduardo Suarez, Markenzy Lapointe and Stephen N. Zack of Boies Schiller & Flexner LLP.

The suit is Sanchez et al. v. Carnival Corp. et al., case number 1:16-cv-21319, in the U.S. District Court for the Southern District of Florida.

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Harley Tropin Honored with American Jewish Committee’s 2016 Judge Learned Hand Award

 Award is highest honor given by AJC in legal profession

MIAMI – April 26, 2016 – Harley S. Tropin, president of Kozyak Tropin & Throckmorton, received American Jewish Committee’s 2016 Judge Learned Hand Award on April 13.  Nearly  400 legal, business and community leaders attended the gala dinner at Jungle Island. AJC established the annual award in 1964 to recognize leaders in the legal profession for their excellence and contributions to the practice of law and the community at large.

The highest honor given by AJC within the legal profession, the Judge Learned Hand Award recognizes the memory of Judge Learned Hand, noted for his significant decisions in constitutional law and anti-trust. The recipients of this award are people who embody much of what the judge represented: the rights of the individual and the importance of democratic values in an orderly society. This philosophy also sums up a major thrust of AJC’s work and the programs it has promoted since its inception in 1906.

“Harley has set a high standard for passion for the practice of law along with commitment to service to the community,” said Brian Siegal, director of AJC’s Greater Miami and Broward Regional Office. “We are honored to recognize Harley’s contributions to the profession and the improvement of our community, adding his name to an illustrious roster of legal luminaries whose professional and personal achievements greatly enhance our society.”

Tropin, a leading high-stakes business litigator, has received many prestigious awards and accolades for his significant contributions to the legal profession and community during the past 30 years. Under his leadership, Kozyak Tropin & Throckmorton began as a three-attorney law firm in 1982 and grew over the years into a 25-attorney firm nationally renowned for its work in bet-the-company litigation, class actions, bankruptcy, and massive financial frauds. (In fact, Kozyak Tropin & Throckmorton has been involved in the litigation of every major financial fraud in South Florida since its inception – and there have been many.) The firm’s key practice areas each stemmed from major cases that Tropin took early on in the firm’s history.

For example, in the recent $500 million Ponzi scheme involving disgraced Fort Lauderdale lawyer Scott Rothstein, Tropin and his team represented most of the defrauded investors in recovering more than 95% of their losses.

Tropin also has represented 700,000 physicians and their medical societies, including Texas Medical Association, the California Medical Association and others. Tropin served as co-lead counsel in a national class action against major HMOs including Aetna, Cigna and Humana for systematically denying doctors reimbursement for services provided to patients by down-coding medical services through the use of their computerized reimbursement procedures.  The case resulted in the recovery of billions of dollars both in actual cash payments to the doctors, and improved reimbursement procedures and dispute resolution methods.

Tropin has received national recognition from his peers as a member of the Board of Directors of the International Academy of Trial Lawyers and the American Board of Trial Advocates.  He currently serves as a professor of trial advocacy at the University of Miami School of Law and was recognized by the Law school with its Alumni Achievement Award in 2012.  He is a member of the Federal Judicial Nominating Committee, has served as a director of the Greater Miami Jewish Federation, and co-chairs the Federation’s Annual Judicial Reception.

Tropin supports Miami community organizations in every way he can. One of his greatest passions is improving access to mental health services and fighting discrimination against those suffering from mental illness. Toward that end, he is co-chair of the Advisory Board to the University of Miami Medical School Department of Psychiatry. Harley also has served on the Florida Supreme Court Committee on Gender Bias and Diversity and is an integral part of the Kozyak Tropin & Throckmorton commitment to diversity in the workplace and community.

About Kozyak Tropin & Throckmorton

Kozyak Tropin & Throckmorton is a complex commercial litigation firm founded in 1982 that focuses its practice on bet-the-company commercial cases, bankruptcy matters and class actions. For more information, visit

About AJC

For more than a century, AJC has served as a leading global Jewish advocacy organization. AJC works to enhance the well being of the Jewish people and to advance human rights and democratic values for all.  Working in over 100 countries through intensive outreach to top decision-makers and diplomats, AJC is uniquely qualified to provide a global response to critical issues facing the Jewish people, Israel, and the world today.  In an increasingly interconnected world, AJC engages the world’s political, religious, and ethnic leaders through high-level diplomatic meetings that build upon long-standing relationships. For more information visit

 About AJC Judge Learned Hand Award

AJC, a non-profit organization dedicated to advancing human rights and democratic values in the U.S. and worldwide, established the Judge Learned Hand Award in 1964 to recognize leaders in the legal profession for their excellence and contributions to the practice of law. The award honors the memory of Judge Learned Hand, a highly distinguished individual recognized as heir to Justice Oliver Wendell Holmes’ legacy of a Jurist and Poet of Liberty. Judge Hand, a graduate of Harvard and its law school, was widely admired as a Dean among American jurists, and was well-known for the extensive range of decisions he tendered that centered on questions of constitutional rights and antitrust legislation.





Greater Miami, Fort Lauderdale chambers may merge

South Florida’s two largest chambers of commerce, the Greater Miami Chamber of Commerce and the Greater Fort Lauderdale Chamber of Commerce, are exploring a merger.

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