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Archive for the ‘Exemptions’ Category

Former British Prime Minister William Gladstone (1809-1898) is generally credited with coining the phrase, “Justice delayed is justice denied.”

Anyone who has had the misfortune of navigating our legal system in a civil lawsuit is keenly aware of the relevance of Gladstone’s insightful observation, especially if an individual should find himself pitted against the unlimited financial and manpower resources of, say, state government.

No one knows that better than three individuals who have seen their cases languish for as long as eight years with no resolution in sight. Murphy Painter, Corey DelaHoussaye and Billy Broussard have found the state attempting to ground them into submission through a flurry of legal motions.

The state has taken a page out of the playbooks of Allstate and State Farm in the aftermath of Hurricane Katrina: Delay, deny, defend. Like those billion-dollar insurance companies, the state can afford to drag a case out indefinitely in the hopes of either demoralizing or bankrupting a plaintiff.

For those who insist that every person is entitled to his day in court, there is an equally compelling argument that justice can be bought. In criminal matters, the wealthy defendant who steals millions from his company or the politician who runs off a bridge, killing his female passenger, has a far better chance of avoiding a lengthy jail sentence—or any at all—than, say, some down on his luck individual who has the misfortune to getting caught with a joint. That’s because he can’t afford the legal representation and extracted courtroom fight as can those with greater resources.

LouisianaVoice will examine the legal pitfalls encountered by each of the three persons mentioned above in separate stories beginning today in an effort to show how the state drags out these cases as a tactic to wear down their finances and their will to keep fighting.

In the case of Murphy Painter, Bobby Jindal tried to set him up on bogus charges way back in August 2010 when he wouldn’t bend to the wishes of the late Tom Benson, a major contributor to Jindal’s political campaign, over a licensing issue. In our initial 2013 story about the prosecution, LouisianaVoice was the only media outlet to say publicly—and correctly—that Painter was being SET UP by Jindal.

Subsequent to that, we learned that the WARRANT executed on Painter’s ABC office was illegal in that the raid was carried out three days before the warrant was signed by Judge Bonnie Parker.

But that didn’t stop Jindal from pursuing criminal charges against Painter. He was indicted on 42 separate counts of computer fraud. But despite Jindal’s marshaling all the resources of state government against Painter, he was acquitted and the state had to pay his legal fees of $474,000—and that didn’t even take into account how much the state spent on his prosecution.

We will return to the state’s legal fees momentarily.

But first, let’s move to August 2011. That’s when Painter filed a lawsuit against the state, the Department of Revenue and Taxation, former Secretary of Revenue and Taxation Cynthia Bridges and Inspector General Stephen Street

It’s been eight years now and Painter’s lawsuit is no closer to a trial than it was in 2011.

Attorneys for the state have responded with stalling tactics that have taxed the patience of presiding judge who, out of exasperation, complained that Painter’s lawsuit had become so clouded by the state’s defensive maneuvers, motions, denials, and delays that the case had become impossible for any legal scholar to follow.

Just like the state planned it.

Justice delayed is justice denied.

Lost in all this is the issue of just how much of taxpayers’ money the state is willing to spend in order to break an adversary who was railroaded for political purposes in the first place.

After all, if his lawsuit had no merit, it would seem the state would be eager to go trial and get the matter settled once and for all. That alone would save untold thousands of dollars. But all too often, defense attorneys with political connections are given contracts to defend these lawsuits. It’s a lucrative arrangement: the attorneys contribute generously to political campaigns and they are rewarded with contracts to sit on a case for a few years—all while the meter is running, of course.

Efforts have been made to learned just how much the state has spent in defending Painter’s lawsuit but the state says that information is protected under the public information statute.

For that matter, we have even been unable to learn how much the state spent in legal fees in its criminal prosecution against Painter. We know his legal fees of near half-a-million dollars were awarded but the state had shielded from view the amount it spent in the criminal prosecution on the grounds the ongoing civil suit prohibit the release of that information.

In fact, there is a provision tucked away in the statute [R.S. 44:4 (15)] which exempts divulging current legal fees in litigation to anyone except the chairman and vice chairman of the Joint Legislative Committee on the Budget and that committee litigation subcommittee.

So, basically, the taxpayers who ultimately foot the bill for defending otherwise indefensible litigation are kept in the dark by state statute from learning how their tax dollars are wasted on years of costly legal maneuvers designed to frustrate and short circuit a system supposedly designed to allow the average citizen to seek redress for wrongs committed against them.

The exemption shielding this information notwithstanding, the citizens of Louisiana should have a right to know when the state deliberately draws out litigation in which it is a defendant with definite exposure—all as a ploy to exhaust the plaintiff physically, mentally and financially. A key element in the equation is the right to know how much taxpayer money is being lavished on contract attorneys who happen to have the right political connections,

A New York Appellate Court judge wrote in a 1968 case, “Public opinion, which is the most effective check on official abuse, can never be aroused (if) any and all acts of such an official are protected either by a veil of secrecy or the critic is subjected to costly litigation.”

William Gladstone would probably agree.

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State Rep. Alan Seabaugh (R-Shreveport) has been kind enough to offer LouisianaVoice a clarification of Monday’s STORY about House Bill 346 which would have given civil service fire and police personnel the right to actively participate in and contribute to political campaigns to the exclusion of all other civil service personnel.

While Seabaugh was in agreement to our assessment that HB 346 was a bad bill, he pointed out that it was in fact the House and Governmental Affairs Committee that actually debated the merits of the bill and passed it unanimously to send it to the House floor.

LouisianaVoice said it was sent to the floor by the unanimous vote of the House Civil Law and Procedure Committee.

In fact, the Civil Law and Procedure Committee was only voting on the ballot language as all constitutional amendments are required to go to that committee for approval of ballot language.

The gist of our story was that seven of the nine Civil Law and Procedure Committee members either changed their votes to vote against the bill or did not vote when it got to the House floor.

That point didn’t change appreciably, however, confirming our initial position that approving the bill in committee and then changing votes on the House floor sends the wrong signals about legislators’ real motives and the courage of their convictions.

While all 13 members of the House and Governmental Affairs Committee voted to send the bill to the full House, six of those still changed their votes to no when it came to a full House vote, which failed, 29-84.

Representatives voting for the bill in committee but switching to no in the full House vote were committee Chairman Gregory Miller (R-Norco), Vice Chair Stephen Pugh (R-Ponchatoula), Ryan Bourriaque (R-Abbeville), Jimmy Harris (D-New Orleans), Dorothy Hill (D-Dry Creek), and Ed Larvadain, III (D-Alexandria).

Voting yes in both committee and on the full House vote were Reps. Roy Daryl Adams (I-Jackson), Lance Harris (R-Alexandria), Dodie Horton (R-Haughton), Barry Ivey (R-Baton Rouge), Sam Jenkins (D-Shreveport), John “Jay” Morris (R-Monroe), and Mark Wright (R-Covington).

Here is the full text of Rep. Seabaugh’s email:

From: Seabaugh, Rep. (Chamber Laptop) <aseabaugh@legis.la.gov>
Sent: Wednesday, May 22, 2019 6:35 AM
To: louisianavoice@outlook.com
Subject: Dodie Horton’s HB 346

I would like to start by telling you that I completely agree with your analysis of the bill. However, the portion of your article that references the actions of the Civil Law and Procedure committee is slightly inaccurate. The bill was originally referred to the House and Governmental Affairs committee who were the ones that the debated the substance of the bill and decided whether to send it on to the House floor for a full vote. It came out of that committee unanimously. I’m sure some of those members also voted against the bill on the floor so you could make the same point with respect to the Members of that committee. However, the House Civil Law committee was only voting on the ballot language. All constitutional amendments must to go to the Civil Law committee for approval of the ballot language. The committee does not have the authority to amend the bill or to kill the bill. All the committee can do is change or approve the language which will appear on the ballot when the measure is placed before the voters in the fall.

If you will go watch the video of the committee hearing, you will see that I handled the bill for representative Horton and explained that I was not for the bill and that I did not support the measure but that I was merely handling it for her to get the ballot language approved. Therefore, the unanimous vote by the Civil Law committee was not an approval of the substance of the bill. It was only a vote affirming that the ballot language fairly and accurately explained the substance of the bill.

 

Alan Seabaugh

Louisiana State Representative, District 5

401 Market Street, Suite 1120

Shreveport, LA  71101

Office (318) 676-7990

Fax (318) 221-0656

Aseabaugh@legis.la.gov

 

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To some readers, this will come under the heading of extremely old news.

To others, it will be a revelation well worth the time to read if for no other reason than to remind us how those in positions to do so tend to take care of their own.

I’m talking about House Bill 1351 of the 2004 legislative session—14 years ago.

It was what insiders to the legislative process sometimes refer to as a snake because it is sneaked into the process as an apparently innocuous piece of legislation. In reality, however, it is a self-serving bill that does nothing to benefit the general population but which serves the purposes of only a small minority, a mere fraction of the population: those in control of the system.

Signed into law by Gov. Kathleen Blanco after passing both chambers unanimously (with five absences—four in the House and one in the Senate), and authored as HB 1351 by then Rep. Taylor Townsend, the bill gave sweeping powers to legislators and staff members to literally snub their collective noses at the authority of state courts.

Should you ever be subpoenaed as a witness or a defendant in a civil or criminal matter, you had best be in court clad in the proper attire, with a respectful attitude and at the appointed time lest you bring the wrath of the presiding judge down upon your spinning head. Try to ignore that subpoena or otherwise buck the system and you’re likely to be shown your new quarters in a local holding cell and with a special new nom de plume, courtesy of the occupants already there: “Fresh Meat.”

Unless you serve in the legislature or are employed by same.

In strict legalese, Act 873, which is formally referred to as R.S (for Revised Statute) 13:4163, is an “Ex parte motion for legislative continuance or extension of time, legislators or employees engaged in legislative or constitutional convention activities.”

In plain English, it’s a doctor’s excuse to skip class for extended periods of time.

With a not from appropriate authority, i.e. the clerk of the House or secretary of the Senate, a legislator or a legislative staff member, when subpoenaed for a court proceeding, may thumb his or her nose at the judge because the STATUTE gives them that authority over a court order.

It says so, right there in the second paragraph: “A member of the legislature and a legislative employee shall have peremptory grounds for continuance or extension of a criminal case, civil case, or administrative proceeding…The continuance or extension shall be sought by written motion specifically alleging these grounds.”

The statute also says the continuance (legal term for delay) is for the benefit of the legislator or legislative staff member “and may only be asserted or waived by a member or employee.” It even applies of the legislator is an attorney who enrolled as counsel of record in the court matter.

In other words, someone with important business before the court will just have to cool his heels while his attorney/legislator tends to more important matters, i.e. taking care of campaign contributors like oil and gas companies, nursing homes, pharmaceutical firms, banks and members of the Louisiana Association of Business and Industry (LABI) and the American Legislative Exchange Council (ALEC) by making sure they are not overburdened with silly requirements to pay their fair share of taxes.

And you surely wouldn’t want your legislator missing out on a fine supper at Sullivan’s or Ruth’s Chris, a gala crawfish boil or some other after-hours function because he was hung up in court representing some poor nobody in a criminal case or civil lawsuit.

Boy Howdy, talk about rank having its privilege.

This exemption even extends to legislative committees and/or subcommittees in addition to legislative sessions and constitutional conventions (the last one of those, by the way, was in 1974 but hey, why take chances?).

So next time you’re required to be in court as a plaintiff, defendant, legal counsel for either side, or a jury member, just be thankful you aren’t a legislator so heavily burdened with the state’s pressing business that you would have to decline the judge’s invitation to attend.

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Jimmy Buffett sang about clichés and we hear them every day:

  1. Life’s not fair. We learn that quickly in our lives.
  2. Those who make the gold make the rules: a subsection of Number 1.
  3. What’s good for the goose is good for the gander. Well, not necessarily.

Here’s another one: Get over it. That’s what those with the gold would tell us.

What’s the point of all this?

Well, for starters, the average salary for state classified (Civil Service) employees in Louisiana was $44,737 per year in 2017. After four years of virtually no growth, the 2017 average salary represented a 6.3 percent increase over the four years of 2010 through 2013 (2.1 percent per year), when the averages were, in order, $42,187, $42,208, $41,864, and $42,140.

If you followed those figures closely, you saw that the average salary for classified employees actually decreased by $47 from 2010 to 2013.

Contrast that with the average salary for unclassified (appointive) employees. Those average salaries increased by $1,565 (2.5 percent) from $61,861 in 2010 to $63,426 in 2013 and were $65,357 in 2017, a difference of $20,620 over their classified counterparts.

Okay, it’s somewhat understandable that unclassified employees would make 46 percent more than their counterparts. They are, for the most part, in managerial positions, after all.

For the most part. But it’s important to keep in mind that these appointees are there only as long as the governor. Generally, a new administration brings in its own personnel to replace those of the previous governor.

Unclassified employees are generally along for the ride and they’re basically temporary employees who come into an agency knowing little of its workings or its personnel. Others are just political hacks who were awarded jobs for supporting the right candidate. The classified, or civil service employees, the ones who do the actual work of keeping the state running, are career employees there for the long haul.

Article X, Paragraph 9 of the Louisiana State Constitution lays out some specific prohibitions for classified employees:

Prohibitions Against Political Activities:

(A)”No…employee in the classified service shall participate or engage in political activity; make or solicit contributions for any political party, faction, or candidate; or take active part in the management of the affairs of a political party, faction, candidate, or any political campaign…”

(C) “As used in this Part, ‘political activity’ means an effort to support or oppose the election of a candidate for political office or to support a particular political party in an election.”

These restrictions were put in place to protect classified employees from pressure from political bosses to ante up campaign contributions or to campaign for a particular candidate. But they also placed limits on other outside activity.

But, no matter how closely you study the Constitution, Civil Service, or Ethics Commission rules, you will not see any reference to activity restrictions on unclassified employees

So, why are the rules that govern ethics and conflicts of interest for classified employees different than for unclassified employees? Why is there an uneven playing field?

Take, for example, the case of Andrew Tuozzolo. He’s the Chief of Staff for Rebekah Gee, Secretary of the Louisiana Department of Health (LDH).

Tuozzolo, who was hired on Feb. 1, 2016, and who earns $105,000 per year, is the manager of WIN PARTNERS, LLC, of New Orleans, a political consulting firm.

By its very name and function, Win Partners necessarily involves its manager in political activity such as supporting candidates, soliciting contributions and taking part in the management of affairs for political candidates.

And it’s perfectly legal—because he’s unclassified.

Incorporation papers for Win Partners were filed with the Secretary of State on Aug. 18, 2010, and the firm began receiving fees almost immediately. Since Sept. 1, 2010, only two weeks after it was incorporated, Win Partners, and to a much lesser extent, Tuozzolo personally, have combined to receive $1.95 million in fees from candidates and political action committees.

Some of those candidates included State Reps. Walt Leger, Austin Badon; State Sens. Karen Carter Peterson, Butch Gautreaux, and Jean Paul Morrell; New Orleans City Council members Joseph Giarrusso and Helena Moreno, New Orleans Mayor Mitch Landrieu, and at least one statewide candidate (Buddy Caldwell).

Since his hire by Gee on Feb. 1, 2016, Win Partners has slowed somewhat in activity but that can be attributed mainly to the fact that the only major elections were for New Orleans municipal offices.

Since beginning his employment with LDH, Win Partners has collected $36,900 in fees for working in the campaigns of Moreno, Giarrusso, and Leger.

Without even taking into consideration the question of when he would have time to devote to a political consulting company, the work itself is enough of a conflict of interest to get a classified employee fired.

And then there’s the matter of Dr. Harold D. Brandt who, from April 7, 2016 to Sept. 2, 2017, served as the Medical Vendor Administrator for LDH. Brand’s salary was $156.25 per hour which, based on a 40-hour week, comes to $6,250 per week, or $312,500 for a 50-week year, allowing a couple of weeks for vacation.

Begin Date End Date Agency Job Title Biweekly Pay Rate
9/2/17 Present Resignation
4/7/16 9/1/17 LDH-Medical Vendor Admin Physician IV $156.25/hour (4/7/16 to 9/1/17)

 

The only problem with Brandt’s serving as the Medical Vendor Administrator for LDH is that he also is on the STAFF of Baton Rouge Clinic.

Since April 7, 2016, Dr. Brandt’s date of employment, Baton Rouge Clinic has received more than $83,000 in PAYMENTS from LDH.

If, as the LDH Medical Vendor Administrator, Dr. Brandt’s duties included approval of vendor payments to Baton Rouge Clinic, that would place him in a position of a potential ethics violation, unclassified or no, but only if he owned greater than a 25 percent share of Baton Rouge Clinic.

The wording of the ethics laws says if an employee owns greater than 25 percent of a business, that enterprise is prohibited from doing business with the employee’s agency. Dr. Brandt likely does not hold a 25 percent interest in Baton Rouge Clinic but he certainly has a financial stake in its serving as a vendor for the state.

That 25 percent interest certainly didn’t come into play with one classified employee a few years back. A state vendor sent her, unsolicited, a baked ham for Christmas. It was delivered to her office unbeknownst to her. She was fined $250 by the Ethics Commission.

That’s because classified employees are prohibited from accepting anything of value (other than a meal, to be eaten at the time it is given) from vendors.

But unclassified employees running a political consulting firm on the side or monitoring payments to a clinic where he is employed apparently are okay.

So, there’s no point in even discussing legislators who purchase season tickets for LSU and Saints football and Pelicans games, leasing luxury cars, or who even pay personal income taxes from campaign funds—all prohibited on paper but certainly not enforced.

Is a level playing field really too much to ask?

At the end of the day, ethics violators are as thick as thieves but it’s just the low hanging fruit that the Ethics Commission, the OIG and the Attorney General’s offices go after—like a kid in a candy store. The tough cases they avoid like the plague. If they would only think outside the box, there’re plenty of fish in the sea for them to go after if they’d just take the tiger by the tail.

(How many clichés did you count in that last paragraph?)

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One of LouisianaVoice’s regular readers commented on Wednesday’s post that “half of Congress is occupied by communists” and “half of the supposed ‘good guys’ are swamp creatures that lie to get elected (only half?) and don’t really want the change that got them elected.”

And then he wrote, “Lay off of Trump. You sat by for 8 years as Obama raped and pillaged our country. He turned the IRS and intelligence agencies against us. He made deals with Iran as they chanted ‘death to America.’ Trump isn’t anyone’s savior but at least I don’t have to wonder if he truly hates this country like I did with Osama…I mean Obama.”

Oh dear, where to start? First of all, he every right to his opinion and the right to express it. But saying that “half of Congress is occupied by communists” is such an all-encompassing, paint-em-all-with-the-same-broad-brush kind of generalization that is all too common to people who go off on tangents and post unsubstantiated comments such as that. How can anyone say half of the 535 members of the House and Senate are communists when at the very most, he may have met a half-dozen of them for five minutes? That is such an inane comment that it really doesn’t even warrant dignifying with a rebuttal, so I’ll just leave it at that.

Obama “pillaged our country”? Just how, exactly, did he “pillage” the country? As I recall, Enron self-destructed in 2003, the housing bubble burst, Lehman Brothers went belly up and Bank of America acquired the cratering Merrill Lynch in 2008 near the end of George W. Bush’s term. Moreover, the entire affair was precipitated by the deregulation of financial institutions during the Reagan years.

True enough, Obama’s attorney general, Eric Holder, refused to prosecute the Wall Street bankers who brought on the collapse. That much I’ll give you and I still harbor resentment toward both Obama and Holder over that colossal malfeasance in failing to go after those thieves. You just know if some street thug had robbed a bank of a hundred bucks, he’d see hard time. Yet, those bankers stole billions—and walked away. Some were even paid bonuses of tens of millions of dollars for their trouble.

(You’d think we would’ve learned our lesson with the savings and loan debacle back in the final two decades of the Twentieth Century. William Black even wrote a prophetic book called The Best Way to Rob a Bank Is to Own One. Who knew then that the S&L collapse would reoccur on a much larger scale with the investment banks?)

And that “deal” with Iran is apparently the $150 billion Trump said Obama “gave” Iran. Pulitzer Prize-winning POLITIFACT says Trump got the name of the country right but that was about the extent of his accuracy. The $150 billion, you see, was Iran’s to begin with but had been frozen under several economic sanctions levied against the country. The money—their money—was released following verification by nuclear inspectors that Iran was complying with an agreement to curb its nuclear program. I suppose, though, if our reader got his information from BREITBART, he would have a somewhat different take on the whole affair.

And I just flat-out refuse to hold Obama responsible for the federal government’s response to Hurricane Katrina as some of Trump’s supporters continue to do. After all, the man wasn’t even president then and had only been in the Senate eight months. I actually heard one woman in Denham Springs mutter in disgust, “Thanks, President Obama” when she found the post office closed on Columbus Day—a federal holiday since 1968.

Finally, in response to the request to “lay off of trump”: not a chance in hell.

He has the chutzpa to question Obama’s loyalty to this country while choosing (typically of the TrumpCult) to overlook the fact that Trump has feuded with CNN, MSNBC, Time magazine, Elizabeth Warren, Jeff Flake, Bob Corker, Hispanics, and The New York Times—but strangely never with the Nazis, David Duke, Jason Kessler, or Vladimir Putin. All of which begs the question of where Trump’s loyalties lie.

Nope, I’m not going “lay off of Trump,” or the rest of the Repugnantcan gang of thugs who want to award generous—and permanent—tax breaks to the wealthy while doling out meager temporary breaks to the middle class and the poor.

  • Especially when Trump and his EPA Administrator have proposed the repeal of the Clean Power Plan which will give the go-ahead for polluting companies to pollute even more. That EPA administrator, Scott Pruitt, you may remember, filed numerous suits against the EPA while Oklahoma attorney general which, I suppose, somehow makes him the perfect candidate to run the agency. Maybe I should sue Microsoft in hopes of being named the new CEO.
  • Especially when Trump appoints his budget director Mick Mulvaney to head the Consumer Financial Protection Bureau created by (ahem) the Obama administration to protect Americans from predatory lenders and faulty mortgages—like the very ones that nearly brought down the world economy in 2008. Mulvaney, by the way, once called the bureau “a joke…in a sick, sad way.”
  • Especially when I read a story from 24/7 Wall Street just this week about the top 50 corporations that park their assets offshore. Of those 50 companies, which have a combined $1.7 trillion stashed in overseas accounts, 10 are healthcare and pharmaceutical companies, three are big oil, two are insurance giants, five are military contractors, five are computer companies and internet providers and 11 (count ‘em) are financial companies—many of the ones whose criminal activity (never prosecuted by Attorney General Holder) brought about the 2008 crash that necessitated the federal bailout.

Those 50 corporations, along with all the others, no doubt, have located enough loopholes to make their 35 per cent tax rate. Despite their bitching and moaning that the rate is too high, the 50 averaged just over 25 percent in effective tax rates.

  • AIG, one of the companies that gave us the 2008 recession, for example had an effective tax rate of minus 5 percent, meaning it not only paid no taxes, but actually got money. Likewise, General Motors had an effective rate of minus 32.9 percent.
  • Morgan Stanley, another of those Wall Street bankers who torpedoed the economy, had an effective tax rate of 17.2 percent, less than half the supposed rate of 35 percent. Bank of America, yet another of the rogue Wall Street bankers, had an effective tax rate of 17.9 percent.
  • The pharmaceutical company Allergan had an effective tax rate of zero.

What was your personal tax rate again?

Just take comfort in the knowledge that the biggest tax breaks under this bill go them that got—corporations and the filthy rich.

The wealthiest 1 percent of people worldwide have more wealth than the rest of the earth’s population combined.

Just eight individuals possess more wealth than 3.6 billion people—half the world’s population.

True, not all of those live in the U.S. But let that sink in and be proud for those who will realize the most generous tax breaks under this bill. But don’t take my word for it. See for yourself by clicking HERE. (Be sure to scroll down to the illustration of the spheres of influence.)

Trump and the Republicans in Congress, having failed in every effort to repeal Obamacare, are now so desperate to accomplish something, anything, before standing for reelection next year (the full House and one-third of the Senate), that they are flailing away like a blindfolded man in a martial arts tournament in a near-hysterical effort to get this ill-advised tax bill passed.

Those who proudly call themselves advocates of good ol’ American capitalism will rail against the redistribution of wealth, spitting out the term as if it were a vulgarism of the vilest sort. But a dramatic redistribution of wealth has been taking place for the past several decades. And it has been—and continues to be—redistributed upward, not downward. That’s the dirty little secret they will never discuss because that kind of redistribution is perfectly okay.

And know, too, that there is only one reason to park money offshore: to dodge taxes.

How much do you have sheltered in the Cayman Islands? Or Aruba? Or Belize?

Didn’t think so. Yet, it is the white middle class and white working poor, the ones who make up the core of the 35 percent that comprises the TrumpCult, who are being screwed by this clown and the Republicans in Congress.

And the saddest part is they don’t even know it.

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