I am so saddened, and at a loss to hear of Rhonda's death. I met Rhonda in late March of 2004 to recruit her for an ATS case on India. At dinner that night we discussed Sosa v. Alvarez-Machain which was about to be heard by the Supreme Court. CCR had filed an amicus in the case, and Rhonda was on her way to Washington with a group of its lawyers to hear the arguments. When I asked innocently what she thought the Supreme Court ruling might do to the precedent set by Filartiga, she said conspiratorially, "You know, I helped bring Filartiga." "Oh really," I asked, sufficiently unimpressed (having already spent too much time with self-inflating lawyers), "in what capacity?" "Well," she whispered, eyes twinkling, "I was co-counsel." Rhonda, delighted with my mortification, agreed to have the CUNY clinic help us on our case.
Over the next two years, Rhonda sent and lost emails for clinic conference calls on a Blackberry she tried to operate while crossing the street, educated us on the finer points of superior responsibility, and tried to convince us that a satellite transmission might be enough for long-arm jurisdiction. She also helped organize NYC screenings of the documentary describing the events of the case, sought out conversations with local activists, and gleefully asked all kinds of uncomfortable questions about a community coalition and its internal politics.
I can't believe she's gone. I miss Rhonda's camaraderie and the spirit she gave to what might have been a lost cause without her. I remember her coaxing us through the "frightening election" of November of 2004, and thought I'd share the words of encouragement she sent for us to start our next year of work:
"wishing everyone peace and progress in 2005, inside and out. and we'll need a good dose of outrage, energy, and hope. rhonda"
