Morrissey in the Entertainment Law Review

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LoafingOaf

Guest
I don't know if I ever posted this before, but I was going through items on my hard disc and came across this old law review article which focuses on Morrissey.

So, if by chance anyone's interested, here ya go....

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Entertainment Law Review

1999

Article

'UNLESS OTHERWISE AGREED...' PRESUMPTION OF PARTNERSHIP FOR MUSICAL ARTISTS

Paul C. Graznak.

Copyright (c) 1999 Sweet & Maxwell Limited and Contributors

Case: Joyce v Morrissey Times, November 16, 1998 (CA)

Legislation: Partnership Act 1890

Keywords: Apportionment; Partnerships; Performers; Profits; Variation

Abstract: Implications of CA ruling that distribution of profits among members of music group is governed by 1890 Act for bands and their advisors including choice of appropriate business forum and partnership agreement issues.

*113 Introduction

When the Court of Appeal case of Joyce v. Morrissey appeared in the Times Law Reports it did so under the typically innocuous headline, "Partners must make change in profits explicit." [FN1] However, the story is one that should grab the attention of musical groups and their advisors. The case illustrates a broad and significant point of English commercial law that has far reaching implications for the entertainment industry. Unless a musical group has set up a limited liability company or created a partnership agreement of some kind, the group will be considered a partnership and will be governed by the Partnership Act 1890. [FN2] This presumption of partnership is not surprising to lawyers in the United States or England, or those who would have the benefit of legal counsel early in their music business endeavours. What would surprise most artists and many managers is the fact that a more than 100- year-old unmodified statute with complex business implications lurks behind their actions. Three factors make this alarming for developing artists:

1) Musicians are unlikely to consider documenting the relationships between themselves and other band members. Most often, bands believe that their third-party agreements with managers and others sufficiently clarify these relationships. Unfortunately, they do not.

2) The Partnership Act 1890 is for the most part a set of default provisions. Fledgling businesses with legal advice will invariably draft express agreements to remove them from such presumptions. However, a very small percentage of developing artists or their representatives realise the importance of legal counsel in this regard. [FN3]

3) English partnership law is in a state of flux and under call for significant reform, further complicating the matter. [FN4]

The Case

*Please refer to news item at page N-44 of this issue.

On the surface the legal issues presented by Joyce v. Morrissey are not complex. It was first established that the activities of the 1980s musical group, The Smiths, constituted the formation of a partnership. The plaintiff, Mr Joyce, was the drummer of the four-piece group. The defendant, Mr Morrissey, was the singer and leader of the band along with second defendant and guitarist Mr Marr. By definition a partnership is merely the relation which subsists between persons carrying on a business in common with a view of profit. [FN5] This low standard is easily met. However, the somewhat surprising decision in the 1998 case of Kahn v. Miah indicates that certain preparatory actions may not constitute the formation of a partnership. [FN6] Still, it is safe to assume that once a band has begun creating original compositions with a view to recording and marketing them, a partnership is formed unless another business form has been expressly chosen. It is also probable that a partnership has come into existence during rehearsals in preparation for live performance or certainly once the set membership of the band has played for pay.

The claim put forward by the plaintiff was that as a performing member of the group he was entitled to an equal share or 25 per cent of all net profits from recordings or live performances. Mr Morrissey countered that he and Mr Marr had made superior contributions by controlling the management and organisation of the band and that these contributions were, by oral agreement of the band, reflected in a 40/40/10/10 division of profits in the defendant's favour.

However, in the absence of an agreement to the contrary, when the band was formed, a presumption was created that the partnership commenced on the basis of equality. [FN7] In the Court of Appeal, Lord Justice Waller said that it was clear as a matter of partnership law that a greater contribution by one or more *114 partners does not rebut the presumption of equality. [FN8] Furthermore, additional documentary evidence presented by the defendant to establish a variation from equality failed to rebut the presumption. Specifically, Morrissey maintained that the mailing of a copy of accounts to Mr Joyce showing an unequal distribution, and Mr Joyce's subsequent silence on the matter, were further indication of his acceptance of this distribution. In upholding the lower courts decision for the plaintiff, the Judge found that the sending of the accounts would need to rise to the level of a contractual offer to Mr Joyce that the only way the partnership would continue, would be if he accepted a lower percentage of profits. The Court reasoned that even if this was established, it was quite impossible to construe Mr Joyce's silence as acceptance. The case may yet end up in the House of Lords.

Comparisons with the Spandau Ballet Case

Comparisons are already being made between The Smiths case and the current internal dispute between members of another 80s group, Spandau Ballet. [FN9] At this writing, three former members of the band are appearing before Mr Justice Park claiming a share of royalties from the group's sole music publishing copyright holder, Gary Kemp.

In the early 1980s as the band began to achieve commercial success, Mr Kemp decided to give half his music publishing profits to the other band members and continued to do so each year for several years. He decided to end such payments in or around 1987.

The plaintiffs allege that when Mr Kemp reclaimed 100 per cent of his publishing profits he breached an oral agreement that they maintain was to run in perpetuity. In addition to the plaintiffs' claims based in contract, they bring an alternative claim in copyright. The band members assert that they wrote many of the instrumental parts on which they played and contributed to the arrangements of the bands songs. Mr Kemp contends that his decision to share the profits from his songwriting was merely gratuitous and that he was entitled to end these payments at will. Mr Kemp also stands firm that he brought rough, but completed songs to the band and that the other members only contributed the occasional idea or suggestion for a free-form solo. It may be important to note that in the second week of the proceedings Mr Justice Park questioned the band's former manager Steve Dagger before releasing him. The judge enquired whether Mr Kemp was simply exercising "good business sense" in the "personal interest of Mr Kemp" to financially support the band as a vehicle for his songwriting.

Without discussing the merits of these arguments here, it is safe to say that there are several factual similarities between the two cases. Both cases are disputes involving 1980s pop bands that deal with internal organisational issues occurring early in the bands' careers but coming to light well after the groups' demise. In each case the defendants have been "leaders" of bands sued by band members for income produced at least in part by the band's collective past success. Furthermore, in the wake of undocumented business relationships, both cases address the value of band member's individual contributions. Consequently, each case looks at the enforcement of oral agreements with an underpinning of equity.

However, two fundamental differences between these two cases stand out. First, The Smiths case was driven by a single controlling statute that leaves little interperative latitude if not circumvented by a partnership agreement. Secondly, the Spandau Ballet case involves band members claiming intellectual property rights in music publishing as opposed to a higher percentage of profits from recordings and live performances only. This distinction is significant, as the music industry has long recognised how precious the longevity of musical copyright is to its holders. While an avenue must always exist to address wrongly assigned credit and accurate copyright ownership, it should be a much tougher legal nut to crack by after the fact disgruntled ex- band members.

The Statute

To reach the decision in Joyce v. Morrissey the Court did not need to look far beyond the Partnership Act 1890. The Act has survived intact for more than a century. While the Companies Act has seen significant reform and has made provisions to address the problems of contemporary small businesses, the Partnership Act has not. [FN10] This may be because it functions perfectly but most probably because the majority of it can be circumvented by express partnership agreement. To have the general law be little more than a well-worn default provision is somewhat unsettling. The business community is beginning to expect more than a law that is merely bearable because it can be evaded by specialist legal advice. Not surprisingly the reform of English partnership law is imminent.

Reform efforts began in earnest with a November 1994 Law Commission feasibility study. [FN11] The Commission had been asked to investigate the needs of small businesses operating as private companies but apparently the Commission's divining rods kept pointing to the deficiencies in partnership law. The study focused on three difficulties which partnerships currently encounter:

1) The retirement or death of a partner dissolves the partnership and the assets of the firm must be realised and distributed;

*115 2) Partnerships do not have separate legal personality from the individual partners who compose it, complicating commercial relationships such as borrowing money;

3) There is no standard form partnership agreement and the default provisions of the Partnership Act may not give effect to the actual intentions of the individual partners. In addition, the drafting of a suitable partnership agreement may increase the establishment cost for those wishing to run their businesses as partnerships.

Proposed changes include clarifying the winding-up process for solvent partnerships and perhaps most importantly the creation of a completely new partnership structure. The DTI has suggested the limited liability partnership (LLP) as a vehicle providing separate legal status and partner liability only for the damage they as individuals have caused. [FN12]

The impact the implementation of such reforms might have upon musical artists is uncertain. For instance, there may be little benefit for a recently formed teenage band that doesn't even realise that their musical union has just assumed all the pitfalls of a statutory partnership. Under these reforms the real beneficiaries may be the large law partnerships.

Not everyone appears to be concerned with the current machinations of partnership law. Ronald Taylor, solicitor for the successful plaintiff in Joyce v. Morrissey thinks the case is evidence of the fact that the statute has survived the test of time because it works. Although he advocates the early documentation of business arrangements for musicians, Taylor says, "The Partnership Act effectively protected the fact that partners may contribute to the partnership in different but equal ways."

The defendant's assessment of the Act would undoubtedly show less admiration for the grand old statute. As the defendants attempted to rebut the presumption of equality in section 24 of the Act, Mr Morrissey gave evidence of his and his co-defendant's far greater contribution and commitment to the venture and its manifestation in the alleged orally agreed disproportionate split of profits. Accordingly, to the defendants, the over 1 million judgment appears inequitable and unfair in commercial terms. Yet it would be equally unfair for the law to allow the balance to tip in favour of easy to identify partnership contributions as opposed to those that are less tangible. Commercial law has long valued the background, skills and connections of less active partners. [FN13] In a musical group, the elusive magic that makes a band successful is difficult to express in purely financial terms. Whatever statutory provisions or model agreements attempt to address this balance they can never provide the value of early legal advice and the documentation of parties' intentions in writing.

Choice of Appropriate Business Form

If Joyce v. Morrissey stands for one single proposition, it is that early in their formative period, band members must document an agreement between themselves in relation to their musical careers. [FN14] There are two basic options for this internal organisation. First, members can become shareholders in a limited liability company that contracts for member services. Secondly, the band members may be parties to a partnership agreement that clearly defines as many relevant rights and responsibilities as possible. Which of these options is best for any group is a function of the particular facts and circumstances of the group both individually and collectively. Additionally, over time the differences between a well-designed partnership and a limited company has become a distinction of device rather than function. [FN15]

Band advisors suggesting which business entity to create must take into consideration the classic characteristics of each form including limited liability, tax consequences, cost, formalities of formation and maintenance, transferability, duration, and the separation of ownership and control. In addition, counsel must be current with developments in company and commercial law including the significant impeding reforms to partnership law. New organisational options may emerge for musical artists. More importantly, the current options may evolve either more adequately protect, or put in peril, the particular interests of the group.

The decision whether to form a limited liability company or partnership must take into account a wide variety of factors. Various factors may be weighted more or less depending on the issues the band members and the advisors see as pertinent to the group's circumstances and welfare. Yet there are a few issues that may strongly influence such decision in favour of a limited company.

1) Significant Longevity of the Group--if a band has been together for a number of years such longevity may indicate the stability of membership for which the corporate form may allow greater long term security. Arbitrary dismissal of a group member is less likely within the context of a limited company.

*116 2) Commercial Awareness of Group Members--Musical artists today have more commercial acumen and interest in business affairs than ever before. Many artists demand an active and highly participative role in the business decisions which effect their careers. A limited company takes more time and maintenance than a partnership but affords band member/shareholders a more sophisticated commercial vehicle than may be possible through a partnership agreement.

3) Significant External Personal Assets of Group Members--Individual band members may need to carefully consider whether they are willing to put their personal assets at risk in a band partnership. Each partner is individually as well as collectively responsible for group liabilities. While a partnership agreement may state that all members share in the risks equally, in reality an individual with significant assets may shoulder the entire burden.

4) Groups Needs to Raise Capital--Like most small business ventures, musical groups invariably need capital to launch their careers. Sometimes these funds are self-generated or come in the form of record company advances. However, many groups may seek outside investment capital. Corporate form may lend credibility to the venture for individuals reticent to invest in such speculative and unorthodox business, much less become partners in a music business project.

5) Group and Individual Member Tax Considerations--An analysis of global tax issues that may necessitate forming one or more limited companies is beyond the scope of this comment, not to mention the expertise of its commentator. Suffice it to say tax concerns alone may drive the decision regarding the appropriate form for conducting the business.

6) Group Members Have Unequal Status--When a band forms, invariably some members bring more to the party than others do. Perhaps one or two members gather others around a concept or extraordinary writing or performing ability. "All for one and one for all" is better in theory than practice in many circumstances. Simultaneously, an employer/employee relationship is often destructive to the ensemble nature of the venture. Often what is necessary is profit sharing agreement documenting a ratio that accurately reflects the contributions of individual members. While an appropriate partnership agreement may adequately create this arrangement, it is difficult to encapsulate the subtleties addressed by the body of company law. The longer this issue goes without being formally addressed the greater the chance for disaster. As a group becomes more successful, each member may develop an entourage and fan base that constantly reinforce the opinion that their contribution is to the whole is significant, unique and indispensable. Both The Smiths case and the Spandau Ballet case [FN16] demonstrate that any disproportionate equity must be ready to stand a full frontal assault perhaps even years after the fact. Arguably, the corporate form is better suited to do so.

Partnership Agreement Issues for Musical Groups

A partnership can not exist without some form of agreement, but that agreement may be oral or scribbled on scrap paper. [FN17] A formal partnership agreement will attempt to create a structure that will avoid or mitigate potential problems and circumvent the default provisions of the Partnership Act. Particular attention should be paid to statutory provisions that are inconsistent with the way the band wants to do business. No agreement can address every eventuality. Furthermore, even the most carefully drafted agreement may need modification over time.

The most common and dangerous approach to entertainment contacts is to initially negotiate each point with zeal and then upon completion file the contract away, allowing it to surface only in times of crisis or dispute. Partnership agreements must be viewed as living documents that should proactively guide partners and provide ongoing assistance with helping them to reach their goals. One of the superior characteristics of the partnership vehicle is the flexibility. Partners may amend their agreement to face the changing demands that the group may encounter.

One need only look at The Smiths and Spandau Ballet cases and a few of the litany of destructive internal band disputes that came before them, to see issues that demand documentation. Such law suits are invariably not only expensive but lend themselves to the painful deconstruction of who contributed what to the group, all under the glare of the publicity these cases generate. While it is impossible to begin to list every potential issue of concern to musical partnerships, the following represent topics that seem to continuously resurface:

1) Capacity of Parties

There is no general restriction as to who may become a partner beyond having the capacity to enter into a contract. However, this issue is becoming more relevant as the music industry's youth movement continues.

2) Group Name

The ownership of the group name must be clearly defined. It is a partnership asset unless otherwise agreed. Provisions dealing with the good will and *117 value of the name, departing members and group disbandment are key.

3) Partnership Property

In addition to the band name, other partnership profit must be explicitly delineated from the property of individual partners. It is appropriate to expressly exclude property such as musical instruments from partnership assets.

4) Contribution of Capital

While this is seldom the issue for newly formed bands, where capital has been contributed to the band arrangements must be made for its return. Generally this is as a first charge against profits.

5) Sharing of Profits, Losses and Expenses

If the distribution of profits and losses are unequal it is necessary to clearly state the method of distribution. Stating the individual contributions providing the basis for these calculations may also help prevent future disputes. Joyce v. Morrissey demonstrates presumption of equality and the necessity of expressly addressing this issue. Additionally, a policy must be set listing allowable expenses and a method for evaluating what constitutes a reasonable expense if it is not specifically enumerated.

6) Drawings

Partners may need to make provision for personal advances as the music industry is famous for the time lag between when money is earned and when it is actually paid to the artist. As this area has great potential for disagreements, a system should include direct provisions for frequency and amount as well as an ability to adjust these terms as profits increase.

7) New and Departing Members

Changes in membership may present enormously complex issues for all involved. Release and indemnification for both outgoing and incoming members must be carefully executed. Rights to future income and accounting provisions as well as new calculations of profit, loss and liability need careful consideration.

Meetings

While partnerships have no statutory requirements for meetings as do limited companies it is important to agree to regular partnership meetings. A lack of ongoing communication between parties is often a large contributing factor to music industry litigation. Band members spend vast amounts of time together early in their careers. As they become more successful it is often surprising how little time they may actually be in contact. As relationships become strained, members may choose to be together only when they are on stage or in the studio. Adherence to regular meetings may at least bring disagreements to the table before they become destructive.

9) Voting

In an equal partnership, most group decisions may be reached by a majority vote of band members. Voting may also be based on profit sharing ratios. It may be agreed that certain major decisions require the unanimous vote of all members. Whatever voting system is employed it needs to be fully agreed between all members, documented and functioning before it withstands the pressure of a dispute over a major career decision.

10) Expulsion

The expulsion from the band of a group member brings to light a harsh provision of the Partnership Act 1890. Unless the partnership agreement states otherwise, Section 25 of the Act provides that a partner may not be expelled and the only recourse is to dissolve the partnership. For this reason it is imperative that a band specify the mechanism for expulsion including voting and notice. Additionally, members must agree in principle to what constitutes conduct resulting in expulsion. While it is impossible to create an all inclusive list, some effort must be made to include examples that allow any particular behaviour to be viewed within the spirit of what the band feels are grounds for removal.

11) Publishing Issues

There has been no decision in the Spandau Ballet case as of this writing. Yet regardless of the outcome, it is a lesson that a division of publishing income is far too important to leave to oral agreement. The extraordinary commercial value of copyright royalties makes a clear written delineation of what constitutes group and composer income a necessity. Bands may construct creative mechanisms that assign income or joint composition rights to compensate certain band members for their contributions. Putting these arrangements in writing may prevent the interpretation of missing or ambiguous terms from being hammered out in court at great expense.

12) Dispute Resolution

The use of full-scale legal warfare to resolve group dispute creates heavy financial and emotional casualties. One of the main purposes of the careful organisation and documentation of a group's business relationships is the avoidance of this eventuality. The entire band should participate in drafting a provision that provides options for modern alternative dispute resolution techniques that stop short of litigation. Such mechanisms provide band members with responses to serious conflict that mitigate the feelings of anger and helplessness that trigger rash and irrevocable actions. If this provision is drafted in an initial period of good will and camaraderie, at least some of it may survive the inevitable periods of conflict the band may face.

[FN1]. Joyce v. Morrissey and Others, The Times, November 16, 1998, CA.

[FN2]. Partnership Act 1890, s. 1(1).

[FN3]. It is important to note that the U.K. has arguably the largest concentration of highly informed and professional artist managers of any music industry market in the world. However, only a relatively small number of developing artists has the benefit of their counsel.

[FN4]. See Ronnie Fox and Clare Murray, "Partnership Law: Recent Developments", (1998) 95 L.S.G. 18 and see the Law Commission, "Company law review: the law applicable to private companies [1994] U.R.N 529.

[FN5]. See n. 2 above.

[FN6]. Kahn v. Miah, The Times, January 13, 1998, CA. This Court of Appeal decision may alter the parameters for when a partnership is formed. The parties had agreed to enter into a partnership to run a restaurant and had arranged for a premises as well as entering into several supply contracts before they fell out just previous to the opening of the restaurant. Traditional thinking as well as the dissent of Buxton L.J. would uphold the trial court view that the agreement to enter into business and the parties subsequent conduct constituted the formation of a partnership. However, to support its decision the Court looked to the fact that the restaurant had not yet opened or carried on restaurant business at the premises and that no food had been purchased or bookings taken.

[FN7]. See n. 2 above at s. 21(1).

[FN8]. See Lindley & Banks on Partnership (17th ed., [1995] paras 19-22).

[FN9]. Hadley v. Kemp unreported.

[FN10]. See n. 4 above at para. 5.62.

[FN11]. See n. 4 above at para. 5.63.

[FN12]. See n. 4 above at 3.1 3.7. Under the Partnership Act 1890 s. 6 and theories of agency law, each partner is directly liable for the acts of other partners in relation to the partnership business.

[FN13]. A recent case illustrates the presumption of equality, in Popal v. Shonchhatra, The Times, July 4, 1997, a partner who had made a greater capital contribution and continued the business after the partnership ended was nonetheless forced to equally share all profits with his former partner as there was no agreement to the contrary.

[FN14]. While it is certainly preferable to define relationships as early as possible, it is never too late to do so. However, great care must be taken by counsel to uncover all pertinent written or oral agreements, as well as the band's informal understandings and expectations. Therefore, it is particularly important to have all band members present at meetings where information is gathered to document the organisational structure of a band with significant history.

[FN15]. See Paul L. Davies, Gower's Principles of Modern Company Law, (6th ed., London, 1997) at 4.

[FN16]. It is important to note that Spandau Ballet formed two limited companies early in their career. The first company, as a band and manager all with equal shares. The second as a publishing entity of which songwriter Gary Kemp held 100% equity but subsequently provided half of the publishing company's income as "band support" back to the band's company.

[FN17]. This need be little more than an assent to carry on a business in common with a view to profit.

END OF DOCUMENT
 
Thanks for that

An interesting read. A bit dry, but I guess the law can be, can't it?
 
I think that the burden of proof should have been on Joyce, as the plaintiff, not on Morrissey and Marr.
I personally don't see how he could have proven that he made an equal contribution to the partnership.
In fact all evidence indicate the contrary.
It's a complicated case, which proves it is always best to have things in writing.
I hope there aren't going to be more cases like these with his solo band mates.
 
> I think that the burden of proof should have been on Joyce, as the
> plaintiff, not on Morrissey and Marr.
> I personally don't see how he could have proven that he made an equal
> contribution to the partnership.
> In fact all evidence indicate the contrary.
> It's a complicated case, which proves it is always best to have things in
> writing.
> I hope there aren't going to be more cases like these with his solo band
> mates.

You don't understand. The law *presumes* that Joyce gets an equal dsitribution of the profits, regardless of whether he made an equal contribution.

Lets say Larry, Moe, and Curly form a partnership to sell whoopee cushions. To get started, Larry and Curly contribute $10,000 and each work 60 hours/week. Moe, however, contriubutes $0.00 and works 20 hours/week to help close big deals. Despite the differences in contributions, they each get a third of the profits...unless they've agreed otherwise. That's basic partnership law, in both Great Britain and America.

Since there was no express agreement, Morrissey and Marr had to show what's called an implied-in-fact contract existed. Which is just as good as an ordinary contract, just that rather than proving it through express words or writing, you prove it through the actions of the parties, their course of dealing, custom, etc., in order to tell the court, "See, these facts demonstrate that we intended, understood, or assumed that this agreement existed between us." So, they had was an intense factual dispute over whether there was an implied partnership agreement taking them outside of the default rule, and the burden was on Morrissey and Marr to convince the court.
 
I do understand the law and I do understand that equal portions are presumed.

The fact of the matter is that Joyce received 10% from the starting point.
He did not act immediately on his right to receive an equal share, thus indicating he settled for less.
There must be a time limitation on these sorts of things.
He can't wake up after 10 years had past and sue, it just doesn't work that way in the legal world. It's dishonesty on his part.

Second of all, I don't see what evidence Morrissey and Marr, could have furnished to convince the court.
Apart from having a signed contract, they had bundles of evidence to support their stance.
If the court wasn't convinced on these grounds, I wonder if there is any way possible to prove such a thing. It is virtually impossible.

Third and last, I believe one can argue only Marr and Morrissey were a partnership, while Rourke and Joyce were not part of it and were hired by the partnership. This can be easily supported.

I admit that not signing a binding legal contract was foolish of Morrissey and Marr, but this Act should be amended.

> You don't understand. The law *presumes* that Joyce gets an equal
> dsitribution of the profits, regardless of whether he made an equal
> contribution.

> Lets say Larry, Moe, and Curly form a partnership to sell whoopee
> cushions. To get started, Larry and Curly contribute $10,000 and each work
> 60 hours/week. Moe, however, contriubutes $0.00 and works 20 hours/week to
> help close big deals. Despite the differences in contributions, they each
> get a third of the profits...unless they've agreed otherwise. That's basic
> partnership law, in both Great Britain and America.

> Since there was no express agreement, Morrissey and Marr had to show
> what's called an implied-in-fact contract existed. Which is just as good
> as an ordinary contract, just that rather than proving it through express
> words or writing, you prove it through the actions of the parties, their
> course of dealing, custom, etc., in order to tell the court, "See,
> these facts demonstrate that we intended, understood, or assumed that this
> agreement existed between us." So, they had was an intense factual
> dispute over whether there was an implied partnership agreement taking
> them outside of the default rule, and the burden was on Morrissey and Marr
> to convince the court.
 
blah blah blah buddy. Are you a f***ing lawyer? No? Then shut the f*** up before you begin to sound like an ignorant idiot..oh too late.
 
The only difference between Morrissey's lawyer, and myself is that I wasn't paid for my legal advice. I could have lost the trial as well as he did.
The only one here who should be called an ignorant idiot is you, if you had anything intelligent to say on the subject, you wouldn't result to name calling.
 
Moron! The other difference is that his lawyer is licensed to give legal advice, if you did..that would be illegal but again you are an ignorant f***er.

And I always result to name calling because it's the only lingo jackmutts like you would understand.

Understand? probably not since you are a smelly c*** anyhow you f***ity f***f***! You are a first class knucklehead.

Tip of the day: You cannot give legal advice unless you are an attorney (does not include pro se clients).
 
That's the most absurd thing I have ever heard.
Then again, should I expect more from you? I should probably expect less.

I can give legal advice to anyone, who cares to listen, however I need a license to represent someone in court.
If I give legal advice while pretending to be a lawyer, that would be illegal.

When defaming and vilifying someone's name, one should always seek legal advice.
I suggest you do the same.

Tip of the day: Don't ever pick on anybody you don't know - you don't know who you're messing with. Someday you might get sued or even worse.
(Friendly advice).

> Moron! The other difference is that his lawyer is licensed to give legal
> advice, if you did..that would be illegal but again you are an ignorant
> f***er.

> And I always result to name calling because it's the only lingo jackmutts
> like you would understand.

> Understand? probably not since you are a smelly c*** anyhow you f***ity
> f***f***! You are a first class knucklehead.

> Tip of the day: You cannot give legal advice unless you are an attorney
> (does not include pro se clients).
 
My advice...(friendly advice as you say):

Suck my dick bitch!

And no you f***ing moron, you are not protected just because you are not in court. Honestly...be quiet if you don't know the pitch donkey nuts.
 
Come on and make me stop giving legal advice. I'm quite sure you're not a lawyer, maybe you're a judge (Weeks is that you?).
Go down to the police station, I'm sure they would appreciate a good laugh as well.

Why would I want to suck your dick? I'm not a homosexual, please stay with your
own kind.

> My advice...(friendly advice as you say):

> Suck my dick bitch!

> And no you f***ing moron, you are not protected just because you are not
> in court. Honestly...be quiet if you don't know the pitch donkey nuts.
 
homophobic and still incorrect

You are a nimrod..that makes 3 strikes.
 
Re: homophobic and still incorrect

> You are a nimrod..that makes 3 strikes.

You're out!
 
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