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Ralph G. Neas (born May 17, 1946) is an American civil rights activist and executive. He is best known for directing a series of national campaigns to strengthen and protect civil rights laws during the Reagan and Bush presidencies.[1][2][3][4][5][6] He is also known for chairing the national coalition that helped defeat the U.S. Supreme Court nomination of Robert Bork.[7][8][9][3]

Neas served as executive director of the Leadership Conference on Civil Rights;[10] president and CEO of People For the American Way (PFAW)[11] and the PFAW Foundation; president and CEO of the National Coalition on Health Care;[12] and president and CEO of the Generic Pharmaceutical Association (GPhA).[13] He served for eight years as chief legislative assistant to Republican Senators Edward Brooke of Massachusetts and David Durenberger of Minnesota. He remained a member of the Republican Party until October 1996.[14]

Early life and education

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Neas was born on May 17, 1946, in Brookline, Massachusetts. In 1955, the Neas family moved from New England to St. Charles, Illinois. There, Neas' father, Ralph, Sr., began a career as a salesman for the American Brass Company. Neas quit public high school and attended Marmion Military Academy (Aurora, Illinois), a private Benedictine military school to set himself up for success in attending university.[15]

Neas states that major influences before he left for college and law school were his parents, the teachings of Vatican II, his love for baseball, the civil rights movement, and the lessons he learned at Marmion.[16][17][18]

Neas graduated from Marmion Military Academy in 1964. He earned a B.A. with honors from the University of Notre Dame in 1968, and a J.D. from the University of Chicago Law School in 1971.[19]

Career

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U.S. Senate

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Neas was both active duty and reserve in the United States Army (1968–1976).[20] In late 1971, he joined the Congressional Research Service's American Law Division at the Library of Congress as a legislative attorney on civil rights. In January 1973, he was hired as a legislative assistant to Republican Senator Edward W. Brooke of Massachusetts, eventually becoming the Senator's chief legislative assistant. He stayed with Senator Brooke until his defeat in 1978, at which time he accepted a job as chief legislative assistant to Republican Senator David Durenberger of Minnesota.[21]

Neas' work in the U.S. Senate spanned eight years. During that time, he focused primarily on civil rights, including the 1975 extension and expansion of the Voting Rights Act of 1965, and the protection of Title IX, reproduction rights, and Title VI and Title VII of the 1964 Civil Rights Act. Neas also worked on the Watergate scandal, health care, and ethics reform.[22] While working for Senator Durenberger in 1979–1980, he conceived and drafted the "Women's Economic Equity Act," parts of which were enacted during the Reagan and Bush Administrations.[23]

Leadership Conference on Civil Rights (LCCR)

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From 1981 through 1995, Neas served as Executive Director of the nonpartisan Leadership Conference on Civil Rights (LCCR), the legislative arm of the civil rights movement.[24] Neas coordinated successful national campaigns that led to the Civil Rights Act of 1991;[25] the Americans with Disabilities Act;[26][27][28] the Civil Rights Restoration Act;[29][30][31][32] the Fair Housing Act Amendments of 1988;[33] the Japanese American Civil Liberties Act;[34][35] the preservation of the Executive Order on Affirmative Action (1985–1986 and 1995–1996);[36][37] and the 1982 Voting Right Act Extension.[38][39][40] Final passage on all these laws averaged 85% in both the House of Representatives and the Senate; in addition, another 15 Leadership Conference on Civil Rights legislative priorities were enacted into law in the 1981–1995 period.[41][42][43]

Neas pointed out during July 11, 1996, testimony before the House Democratic Caucus, Committee on Organization Study and Review regarding Bipartisan Cooperation in Congress, "the average final passage vote on these laws was 85%" in both the House and Senate.

William T. Taylor, former General Counsel and Staff Director of the United States Commission on Civil Rights, and then an LCCR executive committee member wrote that Neas "seemed an unlikely choice [because] he was a white male Catholic Republican who had gone to Notre Dame, where he devoted himself to becoming an officer in the ROTC."[44]

He was chair of the Block Bork Coalition in 1987.[45][46][47][48]

Political career

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In 1998, Neas ran against incumbent Republican Representative Connie Morella in Maryland's 8th Congressional District, composed primarily of the suburban areas just northwest of Washington, DC. Morella defeated Neas 60% to 40%.[49]

People For the American Way

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In late 1999, Neas was named the President and CEO of People For the American Way and People For the American Way Foundation.[50] For eight years, Neas helped lead national efforts to preserve an independent and fair judiciary;[51][52][53][54][55] to protect civil rights and civil liberties;[56][57][58][59] and to defend and reform public schools in the United States.[60]

In addition, Neas helped put together civic engagement partnerships to recruit and manage 25,000 volunteers in 2004 for the non-partisan and nationally recognized Election Protection program[61][62] (to help ensure every vote counts), to direct non-partisan programs that registered 525,000 African and Latino voters in three years, and to establish youth leadership development programs across the country (Young People For and Young Elected Officials).[60]

National Coalition on Health Care (NCHC)

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In late 2007, Neas became active in the health care reform movement, becoming senior advisor to the president of the National Coalition on Health Care (NCHC), a non-partisan coalition of more than 80 national organizations (representing consumer groups, medical societies, civil rights groups, small and large businesses, civil right groups, pension funds, disability senior citizens unions and senior citizen and good government organizations).[63] In February 2009, Neas became the CEO of NCHC to help lead the final push for the Affordable Care Act, focusing on system-wide reform, quality health care, cost containment, and the need for bipartisanship.[64][65][66][67][68][69] Neas also worked closely with the generic pharmaceutical industry to convey the importance of promoting generics as a critical cost saving and pro-consumer strategy to ensure a sustainable health care system.[70]

Generic Pharmaceutical Association

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On September 12, 2011, Neas became President and CEO of the Generic Pharmaceutical Association (GPhA), which represents the manufacturers and distributors of finished generic pharmaceuticals.[71][72]

Neas and GPhA played a leadership role in protecting the Hatch-Waxman Act;[73][74] enacting the Generic Drug User Fees Act;[75][76] promoting and defending biosimilars at the national and state levels;[77][78] and making sure that international trade agreements did not favor manufacturers of brand medicines and biologics.[79][80][81][82]

During Neas' tenure, GPhA also launched the Biosimilars Council.[83]

Teaching

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Neas has taught law school and undergraduate courses on the legislative process, the United States Constitution, public policy, and the media. These courses have been offered at, among other places:

Author

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Neas is a frequent contributor to the Huffington Post. His published works include more than fifty articles, op-eds, and commentaries in national and regional media outlets.

Media appearances

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Neas has been frequently interviewed in the print and electronic media, including CBS's Face the Nation, ABC's Nightline, CBS's Sunday Morning, NBC's Today Show, ABC's This Week, PBS NewsHour, the nightly news shows of ABC, NBC, CBS, CNN, and Fox; National Public Radio; and national, regional, and local newspapers.[87]

Between 1979 and 2016, both the New York Times[88] and the Washington Post[89] cited Neas several hundred times. The Wall Street editorial pages have discussed Neas in more than 45 editorials and op-eds.[90]

Neas has made more than 50 appearances on C-SPAN.[91] In 2009, along with Senators Patrick Leahy (D-Ver) and Arlen Specter (R and then D-Pa), and conservative activist Manny Miranda[92] Neas was the subject of a film documentary entitled Advise and Dissent;[93] In 2014-2016, Neas was featured in a play by Anthony Giardina, "City of Conversation", at the Lincoln Center in New York, the Arena Stage in Washington, D.C, and in theaters in other parts of the United States.[94]

Awards

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  • Hubert H. Humphrey Civil Rights Award from LCCR;[95]
  • Benjamin Hooks "Keeper of the Flame" award from the National Association for the Advancement of Colored People (NAACP), the 91st Annual Convention, Baltimore, Maryland, July 10, 2000;[96]
  • Public Service Achievement Award from Common Cause
  • Edward M. Kennedy Lifetime Achievement Award from the Disability Rights Education and Defense Fund—November 10, 1994;
  • National Good Guy Award" from the National Women's Political Caucus;[97]
  • "Isaiah Award for the Pursuit of Justice" from the American Jewish Committee, Washington D.C. Chapter, October 5, 1994;
  • "Flag Bearer Award" from PFLAG (formerly known as Parents, Families, and Friends of Lesbians and Gays), 1995;[98][99]
  • Edison Uno Memorial Civil Rights Award from the Japanese American Citizens League; 31st JACL Biennial Convention, San Diego, California, 1990;
  • University of Chicago Alumni Public Service Citation;[100]
  • "Citizen of the Year" award from the Guillian-Barre Syndrome Foundation International;[101][19]
  • The Lawyers' Committee for Civil Rights Under Law for efforts to enact the Civil Rights Act of 1991, January 15, 1992;
  • "The Americans with Disabilities Act Award" from the Task Force on the Rights of the Empowerment of Americans with Disabilities for "historic leadership regarding the enactment of the world's first comprehensive civil rights law for people with disabilities" October 12, 1990;
  • Marmion Military Academy's "Centurion" Alumni Achievement Award, March 13, 1991, North Aurora, Illinois;
  • Civil Rights Leadership Award from the Religious Action Center for Reform Judaism at the Embassy of Israel, January, 1988;
  • Rosa Parks Award" by the American Association for Affirmative Action, April, 1996, AAAA 22nd Annual Conference, Philadelphia, Pa.;
  • The National Bicentennial Medal received from American Bicentennial Administration Administrator John Warner (future United States Senator), 1976. Neas was chief legislative assistant to ABA Board Co-Chairman Senator Edward W. Brooke and Senate liaison to the American Bicentennial Administration);
  • "President's Award for Outstanding Service", Leadership Conference on Civil Rights, September, 2007.
  • Received the "Eagle Fly Free Award" from the Institute for the Advancement of Multicultural and Minority Medicine (along with Senator Arlen Specter, Congresswoman Debbie Wasserman Schultz, and former world boxing champion Sugar Ray Leonard), September 29, 2009, Institute's Awards Benefit Gala, Washington, D.C.
  • Received the "Star for Children" Award from the Children's Charities Foundation, Washington, D.C., December, 2015

Neas was named in 2004 one of Vanity Fair magazine's "Best Stewards of the Environment." In May 2008, the national Legal Times designated Neas one of the 30 "Champions of the Law" over the past three decades.

In addition, Neas was named one of the nation's most influential advocates by the National Journal ("150 Americans Who Make a Difference", June, 1986), Regardie's Magazine (1990), and U.S. News & World Report ("The New American Establishment", February 8, 1988). On October 9, 1987, Neas was named ABC World News' "Person of the Week" for his leadership role opposing the Robert Bork Supreme Court nomination[102]

Personal life

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Neas is a baseball fan. As a child, his goal was to play third base for the Boston Red Sox.[15]

In early 1979, Neas received last rites from a Roman Catholic priest after the onset of near-total paralysis which was caused by Guillain–Barré syndrome (also known as "French Polio.")[103][104] After nearly five months in the hospital, much of it on a respirator in the intensive care unit, he recovered, and co-founded the Guillain Barre Syndrome Foundation, whose primary focus is on families affected by the disease.[105]

Neas married Katherine Beh in 1988, and their daughter Maria was born in 1999.

References

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  1. ^ Dorothy Height, "The Neas Years at the Leadership Conference on Civil Rights", 45th Anniversary Journal, May 3, 1995, inserted in the Congressional Record by, among others, Congressman Kweisi Mfume, former Chairman of the Congressional Black Caucus, E930, May 2, 1995
  2. ^ Special Otis Bowen Lecture on Comprehensive Health Care, Ralph Neas, March 26, 2009, the University of Notre Dame, inserted in the Congressional Record by Senator Edward Kennedy, May 5, 2009, S5122
  3. ^ a b Senator Edward Kennedy, Congressional Record, S5996, May 2, 1995, "Ralph Neas: the 101st Senator for Civil Rights"
  4. ^ Congressman Steny Hoyer, Congressional Record, E947, May 3, 1995, "Tribute to Ralph Neas and the Leadership Conference on Civil Rights"
  5. ^ Senator Carol Mosely Braun, Congressional Record, S6028, May 3, 1995, "The Neas Years"
  6. ^ Senator Bill Bradley, S6032, May 3, 1995, "Honoring Ralph Neas."
  7. ^ Mark Gitenstein, "Matters of Principle: An Insider's Account of America's Rejection of the nomination of Robert Bork to the Supreme Court", 1992
  8. ^ Ethan Bronner, "Battle For Justice": How the Bork Nomination Shook America", 1989
  9. ^ Michael Pertchuk, "The People Rising: The Campaign Against the Bork Nomination", 1989
  10. ^ "Congressional Record Senate Articles". www.congress.gov. Retrieved December 6, 2016.
  11. ^ "Statement of Ralph G. Neas President, People For the American Way on Judicial Nominations". People For the American Way. Retrieved September 26, 2020.
  12. ^ "Search for "ralph neas"". NCHC. Retrieved September 26, 2020.
  13. ^ New York Times (September 7, 2011). "Longtime Liberal Advocate to Lead Generic Drug Group". The New York Times. Retrieved January 24, 2013.
  14. ^ Ronald Brownstein, The Second Civil War, 2007
  15. ^ a b The Hill Rag Newspaper, April, 1983, article by Keith Fagon, "Ralph Neas", inserted in the Congressional Record by Senator Edward Kennedy, S9702-S9706, April 26, 1983.
  16. ^ Neas Lecture at the University of Notre Dame, "Professional Life: Vocation and Commitment", October 24, 1983, at a conference convened by the National Conference of Catholic Bishops
  17. ^ Bishop's Committee on the Laity Secretariat, "Work and Faith in Society: Catholic Perspectives": Presentations from a Laity Consultation (Office of Public Services, U.S. Catholic Conference, 1984-Church and the World-40 pages)
  18. ^ LCCR 45th Anniversary Dinner honoring Neas, March 3, 1995, biographical article in the dinner journal
  19. ^ a b "Ralph G. Neas Bio" (PDF). Generic Pharmaceutical Association. 2013. Archived from the original (PDF) on November 27, 2013.
  20. ^ "Ralph Neas". NNDB. Retrieved January 24, 2013.
  21. ^ "Congressional Record Senate Articles". www.congress.gov. Retrieved December 9, 2016.
  22. ^ Neas, "Reflections on the Autobiography of Edward W. Brook."
  23. ^ For descriptions of Neas' role in the Economic Equity Act, see: * * --Savvy Magazine, February, 1983, Lavinia Edmunds and Judith Patterson, "A Hard Act to Follow: A Coalition Uses ERA Lessons to Fight for Passage of the Complex Economic Equity Act" - Senator David Durenberger email to Ralph Neas, 2016 - Washington Post, March 16, 1983, Judy Mann, "Equal Benefits" - Glamour Magazine, August 1982, Sarah Weddington, "Good Guys in Washington" - Harvard Journal of Law and Gender, 2007, Patricia Seith, "Congressional Power to Effect Sex Equity". P 17, Footnote 67.
  24. ^ Dorothy Height, "The Neas years at the Leadership Conference on Civil Rights," LCCR 45th Anniversary Journal, May 3, 1995.
  25. ^ Holmes, Steven A. (December 2, 1991). "Washington at Work; Lobbyist on Civil Rights Wins Despite Hostility". The New York Times. ISSN 0362-4331. Retrieved January 31, 2023.
  26. ^ Lennard Davis, Enabling Acts: The Hidden Story of How the Americans with Disability Act Gave the Largest US Minority Its Rights"
  27. ^ "The Making of the ADA", Disability Rights Defense and Education Fund, Parts One and Three, Summer, 2015
  28. ^ New York Times, August 8, 1989, Nathaniel Nash, "Bush and Senate Leaders Support Sweeping Protections for Disabled"
  29. ^ Johnson, Julie (March 17, 1988). "Reagan Vetoes Bill That Would Widen Federal Rights Law". The New York Times. p. 1.
  30. ^ National Women's Political Caucus, Women's Political Times, October, 1984, "Why the Defeat?"
  31. ^ Ms. Gazette, Lavinia Edmunds, October, 1984, Welding a Civil Rights Coalition"
  32. ^ The New York Times, January 6, 1985, "Reagan Backs Bid to Reverse Effects of Ruling in Bias Case"
  33. ^ "Education for the 21st Century". www.c-span.org. Retrieved October 6, 2022.
  34. ^ Japanese American Citizens League honors Neas for "outstanding Support to Redress for Americans of Japanese ancestry". August 7, 1988
  35. ^ "LCCR Voting Record, 100th Congress" (PDF).{{cite web}}: CS1 maint: url-status (link)
  36. ^ The Wall Street Journal, November, 1985, JoAnn Lublin, "Veteran Political Operator Arranges Campaign to Save Anti-Bias Rules for Federal Contractors"
  37. ^ The New York Times, August 17, 1987, Lena Williams, "Administrator of Many Hats"
  38. ^ . Michael Pertshuck, Giant Killers, 1986 (chapter on the 1981-1982 battle to renew and strengthen the Voting Rights Act of 1965
  39. ^ Congressional Quarterly, September 17, 1983, Nadine Cohotas, "Group Reflects Diverse Rights Community"
  40. ^ New Republic, September 6, 1982, Bart Gellman, "The New Old Movement"
  41. ^ Civil Rights Monitor, Leadership Conference Education Fund
  42. ^ Dorothy Height article, May 3, 1995, 45th Annual LCCR Dinner Journal article, "The Neas Years".
  43. ^ Additional LCCR legislative priorities enacted into law between 1981 and 1995 included the Family and Medical Leave Act, the Motor Voter Act (The National Voter Registration Act of 1993), the Voting Accessibility for Disabled and Senior Citizens Act, the Anti-Apartheid Act of 1986, the Martin Luther King, Jr. Holiday Act, The Voting Rights Language Assistance Act of 1992, key provisions of the Economic Equity Act, the Hate Crimes Statistics Act, the Age Discrimination in Employment Claims Assistance Act, the 1989 Minimum Wage Increase, three disability laws which overturned Supreme Court decisions and reinstated the coverage of anti-discrimination provisions to all airlines, the right to sue states for violations of Section 504, and the right of parents to recover attorney fees under the Education for Handicapped Children's Act (now called IDEA), the Gender Equity in Education Act, the Elementary and Secondary Education Act of 1994 (including Chapter One reform), and the Religious Freedom Restoration Act.
  44. ^ Taylor, William (2004). The Passion of My Times: An Advocate's Fifty-Year Journey in the Civil Rights Movement. p. 133.
  45. ^ See Ethan Bronner, Battle for Justice: How the Bork Nomination Shook America, and People Rising
  46. ^ Washington Post, Lois Romano, September 15, 1987, "Leading the Charge on Bork"
  47. ^ New York Times, Lena Williams, August 16, 1987, "Administrator of Many Hats"
  48. ^ Neas also played a leadership role in the unsuccessful effort to defeat the Supreme Court nomination of Clarence Thomas: Opposition to Judge Thomas Nomination; "Thomas Confirmation". C-Span.{{cite web}}: CS1 maint: url-status (link); Another Rights Group Says No to Thomas
  49. ^ D.C. Political Report, 1998 Maryland Congressional and Statewide Results Archived July 5, 2016, at the Wayback Machine Accessed July 13, 2017
  50. ^ National Journal, February 19, 2000, Shawn Zeller, "Ready to Rumble with the Right"
  51. ^ Wall Street Journal, Bob Davis and Robert Greenberger, "Two Old Foes Plot Tactics in Battles Over Judgeships"
  52. ^ CBS "Face the Nation", July 3, 2005, the Resignation of Supreme Court Justice Sandra Day O'Connor"
  53. ^ New York Times, July 3, 2005, David E. Rosenbaum and Lynette Clemetson, "In Fight to Confirm New Justice, Two Field Generals Rally Their Troops Again"
  54. ^ Washington Post, February 2, 2006, Lois Romano and Juliet Eiperin, "The Alito Confirmation Battle"
  55. ^ See also: Roberts Supreme Court Nomination; Supreme Court Watch; John Roberts Supreme Court Nomination; Filbuster Ad Campaign
  56. ^ Senate Government Affairs Committee, May 1, 2001, Testimony on Election Reform
  57. ^ Congressional hearing on US Elections, December 8, 2004, "Voting Irregularities in Ohio"
  58. ^ House Judiciary Committee, March 7, 2007, "Protecting the Right to Vote: Election Deception and Irregularities in Recent Federal Elections"
  59. ^ Ralph Neas and Julian Bond, Pele For the American Way Foundation-NAACP Report: "The Long Shadow of Jim Crow"
  60. ^ a b "Education Strategies". www.c-span.org. Retrieved October 6, 2022.
  61. ^ Leadership Conference on Civil Rights, "Election Protection Makes Debut"
  62. ^ Voter Intimidtion Supression
  63. ^ NCHC 2008-2009 Annual Report
  64. ^ New York Times, February, 2009, Jim Rutenberg, "Liberal Groups Are Flexing New Muscles in Lobby Wars"
  65. ^ Special Otis Bowen Lecture, March 26, 2009, University of Notre Dame, inserted in the Congressional Record by Senator Edward Kennedy, May 5, 2009
  66. ^ Roll Call, June 8, 2009, with Dr. Henry Simmons, "National Plan Must be Product of Capitol Bipartisanship"
  67. ^ Roll Call, December 7, 2009, with Dr. Henry Simmons, "Congress, Tackle Systemwide Cost in Health Reform"
  68. ^ CBS Sunday Morning, March 23, 2010, "Passage of the Affordable Care Act"
  69. ^ Politico, May 27, 2011, "America's Internal Bleeding"
  70. ^ NCHC Letter to Senator Edward Kennedy and Senator Mike Enzi, opposing 12 year exclusivity for biologics, July 8, 2009.
  71. ^ New York Times, September 6, 2011, Reed Abelson, "Neas to Lead GPhA"
  72. ^ National Journal, September 11, 2011, Mike Magner, "Back at the Front"
  73. ^ Biopharma Dive, February 5, 2015, Nicole Gray, "Passing the Torch: Ralph Neas' Tenure at GPhA"
  74. ^ GPhA 2012 Annual Report
  75. ^ Journal of Generic Medicines, Summer, 2012, "A Global Future for Biosimilars"
  76. ^ San Jose Mercury News, Neas op-ed
  77. ^ October 4, 2013, "Biosimilars: Jerry Brown Should Veto Bill that Protects Big Biotech Profits"
  78. ^ New York Times, Andrew Pollack, October 13, 2013, "Governor Brown of Cal. Vetoes Biotech Drug Bill"
  79. ^ The Hill, January 28, 2015, "Trans Pacific Partnership: Ambitious Enough?"
  80. ^ Huffington Post, July 29, 2015, Neas op-ed with Nancy Leamond, AARP, "TPP Threatens Access to Affordable Medicine for People Around the World"
  81. ^ Statement of Ralph G. Neas, opposing pharmaceutical exclusivity provisions of the TPP, press conference with Doctors Without Borders, AARP, AFL-CIO, and Oxfam, December 17, 2015
  82. ^ 2015 GPhA Annual Report
  83. ^ GPhA 2015 Annual Report
  84. ^ The Law School Record, Volume 40, page 33, Fall, 1994
  85. ^ Fellows: Ralph Neas, Harvard University
  86. ^ "Ralph G. Neas". USC Center for the Political Future. Retrieved June 23, 2023.
  87. ^ "Gphaonline.org". www.gphaonline.org. Retrieved December 22, 2020.
  88. ^ New York Times Index, Archive
  89. ^ Washington Post Index
  90. ^ Wall Street Journal Index
  91. ^ C-Span Archives
  92. ^ "Manny Miranda". www.sourcewatch.org. Retrieved December 10, 2016.
  93. ^ "Advise and Dissent". www.snagfilms.com. Retrieved December 10, 2016.
  94. ^ Anthony Giardina, "The City of Conversation", Samuel French Acting Edition, 2014
  95. ^ "1995 Humphrey Award Recipients - Leadership Conference on Civil Rights". Archived from the original on October 24, 2008.
  96. ^ "Our Campaigns - Candidate - Ralph G. Neas". www.ourcampaigns.com. Retrieved December 12, 2016.
  97. ^ "Good Guy Award Dinner". www.c-span.org. Retrieved December 13, 2016.
  98. ^ Leadership Conference 45th Anniversary Journal
  99. ^ Neas biography
  100. ^ "Past Award Winners | Alumni Association: Alumni, Parents, Families & Friends". Archived from the original on August 14, 2015.
  101. ^ "Guide to the William L. Taylor papers, 1954-2009". The George Washington University. Archived from the original on December 13, 2014.
  102. ^ "October 1987 Broadcast Index". tvnews.vanderbilt.edu. Retrieved September 26, 2020.
  103. ^ Washington Post, January 11, 2016, "Battle with Guillain Barre Syndrome"
  104. ^ GBS Foundation 35th Anniversary video
  105. ^ "Estelle Benson, Founder, Wins PSI's President's Award". GBS/CIDP Foundation International. May 5, 2015. Retrieved September 26, 2020.
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