Happy Birthday to Abraham Lincoln, America’s First Tech-Lawyer

February 12, 2019

Lincoln in his lawyer phaseAbraham Lincoln was born on February 12, 1809. He was probably our greatest President. Putting aside the tears honest Abe must now be shedding over his political party, it is good to remember Lincoln as an exemplar of a U.S. lawyer. All lawyers would benefit from emulating aspects of his Nineteenth Century legal practice and Twenty First Century thoughts on technology. He was honest, diligent, a deep thinker and ethical. Very ethical. He did not need to be lectured on Cooperation and Rule 1. He also did not need to be told to embrace technology, not hide from it. In fact, he was a prominent Tech-Lawyer of his day, well known for his speaking abilities on the subject. Near the end of his legal career Abe was busy pushing technology and his vision of the future. Sound familiar dear readers? It should. Most of you are like that.

Close up of Lincoln's face on April 10, 1865

Lincoln Was a Technophile

Lincoln was as obsessed with the latest inventions and advances in technology as any techno-geek e-discovery lawyer alive today. The latest things in Lincoln’s day were mechanical devices of all kinds, typically steam-powered, and the early electromagnetic devices, then primarily the telegraph. Indeed, the first electronic transmission from a flying machine, a balloon, was a telegraph sent from inventor Thaddeus Lowe to President Lincoln on June 16, 1861. Unlike Lincoln’s generals, he quickly realized the military potential of flying machines and created an Aeronautics Corps for the Army, appointing Professor Lowe as its chief. See Bruce, Robert V., Abraham Lincoln and the Tools of War. Below is a copy of a handwritten note by Lincoln introducing Lowe to General Scott.

Lincoln's handwritten introduction of Professor Lowe

At the height of his legal career, Lincoln’s biggest clients were the Googles of his day, namely the railroad companies with their incredible new locomotives. These newly rich, super-technology corporations dreamed of uniting the new world with a cross-country grid of high speed transportation. Little noticed today is one of Lincoln’s proudest achievements as President, the enactment of legislation that funded these dreams, the Pacific Railway Act of 1862. The intercontinental railroad did unite the new world, much like the Internet and airlines today are uniting the whole world. A lawyer as obsessed with telegraphs and connectivity as Lincoln was would surely have been an early adopter of the Internet and an enthusiast of electronic discovery.  See: Abraham Lincoln: A Technology Leader of His Time (U.S. News & World Report, 2/11/09).

Abraham Lincoln loved technology and loved to think and talk about the big picture of technology, of how it is used to advance the dreams of Man. In fact, Lincoln gave several public lectures on technology, having nothing to do with law or politics. The first such lecture known today was delivered on April 6, 1858, before the Young Men’s Association in Bloomington, Illinois, and was entitled “Lecture on Discoveries and Inventions.” In this lecture, he traced the progress of mankind through its inventions, starting with Adam and Eve and the invention of the fig leaf for clothing. I imagine that if he were giving this speech today (and I’m willing to try to replicate it should I be so invited) he would end with AI and blockchain.

In Lincoln’s next and last lecture series first delivered on February 11, 1859, known as “Second Lecture on Discoveries and Inventions,” Lincoln used fewer biblical references, but concentrated instead on communication. For history buffs, see the complete copy of Lincoln’s Second Lecture, which, in my opinion, is much better than the first. Here are a few excerpts from this little known lecture:

The great difference between Young America and Old Fogy, is the result of Discoveries, Inventions, and Improvements. These, in turn, are the result of observation, reflection and experiment.

Writing – the art of communicating thoughts to the mind, through the eye – is the great invention of the world. Great in the astonishing range of analysis and combination which necessarily underlies the most crude and general conception of it, great, very great in enabling us to converse with the dead, the absent, and the unborn, at all distances of time and of space; and great, not only in its direct benefits, but greatest help, to all other inventions.

I have already intimated my opinion that in the world’s history, certain inventions and discoveries occurred, of peculiar value, on account of their great efficiency in facilitating all other inventions and discoveries. Of these were the arts of writing and of printing – the discovery of America, and the introduction of Patent-laws.

Can there be any doubt that the lawyer who wrote these words would instantly “get” the significance of the total transformation of writing, “the great invention of the world,” from tangible paper form, to intangible, digital form?  Can there be any doubt that a lawyer like this would understand the importance of the Internet, the invention that unites the world in a web of inter-connective writing, where each person may be a printer and instantly disseminate their ideas “at all distances of time and of space?”

Lincoln standing by his generals in the field; close up

Abraham Lincoln did not just have a passing interest in new technologies. He was obsessed with it, like most good e-discovery lawyers are today. In the worst days of the Civil War, the one thing that could still bring Lincoln joy was his talks with the one true scientist then residing in Washington, D.C., the first director of the Smithsonian Institution, Dr. Joseph Henry, a specialist in light and electricity. Despite the fact that Henry’s political views were anti-emancipation and virtually pro-secession, Lincoln would sneak over to the Smithsonian every chance he could get to talk to Dr. Henry. Lincoln told the journalist, Charles Carleton Coffin:

My visits to the Smithsonian, to Dr. Henry, and his able lieutenant, Professor Baird, are the chief recreations of my life…These men are missionaries to excite scientific research and promote scientific knowledge. The country has no more faithful servants, though it may have to wait another century to appreciate the value of their labors.

Bruce, Lincoln and the Tools of War, p. 219.

Lincoln was no mere poser about technology and inventions. He walked his talk and railed against the Old Fogies who opposed technology. Lincoln was known to be willing to meet with every crackpot inventor who came to Washington during the war and claimed to have a new invention that could save the Union. Lincoln would talk to most of them and quickly separate the wheat from the chaff. As mentioned, he recognized the potential importance of aircraft to the military and forced the army to fund Professor Lowe’s wild-eyed dreams of aerial reconnaissance. He also recognized another inventor and insisted, over much opposition, that the army adopt his new invention: Dr. Richard Gatling. His improved version of the machine gun began to be used by the army in 1864, and before that, the Gattling guns that Lincoln funded are credited with defending the New York Times from an invasion by “anti-draft, anti-negro mobs” that roamed New York City in mid-July 1863. Bruce, Lincoln and the Tools of War, p. 142.

As final proof that Lincoln was one of the preeminent technology lawyers of his day, and if he were alive today, surely would be again, I offer the little known fact that Abraham Lincoln is the only President in United States history to have been issued a patent. He patented an invention for “Buoying Vessels Over Shoals.” It is U.S. Patent Number 6,469, issued on May 22, 1849. I could only find the patent on the USPTO web, where it is not celebrated and is hard to read. So as my small contribution to Lincoln memorabilia in the bicentennial year of 2009, I offer the complete copy below of Abraham Lincoln’s three page patent. You should be able to click on the images with your browser to enlarge and download.

Lincoln Patent Pg. 1
Lincoln Patent Pg. 2Lincoln Patent Pg. 3 (Drawings)

The invention consisted of a set of bellows attached to the hull of a ship just below the water line. After reaching a shallow place, the bellows were to be filled with air that buoyed the vessel higher, making it float higher and off the river shoals. The patent application was accompanied with a wooden model depicting the invention. Lincoln whittled the model with his own hands. It is on display at the Smithsonian and is shown below.

Lincoln Hand-Carved Wooden Model of Patent

Lincoln Filing Invention at Patent Office (fictionalized depiction)

Conclusion

On Abe Lincoln’ birthday it is worth recalling the long, prestigious pedigree of Law and Technology in America. Lincoln is a symbol of freedom, emancipation. He is also a symbol of Law and Technology.  If Abe were alive today, I have no doubt he would be, among other things, a leader of Law and Technology.

Stand tall friends. We walk in long shadows and, like Lincoln, we shall overcome the hardships we face. As Abe himself was fond of saying: down with the Old Fogies; it is young America’s destiny to embrace change and lead the world into the future. Let us lead with the honesty and integrity of Abraham Lincoln. Nothing less is acceptable.



The Jimi Hendrix Experience: Sanctions For Destruction

December 2, 2018

James Marshall “Jimi” Hendrix, whom Rolling Stone ranked the greatest guitarist of all time, died intestate in 1970 at twenty-seven. His heirs have been embroiled in litigation ever since. They have recently entered the fiery realm of e-discovery and sanctions. Experience Hendrix, LLC v. Pitsicalis, No. 17-cv-1927 (PAE) (S.D.N.Y., 11/27/18). The opinion by District Court Judge Paul A. Engelmayer is interesting in its own right, but when you add the Hendrix name and family feud, you have a truly memorable order. After all, we are talking about the artist who created “Purple Haze,” “Foxy Lady,” “The Star-Spangled Banner,” “Hey Joe” and my personal favorite, his rendition of Bob Dylan’s “All Along the Watchtower”.

Case Background: The Hendrix Family Feud

The latest suit involves the usual serial litigants. On one side is Jimi’s step-sister, Janie Hendrix (shown right). She is, as Jimi would have said, a “Foxy Lady”. Janie assumed control of the Estate from Jimi’s natural father, Al Hendrix, when he died in 2002. On the other side is Jimi’s brother, Leon Hendrix and Leon’s business partner, Andrew Pitsicalis. Kerzner, Hendrix Sues Serial Infringer Andrew Pitsicalis (American Blues Scene, 3/20/17). There can be big money in the Hendrix name, the top guitarist of all time. I for one still get choked up when I hear his rendition of “The Star-Spangled Banner”:

Jimi’s father, Al Hendrix, won bitterly fought estate litigation in the seventies, but the trademark litigation has never stopped. Multiple injunctions are in place under the corporate name, Experience Hendrix, LLC, but the infringements just keep coming. Companies keep popping up to sell Jimi Hendrix branded goods. Andrew Pitsicalis and Leon Hendrix are frequently involved. Their latest attempts to profit from the Jimi brand include marijuana related products (apparently “Purple Haze” has long been a well know strain of cannabis. See: Legal Battle Ensues Over Jimi Hendrix Usage Rights (High Times, 3/29/17); Jimi Hendrix’s heirs wage court battle over branded cannabis, other products (Cannifornan, 3/22/17).

I am reminded of the closing line of the Hendrix classic, Are You Experienced:

Ah! But Are You Experienced?
Have you ever been experienced?

Not necessarily stoned, but beautiful.

Jimi’s brother, Leon Hendrix (shown right), is an artist and musician himself with his own following. Some think he was treated unfairly by his Dad and Step-Sister. For a variety of reasons, especially I suspect the impact of Pitsicalis, the CEO of “Purple Haze Properties” and Leon’s business partner, there is still bad blood. Chris Fry, Jimi Hendrix’s Brother Fires Back Against Estate (Courthouse News, 3/28/17).

This kind of family feud mentality is not uncommon in litigation, especially in cases involving the intentional destruction of evidence. I am reminded of a Hendrix line from Voodoo Child:

Well, the night I was born. Lord I swear the moon turned a fire red. The night I was born I swear the moon turned a fire red. Well my poor mother cried out “lord, the gypsy was right!” And I seen her, fell down right dead. Have mercy.

Spoliation sanctions generally arise from a haze, just not a stoned purple haze, more like an angry moon turned a fire red haze. Even a seasoned District Court Judge in the SDNY, Paul Engelmayer, was “dismayed” by the conduct of Pitsicalis and Leon Hendrix. Well, what did you expect in matters involving the Estate of a Voodoo Child musical genius? The best guitarist that ever lived?

Judge Engelmayer’s Sanction Order

The scholarly and well-written opinion by District Court Judge Paul A. Engelmayer (shown right) begins by observing:

As the docket in this matter reflects, the Court has been called upon dismayingly often to act when presented with evidence of the PHP defendants’ persistent non-compliance with basic discovery obligations. Plaintiffs now move this Court to sanction these defendants for (1) spoliation of evidence and, more generally, (2) “consistent, pervasive[,] and relentless discovery abuses by [d]efendants and their counsel, Thomas Osinski.” Dkt. 245. Plaintiffs request, inter alia, a preliminary injunction, an order of attachment, an adverse inference instruction at trial, and terminating sanctions. See Dkts. 237, 244. For the reasons below, the Court grants the motion for an adverse inference instruction and directs the PHP defendants to pay the reasonable fees and costs incurred by plaintiffs in bringing this motion.

Experience Hendrix, LLC v. Pitsicalis, No. 17-cv-1927 (PAE) (S.D.N.Y., 11/27/18). Expressing “dismay” is about as emotional as Judge Engelmayer gets in writing an opinion, even one sanctioning a party for destroying evidence and disobeying court orders.

The PHP defendants mentioned are Leon Hendrix, Andrew Pitsicalis and their corporation, Purple Haze Properties (PHP). As you can see from the first quote, the attorney who represents them, Thomas Osinski, was also accused of discovery abuse. That often happens in joker and the thief type cases like this.

A good sanctions case will always have a “parade of horribles” consisting of a list of things the spoliating party supposedly did wrong. Hendrix is no exception. That is how the severe sanctions are justified. It would take too long to list all of the abuses justifying sanctions in Hendrix, but here are the four main ones:

  1. PHP Defendants’ Failure to Produce Forensic Images as Ordered. Apparent intentional disobedience of court orders to make forensic copies of and produce certain drives, even after daily fines are imposed for late production. One of the excuses PHP offered was especially humorous, especially considering the NYC venue, but they actually claimed “that they had had difficulty hiring an expert technician who could image the hard drives.” Yeah, it’s real hard. Need I say more about Osinski’s veracity? When they finally did produce some, but not all of the forensic images, they were not “forensic” images. They were just copies of all active files (a “ghost” copy) with no forensic copy of the slack space. That is what a forensic copy means. It allows for search and examination of deleted files, which was the whole point of the court order.
  2. PHP Defendants’ Use of Anti-Forensic Software. Software allowing for the complete wiping of files was found installed on several of the computer images that were produced. In some there was evidence the software was installed immediately after a court order was entered requiring production. In these the plaintiff’s forensic expert could also show that the software, CleanMyMac, was actually used to wipe files and when, although it was not possible to know what files were destroyed. The moving party (Janie Hendrix and her company Experience Hendrix, L.L.C.)  proved the use was knowing when their expert, John T. Myers, showed how the software was configured to have a pop-out and warn the user to confirm complete elimination of the file (it cannot be recovered after that). The defendants testified that they did not recall ever using it. Sure. Spoliate evidence and then cover-up, or try to.
  3. Andrew Pitsicalis Deleted “Jimi”-related Text Messages from his iPhone. Plaintiff’s forensic expert was able to prove that more than 500 text messages had been deleted from Pitsicalis cell phone after the duty to preserve had arisen (suit was filed). Moreover, they were able to recover nine text messages pertaining to Jimi. As Judge Engelmayer explained: “Fortuitously, Myers was able to recover the deleted text messages from the imaged phone because those communications had been stored not in the applications used to send and receive them (e.g., iMessage), but in databases where files exist until overwritten or otherwise purged.”
  4. Key Computer at First Hidden, then After Discovery in Photograph, Goes South to Florida and is Never Examined. This one sounds like a bad game of Where’s Waldo. A “Seventh Computer” was found, one never reported by PHP, by plaintiff’s study of photos on PHP’s Facebook page. Very clever. One picture on FB showed Andrew Pitsicalis, sitting in his office, in immediate proximity to a mystery desktop computer. When asked about it under oath PHP’s fine attorney, Osinski, swore that he thought it was just a dummy Apple monitor on the office desk, not a computer. He said he did not know that the monitor, and key board next to it, were a real, functional computer, an iMac. What? Did he think these were IKEA props in a display room? They were sitting on his client’s desk in a Facebook photo taken after suit was filed. But wait, there is more, Osinski went on to swear that the computer had moved to Florida. As Judge Engelmayer explained:

“Osinski testified that his present understanding is that the desktop computer belonged to an individual named Hector David, Jr. who has moved to Florida and who, Osinski assumes, took the computer with him. Osinski, however, did not have personal knowledge of this, or of the contents of the desktop in Andrew Pitsicalis’ office. … Andrew Pitsicalis, for his part, denied owning the computer and testified that David was not employed by PHP.”

Apparently no one has been able to locate this mysterious Hector David or know where he took the iMac computer sitting on Pitsicalis desk.

Legal Standards of Spoliation in Hendrix

Judge Engelmayer’s opinion in Hendrix examines two legal standards, Rule 37 and Spoliation. He begins the discussion with the duty to preserve, the threshold issue in spoliation:

The first issue is whether the PHP defendants had an obligation to preserve the categories of evidence at issue. A party has an obligation to preserve evidence when it “has notice that the evidence is relevant to litigation . . . [or] should have known that the evidence may be relevant to future litigation.” Kronisch v. United States, 150 F.3d 112 , 126 (2d Cir. 1998) (internal citations omitted).

That standard is easily met here.

He then goes on to discuss whether that duty as breached, another no-brainer based on the impressive parade of horribles in this case:

The Court further finds—and the evidence to this effect is overwhelming—that the PHP defendants repeatedly breached this duty. The breaches fall in three categories: (1) the use of cleaning software on covered computing devices, (2) the failure to disclose the existence of a seventh computing device containing potentially relevant documents, and (3) the deletion of relevant text messages.

Judge Engelmayer’ then discusses the key issue of intent, the mens rea to spoliate.

Much of the PHP defendants’ spoliation of evidence, the Court finds, was intentional. …

The Court finds that, by installing anti-cleaning software on his own computer and causing it to be installed on Schmitt’s in the face of an unambiguous and known duty to preserve potentially relevant evidence, Pitsicalis intentionally caused the destruction of such evidence.

The defenses proffered by the PHP defendants are unavailing. That Schmitt personally may not have acted with the intent to deleted responsive files is beside the point. The relevant mens rea here is that of Andrew Pitsicalis, who owned PHP, for which Schmitt worked as an independent contractor, and who, despite being a repeat litigant amply on notice of his duty to preserve potentially relevant evidence, urged Schmitt to run this software to delete files. Tr. 125, 133. Also unhelpful is Pitsicalis’ [*13] explanation that, at some unspecified point, he went on “Google to search for ‘top anti-forensic software’ and went through the first 10 pages of search” without finding anything for CleanMyMac. Andrew Pitsicalis Decl. at 2-3. Regardless what Pitsicalis’ internet research may have shown, the evidence adduced at the hearing clearly established both that the CleanMyMac software had the capacity to cause the deletion (and shredding) of files, and that Pitsicalis knew this, not least because the software’s causation of such deletion was made explicit to the user each time. Pitsicalis does not offer any reason for installing and using this software on his computer, let alone for having done so without first creating an image of the full contents of the computer that would have assured preservation of the computer’s contents.

Andrew Pitsicalis’ deletion of relevant text messages was also clearly intentional. By his admission, he personally and deliberately deleted, among other text messages, a series of texts concerning the marketing of “Jimi”-related products, the very subject of this lawsuit. He did so one day after the Court issued an order requiring the Purple Haze Properties defendants to: “produce to plaintiffs the forensic images of” every device, including phones, containing files that are relevant to this action. Pitsicalis did not offer any coherent defense to this misconduct. The Court finds it to have been a willful and blatant violation of the duty to preserve relevant evidence.

Finally, the Court finds that the removal of a computer from Andrew Pitsicalis’ office and its transfer to a Floridian, Hector David, Jr., was an act of intentional spoliation. To be sure, the question is a closer one, if only because the contents of that computer are unknown, and so the Court cannot rule out the possibility that these contents were wholly extraneous to this litigation. The location of the computer in Pitsicalis’ office, however, suggests otherwise. Had the Court been notified of the existence of this computer, it assuredly would have ordered that the computer’s contents be searched for responsive materials. It is also noteworthy that Andrew Pitsicalis did not inform his attorney of the existence of this computer. While conceivably these circumstances, in isolation, might have been consistent with the merely reckless disposal of evidence, when this episode is viewed in the light of Pitsicalis’ other acts of willful spoliation, the Court has little difficulty finding it, too, to bespeak intentional misconduct.

Sanctions Imposed

Judge Engelmayer begins his analysis of the appropriate, proportional sanctions by stating the black letter law:

The trial judge must determine the appropriate sanction for spoliation [*14] of evidence on a case-by-case basis. F, 247 F.3d at 436 . Such sanctions should be designed to:

(1) deter parties from engaging in spoliation; (2) place the risk of an erroneous judgment on the party who wrongfully created the risk; and (3) restore the prejudiced party to the same position [they] would have been in absent the wrongful destruction of evidence by the opposing party.

West, 167 F.3d at 779 . Case-dispositive sanctions, however, “should be imposed only in extreme circumstances, usually after consideration of alternative, less drastic sanctions.” Id.

Based on these objectives Judge Engelmayer sanctioned defendants as follows:

Considering these objectives, the Court imposes the following two sanctions, regarding (1) Andrew Pitsicalis’ computer, iPhone, and desktop computer; and (2) Schmitt’s computer, as to each of which the Court has found intentional spoliation. First, the Court will instruct the finder of fact that it may draw an adverse inference from the PHP parties’ failure adequately to preserve and produce these materials, to wit, that the devices in question contained evidence of conduct by the PHP defendants in breach of their legal duties to plaintiffs in connection with the sale and marketing of Jimi Hendrix-related materials.8

Second, given the resources plaintiffs again have had to expend in establishing the above-chronicled acts of non-compliance by the PHP defendants with the Court’s discovery orders, plaintiffs are entitled to an award reflecting the reasonable attorneys’ fees and costs incurred in connection with bringing and litigating the instant successful motion.

Judge Engelmayer went on to explain why a lesser sanction was inappropriate:

The Court has carefully considered whether lesser sanctions are adequate to cure the harm caused by the disposition of these materials. The Court’s firm conclusion is that no lesser sanction than the combination of an adverse inference instruction and an order directing the prompt recompense of plaintiffs for costs reasonably incurred litigating the meritorious motions for sanctions based on spoliation would adequately remedy plaintiffs’ injury. See, e.g., Moody v. CSX Transp., Inc., 271 F. Supp. 3d 410 , 432 (W.D.N.Y. 2017) (finding adverse inference appropriate where defendants intentionally lost material evidence); Ottoson v. SMBC Leasing and Finance, Inc., 268 F. Supp. 3d 570 , 584 (S.D.N.Y. 2017) (granting an adverse inference instruction where plaintiff “has acted willfully or in bad faith” in [*15] violation of her duty to preserve certain emails); First Fin. Sec., Inc. v. Freedom Equity Grp., LLC, No. 15-CV-1893-HRL, 2016 U.S. Dist. LEXIS 140087 , [2016 BL 337069], 2016 WL 5870218 (N.D. Cal. Oct. 7, 2016) (imposing adverse inference instruction for intentional deletion of text messages and awarding plaintiffs attorneys fees incurred in bringing sanctions motions). The Court has also carefully considered whether this is the rare case in which terminating sanctions are merited, as plaintiffs have urged. See Dkt. 237. At the present time, the Court’s judgment is that such extreme sanctions are not warranted, although further acts of spoliation and/or other discovery abuses could produce a different result.

The footnotes in these last paragraphs are interesting. Footnote 8 explains that “The Court defers decision on the precise formulation of the adverse inference instruction until closer to trial.” That means it could become a mandatory presumption, or merely permissive. Footnote 9 acknowledges that there may be more discovery misconduct in the works. The court noted it could still strike all defenses, if the conduct continues, and save everyone the cost of a trial.

Conclusion

Even with just a permissive presumption, the case at this point will almost certainly be won by Janie Hendrix’ company, Experience Hendrix, L.L.C.. Experience Hendrix, LLC v. Pitsicalis. Yet another loss for Jimi’s brother, Leon, in a long list of losses. Another injunction and businesses shut-down, but for how long? The Estate and L.L.C. have won so many times before. Yet they keep coming back. Is this yet another Pyrrhic Victory in a long line of pointless litigation? How long before the next suit? Some things are just beyond Law’s reach. Purple Haze.

Purple Haze

Purple haze all in my brain
Lately things just don’t seem the same
Actin’ funny, but I don’t know why
‘Scuse me while I kiss the sky

Purple haze all around
Don’t know if I’m comin’ up or down
Am I happy or in misery?
Whatever it is, that girl put a spell on me

Help me help me
Oh no no… No

Yeah
Purple haze all in my eyes
Don’t know if it’s day or night
You’ve got me blowin, blowin my mind
Is it tomorrow or just the end of time?

No, help me aw yeah! Oh no no oh help me…

When you are the best in the world at something, like Jimi Hendrix was at guitar playing, and when you are still famous and admired by millions fifty years after your death, there will be profiteers around. When you add sibling rivalry and family resentments to the mix, then the trouble goes from bad to worse.

The Hendrix family saga, and this lawsuit, are tragedies. So too is the destruction of evidence and this Sanctions Order. It is part of his guitar star legend. Jimi Hendrix’ boy genius was born out of a troubled childhood and family. Diamond in the rough. Bigger than life. Exploded with art, fame and fortune in just three years. Dead at age 27 of an overdose. The day he was born the moon turned a fire red, “Lord, the gypsy was right!”

The greatest guitarist of all time was a Phoenix – tragic, fiery, short-lived, but beautiful and spell-binding too. Where will musical genius appear like that again?



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