Author: TSA Press

If
you’re
in
Biglaw,
you
probably
know
it.
Oppressive
hours?
Ridiculously
high
pay
and
correspondingly
ludicrous
hourly
rates?
Soul-crushing
work
on
behalf
of
evil
corporations
and
partners
you’ve
never
met?
Check,
check,
check,
you’re
at
a
big
firm.

Plus,
you
know,
they
actually
publish
lists
of
the
largest
firms
in
the
country.
If
your
firm
is
part
of
the
Am
Law
200,
it’s
pretty
safe
to
say
that
qualifies
as
Biglaw
(though
it
notably does
not
neccessarily
mean
you’re
qualified to
actually
practice
law).

Likewise,
at
the
artisanal
side
of
the
spectrum,
we
have
a
class
of
lawyers
who
are
just
as
easily
defined:
solo
practitioners.
These
mavericks
are
carrying
the
world
on
their
shoulders,
running
their
own
businesses,
and
never
have
to
even
attempt
to
get
along
with
anyone
else
in
the
workplace
if
they
don’t
want
to.

Between
Biglaw
and
solos,
however,
there
is
a
lot
of
wiggle
room.
I
would
argue
that
two
lawyers
in
an
office
is
the
OG
version
of
a
partnership.
Then
beyond
that
you
get
into
small
firms.

Somewhere,
of
course,
between
small
firms
and
Biglaw
you
have
the
meat-part
of
the
hamburger
when
it
comes
to
the
legal
profession:
midsize
firms.
The
trouble
is,
no
one
seems
to
have
consistent
criteria
to
define
just
what
makes
a
firm
midsize.

Google’s
AI
overview
is
perhaps
as
good
a
place
as
any
to
start.
That
says
midsize
law
firms
“typically
have
between
20
and
100
attorneys.”
On
the
other
hand,
Google’s
AI
also
notes
that
some
sources
define
midsize
firms
“as
firms
with
16
to
350
attorneys.”
Hm,
that
is
quite
a
discrepancy.

Is
number
of
attorneys
the
best
way
to
define
the
size
of
a
law
firm,
though?
I
represented
a
law
firm
once
against
its
biggest
competitor
in
a
case
that
was,
in
part,
about
which
of
them
got
to
advertise
being
the
“largest”
or
“biggest”
firm
in
the
state
in
their
particular
practice
area,
and
I
promise
you,
it
was
clear
which
one
had
the
most
attorneys,
and
that
absolutely
did
not
settle
the
matter.

There
are
a
lot
of
relevant
factors
above
and
beyond
the
number
of
attorneys
a
firm
employs.
As
every
lawyer
knows,
non-lawyer
staff
do
most
of
the
work
anyway,
so
a
firm
with
a
lot
more
staff
but
fewer
attorneys
compared
to
a
competitor
might
be
legitimately
considered
to
be
a
larger
law
firm.
There
are
also
revenue
measurements,
from
total
receipts
to
profits
per
partner.

And
what
about
resources?
It
is
hard
to
quantify
what
that
means,
but
there
is
certainly
some
intangible
form
of
value
in
the
networks
a
firm
has,
from
independent
contractors
it
can
call
in
to
institutional
knowledge
about
the
local
bench
to
a
widespread
geographic
reach
with
multiple
office
locations.

We
do
know
that
midsize
firms
are tremendous
workhorses
within
the
legal
profession.
Perhaps
this
is
no
surprise
considering
that
there
are
over
9,000
of
them
in
the
United
States
employing
some
400,000
legal
professionals.

Maybe
it’s
more
about
how
firms
want
to
self-define
than
anything
else.
There
are
certainly
some
law
firms
on
the
larger
end
of
midsize
that
strive
to
climb
into
the
Biglaw
echelons,
just
as
there
are
others
that
attempt
to
brand
themselves
as
tiny
service-orientated
boutiques.
I’ve
always
thought
it’s
more
about
embracing
who
and
what
you
are
than
trying
to
be
something
else.

Midsize
firms
can
reasonably
tout
a
strong
local
presence
at
the
same
time
they
are
highlighting
their
superior
resources.
They
can
be
flexible
and
dynamic
in
the
way
bigger
firms
with
a
weeks-long
conflicts
check
process
never
can
be.
At
the
same
time,
no
midsize
firms
need
to
rely
on
the
mental
bandwidth
of
a
single
person.
Being
midsize
doesn’t
have
to
mean
a
firm
is
entrapped
in
a
purgatory
between
one
thing
and
another:
it
can
be
the
sweet
spot
that
feels
like
being
right
at
home
for
its
clients.

I
guess
I
haven’t
cleared
much
of
the
confusion
about
where
Biglaw
ends
and
midsize
firms
begin.
But
who
cares
how
some
writer
on
the
internet
defines
it?
If
you
feel
like
your
firm
is
midsize,
declare
it
loudly,
and
wear
that
label
with
pride.

---

Jonathan
Wolf
is
a
civil
litigator
and
author
of Your
Debt-Free
JD (affiliate
link).
He
has
taught
legal
writing,
written
for
a
wide
variety
of
publications,
and
made
it
both
his
business
and
his
pleasure
to
be
financially
and
scientifically
literate.
Any
views
he
expresses
are
probably
pure
gold,
but
are
nonetheless
solely
his
own
and
should
not
be
attributed
to
any
organization
with
which
he
is
affiliated.
He
wouldn’t
want
to
share
the
credit
anyway.
He
can
be
reached
at [email protected].

Ed.
note:
Please
welcome
Liz
Dye
back
to
the
pages
of
Above
the
Law.
Subscribe
to
her
Substack,
“Law
and
Chaos,” here.

“It
is
my
great
honor
to
nominate
Emil
Bove
to
serve
as
a
Judge
on
the
United
States
Court
of
Appeals
for
the
Third
Circuit,”
the
president
screeched
out
on
social
media
on
May
28.
“Emil
is
SMART,
TOUGH,
and
respected
by
everyone.
He
will
end
the
Weaponization
of
Justice,
restore
the
Rule
of
Law,
and
do
anything
else
that
is
necessary
to,
MAKE
AMERICA
GREAT
AGAIN.
Emil
Bove
will
never
let
you
down!”

So
much
for
the
wages
of
sin.

The
president’s
personal
lawyer
spent
the
past
five
months
disgracing
the
Justice
Department
and
his
professional
oath.
He
is
currently
the
subject
of
a

whistleblower
complaint
alleging
that
he
deliberately
defied
court
orders
and
instructed
DOJ
lawyers
to
do
the
same.
And
for
his
loyalty,
he’s
being
rewarded
with
lifetime
tenure
on
the
appellate
bench.

Worst
villain
origin
story
ever

Emil
Bove,
III
began
his
career
at
the
Southern
District
of
New
York,
where
he
was
by
all
accounts
a
competent
prosecutor.
His
management
style
left
something
to
be
desired,
however,
and
he
was
denied
promotion
for

“abusive”
behavior
toward
his
subordinates.

In
2022,
he
left
the
DOJ
for
private
practice,
and
the
following
year
teamed
up
with
Todd
Blanche,
another
SDNY
alum
who
left
the
white-shoe
law
firm
Cadwalader,
Wickersham
&
Taft
to
represent
Donald
Trump
in
his
criminal
cases.
The
only
one
that
went
to
trial
was
the
Manhattan
prosecution,
where
a
jury
found
their
client
guilty
of
34
counts
of
creating
a
false
business
record.
But
Trump
values
obedience
over
competence,
and
so
he
gave
Blanche
and
Bove
the
top
jobs
at
DOJ,
serving
under
another
of
his
personal
lawyers,
Pam
Bondi.

Heel
turn

Back
in
2021,
Bove
worked
January
6
cases
at
SDNY.
But
one
of
the
first
things
he
did
on
his
return
to
the
Department
was
to
launch
a
mass
purge
of
prosecutors
who
worked
January
6
cases.

“I
do
not
believe
the
current
leadership
of
the
Justice
Department
can
trust
these
FBI
employees
to
assist
in
implementing
the
President’s
agenda
faithfully,”
he
wrote
in
a
memo
obtained
by
the

Washington
Post.

As
Trump’s
personal
lawyer,
Bove
signed
his
name
to
dozens
of
briefs
lobbing
baseless
charges
of
politicization
at
the
DOJ.
But
once
ensconced
at
Main
Justice,
he
set
about
reordering
the
DOJ
to
achieve
Trump’s
political
ends.

He
tried
without
success
to

gin
up
criminal
charges
in
connection
with
billions
of
dollars
in
greenbanking
funds
allocated
by
Congress
and
disbursed
in
the
final
year
of
Biden’s
presidency.
He

threatened
to
arrest
local
officials
who
exercise
their
rights
under
the
the
Tenth
Amendment
not
to
cooperate
with
federal
immigration
mandates.
And
he
blew
up
the
prosecution
of
New
York
City
Mayor
Eric
Adams
in
hopes
of
blackmailing
the
elected
Democrat
to
enact
the
administration’s
immigration
priorities.

On
February
10,
he

ordered
Danielle
Sassoon,
the
then-acting
US
Attorney
for
SDNY,
to
dismiss
the
pending
prosecution
of
the
mayor
for
taking
bribes
from
Turkish
officials.
Bove
ordered
her
to
seek
a
dismissal

without
prejudice,
allowing
the
government
to
hold
the
threat
of
re-indictment
over
Adams
if
he
failed
to
do
what
they
asked,
particularly
when
it
came
to
immigration.

“If
a
criminal
prosecution
cannot
be
used
to
punish
political
activity,
it
likewise
cannot
be
used
to
induce
or
coerce
such
activity,”
she
wrote
in
her

resignation
letter.
“Threatening
criminal
prosecution
even
to
gain
an
advantage
in
civil
litigation
is
considered
misconduct
for
an
attorney.”

He
responded
with
an
absolutely

deranged
letter,
defending
the
propriety
of
a
political
quid
pro
quo
with
a
criminal
defendant
and
accusing
Sassoon
of
insubordination
and
dereliction
of
duty.

But
it
turns
out
that
behind
the
scenes,
Bove
was
doing
even
more
crazy
illegal
shit
to
carry
out
the
president’s
agenda.

Whistle
while
you
work

On
June
24,
the
New
York
Times
published
a

whistleblower
complaint
filed
by
former
Justice
Department
lawyer
Erez
Reuveni.
Reuveni
served
as
Acting
Deputy
Director
for
the
Office
of
Immigration
Litigation
until
April
5,
when
he
was
fired
for
telling
the
truth
to
a
federal
judge
in
the
case
of
Kilmar
Abrego
Garcia,
the
Maryland
man
wrongfully
deported
to
El
Salvador.
Reuveni
refused
to
say
that
Abrego
was
a
known
terrorist
(he
wasn’t)
and
argue
that
this
voided
the
immigration
judge’s
order
staying
his
removal
as
a
matter
of
law
(it
didn’t).

But
before
he
was
fired,
Reuveni
witnesssed
a
shocking
pattern
of
disregard
for
court
orders
by
leadership
at
the
DOJ,
particularly
Bove.

Bove
was
instrumental
in
structuring
the
rollout
of
the
Alien
Enemies
Act
proclamation
so
as
to
ensure
that
the
men
renditioned
to
CECOT
in
El
Salvador
could
never
get
due
process.
According
to
Reuveni,
Bove
instructed
the
DOJ
get
it
done,
even
if
they
had
to
disregard
court
orders:

Bove
then
made
a
remark
concerning
the
possibility
that
a
court
order
would
enjoin
those
removals
before
they
could
be
effectuated.
Bove
stated
that
DOJ
would
need
to
consider
telling
the
courts
“fuck
you”
and
ignore
any
such
court
order.
Mr.
Reuveni
perceived
that
others
in
the
room
looked
stunned,
and
he
observed
awkward,
nervous
glances
among
people
in
the
room.
Silence
overtook
the
room.
Mr.
Reuveni
and
others
were
quickly
ushered
out
of
the
room.

And
in
fact
the
DOJ

did
disregard
Judge
James
Boasberg’s
order
to
turn
the
planes
around.
Reuveni
says
that
Deputy
Assistant
AG
Drew
Ensign
lied
in
court
when
he
said
he
did
not
know
if
and
when
planes
of
detainees
were
taking
off.
Reuveni
alleges
that
“Ensign
had
been
present
in
the
previous
day’s
meeting
when
Emil
Bove
stated
clearly
that
one
or
more
planes
containing
individuals
subject
to
the
AEA
would
be
taking
off
over
the
weekend
no
matter
what.”

Bove
is
credited
with
coming
up
with
the
plan
to
allege
that
the
DOJ
complied
with
Judge
Boasberg’s
order
because
the
planes
were
out
of
US
air
space
by
the
time
the
judge
put
his
oral
order
in
writing.
Notably
Bove
refused
to
put
his
name
on
the
motion
making
this
fakakta
argument
on
the
public
docket.
And
Ensign
is
now
smack
in
the
middle
of
Judge
Boasberg’s
contempt
inquiry.

Bove
also
encouraged
the
DOJ
to
defy
another
court’s
immigration
order
in
Massachusetts.
In
that
case,
Judge
Brian
Murphy
barred
the
Department
of
Homeland
Security
from
deporting
immigrants
to
third
countries
without
notice
and
opportunity
to
object
under
the
Convention
Against
Torture.
The
government

repeatedly
defied
this
order,
including
in
one
episode
where
DHS
flew
detainees
to
Gitmo
and
handed
them
over
to
the
Department
of
Defense
to
transport
them
to
CECOT.

Reuveni
does
not
say
if
Bove
was
the
brain
genius
behind
the
plan
to
argue
that
this
did
not
violate
the
court’s
order,
since
DOD
wasn’t
a
party
to
the
case,
and
no
DHS
employees
were
on
the
plane
to
El
Salvador.
But
he
says
that
Bove
was
pissed
that
he
tried
to
comply
with
the
court
order
to
ascertain
how
this
violation
had
occurred:

Mr.
Reuveni
received
phone
call
from
Acting
AAG
Roth
in
which
Roth
relayed
that
Bove
was
very
unhappy
that
Mr.
Reuveni
had
contacted
counsel
at
various
agencies
to
ascertain
whether
DOJ
had
violated
court
order
Roth
conveyed
that
Mr.
Reuveni
should
stop
emailing
agency
counsel
on
the
matter
to
instead
communicate
by
phone
only
where
possible.46
Mr.
Reuveni
understood
this
instruction
to
be
based
on
leadership’s
aim
to
avoid
generating
written
material
subject
to
disclosure
through
FOIA.

Third
Circuit,
here
he
comes!

On
Wednesday,
June
25,
Bove
appeared
before
the
Senate
Judiciary
Committee,
which
is
considering
his
nomination
to
the
Third
Circuit.

He
opened
by
insisting,
“I
am
not
anybody’s
henchman,
I
am
not
an
enforcer.
I’m
a
lawyer
from
a
small
town,
who
never
expected
to
be
in
an
arena
like
this.”

That
is
horseshit,
of
course.
No
one
gets
to
“an
arena
like
this”
without
a
healthy
dose
of
ambition.
Note
that
Bove’s

aw
shucks
modesty
didn’t
extend
to
telling
the
White
House
that
he’d
be
a
more
appropriate
nominee
the
US

District
Court.

And
although
his
tone
during
the
hearing
was
measured,
his
willingness
to
twist
the
truth
was
on
full
display

Asked
about
the
Adams
case,
Bove
pointed
to
the

order
dismissing
the
charges
as
proof
that
he’d
behaved
appropriately.
In
reality,
the
Justice
Department’s
refusal
to
prosecute
left
the
court
little
choice.
And
Judge
Dale
Ho
denied
the
DOJ’s
request
to
dismiss
without
prejudice,
because
allowing
the
Trump
administration
to
reap
the
benefits
of
a
corrupt
bargain
would
be
“difficult
to
square
with
the
words
engraved
above
the
front
entrance
of
the
United
States
Supreme
Court:
‘Equal
Justice
Under
Law.’”

Bove
denied
telling
subordinates
to
defy
a
court
order,
but
said
he
just
plum
couldn’t
remember
if
he’d
told
them
to
give
the
bird
to
a
federal
judge.

Over
and
over
he
simply
refused
to
answer
questions
based
on
spurious
claims
about
the
deliberative
process
privilege.
But,
he
assured
the
senators,
all
was
on
the
up
and
up,
even
if
he

couldn’t
commit
to
recusing
from
cases
involving
his
former
client
Donald
Trump.

And
if
any
Republican
senator
might
be
tempted
to
vote
no,
he
brought
out
the
big
guns.
Alan
Dershowitz,
late
of
Harvard
Law
(and
his
marbles),
sent
a

letter
to
the
Judiciary
Committee
gushing
that
“Mr.
Bove’s
superior
character,
demeanor
and
diligence
are
evident
throughout
his
time
as
Principal
Associate
Deputy
Attorney
General,
as
well
as
in
private
practice.”

FACTS
NOT
IN
EVIDENCE!
But
when
you’ve
got
the
votes,
it
doesn’t
really
matter.

Subscribe
to
read
more
at
Law
and
Chaos….

---

Liz
Dye
lives
in
Baltimore
where
she
produces
the
Law
and
Chaos Substack
and podcast.
You
can
subscribe
to
her
Substack
by
clicking
the
logo:

Ed.
note:
Please
welcome
Liz
Dye
back
to
the
pages
of
Above
the
Law.
Subscribe
to
her
Substack,
“Law
and
Chaos,” here.

“It
is
my
great
honor
to
nominate
Emil
Bove
to
serve
as
a
Judge
on
the
United
States
Court
of
Appeals
for
the
Third
Circuit,”
the
president
screeched
out
on
social
media
on
May
28.
“Emil
is
SMART,
TOUGH,
and
respected
by
everyone.
He
will
end
the
Weaponization
of
Justice,
restore
the
Rule
of
Law,
and
do
anything
else
that
is
necessary
to,
MAKE
AMERICA
GREAT
AGAIN.
Emil
Bove
will
never
let
you
down!”

So
much
for
the
wages
of
sin.

The
president’s
personal
lawyer
spent
the
past
five
months
disgracing
the
Justice
Department
and
his
professional
oath.
He
is
currently
the
subject
of
a

whistleblower
complaint
alleging
that
he
deliberately
defied
court
orders
and
instructed
DOJ
lawyers
to
do
the
same.
And
for
his
loyalty,
he’s
being
rewarded
with
lifetime
tenure
on
the
appellate
bench.

Worst
villain
origin
story
ever

Emil
Bove,
III
began
his
career
at
the
Southern
District
of
New
York,
where
he
was
by
all
accounts
a
competent
prosecutor.
His
management
style
left
something
to
be
desired,
however,
and
he
was
denied
promotion
for

“abusive”
behavior
toward
his
subordinates.

In
2022,
he
left
the
DOJ
for
private
practice,
and
the
following
year
teamed
up
with
Todd
Blanche,
another
SDNY
alum
who
left
the
white-shoe
law
firm
Cadwalader,
Wickersham
&
Taft
to
represent
Donald
Trump
in
his
criminal
cases.
The
only
one
that
went
to
trial
was
the
Manhattan
prosecution,
where
a
jury
found
their
client
guilty
of
34
counts
of
creating
a
false
business
record.
But
Trump
values
obedience
over
competence,
and
so
he
gave
Blanche
and
Bove
the
top
jobs
at
DOJ,
serving
under
another
of
his
personal
lawyers,
Pam
Bondi.

Heel
turn

Back
in
2021,
Bove
worked
January
6
cases
at
SDNY.
But
one
of
the
first
things
he
did
on
his
return
to
the
Department
was
to
launch
a
mass
purge
of
prosecutors
who
worked
January
6
cases.

“I
do
not
believe
the
current
leadership
of
the
Justice
Department
can
trust
these
FBI
employees
to
assist
in
implementing
the
President’s
agenda
faithfully,”
he
wrote
in
a
memo
obtained
by
the

Washington
Post.

As
Trump’s
personal
lawyer,
Bove
signed
his
name
to
dozens
of
briefs
lobbing
baseless
charges
of
politicization
at
the
DOJ.
But
once
ensconced
at
Main
Justice,
he
set
about
reordering
the
DOJ
to
achieve
Trump’s
political
ends.

He
tried
without
success
to

gin
up
criminal
charges
in
connection
with
billions
of
dollars
in
greenbanking
funds
allocated
by
Congress
and
disbursed
in
the
final
year
of
Biden’s
presidency.
He

threatened
to
arrest
local
officials
who
exercise
their
rights
under
the
the
Tenth
Amendment
not
to
cooperate
with
federal
immigration
mandates.
And
he
blew
up
the
prosecution
of
New
York
City
Mayor
Eric
Adams
in
hopes
of
blackmailing
the
elected
Democrat
to
enact
the
administration’s
immigration
priorities.

On
February
10,
he

ordered
Danielle
Sassoon,
the
then-acting
US
Attorney
for
SDNY,
to
dismiss
the
pending
prosecution
of
the
mayor
for
taking
bribes
from
Turkish
officials.
Bove
ordered
her
to
seek
a
dismissal

without
prejudice,
allowing
the
government
to
hold
the
threat
of
re-indictment
over
Adams
if
he
failed
to
do
what
they
asked,
particularly
when
it
came
to
immigration.

“If
a
criminal
prosecution
cannot
be
used
to
punish
political
activity,
it
likewise
cannot
be
used
to
induce
or
coerce
such
activity,”
she
wrote
in
her

resignation
letter.
“Threatening
criminal
prosecution
even
to
gain
an
advantage
in
civil
litigation
is
considered
misconduct
for
an
attorney.”

He
responded
with
an
absolutely

deranged
letter,
defending
the
propriety
of
a
political
quid
pro
quo
with
a
criminal
defendant
and
accusing
Sassoon
of
insubordination
and
dereliction
of
duty.

But
it
turns
out
that
behind
the
scenes,
Bove
was
doing
even
more
crazy
illegal
shit
to
carry
out
the
president’s
agenda.

Whistle
while
you
work

On
June
24,
the
New
York
Times
published
a

whistleblower
complaint
filed
by
former
Justice
Department
lawyer
Erez
Reuveni.
Reuveni
served
as
Acting
Deputy
Director
for
the
Office
of
Immigration
Litigation
until
April
5,
when
he
was
fired
for
telling
the
truth
to
a
federal
judge
in
the
case
of
Kilmar
Abrego
Garcia,
the
Maryland
man
wrongfully
deported
to
El
Salvador.
Reuveni
refused
to
say
that
Abrego
was
a
known
terrorist
(he
wasn’t)
and
argue
that
this
voided
the
immigration
judge’s
order
staying
his
removal
as
a
matter
of
law
(it
didn’t).

But
before
he
was
fired,
Reuveni
witnesssed
a
shocking
pattern
of
disregard
for
court
orders
by
leadership
at
the
DOJ,
particularly
Bove.

Bove
was
instrumental
in
structuring
the
rollout
of
the
Alien
Enemies
Act
proclamation
so
as
to
ensure
that
the
men
renditioned
to
CECOT
in
El
Salvador
could
never
get
due
process.
According
to
Reuveni,
Bove
instructed
the
DOJ
get
it
done,
even
if
they
had
to
disregard
court
orders:

Bove
then
made
a
remark
concerning
the
possibility
that
a
court
order
would
enjoin
those
removals
before
they
could
be
effectuated.
Bove
stated
that
DOJ
would
need
to
consider
telling
the
courts
“fuck
you”
and
ignore
any
such
court
order.
Mr.
Reuveni
perceived
that
others
in
the
room
looked
stunned,
and
he
observed
awkward,
nervous
glances
among
people
in
the
room.
Silence
overtook
the
room.
Mr.
Reuveni
and
others
were
quickly
ushered
out
of
the
room.

And
in
fact
the
DOJ

did
disregard
Judge
James
Boasberg’s
order
to
turn
the
planes
around.
Reuveni
says
that
Deputy
Assistant
AG
Drew
Ensign
lied
in
court
when
he
said
he
did
not
know
if
and
when
planes
of
detainees
were
taking
off.
Reuveni
alleges
that
“Ensign
had
been
present
in
the
previous
day’s
meeting
when
Emil
Bove
stated
clearly
that
one
or
more
planes
containing
individuals
subject
to
the
AEA
would
be
taking
off
over
the
weekend
no
matter
what.”

Bove
is
credited
with
coming
up
with
the
plan
to
allege
that
the
DOJ
complied
with
Judge
Boasberg’s
order
because
the
planes
were
out
of
US
air
space
by
the
time
the
judge
put
his
oral
order
in
writing.
Notably
Bove
refused
to
put
his
name
on
the
motion
making
this
fakakta
argument
on
the
public
docket.
And
Ensign
is
now
smack
in
the
middle
of
Judge
Boasberg’s
contempt
inquiry.

Bove
also
encouraged
the
DOJ
to
defy
another
court’s
immigration
order
in
Massachusetts.
In
that
case,
Judge
Brian
Murphy
barred
the
Department
of
Homeland
Security
from
deporting
immigrants
to
third
countries
without
notice
and
opportunity
to
object
under
the
Convention
Against
Torture.
The
government

repeatedly
defied
this
order,
including
in
one
episode
where
DHS
flew
detainees
to
Gitmo
and
handed
them
over
to
the
Department
of
Defense
to
transport
them
to
CECOT.

Reuveni
does
not
say
if
Bove
was
the
brain
genius
behind
the
plan
to
argue
that
this
did
not
violate
the
court’s
order,
since
DOD
wasn’t
a
party
to
the
case,
and
no
DHS
employees
were
on
the
plane
to
El
Salvador.
But
he
says
that
Bove
was
pissed
that
he
tried
to
comply
with
the
court
order
to
ascertain
how
this
violation
had
occurred:

Mr.
Reuveni
received
phone
call
from
Acting
AAG
Roth
in
which
Roth
relayed
that
Bove
was
very
unhappy
that
Mr.
Reuveni
had
contacted
counsel
at
various
agencies
to
ascertain
whether
DOJ
had
violated
court
order
Roth
conveyed
that
Mr.
Reuveni
should
stop
emailing
agency
counsel
on
the
matter
to
instead
communicate
by
phone
only
where
possible.46
Mr.
Reuveni
understood
this
instruction
to
be
based
on
leadership’s
aim
to
avoid
generating
written
material
subject
to
disclosure
through
FOIA.

Third
Circuit,
here
he
comes!

On
Wednesday,
June
25,
Bove
appeared
before
the
Senate
Judiciary
Committee,
which
is
considering
his
nomination
to
the
Third
Circuit.

He
opened
by
insisting,
“I
am
not
anybody’s
henchman,
I
am
not
an
enforcer.
I’m
a
lawyer
from
a
small
town,
who
never
expected
to
be
in
an
arena
like
this.”

That
is
horseshit,
of
course.
No
one
gets
to
“an
arena
like
this”
without
a
healthy
dose
of
ambition.
Note
that
Bove’s

aw
shucks
modesty
didn’t
extend
to
telling
the
White
House
that
he’d
be
a
more
appropriate
nominee
the
US

District
Court.

And
although
his
tone
during
the
hearing
was
measured,
his
willingness
to
twist
the
truth
was
on
full
display

Asked
about
the
Adams
case,
Bove
pointed
to
the

order
dismissing
the
charges
as
proof
that
he’d
behaved
appropriately.
In
reality,
the
Justice
Department’s
refusal
to
prosecute
left
the
court
little
choice.
And
Judge
Dale
Ho
denied
the
DOJ’s
request
to
dismiss
without
prejudice,
because
allowing
the
Trump
administration
to
reap
the
benefits
of
a
corrupt
bargain
would
be
“difficult
to
square
with
the
words
engraved
above
the
front
entrance
of
the
United
States
Supreme
Court:
‘Equal
Justice
Under
Law.’”

Bove
denied
telling
subordinates
to
defy
a
court
order,
but
said
he
just
plum
couldn’t
remember
if
he’d
told
them
to
give
the
bird
to
a
federal
judge.

Over
and
over
he
simply
refused
to
answer
questions
based
on
spurious
claims
about
the
deliberative
process
privilege.
But,
he
assured
the
senators,
all
was
on
the
up
and
up,
even
if
he

couldn’t
commit
to
recusing
from
cases
involving
his
former
client
Donald
Trump.

And
if
any
Republican
senator
might
be
tempted
to
vote
no,
he
brought
out
the
big
guns.
Alan
Dershowitz,
late
of
Harvard
Law
(and
his
marbles),
sent
a

letter
to
the
Judiciary
Committee
gushing
that
“Mr.
Bove’s
superior
character,
demeanor
and
diligence
are
evident
throughout
his
time
as
Principal
Associate
Deputy
Attorney
General,
as
well
as
in
private
practice.”

FACTS
NOT
IN
EVIDENCE!
But
when
you’ve
got
the
votes,
it
doesn’t
really
matter.

Subscribe
to
read
more
at
Law
and
Chaos….

---

Liz
Dye
lives
in
Baltimore
where
she
produces
the
Law
and
Chaos Substack
and podcast.
You
can
subscribe
to
her
Substack
by
clicking
the
logo:

Ed.
note:
Please
welcome
Liz
Dye
back
to
the
pages
of
Above
the
Law.
Subscribe
to
her
Substack,
“Law
and
Chaos,” here.

“It
is
my
great
honor
to
nominate
Emil
Bove
to
serve
as
a
Judge
on
the
United
States
Court
of
Appeals
for
the
Third
Circuit,”
the
president
screeched
out
on
social
media
on
May
28.
“Emil
is
SMART,
TOUGH,
and
respected
by
everyone.
He
will
end
the
Weaponization
of
Justice,
restore
the
Rule
of
Law,
and
do
anything
else
that
is
necessary
to,
MAKE
AMERICA
GREAT
AGAIN.
Emil
Bove
will
never
let
you
down!”

So
much
for
the
wages
of
sin.

The
president’s
personal
lawyer
spent
the
past
five
months
disgracing
the
Justice
Department
and
his
professional
oath.
He
is
currently
the
subject
of
a

whistleblower
complaint
alleging
that
he
deliberately
defied
court
orders
and
instructed
DOJ
lawyers
to
do
the
same.
And
for
his
loyalty,
he’s
being
rewarded
with
lifetime
tenure
on
the
appellate
bench.

Worst
villain
origin
story
ever

Emil
Bove,
III
began
his
career
at
the
Southern
District
of
New
York,
where
he
was
by
all
accounts
a
competent
prosecutor.
His
management
style
left
something
to
be
desired,
however,
and
he
was
denied
promotion
for

“abusive”
behavior
toward
his
subordinates.

In
2022,
he
left
the
DOJ
for
private
practice,
and
the
following
year
teamed
up
with
Todd
Blanche,
another
SDNY
alum
who
left
the
white-shoe
law
firm
Cadwalader,
Wickersham
&
Taft
to
represent
Donald
Trump
in
his
criminal
cases.
The
only
one
that
went
to
trial
was
the
Manhattan
prosecution,
where
a
jury
found
their
client
guilty
of
34
counts
of
creating
a
false
business
record.
But
Trump
values
obedience
over
competence,
and
so
he
gave
Blanche
and
Bove
the
top
jobs
at
DOJ,
serving
under
another
of
his
personal
lawyers,
Pam
Bondi.

Heel
turn

Back
in
2021,
Bove
worked
January
6
cases
at
SDNY.
But
one
of
the
first
things
he
did
on
his
return
to
the
Department
was
to
launch
a
mass
purge
of
prosecutors
who
worked
January
6
cases.

“I
do
not
believe
the
current
leadership
of
the
Justice
Department
can
trust
these
FBI
employees
to
assist
in
implementing
the
President’s
agenda
faithfully,”
he
wrote
in
a
memo
obtained
by
the

Washington
Post.

As
Trump’s
personal
lawyer,
Bove
signed
his
name
to
dozens
of
briefs
lobbing
baseless
charges
of
politicization
at
the
DOJ.
But
once
ensconced
at
Main
Justice,
he
set
about
reordering
the
DOJ
to
achieve
Trump’s
political
ends.

He
tried
without
success
to

gin
up
criminal
charges
in
connection
with
billions
of
dollars
in
greenbanking
funds
allocated
by
Congress
and
disbursed
in
the
final
year
of
Biden’s
presidency.
He

threatened
to
arrest
local
officials
who
exercise
their
rights
under
the
the
Tenth
Amendment
not
to
cooperate
with
federal
immigration
mandates.
And
he
blew
up
the
prosecution
of
New
York
City
Mayor
Eric
Adams
in
hopes
of
blackmailing
the
elected
Democrat
to
enact
the
administration’s
immigration
priorities.

On
February
10,
he

ordered
Danielle
Sassoon,
the
then-acting
US
Attorney
for
SDNY,
to
dismiss
the
pending
prosecution
of
the
mayor
for
taking
bribes
from
Turkish
officials.
Bove
ordered
her
to
seek
a
dismissal

without
prejudice,
allowing
the
government
to
hold
the
threat
of
re-indictment
over
Adams
if
he
failed
to
do
what
they
asked,
particularly
when
it
came
to
immigration.

“If
a
criminal
prosecution
cannot
be
used
to
punish
political
activity,
it
likewise
cannot
be
used
to
induce
or
coerce
such
activity,”
she
wrote
in
her

resignation
letter.
“Threatening
criminal
prosecution
even
to
gain
an
advantage
in
civil
litigation
is
considered
misconduct
for
an
attorney.”

He
responded
with
an
absolutely

deranged
letter,
defending
the
propriety
of
a
political
quid
pro
quo
with
a
criminal
defendant
and
accusing
Sassoon
of
insubordination
and
dereliction
of
duty.

But
it
turns
out
that
behind
the
scenes,
Bove
was
doing
even
more
crazy
illegal
shit
to
carry
out
the
president’s
agenda.

Whistle
while
you
work

On
June
24,
the
New
York
Times
published
a

whistleblower
complaint
filed
by
former
Justice
Department
lawyer
Erez
Reuveni.
Reuveni
served
as
Acting
Deputy
Director
for
the
Office
of
Immigration
Litigation
until
April
5,
when
he
was
fired
for
telling
the
truth
to
a
federal
judge
in
the
case
of
Kilmar
Abrego
Garcia,
the
Maryland
man
wrongfully
deported
to
El
Salvador.
Reuveni
refused
to
say
that
Abrego
was
a
known
terrorist
(he
wasn’t)
and
argue
that
this
voided
the
immigration
judge’s
order
staying
his
removal
as
a
matter
of
law
(it
didn’t).

But
before
he
was
fired,
Reuveni
witnesssed
a
shocking
pattern
of
disregard
for
court
orders
by
leadership
at
the
DOJ,
particularly
Bove.

Bove
was
instrumental
in
structuring
the
rollout
of
the
Alien
Enemies
Act
proclamation
so
as
to
ensure
that
the
men
renditioned
to
CECOT
in
El
Salvador
could
never
get
due
process.
According
to
Reuveni,
Bove
instructed
the
DOJ
get
it
done,
even
if
they
had
to
disregard
court
orders:

Bove
then
made
a
remark
concerning
the
possibility
that
a
court
order
would
enjoin
those
removals
before
they
could
be
effectuated.
Bove
stated
that
DOJ
would
need
to
consider
telling
the
courts
“fuck
you”
and
ignore
any
such
court
order.
Mr.
Reuveni
perceived
that
others
in
the
room
looked
stunned,
and
he
observed
awkward,
nervous
glances
among
people
in
the
room.
Silence
overtook
the
room.
Mr.
Reuveni
and
others
were
quickly
ushered
out
of
the
room.

And
in
fact
the
DOJ

did
disregard
Judge
James
Boasberg’s
order
to
turn
the
planes
around.
Reuveni
says
that
Deputy
Assistant
AG
Drew
Ensign
lied
in
court
when
he
said
he
did
not
know
if
and
when
planes
of
detainees
were
taking
off.
Reuveni
alleges
that
“Ensign
had
been
present
in
the
previous
day’s
meeting
when
Emil
Bove
stated
clearly
that
one
or
more
planes
containing
individuals
subject
to
the
AEA
would
be
taking
off
over
the
weekend
no
matter
what.”

Bove
is
credited
with
coming
up
with
the
plan
to
allege
that
the
DOJ
complied
with
Judge
Boasberg’s
order
because
the
planes
were
out
of
US
air
space
by
the
time
the
judge
put
his
oral
order
in
writing.
Notably
Bove
refused
to
put
his
name
on
the
motion
making
this
fakakta
argument
on
the
public
docket.
And
Ensign
is
now
smack
in
the
middle
of
Judge
Boasberg’s
contempt
inquiry.

Bove
also
encouraged
the
DOJ
to
defy
another
court’s
immigration
order
in
Massachusetts.
In
that
case,
Judge
Brian
Murphy
barred
the
Department
of
Homeland
Security
from
deporting
immigrants
to
third
countries
without
notice
and
opportunity
to
object
under
the
Convention
Against
Torture.
The
government

repeatedly
defied
this
order,
including
in
one
episode
where
DHS
flew
detainees
to
Gitmo
and
handed
them
over
to
the
Department
of
Defense
to
transport
them
to
CECOT.

Reuveni
does
not
say
if
Bove
was
the
brain
genius
behind
the
plan
to
argue
that
this
did
not
violate
the
court’s
order,
since
DOD
wasn’t
a
party
to
the
case,
and
no
DHS
employees
were
on
the
plane
to
El
Salvador.
But
he
says
that
Bove
was
pissed
that
he
tried
to
comply
with
the
court
order
to
ascertain
how
this
violation
had
occurred:

Mr.
Reuveni
received
phone
call
from
Acting
AAG
Roth
in
which
Roth
relayed
that
Bove
was
very
unhappy
that
Mr.
Reuveni
had
contacted
counsel
at
various
agencies
to
ascertain
whether
DOJ
had
violated
court
order
Roth
conveyed
that
Mr.
Reuveni
should
stop
emailing
agency
counsel
on
the
matter
to
instead
communicate
by
phone
only
where
possible.46
Mr.
Reuveni
understood
this
instruction
to
be
based
on
leadership’s
aim
to
avoid
generating
written
material
subject
to
disclosure
through
FOIA.

Third
Circuit,
here
he
comes!

On
Wednesday,
June
25,
Bove
appeared
before
the
Senate
Judiciary
Committee,
which
is
considering
his
nomination
to
the
Third
Circuit.

He
opened
by
insisting,
“I
am
not
anybody’s
henchman,
I
am
not
an
enforcer.
I’m
a
lawyer
from
a
small
town,
who
never
expected
to
be
in
an
arena
like
this.”

That
is
horseshit,
of
course.
No
one
gets
to
“an
arena
like
this”
without
a
healthy
dose
of
ambition.
Note
that
Bove’s

aw
shucks
modesty
didn’t
extend
to
telling
the
White
House
that
he’d
be
a
more
appropriate
nominee
the
US

District
Court.

And
although
his
tone
during
the
hearing
was
measured,
his
willingness
to
twist
the
truth
was
on
full
display

Asked
about
the
Adams
case,
Bove
pointed
to
the

order
dismissing
the
charges
as
proof
that
he’d
behaved
appropriately.
In
reality,
the
Justice
Department’s
refusal
to
prosecute
left
the
court
little
choice.
And
Judge
Dale
Ho
denied
the
DOJ’s
request
to
dismiss
without
prejudice,
because
allowing
the
Trump
administration
to
reap
the
benefits
of
a
corrupt
bargain
would
be
“difficult
to
square
with
the
words
engraved
above
the
front
entrance
of
the
United
States
Supreme
Court:
‘Equal
Justice
Under
Law.’”

Bove
denied
telling
subordinates
to
defy
a
court
order,
but
said
he
just
plum
couldn’t
remember
if
he’d
told
them
to
give
the
bird
to
a
federal
judge.

Over
and
over
he
simply
refused
to
answer
questions
based
on
spurious
claims
about
the
deliberative
process
privilege.
But,
he
assured
the
senators,
all
was
on
the
up
and
up,
even
if
he

couldn’t
commit
to
recusing
from
cases
involving
his
former
client
Donald
Trump.

And
if
any
Republican
senator
might
be
tempted
to
vote
no,
he
brought
out
the
big
guns.
Alan
Dershowitz,
late
of
Harvard
Law
(and
his
marbles),
sent
a

letter
to
the
Judiciary
Committee
gushing
that
“Mr.
Bove’s
superior
character,
demeanor
and
diligence
are
evident
throughout
his
time
as
Principal
Associate
Deputy
Attorney
General,
as
well
as
in
private
practice.”

FACTS
NOT
IN
EVIDENCE!
But
when
you’ve
got
the
votes,
it
doesn’t
really
matter.

Subscribe
to
read
more
at
Law
and
Chaos….

---

Liz
Dye
lives
in
Baltimore
where
she
produces
the
Law
and
Chaos Substack
and podcast.
You
can
subscribe
to
her
Substack
by
clicking
the
logo:

After
a
years-long
IPO
drought
in
digital
health,
two
companies
—
Hinge
Health,
focused
on
musculoskeletal
care,
and
Omada
Health,
specializing
in
chronic
disease
management
—
have

gone
public
this
year.
The
renewed
activity
follows
a
2021
surge
in
digital
health
IPOs
that
largely
failed
to
meet
expectations.

So
what
have
venture
capitalists
learned
during
this
period
about
health
tech
in
the
public
markets?
That
question
was
posed
during
a
recent
panel
discussion
at
the

AHIP
2025
conference
held
in
Las
Vegas.
The
session
was
moderated
by
Bill
Evans,
founder
and
general
partner
of
Rock
Health
Capital,
a
seed
fund.

One
of
the
panelists
noted
that
it’s
great
to
see
the
public
markets
interested
in
digital
health
again.
However,
the
enthusiasm
is
tempered.

“You
still
need
to
come
out
with
a
solid
business
and
[profit
and
loss],
and
there’s
always
that
kind
of
trade
off
between
growth
and
profitability
that
public
markets
are
looking
at,”
said
Kurt
Sheline,
partner
of
Echo
Health
Ventures.
“If
you’re
unprofitable,
you
better
be
growing
fast.
And
if
you’re
not
growing
fast,
you
better
be
a
pretty
high
margin
business.
And
everything
in
between
is
kind
of
in
this
weird,
not-sure
land. 

“Speaking
for
our
portfolio,
there
are
some
great
companies
that
are
still
private
at
scale,
growing
fast,
solid
margins,
and
trying
to
deal
with
that
trade
off,
and
the
timing
of
when
that
trade
off
hits
the
[profit
and
loss]
to
be
able
to
go
public,”
he
added.

Another
investor
noted
that
the
“doors
were
too
wide
open”
a
few
years
ago
when
there
was
a
spike
of
digital
health
companies
going
public.
Many
of
these
companies
have
since
underperformed.
This
made
it
difficult
for
other
companies
to
go
public
in
the
years
following.

“I
think
it’s
hugely
positive
now
that
we
have
Hinge
and
Omada
that
just
went
out,”
said
Siobhan
Nolan
Mangini,
partner
at
Venrock.
“That
being
said,
the
bar
is
super
high.
And
I
think
it’s
growth
and
profitability.
If
you’ve
heard
of
the
rule
of
40,
you
want
to
make
sure
your
growth
and
your
EBITDA
margins
are
basically
north
of
40%.
And
if
you
look
at
a
company
like
Hinge,
they
were
almost
$400
million
of
revenues
last
year.
They
have
almost
8%
margins,
they’re
profitable.
That
is
a
really
high
bar.
That
is
not
necessarily
where
public
markets
have
been
historically.”

Amy
Belt
Raimundo,
vice
president
and
managing
director
of
Kaiser
Permanente
Ventures,
said
that
health
tech
companies
are
going
back
to
the
fundamentals.
In
2021,
digital
health
became
very
exciting
post-Covid
and
there
was
a
lot
of
“exuberance,”
but
the
“fundamentals
weren’t
there,”
Raimundo
said.
She
noted
that
Kaiser
Permanente
has
been
an
investor
in
Omada
Health
since
2014.

“Having
to
come
out
with
good
fundamentals
is,
I
think,
the
next
wave,”
she
said.
“That
there
is
an
exit
market
here,
which
then
will
spawn
more
investment.”

Photo:
Chunumunu,
Getty
Images

*
Judges
are
delaying
retirement
under
Trump
II
—
and
it’s
not
just
the
liberals!
[Bloomberg
Law]

*
Another
Trump
L
in
court
as
a
federal
judge
held
the
presidents
abrupt
closing
of
Job
Corps
without
Congressional
approval
is
likely
illegal.
[Reuters]

*
Benson
is
leaving
Kasowitz
Benson
Torres.
Time
for
some
new
letterhead.
[New
York
Law
Journal]

*
Judge
cites
none
other
than
The
Simpson
while
handing
Trump
a
loss
(this
time
over
EV
charging
stations).
[Law
and
Crime]

*
The
GOP’s
big
beautiful
bill
means
the
Senate
parliamentarian
is
getting
a
lot
of
attention
all
of
a
sudden
.
[The
Hill]

*
The
Fed
plans
to
ease
capital
requirement
for
big
banks.
This
is
giving
big
2007
vibes!
[Law360]

An
adult
male
lion
was
found
caught
in
a
deadly
snare.
Injured
but
alive,
he
was
darted,
treated,
and
released
back
into
the
wild
–
but
there
was
a
much
more
gruesome
discovery
waiting
nearby…

The
brutalized
remains
of
a
lioness
–
the
snared
lion’s
partner
–
were
found
near
the
snare,
her
flesh
stripped
from
her
bones,
and
her
head
and
paws
hacked
off.

She
leaves
behind
two
four-year-old
offspring
and
three
nine-month-old
cubs
–
all
of
whom
must
now
fend
for
themselves. Without
their
mother,
their
chances
are
slim.

Worst
of
all,
the
tiny
cubs
are
acutely
vulnerable
to
poachers.

This
lion
died
after
being
caught
in
a
lethal
snare.
These
torture
devices
leave
animals
suffering
for
hours
or
days
before
they
succumb
to
their
injuries.
Credit:
Kariba
Animal
Welfare
Fund
Trust

We
need
to
act
FAST
to
prevent
more
despicable
acts
of
cruelty
like
this.

The
grim
discovery
was
made
by
local
conservationists
who
immediately
alerted
Zimbabwean
wildlife
authorities
and
our
partner,
the
Victoria
Falls
Anti-Poaching
Unit
(VFAPU).

There
has
been
an
alarming
rise
in
poaching
in
Zimbabwe,
and
criminals
seem
to
be
particularly
targeting
lions.
This
iconic
species
may
be
king
of
the
jungle,
but
lions
stand
no
chance
against
armed
and
ruthless
poachers,
who
violently
kill
and
sell
their
body
parts
into
the
illegal
wildlife
trade.

Lion
paws,
teeth
and
bones
are
especially
sought
after
as
fake
‘medicinal’
cures
and
status
symbols
in
Asia.
For
poachers
in
the
Zimbabwean
wilderness,
killing
one
of
these
majestic
beasts
and
hacking
off
its
paws
and
head
is
nothing
more
than
a
quick
way
to
make
money.

The
remains
of
the
freshly
butchered
female
lion
that
was
found
near
the
injured
male.
Credit:
Shutterstock/Juanita
Layne
(left,
IMAGE
FOR
ILLUSTRATION
PURPOSES
ONLY)
&
VFAPU
(right).

One
of
the
best
ways
to
stop
poachers
in
their
tracks
is
through
innovative
AI-powered
technology.

AI-powered
camera
traps
are
a
critical
and
highly-effective
tool
in
the
fight
against
poachers
–
and
with
your
help, we
will
install
them throughout
poaching
hotspots
in
Zimbabwe.

This
year
alone,
using
four
existing
camera
traps,
our
partner
VFAPU
has
removed
97
snares,
detected
49
attempts,
and
arrested
11
poachers who,
if
convicted,
could
face
up
to
nine
years
in
prison.
The
team
also
rescued
six
animals
from
snares.

AI-powered
cameras
detect
human
movement
in
real
time
and
send
instant
alerts
to
anti-poaching
units.
Teams
are
immediately
dispatched
to
stop
the
poachers
before
they
can
lay
cruel
snares
or
kill
an
innocent
creature. But
four
camera
traps
are
not
enough
to
catch
every
poacher,
and
we
must
install
more
as
soon
as
possible.

Camera
traps
are
vital
to
identify
poachers,
day
or
night,
and
send
immediate,
real-time
alerts
to
anti-poaching
teams.
Credit:
VFAPU

For
every
$400
(£312)
raised,
we
can
install
an
additional
camera
trap,
helping
our
partner
to
protect
lions
and
catch
poachers.

VFAPU
patrols
a
vast
area
covering
124,000
acres
(50,000
hectares).
The
more
sophisticated
camera
traps
we
can
install,
the
more
animals
we
can
protect,
and
the
more
poachers
will
end
up
behind
bars
–
where
they
belong.

We
need
to
install
at
least
10
more
camera
traps
to
help
the
team
cope
with
the
dramatic
surge
in
poaching
–
but
we
can
only
do
this
with
your
support
today.

Right
now,
lions
are
sitting
ducks
for
poachers.
With
your
support,
we
can
not
only
protect
vulnerable
animals,
but
actively
arrest
and
prosecute
the
criminals
profiting
off
their
deaths.

Please
donate
as
much
as
you
can
today.