What happened to the lost crew of the “Sarah Joe”?

The five friends set out for a day of fishing

A jaw bone was found 10 years later


On February 11th, 1979, in the town of Hana on the Hawaiian island of Maui, five local men left their small village to go pleasure fishing on a 17-foot Boston whaler named the ‘Sarah Joe’. The men, Benjamin Kalama, Ralph Malaiakini, Scott Moorman, Patrick Woesner, and Peter Hanchett, were all experienced fisherman. They left around 10 in the morning. It was a clear day and the weather was calm. But in the early afternoon, the winds suddenly changed direction, the sign of a pending storm. Peter’s father, John Hanchett Sr., grew concerned:

“I told Dave we better get down the coast to see if we could spot those boys and wave them in.”

Benjamin Kalama and Patrick Woesner

As the storm grew, John and a friend went in search of the Sarah Joe:

“By this time it was really blowing a gale. And the rain was beginning to come down and it was storming. We went out of Hana Harbor about a half a mile and then down the coast, and I still didn’t see any sign of the boys. The oceans were fierce; I’ve never seen it get that rough.”

The next day, John continued the search with the help of marine biologist John Naughton. Their search that day would prove fruitless. Nobody else had reported seeing the Sarah Joe. The following day, the Coast Guard joined the search. But, according to Capt. Jim Cushman of the U.S. Coast Guard, they really didn’t know where to look:

“The initial place where we started searching was very ill-defined, because we weren’t really sure exactly where the Sarah Joe had gone fishing. So it encompassed a relatively large area, initially that first day, and then the area got bigger and bigger and bigger. When the search was finally suspended five days later, we had searched 73,000 square miles.” 

Ralph Malaiakini and Peter Hanchett

Over the next few weeks, the Hana residents combed the local beaches, looking for any sign of the missing Boston whaler. When no trace was found, their loved ones eventually gave up all hope.

Then, ten years later, on September 9th, 1988, an incredible coincidence suddenly led to a major break in the case. Two thousand miles west of Hawaii in the Marshall Islands, John Naughton, the very same marine biologist who had searched for the Sarah Joe a decade earlier, was on a wildlife expedition. On a deserted atoll called Taongi, he spotted a small boat. John and his crew went onshore to inspect the wreckage:

“On the boat, there were still a few letters and numbers from the registration number, and immediately I saw that it started with an ‘HA’, which indicates that the boat was registered in the Hawaiian Islands.” 

Scott Moorman

About 60 yards away, John and his crew came upon another startling discovery, a shallow grave:

“When we got up there we could see immediately that there was a human jaw bone protruding out of the pile of rocks. At that time, we had no way of knowing that the gravesite was associated with the wrecked whaler.”

After finding no sign of anyone else on the island, the men contacted the Coast Guard. They ran a check of the registration number and made a positive ID: it was the Sarah Joe.

A storm kicked up soon after they left

The grave was excavated and parts of a human skeleton were uncovered. Dental records identified the remains as Scott Moorman, one of the five missing men. Capt. Cushman explains a strange clue also found buried with the skeleton:

“It was a sheaf of paper, and I’d say a book, except it was not bound. Probably three inches by three inches by maybe 3/4 of an inch thick. But between each one of these pieces of paper, there was a very small square piece of tin foil material. We have not been able to determine who placed that there or, what purpose it serves.”

Their boat was found 2000 miles away

Experts say that the Sarah Joe could have drifted 2,000 miles to the Marshall Islands.  If so, it would have arrived in about three months. But according to the brother of one of the missing men, a U.S. government survey of Taongi a full six years after the men disappeared found no trace of the Sarah Joe. If this is true, where was the boat in the time between its disappearance and the government survey? Who buried Scott Moorman?  And what is the significance of the pad of paper found in the grave?

These unanswered questions have left some wondering if any of the other men might still be alive.

Watch this case now on Amazon Prime in season two with Robert Stack and in season six with Dennis Farina. Also available on YouTube with Dennis Farina. Various seasons available now on Hulu.




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    My guess is that with the start of storm they were met by a accident like engin failure. It delayed their return and then storm took over. Next they tied themselves with ropes to boat. It perhaps kept them alive but when storm was over they were gone miles away. They have some food but not enough so they started to die one by one. Moorman kept throwing dead bodies in sea. By the time some Asian fishermen found him he was dead too. They buried him in the deserted island but kept theboat in use for sometime. When boat became unserviceable they towed it to the grave of Moorman.


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    veronica Lam

    The paper they found under the rocks in the shallow grave of Scott are joss paper, also known as ghost money, are sheets of paper and/or paper-crafts made into burnt offerings which are common in various Asian religious practices including the veneration of the deceased on holidays and special occasions. Joss paper, as well as other papier-mâché items, are also burned or buried in various Asian funerals, to ensure that the spirit of the deceased has lots of good things in the afterlife.


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    The papers with tin foil was possibly an attempt to make a homemade battery of some sort.. OR a means of keeping track of days weeks lost at sea. I believe there’s still several native tribes on a few atolls that practice cannibalism in rituals, etc. Which could explain bones being buried and dispersed. Then there’s also the fact the government was doing testing of the atom bomb just 10 years or so prior to the SarahJo’s dissapearence. ….


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    Does anyone know if the boat is still on the atoll?


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    Anyone count how many pieces of silver foil, could it have represented 30 pieces of silver? and in other words it was a message left by someone?


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    Dave G

    Wonder if they checked the metal for fingerprints?


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    Those square pieces of paper with a square tin in the middle, is a buddhist tradition, youre suppose to burn it to help the spirit of the passing..its suppose to represent money.


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    Keith K.

    The sheaf of paper/foil found in Scott Moorman’s grave resembles an early form of battery called a “voltaic pile,” invented by Alessandro Volta around 1790. It requires alternating layers of dissimilar metals such as copper and zinc, separated by paper which is soaked in salt water or a weak acid. With enough layers it could give a person a shock but it couldn’t produce enough power to do anything useful such as light a lamp or power a radio. Very curious.


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    Alvin Wong

    The United States Coast Guard used three trained pigeons in a glass bubble under the rescue helicopter while searching for the Sara Joe. If I recall correctly two of the three pigeons did indicate a distress situation to the trainer but the crew could not verify what the pigeons saw. Had they found the Sara Joe and five men alive, “Project Sea Hunt” would have proven its worth.


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    I am assuming that Scott was the only survivor or survived the longest before succumbing to the elements. Scott’s body remained in the boat while lost at sea. After years of drifting only bones remained. The boat washes ashore and is found by someone who does the decent thing and buries the remains. The paper was just a custom from that persons belief system. For some unknown reason they did not want, or feel it was necessary to report what they had found.


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    1) Sarah Joe fishing boat was missing.
    2) It was found 10 years later on Marshall Island.
    3) The dead body of Scott Moorman was also found.
    4) Found with the body was a stack of white paper. Each paper has a small square tin foil in the middle. The tin foil is silver in color.
    My Suggestions:
    1) These papers are used during ancestral worship for dead family members. The ritual is practiced in Taiwan and China.
    2) When I was a kid living in Taiwan, I saw papers similar to these. Sometimes the small square tin foil in the middle was gold color. I was told that these papers represent the money that dead people use while lingering on earth.
    3) Asian people believe that the spirits of the dead can linger on earth.
    4) Many who live in the States also saw the spirits of the dead.
    5) According to the Gospels of Matthew, Mark, and Luke, the spirits of the dead (human spirits) not only linger on earth, they also possess living people. The Greek words used to describe the spirits of the dead are “unclean spirits”. According to Google, “unclean spirits” are unclean because they rejected the Jewish cleansing ritual prescribed by the Law of Moses. The Greek words imply that unclean spirits are not fallen angels, because fallen angels were not given the Law of Moses to obey.
    6) In order to transfer the money to dead people, the tin foil papers need to be burned to ashes during ancestral worship.
    7) The person who put the papers on Mr. Moorman’s grave may be an Asian who practices or is familiar with ancestral worship


  12. Avatar


    The squares of tinfoil separated by paper make a crude capacitor and, when coupled with a coil of wire make a resonant circuit needed to make a radio. All that would be needed would be a diode, which could be made from an oxidized penny. It would also need a speaker, but if they had any “walkman” style player, etc.

    This circuit does not need a battery and would only be a receiver.

    Just my tuppence…


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    Laura Denny

    I was driving down the Hana Hwy with my boyfriend, a brother of one of these boys who died, Patrick Woesner. My boyfriends name was Hank Woesner. We were coming for a visit. When we arrived we heard about the boat being lost at sea. We spent the next two weeks searching for this boat along with the whole town of Hana, and the Coast Guard. At the Pavillion we ate Poi and fish and sat through three demonimations of church ceremonies. Once a Kahuna came to speak at the Pavillion and the wind and rain roared the whole place into silence as it sucked the tarps, which were protecting us, inward. I loved the Hawaiian ceremonies, as we would hold hands and sing.

    In 2006 I returned to Hana and searched out the pavilion and saw the plaque set in stone for the Sara Joe. I tried to meet up with Hanks other brother but he wasn’t home. I learned that the town of Hana still mourns and grieves this tragic loss.

    While at Mount Haleakala with my daughter I took some Lava. My daughter Caitlin stayed on in Maui. After I took the lava she got into a car accident on the Hana Hwy. The guy who picked her up and helped her was a relative of Tiny, the big Hawaiian so moved by this tragedy. I remember him so well. Tiny was huge and cried big tears. I liked him a lot even though he made me sit in the back of the bus as I was a Haole. I sent the lava back and Caitlin came home with a tee shirt from Tiny’s restaurant. I think he was dead by then but his family still remembered and the hull of the Sara Joe was in the yard in which Caitlin stayed. I find this one of the most mysterious stories of my life.


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      John Christolos Jr.

      Hi Laura,
      My name is John Christolos Jr. I lived in Oahu 1963-66 near Pearl Harbor when my dad was in the Marine Corps. I’m deeply saddened reading this as I’m almost positive this was my friend Pat after seeing his picture and you saying you were with his older brother Hank which was Pats brothers name. .His other older brothers name was Mike who I knew too. Right around when this happened I got a strange feeling inside and was thinking a lot about him and tried to contact him unsuccessfuly since then which now I understand why I almost gave up but stumbled upon this story thru Google. Pat Woesner was my best friend and we surfed and went to Holy Family School during 7th and 8th grade. Pats dad was a Colonel in the Marine Corps then. My mom was like Pats 2nd mom and she always liked him a lot and reminisced those days in Hawaii until she passed away in 1993 of cancer. She loved taking us to surf near Fort Derrusey I started surfing again right before my mom passed away and she was so happy when I told her. For my closure could you please confirm that based on everything I said that this was in fact my old best friend Pat Woesner. Also if you have any of his families email addresses or contact information, I would love to get it and contact them. My phone number is 925 212-6174 if you want to call me. Thank you very much for your story as it helped me with my long quest to find out finally what happened to Pat.


      • Avatar

        John Christolos Jr

        I’ve looked at other news clips and videos about this tragic loss. I’m now 100% sure this was my old best friend Patrick Woesner who I’ve been trying to contact sadly since this happened. We surfed together for a few years in Oahu, and I still share l stories of those great memories to people I still surf with. If any family members of Patrick see this message, I would love to hear from you. I live in Oakley California and I’m on Facebook and my phone Number is listed in the phone book. Aloha!!


    • Avatar


      I was doing a little bit of family research, and it is crazy to find your comment, Laura. Pat would have been my uncle. Hank is my father.


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    David Allen

    The layers of foil sandwiched between paper might have been an incompleted attempt to make a battery, perhaps to power a signal light, radio, or start a fire. See http://www.instructables.com/id/1-Volt-Cell-from-2-Pennies-and-Foil/

    jaigurudavid at yahoo d o t com


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    Alice Chan

    Those paper with the silver square in the center is Silver paper: for Underworld or Money for the dead people. The paper is generally referred to as the gold and silver bullion, is used for ancestor worship, land, landlords with the paper-based gold and silver go tantamount valuables such as gold or silver sun between. The clothing store gold and silver paper is paper piles, each stack of paper is gold, silver paper, gold paper …… and so on with each other down the row.


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    Mrs. Yang

    The loose paper or loose note pad paper, looks like what I would call spirit money when translated into English. Please go visit a lot of Asian store, they have different kinds of spirit paper money. When I say spirit money, these papers are papers that are burn to the dead, in the spirit world, these papers are money to them. In our culture and in some Asian culture, when someone pass away we give these money to them and burn it so they can have it. *note again, there are many different kinds of these papers, the one that was show on TV, I haven’t seen but it does look a lot like all the other one found in Asian stores. Visit big stores if none is find in small ones.


    • Avatar


      There are three main categories of spirit money: The first is cash in the form of colorful bills usually issued in astronomically high denominations. These are meant for recently deceased relatives and unknown spirits who have nobody to pray for them, also known as “hungry ghosts.” The second is silver leaf paper which is meant for highly revered ancestors and finally gold leaf paper which is meant for Chinese folk gods or the Jade Emperor himself, the supreme ruler of the afterlife.


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  18. Avatar

    Steve Jenkins

    Scott was a class mate of mine at James Monroe H.S. Any new info on the case?


    • Avatar

      Paul Kramer

      The tin or foil found was something Scott may had with him or something from the tackle or food wraper to use as a means of communication from sea to land or air like a mirror


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We rely on you to update and correct your Personal Data.  If you are a user of our Sites, subscriber to [CMP product], purchaser of CMP products and services, you can review, update and correct your information directly on CMP’s website or by contacting us using the information in the “Contact Information” section below.


Typically, we retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.  This may include retaining your Personal Data indefinitely, even after you are no longer a CMP member, in order to provide you with future marketing opportunities and other purposes, as well as to comply with our legal obligations, resolve disputes, or enforce any of our agreements.  


Please note that you can request, at any time, that we delete your Personal Data.  All requests must be directed to the contact in the “Contact Information” section below.  We can decide to delete your Personal Data if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other members, individuals, or third parties.  When we delete your Personal Data, it will be removed from our active databases or anonymized so that the data is no longer identified with you, but the data may remain in our archives if CMP determines that it is not practical or possible to delete it.

Your Personal Data is processed in the United States, where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your data.  By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States.

You, as the data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data does not comply with legal requirements.

In the event we determine the occurrence of a data security incident, we will notify you by email, US mail, telephone, or other means as permitted by law.

If you have questions, comments, or complaints concerning our privacy practices or if you wish to change, access, or remove your Personal Data, please contact us as indicated below.  We will attempt, where practical, to respond to your requests and to provide you with additional privacy related information.

Cosgrove Meurer Productions, Inc. is the owner of this Website and retains all ownership rights to the information collected at this Website. Cosgrove Meurer Productions, Inc. reserves the right to change, modify, add, or remove provisions of this Privacy Statement. Any changes to this Privacy Statement will be posted here, and we encourage you to check back from time to time. In addition, Cosgrove Meurer Productions, Inc. will notify registered users of changes as they occur.

We allow third-party companies to serve ads and/or collect certain anonymous information when you visit our web site. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other Web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit networkadvertising.org. Your use of the site constitutes your agreement to accept cookies, beacons and third-party advertising. Cosgrove Meurer Productions, Inc. assumes no responsibility for third-party ads.

ARTICLE 1. Personalization
1.1 We may use the contact information you give us to better tailor your Website experience to your interests, and to send you information about Cosgrove Meurer Productions, Inc. and its services as well as promotional material on behalf of some of our partners. We may use other information that you provide to us to show you content in which you may be interested and to display the content according to your preferences. We will also share this information within Cosgrove Meurer Productions, Inc. in order to enhance your experience on this and other Cosgrove Meurer Productions, Inc. Websites.
1.2 In addition, we may share this information with advertisers or other third parties that are not part of the Cosgrove Meurer Productions, Inc. family on an aggregate or other basis that does not disclose your identity or contact information.

ARTICLE 2. Online Surveys/Contests
2.1 From time to time, we may conduct online surveys and contests. These may ask you for contact information (like name or email address) and demographic information (like zip code or age).
2.2 We may use this contact information from our surveys and contests to provide you with information about our company and promotional material on behalf of some of our partners, and to contact you when necessary.

ARTICLE 3. Shopping/Commercial Services
3.1 This Website may offer shopping services, which may be offered by us or by a firm that operates a store under contract with us. If our Website offers shopping or other commercial services, you will use a customer order form to request information, products, and services. The order form will ask you to give us contact information (like name or email address), financial information (like account or credit card numbers), and demographic information (like zip code or age).

3.2 We will use the financial information that you provide to bill you for products and services. By giving our Website your credit card and related personal information, you are authorizing our store to give that information to the merchant and credit card company in order to confirm and fulfill your order.

3.3 We will use contact information from the order form to fulfill your orders. We may also use contact data to get in touch with you when necessary. We will not otherwise use or distribute your financial information without your prior approval.

ARTICLE 4. Public forums
4.1 This Website may make available chat rooms, blogs, forums, message boards, and news groups. Please remember that any information that you disclose in these areas becomes public information and you should exercise caution when deciding to disclose your personal information. Information disclosed by you or by others enters the public domain and may be freely used by any other persons or entities using the site.

ARTICLE 5. Information Sharing With Third Parties
5.1 From time to time we may enter into a special relationship with another company that is not owned by Cosgrove Meurer Productions, Inc. to provide additional features at this Website. These special relationships may include “powered by” partners, business partners, sponsors, and co-branded sites (referred to here as “co-branded pages”). These might include, for example, pages that share our name and that of another entity. You should look for a specific privacy statement on any such co-branded page. Any personal information that you provide when signing up at one of those co-branded pages may be shared with our third party partner. You should also check our partner’s website for information regarding its privacy policies.

5.2 Also, the nature of some features of our Website may require that we share personal information about you with persons or companies outside of Cosgrove Meurer Productions, Inc. For example, this may occur at a feature that enables you, via our Website, to ask questions of persons or entities that are not part of Cosgrove Meurer Productions, Inc. By responding to those features of the site, whether by email or direct entry of information on our Website, you are consenting to our transferring that information to such persons or entities.

5.3 With respect to specific registration modules, like contests, we may disclose personal information collected, and we may post a conspicuous statement on the registration module to the effect that we will be disclosing the information collected with third parties.

5.4 Finally, we may share any of the information collected from you with these other non- Cosgrove Meurer Productions, Inc companies in an aggregate basis. The aggregated information is not linked to any information that can identify you.

ARTICLE 6. IP Address and Log Files
6.1 We may use your IP address to administer our Website, to help diagnose problems with our server, to analyze trends, to track users’ webpage movements, to help identify you and your shopping cart, and to gather broad demographic information for aggregate use.

ARTICLE 7. Cookies
7.1 This Website may use a standard technology called a “cookie” to collect information about how you use the Website. Cookies reside on your computer and help our Website to recognize your computer’s browser as a previous visitor. This information allows us to customize delivery of information. For example, our Website may use cookies to save and remember registration information or preferences that you may have set while browsing the Website, to keep track of your shopping cart, to ensure you don’t see the same ad content repeatedly, to deliver content specific to your interests, and to save your password so you do not have to re-enter it each time you visit our site. We use cookies only to gather information as indicated in this policy.

7.2 In addition, on occasion our site may also set a “session cookie” which helps us administer the Website. The session cookie expires when you close your browser and does not retain any information about you after it expires.

7.3 Finally, we may also use an ad network provider to help present advertisements on this and other Cosgrove Meurer Productions, Inc. websites. This ad network provider, like other advertising service vendors, uses cookies, web beacons, or similar technologies on the hard drive of your computer to serve you advertisements tailored to interests you have shown by browsing on this and other sites you have visited, and to determine whether you have seen a particular advertisement before and to avoid sending you duplicate advertisements. In doing so, the provider collects non-personal data such as your browser type, your operating system, web pages visited, time of visits, content viewed, ads viewed, and other clickstream data. The use of cookies, web beacons, or similar technologies by these ad network providers is subject to their own privacy policies, not ours, and Cosgrove Meurer Productions, Inc. assumes no responsibility for the collection or use of such information.

ARTICLE 8. Banner Advertising
8.1 We have contracted with an ad-service to place banner advertising on our Website. All of the data provided and generated by the ad-server software remains in our possession. This feature of our Website may, on occasion, set “cookies” on your computer. Any information collected or stored by the ad-service or the cookies is treated in the same manner as other information described in this statement.

ARTICLE 9. Children’s Personal Information
9.1 Consistent with the Children’s Online Privacy Protection Act:

9.1.1 This site does NOT collect, use, or disclose personal information (including online contact information) of children under the age of thirteen (13).

9.1.2 In the event that a child under the age of 13 attempts to register on our site, we will NOT accept the registration and will delete information received from the child.

9.1.3 In the event that a child posts personal information in a public forum such as a chat room, we will attempt to delete that information once we become aware of it.

ARTICLE 10. Security of Your Personal Information
10.1 Cosgrove Meurer Productions, Inc. employs reasonable security measures consistent with standard industry practice, for information collected through this Website. We believe that we have adequate security measures in place in our physical facilities to protect against the loss, misuse, or alteration of the information we collect on our Website. We also use internal protections to limit access to users’ personal information to only those employees who need the information to perform a specific job.

ARTICLE 11. Sale or Merger
11.1 If this Website is sold to, or merges with, another company not owned by Cosgrove Meurer Productions, Inc., you should expect that some or all of the information collected from this Website may be transferred to the buyer/surviving company. If so, CMP will seek to obligate the acquiring company to use any personal information transferred by this Website in a manner consistent with this statement, but cannot guarantee that it will be able to impose that requirement or that the acquiring company will comply.

ARTICLE 12. Legal Process
12.1 You should be aware that Cosgrove Meurer Productions, Inc. may be required to disclose your personal information to the government or third parties under certain circumstances, such as in court or regulatory proceedings.

ARTICLE 13.  Contacting the Website

13.1        If you have any questions about this Privacy Statement, the practices of this Website, or your dealings with this Website, please contact us at: unsolved@unsolved.com.

ARTICLE 14.  general information

14.1        Choice of Law:  This Agreement and the Additional Terms shall be governed by, construed and enforced in accordance with the laws of the State of California , as it is applied to agreements entered into and to be performed entirely within such state, without regard to conflict of law principles.

14.2        Choice of Forum:  You agree that any cause of action you or Cosgrove Meurer Productions, Inc. brings to enforce this Agreement and/or the Additional Terms, or in connection with any matters related to this Website and/or the Privacy Statement, shall be submitted to arbitration in the County of Los Angeles, State of California, United States of America in accordance with the commercial rules and regulations of the American Arbitration Association then in effect (as amended herein), provided that said arbitration shall be heard before a single arbitrator, who shall be a retired judge, selected pursuant to such rules and regulations, and shall be conducted on an expedited basis and in confidence. The arbitrator’s decision shall be controlled by the terms and conditions of this agreement and any other agreements I may enter into with you, and shall be final and binding, and shall provide for each party to bear its own costs of arbitration and attorneys’ fees.  Each party expressly waives any right to a jury.  Judgment upon the award of the arbitrator may be entered or enforced in any court of competent jurisdiction. 

14.4        If any provision of this Agreement, or the application thereof to any person or circumstances, is held invalid or for any reason unenforceable then such provision shall be deemed superseded by a valid, enforceable provision that matches, as closely as possible, the original provision, and the other provisions of this Agreement shall remain in full force and effect.  The failure of either party to insist upon strict performance of any provision of this Agreement shall not be construed as a waiver of any provision or right.  Unless expressly provided otherwise, this Agreement is the entire agreement between you and Cosgrove Meurer Productions, Inc. with respect to the use of this Website and shall not be modified except in writing, signed by an authorized representative of Cosgrove Meurer Productions, Inc.

ARTICLE 15.  European Union and Other Foreign Nations

15.1        This Website is governed by and operated in accordance with the laws of United States of America and is intended for enjoyment of residents of the United States.  Cosgrove Meurer Productions, Inc. makes no representation that this Website is governed by or operated in accordance with the laws of other nations.  By using this Website and submitting any personal information, visitors from outside of the United States acknowledge this Website is subject to U.S. law, consent to the transfer of personal data to the U.S., and waive any claims that may arise under their own national laws.