Attorneys, E-Discovery, and the Case for 37(G)

There are currently various sources of authority that federal courts can invoke to sanction attorneys who bungle their e-discovery obligations, but each is insufficient. All fifty states have their own rules authorizing courts within the state to refer misbehaving attorneys to the local disciplinary body, but each state’s rule is different, leading to much inconsistency and lack of uniformity among the federal courts. The Federal Rules of Civil Procedure (“FRCP”) address e-discovery abuse but do not authorize courts to impose sanctions on attorneys for their role in e-discovery abuse. This is a problem because attorneys have ethical and professional obligations to preserve evidence and advise clients on what information needs to be preserved and how. Many failures to properly preserve ESI can be traced back to the lawyer. This obligation is especially important today, where much evidence and information is found through various electronic forms. Something must be done to provide predictability, uniformity, and efficiency for courts when imposing sanctions for e-discovery violations. Because ESI is so important to discovery, and because attorneys play such a major role in the discovery process, the FRCP should add a Rule giving courts authority to impose sanctions against attorneys who act improperly in e-discovery. Part I of this Note will discuss the history of discovery and the rise of e-discovery as technology gathered steam. Part II will explain the benefits and costs of technology and e-discovery, and the various ethical obligations and common law expectations that attorneys currently have when it comes to e-discovery. Part III will review several sources of authority that federal courts have used in the past to impose sanctions on attorneys for their role in e-discovery abuse. Part IV will propose a new Rule to be added to the FRCP, which would give federal courts a uniform, reliable system of imposing e-discovery sanctions on attorneys. Part IV will continue with a discussion of the shortcomings of other suggested solutions and potential concerns with a new FRCP Rule

DETECTION OF STX2 COLIPHAGES IN STRAIN OF ESCHERICHIA COLI ISOLATED FROM BOVINE FLEECE AND MILK FILTERS

Lambda(4)-phage vectors of gene codifying for synthesis of Shiga-toxins are suspected to be involved in the virulence evolution of Vero-Toxin producing Escherichia coli(VTEC). Herds of domestic or wild ruminants are reservoirs of these bacteria, but excretion with faeces is more frequent in groups of heifers and feeder calves. Studies have shown that slurries produced by infected herds are often positive for VTEC and that Stx2 carrying lambda coliphages can be isolated. These viruses can induce lysogenic cycles only in some strain of Escherichia coli and the Stx gene is then integrated in the bacterial chromosome. When these bacteria also posses other virulence traits, like those responsible for the intimate attachment to the enteric mucosal cells (eae or saa) the recombinant strains might became pathogen for humans. Our research was aimed at detecting the coliphages form ten Stx2 positive strains isolated in our previous studies. We have included strains, possessing or not the 'eae' genes. In addition we have used other isolates originating from slaughterhouses, with the aim of evaluating their susceptibility to the isolated 4-phages. Following induction of a lytic cycle with mitomycin C, the strains were screened by hybridization of plaque blots with Stx2 probes. The purified extracts of eight of the ten strains produced plaque/halos of lysis in cultures of susceptible strains, thus showing these strains were infected by inducible phages, but only one proved to be Stx2 carrier. Attempt to obtain new lysogens using the purified Stx2 phage with other strains 'eae' positive and STx negative isolated from slaughterhouses were unsuccessful. Stx2 lysogens were obtained only using the reference strains DM1187

Heart Angiotensin-Converting Enzyme and Angiotensin-Converting Enzyme 2 Gene Expression Associated With Male Sex and Salt-Sensitive Hypertension in the Dahl Rat

Angiotensin-converting enzyme 2 (ACE 2) in the heart including its sex dependency in the hypertensive heart, has not been much studied compared to ACE. In the present study, we used the Dahl salt-sensitive rat exposed to fructose and salt to model a hypertensive phenotype in males, females, and ovariectomized females. Blood pressure was measured by the tale-cuff technique in the conscious state. Expression of RAS-related genes ACE, ACE2, angiotensin II receptor type 1, Mas1, and CMA1 in the heart were quantified. The results revealed small but significant differences between male and female groups. The main results indicate the presence of a male preponderance for an increase in ACE and ACE2 gene expression. The results are in accordance with the role of androgens or male chromosomal complement in controlling the expression of the two ACE genes

Genotyping at the CSN1S1 locus by PCR-RFLP and AS-PCR in a Neapolitan Goat Population

The goat CSN1S1 gene has for many years been an excellent model for demonstrating that most of the variability observed in the as1-casein content in goat’s milk is due to the presence of autosomal alleles at a single structural locus. Until now, about 17 alleles associated to at least four levels of as1-casein expression in milk have been described at the CSN1S1 locus in the domestic goat (Capra hircus). The great importance of goat as1-casein polymorphism is due to its qualitative as well as quantitative implications. In the present work five PCR protocols (PCR-RFLPs, AS-PCR) were set up for rapid genotyping of B1, B2*, B3, B4 and C CSN1S1 alleles, until nowdetectable only by milk electrophoresis. Application of these protocols, together with previously described methods to identify CSN1S1 01, E, M, F, N and A* (CSN1S1 A, G, I, H) alleles, allow us to define, at DNA level, the genetic structure of the autochthonous goat reared in the province of Naples for the highest number of possible alleles at this locus. Monitoring of CSN1S1 variability in the Neapolitan goat population indicates a high frequency of low (F, 0.368) and null (N, 0.227) alleles

Comparative morphology of skeletal development in homo sapiens and raja asterias: divergent stiffening patterns due to different matrix calcification processes.

Before calcification begins, the early embryonic and fetal skeletal development of both mammalian Homo sapiens and the chondrichthyan fish Raja asterias consists exclusively of cartilage. This cartilage is formed and shaped through processes involving tissue segmentation and the frequency, distribution, and orientation of chondrocyte mitoses. In the subsequent developmental phase, mineral deposition in the cartilage matrix conditions the development further. The stiffness and structural layout of the mineralized cartilage have a significant impact on the shape of the anlagen (early formative structure of a tissue, a scaffold on which the new bone is formed) and the mechanical properties of the skeletal segments. The fundamental difference between the two studied species lies in how calcified cartilage serves as a scaffold for osteoblasts to deposit bone matrix, which is then remodeled. In contrast, chondrichthyans retain the calcified cartilage as the definitive skeletal structure. This study documents the distinct mineral deposition pattern in the cartilage of the chondrichthyan R. asterias, in which calcification progresses with the formation of focal calcification nuclei or “tesserae”. These are arranged on the flat surface of the endo-skeleton (crustal pattern) or aligned in columns (catenated pattern) in the radials of the appendicular skeleton. This anatomical structure is well adapted to meet the mechanical requirements of locomotion in the water column. Conversely, in terrestrial mammals, endochondral ossification (associated with the remodeling of the calcified matrix) provides limb bones with the necessary stiffness to withstand the strong bending and twisting stresses of terrestrial locomotion. In this study, radiographs of marine mammals (reproduced from previously published studies) document how the endochondral ossification in dolphin flippers adapts to the mechanical demands of aquatic locomotion. This adaptation includes the reduction in the length of the stylopodium and zeugopodium and an increase in the number of elements in the autopodium’s central rays

Preliminary assessment of persistent organic pollutants (POPs) in tissues of Risso's dolphin (Grampus griseus) specimens stranded along the Italian coasts

Ecotoxicological and pathological research on Grampus griseus (Cuvier, 1812) (Risso's dolphins) is scarce both globally and in the Mediterranean Sea. This species has been classified as "Vulnerable" by the International Union for Conservation of Nature (IUCN) in the Mediterranean Sea.To evaluate the presence of "persistent organic pollutants" (POPs), especially organochlorine compounds (OCs), in the animals, chemical analyses were performed on tissues and organs of Risso's dolphin stranded along the Italian coasts between 1998 and 2021. Toxic contaminants such as hexachlorobenzene (HCB), poly-chlorinated biphenyls (PCBs), dichlorodiphenyltrichloroethane and its metabolites (DDTs) were examined in the blubber, liver, muscle, and brain of 20 animals, and data was correlated with sex, age, and stranding locations