Going Beyond Legal Obligations: Be Guided by Fairness and Justice
Robert M. Hendrickson
Pennsylvania State University
When Dixon v. Alabama (1961) was decided, I was a junior in high school, and at the time, I had no idea of the revolutionary nature of this case. What I learned as I began to study legal issues in higher education was that this decision was a watershed case that brought the courts through the college gates and established a new constitutional relationship between students and colleges and universities. This new constitutional relationship resulted in the courts exploring the applicability of certain constitutional rights to college students. These rights, commonly discussed in higher education judicial circles today, included due process, privacy, equal protection under the law, gun control, and freedom of speech, press, and religion. These areas, and many others, have been the topic of discussion in APCA Developmentswhere legal issues have been explored and implications for practice were presented for student affairs practitioners.
This is my last contribution to Developments, and this fact has resulted in some reflection on how far we have come in protecting student’s rights while creating a safe, healthy, and diverse educational environment that promotes student development and growth. It has resulted in a personal retrospective of my own experience as an administrator responsible for enforcing institutional policy while protecting student’s rights, all the time trying to utilize professional and ethical standards. It is not just a question of what is legal, in many cases, but what is fundamentally fair and just. Our standard ought not to be whether we are operating within what the law requires but, rather, how do we conduct a fundamentally fair and just process where the rights of both the accused and the accuser are protected. Applying that higher standard of being fundamentally fair and just is tested directly in Title IX cases of sexual assault.
Particularly difficult are those cases that involve alcohol and acquaintance rape. These cases usually involve alcohol consumption and questions of whether the sexual involvement was consensual. These cases are complicated further by the fact that they may involve criminal activity (i.e., rape), but often we elect, as an institution, not to report a potential crime to police. Though there may be good rationale for not reporting this criminal activity, whether this is educationally and developmentally sound practice remains unclear. Are we actually enabling irresponsible behaviors because students know they will be protected by the institution and not be held responsible by the outside world for their actions? The 18-year-old adult not enrolled in college would face criminal prosecution for similar behavior. Are we being fair and just to all students by protecting a handful from criminal prosecution? An actual case may help to understand how these issues play out in sexual assault cases.
Last fall, as I was beginning to think about this final column in ACPA Developments, I saw an article in the September 6, 2011 issue of Inside Higher Education (IHE) entitled, “New Scrutiny for Sex Assault Cases”. I thought this would be the perfect topic on which to write because it addressed issues that require administrators to go beyond basic legal requirements to provide a fundamental fair and just process for all parties. Little did I know at the time how prophetic this choice was and how sexual assault would affect me professionally, as well as the University to which I have given 28 years of my life. As the reports of child abuse unfolded at Penn State, my reaction was a variety of emotions and a tendency to hide from this topic. Sexual assault involving campus constituencies, regardless of whether it’s abuse of students or children, raises similar issues. In time, however, I was able to move beyond the sorrow and anger I was feeling and realized that understanding the legal and ethical requirements in sexual assault cases will help to understand policy and practice that can be applied equally to cases of child abuse. What follows is not a discussion of the situation at Penn State, where legal process and investigations will determine guilt, dysfunction and remedies to be applied in the future. However, the resolution of sexual assault cases in recent years can provide student affairs administrators with some guidelines to a fundamentally fair and just process in resolving these cases.
In Doe v. University of the South 687 F. Supp. 744 (E.D. Tenn. 2009), after an encounter on August 30, 2008, between the plaintiff Doe (a male student) and a female student, the female student filed a complaint with the University alleging rape. The University’s Title IX sexual assault policy and procedures requires that a student be notified within five class days after a complaint has been filed. The Dean appoints an investigator who interviews students and witnesses involved and, where possible, obtains written statements. The accused and accuser are each asked to provide written accounts of the incident and each is provided with a consultant, one character witness, and a 24-hour notice of the hearing date and time. On September 17, John Doe was asked by the Dean’s office to attend a meeting with the Dean of Students on the morning of September 18. That morning, he was informed of the charges, given statements of witnesses, informed of the hearing scheduled for September 19, 2008, and told to bring a character witness to the hearing. Doe was quizzed on his written statement by the appointed investigator before the hearing. Doe did not hear the hearing investigator’s oral testimony and was allowed in the hearing only during his own and his character witness’ testimony. He was informed later that day that he was found guilty and given two options: suspension for one semester with the assault remaining on his record or suspension for two semesters with no record of the assault and the option to reapply for admission. He was informed of the right to appeal but was told the Vice Chancellor might increase the punishment and the complainant might file criminal charges. He accepted the two-semester suspension but appealed the decision. The Vice Chancellor upheld the original decision. Doe never reapplied for admission but sued in federal court.
As IHE reported, the case was tried before a jury in Federal Court and found that the institution was negligent in the application of its sexual assault policies. John Doe was awarded damages of lost tuition. Further complicating this case was the fact, revealed during the trial, that the female had medical issues requiring medications to control mood, narcolepsy, and these had been combined with consumption of alcohol at levels higher than she had experienced before. The hearing committee ignored any information about her medical condition and alcohol consumption. The statement she gave to the committee was erroneous because she claimed that she had no alcohol for four hours prior to seeing Doe. The hearing committee had acknowledged that Doe thought the sex was consensual and that the committee lacked information about alcohol consumption and her incapacitated condition. In these cases sometimes, institutions will not consider certain facts in order to protect the victim. Other institutions seem to go out of their way to protect the accused. The difficulty in a “he said – she said” case is finding that balance between both the rights of the alleged victim and the accused. Although I could not find the specific counts of negligence by the University found at trial, there are a number of process issues that appear to have been ignored as the institution seemed to have rushed to get this situation behind them. In this case, it appears not handing the case over to the authorities may have actually been detrimental to the accused student.
In April of 2011, the Assistant Secretary of Civil Rights issued a letter providing guidelines for institutions to follow in enforcing Title IX regulations involving sexual harassment and sexual violence. The statistic on sexual violence are that “1 in 5 women are victims of completed or attempted sexual assault in college” while 6.1% of males are victims of similar sexual violence (p. 2). The letter set out specific guidelines that institutions should follow in assessing their policies and procedures surrounding sexual harassment and assault. The letter describes a grievance procedure that institutions should implement to handle these cases and provides that institutions are allowed to use disciplinary procedures in place of a grievance procedure for cases of sexual violence (p.8). The letter argues that the standard to prove guilt used in Title IX grievances be “the preponderance of evidence” (i.e., it is more likely than not that sexual harassment or violence occurred) (p. 11). OCR objects to the “clear and convincing” language (i.e., it is highly probable or reasonably certain that sexual harassment or violence occurred) (p. 11). I would argue that the “preponderance” standard should be applied where sexual harassment is at issue. However, I would recommend that in cases of sexual violence that the institution’s disciplinary procedures be followed judiciously and the “clear and convincing” standard be applied as proof of guilt. Using this standard will achieve balance of a fundamentally fair and just process that protects the rights of both the victim and the accused.
Sexual assaults involve violations of laws and are considered criminal acts. I realize there is a desire to protect victims when acquaintance rape involves students on college campuses. The result is that, many times, there is a tendency to handle these cases within the institution because either the victim requests confidentiality or the institution bases its decision on the concepts of in loco parentis.As a result no criminal charges are filed. Are we enablers when we insulate students from responsibility for their actions? Many of these cases involve excessive alcohol consumption. Are we enabling excessive alcohol consumption by insulating college students from criminal prosecution for sexual assault? Is the college or university an enclave where the community is a protected environment for experimentation? Is the extension of this rationale what resulted in Penn State’s failure to report alleged sexual abuse to civil authorities? The jury is still out on that question, but perhaps we need to rethink policies were we are handling criminal activity internally instead of reporting it to appropriate authorities. This may be legal but is it fundamentally fair, just and educationally sound? Making distinctions between what is legal and what is fundamentally fair and just may be helpful in leading to educationally sound policy and practice.
I truly appreciate this post.Really thank you! Really Great.
Say, you got a nice blog article. Really Cool.
I loved your article post.Much thanks again. Will read on…
Thanks for sharing, this is a fantastic blog article.Really thank you! Great.
Wow, great blog post.Thanks Again. Awesome.
I really enjoy the article. Will read on…
wow, awesome blog post.Much thanks again. Fantastic.
Great, thanks for sharing this article post. Fantastic.
Thank you ever so for you article post.Really looking forward to read more. Cool.
I really liked your article post.Really looking forward to read more.
Your article gave me a lot of inspiration, I hope you can explain your point of view in more detail, because I have some doubts, thank you.
Really informative article post.Really thank you! Much obliged.
Really informative article post.Much thanks again. Really Great.
Thanks a lot for the blog post.Much thanks again. Cool.
A big thank you for your blog.Really looking forward to read more. Want more.
Thanks for sharing, this is a fantastic blog post.Thanks Again. Really Great.
A big thank you for your blog post.Thanks Again. Awesome.
Thanks again for the blog post.Really looking forward to read more. Want more.
Fantastic blog post. Will read on…
Thanks for the blog post.Really thank you! Great.
Thank you ever so for you post.Really thank you! Will read on…
I really enjoy the article.Much thanks again. Keep writing.
Looking forward to reading more. Great post. Keep writing.
Fantastic article.Thanks Again. Cool.
Thank you ever so for you blog article.Really looking forward to read more. Keep writing.
Im grateful for the blog.Really thank you! Much obliged.
Im obliged for the article post.Thanks Again. Want more.
Thanks a lot for the post.Really thank you!
Im thankful for the blog article.Thanks Again. Fantastic.
I really like and appreciate your blog post.Much thanks again. Keep writing.
I really enjoy the article.Really thank you! Will read on…
A round of applause for your article.Really looking forward to read more. Keep writing.
This is one awesome article post.Much thanks again. Will read on…
Really appreciate you sharing this post.Thanks Again. Really Cool.
I truly appreciate this article.Much thanks again. Want more.
This is one awesome article post. Will read on…
I am so grateful for your blog article. Really Great.
Thanks for the blog post.Really thank you! Much obliged.
A round of applause for your article.Really thank you! Much obliged.
A round of applause for your article post.Really thank you! Awesome.
Major thankies for the article.Thanks Again. Really Cool.
Enjoyed every bit of your article post.Really looking forward to read more. Awesome.
Major thanks for the blog article. Fantastic.
Thanks a lot for the blog. Will read on…
Thanks for sharing, this is a fantastic article.Really looking forward to read more. Want more.
Very neat blog.Really thank you! Will read on…
This is one awesome post.Thanks Again. Will read on…
Really enjoyed this blog article.Really looking forward to read more. Really Cool.
I really like and appreciate your blog post.Much thanks again.
I think this is a real great blog article.Thanks Again. Fantastic.
I truly appreciate this blog article.Much thanks again. Really Great.
Really informative article post.Thanks Again. Much obliged.
I really liked your blog article. Fantastic.
I cannot thank you enough for the article.Really looking forward to read more. Keep writing.
Say, you got a nice blog.Much thanks again. Cool.
A big thank you for your post.Thanks Again. Great.
I really enjoy the blog article. Fantastic.
wow, awesome article.Really thank you! Really Cool.
Thanks-a-mundo for the article post.Thanks Again. Awesome.
I think this is a real great blog post.Really looking forward to read more. Want more.
Very good blog article.Much thanks again. Really Great.
Hey, thanks for the blog article. Want more.
Thanks so much for the article.Thanks Again. Cool.
Great, thanks for sharing this post. Great.
Major thanks for the post.Much thanks again. Really Great.
wow, awesome article.Really looking forward to read more. Will read on…
Appreciate you sharing, great blog.Much thanks again. Cool.
This is one awesome blog post. Fantastic.
I loved your post.Really thank you! Great.
I really liked your post.Thanks Again. Really Cool.
I think this is a real great article. Fantastic.
Really enjoyed this blog post. Fantastic.
Thanks-a-mundo for the blog article.Really looking forward to read more. Awesome.
Very informative blog article.Really thank you! Really Cool.
Really enjoyed this blog article.Much thanks again. Keep writing.
Muchos Gracias for your article post.Thanks Again. Awesome.
I am so grateful for your blog post.Thanks Again. Will read on…
Thank you for your post.Thanks Again. Much obliged.
Gratitude is a quality similar to electricity: it must be produced and discharged and used up in order to exist at all.
I think this is a real great article.Really thank you! Awesome.
Thank you ever so for you article.Really looking forward to read more. Really Cool.
Enjoyed every bit of your article.Really looking forward to read more. Will read on…
I loved your post.Really thank you! Want more.
I really like and appreciate your post.Really thank you! Fantastic.
Great blog.Really looking forward to read more.
I value the blog.Thanks Again. Awesome.
Thank you for your blog.Really looking forward to read more. Great.
A round of applause for your post.Really looking forward to read more. Will read on…
Looking forward to reading more. Great blog post. Want more.
Say, you got a nice blog post. Fantastic.
A big thank you for your article post. Fantastic.
I appreciate you sharing this article.Much thanks again. Want more.
Very neat post.Really thank you! Really Cool.
Thanks-a-mundo for the post. Cool.
Thank you very much for sharing, I learned a lot from your article. Very cool. Thanks. nimabi
I am so grateful for your article post.Thanks Again. Really Cool.
Great, thanks for sharing this blog.Thanks Again. Fantastic.
I really enjoy the blog. Really Great.
I really liked your blog article. Awesome.
Muchos Gracias for your blog.Really looking forward to read more. Want more.
Major thanks for the article.Really thank you! Much obliged.
Thank you for your article.Thanks Again. Really Cool.
Wow, great blog post. Will read on…
Im thankful for the blog.Really looking forward to read more. Want more.
Muchos Gracias for your blog. Much obliged.
I really liked your blog article.Thanks Again. Great.
Very neat article.Really looking forward to read more. Awesome.
I cannot thank you enough for the blog post. Great.
Enjoyed every bit of your post.Much thanks again. Great.
Thanks so much for the blog.Thanks Again. Awesome.
I think this is a real great blog article.Really thank you! Really Cool.
Thanks again for the article.Really looking forward to read more.
I truly appreciate this blog.Thanks Again. Fantastic.
Say, you got a nice blog.Really thank you! Great.
A round of applause for your article post.Really thank you! Great.
Thank you ever so for you post. Really Great.
Really enjoyed this article.Really looking forward to read more. Want more.
Thanks a lot for the blog.Really thank you! Fantastic.
Say, you got a nice blog post.Really looking forward to read more. Want more.
I truly appreciate this blog post.Much thanks again. Want more.
Really enjoyed this blog article.Thanks Again. Great.
Thank you for your blog post.Really looking forward to read more. Want more.
I think this is a real great blog. Fantastic.
I loved your blog.Really looking forward to read more. Awesome.
Appreciate you sharing, great post.Really thank you! Fantastic.
I value the article. Much obliged.
This is one awesome post. Cool.
Muchos Gracias for your blog post.Thanks Again. Want more.
I think this is a real great article.Thanks Again. Great.
Very informative blog.Really thank you! Fantastic.
I really enjoy the article post.Really thank you! Awesome.
Appreciate you sharing, great post.Really thank you! Really Great.
Major thanks for the blog.Much thanks again. Keep writing.
Looking forward to reading more. Great article post.
Very good article.Much thanks again. Will read on…
Wow, great blog article. Great.
wow, awesome blog post.Really looking forward to read more. Really Great.
Say, you got a nice blog.Much thanks again. Cool.
A big thank you for your article post.Thanks Again. Fantastic.
Say, you got a nice blog.Really looking forward to read more. Keep writing.
Thanks so much for the article. Fantastic.
Very good article post.Really looking forward to read more. Cool.
Muchos Gracias for your blog.Much thanks again. Much obliged.
Fantastic blog article. Much obliged.
I am so grateful for your blog. Want more.
Im thankful for the blog post.Thanks Again. Really Cool.
This is one awesome article. Want more.
Thanks so much for the blog post.Really thank you! Great.
Thank you ever so for you blog.Thanks Again. Will read on…
Major thanks for the blog article. Fantastic.
Great blog.Really thank you! Great.
I truly appreciate this blog article. Cool.
Say, you got a nice blog post. Awesome.
Thanks a lot for the post. Fantastic.
Appreciate you sharing, great blog post.Much thanks again. Will read on…
Say, you got a nice blog article.Much thanks again. Really Great.
Really enjoyed this blog article.Much thanks again.
Really informative blog post. Want more.
Major thanks for the blog post.Really looking forward to read more. Really Cool.
I really liked your article post. Keep writing.
Im thankful for the blog post.Thanks Again. Want more.
Really appreciate you sharing this blog post. Awesome.
For the reason that the admin of this site is working no uncertainty very quickly it will be renowned due to its quality contents.stream tsn free
Enjoyed every bit of your article post.Much thanks again. Really Cool.
I really liked your post. Really Cool.
I really like and appreciate your post.Thanks Again. Cool.
I loved your post.Thanks Again. Great.
I value the article.Thanks Again. Really Cool.
Really appreciate you sharing this blog post.Much thanks again. Great.
Hey, thanks for the blog post.Much thanks again. Want more.
I really like and appreciate your article post.Really looking forward to read more. Awesome.
Hey, thanks for the article.Really looking forward to read more. Really Cool.
I appreciate you sharing this article. Really Cool.
Major thanks for the post.Much thanks again. Want more.
Really appreciate you sharing this article post.Really looking forward to read more. Awesome.
Wow, great article post.Much thanks again. Much obliged.
This is one awesome post.Really looking forward to read more. Really Great.
Enjoyed every bit of your blog post.Really thank you! Keep writing.
Appreciate you sharing, great blog. Cool.
Fantastic blog article.Really looking forward to read more. Really Cool.
I really liked your article. Really Great.
Enjoyed every bit of your post.Really thank you! Awesome.
Wow, great post.Much thanks again. Awesome.
I think this is a real great blog.Really looking forward to read more. Fantastic.
Some really excellent info I look forward to the continuation.Live TV
Wow, great article post.
Muchos Gracias for your post.Really thank you! Really Cool.
Really informative blog article.Thanks Again. Great.
I really liked your blog.Really looking forward to read more. Keep writing.
Wow, great blog post.Thanks Again. Really Great.
I am so grateful for your article post.Thanks Again. Much obliged.
wow, awesome article.Really thank you! Much obliged.
I loved your blog article.Really thank you! Much obliged.
Thanks again for the post. Awesome.
Really appreciate you sharing this article post.Really thank you! Fantastic.
A round of applause for your blog post.Really looking forward to read more. Really Great.
Thanks for sharing, this is a fantastic post.Thanks Again. Fantastic.
Great website.ots of useful information here. look forward to the continuation.-vox
Im grateful for the article.Really thank you! Really Great.
Im thankful for the post.Really looking forward to read more. Really Great.
Thanks so much for the blog. Keep writing.
I really liked your blog article.Thanks Again. Will read on…
This is one awesome blog. Will read on…
Great blog post.Really looking forward to read more. Really Great.
I appreciate you sharing this blog article.Really looking forward to read more.
I truly appreciate this article post. Really Great.
I am so grateful for your blog article.Thanks Again. Will read on…
Say, you got a nice article. Fantastic.
Great article post. Really Great.
Great, thanks for sharing this blog.Really looking forward to read more. Want more.
Awesome article.Much thanks again. Will read on…
I am so grateful for your post. Cool.
Wow, great blog post.Thanks Again. Really Cool.
Im grateful for the blog post. Want more.
I appreciate you sharing this blog article. Will read on…
I think this is a real great blog post.Really looking forward to read more. Fantastic.
Major thankies for the post.Much thanks again. Much obliged.
Very informative blog article.Thanks Again. Will read on…
Enjoyed every bit of your blog article. Awesome.
Thank you for great article. look forward to the continuation.Bird Foraging Wall Toy Natural Seagrass Woven Parrot Activity Wall Hanging Hammock Mat Cage Intelligence Chew Toy with Colorful Rattan Balls for Small Parrot Parakeet Conure Cockatoo Budgie Lovebird – Hot Deals
Thanks for the blog. Much obliged.
wow, awesome article post.Really thank you! Really Great.
Im thankful for the blog post.Thanks Again. Want more.
Hey, thanks for the article.Thanks Again. Really Cool.
I really like and appreciate your blog article.Really thank you! Great.
This is one awesome blog post.Really thank you!
I really enjoy the blog.
Im obliged for the article post.Much thanks again. Really Cool.
A big thank you for your blog.Thanks Again. Great.
Thanks again for the post.Really thank you! Cool.
Major thanks for the blog post.Thanks Again. Keep writing.
Really appreciate you sharing this article post. Much obliged.
I truly appreciate this blog article.Really thank you! Really Great.
I loved your article. Much obliged.
This is one awesome blog article.Really looking forward to read more.
Say, you got a nice post. Fantastic.
Thanks so much for the blog article.Thanks Again. Great.
Thank you ever so for you blog post.Much thanks again. Cool.
Im grateful for the post.Much thanks again. Really Cool.
Really appreciate you sharing this post. Awesome.
Thanks a lot for the article. Great.
Thank you ever so for you blog post.Much thanks again. Want more.
Major thankies for the post.Really thank you! Awesome.
Hey, thanks for the blog article.Thanks Again. Much obliged.
I loved your blog.Much thanks again. Will read on…
Major thanks for the article.Much thanks again. Will read on…
I appreciate you sharing this post.Really looking forward to read more. Cool.
Muchos Gracias for your blog article.Much thanks again. Will read on…
Im thankful for the article post.Much thanks again. Great.
Very neat article. Awesome.
Very good article post. Much obliged.
Great post Thank you. look forward to the continuation. – hey dudes for men
I really liked your article post.Really thank you! Great.
I appreciate you sharing this article.Really thank you! Much obliged.
I appreciate you sharing this blog article.Really looking forward to read more. Will read on…
I really enjoy the blog.Much thanks again. Awesome.
Thank you for your blog. Great.
I truly appreciate this article post.Thanks Again. Much obliged.
Hey, thanks for the article. Great.
Enjoyed every bit of your article.Much thanks again. Fantastic.
Thanks for sharing, this is a fantastic post.Thanks Again. Really Cool.
I really liked your article.Thanks Again. Cool.
Thanks for the blog article.Really thank you! Awesome.
Appreciate you sharing, great blog.Really looking forward to read more. Awesome.
Major thanks for the blog.Thanks Again. Fantastic.
A round of applause for your article.Really looking forward to read more. Great.
Really enjoyed this blog article.Really looking forward to read more.
Fantastic article post.Really looking forward to read more. Awesome.
Great blog post.Much thanks again. Want more.
I appreciate you sharing this post.Thanks Again. Really Great.
Wow, great blog.Much thanks again. Cool.
Thank you ever so for you blog.Really looking forward to read more. Really Cool.
I really like and appreciate your blog post.Much thanks again. Really Great.
I truly appreciate this blog article.Thanks Again. Awesome.
Im thankful for the article post.
Thanks for the article post.Really looking forward to read more. Really Great.
Awesome article.Thanks Again. Will read on…
Wow, great blog.Much thanks again. Cool.
Great, thanks for sharing this article. Great.
I loved your article.Really thank you! Really Great.
Great post.Really looking forward to read more.
Major thanks for the blog article. Fantastic.
Thanks-a-mundo for the blog article.Thanks Again. Really Great.
Muchos Gracias for your blog. Awesome.
Awesome blog article.Much thanks again. Will read on…
I appreciate you sharing this blog.Much thanks again. Will read on…
Muchos Gracias for your blog article. Much obliged.
Thanks for the blog article.Thanks Again. Fantastic.
Thanks so much for the article post. Fantastic.
Thanks for the post.Thanks Again. Want more.
Thanks again for the blog article.Much thanks again. Fantastic.
Thanks so much for the blog article.Really looking forward to read more. Cool.
Im obliged for the blog post.Much thanks again. Great.
Thanks again for the article.Really looking forward to read more.
Very neat article. Want more.
wow, awesome article post.Really thank you! Want more.
A big thank you for your blog article.Much thanks again. Want more.
Major thankies for the blog article.Really thank you!
I appreciate you sharing this article post. Fantastic.
Thank you ever so for you post.Really thank you! Awesome.
Enjoyed every bit of your post.Really looking forward to read more.
Thanks-a-mundo for the article post.Really thank you! Will read on…
Thank you ever so for you article post.Thanks Again. Awesome.
A big thank you for your article post.Thanks Again. Really Cool.
Really appreciate you sharing this article.Much thanks again. Cool.
Really appreciate you sharing this article.Really thank you! Cool.
Awesome blog article.Much thanks again. Will read on…
Thank you for your article.Thanks Again.
Very neat blog article. Awesome.
Thanks-a-mundo for the article.Much thanks again. Fantastic.
I truly appreciate this article.Thanks Again. Great.
Very informative blog.Really looking forward to read more. Great.
Im grateful for the article post.Much thanks again. Really Cool.
Really appreciate you sharing this blog article.Thanks Again. Really Great.
Really informative blog post.Really thank you! Awesome.
Im obliged for the article post. Great.
I am so grateful for your article post.Really thank you! Fantastic.
Muchos Gracias for your post.Really looking forward to read more. Keep writing.
Thanks so much for the blog.Much thanks again. Will read on…
I really like and appreciate your blog post.Much thanks again. Really Great.
Appreciate you sharing, great article.Really thank you! Much obliged.
Great, thanks for sharing this blog.Much thanks again. Cool.
I cannot thank you enough for the blog.Much thanks again. Much obliged.
Im grateful for the article.Much thanks again. Keep writing.
Major thanks for the blog article.Much thanks again. Cool.
Appreciate you sharing, great post.Really thank you! Really Cool.
I think this is a real great article post.Thanks Again. Fantastic.
Im thankful for the blog post.Thanks Again. Great.
wow, awesome article.Really looking forward to read more. Awesome.
Fantastic blog.Really thank you! Great.
I cannot thank you enough for the article.Much thanks again. Cool.
Thanks so much for the blog article. Keep writing.
I really like and appreciate your article post.Really thank you! Much obliged.
Enjoyed every bit of your blog. Keep writing.
Fantastic blog article. Keep writing.
This is one awesome blog post. Great.
I am so grateful for your article.Really thank you! Much obliged.
I really liked your blog.Thanks Again. Fantastic.
Thanks for sharing, this is a fantastic blog article.Really thank you! Want more.
Really informative article.Much thanks again. Really Great.
Thanks a lot for the article.Thanks Again. Much obliged.
Excellent article! We will be linking to this particularly great article on our website.
Really enjoyed this article.Really thank you! Really Cool.
I loved your blog article.Really thank you! Much obliged.
Thank you for your article.Much thanks again. Cool.
wow, awesome blog post.Really thank you! Cool.
Thanks-a-mundo for the post.Really thank you! Cool.
Really appreciate you sharing this blog.Really thank you! Will read on…
A big thank you for your post.Really looking forward to read more. Great.
Really informative blog article.Thanks Again.
Looking forward to reading more. Great blog. Keep writing.
Thank you ever so for you blog post. Great.
Really enjoyed this article post.Thanks Again. Really Great.
I value the blog.Really looking forward to read more. Much obliged.
Thanks for the blog. Awesome.
Very good article post.Thanks Again. Great.
wow, awesome blog article.Really looking forward to read more. Cool.
This is one awesome blog post. Fantastic.
Im thankful for the article.Really looking forward to read more. Really Great.
Very informative blog.Much thanks again. Cool.
I value the article.Really thank you! Great.
Hey, thanks for the article post.Really looking forward to read more. Awesome.
Muchos Gracias for your blog article.Really thank you! Fantastic.
Thank you ever so for you blog article.Really looking forward to read more.
A big thank you for your blog post.Really looking forward to read more.