The Absurdity of the Hunter Biden Defamation Case

I have taught torts, including defamation for over 30 years, but I have never seen the like of the Hunter Biden defamation case. The defendant made defamatory statements and then just refused to appear. That led to an equally bizarre $1.7 million award by U.S. District Judge Stephen Wilson of the Central District of California to Biden, consisting of just $1 in nominal damages and the rest in punitive damages.

Here is the most interesting line of the opinion: “the damage to Plaintiff’s reputation is difficult to calculate.” It may be the single greatest understatement in the history of judicial opinions.

However, the court also noted “Plaintiff does not seek actual damages above a nominal amount.”

That means that Hunter Biden’s counsel, in a default case, elected not to argue for compensatory damages due to loss of reputation. Why would he do that?

It might be that he has little reputation to lose and that opening up that part of the case was fraught with perils.  However, it also created a potential major appellate issue. His counsel was making it clear that they were litigating purely for punitives.

For Hunter Biden, this is a much-needed windfall. His art sales notably collapsed with the value of currying favor to the Bidens. He is reportedly being pursued by creditors, including former counsel.

The question is whether the award will stand.

For many critics, Hunter Biden is virtually ‘libel proof” as an individual who has no reputation to lose. However, as we have previously discussed, that status is reserved for the most reviled personalities who cannot be defamed due to the lack of any positive reputation.

Judge Wilson, a Reagan appointee, admits in his opinion that determining reputational harm to someone like Biden is difficult to do and further recognizes the argument that “prior tarnishing of Plaintiff’s reputation may reduce the reprehensibility of Defendant’s conduct.”

The case involves a claim by former Overstock.com CEO Patrick Byrne that Biden took part in an $800 million bribery scheme involving Iran and failed to defend his claims in court.

Hunter Biden has long been accused of influence peddling that generated millions for him and his family. I have been one of his longest critics as part of a corrupt family enterprise.

However, this claim was not one of those that his critics, and Congress, focused on during the Biden years. There is no evidence that he took a bribe or payment in a quid pro quo for releasing the money to Iran.

The lawsuit was part of a flurry of such actions brought against Biden’s critics. Most were later dismissed, but played a part in the scorched-earth campaign of Biden. I was even threatened with such an action after criticizing his counsel and financial backer, Kevin Morris.

As Biden dropped the other lawsuits, this one continued to be litigated. It was an easy kill. Byrne simply did not defend himself and defaulted. That left the matter to Judge Wilson, who was clearly irate.

The opinion recounts an extraordinary pile-up as Byrne sought to replace lawyers:

“Defendant initially attempted to replace Mr. Murphy with three new lawyers: Eric Neff, Tom Yu, and Stefanie Lynn Lambert Junttila. ECF Nos. 290, 291, 292. Ms. Lambert was not a member of the California Bar, and her application to appear pro hac vice was denied2 due to her recent history of unethical conduct, which gave the Court reason to doubt she would abide by the Court’s rules and practices. ECF No. 295. When Defendant learned that Ms. Lambert was not qualified to represent him in this case, Defendant also instructed Mr. Neff and Mr. Yu to remove themselves.

Moreover, Defendant himself, now unrepresented, still failed to appear at trial. Accordingly, the Court issued an order to show cause why it should not enter default judgment against Defendant and ordered the parties to return the following day. At that hearing, on July 30, 2025, Defendant again failed to appear. Mr. Yu, who was not authorized to represent Defendant at trial, argued on Defendant’s behalf for a continuance, in lieu of default judgment.”

The defendant would miss a series of filing and appearance dates, including orders that he appear in person.

Wilson, 85, ruled in his opinion that Byrne acted with “intentional misrepresentation” and “conscious disregard” for Hunter’s rights. Making things worse, Byrne was found to have continued making the false claims after the lawsuit, and said Byrne continued to amplify the false allegations even after Hunter filed the lawsuit against him.

Accordingly, the court found that the “defamation went far beyond mere negligence,” and that Byrne actively sought to spread the false claim on social media and to make the story go viral.

The problem is that the actual harm from Byrne’s comments was likely minimal given the widespread influence peddling detailed by Congress and Biden’s federal convictions on other offenses.

In these well-documented dealings, there were gifts such as diamonds, lavish expense accounts, and a sports car, in addition to massive payments that Hunter claimed were “loans.” There are messages like the one to a Chinese businessman, openly threatening Joe Biden’s displeasure if money is not sent to them immediately. In the WhatsApp message, Hunter stated:

“I am sitting here with my father, and we would like to understand why the commitment made has not been fulfilled. Tell the director that I would like to resolve this now before it gets out of hand, and now means tonight. And, Z, if I get a call or text from anyone involved in this other than you, Zhang, or the Chairman, I will make certain that between the man sitting next to me and every person he knows and my ability to forever hold a grudge that you will regret not following my direction. I am sitting here waiting for the call with my father.”

So, accusing Hunter Biden of influence peddling would hardly seem a material blow to his reputation.

Wilson awarded just $1 in nominal damages to Biden but then ordered $1.7 million in punitive damages. Byrne was also ordered to pay nearly $35,000 in previously imposed court sanctions within two weeks or face an additional $1,000 penalty for each day payment is delayed after the deadline.

That 1:1,700,000 ratio is a bit startling. The general rule is that a ratio of greater than 1:10 in compensatory to punitive damages can raise serious constitutional concerns. What makes this case different is the contempt and default elements.

In 1996, the U.S. Supreme Court decided a case, BMW of North America v. Gore, striking down a punitive damage award. The case involved the practice of the company to repair and repaint cars damaged in transit without telling the customers. The jury in the original trial awarded $4,000 in compensatory damages for the lost value to the car in not having a factory paint job and other damage; it then imposed $4 million in punitive damages for the company’s dishonesty.

The Court stated three factors in crafting punitive awards: (1) the degree of reprehensibility of the nondisclosure; (2) the disparity between the harm or potential harm suffered by plaintiff and the punitive damages award; (3) and the difference between this remedy and the civil penalties authorized or imposed in comparable cases.

Even though the Alabama Supreme Court previously reduced the punitive award by half, the U.S. Supreme Court still found that the award violated the Due Process Clause as “grossly excessive.”

The fact that this case involves nominal damages may allow for greater leeway in the ratio. See Arizona v. ASARCO LLC, 773 F.3d 1050, 1058 (9th Cir. 2014). That is clearly a critical part of the decision of counsel to ask for only nominal damages while litigating for punitive damages. However, this ratio is astronomical.

Judge Wilson addresses BMW v. Gore but effectively untethers the ratio analysis from this case, precisely what Biden’s counsel had hoped in seeking only nominal damages. It is an approach that would effectively gut BMW v Gore. Any litigants with a bad reputation or insufficient reputational harm could simply ask for nominal damages and then ask for the moon in punitive damages. Moreover, it relieves the obligation to determine how many people actually read or were likely influenced by Byrne, particularly given the focus of the influence peddling scheme on Biden’s dealings in Ukraine, China, and other countries.

However, it gets weirder. I was curious how, without any record on harm, the Court could come up with $1.7 million. It turns out that the Court used the damages awarded by a Canadian court against Byrne in a similar defamation case. That case in a foreign jurisdiction awarded $1.134 million. Wilson blithely declares that, since Byrne continues such conduct, “a $1.134 million award would be inadequate to deter this particular Defendant. The Court therefore calculates a punitive damages award of $1.7 million, approximately 50% greater than the total judgment in the prior case.”

That is it. The court simply used the damage award in a foreign torts case and elected to increase it by 50%.  However, that earlier judgment only included $250,000 in punitive damages.

I think that the court is dead wrong on the punitive damages analysis. The only question is whether the extent of Byrne’s contempt and default will work to quiet the concerns of appellate judges.

It is a case worthy of appeal.

It is a fascinating car wreck of a case with a scandal-plagued plaintiff, a defaulting plaintiff, the use of a foreign judgment as the basis for a damages award, and a 1:1,700,000 ratio in damages. We will be watching if an appeal is filed by Byrne.

Jonathan Turley is a law professor and the New York Times best-selling author of “Rage and the Republic: The Unfinished Story of the American Revolution.”

 

180 thoughts on “The Absurdity of the Hunter Biden Defamation Case”

    1. *. Yes, it should have been dismissed by the mad hatter. Alice was late for a very important date.

  1. If Trump’s shenanigans are much, much worse than Nixon’s, then why has Trump not resigned yet?

    1. You answer your own question.

      Your displeasure with Trump does not create misconduct where there is none.

      1. John..

        Looks like the libs are really worried today. I guess the war is going in the right direction.

        1. DustOff,
          When the annonys are out in force, trying to deflect from the good professor’s column as they know how right he is.
          Or, there is something in the news that they do not want us to OT on. You know, Platner’s campaign implosion. The chaos in the Democrat party. Mamdani’s affordability promises are imploding as rent in NYC hits record highs,

          ” Rents in NYC have just hit an all-time high.

          Median market rate in June…

          Manhattan: $5,295/mo (+8.2% year-over-year)

          Brooklyn: $4,350 (+8.1%)

          NYC’s housing affordability crisis is at DefCon 1. We need to push harder on every front to address our housing shortage.

          Update…”
          — Mark D. Levine (@MarkLevineNYC) July 12, 2026 NYC Comptroller

          1. “We need to push harder on every front to address our housing shortage.”

            *WE* need to figure out how we can encourage Damned Nanny to double down on his efforts and create an unmistakable mass exodus of the remaining productive residents of NYC. I suspect that we are now just a couple of large, public Democrat missteps from sewing up the midterms for the Republicans, in spite of all the Lemmingade drinkers who will vote “D” regardless. .

  2. Why didn’t God give Moses the Constitution along with the Ten Commandments?
    If the Ten Commandments were that important, then why not go for broke and include
    the Constitution?

      1. Is Upchuck Farmer the censor of free inquiries on the free speech blog, or would he prefer content that just amplifies the echo?

        1. You could not be more wrong.
          I never said anything about censorship.
          Just THAT was a really DUMB question. And you ask dumb questions like that all the time. I am just pointing out the fact, that was a DUMB question.
          How marvelous! 🙂

        2. Who is censoring you ?
          Pointing out that your remarks are stupid is not censorship. It is free speech.

          As Justice Brandeis noted the correct response to bad speech is more speech.

          1. John Say,
            That is the default when we point out the annony making dumb questions, related to pretty much nothing and the annony in desperation attempts to deflect and conflate my criticism with censorship. I never said anything about censorship and have pointed this out more than a few times. But, in desperation, the annony just keeps repeating the same old narrative.
            Just like the same annony trying to make the claim the good professor is a free speech advocate but wants to censor someone who also made dumb comments.

    1. That’s all he does these days.
      He hypocritically and disingenuously stokes the very rage that he claims to despise in his worthless books.
      And the MAGA mob here falls in line and regurgitates the same tired old comments that they make every single day.
      A continuous cycle of absurdity.
      Wash, rinse, repeat.

      1. MAGA did not assassinate Charkie Kirk.
        They did not try several times to assassinate the president.
        They did not assassinate Brian Thompson.

        Look arround – the violence today is from the left.

        YOU are clearly hate filled and burning with rage.

        Over what ?
        That your lawless policies are being undone ?

    2. The good professor would have nothing to comment about if Democrats did not do, or say stupid and crazy things. You know, like, putting their support behind a guy who had a Nazi tattoo for something like 17 years. More than a few women have come out and accused him of emotional, physical abuse and now alleged rape. And they have evidence. It was only when the alleged rape case, with evidence, was so overwhelming they dropped their Nazi tattoo wearing candidate and got BACK on board of the “Believe all women!” train.

    3. If you do not want criticized quit doing stupid things.

      In this case the judge is a reagan appointee and the decision is in error.

      If the actual damages are inconsequential there can be no punitive – that is not a political issue.

  3. That is it. The court simply used the damage award in a foreign torts case and elected to increase it by 50%. However, that earlier judgment only included $250,000 in punitive damages.

    Why does that matter? How is it relevant either that the previous award was foreign, or that the vast majority of it was compensatory? The point here is that he had to shell out that amount, and yet was not deterred from repeating the offense, therefore such a penalty is clearly not enough to deter him from doing it again. Since the whole point of punitive damages is precisely to deter future reoffending, clearly more than $1.134M is needed. What’s wrong with that reasoning?

    1. If there is not actual damage – punatives are improper.

      I repeatedly harp on Actual harm – without actual harm we are outside the domain of govenrment.

      Government do es not exist to protect you from hurt feelings.

      Hunter claimed only nominal actual damages for good reason – otherwise his entire reputation was legitimate in the context of a defamation lawsuit.

      It was a cute legal trick to avoid the defendant being able to bring in all the other bad conduct that Hunter was involved in.

      But defamation is about damage to reputation – if there is no damage then there is no jurisdiction for government.

      The legal system does not exist to protect you from the truth – or from yourself.

      I do not know why Byrne did not defend himself – but it is reasonable to assume that he had no reason to – Hunter was not claiming any actual damages – so Byrne had nothing to lose – or should not have – until the Judge F#$Ked up.

      It is entirely possible that Byrne deliberately defamed Hunter in the hopes of Rope-a-doping Hunter into a court battle where Bryne could further savage his reputation or get him to lie under oath – which would not be protected by his Pardon. I do not know what was in Byrnes head – but there are many legitimate reasons for Byurne to have chosen to seek to draw Hunter into a court fight.

      Hunters choice to of not seeking actual damages – is a legitimate response – but without actual damages the court should have tossed the case – or awarded Hunter $1 and gone home.

      I am sure the judge was pi$$ed at Byrne – and justifiably so. But the court is not their to punish people for lacking respect for the court.
      It is there to punish actual harm.

      Further like all of us courts are NOT entitled to respect – they must earn it.

      Hunter Biden has made his own name worthless – that is a problem of his own making. The courts can not and should not remedy that.

      1. If there is not actual damage – punatives are improper.

        Since when? Which orifice did you pull that out of? Which legal authority says such a thing?

  4. To use an accounting analogy, after all of the debits and credits have been added together, it should be about whatever has the greatest debit.

  5. It is moderately amusing when Turley calls the Bidens a corrupt family while ignoring all the openly corrupt and illegal actions by Trump.

    1. That’s because there aren’t any “openly corrupt and illegal actions by Trump”.

      Remember that Hunter Biden was not simply making money from his name. There’s nothing wrong with that. The entire point of the scandal is that the money he was collecting was not in exchange for any services he could provide, but was clearly intended as bribes for his father. The only services he could sell were those of his father, because he himself had nothing to sell. He contributed nothing at all to Burisma, except the promise that his father would protect them, which he did. That makes it very different from Trump’s children, who are very talented people and have a lot to sell. If they use their father’s name as a marketing tool, there’s nothing unethical about it.

      1. Trump is literally selling pardons for money. He is enraging in market manipulation and insider trading. He took a $400 M bribe from Saudi Arabia. Playing dumb to Trump’s crimes is something that will come back to MAGAs.

        1. I am not happy with many presidential pardons – not Trump’s not other presidents through history.
          Clinton and Obama and Biden have some real stinkers. Most of Trumps are pretty tame.

          Further many of Trump’s pardons are truly excellent.

          But there is no evidence that Pardons are actually being sold.

          There is no market manipulation or insider trading.

          Is the Trump family making more money becuase Trump is president – possibly – But they have been making money for decades.
          You left wing loons are now going past those who hold political office must become impoverished dependents on govenrment charity – to requiring their family do too.

          You say the Saudi’s bribed Trump.

          What exactly did Trump do for the Saudis that he was not going to do regardless ?

          Worse for you still – the american people are benefiting.
          Isn’t that what we expect from Presidents ?

          1. “Is the Trump family making more money becuase Trump is president – possibly – But they have been making money for decades.”

            While I don’t particularly like the idea of a President directly profiting from his Presidency during his term of office, I don’t think that even that is illegal, or legitimate grounds for impeachment. I believe that there would need to be proof that some decision was made that was in his interests and simultaneously against the interests of the US. That would be difficult to substantiate, and, while Trump’s personality frequently rubs me the wrong way, I don’t suspect that he has done that. I think that Joe Biden probably did that on numerous occasions.

      2. Milhouse – correct – but the critical point is that he was not selling his fathers services – he was selling the power of the vice president of the united states.

        With respect to the Trump family – Trump has been a brand since the 70’s – that is not slightly new. They are not selling their fathers name they are using their family name – that brand as a marketing tool.

        Doors opened for Hunter because he was the son of the United States VP – that is problematic, but it is legal.
        It is not the doors that were opened that is the crime. it is not the oportunities Hunter had that is the crime. It is specifically that what he was selling was the USE of the Power of the Vice President. This was a clear quid pro quo.

      1. DustOff,
        That is just it. They make wild accusations and claims and never provided real proof.
        Steve’s analysis today really was on target.

    2. Sallu – the Biden family literally sold public office for personal profit.

      Further they did so extremely badly.
      The Clinton did much the same but wisely papered over the corruption by laundering it through charitable foundations.

      It is obvious looking at the Clintons and Pelosi’s and pretty much all of congress right and left, that finding ways to personally profit from publci office without breaking the law is trivial. Maybe we should reign that in – but it is quite difficult. Trying to make an otherwise legitimate act illegitimate when done by an elected official is rife with potential problems – including constitutional violations. You do not shed your rights by taking public office.

      As to the Trump’s – not only is there nothing being done that is illegal – but much of it was initiated before Trump was president.
      And nearly all of it is either passive or done by members of Trump’s family that are NOT in government.

      There are no government actions Trump has done that he did not telegraph – often decades before being president.

      There is no evidence at all that decisions within the Trump administration are being made differently to benefit Trump or his family – and That alone would NOT be sufficient to prove corruption.

      Buy Trump coin or don’t
      Buy Golden Sneakers or dont

      That is your choice. You are free – no one is coercing or inducing you.

      Everyone who donates to a political campaign beleives they are going to get something for that.
      That is not new, it is not corruption.

  6. This makes a nice convenient diversion away from real stories like Trump’s flagrant attempts to destroy are democracy by nationalizing the elections. Turley never talks about that stuff other than the totally lame observation that Trump fired at the EAC members without any serious in depth discussion of the consequences.

      1. Professor Turley is a lawyer. He argues facts and law. An idea of which seems to have been lost on you due to your TDS. You argue like a non lawyer. None, and I mean none, of your comments contain any facts or law that supports what you are ranting about. But, that’s true of all the detractors on the good professor’s blog. If you don’t like what he writes, and you can’t counter his legal arguments with your own cogent legal response, than stop making yourself look stupid. Start your own blog.

    1. Virtually all countries require identification for voting…..? Why should U.S. continue in its current careless process?

    2. “Trump’s flagrant attempts to destroy are democracy by nationalizing the elections.”

      That is a paranoid fantasy by Democrats who have no actual arguments to make.

      1. MilHouse,
        Correct.
        And the annonys, Sally et al. come here to the good professor’s blog everyday repeating the same fantasies and lies, all the time.

        1. UF – this current claim is the equivalent of
          Pulling out their hair and screaming “Trump has beat us at our own game – that is corrupt”

          There are only a few constraints on congressional power with respect to elections to federal office.

          Without violating those constraints – super majorities of people actually want federal elections conducted the same everywhere.

          If it is constitutional and democrats and republicans alike want it – where is the crime ?

          The issue is NOT that Trump is seeking to nationalize federal elections, it is that he is doing so in a way super majorities want – and not in the way a small percent on the far left want.

      2. It is an absurd claim – even if it was true – which it is not, it is something Democrats have WANTED.

        Democrats want lax election rules imposed by force by the federal govenrment, republicans want strict election rules enforced by the federal govenrment.

        While what democrats want is a bad idea that will lead to large scale fraud inevitably if it has not already.

        Just because it is a bad idea does not meant hat they can not constitutionally do it.

        What Trump wants is a good idea that will diminish the opportunity for fraud and make our elections more trustworthy.
        A good idea and constitutional.

    3. How is Trump trying to nationalize elections ? That is something Democrats have sought to do – eliminate the electoral college, etc.

      The constitution gives congress and the states the power to make the rules for FEDERAL elections – states may conduct state and local elections however they please.

      But lerts presume Trump was seeking to “nationalize electiosn” whatever that means – how would that “destroy democracy”
      That would actually be more not less democratic.

      Further how can Trump destroy something that does not exist – the US is not a democracy.

      The EAC continues to do the tasls congress delegated to it.

      What is can not do right now is make new non-binding recommendations to states.

      Contra your claim Trtump is THWARTING the nationalization of elections.

      Your whole post does not have two adjacent words that are true, nor make an argument that is not massively self contradictory.

    4. You state a conclusion and provide no evidence of how nationalizing elections in the U.S. would “destroy our democracy.” Having a specific set of rules for national elections doesn’t “destroy our democracy,” it would strengthen it by making sure that everyone is legally permitted to vote, i.e., that the person voting is a U.S. citizen. And don’t argue that there is no proof of non-citizens voting. That’s a red herring. The fact that some could vote illegally is sufficient to require ID and proof citizenship. The rest of the world doesn’t seem to have a problem requiring their voters to show proof if eligibility to vote. There is nothing in the Constitution that prohibits it.

  7. Our legal system has serious problems. In New York State, the biggest problem is political bias. Generally, the biggest problem is lack of guidance and control over judges and juries in awarding damages, both compensatory and punitive. High damage awards lead to advertising by personal injury lawyers as to “million dollar verdicts” which only habituate the public to granting high awards. Like teacher unions, the PI bar then contributes money to politicians who advance their interests. As a result , the rest of us pay a higher price for goods and services to pay for hidden insurance costs. Poor people and workers are hurt most.

    1. EM – While you are correct that our legal system is a mess.

      More important is that it is much like winning the lottery.

      Most cases do NOT result in massive awards – most cases die or settle. The massive awards are rare.

      Sometimes they are bad, sometimes they are good. Is some reform needed – but not a massive overhaul and not broad limits on awards.

      Far more important is eliminating regulations.

      Torts which you are complaining about it is LEGITIMATE means for regulating private actions.

      Contra the left big business WANTS regulation. There was a recent SCOTUS decisin limiting awards – the basis of the decision is that the defendants complied with federal regulations. Big Business LOWVES regulation – they can rent seek regulation – they can not game juries.

      1. John Say – I hope that someone will conduct a thorough comparative study of the systems for compensation in the advanced countries. I think we would finish low on the desirable metrics like speed, cost, predictability and fairness. Our whole legal system seems to me to impose too high a cost on society.

  8. Hunter Biden is a useless as Prince Harry! Both seem to have histories of influence peddling, drug abuse and appendages to a family name. The problem seems to be that the families have created the monsters they have spawned and most probably, not intentionally. Powerful people have little time to parent and it does take time and extreme energy to raise kids. How to give usefulness to these people now is the question of the ages but it starts with humility on the part of the now adult to ‘get it’ — the ‘gravy train’ of privilege and money has ended.

    1. You presuppose that Turley actually writes this garbage.
      But you would be wrong.
      Just yesterday he mentioned that he is NY this week for a book event, yet somehow he managed to crank out 4 pieces in 2 days, all of which would require factual research.

      He does not write this garbage,

        1. I notice that you do not defend Turley, because you know that I am correct.
          Instead you vomit up your own MAGA bile.

          1. ATS – EM was defending Turley.

            Regardless – no you are not correct – nor are your claims relevant.

  9. Hunter is absurd,y lucky. All that criminal behavior and not a day behind bars. Disgusting.

  10. Dear Mr. Turley, Hunter Biden needs to go away and stop trying to find even more terrible publicity for himself. He is a very sad example of someone who had a famous father and tried to capitalize on the father’s name. The Old Man seems to be well off, perhaps, by begging forgiveness from the Old Man for ruining the end of his life and political career, maybe, just maybe the Old Man will cough up the $17 million poor Hunter needs.

    1. I think that Joe Biden was more than capable of ruining his own career and remaining life. Hunter’s “help” was unnecessary and redundant.

  11. QUOTE: “It is a fascinating car wreck of a case with a scandal-plagued plaintiff, a defaulting plaintiff…”

    Defendant! Not the only error, but one that really should be fixed, coming as it does at the essay’s conclusion.

    More trivially, the Brits say “car crash” and we Americans say “train wreck” — FWIW.

  12. As a recovering attorney, I can tell you that there is nothing that upsets a judge more than thinking is authority is being ignored.

    1. Yup, but a judge has no authority in a non case.

      If you file a defamation claim and do not make any consequential actual damage claims – the case must be tossed.

      Courts are not there to punish people for conduct they do not like – in the case of Torts such as they – they are their to punish ACTUAL HARM

      no harm, no foul, no case.

      1. If that were true then punitive damages would not exist. The law clearly does provide for them, and no one disputes them — the arguments are only about how high they can go, not about their legitimacy at all, which is what you seem to be challenging.

  13. Come On Man – Its Deep Blue Black Robe Illuminati time to ring in and support the lunacy of the Biden Legacy! The Judge was feelin kinda bad for the Junkie and thought this might help him get through a rough patch in life AND GIVE HIM A CHANCE TO SCORE SOME CLEAN BLOW AND A REALLY SWEET HOOKER!! Bah haha.

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