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Lawyer of the Day: Jack Tuckner

Jack Tuckner Sipser Weinstock.jpgThe legal profession is populated by some colorful characters -- like our latest Lawyer of the Day, Jack Tuckner. From the New York Post:

A leading lower Manhattan women's-rights lawyer watched porn at his desk, discussed his "pierced genitalia" and wears a "slave" collar at work as part of a sadomasochistic relationship with his girlfriend, a shocking sex- harassment suit alleges.

Jack Tuckner, 50, whose law firm says it's "dedicated to the empowerment of women in the workplace," is a "self-described 'testosterone-poisoned' attorney with a penchant for bondage . . . who demeaned all of the women who worked for him," says the suit.

It was filed yesterday in Manhattan Supreme Court by former office manager Lisa Brockington.

But if the slave-collar-wearing Tuckner is the "sub" in the S&M setup, doesn't that make it okay? Isn't he the one being demeaned, rather than the one doing the demeaning?

More after the jump.

Continue reading "Lawyer of the Day: Jack Tuckner"

Farewell, Ally McBeal; Enter the Litigatrix

Tilda Swinton Karen Crowder Ally McBeal Calista Flockhart.jpgThat's the title of our latest column for the New York Observer, which reflects upon recent television and film portrayals of women litigators.

It touches upon some of the same themes highlighted in Amy Kolz's excellent American Lawyer article from last year, but it's more focused on fictional female litigators, as opposed to real-life ones. Here's how it starts:

Whatever happened to Ally McBeal? If recent movies and television shows are any guide, the life of a female lawyer has gotten a lot less pleasant since the carefree, charmingly neurotic days of dancing babies and bathroom kisses. But today's portrayals may be more accurate, and certainly more critically acclaimed.

Last January, Glenn Close won a Golden Globe for her compelling performance as Patty Hewes, a fearsome and wildly successful plaintiff's lawyer, on the addictive TV show Damages. The following month, Tilda Swinton snagged an Oscar for stepping into the pumps of Karen Crowder, a hard-charging in-house litigator, in Michael Clayton.

In March, Julianna Margulies (of ER) returned to television as aggressive defense lawyer Elizabeth Canterbury, the title character of Canterbury's Law. Even Katey Sagal, who embodied the famously vulgar Peggy Bundy on Married With Children, reincarnated herself this year as Marci Klein, the sleek, powerful, and ruthless founding partner of the law firm on Eli Stone.

You can read the full column over here.

Farewell, Ally McBeal; Enter the Litigatrix [New York Observer]

Time for Winston Women To Go Burqa Shopping?

Ally McBeal Calista Flockhart micromini skirt miniskirt Above the Law blog.jpgAlthough many tipsters emailed us about it, we never wrote about this buzz-generating Wall Street Journal article, reporting on how many older lawyers are displeased by the overly informal, even sloppy attire of their younger colleagues. We didn't write about it earlier because we felt preempted: the piece received lots of online attention, from such widely read outlets as the ABA Journal and the WSJ Law Blog, where it generated heavy comment traffic.

But now we have a new angle on it. Focus on these portions of Christina Binkley's WSJ article:

[Winston & Strawn D.C. managing partner Thomas Mills] says he is partial to well-fitted Brioni suits for himself. He notes that the going rate for new associates in New York, Los Angeles and Washington is $160,000 a year -- enough to buy suits while paying down school loans. Yet all too often, associates show up at work in jeans -- attire that he doesn't condone "unless it's moving day."

Winston & Strawn brought in a personal shopper from a local department store last year to address associates on how to shop and dress for work. Mr. Mills says that when some associates do make an effort to dress up, they seem to base their look on Hollywood. "You get the TV-woman lawyer look with skirts 12 inches above the knee and very tight blouses," he says. "They have trouble sitting and getting into taxis."

burka burqa burkha burqha.jpgThese remarks apparently didn't go over too well back at Winston:

W&S DC office's managing partner comes off as a total a**. His comments re: his custom suits are one thing. But his comments re: the way women in the office dress have created a stir....

People are seriously pissed, particularly the women. Man comes off as a total pig.... Read the article, you'll see why.

This is prime ATL material. Firm has called impromptu associates meeting for 9:30 Monday, no topic given. But the guess is it is damage control.

The guess was correct. More about the meeting, after the jump.

Continue reading "Time for Winston Women To Go Burqa Shopping?"

Lawyer of the Day: Thomas Decea

If she hadn't already gotten a shout-out in Morning Docket, we might have named Karyn McConnell Hancock our Lawyer of the Day. She's the pregnant Ohio attorney who, as reported by the AP, disappeared for four days, then made up a story about being kidnapped at gunpoint and taken to Georgia. According to her husband, she had "a meltdown."

Instead, since Hancock's story has already gotten lots of MSM coverage, we'll bestow today's prize upon New York lawyer Thomas Decea. From a story in the New York Law Journal by Anthony Lin (who's on a roll lately; two words: Charlene Morisseau):

A New York judge has ordered court supervision of a lawyer for "objectionable conduct" toward a female opposing counsel who he said had a "cute little thing going on" during a deposition.

According to transcripts of the deposition, Thomas B. Decea of Danzig Fishman & Decea in White Plains also called Michelle A. Rice of Arkin Kaplan & Rice "hon" and "girl" and asked her why she was not wearing a wedding ring.

Attila the Hun Attilla the Hun Atilla the Hun Above the Law blog.jpgIt's interesting to note that Michelle Rice, alleged possessor of the "cute little thing," is a name partner in the law firm of legendary litigator Stanley Arkin -- who's renowned for his toughness.

The underlying litigation is also noteworthy. It involves Lowenstein Sandler, one of New Jersey's largest and most profitable law firms (Rice's client).

More excerpts and discussion -- including an attempt to explain away Decea's calling Michelle Rice "hon" as a reference to "Attila the Hun" -- after the jump.

Continue reading "Lawyer of the Day: Thomas Decea"

Heller Ehrman (Los Angeles) Has a Diva-licious New Leader

Nancy Cohen Nancy Sher Cohen diva Heller Ehrman Above the Law blog.jpgSome of our prior coverage of Heller Ehrman has been a bit gloomy. We take it all back. Now that the firm's Los Angeles office is under a magnificent new leader -- Nancy Sher Cohen, whom we have previously praised in these pages -- we see nothing but good things ahead.

Legal Pad conducts a very interesting interview with Nancy Cohen. Here's an excerpt:

Legal Pad: How do you feel about “Above the Law” blog calling you “divalicious”?

Cohen: I found out about it from several associate who came to show it to me. Isn’t that funny? I just looked at it and howled. There is a lesson there. You just never know who is going to be writing about you, thinking about you, making comments about you. It’s a reminder that you should always do your best and always be sensitive and nice, civil.

We're confused. Does Ms. Cohen think that we were speaking negatively of her? To the contrary, we had only good things to say. From our prior post:

When we were in private practice, our experiences with Heller Ehrman were quite positive. We attended several depositions defended by the diva-licious Nancy Sher Cohen, who protected her witnesses like a lioness protecting her cubs. We were most impressed by this badass litigatrix (who is also a community activist and cancer survivor; see this profile).

As for the "diva-licious" quip, let the record reflect that the term "diva" is ATL's highest form of praise. Longtime readers are well aware of our obsession with strong-willed women -- especially women who have managed to achieve tremendous success in a traditionally male-dominated field like law.

This is why we are such fans of Senatrix Hillary Clinton, who is a tough, smart, fearless leader. We have no clue why some of you seem to think we don't like her. We think Senator Clinton is fabulous.

Why do you think we've snapped up so many domain names related to her? Visit HillaryClintonIsMyGirl.com, HillaryIsMyGirl.com, Hillarylicious.com, HillaryIsSexy.com, HillarySexy.com, or HillarySex.com. Where do you get redirected to?

'Badass Diva' Ready to Run Heller in L.A. [Legal Pad /CalLaw]

Earlier: Going to Heller in a Handbasket? (Part 2)

If Wanda Sykes Were a Biglaw Associate...

She probably wouldn't be very happy with her law firm. From the Minority Law Journal:

[N]owadays most associates don't plan on spending their entire legal career at one law firm. But some associates are more likely to head for the exits than others. Nearly half of all white male midlevel associates say that they expect to be working at their current firm in five years, according to our Minority Experience Study. Just over 40 percent of minority male midlevels said the same. Of the minority female midlevels, though, fewer than a third planned to stay put.

Minority women seem to have more reason to want to leave big firms, according to our findings. [The study] showed women of color experiencing less satisfaction and more obstacles at large firms than their peers, including men of color.

You can read the full article -- replete with numerous quotes from "diversity advisers, "diversity consultants" and "diversity officers" -- over here.

Janice Rogers Brown Above the Law Wanda Sykes.JPGP.S. Yes, the Wanda Sykes reference is pretty random. We just think that she is hilarious, and we try to mention her at every opportunity. We also think she bears an uncanny resemblance to one of our favorite jurists, Judge Janice Rogers Brown (D.C. Cir.; see photo at right).

P.P.S. And have you seen -- or rather, heard -- Wanda Sykes in the new Applebee's ads? The restaurant chain has hired her to serve as the voice for their new "spokesapple." Genius.

Why Are Minority Female Associates Leaving Law Firms? [Minority Law Journal]

A Sexist Screed Against Female Attorneys?

We are not easily offended, nor are we very politically correct. Sometimes we write things that upset or antagonize people (sometimes intentionally, and sometimes not).

But this discussion of women lawyers, while certainly provocative, is a bit too inflammatory for our taste. We won't post excerpts here (because finding a portion that isn't offensive is difficult).

It's generating discussion and making the rounds by email, however, and people have brought it to our attention. We're passing it along for your consideration, so you can see what all the fuss is about. But please keep in mind that we agree with Jeff Jarvis's linking philosophy: “A link is not necessarily an endorsement, but a way to say ‘you go judge for yourself.’”

What A Girl’s Job Tells You [Roissy in DC]

ATL Field Trip: The Building a Better Legal Profession Press Conference

Andrew Bruck Building a Better Legal Profession Above the Law blog.jpg
Andrew Bruck takes a question at Wednesday's press conference.

Every now and then, we leave our apartment. We did so on Wednesday, to attend the press conference of Law Students Building a Better Legal Profession, where the organization unveiled its law firm diversity rankings (accessible here; Los Angles Times article here).

It was quite informative. For those of you who might be interested -- and we're guessing there are a number of you, judging from the robust commentary on our earlier post -- read more, after the jump.

Continue reading "ATL Field Trip: The Building a Better Legal Profession Press Conference"

Law Firm Diversity: Who's Naughty, Who's Nice?

Law Students Building a Better Legal Profession Above the Law blog.jpgAre you concerned about diversity (or the lack thereof) at America's top law firms? Have you been wishing for a handy resource that would rank the Biglaw shops by their performance on diversity metrics, as well as other measures, such as billable hours and pro bono work?

Well, you're in luck. Later today, Building a Better Legal Profession will be issuing just such a report. Here's a blurb for their upcoming press conference:

Over one-third of all large law firms in Manhattan don't have a single African-American partner. Nearly half of all large law firms in Washington, D.C. don't have a single Hispanic partner. One firm doesn't have a single LGBT partner or associate in either office. On October 10, find out who.

Building a Better Legal Profession, a national grassroots coalition of law students, will release its first report on the status of the legal profession. The groundbreaking study compares the largest law firms in each of the top six legal markets (New York, Washington, Boston, Chicago, Northern California, and Southern California) by various metrics. The report ranks firms by billable hours, pro bono participation, and demographic diversity (percentages of partners and associates who are female, African-American, Hispanic, Asian-American, and LGBT).

On hand at the press conference will be statements of support from Marcia Greenberger, co-president of the National Women's Law Center, and Prof. Deborah Rhode, former chair of the ABA Commission on Women in the Profession. Media: Please contact Andrew Bruck or Prof. Michele Landis Dauber for more information and sample rankings.

To get a sense of the rankings, click here (PDF), for a report card showing how D.C.'s top law firms stack up on diversity, or here (PDF), for the New York law firm diversity rankings.

The leading firm for diversity in Washington (with an overall grade of B+; almost all the firms earn C's or worse): Nixon Peabody! Remember, they hired lots of minorities to sing their theme song (mp3).

For those of you here in D.C., consider attending today's press conference (we'll be there):

Wednesday, October 10, 2007 -- 12:30 p.m.
National Press Club
13th floor, Zenger Room
529 14th St. NW
Washington, DC

Very exciting. Congratulations and thanks to Building a Better Legal Profession!

Law Students Building A Better Legal Profession [official website]
Diversity Report Card: D.C. [PDF]
Report on Big Law Firms [National Press Club]

Biglaw Perk Watch: Lactation Rooms

breastfeed redacted lactate lactation room Above the Law blog.JPGWe continue our series profiling the perks or fringe benefits of life at a large law firm. This one may be the breast one yet. From a (male) tipster:

A friend of mine ran across this Simpson Thatcher perk: "The Firm maintains a lactation room for new mothers in each of its New York, Los Angeles and Palo Alto offices to facilitate their transition back to work."

I have a hard time seeing candidates asking about it during interviews, so I thought I'd pass it along. I'm not a chauvinist or anything! I just have a childish sense of humor...

You're not alone. We'd note that this perk may have broader appeal than our correspondent might think. See here.

Also, we'd suggest to STB that they regularly sweep their lactation rooms for spycams. Remember this guy?

Update: Jeez, some of you are oversensitive. With respect to the photo, here's what happened. To avoid copyright issues -- hello, Nixon Peabody! -- we use pictures primarily from royalty-free, stock photography sites. People upload pics to these sites that they allow others to use for free.

Our favorite such website, to which we have contributed many photos of our own, is stock.xchng. For this post, we went to stock.xchng and ran a search for "breastfeed." The pic we used was one of three images that came up. That's all.

Flexible Working Arrangements [Simpson Thacher & Bartlett]
Male lactation [Wikipedia]

And No, She Doesn't Do Windows

Florence maid Jeffersons Marla Gibbs Above the Law blog.jpgThis email exchange, between two law students at Washington University Law, took place late last month. It's reminiscent of that Greenberg Traurig email exchange from the other day -- which, in our book, is high praise.

Some background, from our tipster:

I'm an avid reader of ATL. Although I don't see much law school coverage on your site, I thought you might find this email string between a couple Washington University in St. Louis law students amusing.

Note that the email string starts as a solicitation sent to the entire school, marketing a washer/dryer for sale. The proceeding communications are also copied to the ENTIRE school of law (including professors, deans, etc.).

Check it out, after the jump.

Continue reading "And No, She Doesn't Do Windows"

But What About the Dads?

A tipster drew our attention to this Craigslist posting, to which he appended a single line of commentary: "Discriminatory? Ha Ha."

It seems that only the title of the posting implicates motherhood. The main body of the listing refers to the candidate as "he or she," and the job responsibilities do not require a maternal figure. E.g., breastfeeding the CEO is not required.

Moms Wanted - General Counsel, Part time/flexible hours (Midtown East) [craigslist]

Picture of the Day (and Possible Bar Exam Question)

For those of you who just took the bar exam, the last thing you want is another essay question. But just for fun, and to see how much you've retained, here's one for you (in the style of an MPT question):

Your client is a junior associate at a top New York law firm. She agreed to be interviewed and photographed for an article in the New York Times.

When the article appeared, your client was captured in this unfortunate pose:

New York Times photograph young lawyer Abovethelaw Above the Law blog.jpg

Your client is distraught. She admits that she consented to the interview and photo shoot. But when she did, she had no idea the Times photo editors would choose THAT picture (out of literally hundreds that were taken).

What possible theories of liability would you explore as the basis for a possible lawsuit by your client against the New York Times?

(Hint: New York does not recognize the tort of "Being negligently photographed in the Sharon Stone pose.")

Update: At least one of you thinks this photo is no big deal. But we view the photograph as brilliantly composed, fascinating, and tantalizing. It's like the smile of the Mona Lisa: the more you stare, the more elusive the mystery becomes.

For Young Earners in Big City, a Gap in Women’s Favor [New York Times]

Lawsuit of the Day: Legal Fight Over Ladies' Night

Ladies Night party girl Abovethelaw Above the Law blog.jpgSo what do lawyers do when they leave the hallowed halls of Cravath, Swaine & Moore?

Some move on to smaller firms. Some, like former corporate partner Robert Kindler, go into investment banking (and make even more money).

But some take more surprising paths. From the current issue of the New Yorker:

A former associate at Cravath, Swain [sic] & Moore, [Roy Den Hollander] had moved to Russia to work as a private investigator. There he met a woman, with whom he returned to New York. They were married in March, 2000, and separated by December. In Den Hollander v. Flash Dancers Topless Club et al., Den Hollander sued his ex-wife and her employer under the auspices of a civil RICO statute. The suit was dismissed.

Did that romantic misadventure leave Hollander with hostility towards women? It might explain his latest legal quest, which is our Lawsuit of the Day:

In June, [Hollander] filed a federal lawsuit alleging that ladies’ nights constitute a violation of the Fourteenth Amendment. Citing invidious discrimination, he named as defendants the night clubs A.E.R., Lotus, Sol, China Club, and the Copacabana—which charged lower admission fees for women at, respectively, their Remix Thursdays, Velvet List Wednesdays, Models and Bottles Fridays, Metropolis Fridays, and College Party Thursdays.

What do other crusaders for gender equality make of the case? Karen DeCrow, vice-president of the Greater Syracuse chapter of the National Organization for Women, agreed with Hollander's legal theory -- even if, she noted, "it probably wouldn’t be very fun to go out to dinner with him."

On the Docket: Hey, La-a-a-dies! [New Yorker]
N.Y. Lawsuit Calls 'Ladies' Night' Discriminatory [National Law Journal]

Are You A Female Lawyer?

scales of justice ABA Journal UC Hastings women lawyers Abovethelaw Above the Law blog.jpgIf so, then please take this survey.

Please note that the survey is for WOMEN LAWYERS ONLY (sorry, boys). It's being conducted by the ABA Journal and the Center for WorkLife Law, at U.C. Hastings. The goal of the study is to find out how women lawyers treat each other in the workplace.

(We could offer a few editorial thoughts of our own on that subject. But we should probably refrain, so as not to skew the survey results -- or get ourselves in trouble....)

To take the survey, please click here. And please feel free to forward the survey link to your female lawyer friends. The survey will be kept open through the end of June.

Thanks!

Women Lawyers Working Together [Survey Monkey]

Justice Ginsburg: No Future in Voice-Over Work, But Could Become the Next Great Liberal Lioness

Ruth Bader Ginsburg Justice Ginsburg Above the Law Legal Website.gifThe front page of today's Washington Post has an interesting article about Justice Ruth Bader Ginsburg's dissent yesterday in Ledbetter v. Goodyear:

The court ruled 5 to 4 that Lilly Ledbetter, the lone female supervisor at a tire plant in Gadsden, Ala., did not file her lawsuit against Goodyear Tire and Rubber Co. in the timely manner specified by Title VII of the Civil Rights Act of 1964.

The decision moved Justice Ruth Bader Ginsburg to read a dissent from the bench, a usually rare practice that she has now employed twice in the past six weeks to criticize the majority for opinions that she said undermine women's rights.

Speaking for the three other dissenting justices, Ginsburg's voice was as precise and emotionless as if she were reading a banking decision, but the words were stinging.

Justice Ginsburg's style of delivery should come as no surprise to regular visitors to the Court. She's generally regarded as the most soporific when it comes to reading opinions from the bench.

But Justice Ginsburg's decision to dissent from the bench is interesting. A number of more hard-core liberals -- e.g., Judge Stephen Reinhardt, of the Ninth Circuit -- view RBG as insufficiently liberal (or insufficiently outspoken in defense of her liberal views). They see her as something of a disappointment on the SCOTUS, given her pre-robescent background as a crusading lawyer for the ACLU and feminist legal scholar.

But RBG's vociferous dissents in Ledbetter and in Gonzalez v. Carhart, the partial-birth abortion case from earlier in the Term, raise a question: Could Justice Ginsburg finally be flowering as liberal leader of the Supreme Court?

P.S. To be sure, "flowering" is not a term usually applied to Justice Ginsburg. But you know what we mean.

P.P.S. Among the federal appeals courts, we'd say the Eleventh Circuit has the greatest track record of producing liberal lionesses. E.g., Rosemary Barkett; Phyllis Kravitch.

But there are some noteworthy liberal judicial divas on other circuit courts. E.g., that New England ice queen, Sandra Lynch, of the First Circuit; that luscious Latina, Sonia Sotomayor, of the Second Circuit; the frighteningly brilliant Diane Wood, of the Seventh Circuit; the ancient yet energetic Betty Fletcher, of the Ninth Circuit; and the magically delicious Marsha Berzon, also of the Ninth Circuit.

Over Ginsburg's Dissent, Court Limits Bias Suits [Washington Post]

Gentlemen: Do You Have a Parasite?

Working woman.jpg

No, we're not talking about the penis fish in Assistant Director Skinner's member on "Grey's Anatomy" last night. (Although that was seriously cool.)

Via the Legal Times, we see that Judith Warner has weighed in on the "mommy wars" in her NYT blog, commenting on the genre of anti-stay-at-home-motherhood writing, of which Leslie Bennetts' "The Feminine Mistake" and Linda Hirshman's "Get To Work" are the prime examples.

Warner reports that Bennets, who calls non-working wives "parasites," is the target of an online boycott spearheaded by outraged mommy-bloggers. Warner sides more with the moms than with Bennets:

[T]here is more than one way to provide for one's family. Sometimes, for a host of reasons, ranging from a spouse's excessive or erratic work schedule to a child’s special needs, the best way to provide for one’s family is by upping one's own presence at home. Sometimes it just works out that one parent needs to be at home in order to keep the machinery of life from spinning apart.

Good point. There are no children in the LEWW household, and even so, our machinery of life sometimes teeters perilously close to shutdown. Unfortunately, lawyers know all about "excessive or erratic work schedules."

A boycott of Bennets' book may not be necessary, though; the NYT reported Wednesday that despite all the heat generated by the topic, the mommy-wars books generally have dismal sales.

October Term 2007 Clerk Hiring: A Request for Information

Supreme Court hallway Above the Law Above the Law Above the Law.JPGWe're interested in figuring out how many law clerks for the upcoming Supreme Court Term, October Term 2007, are women or minorities. But we don't know all these folks personally (much as we might like to). So we need your help.

After the jump, you'll see a list of the Supreme Court clerks for OT 2007. Check it out. Do you know any of these individuals?

Okay. It appears to us that of the 37 clerks, 14 are women. Is this correct? In terms of clerks with gender-ambiguous names, we've categorized the following as male: Aditya Bamzai (see here), and C.J. Mahoney (the "C." stands for "Curtis").

As for ethnicity, we're speculating -- based largely on surnames -- that the following individuals are Asian American: Aditya Bamzai, Michael Chu, and Bert Huang (whom we know from college, so we're pretty sure about him). But we're sure that we're missing other minority law clerks from our tally.

Can you help us out? If you know of any other OT 2007 clerks who are minorities, or if our tally of female law clerks is off, please note that in the comments (or send us an email).

Update: In case you're wondering, we're collecting this information for a freelance piece we're working on. (In addition to writing for ATL, we freelance for various print publications on the side.)

The full list of OT 2007 clerks appears after the jump. Thanks in advance for your tips!

Continue reading "October Term 2007 Clerk Hiring: A Request for Information"

Non-Sequiturs: 04.20.07

Kate Moss Katherine Moss model supermodel Above the Law blog.jpg* Like you, this attorney and concerned citizen opted for law school because science just wasn't her thing. [J-Walk Blog]

* Kettles Retailers are being told they're black warned not to infringe upon Kate Moss's much-hyped and copyrighted "Pot"-shop Topshop collection. [Fashionista; Retail Week]

(An explanatory note for those of you who couldn't care less: Topshop is an H&M-esque retailer that rips off designs from everybody so that broke girls and boys can swath themselves in sweatshop-produced crap and still have money left over for cigarettes.)

* Power may be the great aphrodisiac, but in my experience, sexual harassers in the professional workplace are just pervs or losers who couldn't find a date in high school. Sometimes it's that simple. [Feminist Law Professors]

* In these violent times, "Red Asphalt" just doesn't do the trick in scaring the bejesus out of high school drivers. [Central Ohio]

* School lunches + biometrics = ACLU. Of course. [Turn to 10]

Morning Docket: 03.28.07

D Kyle Sampson Kyle Sampson Kyle D Sampson Kyle Samson Above the Law blog.jpg* Return of the Equal Rights Amendment? [Washington Post via How Appealing]

* Rumsfeld torture charges dropped because his actions were related to his government position. [CNN]

* DOJ: Monica mum, but Sampson speaking. [MSNBC]

* On that subject, here's a chart and timeline with links for all you need to know about "Attorneygate." [Slate]

* Now that his ex-wife has become a man, the ex-husband is seeking to end alimony payments on that basis. [CNN]