Plaintiffs-Appellants in Rubin v. Iran File Reply Brief in First Circuit

"The Plaintiffs successfully obtained judgment against Iran and seek to execute that judgment—pursuant to federal law—against Iranian assets held by the Trustees-Appellees (“Garnishees”). The Garnishees, wealthy museums represented by aristocratic law firms, have sought to stop the Plaintiffs, claiming that the exercise of federal law is somehow unfair to them—that they are above the law." So begins the reply brief filed on behalf of Jenny Rubin and others affected by a 1997 terrorist attack that held Iran liable for damages.  The appellees in the case of Rubin v. Iran are the museums at Harvard and the Boston Museum of Fine Arts (MFA), which house Persian artifacts that are sought after by the plaintiffs-appellants to satisfy a money judgment they were awarded by a federal court against Iran.

The Rubin plaintiffs-appellants appealed to the U.S. First Circuit in March 2012 after losing their case in federal district court.  The museums filed appellate briefs on May 31, 2012, and the United States government submitted a friend of the court brief in June 2012 in support.  Now the Rubin plaintiffs-appellants have entered their response.

The litigation has become complicated, involving technical legal issues and multiple courts.  Highlights of the arguments put forward by the plaintiffs-appellants follow.

First, the plaintiffs-appellants argue that there is a legal basis to award them the artifacts in the collections of the museums under the Foreign Sovereign Immunities Act (FSIA) 28 U.S.C. §1610(g) even if Iran does not own the property.  The museums, they say, have waived their right to challenge the conclusion that plaintiffs-appellants can execute judgment.

Second, the plaintiffs-appellants charge that the museums' "failure to engage in due diligence" cause the institutions to "suffer at their own hands."  That is because, as the plaintiffs-appellants write, the museums "are not 'innocent third parties' (Gov’t 12; Harvard 26, 63; MFA 60) or 'innocent property owners' (Gov’t 17). They are, in some cases, successors in interest to thieves. In other cases, the provenance of their artifacts is simply unknown . . . . Garnishees did no due diligence (or have deliberately hidden the results of their due diligence) in reliance on a three-year statute of limitations and a three-year rule for adverse possession. (Harvard 47, 49-51). Now they have discovered that the state statute of limitations and adverse possession rules are not ironclad and are subject to federal preemption and beg this court for cover."  As a result, the Rubin plaintiffs-appellants say that this "decision not to insist upon documentation—or to ignore and discard the documentation that they received—opens them to recapture by the property’s rightful owner or, as in this case, another party that claims a primary statutory interest." (footnote omitted)

Third, the First Circuit Court should wait to issue a decision until the Second Circuit Court rules on other cases that involve the FSIA and the Terrorism Risk Insurance Act (TRIA), two laws applicable to the Rubin v. Iran case.  The plaintiffs-appellants argue that "[t]he cases squarely present before the Second Circuit the scope of TRIA and FSIA without all of the extraneous complications in [Rubin v. Iran] pertaining to factual questions about the provenance of the Property, the question of whether the Property are rightly considered 'blocked assets' for purposes of TRIA, and the proper interpretation of Iranian domestic law."

Fourth, the Rubin plaintiffs-appellants contend that their case can be resolved in their favor under either FSIA or TRIA: "Plaintiffs request that this Court either resolve this dispute pursuant to [FSIA] §1610(g) or remand for further proceedings under §1610(g). If this Court chooses not to do so, it should grant Plaintiffs the relief requested pursuant to TRIA."

Fifth, the Rubin plaintiffs-appellants say that if the First Circuit decides the case on the basis of TRIA, then the museums hold the burden of proof regarding ownership of the artifacts in their possession, not the plaintiffs-appellants.  They write in their brief that the museums "have argued repeatedly that Plaintiffs have the burden of proving that Iran owns the assets at issue in this litigation and that Plaintiffs have not met that burden. (Harvard 21, 31, 41-46; MFA 12-14, 25-35). They ignore that the reason that conclusive evidence is lacking is because Garnishees cannot document the provenance of their artifacts."  The plaintiffs-appellants submit that they have presented evidence of the artifacts "have presented adequate evidence showing where the Property originated, approximately when it was taken from those locations, and the long history of pillaging that occurred in those locations. Plaintiffs have likewise presented adequate evidence showing—at very least—that the Iranian government retains title or a right to immediate possession of all artifacts that it has not gifted or sold to others."

Finally, the plaintiffs-appellants criticize the museums' argument that TRIA would prompt "an unconstitutional taking of private property."  They write, "Their arguments are frivolous."

The case will continue to move forward in the coming weeks.

This post is researched, written, and published on the blog Cultural Heritage Lawyer Rick St. Hilaire at http://culturalheritagelawyer.blogspot.com. Text copyrighted 2012 by Ricardo A. St. Hilaire, Attorney & Counselor at Law, PLLC. Contact: www.culturalheritagelawyer.com

Federal Attorneys File Motion in Support of Cambodian Statue's Forfeiture from Sotheby's, Arguing the "Signs of Theft Should Have Been Obvious"

"In this case, the signs of  the Statue's theft should have been obvious to a major international art dealer like Sotheby's."  That is what the United States Attorneys Office, Southern District of New York, contends in its objection filed yesterday in the case of United States Of America v. A 10th Century Cambodian Sandstone Sculpture, Currently Located at Sotheby's In New York, New York.  A June 5 motion submitted by Sotheby's auction house and Ms. Ruspoli di Poggio Suasa--the claimants--urges the federal district court in Manhattan to dismiss the case.  Federal attorneys have now filed their objection.

The United States government is seeking the seizure and forfeiture of the statue claimed to have been removed illegally from the Prasat Chen Temple in Koh Ker, Preah Vihear Province, Cambodia.  Sotheby's attempted to sell the artifact on behalf of the consignor, Ms. Ruspoli di Poggio Suasa, this spring when prosecutors filed their civil lawsuit against the sculpture, known as the Duryodhana.  The government seeks to repatriate the statue, whose carved feet remain in Cambodia.

Calling the claimant's motion to dismiss a "thinly-disguised effort to circumvent discovery ... and argue the ultimate merits before the Government has had an opportunity to obtain further evidence of their wrongdoing," the federal attorneys, led by Sharon Cohen Levin, forcefully explain that the government's complaint is more than sufficient to justify a forfeiture action.  The lawyers argue, in part, that Cambodian law clearly vests title of the statue in the hands of Cambodia, that the statue was taken from Cambodia unlawfully, and that Sotheby's knew that the statue was stolen.

"Cambodian national ownership laws, in fact, are clear and unequivocal," write the prosecutors, and the laws that award title of cultural property to Cambodia have existed since the 1900's.  Counsel for the United States reject the implication that "the archaeological treasures at Koh Ker were abandoned property, free for the taking by anyone willing and able to cut them off their pedestals."

The government also rejects the claimant's argument regarding Cambodia's alleged lack of enforcement of national ownership laws, arguing that there is no requirement to brief such facts at this stage of the litigation.  Nevertheless, the government points out that it "has gathered substantial additional evidence that Cambodia has enforced its laws, which has also revealed that Sotheby's is intimately familiar with Cambodia's enforcement efforts" because there have been "instances where Cambodia has sought to recover its cultural property from Sotheby's, specifically."

Federal prosecutors assert that the Duryodhana was looted without Cambodia's permission, and they distinguish the case from the Ka Nefer Nefer mask case: "In Mask of Ka-Nefer-Nefer, the district court dismissed the Government's civil forfeiture complaint because the complaint, rather than alleging that the mask was stolen, merely stated that the mask was found to be 'missing' from Egypt in 1973." The attorneys reaffirm that the Duryodhan was stolen from Cambodia at a time when Cambodia's patrimony laws were in operation.

The prosecutors contend that "the allegations demonstrate that Sotheby's was well aware that the Statue had been removed from a temple at the Koh Ker archaeological site." As "a sophisticated participant in the Southeast Asian art market" with a Worldwide Compliance Department, prosecutors allege that "Sotheby's either knew that it was stolen from Cambodia, or 'was aware of a high probability that [it] was stolen and deliberately looked the other way,' either of which would meet the Government's burden."  In fact, the attorneys declare that the auction house's actions, which followed a scholar's warning that the statue was stolen, was part of "behavior of a company trying to sell artwork it knows to be stolen if it can figure out how to get away with it."

Sotheby's will have a chance to respond to the government's claims by September.

All quotes are taken from the Memorandum of Law in Support of the Government's Opposition to Claimants' Sotheby's, Inc. Ms. Ruspoli di Poggio Suasaof's Motion to Dismiss.  Citations have been omitted.

This post is researched, written, and published on the blog Cultural Heritage Lawyer Rick St. Hilaire at http://culturalheritagelawyer.blogspot.com. Text copyrighted 2012 by Ricardo A. St. Hilaire, Attorney & Counselor at Law, PLLC. CONTACT: www.culturalheritagelawyer.com

Camera Reviews

On my cycling commutes I like to record the action around me onto camera.  Over the last several months I have been experimenting with different cameras.  Different users will have different uses and purposes but, for what it is worth I tender my thoughts on the cameras I have tried.

Veho Muvi with sports kit.




Basic cheap camera with, I think, very reasonable quality of vision and sound for the price.  Ease of editing files is, for me, very important as I do not wish to spend all day reviewing and editing files.  The Veho records onto 30 minute files of around 635MB.  A relatively  low capacity (4 or 8 GB) SD card will therefore take many hours of video, which can be easily cropped using Microsoft Moviemaker.
The limiting feature for my commute is the battery life.  Although sometimes advertised at 2 hours I have never had this long on any of my Muvi cameras.  More like 1 to 1 1/4 hours and this deteriorates with age.  Mine generally last about a year before the battery life is so low I change the camera (the batteries are not replaceable and the units are relatively cheap).  I bought my last one from Amazon for about £40.  I did buy one once when the colour was all off but it was replaced without drama.
The sports kit enables me to place it in a 'shell' that attaches to a strap which can be run around the vents of a helmet if you wear one or attached to the bike.  Be sure though to secure something through the little eye on the camera itself in case it falls out of its shell.

Daytime example:  Film used to convict Scott Lomas of threatening/abusive words and behaviour.


Quality at night is obviously diminished but still useable and better than nothing.
Nighttime example.  Film used to convict Levi Rayner of careless driving (and caution for threatening/abusive words and behaviour).

The camera does struggle when pointing towards the sun.  Since I live southwest of where I work this is a particular problem for me and calling out the number plate is always advisable as a backup.

Likes: Inexpensive.  Ease of operation.  Ease of preparing files.  Usable quality of video/audio..
Dislikes: Short battery life, not good in wet.


Dogcam DVIIIR

The police cycle team spoke highly of this camera when I spent a half day with them last November and, thinking them to be experts, I ordered one.  The bullet camera is mounted onto the side of a helmet (or onto googles) and a lead is run from there to the central unit.  After a bit of experimenting I decided the best thing to do was place the unit in a freezer bag and drop it down the front of my jersey hoping it did not migrate too far (or pawing at myself trying to encourage it one way rather than another).  The controls were out of reach but since I set the camera to run and left it that was not a great problem.
I never got on with this device.  The advertised battery life of 2 hours+ never materialised for me.  Mine lasted 1h19m.  I tried a new battery: same result.  The unit then started to record sound but no vision.  When I sent it back the replacement had a blank screen with just a narrow strip at the top.  The screen is used for the controls and settings and not just for playback so that unit had to go back too.  Picture quality was ok but I was expecting greater things of HD.  File sizes were bigger and harder to edit and to play.  I had to download software to play the files.
One further considerable annoyance was that the computer cable was non-standard size, meaning I had to carry the cable around with me or use only my work or only my home computer.
I did not use it for long but here is an example picture.  As you can see night time quality was not great:



Likes:  None (though the Met Police like it)
Dislikes: Expensive.  Hard to use.  Unreliable.  Not great quality (especially for HD).

Justice camera issued by 'Policewitness'


I was loaned a Justice camera to review and I have to say that once I got used to using it I have been favourably impressed.  The first camera I was sent did keep shutting down unexpectedly but a replacement was fine and it is possible that the fault lay in the SD card I was using rather than the camera.  Picture quality in daytime is good though at night mediocre.  The camera can be set to record in files that are whatever length you wish.  The default is only 60 seconds which is too short as the film skips half a second between files and this is always at a critical moment.
It is easy to use.  Just two buttons on it and the back screws off to reveal the standard mini USB port and SD card slot with a reset button (which is quite frequently needed to 'reboot' the camera).
The camera comes with mounts for helmet and bike frame though I had to rig something together for a rear view as the frame attachment only adjusts in one dimension (which leaves it pointing down if attached to a seat tube)..
Battery life is comfortably sufficient for my 2 hour commute.  For reliable use though I find that I do need to use a 16GB SD card.
One thing I do like about this camera is that (like the Veho but unlike the Contour) it has a similar focal length to the human eyeball so what you see on the film is much as it looks in real life.
Example, the driver of this van was required to attend a driver improvement course:


Like the Veho it struggles when pointing towards the sun (this vehicle remained unidentified) and nightime use is not great either


Another minor irritiation is that, I find, the time and date needs to be reset at regular intervals if you wish it to remain accurate.

I find it very good as a rear view camera (though you will see a skip here):


The idea of policewitness is to engage an enterprising ex-police officer to report road crime and shove the police into taking action.  Shame it has come to that but, given the level of interest in most police forces in prosecuting bad driving, I fear that it has.  Google 'Policewitness' for further details.

Likes: Ease of use, picture quality (daytime), battery life, focal length.
Dislikes: Skips between files, occasionally needs resetting, time/date drifts off.

Contour Roam




Well this I thought ought to be the bee's knees and youtube is full of cyclists (like the famous Gaz) who use and recommend it.  It can be fitted to a helmet but is relatively bulky and I fit to the bike frame.  It records in files that are approximately half an hour long and absolutely gynormous. (3.66GB).  I will only play with these files if I feel I absolutely have to and have only managed to send the police stills when reporting an incident.  Contour provides some software called 'Storyteller' which is basically useless.  you can see the files but not edit them and I can not even get their 'Awesome' feature (whereby you should be able to upload part of a file to youtube) to work.
Only the Windows MovieMaker on my newest computer (latest version) can handle the .mov files and these take overnight to load before stills or shorter clips can be taken.
So this camera gives you the highest quality but at the expense of useability.  If you have the patience to spend hours editing your film footage then this is the camera for you.
One serious drawback though is that the lens is very wide angle.  this means you will not miss much in the fisheye world but that, when you show the police footage of a vehicle passing 6 inches from you, they will have every excuse to say 'that was not so close'.


Likes: Picture quality.  Ease of use (of camera)
Dislikes: Ease of use of files.  Fisheye effect.  Pricey.  Software.

Conclusions

I use the Justice camera a great deal and have it set up rear facing on my commuter bike.  I have the Contour forward facing on the handlebars but because i would much rather not have to look at those files I back this up with the old cheap but good value Muvi camera on the front.

Readers' Requests: Nannies' Rights and Mental Illness in Academia

This may be a first in 10 years of blogging, but I have recently received two (non-spam) requests for certain stories to be posted here that I have decided to follow.

Unlike the requests which are clearly shot-gunned to a number of bloggers since they have no relevance to a blog focused on employment law, these two are relevant.  One is from a for profit company and the other from a law student.

From the for profit world, is a request to link to an article on the employment law rights of nannies.  Because wage and hour law for nannies can be tricky, I would not without checking (which I have not) vouch for all the wage and hour advice, but I think it is a worthwhile post. Although nannies vary widely in age and sophistication, it is sometimes an entry into the workforce and being knowledgeable of one's rights is important. 

If interested see, Employment Rights All Nannies Need to Know.

This is also in a very small way a tribute to my mother, who paid our part-time maid in cash, but had a separate jar that she set aside to put the withholding for social security among other things that she dutifully reported. It was a way to both comply with the law and educate on how social security etc worked to someone who had probably never been paid properly before. For a small town in Texas in the 50's I have to believe that doing so, like my mother who got her doctorate at age 60, was unique.

The second request is from a law student, who self-identifies as having a mental illness and requests I post a link to a critique of the Americans with Disabilities Act in the way it deals with mental illness. The author, Gregory M. Duhl, identifies himself as a "law professor with Borderline Personality Disorder."

Here's the abstract:
This essay is about “madness” in higher education. In Mad at School: Rhetorics of Mental Disability in Academic Life, Professor Price analyzes the rhetoric and discourse surrounding mental disabilities in academia. In this essay, I place Price’s work in a legal context, suggesting why the Americans with Disabilities Act fails those with mental illness and why reform is needed to protect them. My own narrative as a law professor with Borderline Personality Disorder frames my critique. Narratives of mental illness are important because they help connect those who are often stigmatized and isolated due to mental illness and provide a framework for them to overcome barriers limiting their equal participation in academic life.
Here is the link to: Over the Borderline: A Review of Margaret Price's Mad at School: Rhetoric of Mental Disability in Academic Life.

Although I have not read the essay, certainly the object of minimizing the stigma and isolation of those with mental illness is a noble one.

Thanks to my readers who made the requests.

A New Source of Business: TMI

Truth be told, people who do what I do, represent employers in disputes with their employees really don't need new sources of business. Still an article in today's New York Times, Sharing Too Much Information in the Workplace, relays complaints by older managers about comments made by 20 year olds in the workplace, indicates there's always some trend that ends up resulting in more lawsuits.

Some e.g. - asking a manufacturing manager how many times they can miss work before they will get fired or advising that they are seeking another job that will take 6 to 8 months to land. And those are just the not very politic ones by kids who obviously are not sensitive to the ways managers think.

Terminations are the primary driver of employment law litigation and the folks who get terminated are the ones who do stupid things or don't fit in. TMI can often put you squarely in both camps.

Some History Behind the Cleveland Museum of Art's "Vessel with Battle Scene" or "Maya War Vase"

The Cleveland Museum of Art announced this week that it acquired a Roman marble head and a Maya vase.  Yesterday's blog post discussed the new Roman head, the due diligence questions surrounding the acquisition, and a possible connection with a similar Roman head called the "Magdalene Tiberius."  Today the collecting history of the Maya War Vase or Merrin Vase will be explored, noting that the Cleveland Museum has published little information about the chain of custody of the vase.

Source: Cleveland Museum of Art
The Cleveland Museum's newly acquired "Vessel with Battle Scene" appears to be the Maya War Vase or Merrin Vase cataloged at Kerr archive number 2352.  It is evident that the two are the same.  But this information is unconfirmed in the museum's press release.

The Cleveland Museum's August 13, 2012 public statement begins and ends the collecting history of the vessel by saying that the archaeological artifact was in the Edward H. Merrin collection in New York by 1973 and is now in the museum's holdings:

"This exceptional artwork, Vessel with Battle Scene, is one of several polychrome cylinder vessels known as the Fenton Group, painted by the same Maya master artist in the Nebaj region of Guatemala. The vessels portray a related series of events that involve Kan Xib Ahaw (Lord Kan Xib) and include the taking and presentation of prisoners as well as a ritual perhaps related to tribute payment or blood-letting. 
...
"The Vessel with Battle Scene was in the Edward H. Merrin collection in New York by 1973, when the vessel was first published. Dated photographs place the vessel in New York City in March of 1969. Since the early 1970s, the vessel has appeared in at least a dozen print and electronic publications."

It is unknown how the archaeological artifact came to reside in the Edward H. Merrin collection.  Moreover, the Cleveland Museum does not identify from whom it purchased the vase, when, or for what price.

It is reasonable to conclude that the vase may have been last possessed by the Merrin Gallery in New York City, a business started in 1987 by Edward H. Merrin's son.  The gallery certainly had the Maya War Vase in its inventory.  An April 11, 2011 gallery blog entry titled "Maya Art - Among Samuel Merrin's Favorites" quotes Samuel Merrin as saying, "As a child, in the mid to late 1960s, I remember my father, Edward Merrin, displaying this magnificent vase in our house. He had two vases in his private collection, this war vase and a carved vase now in the Kimbell Art Museum in Fort Worth, Texas. . . . This is the last one of a group of six vases still in private hands."

A video produced by the gallery displays the Maya War Vase and appears below.



The Samuel Merrin and Gallery blog notably describes the Maya War Vase as "recomposed." "This cylindrical terracotta Mayan war vase, depicting a battle scene, is one of Samuel Merrin's favorite pieces. (Although recomposed from several pieces, it is complete.)," explains the post.

The blog post also identifies the five other Fenton school vases located at the British Museum (K2894), the Museum of Fine Arts in Boston (K558), the Museum für Volkerkunde in Berlin (K2206), the Virginia Museum of Fine Arts, Richmond (K1392), and the Museo Popol Vuh, Universidad Francisco Marroquín, Guatemala City.  A fragment, whose whereabouts is unknown, is also mentioned.

The Merrin Gallery identifies many publications in which the Mayan War Vase appeared.  The earliest publications listed are from the 1970's and include
  • Edward H. Merrin Gallery, New Acquisitions: Pre-Columbian Art of Mexico and Guatemala – a Sales Exhibition, (New York) illus. no. 22 (N.B. Princeton Art Museum Marquand Library’s accession date for this publication is June 29, 1970).
  • Michael D. Coe, 1973, The Maya Scribe and His World, The Grolier Club (New York) illus., cat. no. 26.
Meanwhile, the Facebook page of the Merrin Gallery explains, "According to his records, the photographer, Justin Kerr, reports that this vase was photographed for 'The Maya Scribe and His World' in June, 1971. He previously had photographed it in March, 1969 (K132)."  Of note is that the 1969 photo is cataloged as K132, not K2352.

A final observation.  It may be helpful to learn a little bit about the Fenton school vases housed in some of the five named museums.
  • The British Museum says on its web site that The Fenton Vase "(K2894) was found at Nebaj, a Maya site in the highlands of Guatemala" and was "[p]urchased with the assistance of the National Art Collections Fund."  Additional reference sources cite the artifact as being known since the early 1900's.
  •  
  • The Museum of Fine Arts, Boston (MFA) describes the place of manufacture of its Maya cylinder vase (1988.1170) as "Southern Highlands, Nebaj area, Guatemala."  It reportedly was given to the MFA by Landon Clay.  The provenance averred is, "Collected between 1974 and 1981 by John Fulling, Art Collectors of November, Inc., Florida (and known as the "November Collection"); to Landon T. Clay, Boston, Massachusetts, in 1987; to MFA, December 1988, gift of Landon T. Clay."
  •  
  • The Virginia Museum of Fine Arts explains that its vase is either from Mexico or Guatemala.  No collecting history of the piece is given except to say that it was a gift of the Adolph D. and Wilkins C. Williams Fund.
Further information surrounding the Cleveland Museum's recent acquisition of the "Vessel with Battle Scene" would no doubt help the public to understand and evaluate the artifact's collecting history better.

This post is researched, written, and published on the blog Cultural Heritage Lawyer Rick St. Hilaire at http://culturalheritagelawyer.blogspot.com. Text copyrighted 2012 by Ricardo A. St. Hilaire, Attorney & Counselor at Law, PLLC. CONTACT: www.culturalheritagelawyer.com

"Unable to Obtain Documentary Confirmation" - Due Diligence and Questions Posed by the Collecting History of The Cleveland Museum of Art's Drusus Minor Head

Source: AAMD Object Registry
The Cleveland Museum of Art announced this week that it was accessioning a marble head depicting Drusus Minor (photo at right), the son of Roman Emperor Tiberius.  That acquisition appears on the Association of Art Museum Directors' (AAMD) object registry because the Cleveland Museum seeks an exception to AAMD's "1970 rule."

The Report of the AAMD Task Force on the Acquisition of Archaeological Materials and Ancient Art (Revised 2008)  declares, "Member museums normally should not acquire a work unless provenance research substantiates that the work was outside its country of probable modern discovery before 1970 or was legally exported from its probable country of modern discovery after 1970. The museum should promptly publish acquisitions of archaeological materials and ancient art, in print or electronic form, including in these publications an image of the work ... and its provenance, thus making this information readily available to all interested parties."  In the case of  the Cleveland Museum of Art, the institution reports that it "has provenance information for the marble head back to the 1960’s, but has been unable to obtain documentary confirmation of portions of the provenance . . . ."

Documented information about an antiquity's find spot, its archaeological context, and the artifact's subsequent collecting history are important in order to learn about human history, to authenticate an artifact, to ensure compliance with national and international laws, and to preserve confidence in cultural institutions--especially those supported in part by taxpayer funds like the Cleveland Museum.  That is why inquiry into the history of the Drusus Minor head is essential.

There is no reported information about the Drusus Minor head's find spot or the archaeological context in which it was found. The Cleveland Museum explains that the head appeared on the market at auction in 2004.  The museum was not the purchaser of the piece at the time, and the auction buyer remains unknown. Apparently there is no import or export paperwork supplied to the museum that may shed more light on either the object's country of manufacture, the original seller of the piece, or any other data that might help complete a due diligence investigation.

The museum suggests an ownership history of the piece prior to the 1960's but it concedes that its pre-2004 information is sourced in a "certificate of origin" produced a day after the auction by antiquities dealer and adviser Jean-Philippe Mariaud de Serres.  He "assisted the prior owner and consigner, Fernand Sintes," according to the Cleveland Museum's object registry narrative.  The certificate--not generated by the actual consignor but produced by an author who passed away five years ago--appears to be one of two primary sources relied on by the museum to establish the head's collecting history.  Meanwhile, the museum has not published any post-2004 collecting history information except to say that it bought the Drusus Minor head from Phoenix Ancient Art, an antiquities dealer with galleries in Geneva and New York.

Why an affidavit describing the ownership history was not produced by consignor Fernand Sintes to the Cleveland Museum is unknown.  The circumstances under which a "certificate of origin" was produced by  Mariaud de Serres after the 2004 purchase at auction are also not known.  And how the Cleveland Museum obtained this "certificate of origin" remains unclear, particularly where the museum asserts that it has no information about the 2004 purchaser of the Roman head.  There is also no information about who, when, or how the marble artifact entered the United States or how it was transferred from the unidentified auction buyer in 2004 to Phoenix Ancient Art, or to which location of Phoenix Ancient Art (Geneva or New York?).  These are a handful of the many chain of custody questions that remain unresolved.

The chain of custody of an archaeological object is expected to come under scrutiny when accessioned by a major museum.  Due diligence is anticipated to be used to investigate the object's find spot and its subsequent ownership, possession, export, and import.  And due diligence would particularly be expected in this case because the Drusus Minor head garnered much public attention in 2004, fetching a remarkably high purchase price.

The Cleveland Museum reports that the Drusus Minor head was listed at Piasa, Paris, Hôtel Drouot-Richelieu, Archéologie, 28–29 Septembre (Paris 2004) 74, lot. no. 340.  That auction listing describes a marble head of Tiberius, which is in fact the Drusus Minor head.  The Cleveland Museum explains in the object registry, "The work was initially identified and published as Tiberius, but was later (after 2007) recognized as a likeness of his son, Drusus Minor." 

Le Journal des Arts wrote in a 2007 article that the Drusus Minor/Tiberius head originally had an estimate of  €100,000 ($123,150 USD in 2004) before it was purchased for over three times that amount, specifically $399,022 USD. The Drouot auction house continues to celebrate the sale on its web site:

"La plus haute enchère a été portée sur une tête monumentale représentant le portrait de l’Empereur Tibère, lot n°340, en marbre blanc à grains fins, Art Romain du Ier siècle, qui a été emportée à 324 013 €. Cette tête provenait d’une collection particulière."

(Author's translation: "The highest bid was given a monumental head representing the portrait of the Emperor Tiberius, Lot No. 340, in white marble-grain, first-century Roman Art, which was purchased for €324 013. This head came from a private collection.")

As previously mentioned, the Cleveland Museum does not know who bought the archaeological object at this noteworthy sale.  The museum, however, possesses the "certificate of origin" that, in all likelihood, would have been handed to the buyer.  Did the museum specifically ask from where and under what circumstances the "certificate of origin" materialized as part of its due diligence investigation?

The Cleveland Museum, nevertheless, describes that Mariaud de Serres' "certificate [of origin] stated the sculpture came from the collection of Mr. and Mrs. Sintes of Marseilles; that the sculpture had been in Mr. Sintes’s family for many generations; that the family’s name was Bacri; and that they had lived in Algeria since 1860." To verify this information, the museum says that it turned to a second source of primary information.  It "contacted Mrs. Sintes who confirmed on behalf of herself and Mr. Sintes that Mr. Sintes’ grandfather, Mr. Bacri, had owned the sculpture; that Mr. Sintes inherited the sculpture from his grandfather; that Mr. Sintes brought it from Algeria to Marseilles in 1960; that he had inherited it from his grandfather prior to bringing it to Marseilles; that the sculpture was sold at the Hôtel Drouot in 2004; and that they had worked with Mr. de Serres."

There is no explanation why the museum did not contact Fernand Sintes.  There is also no information about Mr. Bacri's first name, how he came to own the artifact, or if there was paperwork specifically describing that Fernand Sintes would inherit the marble head after his grandfather's death.  Did the museum seek out other family members or those in the Bacri family to get a more complete collecting history?  That is not known.

Additionally, there is no information about  Mariaud de Serres' exact role in the 2004 auction.  Mariaud de Serres collected Roman-era antiquities, set up shop in Paris in the 1960's, and is said to have created the "certificate of origin" on behalf of the Sintes couple.  He reportedly opened a gallery in the 1960's at the Palais Royal in Paris and was described in a 1999 New York Times article as "the Paris dealer who operates as a registered expert guaranteeing the authenticity of the items" at Dourot auctions.  He died in 2007.  A Christie's February 2011 sale of his many lots of antiquities in Paris earned a total of € 2,737,912 ($3,763,807 USD). Many pieces offered were Roman. Prior to the sale, France's Le Figaro paid tribute to the influential antiquities dealer by describing his many global travels around the Mediterranean basin, his advice to institutions and collectors, and his passion for collecting ancient artifacts.  His specific involvement with the Drusus Minor head may or may not be of importance to understanding the object's collecting history.  But due diligence would require investigating what role, if any, he may have had acquiring the Roman head, facilitating its sale, and/or exporting the object.

The Drusus Minor head reached the shores of the United States at an unknown time and at an unknown place. What is known is that the 2007 Phoenix Ancient Art catalog titled Imago features the marble head as an image of Emperor Tiberius on the front cover and on pages 14 through 17. The catalog gives the archaeological piece pride of place, providing only the briefest collecting history.

The catalog also lists a bibliography with an interesting reference to a journal article by John Pollini titled "A New Marble Head of Tiberius."  Writing in Antike Kunst 48, 2005, pp. 55–72 pls. 7–13, the professor of art at the University of Southern California describes the previously unknown archaeological object:

The "Magdalene Tiberius" 
Source: Antike Kunst
"A magnificent, previously unpublished over life-size marble portrait of Tiberius (pl. 7, 1–4), which in the 1960s had been in a private French collection assembled in Marseilles, is to be found today in a private American collection. Now called the 'Magdalene Tiberius', after a member of the present owner's family, this head is superbly carved in a luminous, fine-grained white marble with a slight beige patina that extends over the area of the break at the base of the neck. Although this portrait is said to have been found in North Africa, its provenance cannot be established with any certainty."

A Roman marble head of Tiberius in a private collection in the 1960's that is said to have been found in North Africa (perhaps Algeria?) sounds similar to the history of the Cleveland Museum head.  The Magdalene Tiberius and the Cleveland Drusus are also similar in size, measuring 32.5 cm and 35 cm respectively. Moreover, both heads were acquired by sale in 2004, and they look to be, at least photographically, of similar quality and appearance.

Pollini tackles the question of provenance of the Magdalene Tiberius by assessing style and laboratory analysis.  He writes:

"Although, as noted at the outset, the Magdalene Tiberius is said to come from North Africa, this provenance cannot be established with certainty. Indicating, in fact, the possible hand of a sculptor from Asia Minor are the particularly close comparisons in quality, subtlety of carving, and treatment of hairlocks that can be made between the Magdalene Tiberius and various portraits from this region . . . The marble of the Magdalene portrait also comes from the same area (Phrygia) as the head of Tiberius from Philomelion in the Louvre (MA 1255). Itinerant sculptors, including those from Asia Minor, worked in the wealthy cities of North Africa, where the lack of high quality white statuary marble necessitated the importation of marble for portraits."

Pollini continues to speculate about the possible provenience of the Magdalene Tiberius based on laboratory analysis of the marble.  Testing showed that the marble from the Magdalene Tiberius came from "ancient Phrygia in central west Turkey. The statistical analysis suggests two possible locations in Phrygia, Afyon and Usak. Afyon, ancient Dokimeion, is the most logical choice. . . . On the basis of the isotopic ratio analysis and what is known about the two quarries, Afyon appears to be the best choice for the provenance of the marble head."

Were the Magdalene and Cleveland Museum marble heads owned by the same collector(s)?  Were they unearthed from the same location? Did they come from Turkey? From Africa? Were they exported to the United States at the same time?  Is the marble the same?  Why did a sales catalog editor determine that Pollini's "A New Marble Head of Tiberius" in Antike Kunst article should be included in the bibliography featuring the Cleveland head?  Answers to these questions can aid a proper due diligence analysis.

Museums are invaluable institutions that transmit culture and knowledge to Americans.  Continued public confidence in our cultural institutions is essential to maintaining a vibrant museum community.  And the application of due diligence to the acquisition of archaeological heritage--as opposed to gentle inquiry--can help museums fulfill their legal, ethical, and social obligations.

In fact, AAMD ethics rules and professional practice guidelines place many responsibilities on a museum director that call for due diligence to investigate an object's collecting history. These include duties that "[t]he director must ensure that best efforts are made to determine the ownership history of a work of art considered for acquisition;" that the "[t]he director must not knowingly allow to be recommended for acquisition—or permit the museum to acquire—any work of art that has been stolen (without appropriate resolution of such theft) or illegally imported into the jurisdiction in which the museum is located;" and that "the director is responsible for the daily monitoring of the institution's compliance with laws and regulations."  AAMD says that "is committed to the exercise of due diligence in the acquisition process, in particular in the research of proposed acquisitions, transparency in the policy applicable to acquisitions generally, and full and prompt disclosure following acquisition."

Among the several rules issued by the Report of the AAMD Task Force are:
  • "Member museums should thoroughly research the ownership history of archaeological materials or works of ancient art (individually a “work”) prior to their acquisition, including making a rigorous effort to obtain accurate written documentation with respect to their history, including import and export documents." (emphasis added) 
  • "Member museums should require sellers, donors, and their representatives to provide all  information of which they have knowledge, and documentation that they possess, related to the work being offered to the museum, as well as appropriate warranties." (emphasis added)
These rules naturally apply to the acquisition of the Drusus Minor head by the Cleveland Museum of Art .

Dr. David Gill's Looting Matters is a blog worth following on this topic.

This post is researched, written, and published on the blog Cultural Heritage Lawyer Rick St. Hilaire at http://culturalheritagelawyer.blogspot.com. Text copyrighted 2012 by Ricardo A. St. Hilaire, Attorney & Counselor at Law, PLLC. CONTACT: www.culturalheritagelawyer.com

The Difference an Ocean Makes

I have recently started receiving email updates from The Global Legal Post, a publication that purports to cover the legal community world-wide. In March 2012, they incorporated the European Lawyer into the publication and so it definitely has a European/British flavor to its reporting.

Which made me smile today when my email contained this teaser:
Row over non-lawyer ownership of legal firms The US's largest legal profession trade union is in disarray over the contentious issue of non-lawyer ownership of law firms, with its senior figures unable to agree a policy.

Not because the American Bar Association is having trouble reaching consensus on an issue, but the description of it as the "largest legal profession trade union." My emphasis.

I am quite sure that many lawyers, and not just at management side employment law boutiques, would be surprised to think of themselves as "trade unionists." But maybe a different way of thinking of ourselves would not be an entirely bad thing.

Grand Jury Hands Up Indictment in Matisse FBI Sting

A federal grand jury in the southern district of Florida (Miami) handed up indictments on Tuesday against a pair with alleged ties to the stolen Henri Matisse painting, Odalisque in Red Pants.  The grand jury charged Pedro Antonio Marcuello Guzman and Maria Martha Elisa Ornelas Lazo with a three count indictment.

The indictment alleges that on or about December 1, 2011, Guzman met with an undercover  Federal Bureau of Investigation (FBI) agent an agent and a confidential informant (CI) of the Federal Bureau of Investigation "to discuss the sale of the Henri Matisse painting 'Odalisque in Red Pants' which had been reported stolen from the Caracas Museum of Contemporary Art (Museo de Arte Contemporaneo de Caracas (MACCSII) in Caracas, Venezuela in or around December 2002." Guzman allegedly gave the CI a password four days later to access an email file containing photographs of the artwork.

Talks continued to work out the payment and transfer of the painting, and Lazo allegedly agreed to transport the stolen artwork from Mexico to the United States. A transaction date of July 17, 2012 was set up where both cash and a wire transfer totaling $740,000 would purchase the painting.

Lazo flew from Mexico City to Miami International Airport on July 16 carrying a red tube that contained the Matisse painting.  She then met with the undercover FBI agent and a second one "posing as an art dealer" in order to close the deal.  Arrests followed.

A July 19, 2012 press release issued by the United States Attorney for the Southern District of Florida, and the FBI Miami Field Office reported that the painting is valued at $3 million.

Guzman and Lazo are each charged with conspiring to transport and sell stolen property (18 USC 371), interstate transportation of stolen property (18 USC 2314), and possession of stolen property (18 USC 2315).  They face potential maximum penalties of five years in prison on the conspiracy count, ten years on the transportation count, and another ten years on the possession count.

Prosecutors also filed a criminal forfeiture action under 18 USC 981(a)(1)(C) in order to gain custody of the painting.  Both the criminal and forfeiture cases are docketed at 12-CR-20559.

An indictment is simply a process of bringing persons into the court process.  The defendants in this case are presumed innocent unless the government proves guilt beyond a reasonable doubt in a court of law.

This post is researched, written, and published on the blog Cultural Heritage Lawyer Rick St. Hilaire at http://culturalheritagelawyer.blogspot.com. Text copyrighted 2012 by Ricardo A. St. Hilaire, Attorney & Counselor at Law, PLLC. CONTACT: www.culturalheritagelawyer.com

Joao Lopes Sentence

This afternoon I joined Kate Cairns, the admirable woman who has campaigned so tirelessly to prevent others sharing the fate of her sister Eilidh who was run down and killed by a lorry driven by Lopes in Notting Hill in February 2009, together with a representative of Roadpeace and a Cairns family friend, at Isleworth Crown Court.  We were there to see Lopes sentenced for the crimes of (1) causing the death by dangerous driving of Ms Nora Gutmann, an elderly pedestrian whom Lopes ran down in June 2011 with a lorry on a light controlled pedestrian crossiing  near Madame Tussauds on Euston Road and (2) falsifying data from the tachograph of the lorry he was driving.
I could have spent the first day of the long legal vacation watching Bradley Wiggins and Chris Froome winning medals in the Olympic Time Trial but I am glad that I instead spent time seeing a case of the type I regularly comment upon.  As a mere member of the public I struggled even to remain in the Courtroom - but this is not the place for me to express my views on the importance that Justice is dispensed openly and publicly.
The simplified facts were that Lopes did not see Ms Gutmann on the pedestrian crossing when he moved off once the lights had changed in his favour.  He was not wearing the glasses that he was required to wear as a condition of his licence following his conviction of driving with uncorrected defective vision which resulted from the investigation, such as it was, that followed the death of Eilidh in February 2009.  When the police drove the lorry away from the accident scene they noticed that the tachograph had been induced to record that the vehicle was at rest.  This had the effect of disabling both the speedometer and the milometer and would have prevented the brakes from applying automatically in the event of an emergency.  Chillingly the magnet was then stolen from the lorry when it was in the police compound, though there is no way of knowing whether Lopes or his employer was responsible for this.
The relevance of Eilidh's death was of course that it made it plain to Lopes that he needed glasses to drive and one would have thought that tragedy would be a sobering experience for any driver regardless of whether or not the police investigation had demonstrated fault on his part.  Yet his subsequent driving record was appalling.  In July 2009 he drove into the rear of another vehicle causing £3,000 worth of damage.  In August 2010 he was involved in a collision though he disputes this was his fault and the Judge therefore rightly disregarded it.  In March 2011 he collided with a parked motor vehicle and failed to stop, as a consequence of which he was dismissed by his then employer.  In June 2011, shortly before he killed Ms Gutmann, he attempted to overtake a minicab so closely that he removed the wing mirror.
His solicitor argued that since none of these incidents had resulted in any conviction they should be disregarded but the Judge wisely disagreed.
His best mitigation was that he had, in interview, come clean over the fact that he had not been wearing his glasses and the effect that imprisonment was having on his family.
The sentence was 4 years imprisonment for the causing death by dangerous driving with disqualification from driving for 6 years following which he would be required to take an extended driving test.  On the tachograph matter he was sentenced to 12 months imprisonment to be served concurrently (i.e 4 years in total).
My own take on this is how very bad we are at preventing needless tragedies on the roads.  I say no more about the admitted deficiencies of the original investigation into Eilidh's death.  The July 2009, March 2011 and June 2011 events are all strongly suggestive of driving offences that merited (at least) points on a licence but it is no surprise that no prosecutions followed these damage only incidents, let alone any near misses there might have been.  Equally it seems implausible that Lopes's employers were unaware that the tachograph on their vehicle was being disabled, yet no action appears to have been taken to ensure that that particular haulier was closed down.
Both Eilidh's and Nora's families have been very generous in their forgiveness, preferring that Lopes never drive again than that he go to prison for a prolonged period.  Their joint press release deserves all the publicity it can get and I reproduce it below.  It is perhaps to be hoped that one day the Court of Appeal will revisit their caution over prolonged and even lifelong driving ban, as technology develops to make such bans more reliably enforceable.

The remainder of this post is the families' press release:


CALL FOR BAN FOR KILLER DRIVER

In a momentous week for cycling when Great Britain's first 2012 Olympic medal has gone to Lizzie Armistead in the women's road race, and Bradley Wiggins became the first Briton ever to be crowned Tour de France champion, families of the nation's everyday cyclists live with fear.  

The failure on the part of authorities to properly protect cyclists and pedestrians on our streets, or to treat these deaths as real crime, is a cause for shame not pride. The families of two victims today stand together to demand better.

They are calling for the Judge at Isleworth Crown Court to permanently revoke the license of Joao Lopes, 56, who has killed not one, but two Londoners. He is to be sentenced today for death by dangerous driving after he killed youthful, fit and active 97 year old Nora Gutman, at a pedestrian crossing in Marlebone.

Shockingly, Lopes had already killed before, but had not been prevented from driving again. In February 2009, Eilidh Cairns, 30, died after being knocked off her bike from behind, run over, and crushed by Lopes' truck. Eilidh, a TV producer, was a strong and experienced cyclist who did a daily 20 mile commute and knew of the dangers of HGVs.

The police found no connection between Eilidh's death and the actions of the driver.  Lopes pleaded guilty to the minor charge brought of driving with uncorrected defective vision. He was fined £200 pounds, given three points on his licence and permitted to carry on driving a tipper lorry.

Police later admitted the investigation had been substandard and carried out a full review following the death of Ms Gutman but the CPS again decided that no charge would be brought with respect to Ms Cairns' death.  Lopes went on to have at least three more driving collisions before finally killing Nora Gutman whilst driving without his glasses. He also pleaded guilty to a tachograph offence.

There is a shocking disconnect between our national pride and support for the cyclists representing our country in competition and the inherent complacency about the slaughter of cyclists and pedestrians on our streets. HGVs are involved in more than 50% of deaths of London's cyclist and yet make up less than 4% of road traffic. Twice as many pedestrians were killed by HGV than cyclists in the first decade of this century.

And yet, dangerous drivers generally do not have their licences revoked after fatal collisions. Only three drivers were given a lifetime ban in 2011. If Lopes is banned for life today it will be two deaths too late.

Kate Cairns, sister of Eilidh, set up the See Me Save Me campaign to eliminate the blind spots in lorries.

Kate says: The defence of most drivers involved in the death of vulnerable road users is that they simply didn't see them. This is not good enough. We have affordable technology such as cameras and sensors which eliminate blind spots. It is installed on new cars to protect bumpers so why do we value the life of a cyclist less than the sheen of a bumper? We need to re-evaluate the focus on victim blaming. More pedestrians are killed by HGVs than cyclists, but the government doesn't urge pedestrians to wear high vis and helmets. The danger is posed by huge clumsy vehicles driven blind in tiny shared spaces. Focus has to be on the vehicle that poses the greatest risk, the trucks, and the responsibility to manage the risk has to be proportionate.

It is clear that the justice system in Eilidh’s case failed to respond properly and Lopes was allowed to carry on driving. If it is decided he will be kept off the road today it will be a great relief but it is too late for Nora, and too late for Eilidh. We need to treat road crime as real crime.  We need proper and competent police investigation that is transparent and accountable. We need to afford cyclists and pedestrians the protection of the law, just like any citizen.

Stricter liability, as in so many other countries, would incentivise employers to equip their drivers properly and to train them to do the job asked of them. It would also ensure truck companies and construction clients set and enforce proper standards and best practice. All we are asking is that the legal system is such that people on our streets are not at danger of death and maiming from commercial activities. HGVs are mobile places of work.

Having campaigned for three years since Eilidh's death so others do not have to die I am here because of the death of another amazing woman, Nora Gutman, who was run over by the same kind of truck by the same driver. None of us should be here to today and that includes Lopes. Blind spot danger could have and should have been designed out. Because our transport and justice systems tolerate risk on our roads, my family and the Gutmans are shattered, whilst that of Lopes will suffer his imprisonment. No-one should have had to suffer, least of all Nora and my sister.


Victim impact statement from the family of Nora Gutmann

Though 97, Nora Gutmann was still youthful when she died. She was still healthy, still living on her own, still totally independent. We all looked forward to many years left with her. She was also still totally engaged in living, learning, growing. She listened to various engaging programmes on the BBC on a regular basis, read voraciously and has, for many years, been enrolled and engaged at the University of the Third Age -- a school for retired people where she had signed up for a course in Buddhism for the fall term. Nora was also a deeply forgiving person. I don’t think she would have wanted Joao Lopes to be sent to prison, or to deprive his family of a breadwinner. As a family we don’t feel a desire for retribution against Lopes. We have been informed by the police that Lopes may drive again, and could even get his Heavy Goods Vehicle (HGV) license back at some point. We find the possibility that Lopes could ever drive again to be completely outrageous. Lopes killed Eilidh Cairns, a 30 year old experienced cyclist in 2009. He continued driving dangerously after that, having at least three more driving collisions before killing Nora, and shockingly there was no system in place to monitor this dangerous behavior or to take him off the roads. We ask the court to do everything in its power to protect the public and prevent Lopes from ever again getting behind the wheel of any vehicle.


MOPAC Survey

MOPAC, the Mayor's Office for Policing and Crime, just emailed me inviting me to complete a questionnaire on where I consider that the Metropolitan Police's priorities should lie.  I have indicated that I would like to see steps taken to make bad driving easier to report and more likely to be prosecuted.  If you are affected by policing in London you may like to know that there questionnaire is here

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