How the Federal Judiciary is Becoming More Anti-Abortion Each Day

**Note: This episode was recorded before the heartbreaking death of Justice Ruth Bader Ginsburg. 

In legislative sessions across the U.S. in the year of 2019, more than 300 anti-abortion bills were introduced and 58 restrictions were enacted. Some of these sexual and reproductive health-related laws will end up in front of the courts, meaning an individual’s right to abortion access in some states ends up in the hands of whatever judges preside in the court. Anisha Singh, Director of Judiciary and Democracy Affairs with Planned Parenthood Action Fund (PPACT), sits down to talk with us about how our courts play a critical role in our sexual and reproductive health and rights.

In order to contextualize the U.S. court system, it is helpful to understand that the federal judiciary system is made up of the district courts, the court of appeals (or circuit courts) and the U.S. Supreme Court. There are approximately 677 authorized judgeships on the 94 district courts, 179 judgeships on the 13 circuit courts, and nine on the Supreme Court. The district court handles approximately 300,000 civil cases and 70,000 criminal cases each year, and the circuit court takes on about 48,000 cases a year.

When it comes to the Trump administration and the current Senate, there is a momentum to ensure conservative-led judgeships throughout the U.S. For example, Senate process has been disregarded in order to get as many conservative judges seated as possible (including getting rid of the blue-slip rule, reducing debate time on federal district court judges, including multiple nominees in the same hearing, and moving quickly so the American Bar Association cannot determine whether nominees are qualified). Trump administration-appointed judges have been appointed at younger ages (meaning they will serve for longer amounts of time), and are mostly white men. It may come as no surprise that these appointees have already tipped three courts of appeals to be an anti-reproductive health majority. Not only do these judges have anti-sexual and reproductive health and rights records, but they have anti-LGBTQ and anti-Affordable Care Act records, as well.

 There are currently 16 cases that are making their way through the system that could potentially impact abortion access in this country. Right now, the Supreme Court is considering a couple of cases-- including whether or not to grant the Trump administration’s request to reinstate an FDA policy that subjects patients to COVID risks in order to access medication abortion during the pandemic and hearing another appeal on the Affordable Care Act.

Links from this episode

Planned Parenthood Action Fund on Twitter
Planned Parenthood Action Fund on Facebook
Crisis In the Courts

Transcript

Jennie: Welcome to RePROs Fight Back, a podcast where we explore all things reproductive health, rights and justice. I'm your host, Jennie Wetter, and I'll be helping you stay informed around issues like birth control, abortion, sex education and LGBTQ issues and much, much more-- giving you the tools you need to take action and fight back. Okay, let's dive in.

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Jennie: Hi, repros, a quick note. Before we start this week's episode, this week's episode was recorded before the devastating loss of Justice Ruth Bader Ginsburg. And I, like many of you, I'm not okay. This is a real devastating loss for our community. She was a real leader in the fight for women's equality, for equality. Overall, her voice is going to be profoundly missed on the court. She has written some really eloquent opinions, some really sharp and pointed dissents. Her voice has been a large one over the years, whether it was when she was arguing in front of the court for equal rights or when she was writing opinions, I'm really heartbroken right now. As many of you are, it's going to be a really big loss for our community, but like many of you, as heartbroken as I am, I am ready to fight as we go forward-- it's going to be hard. It's going to be a long fight, but we're going to stay firm until we have achieved equality and reproductive justice. So this week's episode, we actually talk about how the Trump administration is reshaping the courts. So while we had this conversation before the death of Justice Ginsburg, what we say holds true; it takes on so much more urgency now with her passing and with you all, I'm just as heartbroken. And I'm going to take a little bit to get myself together and then we will be ready to fight back

Jennie: Hi, repros, welcome to this week's episode. I'm your host, Jennie Wetter, and my preferred pronouns are she/her. So this week, unfortunately we need to start with another really heavy and rage-inducing topic. And that is the topic of sterilizations. Hysterectomies are actually happening at an ICE detention facility. We learned about this through an amazing whistleblower Dawn Wooten, who stood up to talk about all of these staggering, egregious human rights violations that are happening in ICE detention. It's more than just the forced hysterectomy. She had several other things listed in her complaint and it all needs to be investigated and we need to get to the bottom of it. But I'm just going to focus on the hysterectomies part. There's been a lot of outrage and you see people talking about how this is an unprecedented violation of human rights, but unfortunately in this country, it's not, there is a very long and very shameful history of reproductive coercion, particularly around Black indigenous and people of color, along with people with disabilities, to have reproductive coercion, whether that is in the form of sterilization or coercion around what type of birth control they're using, or whether to use birth control at all. When you look back to the start of gynecology and the way that Black bodies and Black women were subjected to basically tortures so that doctors could learn more about gynecology, it's all really horrifying, but it's really important that we know the history. If we know it, it's easier to prevent it from happening again, and a really great place to start. Actually, I read it this year, [a book called] Killing the Black Body by Dorothy Roberts. It's a really great book. It's very horrifying because it looks at so many of these reproductive violations. And it's just really important to remember that reproductive rights are a part of human rights. We really need to make sure that we are protecting people's ability to have kids, if they want to not have kids, and how to parent their kids and the way they would like… it is so important that all of this is talked about together.

Jennie: And that's why it's so important that we use a reproductive justice framework when we're talking about these things, because we need to ensure that people not only have access to abortion, but that they also were able to get pregnant if they wanted to get pregnant and that they are able to raise their kids in the safe environment and parent the way they would like… this all works together. So, hearing about what is happening in ICE facilities is rage inducing, and we need to do better. We need to make sure that we are protecting everybody's human rights. And that goes in particular right now for immigrants who are in ICE detention. This is so horrifying. And again, not surprising because we know this long history of where the U.S. has fallen short on human rights, especially around Black women, indigenous women, people of color and people with disabilities. And actually, I'm sorry. I said women for all of those, but it's not just Black women, right? It is people, people who are able to get pregnant. So, it's not a gender binary. It's not just women, it's people. And that's my mistake. We need to do better. And we need to make sure that we are defending those rights and we are calling for a change. So, at some point we may do an episode on the history around this. Let me know if y'all are interested in us having somebody on to talk about that. I think it's really important that people know the history to make sure that it doesn't happen like it is right now. So, since that was so dark and heavy, let's switch tracks and talk about something light and fun. Before we talk about this week's topic--I have kept you all updated on my various baking adventures, and so I have had several things that I've really wanted to try, but I've been too scared and too intimidated to try. And one of those things that has been really high in my list of wanting to try is making English muffins. I have really been wanting to try making them for a long time. And it really was nerve wracking to me because you don't bake them. You cook them on a griddle. So that was so scary. I don't know. It was just really intimidating to me that you're not baking them. You're griddling them. So, anyway, this past weekend, I decided to try my hand at making sourdough English muffins and y'all, they turned out so good. They didn't have really big holes in them like the great nooks and crannies that you kind of love, but they were so pillowy soft and delicious that I will absolutely be making them again. I was so excited. So I'll have to think of what my next new intimidating product is.

Jennie: So now we'll turn to our next heavy topic. And that is talking about how the Trump administration is really changing the federal judiciary. And I was really excited today to talk to Anisha Singh with Planned Parenthood Action Fund, to talk about the ways that you're seeing this. The Trump administration has pointed over 200 judges, and that is really leading to a change in how the federal judiciary is. And that's going to impact so many things. We mostly focus on reproductive rights, but we do talk about other things that are going to be impacted, whether that's healthcare, LGBTQ rights, the list goes on and on and on. So, with that, sit back and enjoy my interview with Anisha.

Jennie: Anisha, thank you for being here today.

Anisha: Thank you so much for having me.

Jennie: So before we get started, do you want to take a second and introduce yourself and include your pronouns?

Anisha: Sure. My name is Anisha Singh. I'm the Director of Judiciary and Democracy Affairs at Planned Parenthood Action Fund. My pronouns are she, her, hers.

Jennie: So before we get too deep into what's happening in the courts, maybe we should take a minute and talk about the federal court system. I feel like people are really familiar with the Supreme Court, but might not be as familiar with the full court structure. So do you want to take a quick minute and talk about the court system?

Anisha: Sure. And first off, I just want to say thank you so much for inviting me to talk about this subject for so long. We've seen conservatives talk about the, and prioritize the courts, whether it's an election year or outside of an election year, and that has yielded great results for them in terms of long-term protecting their own agenda. And so it's critically important that progressives and the general public really just understand why the courts are so important for our everyday lives and how they affect us. And so part of that is understanding how the courts work like you're mentioning, so that we're equipped with that knowledge when we think about the advocacy side of things. And so to answer your question, there's the state courts, and there's the federal courts for this conversation. We're going to talk specifically about the federal courts, because that is where the president and the U.S. Senate have a large role to play. There is a lot at stake in the state courts as well. And we do know that state judges are sometimes picked for federal courts. So that is a worthwhile conversation too. But when it comes to our federal judiciary system, there are basically three main levels. And one is the district courts. That's kind of a trial courts as the first point of entry for a case to go into once appealed. It goes to the court of appeals, which is kind of the intermediate appellate courts, also known as a circuit court. And then there's the U.S. Supreme Court, which as you mentioned, the one that most people know about. There are also other federal courts, such as the court of international trade, federal claims court, all these other courts, but these court rulings sometimes are not as directly impactful to day to day issues and rights. There are around 677 authorized judgeships on the 94 district courts, 179 on the 13 circuit courts, and nine on the Supreme Court. Just to give you an idea of how many judges sit on each of these. And so when it comes to actual caseload, when it comes to the district court level, we have approximately 300,000 civil cases a year in addition to 73,000 criminal cases, which goes to show you just the breadth of how many cases enter our federal court system every year and how critically important the district courts are…

Jennie: Wow I had no idea.

Anisha: Yeah. And a lot of folks pay attention to the Supreme Court, but the Supreme Court actually only takes up 60 to 80 cases per year. So, you have so much of what is decided on everyday life coming from a district court. And then the circuit court has a good chunk of cases too. That's about 48,000 cases a year. And so you'll see that the district court takes up the most. And we saw with the Trump administration, particularly, we have seen a lot of district courts kind of block the administration's executive orders, whether it was the Muslim ban or family separation, many abortion and reproductive healthcare cases that have come through the pipeline. And so just really paints that picture of how important these lower courts really are.

Jennie: Yeah. I think that gives us a really good overview of the background we're talking about. Right? So now that we have an idea of how the system looks, let's talk a little bit about how this looks for sexual and reproductive rights right now.

Anisha: Yeah, that's a really great question. So while the federal courts rule on so many issues important to Americans, reproductive healthcare is particularly at risk due to the attacks on Roe and abortion access by the federal government and state legislators across the country. In 2019, we saw in legislative sessions more than 300 anti-abortion bills introduced and 58 restrictions enacted, nearly half of which were abortion bans. And these cases we know end up going before the courts. And we see that the fate of people's right to abortion access in these states ends up in the hands of these judges. One in three women of reproductive age, live in a state [that is trying] to outlaw abortion. If Roe is overturned, that's over 25 million people who would be denied critical access to safe and legal abortion, it's a lot at stake. And when we look at just the number of bills that were introduced in those state legislators and the number of those bills that are then challenged in the courts, we can see just how critical our federal courts really are for reproductive health and rights. And we know what the agenda has been it's to appoint judges who have a hostile record for healthcare and reproductive healthcare in particular. And so that's why watching what's happening to our courts and paying attention, and then fighting to make sure that some of these anti reproductive healthcare judges are not confirmed as critically important for our work.

Jennie: Yeah. And I know this administration in particular has done a lot. So how has the administration shaped all this?

Anisha: It comes to how they've shaped the courts. This goes before the last three and a half years that Trump has been in office. I mentioned this at the top of this conversation, but the conservatives have had over 50 years of a head start over progressive's in terms of thinking of how to reshape the courts. They're very attentive to it. They find a lot towards it. They have organizations and groups that are dedicated to reshaping the courts. And so what we've seen over time is this kind of transformation, our records to not really speak to the people, but more so speak to corporations. And in particular, we've seen during the last couple of years of the Obama administration, there were over 110 vacancies that were kept open on purpose by a Republican led Senate to make sure that the new president that was elected our now president Trump had the opportunity to fill those seats. So we saw this obstruction happen from day one, just to give you a little color there in president Obama's last two years, the Senate confirmed judges at the slowest rate in more than half a century, including only two circuit judges. And the last circuit judge at the Senate confirmed during Obama's tenure was January 2016. And the last district judge was in July 2016. Just to give you a comparison. We are now in of an election year, just two months out from the election and Mitch McConnell and the Senate Republicans are still confirming judges. So you can see the hypocrisy there a bit. They also refused, if you guys remember it, I'm sure everyone remembers to hold a hearing or vote on judge Merrick Garland, who was president Obama's nominee to the Supreme Court. So that was already some groundwork that they did to make sure that when Trump was in office, he had plenty to work with and plenty of poor packing to do. So then once president Trump was in office, there was no hesitation. Neil Gorsuch was confirmed pretty immediately. We saw them up and sent a tradition of process in order to pack the courts. And that has included things like getting rid of the blue slip rule on circuit court nominations. And just to give some context on what that is, the blue slip is a hundred-year long tradition where home state senators turn in literal blue slips of paper stating whether they approve or disapprove of the nominee. So just to paint a picture, in Pennsylvania, you have Senator Casey and Senator Toomey. One D, one R, one of them could decide not to turn in their blue slip and it would help the nomination process from going forward until that blue slip is either turned in or there's a negotiation that happens to remedy it. So that blue slip rule, which again was a hundred-year long tradition was completely eliminated by this Senate specifically on circuit court nominations.

Jennie: There have been so many norms broken in this Senate that I honestly forgot about that.

Anisha: Yeah. And that's their hope, right? So many changes that have been enacted. We can't keep up with them. There's others. Unfortunately, we also know that they've reduced debate time on federal district court judges from 30 hours down to two hours, which is insane because I don't think I've even said this verbally yet in this call, but these are lifetime appointments. These are all lifetime appointments of district court, circuit court, the Supreme Court-- all lifetime. And so when we're talking about putting folks in for a lifetime, we're reducing debate time from 30 hours to just two for the district courts, which then allows them to confirm district court judges 15 times faster. So there's that as well. There's also having multiple nominees in the same hearing. That's also something that they've started to do so that they could expediate the process as well. And then finally, they have refused to provide time for the American Bar Association to determine whether nominees are qualified to be judges, which then takes away the opportunity to really get that nonpartisan bipartisan rating. And we've seen at least seven now of Trump's nominee’s kind of fall under “unqualified” by the American Bar Association and still be proceeded forward with despite that rating. So that kind of just paints the picture of the kinds of processes that have been broken, the kinds of vacancies that they left open for president Trump to fill. And so their efforts to remake the courts have been really effective for that reason. So we have 24% of judges across our judiciary are now Trump-appointed. That's crazy, right? It's almost a fourth of our entire judiciary has just been completely transformed in a little over three years. And it's 30% of our appellate court judges, which is almost a third of our appeals court have been transformed. And I wish I could say that these are diverse, great nominees, but we can have about the composition of who these individuals are in a moment. But just to give you a comparison again, to what president Obama's situation was in the short three and a half years that Trump has had, which has felt like a lifetime. I know they've already appointed 53 court of appeal judges, president Obama appointed 55 in eight years. So just to give you that comparison of how fast they're making this happen and how quickly they're reshaping and packing our courts.

Jennie: Yeah. It's really breathtaking hearing all of those numbers and thinking about how much he has changed the courts on all of them.

Anisha: That's right. So I wanted to just talk a little bit about what that composition now looks like.

Jennie: I think that's so important, especially cause it's lifetime.

Anisha: Yeah. So these are lifetime appointments. And so they've been very, very strategic. They are the average age of their circuit court. Judge appointments have been less than 50 years old. What does that mean? That means that the amount of time that the judges will serve is longer and that means Trump's legacy and Mitch McConnell's legacy lasts longer on the courts that is completely intentional. And that's a full 10 years younger than the average age of president Obama circuit nominees. So that's something to keep in mind. Approximately 85% of these appointees are white. 76% are men. One of the things that breaks my heart is president Obama had a very, very diverse set of nominees and appointees that he put into the court. And several of his nominees that were pending that Senate majority leader, Mitch McConnell, refused to confirm in Obama's last couple of years of office. Like I talked about earlier, we saw the first Black judge in a certain circuit or the first Hispanic judge in certain circuit. And really just kind of breaking records through and through across our nation. And yet those same nominees have now been replaced by white men who are ultra conservative ideologues on our courts. As I mentioned, seven of these judges were deemed not qualified by the American Bar Association and many, many, many of these nominees hold views that are so, so hostile to reproductive health consistent again with the president's repeated promise to appoint judges who oppose abortion rights and will overturn Roe v. Wade. And so the administration's appointees have already tipped the balance of three court of appeals to an anti-reproductive health majority. And that's the second, third, and eleventh circuits and combined all of the judges that have been appointed by the current administration are expected to give the nation more than 2,600 years of combined judicial service. So just painting that picture of really the makeup in diversity or the lack of diversity and what that has looked like. And we know that the vast majority of the recently appointed judges are members of the conservative Federalist society. And that group has served as a pipeline for young right-winged ideologues to be confirmed to lifetime court seats. So that, again goes to my point previously, which is this has been in the making for quite some time. And now they're just realizing that kind of goal that they've had for quite some time to remake the courts with these young right-wing ideologues who will then solidify their agenda using the judiciary. And one of the reasons for that is they recognize that a lot of their policies and viewpoints are not popular with the public and will not gain traction in Congress. And so having the judiciary locked in step with their agenda helps them block progressive legislation and also solidify conservative legislation.

Jennie: A lot of these judges have extreme views, which some of them were pretty shocking. And unfortunately, I can't remember any good examples off the top of my head, but…

Anisha: I'm happy to give you some.

Jennie: Let's do it. Cause I think to hear how far out of the mainstream these judges are [is important], because they really are,

Anisha: They really are. I'll give you a few examples. So there's Sarah Pitlyk. She's a judge on the U.S. district court for the eastern district of Missouri. She defended Iowa's unconstitutional abortion ban at six weeks, when many women do not even realize they are pregnant. We have Kyle Duncan who was a judge on the fifth circuit court of appeals, which covers states like Texas and Mississippi and Louisiana. He voted twice to ban nearly all abortions in Texas during the pandemic and litigated multiple cases seeking to restrict LGBTQ rights. Another one is Amy Coney Barrett. She is a name that's been floated for Supreme Court vacancy. God forbid that happens, but she is currently a judge on the seventh circuit court of appeals. She has been critical of the framework of Roe. And then there's also Cory Wilson, who was recently confirmed. He supports the complete and immediate reversal of Roe v. Wade. And then a couple of other examples-- Wendy Vitter. She was confirmed for the district court of the eastern district of Louisiana. She moderated an anti-abortion panel where she promoted the baseless claim that women who take contraceptive pills are more likely to die violent deaths. She also encouraged panelists to discuss and push anti-abortion propaganda. And then the final example I do want to highlight is Steven Menashi. And he was confirmed for the second circuit court of appeals. He believes that certain ethnicities make better citizens at a time when white supremacy, as we know, is fueling rising acts of racial violence. He has supported policies that are overwhelmingly racist, sexist, homophobic, Islamophobic, and he has spent his career attacking sexual and reproductive healthcare in similar fashions. As the other examples, I just listed out these judges will carry the viewpoints of this administration and the Senate majority forward for a lifetime.

Jennie: So those are the judges and the judges are only part of this strategy, right? The other part is passing laws and then having those laws challenged in courts to have these judges rule on, right? So what are some of the cases that are coming that we should be paying attention to right now?

Anisha: Yeah, there are 16 cases right now that could impact abortion access in this country and they're making their way through the system and could end up in front of the Supreme Court. We all watched last term when June Medical came before the Supreme Court, despite being identical to the Texas law struck down four years ago, Whole Women's Health. And so we know that those attempts to bring those courts up the chain to the Supreme Court continue. And so we're currently waiting for the Supreme Court to decide on a couple of cases. One is whether or not to grant the Trump administration's request to reinstate an FDA policy that subjects’ patients to COVID risks in order to access safe and legal medicated abortion during the pandemic. But we know that abortion isn't the only thing under attack under this administration. In the Senate, they're coming after all reproductive health and rights… in Trump versus Pennsylvania, we just saw the Supreme Court also rule your boss or your university can deny you access to birth control coverage. And so there are these cases in the pipeline and the state legislators continue to pass these egregious bills that we can expect to continue to be challenged in these courts. And so the fight is yet to be over. And one thing that's critically important is we've already seen this much of a change, this much of a reshaping of our courts to a place where we just can't afford anymore. The number of vacancies have dwindled because of how quickly that they have been able to pack the courts. And as more judges take senior status, as more judges die, these vacancies will continue to pop up. And it really matters who is sitting in the White House, who was sitting in the Senate to determine who those judges are that are going to replace them. Are they going to be reflective of the people that they serve, or are they going to be reflective of the various experience and professional backgrounds that are necessary? Public defenders, advocates in civil service and civil rights? Are they going to be in the pockets of corporations or they going to be adhering to the people? These are all things that we need to be considering because these cases are going to keep coming. And it's not just when it comes to sexual and reproductive rights, right? Again, it's immigrants, it's LGBTQ, it's racial justice. It's so many of the things that we are grappling with as a society today, especially with the veil of a pandemic over us. And so the courts are critically, critically important for all the things we care about. And it's critically important that we make sure we're paying attention and that the people who are appointing these folks are finding the right people that are representing us.

Jennie: Thinking about all the things from this year, right? We had some big victories at the Supreme Court. And I say that definitely with air quotes, because they seemed like really big victories, but you can kind of see these crises looming with them. So, June medical has already been used as the basis in lower courts to uphold some really bad abortion restrictions. And then there's also the worry with all these religious exemptions being used to undercut things like the great decision in not being able to fire employees for being LGBTQ, but you can see in their other rulings around religious exemptions that they're just waiting for a big carve out. So, this really matters in the next couple years.

Anisha: Yeah. And I just want to point out one thing that has not gotten much traction by the media, but it's critically important is there were several voting rights cases that came before the Supreme Court this year in which the justices did not rule in favor of expanding voter access, but instead for voter suppression and in an election year, that is terrifying, right, where we're already seeing attacks to our electoral system, the pandemic raising concerns about are there enough funds for the United States postal service. We're seeing Congress, the Senate particularly blocking any funding to expand voter access. And yet we have the Supreme Court similarly kind of following this administration's agenda for voter suppression as well. So that's really important to point out the voting rights aspect of all of this as well, given that it is 2020.

Jennie: Absolutely. So I think that leads us to where can people go now that they know all of this information? Where can they go to learn more about how the administration is reshaping the court?

Anisha: That's a really great question. Parenthood Federation of America has a great website called crisis in the courts. You can visit it by going to crisisinthecourts.com where you can see how we got here. Basically, everything I've been talking about is outlined there in a very interactive way. Step-by-step, folks can really see how that transformation has happened. They at Planned Parenthood Federation also have a few steps on ways to engage. I would just say, generally speaking, critically important again, to pay attention to what's happening and to call your senators when there is a really egregious nominee on the table right now, as we speak today, the Senate has held a hearing for another nominee. And so they're continuing to do the work all the way up until the election and beyond. So paying attention to who these nominees are, especially if they're going to be representing you in your district or your circuit, calling your senators to express concern. One of the things that stuck with me earlier in my career when I just started out in this work and continues to stick with me is having a conversation with Senators and them saying to me, why should we make courts and judicial nominations a priority when we get so many calls from the opposition and their constituents saying, please do confirm these nominees? Well, we don't get as many calls from progressive saying don't. And so it's critically important that they hear from both sides and it's critically important. Progressive speak up in this moment, especially as these nominees come down the pipe.

Jennie: Well, I think you already hit my last question, which is always what can listeners do? So do you have anything else or I really think those are probably the biggest ones?

Anisha: It's really important to also pay attention to what's happening with this election year. We know that whoever's elected next is going to have the decision to appoint hundreds of more judges to our lower courts, but also the Supreme Court. We can expect that there will be at least a couple of more vacancies there. So there's a lot at stake with this election as well. So yes, make your calls to your Senators as nominees are being put forward right now every day. But let's look at the election as another way to engage and to pay attention to what's happening and what could happen. And let's think about that long game because that's how we actually win. And that's how we make progress and assure that we are protecting all of our rights, including reproductive health and rights.

Jennie: Well, you thank you so much for being here today. It was a real pleasure talking to you.

Anisha: Thank you so much for having me and again, please visit Planned Parenthood Federation's website crisisinthecourts.com and get engaged. The courts are so critically important to everything we care about.

Jennie: Thanks for listening everyone. And we'll see you on our next episode of RePROS Fight Back. For more information, including show notes from this episode and previous episodes, please visit our website at reprosfightback.com. You can also find us on Facebook and Twitter at RePROS Fight Back, or on Instagram at reprosfb. If you like our show, please help others find it by sharing it with your friends and subscribing, rating and reviewing us on iTunes. Thanks for listening.

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