In the recent TLS I have an essay on Benn Steil’s new book on Bretton Woods. Unlike some notices, mine is critical. You can read mine here. If you’re interested in the theory, put forward in Steil’s book, that Harry Dexter White caused US intervention in World War II, read below the fold. If you’re more interested in the late Baroness Thatcher, please carry on down to the other posts for today.
For a quick primer on where I stand on Bretton Woods, here’s an excerpt from the TLS:
…the Great Depression showed that the gold standard came at a price – it bound governments to worsen the economic slump, forcing prices to fall further by seeking to preserve convertibility to gold. As countries left gold – Britain went off in 1931, the United States in 1933 – they began to recover from the crisis. The Bretton Woods system acknowledged this lesson by permitting nations to adjust the peg that fixed their currencies to each other in case of need.
To prevent such adjustments from coming too often, members chipped in to the International Monetary Fund, on which they could draw to cover short-term international imbalances.
And to enable more nations to join the system, signatories also contributed to the International Bank for Reconstruction and Development (generally known as the World Bank) which would guarantee and make loans to rebuild war-torn countries and develop poor ones.
Thus the exchange rate regime would establish a prosperous status quo of trade at levels that would ensure full employment and high real incomes; the Fund would help maintain this status quo; the Bank would ensure over time that more nations could join the ranks of the prosperous and participate in this status quo.
The Bretton Woods system operated for twenty-five years, until in 1971 the United States, under President Richard Nixon, abandoned it. The Bretton Woods era saw low, stable inflation rates and high, stable economic growth. Indeed, the economic historian Michael Bordo’s comparative examination of monetary systems (including the old gold standard and the modern regime of floating currencies) shows that Bretton Woods performed “by far the best on virtually all criteria”. Capitalism has never looked more attractive than during this short happy period.
Which puts a sharper point on one of the most peculiar, if not poignant paradoxes of Bretton Woods: its major US architect was a Soviet spy.
So, to be clear, I wouldn’t argue that Bretton Woods was without flaws. But Steil says that Bretton Woods was “an economic apocalypse in the making”. (If you missed the apocalypse, it isn’t here yet. You have to wait.) And like Steil – and nearly everybody else – I think Harry Dexter White passed information to the Soviets. (To be precise, I think there is good evidence he passed information to the GRU in the middle 1930s and then to the NKVD (the later KGB) in the middle 1940s. I lay out some this story in the TLS essay.) Steil thinks White was not only a Soviet spy, but that he caused US intervention in World War II to benefit the USSR.
The story that Steil gives is dubious on its face. An NKVD officer, in his memoirs fifty years onward, remembered having lunch with White in May 1941 and asking him, “Did the United States recognize the Japanese threat, and was it determined to do something to counter Japanese aggression?”
Now, there are problems with the story already. Leave aside the source being a much-after-the-fact memoir. Note that the date is May 1941 – this is the month after the Soviets signed a neutrality pact with Japan, and a month before the Germans violated their neutrality pact with the Soviets. There is therefore no obvious reason why the Soviets should at this point want the US to go to war with Japan, let alone be anxious for it, as they are in Steil’s account. To be sure, one might concoct an explanation as to why this might be so, but Steil doesn’t, and should.
White did, in mid-1941, write a memorandum about US relations with Japan. At this time he was an assistant to the Treasury Secretary, Henry Morgenthau, Jr. Morgenthau was certainly close to Roosevelt, but he was (to repeat) the Secretary of the Treasury, not of State. Which is to say he was not at the center of US-Japan negotiations at this time. (Harvey Klehr notes this here.)
Steil’s argument is that the concessions which White’s memo asked of Japan “were unrealistic; the Japanese would never accept them. This, at least, was what Soviet intelligence was counting on.” Thus, if the White memo were presented to Japan it would ensure a war – that’s what the Soviets meant to happen. White thought the opposite, saying he aimed at “the successful transformation of a threatening and belligerent powerful enemy into a peaceful and prosperous neighbor.” So if he was acting as a Soviet agent because the Soviets wanted the US at war with Japan, he was not acting very effectively.
White presented his memo to Morgenthau; Morgenthau sent it to State; some of its language did find its way into a communiqué. As the historians William Langer and Everett Gleason write, it would “lose its identity and become merged in the final draft of a State Department document” – a memorandum from Hull to the Japanese presenting ten points, delivered on November 26.
Steil says that “That White was the author of the key ultimatum demands [i.e., those of November 26] is beyond dispute.” Clearly this statement is untrue; historians do not generally believe that White was the author of this document.
Moreover, it is not “beyond dispute” either that this document was “the key” document, or even an “ultimatum” in the run-up to Pearl Harbor. As Roberta Wohlstetter writes,
… the documents of these critical days in November make clear that history has many candidates for the “initial incident” in the last moments of tension before war, and what finally sparks the explosion is largely a matter of accident. When Secretary Hull presented his Ten Point Note, the Pearl Harbor task force had been under way for 24 hours.
So, contrary to Steil, I do not know of any reading of the scholarship, however charitable, that can justify Steil’s use of the phrase “beyond dispute”.
Then there is the question of sourcing. For his Pearl Harbor section, Steil relies on the decades-later reminiscence of an NKVD officer, as noted, and on the 2002 book by Jerrold and Leona Schecter, Sacred Secrets. There’s a problem with that, though. John Earl Haynes and Harvey Klehr describe the Schecters’ work as showing how
faulty memories, Soviet intelligence agency disinformation campaigns, sloppy citations, misplaced trust in documents provided by unidentified sources under unexplained circumstances, egregious lapses in logic and judgment can lead to conclusions unsupported by evidence.
The Schecters deposited the documents on which they depended in the Hoover library, to be available after ten years. Haynes and Klehr looked at them when they became available, and published their findings in 2011.
We did … find four purported KGB documents that internal evidence clearly indicates are inauthentic. All four documents purported to report on the espionage activities of Harry Dexter White, a senior US Treasury official who cooperated with Soviet intelligence in the 1930s and 1940s.… Sacred Secrets uses three of these fake documents in sections of the book dealing with Harry White. We do not suggest that the Schecters are responsible for creating these inauthentic documents or were aware of their inauthenticity and presume their unidentified suppliers of purported KGB material are the responsible parties. The Schecters, however, should have checked.…
Steil should have checked his sources, too. Haynes and Klehr say in that passage, it’s worth noting, that they’re sure that White spied for the Soviets. Yet they do not find the Schecters reliable.
The tale that White played an instrumental role in causing the Pearl Harbor attacks is so far from “beyond dispute” that cursory attention to scholarship would have tempered any such declaration.
Furthermore, what does it have to do with Bretton Woods? Steil gives it an extended section at the conclusion of his chapter introducing Harry Dexter White. But it is hard to understand why. These stories about White originate with scholars who thought US involvement in World War II was a terrible idea.
The war against Japan upset the whole structure of the international balance of power in Asia. The United States destroyed the one power that was able to check the flow of that Red tide in the Far East.… With the fall of Japan the last barrier to Russian domination of the Far East was removed.… The present Soviet military might, which threatens our national security, is the direct product of billions of lend-lease aid, coddling of Communists in high places in the American Government and failure to understand the basic drives of world Communism.
I do not think that Steil believes the war against the Axis was a bad idea. But I do not know what he does believe that makes the implausible Pearl Harbor story an important part of his book about Bretton Woods.
Then there is the whole thing about gold. But I’ve gone on too long already; maybe more on that another time.
{ 26 comments }
Mitchell Freedman 04.09.13 at 3:47 am
I for one think that we are wrong to not give HDW the benefit of the doubt we give to the Dulles brothers, who could be made out to be Nazi or Fascist agents, before, during and after World War II, when we use the same nomenclature as we use for those on the so-called “Left.”
HDW wanted the Soviets to join the IMF. He wanted the Soviets to be working with (and therefore under) Western bankers. He stood for the US interests above England’s and also above the Soviets’ interest. The British had no choice but to capitulate to what the US government, through White was demanding, while the Soviets did not. As Chambers noted in “Witness,” even HDW’s handler’s contact in Moscow said HDW gave nothing of value to the Soviets. It was mostly arcane monetary and economic papers that the Soviets found, frankly, too confusing to understand.
To compare White to a true Soviet spy like Julius Rosenberg would be gravely wrong.
I wish people would read R. Bruce Craig’s book on HDW. Steil, unfortunately, misleads his readers in attacking Craig’s book. It does state at the end of Craig’s book, for example, something about HDW’s “mother country” and mentions Russia, but in the beginning of Craig’s book it states that HDW was born in the US in Massachusetts. The late reference was a colloquial turn of the phrase that is a sad editing error.
The second criticism of Craig concerns Craig saying, at page 111 of his book on HDW, a person’s membership in the Communist Party was “largely irrelevant” to White. Mr. Steil goes on to quote Congressional testimony from White when White was under attack as if to contradict Craig’s qualified statement. Mr. Steil quotes White as testifying that he “can understand and thoroughly sympathize with the view” that hiring Communists is bad. That is not agreeing with that view, though it could be seen as ambiguous. Steil also relies on Elizabeth Bentley on White’s “knowingly” hiring Reds at Treasury, when there is no other evidence on this score other than Bentley’s recollection. Craig’s statement is judicious and more nuanced than what Steil is on about…
Overall, White did not act in a vacuum, and acted on orders of his superiors in the US government, whether it was the US Military or Secretary of Treasury Morgenthau. To call him a spy is to give too much to the hysteria of the late 1940s and to not see that the elite in the 1930s USA had indeed chosen sides and decided which totalitarian regime to support in order to defeat another totalitarian regime. For the Dulles brothers, for George Kennan, for Joseph Kennedy, for William Bullitt, and the Morrow family, among so many others, it was more important to defeat “Bolshevism,” and that is why they each supported in varying degrees Hitler, Mussolini and Hirohito/Tojo. Yet, they were not excoriated and hounded and called spies for other governments after World War II was over–even when the Dulles brothers and Kennan were supporting rat lines to allow Nazis to escape Europe for South America.
Interesting that…
Steil’s book, the more I am reading about it, sounds like it will not be the last word on this subject, and perhaps it is time for Ron Chernow or someone with a better understanding of historical documents and cultural history, to write the book on Bretton Woods.
Harold 04.09.13 at 4:19 am
Don’t look at Allen Dulles. Look over there, at Harry Hopkins, Roosevelt’s closest adviser. Hopkins was also a spy, according to Air Force Historian Eduard Mark and other unimpeachable authorities.
Also, Margaret Fuller was identified by Elizabeth Barret Browning as a well-known red. It must be endemic to New England.
Anderson 04.09.13 at 7:23 am
Bizarre. One could make a stronger case that Dean Acheson “provoked” Pearl Harbor – tho that would still be a stretch. Pretty much the next-to-last thing the Soviets would have wanted in May 1941 would have been any stirring up of the Japanese. The last thing being what happened on June 22.
I am agnostic as to the larger issue of White’s spying, not having read up on it, but this Steil book sounds awful.
Kindred Winecoff 04.09.13 at 7:29 am
I haven’t read the book, so just a couple quick notes:
1. In terms of BW being “an economic apocalypse in the making”: this isn’t an absurd claim. Or at least it’s not unprecedented. Perhaps you’re familiar with the “Triffin dilemma”? BW had serious internal contradictions, the unwinding of which caused enormous economic instability over the next decade or so. This instability eventually paved the way for neoliberalism to take hold. Keynes understood some of these contradictions, but the Americans were not willing to concede enough power to resolve them; nor, given the experience of the 1920s-1930s, should they have. Moreover, BW effectively shut out what we used to call the global South from real participation in the global economy. During BW, dependency theory was more-or-less true. After BW, not so much (or at least *as* much). So yeah… BW was on a countdown from the day it began.
1.a. It is not talked about nearly enough that almost everything bad in what used to be called the global North — increasing inequality, the collapse of labor power in politics, the rise of finance and concomitant financial crises, the rise of neoliberalism, etc. — begins around 1971. I.e., it all starts where BW stops. This needs much more attention than it has so far gotten. Noting this does not make the contradictions of BW go away, which is why what Lindsey rightly called “Nostalgianomics” is so frustrating: the magical era of BW in which American (white male) labor got rich while no one else in the world did is gone forever. It was a particular set of circumstances which had never held before and will likely never hold again. From the perspective of the species (rather than segments of the nation) this is probably a Very Good Thing, as American labor was profiting in large part because they faced no competition. The rest of the world was destitute. The sooner the left (and right) faces up to this fact, the better.
2. I like Eichengreen well enough, but I like Beth Simmons’ comparative political history of the interwar period — *Who Adjusts?* — much better. At least I think I do… I haven’t read it in five years or so, and my thinking has gotten quite a bit weirder during that time. But I liked it back then, and I think it has some things to say about contemporary discussions concerning austerity in democracies.
Anyway, I enjoyed the review.
Mitchell Freedman 04.09.13 at 1:25 pm
I am assuming “Harold” is being sarcastic, particularly the citation of 19th Century literary icon, Margaret Fuller.
With respect to Hopkins, for those who may not be so sure of Harold’s sarcasm, see the new book on Hopkins: The Hopkins Touch: Harry Hopkins and the Forging of the Alliance to Defeat Hitler by David Roll (Oxford U Press). In the book, no less an anti-communist historian John Earle Haynes is identified as helping the author, David Roll, prove that Hopkins was not a Soviet agent.
virgil xenophon 04.09.13 at 3:44 pm
@Kindred Winekoff/
Yes, agree with you about the unique circumstances immediate post-WW II. Mary Kaldor heavily spotlights this also in her work The Disintegrating West.
ajay 04.09.13 at 4:18 pm
Note that the date is May 1941 – this is the month after the Soviets signed a neutrality pact with Japan, and a month before the Germans violated their neutrality pact with the Soviets. There is therefore no obvious reason why the Soviets should at this point want the US to go to war with Japan, let alone be anxious for it, as they are in Steil’s account.
I dunno, does that really follow? Just because the Soviets had signed a pact with the Japanese doesn’t mean that they weren’t still worried about them. It hadn’t even been two years since the last Soviet-Japanese conflict. At the very least, if the US was planning to go to war with Japan, the Soviets would want to know – it would have a major effect on their own foreign policy.
Eric 04.09.13 at 5:20 pm
Mitchell Freedman: “To compare White to a true Soviet spy like Julius Rosenberg would be gravely wrong. I wish people would read R. Bruce Craig’s book on HDW.”
I think the first statement here is correct, and there is of course a debate over trying to distinguish “agents” from “sources” and so forth. I lay out, to the best of my ability in the TLS essay, my understanding of precisely what White did. I have read Craig’s book, and of course Craig does conclude, with qualifications, that White was a Soviet spy. (Committed a “species of espionage,” I think is the phrase.)
Eric 04.09.13 at 5:21 pm
Kindred Winecoff: “what Lindsey rightly called “Nostalgianomics†is so frustrating: the magical era of BW in which American (white male) labor got rich while no one else in the world did is gone forever.”
Wait a second. This is not right. Bordo’s pretty clearly established that the BW era was good not just for the US. It may not have been best for everyone, but it wasn’t good only for the US. Maybe I’ll put up a graph. We all like graphs, right?
Anyway, glad you liked the review.
Harold 04.09.13 at 5:28 pm
“species of espionage” = I understand the Soviets considered him an “unwitting” spy. Can you be an “unintentional spy” if your motivation is, say, to defeat the Nazis and help save Jews?
Mitchell Freedman 04.09.13 at 5:35 pm
To Eric:
Yes, Craig’s book calls what White did a species of espionage. I think even that is too harsh a conclusion on Craig’s part. I wonder what we make of the conduct of the Dulles brothers after one reads the revelations in Christopher Simpson’s “Blowback” and “The Splendid Blond Beast” or even Morley’s biography of the Dulles brothers. If we run through the nomenclature we use automatically to tar anyone left of center in the New Deal era who had any discussions with Soviet representatives to see how things look on the other side of the ledger, we could say similar things about John Foster and Allen Dulles.
Your own review reveals the shortcomings of the arguments against White. What did he give of importance to the Soviets? Nothing I’ve seen or read. And the answer to your rhetorical question in the review is answered by saying White was trying to cajole the Soviets into what became the Bretton Woods system, the IMF and World Bank.
What again is missing, and I’m aware of no historian tackling this, is the cultural history of the 1930s United States where the elites had drawn sides in which totalitarian regimes to support in the short term against the other. There was also a loss of faith in open institutions and the ability of open institutions to solve problems. One sees it in the calls from Hollywood (“Gabriel Sounds his Horn” or some such film with Walter Huston) to the NY Times enamored feelings about Mussolini. That changed by 1944 or 1945 and yet only one side was demonized and hounded from government after WWII.
Eric 04.09.13 at 5:46 pm
Harold: ““species of espionage†= I understand the Soviets considered him an “unwitting†spy. Can you be an “unintentional spy†if your motivation is, say, to defeat the Nazis and help save Jews?”
Craig doesn’t think he was unwitting. And he wasn’t trying to defeat Nazis/save Jews in the 1930s.
Eric 04.09.13 at 5:48 pm
Mitchell Freedman: I’m not holding any brief for the Dulles brothers. And I’m not tarring anyone with anything. I say what I think the evidence says, re: White.
If you want to make comparisons, I would say that MI-6 was probably much more influential in the US than NKVD in the run-up to US intervention in World War II.
As for “the cultural history of the 1930s United States where the elites had drawn sides in which totalitarian regimes to support in the short term against the other” – I’m not sure that’s how “the elites” saw it. Roosevelt was an elite, and that’s not how he saw the 1930s. Nor did senior members of his administration.
Harold 04.09.13 at 6:05 pm
It seems to be a case of “Craig said, she said.”
http://www.documentstalk.com/wp/de-profundis-lauchlin-currie-and-harry-dexter-white-julius-kobyakov-evidence
Eric 04.09.13 at 6:21 pm
Harold: I agree with Craig. I’ve looked at the Vassiliev notebooks, and Venona. As I say in the TLS review, I think there’s reason to believe White felt threatened in 1944, and that’s why he talked to NKVD. But I don’t think there’s any case to be made he was unwitting.
Mitchell Freedman 04.09.13 at 6:22 pm
I apologize, Eric, if you thought I was implying you were doing a brief for the Dulles brothers. I have great respect for your writings and feel you are a kindred spirit.
I would only say, and I hope I will show restraint and not comment further, that there were elites who did choose sides. These include JP Morgan lawyer Thomas Lamont, editors at the NY Times, Alfred Sloan, Charles Lindbergh and his in laws the Morrows, again the Dulles brothers (who were the nephews of Wilson’s Secretary of State Lansing), George Kennan and a host of people in the State Department, William Bulllitt, Joseph Kennedy. That’s just for starters on the side that said Hitler was less a threat than Stalin, and who had all sorts of cozy, off the record discussions with Nazi and Fascist officials throughout the 1930s, and some of them even during the time we were at war with Fascist Italy and Nazi Germany. People also forget or don’t know about John Foster Dulles’ defense of Japanese imperial ambitions in Harper’s in the mid-1930s while Japan was doing terrible things in Manchuria and Nanking.
That FDR, Morgenthau and Hopkins did not succumb is what you and I say. However, that is not what others have said for years and years, whether it’s Herbert Romerstein, the late Eric Breindel, or others.
My point is that we need to be kinder to all these players and start to give them an equal benefit of the doubt. The nomenclature of “agent of influence,” “spies,” “useful idiot,” “dupe,” “fellow traveler,” etc. are ultimately propagandistic terms when we do not provide the more full cultural perspective of the era stretching from 1929-1945.
Eric 04.09.13 at 6:24 pm
Mitchell Freedman: No need to apologize, and I agree re: benefit of the doubt, proper nomenclature.
Harold 04.09.13 at 6:42 pm
Well, Eric, if you have read the entirely unproblematic Vassiliev notebooks and Venona and are satisfied, that settles it.
Eric 04.09.13 at 7:14 pm
Harold: saying sources are “problematic” doesn’t mean you can dismiss them out of hand. They are part of a body of evidence.
Historians actually have principles of evaluating conflicting and fragmentary evidence; there are well known books that address the subject – Marc Bloch’s Historian’s Craft and Jacques Barzun’s Modern Researcher are two of the best.
The evidence on White in the 1930s comes down pretty much to Whittaker Chambers’s word, buttressed by the memorandum Chambers had in White’s handwriting, supplemented by references to White’s serving as a source for the GRU in the Vassiliev notebooks.
The evidence on White in the 1940s comes down to Vassiliev and Venona. As to Vassiliev, for years New York is telling Moscow that White may have been a source for GRU in the 1930s but that he didn’t want to be a source now. Considering that the pressure was on New York to produce sources, one’s inclination should be to credit New York saying that White did not want to be a source now. Likewise, though, something happened in 1944 that made Moscow tell New York directly to contact White and tell him he “must” cooperate. And then the subsequent record gives us reason to believe that White did talk to a Soviet officer, at Bretton Woods and again at San Francisco.
Craig is sympathetic to White, perhaps even to a fault. Yet he cannot bring himself to believe that all this happened to an “unwitting” source. The evidence tends too much against that interpretation. At the outside, I think it is possible that White began in the 1930s as unwitting, but he could not have remained unwitting for long. And in the 1940s it seems very unlikely that he could have been unwitting at all – unwilling, perhaps – in fact, I think probably – but that’s different.
Harold 04.09.13 at 7:57 pm
I thought that when evidence was fragmentary and problematic, the principle method employed by professional historians (as opposed to interested parties, such as, say, the legal profession who are trying to make a case) was to note the fact and suspend judgment.
It was my understanding that the files that Vassiliev copied and translated have never been made available for independent inspection.
Anderson 04.09.13 at 8:03 pm
20: fragmentary & problematic evidence is the norm, not the exception. Historians, like the rest of us, deal in shades of probability.
Switching disciplines, we have nothing *but* “fragmentary and problematic evidence” for the origins of the New Testament’s gospels, but a large majority of scholars accept Marcan priority and the two-source hypothesis as the most probable theory. If and when the evidence points the other way, they’ll change their minds. Such is life.
Harold 04.09.13 at 8:16 pm
@ 21. Indeed. However in the case of the gospels, the evidence (fragmentary though it may be) is available to more than one person.
Eric 04.09.13 at 8:17 pm
Harold: “I thought that when evidence was fragmentary and problematic, the principle method employed by professional historians (as opposed to interested parties, such as, say, the legal profession who are trying to make a case) was to note the fact and suspend judgment.”
No. I recommended a couple of books for you. Here are some excerpts.
First, Bloch on Marbot.
Note that (as Anderson says), this is of course all about probability. But note Bloch’s phrasing, after judging one alternative “likely”: “The Memoirs have lied again.” Not “probably,” or “I think.”
Yes, Vassiliev took notes on files that nobody may now see. We can choose to ignore his notes, or to treat them carefully. They contain much that is corroborated in what else we know. They contain much that complicates any simple explanation. They may, of course, be a contrivance but their character, the circumstances of their production, indicate they are not.
Here, really just restating Occam’s Razor, are Barzun and Graff:
It might be true that every single one of the data pointing toward White’s cooperation with two different agencies of Soviet intelligence is, for different reasons pertaining to each one, erroneous. But it is not likely.
Harold 04.09.13 at 9:18 pm
Though I am interested in the blacklist period and have come across the subject while reading about other things, I have not gone deeply into the case of Harry Dexter White.
However, I don’t see that the question of whether White was or was not a spy resembles the problem of whether an army made camp on the left or right side of a river (this sounds a bit like the kind of question that might come up when reading the writings of Whittaker Chambers, actually). Neither is it like the problem of the primacy of the gospel of Mark.
Nor, IMO, is maintaining a mild skepticism by suspending belief until more evidence is made available (which is very likely to happen) at all comparable to “multiplying hypotheses in order to cling to a belief”. In fact, there is just as much of a likelihood that there exist some people with extrinsic personal and/or professional motives to adopt premature conclusions before the evidence is in — if one wants to go in for insinuations.
Eric 04.09.13 at 10:36 pm
there exist some people with extrinsic personal and/or professional motives to adopt premature conclusions before the evidence is in — if one wants to go in for insinuations.
Right. Which is why I wrote an essay for the TLS half devoted to explaining that it’s crazy to think HD White was in any way responsible for Pearl Harbor.
Harold 04.10.13 at 12:56 am
Well, this is a dead or dying thread, but an abbreviated version of Craig’s opinion is here: http://hnn.us/node/145913
Eric states that “Craig does conclude, with qualifications, that White was a Soviet spy.” The qualification, at least Craig’s article, “Setting the Record Straight: Harry Dexter White and Soviet Espionage,” is that White’s communications with the Soviets would not have met the legal standards of espionage in 1943. Thus he was not a spy by the standards of his time. However, Craig qualifies this by saying that by present day legal standards, his activities would today indeed constitute espionage (sort of like the paradoxical Schrödinger’s cat who was both alive and dead).
Eric believes that this assessment is sympathetic to White “perhaps to a fault.”
It would be interesting to know rather, in considering the question, what the legal standards were and how they have changed.
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