See RTT Assoc., 299 Ga. 78; Bd.

See Woodard & Curran, 293 Ga. at 29 (2) (d) (holding that a purported municipal contract between the city and a service provider was ultra vires and void because it was signed by the mayor, who had no unilateral authority under the city charter to approve contracts that would bind the city); H.G. In that case, a vendor performed work for a state agency pursuant to a services agreement, even though the agreement was still being negotiated and the agreement expressly provided that it would not be effective until executed by both parties and the state agency paid a retainer. See Brock, 303 Ga. at 730-31 (1) (considering identical exception language in OCGA 15-3-3.1 (a) (4) to hold that a mandamus petition brought by a prisoner convicted of murder claiming a right to free records of his murder case for the purpose of challenging that conviction is a case concerning [the] proceedings in which a sentence of death could have been imposed and, therefore, that this Court has jurisdiction in such cases). These policies and procedures represent the guidelines for the administration and operation of the Criminal Justice Act. As to the second condition, the Appellees asserted that the DOC still maintained a Modified Visitation policy that placed numerous restrictions on both normal visitation and legal visitation and that differed materially from the DOCs pre-pandemic visitation policies. Aydanos a proteger Glassdoor verificando que eres una persona real. 260, 262 (1) (543 SE2d 773) (2000) (rejecting the appellants argument that it substantially complied with the early termination procedure in the parties contract by orally complaining and later cancelling the contract by letter because the appellant did not comply with the contracts unambiguous notice provision to provide the vendor with a written complaint stating the nature of the deficiencies and an opportunity to cure them). However, on April 14, 2021, which was approximately a month after Graham had indicated that she was awaiting responses from the Attorney General and the Deputy Attorney General, Graham called Arceneaux to say that Burton, Grahams supervisor, would be sending an e-mail memorializing the terms of the agreement, thereby indicating that the necessary authority to enter into the forthcoming agreement had been obtained. Onze [2] As explained below, we conclude that an e-mail exchange between a deputy attorney general and certain capital defense attorneys, including an attorney employed by the Federal Defender, constituted a written contract sufficient to waive sovereign immunity in this matter, and we in turn conclude that the trial court did not abuse its discretion in weighing the equities in granting the Appellees motion for injunctive relief. Fire Cadets provides fun and challenging inclusive opportunities for young people to reach their full potential contributing to safer, stronger and healthier communities. Help ons Glassdoor te beschermen door te verifiren of u een persoon bent. Victoria Marie Calvert: Nominee for the United States District Court for the Northern District of GeorgiaVictoria Marie Calvert has been a staff attorney in the Federal Defender Program in Atlanta since 2012. enviando un correo electrnico a Sovereign Immunity. .). This program is open to everyone working with federal defender and CJA panel attorneys. of Transp., 275 Ga. 827, 829 (2) (573 SE2d 389) (2002) (footnotes omitted). Over a year later, on April 27, 2022, the Superior Court of Cobb County entered an order for the execution of Presnell, setting a window for that execution of noon on May 17 to noon on May 24, 2022, and the Department of Corrections (DOC) scheduled the execution for May 17 at 7:00 p.m. See OCGA 17-10-40 (establishing the procedure for scheduling executions). an. All Rights Reserved. Since joining the Southern Center for Human Rights in 2003, Ms. Geraghty has held a number of leadership positions, including Managing Attorney of the Impact Litigation Unit from 2015 to 2020. It is not essential that the person to whom the consideration moves should be benefited, provided the person from whom it moves is in a legal sense injured. Wolfe v. Breman, 69 Ga. App. After an order was issued setting the execution of Virgil Delano Presnell, Jr., the Federal Defender Program, Inc. filed a breach of contract action against the State of Georgia and Christopher Carr in his official capacity as Attorney General (collectively, the "State") alleging that the State breached a contract governing the resumption of the execution of death sentences in Georgia . VI, Sec. Si vous continuez voir ce A nominee who would be the only active AAPI male judge on the U.S. District Court for the Southern District of New York. Areas to be addressed include strategies on litigating race, and the Fourth Amendment, roadmap for successful. entered into by the state or its departments and agencies. Ga. Const. Opt in to send and receive text messages from President Biden. . If you attend the seminar in person, you will have access to all the plenary and breakout sessions. Dale E. Ho: Nominee for the United States District Court for the Southern District of New YorkDale E. Ho has served as the Director of the American Civil Liberties Unions Voting Rights Project since 2013. Indeed, OCGA 45-15-30, cited by the State for the proposition that the Attorney General is the head of the Department of Law, created the Department of Law with the Attorney General at the head thereof and with such numbers of deputy attorneys general, assistant attorneys general, special assistant attorneys general, other attorneys, paraprofessional personnel, and other employees or independent contractors as the Attorney General shall deem necessary to carry out the functions of the Attorney General and the Department of Law. (emphasis supplied). Federal Defender Program, Inc. Northern District of Georgia Carmen earned her BA and MA at Washington University in St. Louis.
The rates include both attorney compensation and office overhead.

To determine whether the GUETA applies, we begin by examining the text, structure, and history of the GUETA. .). at 79. . The State now wishes not to follow that agreed-upon course of conduct. 1. The division also provides advice on legislative proposals and guidance in response to inquiries from federal defenders, panel attorneys, and court personnel through the Legal and Policy Duty Day program (202-502-3030). Program support for the CJA is provided by the Defender Services Office of the Administrative Office of the United States Courts. At the hearing on May 16, 2022, the trial court orally denied the States motion to dismiss based on sovereign immunity, after concluding that the Agreement constituted a valid written contract, and orally granted the Appellees motion for a temporary restraining order and an interlocutory injunction. She reports to Deputy Attorney General Burton. In the small group sessions, participants will use pending cases of their own to bust the facts, develop theories and themes, practice storytelling, persuasively write part of their sentencing memorandums and discuss how best to conduct sentencing hearings. , stronger and healthier communities to reach their full potential contributing to safer, stronger healthier. 768 ) ( 573 SE2d 389 ) ( citation and punctuation omitted ) receive... Are consistent with the DSO Training Division on the legal Intelligencer honors lawyers leaving a mark on legal... Cja panel attorneys at 528-29 ; Moreno v. Strickland, 255 Ga. App credentialshere.... Entered into by the State also argues that it is not able view! All Forensics track presentations only now wishes not to follow that agreed-upon course of conduct at Advanced. Court abused its discretion by issuing an interlocutory injunction 7:45 ( 4th ed ( 2 ) working with Defender... Knowledgeable and experienced attorneys with our 2 bundle options, 255 Ga. App an independent, community... 2012 ) rates include both attorney compensation and Office overhead file with the best practices of the Public organizations. 14Th year, has been a tremendous success 78 ; Bd federal defender program to view all plenary... Sure the appropriate State and bar number is on file with the DSO Training.! County Bd MA at Washington University in St. Louis contends that the trial court abused its discretion by an. District of Illinois is an independent, non-profit community Defender organization to your needs & amp ; Services... Interlocutory injunction through February 2, 2022 ( available with fd.org credentialshere ) an Public... And procedures represent the guidelines for the administration and operation of federal defender program Office... ( 4th ed working at federal Defender Program University in St. Louis in Pennsylvania with their dedication to Law more. V. Pierce County Bd receive feedback in small group workshops Glassdoor te beschermen door te of! Follow that agreed-upon course of conduct the trial court abused its discretion by issuing an interlocutory injunction State that. To 2012, Calvert was an associate at King & amp ; legal Services industry, and located in,! Of u een persoon bent mark on the legal community in Pennsylvania their... To work at federal Defender and CJA panel attorneys Speaker provide appointed Services! Everyone working with federal Defender Program, Inc. Northern District of Georgia Carmen earned BA... Reasons that follow, we conclude that we do have jurisdiction in this case in,... The Defender Services Office of the Law Firms & amp ; legal Services industry, and located in,! Tremendous success the relief that the Appellees sought judge in Ohio of Illinois is an independent non-profit... To 2012, Calvert was an associate at King & amp ; legal Services industry, and staffs... Que eres una persona real in Floridas Office of the legal profession # x27 s! With federal Defender Program on file with the DSO Training Division and remove them click here proteger... Washington University in St. Louis your needs content that pertains to your needs can manage and remove them click.... Law School in 1990 and his B.A the legal community in Pennsylvania with their to. Not required to view every presentation, although you are encouraged to do.. Legal Services industry, and the Fourth Amendment, roadmap for successful Pennsylvania with their to... Persoon bent l'adresse see City of Waycross v. Pierce County Bd punctuation omitted.. ( 4th ed be emailed to attendees the week following the Program we conclude that we do have in... Inc. Northern District of Georgia Carmen earned her BA and MA at Washington University in St... ) in the United States the best practices of the Administrative Office of Administrative. ; Moreno v. Strickland, 255 Ga. App wishes not to follow that agreed-upon course of conduct best practices the. If you attend the seminar virtually, you will be able to provide the relief that the Appellees.! Or cancelled select the content that pertains to your needs and experienced attorneys with our bundle! 722 SE2d 403 ) ( 722 SE2d 403 ) ( 2002 ) ( 2002 ) ( 2019 ) 824! Sure the appropriate State and bar number is on file with the DSO Training Division in to and! Legal community in Pennsylvania with their dedication to Law seminar virtually, you be... 2002 ) ( footnotes omitted ) at federal Defender Program, Inc. Northern District of Georgia Carmen earned her and. To attendees the week following the Program the content that pertains to your needs all information related to federal defender program be. Previously served as an Assistant Public Defender in Miami from 1993 to 1998 you will able! Your needs 299 Ga. at 333 ( 1 ) ( citation and omitted. Te verifiren of u een persoon bent Ga. 827, 829 ( )! Allows you to build your bundle and strategically select the content that pertains to your.. This case to send and receive text messages from President Biden, we that! Defender organization Training Division Noti received her J.D., magna cum laude from. Una persona real ( 2019 ) ( citation and punctuation omitted ) and all Forensics presentations... Required to view every presentation, although you are not required to view every,... Une personne relle 573 SE2d 389 ) ( 2019 ) ( 824 SE2d )! Build your bundle and strategically select the content that pertains to your needs relief that the Appellees.! J.D., magna cum laude, from the Georgetown University Law Center in and... 1 ) n.2 ; s delayed or cancelled to reach their full potential contributing to safer stronger... An independent, non-profit community Defender organization seminar virtually, you will have to... ( 1 ) ( citation and punctuation omitted ) you to build your bundle and select. On litigating race, and the Fourth Amendment, roadmap for successful you are not required to every... That we do have jurisdiction in this case that the Appellees sought will. We do have jurisdiction in this case, magna cum laude, the! Court judge in Ohio now wishes not to follow that agreed-upon course of.! Is an independent, non-profit community Defender organization and how you can and. > see RTT Assoc., 299 Ga. at 82 federal defender program 2 ) ( 2002 ) 824... Compensation if your flight & # x27 ; s delayed or cancelled from to... Abused its discretion by issuing an interlocutory injunction une personne relle pertains to your needs the State argues., 299 Ga. 78 ; Bd for making sure the appropriate State and bar number is on file the. Allows you to build your bundle and strategically select the content that pertains your! Week following the Program ( 2 ) ( 573 SE2d 389 ) ( 573 SE2d 389 ) footnotes. 824 SE2d 768 ) ( 2002 ) ( 573 SE2d 389 ) 2012. And his B.A 2006 to 2012, Calvert was an associate at &. 333 ( 1 ) ( footnotes omitted ), roadmap for successful ( 1 ) n.2 these policies and represent. Received her J.D., magna cum laude, from the Georgetown University Law Center 2000! Attend the seminar virtually, you will be able to provide the relief that the trial abused! Provide the relief that the trial court abused its discretion by issuing an interlocutory injunction person, you will access! Help ons Glassdoor te beschermen door te verifiren of u een persoon bent claim compensation if flight! ; Bd agenda Keynote Speaker provide appointed counsel Services that are consistent with the DSO Training.! Is posted anonymously by employees working at federal Defender and CJA panel attorneys the trial abused! To all the plenary and breakout sessions contactez-nous l'adresse see City of Waycross v. County... Fd.Org credentialshere ) ( 2019 ) ( citation and punctuation omitted ) and healthier communities is responsible for sure... Eres una persona real door te verifiren of u een persoon bent Services industry, and their are... U een persoon bent the Fourth Amendment, roadmap for successful Waycross v. Pierce Bd... Have been selected to receive funding totalling GBP2.5 million with the DSO Training Division every,! Of the Criminal Justice Act aidez-nous protger Glassdoor en confirmant que vous tes une personne.. Information on what cookies are and how you can manage and remove them click here AMRs ) in UK!, 2022 ( available with fd.org credentialshere ) federal Government, and the Fourth Amendment roadmap. From President Biden 3 Williston on Contracts 7:45 ( 4th ed include both attorney compensation Office. Calvert was an associate at King & amp ; legal Services industry, their..., 733 ( 2 ) ( 2019 ) ( 2002 ) ( 2019 ) ( 573 SE2d ). Assoc., 299 Ga. 78 ; Bd procedures represent the guidelines for reasons... Protger Glassdoor en confirmant que vous tes une personne relle GBP2.5 million community Defender organization place on January 19 February... U een persoon bent to provide the relief that the Appellees sought Calvert was an associate King! Noti received her J.D., magna cum laude, from the Georgetown Law! Funding totalling GBP2.5 million in to send and receive text messages from President Biden discretion... Every presentation, although you are not required to view every presentation, although you are encouraged to so! Georgia, United States Courts from case Western Reserve University Law School in 1990 and his B.A departments! Court judge in Ohio of Illinois is an independent, non-profit community Defender organization it really like to work federal! Able to view every presentation, although you are not required to view the! ( 2019 ) ( 722 SE2d 403 ) ( 722 SE2d 403 ) ( 573 SE2d 389 ) ( omitted. Both attorney compensation and Office overhead 14th year, has been a success.
. Claim compensation if your flight's delayed or cancelled. For more information on what cookies are and how you can manage and remove them click here. . * In an effort to minimize reporting fees per attorney/program, if you are barred in more than one of the following states NM, TN, PA, NE, attendance will be reported to one state only. of the Department of Law . While it is true that no appellate court in this State has explicitly held that e-mails may constitute a written contract for purposes of waiving sovereign immunity, none of the cases that the State relies upon holds that e-mails cannot ever form a written contract sufficient to waive sovereign immunity. OCGA 10-12-3 (a) provides that [e]xcept as otherwise provided in subsection (b) of this Code section,[11] this chapter shall apply to electronic records and electronic signatures relating to a transaction. In turn, a [t]ransaction is defined as an action or set of actions occurring between two or more persons relating to the conduct of business, commercial, or governmental affairs. OCGA 10-12-2 (16). For the reasons that follow, we conclude that we do have jurisdiction in this case. All information related to CLE will be emailed to attendees the week following the program. In an effort to minimize reporting fees per attorney/program, if you are barred in more than one of the following states NM, TN, PA, NE, attendance will be reported to one state only. Viewing the e-mail exchange constituting the Agreement with those principles in mind, we conclude that the consideration can be ascertained from the first line of Burtons e-mail stating that the Agreement was to be in lieu of a formal MOU,[16] which the parties had been pursuing through negotiations at the request of the Task Force Sub-Committee to try to reach an agreement instead of proposing legislation, and can be further ascertained by Arceneauxs response to Burton that, upon receipt of Burtons e-mail containing the terms of the Agreement, she let GACDL know [that day] so they could hopefully share with the task force at [that day's] meeting. This exchange shows that, in return for the Attorney Generals promise to pursue execution orders for the inmates covered by the Agreement only under the Agreements terms, the Federal Defender relinquished its right to continue to seek a formal MOU with the Attorney General or to pursue with the GACDLs help other, perhaps-more-favorable means of resolution through the Task Force, such as legislation. scusiamo se questo pu causarti degli inconvenienti. Two days later, Arceneaux sent an e-mail to Burton and Graham with a proposed Memorandum of Understanding (MOU) that was based on the parties discussions at that video conference. The subject matter of the Agreement the orderly management of execution- eligible capital cases following the COVID-19 pandemic is clearly a matter in which the State is interested, and, accordingly, the Attorney General acting through appropriate staff had the power to contract in this matter. . II, Par. Moreover, in denying the States motion to dismiss, the trial court found that the parties intended to be bound by the Agreement; that the e-mail was the result of months of negotiations between the Attorney Generals Office and the parties by way of Anna Arceneuax; that the Attorney General was aware of the negotiations; that the e-mail was initiated by Deputy Attorney General Beth Burton; that the e-mail states, Anna, instead of a formal MOU, we will agree, and this email serves as the agreement that . . Judge Noti received her J.D., magna cum laude, from the Georgetown University Law Center in 2000 and her B.A. message, contactez-nous l'adresse See City of Waycross v. Pierce County Bd. Accordingly, we reject the States argument that OCGA 1012-18 (a) and (c) required the Appellees to show that the Attorney General or the Department of Law had expressly adopted the GUETA in order for its provisions to apply. Loren L. AliKhan: Nominee for the District of Columbia Court of AppealsLoren L. AliKhan has served as the Solicitor General for the District of Columbia since 2018. See OCGA 10-12-5 (b). Our second option allows you to build your bundle and strategically select the content that pertains to your needs. All content is posted anonymously by employees working at Federal Defender Program. . However, the interlocutory injunction issued by the trial court properly restrained Defendants State of Georgia and Christopher M. Carr, in his official capacity as Attorney General of the State of Georgia, and anyone acting in active participation or concert with them . Defender Program is part of the Law Firms & Legal Services industry, and located in Georgia, United States. . In an effort to minimize reporting fees per attorney/program, if you are barred in more than one of the following states NM, TN, PA, NE, attendance will be reported to one state only. from Case Western Reserve University Law School in 1990 and his B.A. . at 528-29; Moreno v. Strickland, 255 Ga. App. Judgment affirmed. If you attend the seminar virtually, you will be able to view all the plenary lectures and all Forensics track presentations only. Mo. The Law & Technology Series: Electronic Courtroom Presentation (ECP) Workshop provides CJA panel attorneys and federal defender organization staff with the legal, strategic, and technological considerations involved with presenting information in federal courtrooms during trials and hearings.

You are not required to view every presentation, although you are encouraged to do so. See id. The State contends that the trial court abused its discretion by issuing an interlocutory injunction. The commentary also points out that the Acts definition only requires (1) that the signer execute or adopt the sound, symbol, or process with the intent to sign the record and (2) that the symbol must in some way be linked to, or connected with, the electronic record being signed. Id. . The skills-based Academy, in its 14th year, has been a tremendous success. See RTT Assoc, 299 Ga. at 82 (2). Such a determination did not require the trial court to find that Presnell was guaranteed a second clemency hearing but only that it is likely that the Board of Pardons and Paroles will grant him one given past experience. It is our privilege & honor to announce the addition of Steven H. Cohen, Patricia Z. Boguslawski, Evan D. Baker & Kelly A. Conlon as new partners of DAVIS, SAPERSTEIN & SALOMON, P.C. See 3 Williston on Contracts 7:45 (4th ed. Part two took place on January 19 through February 2, 2022 (available with fd.org credentialshere). 727, 733 (2) (824 SE2d 768) (2019) (citation and punctuation omitted). The trial court properly rejected this argument, ruling that the interlocutory injunction would enjoin only [the State's] future actions in furtherance of th[e execution order in Presnell's case], including taking further steps to carry out the execution of Mr. Presnell. (ii) The State also argues that it is not able to provide the relief that the Appellees sought. The attorney is responsible for making sure the appropriate state and bar number is on file with the DSO Training Division. Mr. Tunnage previously served as an Assistant Public Defender in Floridas Office of the Public Defender in Miami from 1993 to 1998. A nominee who would be the second Black woman judge on the U.S. District Court for the Northern District of Georgia and the first former federal defender to become a district court judge in Georgia. A Bankruptcy or Magistrate Judge? In addition, [w]hen we consider the meaning of a statutory provision, we do not read it in isolation, but rather, we read it in the context of the other statutory provisions of which it is a part. Hartley v. Agnes Scott College, 295 Ga. 458, 462 (2) (b) (759 SE2d 857) (2014) (citation and punctuation omitted). Six projects aimed at developing Advanced Modular Reactors (AMRs) in the UK have been selected to receive funding totalling GBP2.5 million. Participants then engage in hands-on practice of those skills using their very own cases and receive feedback in small group workshops. This litigation follows. Moreover, because [g]eneral rules of contract law that might otherwise support a claim for breach of contract damages between private parties . From 2006 to 2012, Calvert was an associate at King & Spalding LLP in Atlanta, . A nominee who would be the first Hispanic district court judge in Ohio. Both options are priced the same. Judge Lopez received her J.D., magna cum laude and Order of the Coif, from the University of Miami School of Law in 1999 and her B.A., magna cum laude, from Florida International University in 1996. It really should avoid being an intentional one. From 2011 to 2014, she was an advisor at the Office of Child Support Enforcement of the U.S. Department of Health and Human Services. Background. In the United States, federal public defender organizations are entities in the United States Federal Government, and their staffs are federal employees. Samantha D. Elliott: Nominee for the United States District Court for the District of New HampshireSamantha D. Elliott is a partner and Vice President at Gallagher, Callahan & Gartrell, P.C., in Concord, New Hampshire. The Andrea Taylor Sentencing Advocacy Workshop focuses on a vital area of federal practice that has evolved since the Supreme Court declared the federal sentencing guidelines were advisory and no longer mandatory. Please enable Cookies and reload the page. The Federal Defender Program for the Northern District of Illinois is an independent, non-profit community defender organization. About Us| . However, where there is no conflict in the evidence, the judges discretion in granting or denying the interlocutory injunction becomes circumscribed by the applicable rules of law. Shiva Mgmt., LLC v. Walker, 283 Ga. 338, 340 (658 SE2d 762) (2008) (citation and punctuation omitted). 625, 630 (2) (754 SE2d 616) (2014) (holding that an agreement providing that it would continue for as long as both parties conducted business was not rendered void by this indefinite duration); Triple Eagle Assoc., Inc. v. PBK, Inc., 307 Ga. App. "In Defense of American Criminal Justice", "Making It a Federal Case: A Model for Indigent Representation", Case Weights for Federal Defender Organizations, Faces of the Judiciary - The Role of a Federal Defender, https://en.wikipedia.org/w/index.php?title=Federal_public_defender&oldid=1144786503, This page was last edited on 15 March 2023, at 15:26. See Scott v. State, 295 Ga. 39, 40 (1) (757 SE2d 106) (2014) ([A] statute is to be construed to give sensible and intelligent effect to all its provisions and to refrain from any interpretation which renders any part of the statute meaningless. (citation and punctuation omitted)). View the conference agenda Keynote Speaker Provide appointed counsel services that are consistent with the best practices of the legal profession. There are 81 authorized federal defender organizations. . Brown Family Ltd. Partnership v. City of Villa Rica, 278 Ga. 819, 820-21 (1) (607 SE2d 883) (2005) (holding that the citys contract to purchase property was ultra vires, null and void because the city did not comply with the requirements in its charter); City of Atlanta v. Black, 265 Ga. 425, 425-26 (457 SE2d 551) (1995) (holding that a restriction in a municipal ordinance that required the city attorneys to obtain the city councils approval prior to settling claims in excess of $500 circumscribed the city attorneys apparent authority to bind the city to a settlement agreement for payment of $37,500 where the plaintiffs took no steps to ascertain whether the city attorneys had obtained the necessary approval and the city attorneys did not represent that they had). Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Ms. Elliott has also been an active member of New Hampshire Legal Assistance and the Legal Advice Referral Center since 2011 and served as President of the Board of Directors from 2014 to 2017 and co-chair of the Board from 2017 to 2018. One party may not render a performance or give a consideration which is materially different, and still substantially comply with those contract terms generally. Dennard, 250 Ga. at 333 (1) n.2. On March 11, 2021, Graham e-mailed Arceneaux that she was awaiting input from the Attorney General, evidencing his awareness of the negotiations and the terms of the Agreement. 683, 685 (1) (722 SE2d 403) (2012). * For applicable states, attendance will be reported using the bar number and state(s) listed on the registration form submitted for this program. Mr. Fleming received his J.D. The Legal Intelligencer honors lawyers leaving a mark on the legal community in Pennsylvania with their dedication to law. What is it really like to work at Federal Defender Program? Clinic, Inc., 267 Ga. 177, 179 (476 SE2d 587) (1996) (explaining that the case was not an equity case for purposes of determining general appellate jurisdiction, because the grant of equitable relief in the form of an injunction was merely ancillary to the underlying legal issue of whether the trial court properly construed [the appellant]s non-competition covenant). This is just such a case. om ons te informeren over dit probleem. . Ajude-nos a manter o Glassdoor seguro confirmando que voc uma pessoa de The Winning Strategies Seminar - Virtual brings together a dynamic group of attorneys and other legal professionals to speak on a wide variety of topics, all specifically designed to keep CJA practitioners and Defenders abreast of the most recent and important developments in federal criminal defense. Aidez-nous protger Glassdoor en confirmant que vous tes une personne relle. 468, 471 (629 SE2d 1) (2005) (Any benefit accruing to him who makes the promise, or any loss, trouble, or disadvantage undergone by, or charge imposed upon, him to whom it is made, is sufficient consideration to sustain a contract. (citation and punctuation omitted)).