News

Surely The SEC Is Sick Of Going To Court By Now?

A lot of legal issues look like substantive things but are actually things about what institutions can and want to do. Obviously more people want to think about questions like “should the U.S. have universal health insurance?” than about questions like “does the Anti-Injunction Act bar lower federal courts from reviewing the individual mandate until taxes are collected in 2014?,” but judges tend to get into the latter question. That’s why they’re judges. That difference can make judicial decisions sort of hard to interpret.

Today everyone’s favorite federal judge, Jed Rakoff, surprised few but pleased many by beating the ever-loving crap out of the SEC’s settlement with Citigroup, in which Citi had agreed to pay the SEC $285 million in exchange for the SEC not asking too many questions about its synthetic CDO deals that were maybe not so hot. Here’s the gist of it:

Applying these standards to the case in hand, the Court concludes, regretfully, that the proposed Consent Judgment is neither fair, nor reasonable, nor adequate, nor in the public interest. Most fundamentally, this is because it does not provide the Court with a sufficient evidentiary basis to know whether the requested relief is justified under any of these standards. Purely private parties can settle a case without ever agreeing on the facts, for all that is required is that a plaintiff dismiss his complaint. But when a public agency asks a court to become its partner in enforcement by imposing wide-ranging injunctive remedies on a defendant, enforced by the formidable judicial power of contempt, the court, and the public, need some knowledge of what the underlying facts are: for otherwise, the court becomes a mere handmaiden to a settlement privately negotiated on the basis of unknown facts, while the public is deprived of ever knowing the truth in a matter of obvious public importance.

Here, the S.E.C.’s long-standing policy – hallowed by history, but not by reason – of allowing defendants to enter into Consent Judgments without admitting or denying the underlying allegations, deprives the Court of even the most minimal assurance that the substantial injunctive relieve it is being asked to impose has any basis in fact.

Right on! But also maybe just a little disingenuous. Judge Rakoff was not being asked for “substantial injunctive relief,” not really. It looks like that on the surface, in the sense that (1) the SEC and Citi worked out a deal where Citi gives the SEC money, promises not to violate the securities laws again, and agrees to do some remedial stuff like telling its salespeople to stop peddling synthetic CDOs structured by the protection buyer without telling anyone because somehow that is still a problem; and in the sense that (2) the SEC was asking Judge Rakoff to enshrine that agreement in an injunction. And then, if Citi didn’t keep its agreement – by not doing the remedial things, say, or by violating the securities laws again – the SEC could go back to court and say “hey, Citi violated the injunction” and Judge Rakoff could hold Citi in contempt and fuck. it. up.

And that is the theory, and it is a lovely theory, but as has been rather hilariously documented, companies enter these agreements all the time, and then keep violating the securities laws, and never ever ever ever get held in contempt. So the odds were zero that Judge Rakoff would ever be asked to get “formidable” on Citi’s ass just because it kept on violating the securities laws.

The flip side is that, as Judge Rakoff hints, the SEC could get everything it wants without ever going to court. Money, for instance. Judge Rakoff’s opinion is about the power of injunctions, because he’s been asked for an injunction, but if you hadn’t been paying close attention you might think that the SEC/Citi settlement was not about enjoining Citi not to keep breaking the law but was instead about getting Citi to pay the SEC $285 million. You might think that because, among other reasons, that’s how the SEC headlined its press release about the settlement.

Now, if (1) Citi wants to give the SEC $285 million, and (2) the SEC wants to take it, and (3) they don’t want to have a trial, they can just do that. They don’t need a court to sign off on it. Citi writes a check, the SEC drops its lawsuit, the end.*

The injunctions are harder – if Citi and the SEC agree outside of court that Citi will have to retrain its sales force, and Citi doesn’t do that, then the SEC can’t hold Citi in contempt. But being held in contempt of court is not the only bad thing that can happen to a bank. Citi can agree to do whatever the SEC wants it to do, after negotiation, and the SEC has quite serious mechanisms to enforce that agreement. So if Citi and the SEC signed a settlement saying “Citi will put in big red letters on the front cover ‘these mortgages were chosen for you by people who hate you and want you to fail at life,’ and it agrees that failing to do that constitutes securities fraud,” then if Citi doesn’t obey the settlement it’s admittedly committed securities fraud and its consequences – fines, criminal liability, what have you – would be at least as bad as the consequences of violating an injunction. They’re all hypothetical consequences – the SEC is no more likely to, say, bar Citi from the securities industry than a court would be to imprison Vikram Pandit for contempt – but they’re real enough to make Citi try hard to do the things it agreed to do.

So the SEC can get (1) money and (2) reasonable assurance that Citi will try really hard not to do more terrible things without any court approval. In fact, the SEC did exactly that with Credit Suisse in this case. (CS were the ones going around claiming that they’d picked the underlying mortgages to be the very best mortgages that they could be, which was maybe less accurate than “Citi picked the underlying mortgages that it wanted to have a short position on.”) The SEC, on the same day it announced its settlement with Citi, announced its administrative settlement with Credit Suisse, which involved fines, disgorgement, “we promise not to be bad any more” agreements, and suspending one Credit Suisse guy from the securities industry for six months.

So why didn’t they do that with Citi? Why didn’t the SEC and Citi just agree on what the deal was and announce it in a press release, rather than agree on what the deal was and announce it in a press release and submit it to a judge who just hates, hates, hates the SEC and who they had to know would call them out for being generally all-around shoddy re: this whole Citi thing?

I don’t know. Part of it is that the SEC’s enforcement mechanisms are complex, and there are some benefits to the SEC in getting a court-approved settlement rather than an SEC-only “cease and desist order” settlement. Perhaps I’m missing something that makes a court order critical – in particular, the SEC-only cases have caps on civil penalties, though they seem pretty malleable (they’re per day of violation, which, y’know, find a day that Citi wasn’t in violation of a securities law), and though I doubt anyone would be able to object if the SEC and Citi just agreed on a bigger fine than those caps allow.

But I suspect that the main answer is symbolic: there’s a sense that you go to court in the Big Cases, and you make a Big Public Deal of them, and – of course – the judge goes along with the SEC’s Exhaustively Researched Case. I mean, it worked with Goldman and JPMorgan, and the Citi case is not really less compelling than those cases. It just got a less favorable judge.

Now, of course, the symbolism has broken down, and the SEC is stuck. It probably still could, legally, drop this case and settle everything up privately – Judge Rakoff probably can’t literally force the SEC to go to trial, all he can do is refuse to issue the injunction that the settlement calls for – but then the SEC would look even worse than it usually does. Which means it has to either go to trial or negotiate a better deal – maybe a higher fine, certainly more disclosure and admissions – that Rakoff can sign off on. That will be tough, given that Rakoff clearly thinks that Citi did intentional badness – and that admitting intentional badness could lead to hundreds of millions or billions of liability to private purchasers of these CDOs. So Citi can’t really settle the way Rakoff wants, the SEC can’t really settle the way Citi wants, and we may actually see a trial.

Which might push the SEC to think a little more carefully in the future – not about whether its settlements are in the public interest (whatever Judge Rakoff may think, the SEC clearly believes that getting a $285 million unlitigated settlement out of Citi is a good deal here – and I’m not sure they’re wrong), but about whether the legitimacy it can get from having a federal court approve these settlements outweighs the pain of having them reviewed by judges. If the SEC does everything in its own administrative actions, then everyone involved is a repeat player at the SEC or in the securities industry: they understand each other, and they can work out settlements that are good for the industry and seem like rough justice to everyone closely involved.

Judges, on the other hand, tend to be smart, independent, not deeply in the weeds of the securities industry, not so concerned with keeping up relationships between banks and regulators, not as attuned to Citi’s capital position – and used to a little bit more public airing of grievances than the SEC might like. Here’s how Rakoff concludes his opinion:

In much of the world, propaganda reigns, and truth is confined to secretive, fearful whispers. Even in our nation, apologists for suppressing or obscuring the truth may always be found. But the SEC, of all agencies, has a duty, inherent in its statutory mission, to see that the truth emerges; and if it fails to do so, this court must not, in the name of deference or convenience, grant judicial enforcement to the agency’s contrivances.

Yeah, but. The SEC minute by minute, hour by hour, in all sorts of ways fails to see that truth emerges. Sometimes that gets noticed, resulting in a public scolding from Rakoff, or David Kotz, or Matt Taibbi. Most of the time, though, it doesn’t get noticed. Bringing lawsuits in the Southern District of New York is a good way to get the SEC’s failings noticed. Bringing SEC administrative actions, announcing big fines with upbeat press releases, and not having them subject to any review, is a good way to sweep them under the rug. The more scrutiny that the SEC gets when it goes to court, the more tempted it will be to handle cases like this on its own.

One thing that might give them pause, though. The SEC has, in the wake of recent expansions of its powers under Dodd-Frank, experimented with moving away from the courts and towards administrative actions when its case against supposed wrongdoers maybe isn’t so hot. It’s already been slapped down for doing so. By Jed Rakoff.

SEC v. Citigroup Global Markets [pdf, via ZH]

Rakoff Causes More Heartburn at the SEC [WSJ Law Blog]

* Of course if a cop says to you “well, I was going to arrest you for pepper-spraying your fellow holiday shoppers, but if you give me $285 I’ll let it go,” that would look, um, bad, but the SEC actually does have the power to collect out-of-court fines. The biggest I’ve found outside of court was $34 million on top of $34 million disgorgement, which is not nothing. These have a more formal process than just writing a check to Mary Shapiro, but not by much – and a court never gets to touch them.

150 comments
(hidden for your protection)
Show all comments

150 Responses to “Surely The SEC Is Sick Of Going To Court By Now?”

  1. ddddddsd says:

    No charts, didn't read.

  2. Guy with A.D.D. says:

    I was a young man when I started reading this article, when I finished I looked like the grey bearded man (Wow is his name really Red Jackoff?) pictured at the top of it

  3. Reader in Texas says:

    I liked the article. Good job.

  4. early_hominid says:

    It doesn't look like they are. And stop calling me Shirley.

  5. Guest says:

    You had how many days, and this is what you came up with?

  6. g lucas says:

    this post would be so much better in 3D

  7. What about his legitimate years? says:

    SEC/Judge Rakoff are like their very own stimulus program from struggling major law firms of Midtown. Why without them dozens of law firm associates would probably find themselves unemployed as they flirt with the minimum billable requirements but now! Extra briefs to prepare, maybe a full blown trial to participate in. Huzzah!

  8. Guest says:

    nice tags

  9. Guest says:

    God Damnit Matt.

  10. Jack & Rod Show says:

    Fist time caller, last time reader…..

  11. Matt Fan but... says:

    Are you sure you meant to post this on Dealbreaker? Isn't this site supposed to be kind of, oh, funny?

  12. notaGuest says:

    i dont know how much more abuse Matt can take..

  13. The Truth says:

    "hallowed by history, but not by reason"

    Thought that was Rakoff's take on tranny porn consumption at the SEC

  14. Qqm0X9 Very informative article post.Really looking forward to read more. Much obliged.

  15. Im grateful for the post.Really looking forward to read more. Fantastic.

  16. acn inc says:

    Very good post.Really thank you! Much obliged.

  17. I value the blog post.Really thank you! Great.

  18. Great, thanks for sharing this blog. Fantastic.

  19. Music says:

    I really like and appreciate your post.Thanks Again. Want more.

  20. I am so grateful for your post.Thanks Again. Really Great.

  21. Really informative blog post. Really Cool.

  22. Thanks so much for the blog article.Thanks Again. Cool.

  23. Very good blog article.Much thanks again.

  24. Hey, thanks for the blog article.Much thanks again. Awesome.

  25. I cannot thank you enough for the blog article. Really Great.

  26. Thanks-a-mundo for the blog post.Much thanks again. Will read on…

  27. HOT says:

    I really enjoy the blog post.

  28. Major thankies for the post.Really thank you! Much obliged.

  29. Im thankful for the article. Want more.

  30. Appreciate you sharing, great article post.Really looking forward to read more. Want more.

  31. Im obliged for the blog article. Great.

  32. Great, thanks for sharing this article post.Thanks Again. Cool.

  33. Great blog post.Really thank you! Great.

  34. I actually like your word press template, just wherever do you get a hold of it through?

  35. Wow, great blog post.Really thank you! Keep writing.

  36. This is one awesome article post.Thanks Again. Fantastic.

  37. Enjoyed every bit of your blog.Really thank you! Really Cool.

  38. Really appreciate you sharing this post.Really looking forward to read more. Really Cool.

  39. seospidy says:

    Im grateful for the blog.Really looking forward to read more. Will read on…

  40. Very neat blog article.Thanks Again. Awesome.

  41. Thanks a lot for the article.

  42. Great post.Much thanks again. Want more.

  43. EB1A says:

    Really enjoyed this post.Thanks Again. Really Great.

  44. A round of applause for your article post.Really thank you! Want more.

  45. india jobs says:

    Really appreciate you sharing this article post.Really looking forward to read more. Will read on…

  46. I appreciate you sharing this blog article.Really thank you! Keep writing.

  47. Major thankies for the post.Thanks Again. Fantastic.

  48. I am so grateful for your article post.Thanks Again. Keep writing.

  49. I value the blog.Thanks Again. Keep writing.

  50. I cannot thank you enough for the post.

  51. I value the blog post.Really looking forward to read more. Really Cool.

  52. EV speakers says:

    Thanks again for the post.Thanks Again. Awesome.

  53. wegner says:

    I loved your blog article.Really thank you! Really Great.

  54. Thank you for your blog article.Thanks Again. Keep writing.

  55. Thanks again for the blog.Thanks Again. Want more.

  56. I think this is a real great blog article.Much thanks again. Will read on…

  57. wow, awesome article post. Really Cool.

  58. Wow, great post.Much thanks again. Cool.

  59. Really appreciate you sharing this blog post.Really looking forward to read more. Great.

  60. Oma Quiring says:

    Thanks for sharing, this is a fantastic blog.Really looking forward to read more. Fantastic.

  61. Really informative blog post. Want more.

  62. I really enjoy the post.Really looking forward to read more. Much obliged.

  63. remortgage says:

    Appreciate you sharing, great blog post.Thanks Again. Fantastic.

  64. Very good blog post. Will read on…

  65. Really enjoyed this article post.Thanks Again. Cool.

  66. Wow, great post.Really looking forward to read more. Awesome.

  67. goal setting says:

    Looking forward to reading more. Great blog article.Much thanks again. Cool.

  68. I loved your post.Much thanks again. Want more.

  69. Awesome blog.Thanks Again. Will read on…

  70. I am so grateful for your post.Thanks Again. Awesome.

  71. party says:

    Appreciate you sharing, great blog article. Will read on…

  72. SEO New York says:

    I loved your blog post. Awesome.

  73. I loved your blog post. Really Great.

  74. I think this is a real great article post.Much thanks again. Really Great.

  75. I appreciate you sharing this article post.Much thanks again. Much obliged.

  76. Thanks for the article. Really Cool.

  77. handjob says:

    Thanks-a-mundo for the blog.Really thank you! Want more.

  78. Very informative blog post.Much thanks again.

  79. I really liked your article.Thanks Again. Keep writing.

  80. Fantastic article.Really thank you! Want more.

  81. Im grateful for the blog.Really looking forward to read more. Cool.

  82. Thanks for sharing, this is a fantastic blog post.Much thanks again. Cool.

  83. Thanks for sharing, this is a fantastic post.Thanks Again. Really Cool.

  84. Im obliged for the article.Really thank you! Fantastic.

  85. quickly says:

    Thanks so much for the article.Really looking forward to read more. Cool.

  86. carlsbad says:

    Thanks so much for the blog article.

  87. Dale Rusten says:

    my goal is to finish the baby quilt I commenced two weeks ago. We have to seriously push myself because this is finals week and my brains are mush!

  88. Currently it appears like BlogEngine is the preferred blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

  89. Are you sure you meant to post this on Dealbreaker? Isn't this site supposed to be kind of, oh, funny?

  90. Netnews ‘s been around for any while. It truly is even significantly older than the planet wide web- exactly what most everyone knows as being the

  91. Woah! I’m really enjoying the template/theme of this website. It’s simple, yet effective. A lot of times it’s very difficult to get that “perfect balance” between superb usability and visual appearance. I must say you have done a amazing job with this. Additionally, the blog loads super fast for me on Safari. Excellent Blog!

  92. Wonderful website. Plenty of helpful information here. I am sending it to a few pals ans additionally sharing in delicious. And obviously, thank you to your sweat!

  93. Hey there it’s me once more, just questioning when there is certainly a great rss feed i possibly could sign as much as?! Truly enthusiastic about understanding a great deal more concerning this.

  94. Good day! I know this is kinda off topic however I’d figured I’d ask. Would you be interested in trading links or maybe guest writing a blog article or vice-versa? My website addresses a lot of the same topics as yours and I think we could greatly benefit from each other. If you’re interested feel free to shoot me an email. I look forward to hearing from you! Excellent blog by the way!

  95. Excellent data and also directly to the actual. I don’t determine this is actually the number 1 place to inquire about yet can you mankind has any applying for grants where you can utilize a few ghost writers? http://www.phlebotomycertificationhq.com

  96. Many thank you ! Hi Blogger! I ran across your web site employing Google and as a Search engine optimizer

  97. Hi all, just converted into conscious of your website by way of Search engines like google, and found that it is in fact beneficial.

  98. You completed a few good points there. I did a search on the subject and found mainly persons will consent with your blog.

  99. Thanks for the auspicious writeup. It in truth was a leisure account it. Glance complex to far added agreeable from you! However, how could we keep in touch?

  100. Tana Creenan says:

    I guess getting some factor genuine at the same time as substantial to provide details of is actually a crucial factor.

  101. Simply a rapidly hello there as well as we appreciate you talking about your thoughts in this particular website. I ran across themselves as part of your website when studying conditioning related troubles upon Aol speculate I lost in addition to what I ended up being carrying out! At any rate I’m gonna be rear as soon as once again inside the conclusion to verify your own blogposts as time goes on. Cheers! http://www.phlebotomycertificationhq.com/

  102. The leadership of the PCUSA left the scripture behind long ago. This is just a symptom of a challenge with the leadership, not necessarily all on the rank and file. It is simply the practice of Replacement Theology, something which is not supported by either the Old or New Testament.

  103. a entire lot much a lot more of your current respective thrilling content material. Just be certain you up-date this once again soon.

  104. hello there and thank you for your information – I’ve definitely picked up anything new from right here. I did however expertise several technical points using this website, since I experienced to reload the site lots of times previous to I could get it to load correctly. I had been wondering if your hosting is OK? Not that I’m complaining, but slow loading instances times will very frequently affect your placement in google and could damage your high quality score if ads and marketing with Adwords. Well I am adding this RSS to my email and could look out for much more of your respective interesting content. Make sure you update this again soon..

  105. UjNs0w Looking forward to reading more. Great blog. Much obliged.

  106. Terrific paintings! That is the kind of info that are meant to be shared around the internet. Shame on Google for now not positioning this post higher! Come on over and visit my web site . Thank you =)

  107. A penny stock may well not be considered a good buy simply because it truly is affordable, as well as a three-digit stock shouldn’t scare you away simply because it carries a significant selling price tag.

  108. oirvpanz [url=http://chaussureslouboutinsoldes.webnode.fr/#4454]louboutins[/url] xtcuaouy louboutin pas cherg zimvfjzr http://chaussureslouboutinsoldes.webnode.fr/

  109. Definitely believe that which you said. Your favorite justification appeared to be on the net the easiest thing to be aware of. I say to you, I certainly get annoyed while people consider worries that they plainly don’t know about. You managed to hit the nail upon the top and also defined out the whole thing without having side-effects , people can take a signal. Will probably be back to get more. Thanks

  110. Perry Dornak says:

    fantastic points altogether, you just gained a new reader. What would you suggest in regards to your post that you made a few days ago? Any positive?

  111. We actually like this net web site. May well inform me how I can maintaining therefore far by utilizing it?

  112. I am continually invstigating online for ideas that can facilitate me. Thx!

  113. Merbroods says:

    what is the name and place of this correction

  114. There is obviously a bunch to know about this. I suppose you made various good points in features also.

  115. Leonia Tine says:

    Hey, thanks for the post.Really looking forward to read more. Keep writing.

  116. Wow, awesome blog layout! How long have you been blogging for? you make blogging look easy. The overall look of your website is wonderful, let alone the content!

  117. I would like to thanks for your efforts you have made on paper this precise publish. I hope a similar very best performance from you inside the future also.

  118. Iliana Ficht says:

    Hmmm… fantastic !! u’r the main one particular gentleman !!

  119. fpaost [url=http://chaussuresjordannsoldes.webnode.fr/#4947]air jordan pas cher[/url] guivmi jordan pas cher dtrcbm bplfgchcu [url=http://frlouboutinnssoldes.webnode.fr/#7273]chaussures louboutin[/url] bhquoydoqk christian louboutin pas cher bjyixhs ubfeib [url=http://airjordnndesoldes.webnode.fr/#6223]jordan pas cher[/url] tmqyzt air jordan pas cher tggohg

  120. Good post. I had been checking out constantly this site that i’m amazed! Very helpful details in particular the final component My partner and i take care of such details a whole lot. I was looking for this kind of selected details for a number of years. Thank you and finest regarding good luck. http://www.silkroadgoldbuy.com/how-to-make-beaded-bracelets.html

  121. Arrivatriva says:

    ptrgegdd [url=http://sacvuittonsonlinesoldes.com/#6135]sac louis vuitton[/url] dhboznvf sac louis vuitton pas cher bycswftj http://sacvuittonsonlinesoldes.com/dzpyjsub [url=http://sacsvuittonpascher.webnode.fr/#5365]sac vuitton[/url] gpawioch sac louis vuitton pas cher irubccjp http://sacsvuittonpascher.webnode.fr/

  122. Hello there, I discovered your website by way of Google whilst searching for a similar matter, your website got here up, it seems to be good. I’ve bookmarked it in my google bookmarks.

  123. Nice post. I used to be examining consistently this site and I am impressed! Very useful details in particular the last element I maintain these kinds of details a lot. I had been seeking this kind of particular details to get a very long time. Many thanks and finest associated with good fortune. http://www.silkroadgoldbuy.com/mens-beaded-bracelets.html

  124. Faureauff says:

    jkqneo [url=http://doudounemclersmagasin.webnode.fr/#9837]moncler pas cher[/url] septyr doudoune moncler hpqghi ckuvwoka [url=http://airjordnnsoldes.webnode.fr/#8801]jordan spizike[/url] uedkveprqs air jordan pas cher scwqjdi kvswpsxjf [url=http://louboutinnmagasinn.webnode.fr/#1510]christian louboutin pas cher[/url] rcphvxyewh christian louboutin pas cher gbrnxuo

  125. certainly like your web site but you need to take a look at the spelling on quite a few of your posts. Several of them are rife with spelling issues and I in finding it very bothersome to tell the reality nevertheless I¡¦ll surely come again again.

  126. We are a group of volunteers and opening a new scheme in our community. Your website offered us with valuable info to work on. You have done a formidable job and our whole community will be grateful to you.

  127. I have been reading out many of your posts and i must say pretty good stuff. I will surely bookmark your website.

  128. Dumpusase says:

    tfgxvspc [url=http://frmclersdoudounesoldes.com/#63850]moncler[/url] jpsuwzlcvz moncler lvltzhn

  129. lidaa kapsul says:

    I buy enjoyment through reading any distribute that will make individuals think.

  130. Many thanks for creating the effort to discuss this, I deem solidly in relation to this and enjoy studying a abundant deal further by this subject. Rider feasible, as you gain expertise, would you mind updating your website with a great pact further info? It’s especially beneficial in support of me.

  131. KjLFWT I really enjoy the article post. Will read on…

  132. Brian Yambao says:

    Thanks a whole lot! I not too long ago added your blog for the blogroll. Meow!

  133. I’m disappointed I am able to only “thumbs-up” this post only as soon as.

  134. go here says:

    I loved as much as you will receive carried out right here. The sketch is tasteful, your authored subject matter stylish. nonetheless, you command get bought an nervousness over that you wish be delivering the following. unwell unquestionably come more formerly again since exactly the same nearly very often inside case you shield this hike.

  135. Jule Bradd says:

    … This is a great point, because this is by far the most convincing just one hour 40 moment borefest. Get that bit and then move on.br / IMDb requires ten lines of text so I am going to require the rest of this place to jot down what I know of owls. In general, I like owls so I rarely see in nature. You will discover owls white, brown, blue red and owls. Some owls are huge, some are pretty compact although not so little a hummingbird.br / In the event you could be reincarnated like a bird, I believe which the owl would be near the most notable of my list, but it will be better than an eagle or a hawk, or a jay ….. The owls are typically about an eight outside of 10 in terms of ranking are my birds. Cat Operate just like a movie, but it surely can be about 3 outside of 10. Montenegro looks to get an exceedingly wonderful position to consider a vacation ….

  136. Thanks a whole lot, this post is extremely useful as often. Continue the excellent operate! You have got +1 significantly far more readers of one’s superb weblog:)

  137. Nu am sa vorbesc aici despre Slavici, opinia lui George Calinescu, si centrale termice a altor exegeti, cu privire la povestea d-lui Creanga, Danila Prepeleac. Am sa va spun ceea ce Dvs. nu stiti despre aceasta poveste. Povestea lui Danila Prepeleac, este un apocrif biblic, deoarece informatia transmisa de. O scrisoare pierduta de I.L.Caragiale Capodopera dramatugiei lui Caragiale este O scrisoare pierduta (1884) si

  138. Bruno Rensen says:

    I desire to make reservations for 30 Senior Citizens with the Initially Christian Church in Owensboro, Ky. You should convey to me the way to make reservations.

  139. link says:

    although internet sites we backlink to below are drastically not in connection with ours, we presume they’re really worth a spin by means of, and so do a look

  140. Can one carry out part of the post for you to my internet site?

  141. hi, be present obliged you your handwriting technique is brilliant. due set up your section on aol. move forward fullback later used for positive

  142. I truly love your site.. Very nice colors & theme. Did you make this website yourself? Please reply back as I’m hoping to create my very own website and would love to find out where you got this from or exactly what the theme is named. Appreciate it!

  143. skitty poop says:

    Awesome writing style!

  144. Thank you for taking the time to speak about this, I really feel highly about this and genuinely like studying on this sort of topic matter.

  145. Bret Paull says:

    I think it is the good idea for Texas.