Residential Renewal Leases and the Ohio Statute of Conveyances: Invalidation and Subsequent Treatment

The Ohio Revised Code, in the section referred to as the statute of conveyances, mandates, inter alia, that all leases of any interest in real property shall be signed by the lessor, attested to by two witnesses, and bear a certificate of acknowledgement subscribed to by a proper authority. Exempted from the operation of the statute are leases for a period of less than three years. Thus, all leases in Ohio, even the typical form lease for a residential apartment building, must comport with the formal requirements of the statute of conveyances if they convey a term of three or more years. Once a court has determined that such a lease fails to meet the requirements of the statute of conveyances, it must define the remaining relationship between lessor and lessee. Historically, Ohio courts have had difficulty with this definition. The recent decision of the Eighth District Court of Appeals in Friedrich v. Matrka is an excellent vehicle by which to illustrate the problems existing in this area of Ohio law

Privileged Communications between Counsel and the Corporate Client

At present inconsistent lower federal appellate court decisions governing the use of the attorney-client privilege and work-product doctrine apply to the discovery of communications between counsel and the corporate client. Because of the distinctions that have developed in the application of the corporate attorney-client privilege and work-product doctrine due to the unique factual settings in which the issues have arisen, prior case law may not be totally preempted by the Supreme Court decision in Upjohn. This article will explore some of these divergent opinions to determine the probable effect that the Court\u27s decision in Upjohn will have upon communications between counsel and the corporate client

Privileged Communications between Counsel and the Corporate Client

At present inconsistent lower federal appellate court decisions governing the use of the attorney-client privilege and work-product doctrine apply to the discovery of communications between counsel and the corporate client. Because of the distinctions that have developed in the application of the corporate attorney-client privilege and work-product doctrine due to the unique factual settings in which the issues have arisen, prior case law may not be totally preempted by the Supreme Court decision in Upjohn. This article will explore some of these divergent opinions to determine the probable effect that the Court\u27s decision in Upjohn will have upon communications between counsel and the corporate client

Privileged Communications between Counsel and the Corporate Client

At present inconsistent lower federal appellate court decisions governing the use of the attorney-client privilege and work-product doctrine apply to the discovery of communications between counsel and the corporate client. Because of the distinctions that have developed in the application of the corporate attorney-client privilege and work-product doctrine due to the unique factual settings in which the issues have arisen, prior case law may not be totally preempted by the Supreme Court decision in Upjohn. This article will explore some of these divergent opinions to determine the probable effect that the Court\u27s decision in Upjohn will have upon communications between counsel and the corporate client

Electric field and tip geometry effects on dielectrophoretic growth of carbon nanotube nanofibrils on scanning probes

Single-wall carbon nanotube (SWNT) nanofibrils were assembled onto a variety of conductive scanning probes including atomic force microscope (AFM) tips and scanning tunnelling microscope (STM) needles using positive dielectrophoresis (DEP). The magnitude of the applied electric field was varied in the range of 1-20 V to investigate its effect on the dimensions of the assembled SWNT nanofibrils. Both length and diameter grew asymptotically as voltage increased from 5 to 18 V. Below 4 V, stable attachment of SWNT nanofibrils could not be achieved due to the relatively weak DEP force versus Brownian motion. At voltages of 20 V and higher, low quality nanofibrils resulted from incorporating large amounts of impurities. For intermediate voltages, optimal nanofibrils were achieved, though pivotal to this assembly is the wetting behaviour upon tip immersion in the SWNT suspension drop. This process was monitored in situ to correlate wetting angle and probe geometry (cone angles and tip height), revealing that probes with narrow cone angles and long shanks are optimal. It is proposed that this results from less wetting of the probe apex, and therefore reduces capillary forces and especially force transients during the nanofibril drawing process. Relatively rigid probes (force constant >= 2 N/m) exhibited no perceivable cantilever bending upon wetting and de-wetting, resulting in the most stable process control