Diligent and compassionate counsel in domestic relations and divorce.

digital workflows — complimentary childcare — 24/7 urgent attention — mediation or litigation


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Offerings

Domestic relations litigation infused with exposure to other complex disciplines.

Schedule Time

Domestic Relations

  • Prenuptial Agreements / Marital Agreements
  • Mediation / Conciliation
  • Divorce / Separate Support
  • Temporary Orders / Alimony
  • Child Support / Child Custody / DCF Hearings
  • Paternity / Co-Parenting / Parenting Coordination
  • Asset Recovery / Asset Division / Inventory Control
  • Separation Agreements / Modification / QDROs
  • Delinquency / Contempt / Enforcement

Litigation

  • Prosecution & Defense in Law / Equity
  • Mediation / Conciliation
  • Complex Case Management
  • Pre-Trial Motions / Discovery
  • Information Architecture & Analytics
  • Trial Preparation & Digital Media Presentation
  • Trial Advocacy & Practice
  • Appeals, Briefing & Appellate Advocacy
  • Policy RND / Legislative Research & History

Kind Words

Affirmation from colleagues and clients.

"Cares individually and provides impeccable legal service — highly recommended.” MA Attorney
”An exemplary combination of acumen, communication and judgment.” Founding Director
”Highly analytical and talented — the best legal writer out there.” MA Attorney
“Shatters expectations and refreshes the whole concept of legal counsel.” Business Development Director
”An example in how to raise the conversation to another level.” Business Owner
”Innate talent for briefing — don't waste your time with anything else.” RI Attorney
”An ace innovator, incredibly responsive, and a consummate professional.” Creative Producer

Select Cases

Access to an expansive portfolio of legal work to inform the particilarities of domestic relations cases.

View Highlights

Development, research and drafting of arguments for principal brief before the U.S. Supreme Court treating constitutional sovereign immunity as applicable to arms of state in admiralty actions

Research, development and drafting of arguments for federal appellate case treating ownership of artifacts recovered from shipwreck Titanic

Drafting of technical production contract for art exhibition in major New York City museum, including extensive protections for highly controversial content

Complex international divorce with substantial offshore assets and conglomerate business interests

Counsel fine artist with piece permanently acquired for lobby of 7 World Trade Center (New York City) on creative independent contractor agreements

Equitable reformation of domestic separation agreement based on mutual mistake and judicial estoppel

Successful regulatory contestation on behalf of charter school blocked from proceeding before the MA Board of Elementary and Secondary Education

Establishment of nonprofit entity managing the theatrical rights of an Academy Award winning film

Successful defense of national and international law firms against claims for malpractice and breaches of fiduciary duties, including research, development and drafting of novel precedent-setting theories won before the Louisiana Supreme Court

Appellate review of substantial tort liabilities for abuse of process and invasion of privacy on multiple grounds

Negotiation and drafting of 20,000 sf commercial lease in Brooklyn NY

Development and drafting of arguments for disposition of $250M in property casualty proceeds due on losses caused by Hurricane Katrina

Injunctive relief for employer under non-disclosure agreement with former employee asserting counterclaims for discrimination and wrongful termination

Six-figure settlement of medical negligence action against largest healthcare provider in a New England jurisdiction

Drafting of profit-sharing compensation agreement for company executives, including designing formulaic computations drawing on the IRC

Research, development and drafting of arguments for constitutional litigation treating public teachers’ union contract renewal during fiscal crisis

Representation of municipality in construction litigation, including discovery, depositions, and pre-trial motions leading to favorable settlement

Drafting of public employment legislation for state senate finance committee

Drafting of federal appellate brief on constitutional issues attendant to Department of Labor rulings and conflicting workers’ comp precedents

Research and draft successful motion to dismiss retrocessionaire in Department of Labor workers’ comp suit involving insolvent reinsurer and state guaranty entity

Preparation of memorandum on liabilities for effects of fracking in PA under federal and state law for national public interest group, including significant on-site document review, retention and analysis

Drafting of non-profit executive compensation protocols and policies that comply with IRS regulatory requirements

Establishment, governance and dissolution of MA, RI, NY, and DE LLCs and corporations, including operating agreements, bylaws, meetings, resolutions, elections/appointments, fiduciary counsel, foreign authorizations, publication requirements, annual reporting, franchise taxation, registered agency, investment/capitalization, distributions, stock transfers, maintenance of corporate veil, dissolution, etc.

Obtaining of permission from the MA Division of Banks to use of the prohibited word “trust” in a newly established corporate entity

Sexual harassment investigations and company-wide interviews in hostile work environment case that was favorably settled

Successful interpleader on behalf of insurer divesting itself of proceeds disputed among three parties and an attorney

Negotiation and drafting of licensing agreement with a major media production company and Fortune 10 subsidiary

Defense of specific performance action concerning conveyance and financing of commercial real estate, including prosecution of counterclaims for fraud, stringing, slander of title, and abuse of process

Monitoring of water testing on behalf of client sued for toxic leaching across commercial property lines, and successful motion in limine for suppression of improperly obtained evidence

Corporate nonprofit start-up qualification, documentation and drafting, including IRS 1023, document retention, conflict of interest, and whistleblower policies

Settlement negotiation and drafting of agreements for bad educational and revolving credit debts for individual vis-à-vis university and collection agency

Construction litigation discovery and defense related to failure of hotel fixtures

Counseling to public school on applicability of constitutional search and seizure law for the institution of a breathalyzer test at school functions

Opinion letter drafting for industry-pooled self-insurance organization on regulatory status vis-à-vis state insurance department

Trust reformation to segregate benefits owed to disabled sibling from benefits owed to other siblings, including qualification for state benefits

Drafting of Fifth Amendment right to remain silent analysis in police officer misconduct investigation

Research and development of memorandum of understanding for federally protected information sharing between municipal agencies

Workers’ compensation representation for reinsurer, including imposition of discovery by physical examination

Consolidation of federal discrimination actions on behalf of private corporation operating nationally

Civil suit prosecution and settlement on claim for redhibition (civil law implied warranty) concerning fraud in a real estate transaction

Drafting of opinion letter treating implied accord and satisfaction under CA law for corporate client seeking large recovery from insurer

Drafting of pre-eviction notices and eviction process management and trials public (federally financed) real estate clients

Representation of city in union ERISA withdrawal litigation, including drafting of complaint for declaratory and injunctive relief

Defense of state legal agency in employment discrimination matter concerning age and association, with extensive e-discovery utilizing custom coded metadata queries

Pre-trial litigation concerning six consolidated cases on municipal land licensing, including dismissal of pending appeals and coordinated catalog of motions in limine, and drafting of settlement agreement for the resolution of all interconnected matters

Successful prosecution of G.L. c. 93A contract dispute under theories of agency and quantum meruit, and a newly devised theory of stringing

Successful prosecution of loss recovery litigation on behalf of online equipment rental company, including design of master loss recovery file for integration with backend web platform to enable efficient extraction of determinative data

Successful defense of creative studio in personal injury suit through liquidation of claim and shift of coverage pursuit to plaintiff via arbitration, and coordinate stipulation of dismissal with prejudice

Develop G.L. c. 61A roadmap on conversion of agricultural land for development in conjunction with strategic procedural approach derived from financial counsel

Prosecution of G.L. c. 40B appeal of comprehensive permit, including leading and defending depositions of developers and public officials, drafting and coordinating discovery program, procuring expert materials, pre-trial motion practice, drafting project settlement agreement, and analysis of agency discretion and interlocking state/local regulatory standards and processes

Mediation & Conciliation

Alternative means of dispute resolution to break through issues.

  Intake

Key documents and memoranda are provided to inform our participation in the process. We study matters to ascertain context, positions and needs. We set timetables for analysis, discussion, expert involvement, drafting, review, and implementation.

  Process

Our services are provided as an alternative to litigation, or layered on top of litigation. The process is voluntary, informed, confidential, and benefits from the inclusion of a neutral. Special and powerful communication strategies are utilized to isolate issues.

  Outcomes

Together with the parties and/or their attorneys, we move the needle with interest-based resolutions and the assistance of specialized experts to the extent warranted. The parties thereby maintain efficient ownership and control over outcomes.

  Implementation

Upon resolution, private agreements are drafted and court papers are prepared. The groundwork to call on our practice as an ongoing resource is laid through the establishment of a knowledge base and open lines of communication.

Justin DuClos

My take on my path.

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State of the art in the art of the state — I entered law school following 9/11/01, clerked for now Justice Gilbert V. Indeglia of the Rhode Island Supreme Court, earned a JD from Emory University, and, until returning to academia at Harvard University, practiced with firms handling cases of public import. I am licensed in MA, RI, CT, NY, and LA. I am an active member of the Plymouth and Barnstable County Bar Associations, as well as the American, Massachusetts and Boston Bar Associations.

I began my practice briefing the U.S. Supreme Court and U.S. Courts of Appeals. I worked up appeals with scholar and advocate David J. Bederman, renowned specialist in matters constitutional and international. I have since been leading complex cases in multiple jurisdictions and across subjects — including domestic relations, trust/estate/probate, real estate, professional liability, municipal/legislative, constitutional, international, intellectual property, construction, regulatory/administrative, corporate and commercial, labor/employment, environmental, maritime, insurance, education, nonprofit, and tax.

I took the first opportunity I had out of law school to get involved in public affairs: I moved to New Orleans after Hurricane Katrina to litigate the flood and levee cases. There, I superintended an array of matters proceeding through governmental systems disrupted to their cores, including representation of the Louisiana Recovery School District in its bid to take over Orleans Parish schools. There was no shortage of civic issues to shepherd, some of which bore directly on civil rights.

I returned to New England to attend Harvard University, where I earned an additional degree in Policy and Management, was a fellow at the Center for State and Local Government and the Program on Education Policy and Governance, as well as a Zuckerman Fellow at the Center for Public Leadership, and where I published a scholarly account of democratic malfunction. I also joined a Harvard Law School clinic as a teaching/practicing attorney, continued publishing on public policy, and finally took a residential position at Harvard College (Cabot House) before exiting the university and signing on as the director of legal studies at Cape Cod Community College in 2013 to make a difference in the lives of those facing inordinate challenges to their professional progress.

After moving my residence to Duxbury on the South Shore of Massachusetts, I also relocated my practice there to incorporate regional family cases into my portfolio. After practicing in a variety of environments and disciplines, I found the pivotal and highly interpersonal nature of domestic relations to be a vocational addition to my litigation practice. I am a qualified neutral mediator and conciliator in conformance with G.L. c. 233, §23C, and a member of the Massachusetts Council on Family Mediation. In the course of developing this area of practice, I researched and wrote an historical novel about a young man caught between political and familial priorities in 1960s South Africa, including detailed treatment of the customary laws of domestic relations of the isiXhosa people. My work with families also draws on my experience in education, which is centered on student growth and development.

While I most often tackle matters in accordance with existing law, I appreciate stewarding issues the law does not yet reach, either because they are rapidly developing or inadequately addressed by demonstrably preferential policy, or because there is demand for a predictive application of law to emerging technology.

Writing Samples

Examples of work product from diverse matters set in a variety of contexts.

Appellate

SHIPWRECK TITANIC ARTIFACTS

Finding the Titanic was a major technological effort and investment. What incentive do salvors have to go all in on such risks? The public benefits from the archeological recovery of lore. Individual careers can be made, too. But is it enough? When the exclusive salvor in possession of the Titanic shipwreck came up with artifacts technically abandoned under age-old maritime and property doctrines, it expected to recoup its investment. A skein of conflicting property law concepts in the common, international and constitutional domains came into relevance. The matter was resolved before a U.S. Circuit Court of Appeals.

I was on a small briefing team that researched and drafted the position of ownership. My work was documented in a Journal of Maritime Law and Commerce piece titled A Conceptual Wreck: Salvaging the Law of Finds. That article was dubbed the last word on the distinction between the laws of finds and salvage by the journal’s editors.

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Appellate

CONSTITUTIONAL SOVEREIGN IMMUNITY

Chatham County, Georgia, home to Savannah, was sued in a bridge allision. Admiralty jurisdiction — constitutional from inception — is historical, complex and recondite. Intersect the ancient jurisdictional issue with sovereign immunity and modern municipal governance, and a case before the United States Supreme Court was born, Northern Insurance Company of New York v. Chatham County, Georgia, 547 U.S. 189 (2006). I was on a small team that provided deep pre-colonial research and technical writing in the admiralty lexicon for the principal brief.

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Appellate

ATTORNEY FIDUCIARY DUTIES

The fiduciary duties built into the attorney-client relationship are traced back far into recorded history. They continued to develop consistently under the reigns of kings, through the American colonial transfer of legal regimes, and into the 21st c. when a new facet was revealed. What duties do co-counselors owe each other when collaborating on behalf of a client? The opinion of the Louisiana Supreme Court rendered on this issue as it swept across the states in 2007 derives virtually wholesale from the brief to which my research and writing were central, including citation to the Bible at footnote 5 to highlight the governing principle that an attorney can have but one master: the client.

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Environment

THE HURRICANE KATRINA CASES

In the years after Hurricane Katrina, the New Orleans community carried on, but not without a comprehensive collection of distractions. The vestiges of destruction went on for miles. Basic services were scarce. Wind and water scars cut far inland. Water pressure was intermittent, as was power. The metropolitan infrastructure was unmanned. Half the population had not returned. The most violent crimes were at an impossible high. The United States military was permanently stationed downtown. The economy recessed. Skyscrapers laid vacant.

My office was on the 33rd floor of the Energy Centre — floor-to-ceiling windows overlooking the Mississippi, Brazilian hardwoods, Italian marble, and a spiral staircase wound through the floor to a law library worthy of an ABA accredited law school — but I’d step up to the brass faucets, turn the tap, and out would shoot air. It was an apt metaphor for the whole shebang. A crippled government struggled to instill confidence. At the time, and even in retrospect, the list of problems and failures was endless.

I moved to New Orleans to participate in those national civic affairs, and worked fallout cases: the enormous levee, flood and environmental catastrophes; state takeover of the Orleans Parish schools; and a broad array of matters proceeding through governmental systems disrupted to their cores.

Many moments stay with me, but one in particular sums up the experience. I had read the story of how the flood came to be in the levee failure complaint, which landed on my desk. Dozens of plaintiffs’ pages recounted the scientific history and all the warning signs. Straight-line canals were dug to shortcut the shipping distance between the Gulf and New Orleans, rather than winding up the Mississippi. The sediment under those wetlands was fine and soft, and it’d fall in on itself from the sides and fill up the canals again, making them too shallow for ships to pass. The dredging would repeat, as would the cycle, which would widen the canals, not just deepen them. When Katrina blew in running at a dead angle south to north, the biblical storm surge charged up the canals (“superhighways”, as they were dubbed) and either overtopped or simply shattered the levees.

A few months after my educational read, I was sitting in a deposition in another tower on Poydras — it was a resident of the Lower 9th telling it from his vantage, where lives were swept away in an instant. The question was, “What did it sound like?” He testified among a cadre of lawyers holding bated breath around a mahogany table, “Like a crack of thunder, then a jet plane. Water started in under the doors and poured over the windowsills.”

View a motion I prepared for the consolidated dredging actions, which proceeded in admiralty. Most do not know it, but much Hurricane Katrina litigation proceeded that way, in admiralty. I maintain a deep respect for the admiralty bar and maritime practice.

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Environment

BLUE MIND 3

Blue Mind 3 was the third iteration of an annual convening of ocean experts and neuroscientists founded by Wallace J. Nichols. Mind and ocean; neuroscience and conservation; emotion and environment; grey matter and blue space. Watch a video summation here. The event was held from May 29 to May 31, 2013 on Block Island. I was a partner, assisting with development, logistics, media, and programming. I also opened the weekend with Rhode Island’s state poet laureate Lisa Starr (2007-2012), using original underwater imagery obtained from sites on- and offshore during dives with Tampa’s photographer laureate Karen Glaser, exhibitor at the Smithsonian National Museum of Natural History, and author of the grainy Dark Sharks series. Presentations followed from filmmaker and granddaughter of Jacques Cousteau (Celine Cousteau), chef and National Graphic fellow Barton Seaver, mesmerizing painter and client Ran Ortner, and a host of neuroscientists from Harvard, NYU, and Vanderbilt, who paired up with entrepreneurs, elected officials and creatives from a dozen organizations and agencies to explore new questions about our connection to water.

Media

NEW MEDIA PROTECTIONS

There are stakes in art. Visual media are often the most powerful instances of information and influence. As with every Whitney Annual and Biennial, the 77th of these in the museum’s history (begun in 1932 by Gertrude Vanderbilt Whitney) would be no exception to offering one of the broadest and most diverse takes on art in the United States. It brought together 103 artists and three curators — Stuart Comer of MoMA, Anthony Elms of the Institute of Contemporary Art in Philadelphia, and Michelle Grabner of the School of the Art Institute in Chicago.

To make this exhibition possible, I developed special media protections on behalf of Navia Vision, including medium-aware indemnities accounting for controversial content. This was the last Biennial to take place at the Whitney’s Madison Avenue building. In 2015, the museum celebrated its new downtown waterfront locale.

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Media

NON-PROFIT RIGHTS TO ACADEMY AWARD WINNING FILM

New Orleans gets its character from a few sources, like the lay of swamps, rivers and mud. But its people are the true prize. One of them is Sister Helen Prejean, who has been fighting the death penalty for decades. She writes best-selling books about her work, which include several compelling case studies. Her mission is charitable in nature, so when I was asked to establish the nonprofit media entity holding rights to the Academy Award winning Dead Man Walking for her group of advocates, I gladly undertook the work pro deo.

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Media

CORPORATE GROWTH & ADMINISTRATION

Chemistry Creative, Inc. is the neoteric kingpin in visionary design and media production. This gifted outfit from Brooklyn is at a nucleus of inventive energy, but the reach of its operation and imagination is limitless — for example, it unfurls elaborately fabricated and timed campaigns that roll out synchronously in multiple metropolises on a global scale, beautifully, and at the height of technical competence. From cinematography and environmental design, to audio engineering and astonishing events, the all-star troupe infuses its clients’ businesses with the extraordinary artistic verve emanating from New York City. Its clientele includes HBO, American Express and Def Jam.

Chem asked me to furnish corporate development, administration and governance so that company growth could be received and channeled. I did that, and also developed intellectual property compacts and licenses to splice joint ventures, negotiated and composed leases on large commercial spaces in the city, and devised intricate compensation agreements that rewarded the aces who bring Chem’s magic to life.

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Government

FEDERAL CAMPAIGN ADMINISTRATION

California’s special election to vote up a successor to Rep. Xavier Becerra proved extraordinarily competitive. When Rep. Becerra was appointed Attorney General of California, dozens of candidates filed for presence on the federal congressional ballot. The 34th Congressional district is exceptionally influential for its representation of major constituencies encompassed within the United States’ second most populous city, notably Koreatown and the financial and arts quarters. I lent top-to-bottom campaign administration to Dr. Jason Ahn, a remarkably selfless and grounded public servant with a strong record of domestic and international humanitarian work on fundamental issues, like superior healthcare, disaster response and family reunification. The project comprised administrative compliance — including financial/treasury activities — at the county and state levels, as well as at the federal level with the Federal Election Commission and Internal Revenue Service. The rapidity with which a federal special election campaign must develop also required small-team attention to details that reached media, research, staff, events, communication, and design — for example, the campaign logo was procured from the talented Matt Player of Sydney.

Ultimately, Dr. Ahn chose to support Robert Ahn, an attorney, a Planning Commissioner for the City of Los Angeles, the only other Korean American in the race, and the eventual run-off candidate who faced Jimmy Gomez in the final contest.

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Government

PUBLIC LABOR & FINANCE

Teachers’ unions continue to play a significant role in both the labor and education sectors. In 2008, during the depths of global economic recession, the expiration of a Rhode Island teachers’ union contract seized a school system. The law in this space is taut, and a municipality caught between revenue shortfalls and perpetual contracts sought slack. I researched the history of applicable constructs and policies, and drafted the foundational positions that freed the municipality from additional obligations. This analysis led to a commission from the Harvard Kennedy School of Government, the Taubman Center for State and Local Government, and the Program on Education Policy and Governance, to document the event in a piece titled The Etiology of a Malfunction in Democratic Processes, which was published in the Arizona State Law Journal.

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Tech

GITHUB FOR LAWYERS — CONCEPTUAL

GitHub for Lawyers is a piece I wrote in 2013 about how legal drafting is procedurally and logistically consistent with software code drafting, and that the most popular tools used by developers for version control (Git) could just as well be put to use by those desiring to manage a legal drafting project. This article rose into the top 10 of Hacker News, driving tens of thousands of reads in one 24 hr period. In particular, I struck a note on public participation in the legislative process.

Our current model for representation by Congress and the Senate (and state replications) is exactly that model deployed when our federation barely broke the teens in number, was concentrated on the eastern seaboard still distant from even the Mississippi River, was populated by something like 1/50 the population represented coast-to-coast and Alaska/Hawaii today, and when transportation technology consisted of horse and saddle, or waterfaring steam vessel — not even train. There were then good reasons for representative bodies — it was a convenience, if not a necessity of federal governmental management. But each of those reasons has lapsed. So why not encourage citizens to compete with lobbyists, to form their own groups, to draft legislation using version control tools, and to advance causes through bill-drafting efforts? Do not ever be fooled into believing power does not ultimately rest in your hands — perhaps more now than ever before, it truly does.

GitLaw is a platform for collaboratively drafting, committing and pushing legislation — essentially GitHub for lawmaking. Individuals (or groups) initiate legislative proposals, and the community revises them, or forks and revises them, tracking all changes asynchronously. Legislation is categorized by community and/or issue and/or organization (e.g., ride-sharing, or New York, or the National Institute for Trial Advocacy). When a proposal is fully committed and ready for deployment, it is pushed directly to the representative empowered to sponsor and advance the legislation in the relevant congressional environment (local, regional or national).

Internal democratic processes within the platform highlight legislation with particularly strong viability, in a form of pre-voting and constituency polling. Actual legislative outcomes are tracked, logged and visually depicted. The legislative side of the platform is provided pro bono; the platform is supported by paid accounts owned by lawyers and organizations wishing to negotiate/draft/revise legal documents in tandem with other lawyers and organizations. GitLaw is a decentralized collaborative lawmaking platform for logistically airtight direct democracy.

Tech

NON-PROFIT FINANCIAL APP — CONCEPTUAL

Cashcare was conceptually born when, in the process of considering a non-profit post-secondary education directorship, I was asked to design a program for scaling financial health outreach work. Instead of laying things out in a word processor, I took to my code editor. I designed an application and built a website to showcase it, with an associated write-up.

My suggestion was to evolve the program to a digital platform by rolling out a Cashcare application owned by a non-profit organization comprised of a bank consortium. This would have the effect of streamlining the effort — both instructionally and actionably. The many possible features such an application might offer to mitigate impediments to program goals took several shapes: harnessing limited self-control through gamification; increasing control through customization; satisfying control through information; reducing time commitment and cognitive overload through convenience and simplicity; and providing comprehensive advice and instruction through trusted in-app support.

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Writing

FOREIGN LEGAL RESEARCH & WRITING

Jong’lwazi is a novel about the maturation of a young man navigating political schism in his rural South African village circa 1960s; when apartheid most acutely took root; when his region was being carved out of the Union-cum-Republic for a new sovereignty premised on lingo-ethnic genealogy; and when certain processes of democracy were novel if not indigenous. There manifests a parochial dispute over the failure of primogeniture (chiefdom of Mthonjana) that is of political value to the urban power vacuum (based in Mthatha), which is under competing pressures from a national tide (reconstituted as the Republic of South Africa) and international opposition (concentrated in the U.N.). The wayfaring young man is swept into these hierarchies through an illicit relation with the daughter of a parochial disputant of imperfect stature. But his development is more than civic. While endeavoring to unearth the material resources required to bring his infant daughter into his lineage, he is visited with experiences that evoke fragmentary memories of his father, who he incrementally learns was a dualist — a traditional healer skilled with medicinal herbs, and a mystical Christian novitiate who sought to harmonize faiths on a scientific plane. His multilayered pilgrimage is recounted by means of a lengthy correspondence addressed to a Native American who had visited Transkei at a pivotal juncture fifty years prior to the date the composition begins — and through it, and the involvement of a surrounding ensemble, an ethnographic account of a little-known but hugely important time, place and people is assembled. The resulting story grips as much as it elicits.

The creation of this work was a twenty-year project. The text addresses, crosses and compares topics spanning economics and labor, religion and spirituality, race and gender, government and democracy, love and parenthood, and the environment and medicine. At heart, it is a work of preservation — for amaXhosa and amaBomvana, and isiXhosa generally. Relative to the voluminous annals of literature published in the Indo-European language family, there exist very few texts published in a Bantu language, thus even fewer in a Nguni language, such as isiXhosa. Coordinately, there are relatively very few novel-length stories written about amaXhosa, and again thus even fewer about amaBomvana.

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