At this stage, he argued that takeovers did not present a direct conflict of interest requiring the recusal of the management directorsespecially given that he was writing before the advent of management buy-outsbut he referred frequently to the independent directors and ensuring that they had financial and legal advice independent of management, and that the board as a whole, and not management in isolation, was the instrument that would determine how the company reacted to the takeover offer. at 105.24Lipton, 35 Bus. 101 (1979), was a ground-breaking statement of the case for takeover defense by target company boards of directors. L. Rev. Rabbi Ronald Sobel officiated. In fact, before Lipton developed guidance for takeover targets, he developed a checklist for those making a hostile tender offer for control. at 858.49Gilson, 33 Stan. Martin Lipton & Erica H. Steinberger, Cash Tender Offers, in Takeovers & Takeouts 9, 9-107 (1976); see also Martin Lipton & Erica H. Steinberger, Introduction, 23 N.Y. L. Sch. Under the City Takeover Code (which was not even official government policy but which all participants in the U.K. adhered to). Decades ago, no one bought milk at the store. Martin Lipton (LAW '55) is a founding partner of Wachtell, Lipton, Rosen & Katz and specializes in advising major corporations on mergers and acquisitions and matters affecting corporate policy and strategy. In 1982 Lipton created the Shareholder rights plan or poison pill, which has been described by Ronald Gilson of the Columbia and Stanford Law Schools as "the most important innovation in corporate law since Samuel Calvin Tate Dodd invented the trust for John D. Rockefeller and Standard Oil in 1879. at 876.51Gilson, 33 Stan. As Lipton warned in Takeover Bids, if corporate boards faced the constant possibility of being forced to sell, it disrupted their ability to invest and implement business plans focusing on sustainable, socially responsible growth. Over a nine-month period in 1974, Wachtell Lipton successfully represented Loews Corporation in its tender offer for CNA, establishing the firm in the takeover arena. Mr. Lipton is an Emeritus Chairman of Prep for Prep, having served as Chairman from 1990 to 2002. at 1201.38Easterbrook & Fischel, 94 Harv. L. Rev. L. Rev. Lu June 16, 2022 Recent high profile investigations into greenwashing, the ongoing war in Ukraine and soaring energy costs have prompted questions as to the purpose and value of ESG, and more broadly, stakeholder capitalism. For Harold it was not about money. [3] While at NYU Law School, Lipton joined Rosen and Katz, as well as Herbert Wachtell, to form Wachtell, Lipton, Rosen & Katz in 1965. He said he considers the poison pill to be the most significant piece of corporate legal artistry in the 20th century. But we gave an opinion, an absolute opinion. Martin Lipton is Chairman of the Board of Trustees of New York University, a trustee and former Chairman of the Board of the New York University School of Law, a member of the Council of the American Law Institute, and a director of the Institute of Judicial Administration. Even if there were no empirical evidence that refuted the argument that shareholders almost always benefit from a takeover (as noted below, the empirical evidence is to the contrary) and even if there were no real evidence, but only suspicion, that proscribing the ability of companies to defend against takeovers would adversely affect long-term planning and thereby jeopardize the economy, the policy considerations in favor of not jeopardizing the economy are so strong that not even a remote risk is acceptable.23. Dinners solution became Clarifi, a software platform that helps students stay focused by locking down their desktops, breaking work into 25-minute chunks, and gamifying homework, with rewards and power-ups for accomplishing tasks. Building on their NYU affiliations, the firm recruited other talented NYU graduates and faculty, and it encouraged its lawyers to engage in law school teaching and publishing. Trustee Brearley School, 1991-2005, Wildlife Conservation Society, 1991-2005. Detoxyfi was a runner-up in Venture Labs 2022 Startup Challenge and winner of the 2022 Jacobson Social Impact Prize. 358, 360 (1973-1974) (review of a book on tender offers in which Lipton refers to decisions under the Williams Act that have made it an almost impossible barrier to contested takeovers. This article also refers to one member of the New York Bar who has become so renowned for his successful defense against takeovers that the first question on Wall Street is which side has him. Lipton, Recent Books, at 360. According to a 2022 NPR study, 62 percent of Americans use voice assistants regularly. Even under the most far-reaching of the state takeover statutes, no tender offer has been blocked on the question of price. Daughter of Samuel 'Schmul' Cohen / Katz / Cohen Tzedek Katz and Chana Lea Ratnowski / Rolnoski / Berestizky Katz Wife of Simon Lipton Mother of Martha Lipton; Seymour Lipton; Leon Lipton and Martin Lipton . Location. Lipton served for two years as Judge Edward Weinfelds clerk before joining the Seligson, Morris & Neuburger firm, where his law school friends Len Rosen and George Katz already had jobs. So Sanju Pancholi WG12 used his technical background in conversational AI to create Vurbalize, a voice shopping assistant thats like a personal shopper in your pocket. . The CEO of McGraw-Hill, and descendant of the founders, Harold McGraw, begged Lipton to defend his company against a hostile bid from American Express. As Wachtell Lipton became intensively involved in coming up with creative techniques for addressing legally novel situations, the firm viewed it as unwise to take on matters where loyalty to the bidder-client might require arguing that actions the firm had recommended might be invalid under statute or be found a breach of fiduciary duty. Lipton found that he enjoyed being able to practice law and teach law, and decided to eschew a full-time career in academia to become a partner at the Seligson firm, while continuing to teach at NYU. [6] In October 2015, Lipton retired as Chairman when his term ended. Takeover bids are not so different from other major business decisions as to warrant a unique sterilization of the directors in favor of direct action by the shareholders. The New York Times, when highlighting the accomplishments of Lipton, maintains, While shareholder gadflies have criticized Mr. Lipton for being an apologist for corporate management, that assertion misses the point that Mr. Liptons fiduciary responsibility is to best represent and advocate in support of his clients interests. And on that notion, Mr. Lipton leaves little room for objection. I thought what Id really like to be is a lawyer.2 Intrigued by the law, Lipton put in a late application to the then emerging School of Law at New York University, in part because its recent Dean had been Arthur T. Vanderbilt, who had become the Chief Justice of Liptons home state, New Jersey.3. His father is a vice president at Sterling National Bank in New York. Now, AptDeco is expanding with its launch of national shipping and is the only end-to-end marketplace that accepts all kinds of furniture resale items, from futons to rugs to floor lamps. Martin Lipton, a founding partner of Wachtell, Lipton, Rosen & Katz, specializes in advising major corporations on mergers and acquisitions and matters affecting corporate policy and strategy. Anyone can read what you share. L. Rev. 3Slater, Partner for Life, at 30. Law. More details The decisions are uniform that where there is a cash tender offer, the state will not determine what is a fair premium but will leave that determination to the shareholders. Adolf Berle (1895 1971) gives a speech at the Waldorf Astoria in New York City, circa 1950. Membership. 1733 (1981).43Easterbrook & Fischel, 36 Bus. Lipton also had recurring roles on such shows as Popular, Alias and Crash. [6], In 1975, Lipton represented New York City in several financial transactions, including a temporary $2.5 billion U.S. Government loan, the rollover of the then short-term City debt held by banks and the placement of $500 million of City bonds with City pension funds, that resolved the two-year financial crisis and saved the City from bankruptcy. Law. Martin Lipton is a founding partner of the law firm of Wachtell, Lipton, Rosen & Katz specializing in advising on mergers and acquisitions and matters affecting corporate policy and strategy. During that period, developments at the Securities Exchange Commission, and in securities law in general, were at the forefront for lawyers working internally at large, public companies. Part of Venture Labs VIP-X Fall 2022 cohort, Vurbalize is built to function with any device, any language, any channel.. 1017 (Apr. at 1734-35, 1736, 1737.44Easterbrook & Fischel, 36 Bus. Most of the academic writing up to that point was that this was something the shareholders should decide, not management, not the board of directors. Trustee Jewish Museum, since 1986, chairman, 2002-2004. Litigators, Trials 5 Litigation Lessons From Joe Jamail's Trial Strategy In. During his time at the Seligson firm, J. Lincoln Pud Morris took a special interest in Lipton, and Lipton worked closely with Morris on complex corporate and securities matters. YOU HAVE 10,000 FOLLOWERS: As of May 2022, AboveBoard had raised $6 million in seed funding and reported 30,000 approved members and 1,300 companies using the website. Essentially what we are talking about is if the management of a corporation is not doing a good job, the company is under valued at the market or the assets of the company are not being profitably employed, the company becomes vulnerable to takeover by tender offer [I]t is quite obvious from the current popularity of cash tender offers that this is a means of acquisition of control of other companies that is acceptable.). Law. And as an important practical matter, the article served to encourage courts to embrace its arguments, and create a body of case law that followed it and could be used to defend takeover targets. [27], Lipton served as counsel to the New York Stock Exchange Committee on Market Structure, Governance and Ownership (19992000), as counsel to, and member of, its Committee on Corporate Accountability and Listing Standards Corporate Governance (2002) and as Chairman of its Legal Advisory Committee (20022004). [2] Lipton received his a B.S. The additional leading commentary during the interim included: After Takeover Bids in the Targets Boardroom, Lipton and Wachtell Lipton found themselves literally on the defense. Growing up with ADHD, Bryan Dinner L22 WG22 had a reliable repertoire of study hacks: work with a buddy, chunk projects into small tasks, put away distracting devices. Recognizing the potential for conflicts between managements self-interest in preserving the independence of a target company and the directors decision to accept or reject a takeover bid, Lipton advocated the following best practices: In this section of the article, Lipton began to embrace a more assertive role for independent directors and advisors. To fill that gap for his burgeoning defense practice,19 Lipton then wrote his now-iconic 1979 article, Takeover Bids in the Targets Boardroom,20 using the firms legal opinions to the McGraw-Hill board as the first draft.21 The intent of the article was to advance a sound and well-grounded argument for target boards responding to takeovers to protect not just stockholders, but the companys full range of stakeholders. Martin has been found in 13 states including California, Massachusetts, Ohio, Connecticut, Illinois. An independent investment banker or other expert should opine as to the adequacy of the price offered and managements presentation. Lipton with early client J. P. Burroughs Company, a Michigan sand, gravel and farm machinery company. L. Rev. . https://www.nytimes.com/1990/12/24/style/katherine-lipton-student-marries.html. Education. His mother, Fannie, concentrated on raising Marty and the home front, and his father, Samuel Lipton, was the manager of a lingerie manufacturing plant owned by his brother. The cost is nil; the value, high. Konen Insurance Agency. After graduation, Liptons father hoped he would go to work for an investment bank, but Lipton did not find that pathway which was very different in the 1950s than today of interest. (June 21, 1976), 52-61; see also, Pearlman, 75 Bus. at 103-04.25Lipton, 35 Bus. Throughout his illustrious career, Lipton has been instrumental in the continued growth of NYU and has used his talents to navigate New . Outside legal counsel should opine as to the antitrust and other legal and regulatory issues in the takeover and as to whether the directors have received adequate information on which to base a reasonable decision. McGraw-Hill would shock the business world for spurning American Expresss initial offer of $830 million and calling it illegal, unsolicited, and improper. CNN . They are beginning to suspect that what Martin Lipton told them twenty-five years ago might be correct. In the series finale, she and her sister speak in a secret language they created when they were little. 1952 . 10 Slater, The Titans of Takeover, at 152. TimesMachine is an exclusive benefit for home delivery and digital subscribers. Arthur Fleischer, Tender Offers: Defenses, Responses and Planning (1980). Duncalfes AboveBoard, launched in 2020, is an executive platform and community that provides access to senior leadership opportunities, particularly for under-represented job-seekers. L. Rev. 11, 1974).15Beneficial Ownership, Takeover and Acquisitions by Foreign and Domestic Persons, at 151-62, 206; see also Martin Lipton, Recent Books, 72 Mich. L. Rev. All rights reserved. Peggy Lipton -- model, "It" Girl, and Golden Globe-winning actress -- has died at age 72. The shareholders then have the power, independent of the directors, to determine whether or not to accept the offer. Near the end of Liptons clerkship, Dean Niles recommended that he spend a couple of years at a law firm specializing in corporate law, the field that most interested Lipton, so that he could round out his experience before a career in teaching. In his 50 or so articles, he has written about poison pills, politics and corporate law, hedge funds, corporate voting, proxy access, corporate federalism and mergers and acquisitions, among . Lipton, Rosen, and Katz decided to invite Wachtell and his partner, Jerome Kern, another NYU grad, to join their new firm. On MENTOR dna, Pierce interviews her C-suite friends on topics such as when to take calculated risks and the patience needed to build a company. $35 per post at $7/CPM. Whether for dating, shopping, or networking, most of us spend hours on our phones. I guess we also just didnt want to have a situation where people thought they were working for us rather than that they were part of a family.7 Or as he put it another time, Basically, the firm was a group of friends joining together and we did not view it as a business. Back in California, I realized these traditional healing foods were hard to find, says Khole, who, with co-founder Mihir Korke WG12, launched Sanchi, a crispy plant-based snack sourced from three powerhouse ancient beans originating from regenerative farms. This debate was featured not only in academic journals, but also in the New York Times. Lipton is a Trustee of New York University (Chairman 1998-2015), a Trustee of the New York University School of Law (Chairman 1988-1998), a Trustee of the NYU Langone Medical Center, an emeritus member . It is reasonable for the directors of a target to reject a takeover on any one of the following grounds: adverse impact on constituencies other than the shareholders; failure to provide equally for all shareholders; and. Lipton, who starred in "Mod Squad" and "Twin Peaks," died last year of . The 'We Are The World . Conducted by Jessica C. Pearlman [*], republished from The Business Lawyer. That feature of the practice grew even more as Wachtell Liptons relationship with Goldman Sachs, the leading M&A defense investment bank, deepened. A dozen years ago, investor and entrepreneur Marc Andreessen described software as eating the world. Today, the same might be said of mobile apps. At the end of 1978, Lipton and Wachtell Lipton then took on a matter that would profoundly change his perspective on hostile takeovers, and corporate law more broadly. Genealogy for Gussie Lipton (Katz) (1880 - 1932) family tree on Geni, with over 230 million profiles of ancestors and living relatives. Family members can then log on and add descriptions. Relatives & Associates. [5] Shortly thereafter Lipton began a 20-year period as a lecturer and adjunct professor teaching corporate law and securities regulation at NYU School of Law. Martin Lipton, a founding partner of Wachtell, Lipton, Rosen & Katz, specializes in advising major corporations on mergers and acquisitions and matters affecting corporate policy and strategy. For a more complete overview, see the introduction to the collection of Liptons articles and memos at the archive section on this site. As he put it, You didnt just walk into an investment bank and say, I want to be an associate, as you do now. There werent these great jobs for aspiring bankers. In it, Lipton marshaled the legal and policy arguments in favor of the authority of boards of directors to reject and actively oppose unsolicited takeover bids. Writing at a point in time when takeover activity was accelerating but judicial treatment of the proper role of target directors was nascent, Lipton framed the subject in elemental terms: It would not be unfair to pose the policy issue as: Whether the long-term interests of the nations corporate system and economy should be jeopardized in order to benefit speculators interested not in the vitality and continued existence of the business enterprise in which they have bought shares, but only in a quick profit on the sale of those shares? When the Seligson firm dissolved in December of 1964, Lipton, Rosen, and Katz decided to form their own law firm. Law. The app uses blockchain technology for secure direct messages and live video calls. Susan Lytle Lipton LL.M. Its always been a team effort, but we all know that Marty has always been first among equals.9, Lipton grew the firm based on his valuesa firm that was based on mutual trust, a commitment to professional excellence, and thought leadership. By dint of his work on securities law matters and his relationship with Dean Niles, Lipton was asked to step in and teach securities law at NYU on short notice after the death of a faculty member. The obvious and inherent conflict of interest between management and shareholders, Gilson posited, led to corporate laws resolution of the conflict by focusing on managements motive in defeating the tender offer; that approach (he argued) is inadequate not only because of the uncertainties of motivational analysis, but because it fails to address the structural question of whether management should be able to act at all.49 Gilsons construct was that as a general principle shareholders must make tender offer decisions.50 In Gilsons view, the tender offer was the critical mechanism through which the corporate structure imposes constraints on certain forms of managerial self-dealing, while management-adopted defensive tactics could make tender offers impossiblewhich (in his view) was flatly inconsistent with the structure of the corporation.51 Gilsons conclusion: Defensive tactics, because they alter the allocation of tender offer responsibility between management and shareholders contemplated by [the structure of the modern corporation], are inappropriate.52. [8][10] Also, in 1975, as a trustee of the NYU School of Law, Lipton played a major role in saving NYU from its financial crisis by selling the Mueller Macaroni Company. Basically, the firm was a group of friends joining together and we did not view it as a business. Law. Chen and Ang created a plant-based beverage inspired by Asian milk tea the iconic drink theyve loved since childhood by ethically sourcing tea from fair-trade, single-origin family-owned farms and focusing on sustainability and flavor. 14See, e.g., Beneficial Ownership, Takeover and Acquisitions by Foreign and Domestic Persons: Proceedings Before the Securities & Exchange Commission 151-52 (Nov. 14, 1974) (statement of Martin Lipton) (opens by arguing that tender offers should not be impeded, that they provide valuable liquidity, and that they are the only practical way that has evolved for changing control . [23][24], Lipton has received honors from organizations, including the Wharton School, New York University School of Law, New York University, the Legal Aid Society, and the NYU Langone Medical Center. Wharton guests have included Dan Beldy WG98, a partner at Canapi Ventures and former Navy fighter pilot, as well as marketing professor Peter Fader, who turned the tables and interviewed Pierce. But McGraw impressed upon Lipton how serious the threat was to his companys employees and its tradition of excellence, and Lipton relented. On file we have 53 email addresses and 91 phone numbers associated with Martin in area codes such as 617, 415, 312, 949, 773, and 29 other area codes. Can computed tomography improve outcomes in acute coronary syndrome? In 1976, Lipton authored "Corporate Takeovers: Tender Offers and Freezeouts" (American Bar Association, National Institute on Corporate Takeovers). To that end, Lipton attended and graduated from the Wharton School of Business at the University of Pennsylvania in 1952. In 1964, Rosen and Lipton asked another NYU law friend, George Katz, to leave his firm and join them at the Seligson firm as a partner. To preserve these articles as they originally appeared, The Times does not alter, edit or update them. at 1164; see also 94 Harv. The news was confirmed by her two daughters Kidada and Rashida Jones (star of TV's "The Office" and "Parks and Recreation"), from Lipton's 15-year marriage to music producer Quincy Jones. [5] In the fall of 1958 he practiced law at Seligson, Morris & Neuburger, a ten-lawyer firm of Charles Seligson and J. Lincoln Morris, where he teamed with Leonard Rosen and George Katz, fellow NYU Law graduates. Berle was the author of the iconic 1932 book, The Modern Corporation and Private Property, and numerous other important publications on the role of corporations in society, and one of the Brain Trusters who helped President Roosevelt develop and implement the New Deal. Though still unconfirmed, it is possible that the new name refers to chairman of the Board of Trustees, Martin Lipton although the possibility remains that the name refers to another person by the name of Lipton. Martin Lipton was born June 22, 1931 in Jersey City, New Jersey, to a family of Jewish background. One of the biggest issues in health care is often overlooked: physician burnout. University of Pennsylvania, B.S. Image 163 of 168 from the May 16, 2003 publication of The Detroit Jewish News. A trip to India after an autoimmune diagnosis prompted Priyanka Khole to re-examine what was on her plate, literally. 2019-2020 Wharton Alumni Magazine. He graduated from Duke University and received a J.D. When a client presses you on a legal opinion, you really want to research it carefully. Wachtell Lipton, the obscenely profitable and dazzlingly prestigious New York law firm, just elected three lawyers to its millionaires' club partnership. Lipton, as will be seen, used this developing bidder tactic as additional ballast for his argument that boards of directors not only had the duty to make sure that other opportunities that could provide higher value were explored (a duty that Gilson accepted as valuable to stockholders), but to protect stockholders against structurally coercive tender offers. With the adoption this week of The UK Stewardship Code 2020, to accompany The UK Corporate Governance Code 2018, the UK Financial Reporting Council has promulgated corporate governance, stewardship and engagement principles closely paralleling The New Paradigm issued by the World Economic Forum in 2016. The senior partner of the firm, Charles Seligson, taught at NYU and Lipton had been a student in Seligsons bankruptcy course. At the same time, because Flom was becoming the lawyer of choice for the most common bidders for controland the most assertive investment bank, Morgan Stanley, then pushing hostile tender offersLipton and Wachtell Lipton continued to get defense-side representations. But even more important than the money, Harold spoke about the culture and integrity of McGraw-Hill, its independence, and its leadership role in publishing and media. This post is based on his Wachtell Lipton memorandum. Fortunately, I survived the experience as did our nascent friendship, which is still going strong after six decades.5. 1981). Citing to the 36 unsolicited tender offers defeated by the target company in the 1973-1979 period, Lipton noted that the shares of over 50 percent of the targets were either trading at a higher market price than the rejected offer price or were acquired after defeat of the tender by another company at a higher price.27 Going further, Lipton posited (a) that [t]he proper comparison is not between the price of the stock in the market at the rejected offer price, but between the rejected offer price and the amount that could be obtained otherwise upon the sale of the entire company; (b)by the same token, that stockholders were never damaged by rejection of a takeover bid since the true value of the target remained undamaged by rejection of a takeover bid; and (c) citing an unpublished Goldman Sachs study, that in 95 percent of the cases where a company was acquired after an initial resistance to a takeover bid, the stockholders received a higher price than the original offer.28. Law. at 121-23. Suki uses AI-powered voice technology to complete documentation 76 percent faster on average, saving physicians hours of time. Just like milkmen the startup was originally named Mlkmn subscribers avoid single-use plastic. Lipton was a good student and hoped to study the humanities in . Perhaps most fundamental was the then-bold claim that the directors statutory authority to manage the corporations business and affairs encompassed takeover bid decision-making.25 This was bold because under federal law, tender offers were directed solely to stockholders, and the target board had no approval right. at 113.30Lipton, 35 Bus. Throughout most of the 1970s, Wachtell Lipton was as likely to represent those making hostile tender offers as those resisting them. Law. . Law. In the course of developing arguments to help McGraw defend the company he created, Lipton began to embrace them as a personal belief system. Peggy Lipton with her daughters Rashida and Kidada. The snack packs (available in Sea Salt, Tikka Masala, and Chili Garlic) are gluten- and soy-free, reflecting the companys goal to get the right nutrition while helping the planet. Sanchi was part of Venture Labs VIP-X Fall 2022 cohort. The bridegroom, 25, is an associate in the New York law firm of Simpson, Thacher & Bartlett. In 1979 Lipton authored "Takeover Bids in the Target's Boardroom",[17] the seminal article advocating the right of a board of directors to take into account the interests of all the constituencies of the corporation, a position adopted by the Delaware Supreme Court in 1985, and in more than thirty other states by statute or judicial decision and in the Companies Act 2006 of Great Britain. Interviewer's note: In September of 2019, after wrapping up meetings of the Mergers and Acquisitions ("M&A") Committee of the Business Law Section of the American Bar Association ("ABA"), I took the train from Washington, D.C. to . For another, the article led to Lipton and Wachtell Lipton having to respond to critics of the articles position. Nonetheless, Lipton has been increasingly involved in tender fights and enjoys the distinction of having won the most grueling fight of allin which Loews finally took over CNA in a battle that lasted nine months and was complicated by six state insurance statutes and a bitter political and publicity fight waged by a CNA management that simply wouldnt let go.13. at 108.29Lipton, 35 Bus. As we look to the future of the furniture industry, we recognize the importance of the role we play in changing consumer mind-sets around used furniture. Law. Martin Lipton was born on June 22, 1931 in Jersey City, New Jersey, where he grew up. She has one sister named Rachael who is her best friend. Martin Lipton Wiki: Salary, Married, Wedding, Spouse, Family Martin Lipton (born June 22, 1931) is an American lawyer. While the FRC codes are "comply and explain," they fundamentally [] The environmentally sustainable devices exceed WHO requirements for safe drinking water, eliminating harmful micro-plastics, pesticides, viruses, and bacteria. In one, General American Oil was defending itself against a bid by corporate raider T. Boone Pickens. Katherine Bryce Lipton, a daughter of Jane Bryce Lipton and Martin Lipton, both of New York, was married last evening at the Pierre to Steven Rod Chabinsky, a son of Mr. and Mrs. Stanley Chabinsky . Mag., Fall 2013, at 30. The board of directors agreed . The Mod Squad and Twin Peaks star is survived by her two actress daughters, Kidada and Rashida Jones, her . 6Martin Lipton, Collected Quotations (2021).7Hoffer Kaback, Martin Lipton: For the Defense, Directors & Boards, Summer 1999. The contest received high-profile media coverage, and resulted in major companies and investment banks looking to Lipton and his firm for advice on takeover matters.
Brandon Green Obituary, Articles M
Brandon Green Obituary, Articles M