Law And More

Apollo Continues Pivot into Sustainability - Focus on Transition to Non-Fossil Sources of Energy and Game Theory

Recently, Apollo Global Management had announced it was creating the function of Chief Sustainability Officer.

The mission has been to review all investments in terms of its compliance with ESG criteria for Environment, Social and Governance principles. This Law and More article analyses the rewards and risks of that move.

On Friday, October 22nd, the financial giant expanded its reach and branding in sustainability. As it details in its press release it has bet big money on the energy transition to non-fossil sources. Here is the financialese:

"Apollo (NYSE: APO) today announced that funds managed by its affiliates (the “Apollo Funds”) have agreed to invest $824 million in a convertible equity portfolio financing agreement with NextEra Energy Partners, LP (NYSE: NEP) in a 2.5 GW renewable energy generation portfolio (the “Portfolio”). The Apollo Funds committed to the investment as part of the sale of 50% of the Portfolio from NextEra Energy Resources, LLC, a subsidiary of NextEra Energy, Inc. (NYSE: NEE) to NextEra Energy Partners."

That portfolio contains 13 utility-scale wind and solar assets. Of those, three facilitate battery storage. 

The transaction had been handled by law firms Allen & Overy and Paul Weiss. 

What does this mean?

Well. to begin with, it's a kind of what's called "virtue signaling." That is, the message is: We are on the right side of global values. Salvation for mankind entails the battery's replacing gasoline.

In addition, Apollo is leveraging its influence to confirm the importance of energy transition. That includes how investors should make their choices. Yes, investors, non-fossil fuels are the horse to bet on.

And, Apollo is positioning and packaging itself as being in the front lines of a business philosophy that goes by the umbrella term "ESG." Apollo publishes an annual report "The Apollo ESG Effect." Here you can read it. 

The stars are aligned that Apollo will impact the energy sector in a major way.

In the global corridors of influence what moves the dial on getting things done are the connections among the movers and shakers. Journalist Hedrick Smith explained those dynamics in his book "The Power Game."

It is interesting to note in Apollo's journey toward being the player in sustainability its long-time legal counsel has been law firm Paul Weiss. Yes, that firm oversaw this most recent transaction. 

The Paul Weiss Chairperson Brad Karp has been a first-mover in the law firm sector's embrace of ESG values. For example, it established the first ESG practice.

Also, on personal level, Karp has mobilized collective action throughout law firms to support causes associated with ESG values. They include push-back against suppression of voters' rights. Those initiatives reinforced Paul Weiss' presence for being a force field in social justice. That fits nicely where Apollo is heading. 

It also can be useful to observe that Apollo's actions may be based on a version of game theory. The genius John Nash brought the erudite discipline mainstream. Recently I have created material for a client on the implications of game theory for the crypto market. 

Essentially, game theory strategy is about optimizing outcomes through ensuring cooperation among those in the loop. That seems to be underlying how Apollo is going about sustainability. The self-interest of all the players is brilliantly locked in. 

Game theory is becoming an increasingly useful lens for assessing investing initiatives. Meanwhile, green is good. It's in the public interest. 

Feedspot selected Law and More as one of The Top 100 Legal Blogs.

Marketing communications. It’s about results. Not quantity. Not clickbait. Not even influence. Together we will get those results. Clients range from American Express to industrial accounts. Fees customized for your unique budget. Complimentary consultation - janegenova374@gmail.com.

"Vanessa Bryant v County of Los Angeles, et at." - Grief Is So Hard

"Vanessa Bryant is being asked to undergo 'a physician-ran test on her mental state' to assess and 'evaluate' the extent of her alleged emotional distress regarding the Kobe Bryant helicopter crash images." - Daily Mail, October 17, 2021.

Essentially the defendants are attempting to discern if Bryant's suffering is the result of the original trauma of the death of her husband and daughter or is primarily related to what she contended in her lawsuit "Vanessa Bryant v County of Los Angeles, et al."

She claims that the photos of the dead had been distributed among law enforcement. As a result, she is accusing those in authority loop of negligence, intentional infliction of emotional distress, and the invasion of her husband's right to privacy.

Previously, she had refused a psychiatric evaluation requested by the plaintiff. Also, as many know, psychiatry does involve subjectivity. On the popular series "Chicago Med," the respected psychiatrist Dr. Charles admits that the science is an imperfect one. He is a humble man and and equally humble member of the healing profession.

Also, grief is a complex force field. How can even a trained expert separate out its parts?

During the first week of January, just a few weeks after my four-legged son LOV and I arrived in Arizona from the midwest, he could no longer hold up in his battle with congestive heart failure. One overcast Sunday morning I allowed the vet to let LOV go.

To today I am overwhelmed with sadness. And there isn't a day that I live that I don't remember a joy we had shared together. 

My pain of loss is my pain. Bryant's pain of loss is her pain. But understanding it may be beyond the imperfect science of psychiatry. 

This blog passes along wishes for strength for the Bryant family.

 

U.S. Crude Crosses $80-a-Barrel Mark - Get a Horse or a Smart Car (and back off law firms representing fossil-fuel corporations)

"U.S. crude rose more than 2% early Monday to a seven-year high of $81.50 a barrel, bringing its climb since the end of last October to more than 120%. If sustained, it will be the first time the U.S. oil benchmark closes above $80 a barrel since October 2014, when the shale revolution set off a multiyear slump in fossil-fuel prices." - The Wall Street Journal, October 11, 2021.

A major reason is: problems in supply. And one reason for that is inadequate investment by BigOil in the fossil fuel side of its business.

In this era of ESG (Environmental Social Governance) principles being applied to all businesses, old-line energy companies have been hit hard by myriad constituencies for remaining in fossil fuels.

Iconic had been the high-profile board-room coup orchestrated by small hedge fund Engine Number-One (aka The Little Engine That Could) at Exxon. More recently that investor activism has moved on to Chevron. Yet, alternates such as the electric vehicles are not ready for prime time and the consumer cost of EVs could be an obstacle to their going mainstream.

If the supply situation continues crude prices could continue going up. Of course, that could hobble the global economic recovery as COVID eases. Therefore, it would be bad taste to make a joke, given that grim scenario, that it's time to get a horse. Or a smart car - mine gets 40 miles to a gallon. 

Let's get to the chase: It now seems naive for groups such as Law Students for Climate Accountability to vilify law firms which represent corporations whose business is fossil fuels. Among them are Paul Weiss, Latham & Watkins, and Gibson Dunn. How is the world going to function until there is a full transition to new sources of energy? 

Unfortunately, given that ESG beliefs have hardened into orthodoxy, some media outlets seem to be reinforcing the perception of those law firms as the bad guys. Or, at least, those who should be questioned carefully.

In a wide-ranging Bloomberg Law interview with Paul Weiss Chairperson Brad Karp Roy Strom did introduce its controversial representation of Exxon. That part of the interview had been handled professionally on both sides, but it was still there. That showcases the looping in between ESG ideology and the media. Here is an excerpt:

"Paul Weiss itself has seen the fallout from activists who pressured the firm to drop ExxonMobil. The firm represented the oil giant and beat back a New York State claim that the company misled investors about the risks of climate change. Karp said there are certain types of matters and clients the firm wouldn’t represent, but he defended its work on behalf of its long-term client, Exxon. He said the firm’s victory at trial showed the case 'was, and without any basis.'"

BTW, there was another aspect of that interview which might have been labeled: A Funny Thing Happened on the Way to the Present: Media Stayed Stuck in the Past. 

Strom circled back to the 2018 dustup in The New York Times about Paul Weiss' all-white partner class. In ESG time that essentially had been light years away. Diversity hadn't been embedded in society's expectations about the right way for business to function. Also, the law firm did rapid course correction. 

The irony, of course, is that ESG itself has become controversial. In some circles, it is the bad guy.

That is playing out in lawsuits, regulatory agencies, planning for IPOs, and public opinion. The classic example is Allbirds. In response to its sustainability-centric promotions it is being sued in "Patricia Dwyer v Allbirds." Here is a copy of that complaint. On October 4th, it amended its IPO filing. 

In addition the wild west world of ESG investing is beginning to be tamed.

In both the U.S. and in Germany, government is investigating Deutsche Bank's DWS. One issue is how it reports on ESG investments.

Nevertheless, though, optimism prevails about ESG investing. Giant Apollo Global Management recently hired its first Chief Sustainability Officer. The function will review all businesses for sustainability issues. Of course, that all could sour. Currently, though, the move is assessed as smart. 

A sign of ESG times, my recent article in ST Magazine on sustainability is receiving lots of attention. Here you can read it.  

Obviously, the world is in flux. But meanwhile it still needs fossil fuels for industry, transportation, and even heating.  Green could be mutating into the enemy. 

UPDATE:

Stocks down 250.1 points, rising crude prices factor into the plunge.

The Wall Street Journal reports:

U.S. stocks fell on Monday on worries about slowing growth and mounting inflation, punctuated by a rally in oil prices. Front-month U.S. oil futures climbed 1.5% to settle at $80.52 per barrel, their highest level since 2014. Futures on Brent crude, the global oil benchmark, rose 1.5% to $83.65 a barrel, their highest settle value in three years.

Marketing communications. It’s about results. Not quantity. Not clickbait. Not even influence. Together we will get those results. Clients range from American Express to industrial accounts. Fees customized for your unique budget. Complimentary consultation - janegenova374@gmail.com.

Apollo Global Management Continues Repositioning Post-Scandals: Reward/Risk of ESG Pivot

f"Father, Forgive me, I had underestimated the resilience of Apollo Global Management"

"Stop being a guilt-ridden Catholic. The reputation restoration is not a done deal. Your dark thoughts could be on the money, my child."

"Apollo Global Management Inc. named Dave Stangis as its first chief sustainability officer, a new position for the $472 billion alternative-asset manager." - Melissa Karsh, Financial Post, October 4, 2021.  

Apollo may have had made yet one more giant step toward reputation restoration. Not too long along it had been embedded in the deep circles of scandal hell. But, the jury is still out on the sustainability part. The story on that is complex and keeps changing. 

Apollo's founder Leon Black had been sucked into the force field of being associated with convicted pedophile Jeffrey Epstein.

Despite getting off the hook on criminal charges, Black couldn't shake that. After all, this is America, founded by the rigid punitive Puritans. Shame is the standardized ethos. That emotional set is even expected in the courtroom.

Black stepped down from the leadership and Marc Rowan took charge. More recently, there had been the headline-grabbing lawsuit against Black by a former mistress. That didn't help the Apollo brand.

In addition, the nasty expose "The Caesars Palace Coup" by Sujeet Indap and Max Frumes heaps on Apollo all the negative cliches about the greed and sharp elbows on Wall Street. The book focuses on the bankruptcy of Vegas entertainment icon Caesars. The shade thrown by the book - it ranks 11,338 on Amazon - still hasn't gone away. But, its allure seems mostly to be the titillation of gossip. No one expects Congress to set up a subcommittee to investigate Apollo after that.

With Rowan as chief executive officer Apollo has shifted to being a credit powerhouse. That was cemeted when it acquired the rest of Athene it hadn't owned.

Now, it pivots to the side of the angels and where 33% of assets in the investment world are: ESG - that is, Enviromental Social and Governance. 

Investopedia defines "ESG" as:

"Environmental, social, and governance (ESG) criteria are a set of standards for a company’s operations that socially conscious investors use to screen potential investments. Environmental criteria consider how a company performs as a steward of nature. Social criteria examine how it manages relationships with employees, suppliers, customers, and the communities where it operates. Governance deals with a company’s leadership, executive pay, audits, internal controls, and shareholder rights."

In appointing Stangis as Chief Sustainability Officer, Apollo gets into the ESG game in a major way. Part of Stangis' role is to integrate ESG principles across all of Apollo's businesses. Sounds great, right. Also, it can be interpreted as in the public interest. Green is good. Previously Stangis had headed ESG initiatives at Campbell and Intel. 

However, there is risk, as there is in all strategies. As many know, essentially ESG investing has been the wild west, with little accountability or regulation. The joke is that if you want to set up an ESG investment just say that it is an ESG investment and that will be that. There isn't even a standard definition of what is an "ESG Investment."

The first sign of the taming of that wild west are the investigations in the U.S. and in Germany of Deutsche Bank's DWS. The data it has used to assess and report on ESG investments has been called into question. 

The Wall Street Journal reported:

"DWS’ ESG data was sourced from outside providers, and then the numbers were averaged together, documents show ... that was a problem, because if one firm awarded a company an A and another gave it an F, the result was 'right in the middle, everything looks OK.'"

Here is Law and More's analysis of the implications of DWS' problems.

The financial and the branding realities are that financial institutions betting a significant piece of the ranch on ESG could find themselves in trouble in a number of ways. The asset class could sour. Those firms could be accused of greenwashing as has Exxon with its algae initiative. 

Also, the aura surrounding ESG investing is often just that: a happy-clappy glow. When the rubber meets the road on actual investing decisions, the deciders usually approach that as a hard-nosed financial transaction.

There is research creating exactly that kind of lens for sizing up the ESG investing craze. That research has been by experts at Morningstar Steve Wendel and Samantha Lamas, reports MarketWatch. And the focus is on actual investor behavior, not macro warm-and-fuzzy. 

The Morningstar findings indicate that ESG criteria represent only one factor in choices about investing. The process is complex. It becomes even more complex in that scary matter of growing funds for retirement. Among what's considered are the usual concerns. Those range from tax efficiency to how much the investors trust their financial advisor. 

So, where is Apollo in reputation restoration? Obviously, it's doing well. Its financial performance crushed in the last quarter. Black has managed to recede from the headlines. Rowan is respected. And this embrace of ESG can give it new runway in its journey to move away from the past. 

On the other hand, ESG can pile on Apollo new kinds of problems. Most recently, once sustainability darling in financial circles and in the media - Allbirds - seems to have overplayed its hand. In lawsuit "Patricia Dwyer, et al. v Allbirds" its sustainability-centric advertising is being challenged. Here is a copy of the complaint. And here is Law and More's analysis of the pickle Allbirds now finds itself. 

Green is evolving into a wobbly platform for the bottom line, branding, and reputation restoration.

Apollo has taken on new risk in its ESG commitment. 

Place your sponsored content here on this syndicated site. Affordable rates. Please contact janegenova374@gmail.com.

"US v Elizabeth Holmes" - Sure, Trial Delay Benefits the Defense, But Not So Much in Era of Email, Texting

"Human memory is fallible. That’s why defense lawyers like to age their cases — and why prosecutors were so frustrated with the multiple delays in trying Elizabeth Holmes for her role at the failed blood-testing company Theranos. Given enough time, people forget things. That can open the door for reasonable doubt." - Elizabeth Lopatto, The Verge, October 1, 2021.

Of course, that's true. But, as Lopatto goes on to discuss, it's not that true. Not any more when the prosecution can have as exhibits email threads and texts. And that's exactly what the prosecution in "US v Elizabeth Holmes" has been presenting in court.

The skilled lead lawyer from Williams & Connolly Lance Wade is chipping away at the strength of that kind of digital evidence. However, the testimony of the former Theranos lab head Dr. Adam Rosendorff still is damning. It positions and packages Theranos founder Holmes as aware of the flaws in the finger-prick technology. 

The defense strategy had been to place the burden of blame for any funny stuff at the startup on the folks in the lab. Dr. Rosendorff had anticipated that. That's why, despite the NDA he signed banning copying office email to a personal account, he did that.

Right now, Holmes looks culpable. However, the defense hasn't put on its own case yet.

Meanwhile, youth interested in science careers might have second thoughts. Dr. Rosendorff was only pulling down $240,000 at Theranos.

In 2003, my younger sister Anne Murga-Ring, with only a Master degree in public health from a non-elite university, had earned almost $200,000 annually. That was as a vice president in administration for a small hospital in Bayonne, New Jersey. That was not a STEM job. 

STEM may seem sexy. But many career paths in it aren't lucrative. Law and Wall Street often pay more. For example, associates, right out of law school, are being paid $205,000 in entry-level positions in large law firms. They usually aren't bringing hands-on experience into the job. With  one or two bonuses, the annual compensation could approach Dr. Rosendorff's $240,000.

Seven months after I hung out a shingle in communications in 1987 I was grossing the equivalent in 2021 dollars of what Dr. Rosendorff had been earning. And without his responsbility. He also wound up with more than seven years of legal bills.

Those intruding in aka guiding the career choices of youth and career-changers should give them the straight story about earnings, responsibiity, and even legal liability. The worst that will happen to me in communications is that the client is unhappy with the tone of the content marketing and doesn't use me again as a vendor. Yeah, and I was a English major in college. Plus, in my 70s right now, I am still marketable. 

"US v Holmes" is exposing not only the ugly underbelly of the Silicon Valley ethos. It is also blowing up assumptions about STEM.

Dr. Rosendorff didn't have a glam job. Along my career path in communications I have flown on the private jets of so many business leaders. I had taken the ferry from Connecticut to clients in the Hamptons. What I had researched and ghostwritten had been published in establishment media such as The Wall Street Journal and The New York Times. 

Reflection: Prevailing memes frequently are platforms for great suffering. The current dominant ones deal with careers.

Less is more. PAN Communications found consumers are only paying attention to about 1/16^th of your content. So, together let's create the marketing communications that engage them. Fees customized for your unique budget. Complimentary consultation - janegenova374@gmail.com.

 

Law Firms & Office Reopenings - Smirk

As virus cases mount and vax mandates spread, holdouts plague police and fire depts...
California first state to order shot for public, private schools...
Sotomayor lets NY order remain...
J&J jab linked to another clotting condition?
PFIZER antibodies gone in 7 months...
PILL 'CUTS HOSPITALIZATION, DEATH IN HALF'...
Restaurants' Fragile Recovery Fizzling...
Rural Americans dying at twice rate of urbanites...

Intuitive readings about your career. Drop your story line and open to extreme possibility. Sliding Scale Fees. Please make an appointment for a complimentary consultation at janegenova374@gmail.com.

 

Former Theranos Lab Director Dr. Adam Rosendorff: The Professional and Legal Risks of Being Associated with an Alleged Fraudulent Enterprise

"Dr. [Adam] Rosendorff’s testimony has connected Theranos’s problems directly to Ms. Holmes, supporting prosecutors’ contention that the company’s founder intended to defraud patients and investors about Theranos’s technology." -Sara Randazzo, The Wall Street Journal, October 1, 2021.

Despite signing on to the provisions of the Theranos NDA, Dr. Rosendorff copied his work emails to his personal account. That was forbidden. But he was becoming aware that it was a risk to his professional brand and maybe more to be part of the Theranos alleged fraud.

However, what is puzzling is that given this fear why then did he become a source for The Wall Street Journal for the article which broke the story about the problems with the finger-prick technology? After that became public other media outlets, which had made Theranos founder Elizabeth Holmes a celebrity, turned on both the enterprise and Holmes.

Was Dr. Rosendorff being self-protective of did he felt compelled to "do the right thing?" Maybe both. Or neither. Could he have been enraged at Theranos' leadership?

The coverage of the trial mentions that Dr. Rosendorff has incurred seven or eight years of legal expenses. His compensation at Theranos was not huge: $240,000. My younger sister Anne Murga-Ring was pulling down almost $200,000 in 2003 being in administration at a small Bayonne, New Jersey hospital. So, no, Dr. Rosendorff was not in the big bucks.

His story is quite a subtext in this drama legally titled "US v Elizabeth Holmes."

Place your sponsored content here on this syndicated site. Affordable rates. Please contact janegenova374@gmail.com.

John Hinckley's Unconditional Release - Yes, Mental Illness Can Be Treated Or Simply Run Its Course

"A U.S. judge [U.S. District Judge Paul Friedman] on Monday said he would grant 'unconditional release' to John Hinckley, who wounded former U.S. President Ronald Reagan and three other people in a 1981 assassination attempt." - Jan Wolfe, Reuters Legal, September 27, 2021.

The previous terms and conditions imposed for Hinckley's ability to live his life outside a psychiatric hospital had included restrictions on travel and the use of the internet. Those are no longer in effect.

In 1982, a jury ruled Hinckley not guilty of the shooting carnage by reason of insanity. Over the years there have been ongoing reports of psychiatric evaluations that his mental condition had been improving. He had been allowed, for example, weekend visits out of the psychiatric hospital with his mother.

This unconditional release represents a great leap forward in giving both those suffering with mental illness and society hope that the disease can be treated or simply run its course. A diagnosis doesn't necessarily mean being doomed forever to have to struggle with the symptoms. 

Less is more. PAN Communications found consumers are only paying attention to about 1/16^th of your content. So, together let's create the marketing communications that engage them. Fees customized for your unique budget. Complimentary consultation - janegenova374@gmail.com.

"Dwyer v. Allbirds" - Cautionary Tale about Legal/Reputational Risk Associated with Sustainability-Centric Marketing

The filing of  potential class action lawsuit "Patricia Dwyer v Allbirds" on July 13, 2021 should be cautionary tale about using sustainability-centric marketing. Here is a copy of the complaint.

Eco-friendly is turning out to be risky business.

Essentially the contention is that the eco-friendly phrases are misleading. More specifically, the lawsuit claims the much-touted life-cycle assessment tool doesn't measure carbon footprint impacts beyond the manufacturing process itself.

In addition, it hits on the high-profile matter of animal welfare. Allbirds features the sheep looped into the wool-gathering process as "happy sheep." The lawsuit alleges mistreatment ranging from beatings to slitting the throats of conscious sheep. 

A similar kind of lawsuit alleging misleading advertising has been filed against Canada Goose. It has put out there that its fur-gathering process and products are ethically sustainable. The lawsuit takes that on. 

Shade is also being thrown on Allbirds ESG posturing in terms of another of the ESG components - governance. Reuters Legal rates Allbirds' second-rate. Its founders Joey Zwillinger and Tim Brown hold super voting shares and only a portion of the board comes up for reelection each year.

Part of the problem in this sustainability space is that there is no formal definition of "green." These kinds of lawsuits can accelerate the push for such a standard definition in terms of the law and commercial fields such as advertising and manufacturing. 

As many know, Allbirds had been the darling in integrating ESG (Environmental Social Governance) principles into all aspects of how business is done. Its eco-friendly positioning and packaging attracted investors ranging from Fidelity to T. Rowe Price. And, as Dwyer has hammered, current consumers factor in business practices in their purchases. Allbirds has had a high rate - 53% - of repeat customers, reports CNBC. It plans to take on Nike and Adidas.

Allbirds quickly grew to a $1 billion startup. It approached its IPO as creating a new template for other businesses going public. It calls the model the Sustainability Public Equity Offering. That received plenty of media attention. At the time Allbirds was making all the right moves in what's called "virtue signaling."

Fashion Law provides highlights of Allbird's response to "Dwyer":

" ... asserting that Dwyer’s and putative class members’ claims are barred, in whole or in part, due to 'a lack of standing and failure to establish any cognizable injury,' and that Dwyer 'fails to and cannot prove money damages with any degree of certainty sufficient to permit recovery of damages,' Allbirds claims that its actions were 'authorized by the applicable law and thus, are not actionable,' and that Dwyer’s claims are barred because 'Allbirds was not under a legal duty to disclose the allegedly concealed facts.'" 

Marketers might understand - but not forgive - how Allbirds might have allegedly overstated its conformance to sustainability principles in terms of the environment, labor practices (including the entire supply chain process), and animal welfare.

But lawyers are probably scratching their heads. This kind of legal and reputational trouble probably could have been prevented.

Dating way back to April 2020 when Paul Weiss' Brad Karp launched a ESG practice, it was out there: How increasingly difficult it was becoming for business to identify, interpret, and mitigate the risks associated with the broad category of sustainability. This month research by the Rock Center for Corporate Governance at Stanford confirmed the extent of that risk. General Counsel admitted the function was struggling. 

In its ESG practice mission statement, Paul Weiss captures how wide-ranging the challenge is:

"Business leaders face greater pressure to increase their organizations’ resilience while simultaneously addressing social issues of importance to stakeholders. Our advisory practice helps companies navigate the legal, business and political ramifications of developing and implementing ESG initiatives. We advise on matters such as stakeholder engagement, corporate governance, crisis management, corporate social responsibility, sustainability, diversity and inclusion, ethics and compliance."

Just as "US v Elizabeth Holmes" might rein in the excesses of Silicon Valley, "Dwyer v. Allbirds" could trigger a rethinking of hyperbolic sustainability-centric marketing. 

Place your sponsored content here on this syndicated site. Affordable rates. Please contact janegenova374@gmail.com.

Law Firm Chairpersons Off Hook for Politics/Drama of Mandating Booster

"The Covid-19 vaccine booster shot proposed by Pfizer Inc. and BioNTech SE should be given to older Americans [65 and older] and those at high risk, a panel of expert advisers to the U.S. Food and Drug Administration said, rejecting a request for broader distribution." - Bloomberg Law, September 17, 2021.

Members of that panel voted 18-to-1 to facilitate emergency use authorization for the 65 and older as well as others at high risk. That's a more limited clearance than full approval. 

This gets law firm chairpersons off the hook for having to make a decision - which has become political and full of drama - whether to mandate booster shots.

However, it is a setback for the Biden Administration. It had conjured up a plan on a massive scale to make available booster shots next week. Joe Biden's approval rating is down to 44%.

Place your sponsored content here on this syndicated site. Affordable rates. Please contact janegenova374@gmail.com.