The French Firm Co., L.P.A.
Call Us at (440) 826-1616

Update (after many years of not updating this website):

I have stopped accepting contested matters (litigation), and I am only working part time as I have declared myself to be semi-retired.

Credentials added since website created:

Real Estate Broker - New York

Real Estate Agent - Ohio

Both of these licenses are used primarily as credentials for me to handle real estate transactional matters, mostly with commercial realty.  I am still accepting some commercial real estate transactional work and FAA regulatory matters.

This site  The Web 
 

YOU CRASH 'EM.

WE SUE!

This is Rick French, the AIRLAWYER's website.
 
Rick has practiced law for over 35 years.  His practice has emphasized air crash litigation of all sorts of aircrash, representing victims of air crash disasters since 1987, having represented airlines, aircraft manufactures and the Federal Aviation Administration before "shifting gears" to represent those injured as a consequence of air crashes. 
 
 
 

Welcome to AIRLAWYER.COM, the official Web site of THE FRENCH FIRM Co., L.P.A.

 

The AIRLAWYER is:

RICHARD H. FRENCH, JR.

THE FRENCH FIRM Co., L.P.A.

101 Seminary Street

Berea, Ohio 44017

Phone (440) 826-1616

Fax (440) 826-1617

e-mail: RICK@AIRLAWYER.COM

Attorney French is a pilot and an attorney licensed to practice law in Ohio, California, New York and Washington, D.C., and licensed to practice law before the United States Supreme Court, various United States Courts of Appeals and various United States District Courts. He is a Federal Aviation Administration-licensed Commercial Pilot, with an Instrument Rating and over 1800 hours of flight time logged. Attorney French earned his first pilot's license in 1974.

The AIRLAWYER's Resume follows:

RICHARD H. FRENCH, JR.

THE FRENCH FIRM CO., L.P.A.

101 Seminary Street

Berea, Ohio 44017

Phone (440) 826-1616

Fax (440) 826-1617

E-mail: RICK@AIRLAWYER.COM

 

LEGAL EXPERIENCE:

 

1999 - Internationally Judicially Proclaimed Expert in United States Aviation Law.

1992 – Judicially Declared Expert In Major Tort Disaster Litigation.

1985 – Present:

THE FRENCH FIRM CO., L.P.A.  (Formerly French & Associates Co., L.P.A.)

Berea, Ohio Litigation Attorney - Civil litigation, emphasizing representation of plaintiffs. Full conduct of all phases of investigation, pretrial, discovery, negotiation, settlement, and trial in all courts.  1983 - 1985

GALLAGHER, SHARP, FULTON & NORMAN, Cleveland, Ohio:  Litigation Attorney - Civil litigation, emphasizing defense of aviation-related matters. Full participation in all phases of pretrial, discovery, negotiation, settlement, and trial in state and federal courts.  1980 - 1983

FEDERAL AVIATION ADMINISTRATION, Washington, D.C. Trial Attorney - Air crash and administrative claims, participate in pretrial and discovery, conduct federal court and administrative trials. Draft Federal Aviation Regulations and federal Orders.  1979 - 1980

PRIVATE LEGAL PRACTICE, Los Angeles, California:  Aviation and general practice, sole practitioner.  1979

SANTA MONICA AIRPORT ASSOCIATION, Marina del Rey, CA:  Law Clerk - Prepare evidence and briefs in major aviation, constitutional law, and noise litigation.  1977 - 1978

TUCKER & CODDINGTON, Los Angeles, California:  Law Clerk - Prepare pleadings and memoranda of law; analyze depositions in air crash litigation.  1976 - 1977

LOS ANGELES CITY ATTORNEY'S OFFICE, Los Angeles, CA:  Legal Intern - Law Clerk to city attorney in aviation litigation for Los Angeles airports.

Bar Memberships: California; Ohio; Washington, D.C.; and New York

 

EDUCATION

SOUTHWESTERN UNIVERSITY SCHOOL OF LAW

Los Angeles, CA., Juris Doctor, 1978

 

UNIVERSITY OF SOUTHERN CALIFORNIA

Los Angeles, CA., Bachelor of Arts, 1974

 

PUBLICATION

CASES & MATERIALS ON AVIATION LAW

Sherman & French, 1978

Aviation law casebook.

 

PILOT EXPERIENCE

FAA-licensed Commercial pilot, instrument rated; Over 1800 hours of pilot flight time. Owned and operated Mooney M20E high performance single-engine 4-seat aircraft) and Cessna 150 (two-seat, single-engine) aircraft for many years.

PROFESSIONAL AFFILIATION

Aircraft Owners and Pilots Association (AOPA)

Legal Services Plan, Attorney Service Provider

 

Air crash litigation, the emphasis of Attorney French's law practice since 1980, is normally conducted by highly-trained, aviation litigators who commonly are also aeronautical engineers or pilots, such as Attorney French.

Attorney French has handled aviation law matters or aircraft crash litigation in federal and state courts around the United states, Canada and Europe while representing the United States Government, American and European aircraft, engine, avionics and component manufacturing and service organizations, pilots, passengers, ground victims, widows, orphans, and executors of innocent people killed or injured in air crash disasters.

When an air crash disaster strikes, the National Transportation Safety Board (NTSB) and/or the Federal Aviation Administration's (FAA) aircraft accident investigators go to the site of the accident and conduct an accident site and wreckage examination, commonly assisted by representatives of the aircraft manufacturer, engine manufacturer, subcomponent manufacturers or other technically oriented people whose employers may be target defendants by the victims of the tragedy. The FAA and NTSB do not investigate aircraft crashes for purposes of providing evidence in court for the victims of the crash. The victims' legal representatives perform that function, as well as suing the responsible party to obtain full, fair and adequate compensation for the innocent injured victims and the families of the victims killed in the crash. It is important for the victims to obtain their own attorney representative(s) who will work with technical representatives and investigators with the goal of assisting the victims of the crash. The government investigators have a goal of determining the "Probable Cause" of the crash for purposes of attempting to avoid future mishaps caused by the same thing. The victims' AIRLAWYER must prove to a reasonable degree of scientific certainty the cause of the crash, and that each injury sustained by the victim was proximately caused by the crash, and not by some other event or condition. It is a heavy burden of proof to sustain. The NTSB and FAA do not have a goal of proving the ACTUAL CAUSE of the crash, but merely the Probable Cause of the air crash disaster.

The victim is well advised to retain an attorney such as Attorney Richard H. French, Jr., the AIRLAWYER, a highly skilled, highly trained and experienced air crash litigation attorney who is capable and willing to represent the innocent victim of the tragedy against the people or companies that caused the preventable tragedy and who must compensate the victim(s) and their families under our system of aviation litigation laws in the United States of America.

Few attorneys consistently spend much of their time in aircraft accident wrongful death, personal injury and damages investigation, discovery and litigation, defense of FAA-licensed airman certificate holders (such as pilots and aircraft mechanics).

The AIRLAWYER, Richard H. French, Jr. has devoted a substantial portion of his time over his entire career to aircraft crash litigation. Attorney French also handles vehicular crash cases (automobile accidents, truck crashes, motorcycle accidents, etc.), fire claims and litigation and general litigation.

Attorney French has handled claims or litigation arising from at least 75 separate aircraft crash disasters involving commercial jet aircraft, business jet aircraft, single-engine aircraft, multi-engine piston and jet, turbine-powered large and small airplanes, helicopters, gyroplane, kit plane and homebuilt aircraft. Causes of aviation disasters handled by the AIRLAWYER, RICK FRENCH have included:

1. Midair collisions;

2. Icing, including ground and in-flight engine and airframe icing;

3. Aircraft-truck collision;

4. Engine failures

5. Fuel system failures;

6. Mechanical and electronic failures;

7. Pilot negligence;

8. Weather;

9. Air Traffic Controller negligence;

10. Defective or illegal maintenance;

11. Bogus parts, and many other causes.

Some of the types of aviation disasters the AIRLAWYER has handled include:

1. Commercial jet transport aircraft crashes;

2. Charter aircraft accidents;

3. Business jet crashes;

4. Single-engine aircraft accidents;

5. Multi-engine airplane crashes;

6. Helicopter crashes;

7. Gyroplane crash;

8. Kit built aircraft crash;

9. Skydiver disaster;

10. Floatplane or seaplane crash;

11. Trainer airplane crashes;

12. High Performance airplane crashes;

13. Airliner (transport aircraft) crashes;

Some of the types of aviation clients who the AIRLAWYER has represented include:

1. Passengers in airplane crashes;

2. Ground victims of aircraft accidents;

3. Pilots;

4. Mechanics;

5. Air Traffic Controllers;

6. Flight Service Station Specialists;

7. Widows, orphans, administrator and executors of the estates of victims killed in aircraft accidents, family members, wives and husbands of air crash victims;

8. American and European aircraft manufacturers;

9. Aircraft Jet engine manufacturer;

10. The United States government;

11. Aircraft maintenance facilities; and

12. Aircraft avionics (electronics) facilities;

 

 

Aircraft Accident Investigators work closely with AIRLAWYER French to determine the actual cause of the crash and to unravel the mysteries surrounding the reason(s) why the preventable tragedies occurred. The AIRLAWYER and private aircraft accident investigators such as those who work with AIRLAWYER French are responsible for helping and requiring aircraft manufacturers to build safer aircraft, pilots conducting safer flight operations, mechanics conducting more reliable maintenance and inspection procedures (a particularly important area where safety improvements are needed, considering the aging of the aircraft fleet and resulting higher aircraft maintenance requirements, along with many "Bogus Parts," components sold as aircraft parts, but which do not meet the FAA's strict requirements for aircraft parts because of poor quality, improper licensing or paperwork, improper quality of materials or workmanship, possible illegal recycling of unairworthy parts, etc.).

Lawsuits are filed in federal or state court (if a suitable settlement cannot be negotiated) against the people and companies responsible for causing the air crash tragedy by the AIRLAWYER, Rick French. The AIRLAWYER's goal is to obtain full and fair monetary compensation for the victims of air crash tragedies through the legal system. The AIRLAWYER believes that it is common that insurers and attorneys for the people and companies that caused the air crash disaster refuse to negotiate a settlement in good faith without the pressure, expense, time and inconvenience of major litigation. Defense attorneys, those who represent the people and companies who may have caused the aviation tragedy, are commonly paid by the hour for their legal services, offering a strong disincentive to defense counsel recommending an early settlement. Defense attorneys make more money if they bill out more hours. If a defendant settles early, the defense attorney cannot bill out as many hours as if a settlement is effectuated late in the life of the case. The defense attorney has no personal risk of losing a case until the trial. Thus, settlements immediately before, or during a trial are common.

Attorneys sometimes aggressively solicit the business of the victims of air crash disasters. Some of those attorneys are qualified to handle the air crash litigation; most are not. Many of the attorneys who are able to enter into a fee agreement (contract to provide legal services for the victim, commonly on a contingency fee basis - the attorney keeps a certain percentage of the money ultimately collected for the victims, and does not earn a legal fee if the attorney does not collect money for damages suffered by the victims) with air crash victims, their families or the executor of the Estate of the victim are not themselves experienced and skilled in air crash litigation. These non-aviation attorneys may then retain an experienced air crash attorney such as the AIRLAWYER, Rick French, and split the contingency fee with the aviation attorney. The AIRLAWYER and many of the AIRLAWYER's colleagues who handle air crash litigation accept cases with a "referring" non-aviation attorney.

Air crash victims can often arrange a more advantageous (to the victim) legal fee agreement directly with the experienced aircrash litigator who has knowledge of the special laws, science and physics of aircraft accident litigation and investigation, such as the AIRLAWYER, RICK FRENCH. This is because there is no need to pay a portion of the legal fee to the non-aviation "referring" attorney if the victim contracts directly with the aviation attorney. Just because an attorney can competently handle a divorce, an automobile accident, business, general or criminal litigation does not mean that the attorney is also qualified to handle an air crash claim and litigation.

DISCLAIMER:

This Web page is not intended to, and does not provide legal advice and it does not create an attorney-client relationship. This Web page is provided to offer a general overview of aircraft accident claims and litigation. Each crash is individual and unique, with many unique factual and legal issues, making the giving of aviation law advice specific to the reader of this Web page impossible.

 
 
Rick French
101 Seminary Street
Berea, OH 44017
rick@airlawyer.com  

You crash 'em;  We sue!


 
 
  • Attorney
  • Pilot
  • Former FAA Attorney 
  • Litigator
  • Victim's Advocate
  • Judicially Declared Expert
    In US Aviation Law
  • Honest & Fair
    All Around Good Guy     
  • Air Crash Victims:
    Let Attorney Rick French
    Fight For Justice For You!
  • Air Crash Victims
    Families of Victims and
    Administrators of Air Crash Victims' Estates
    Call Attorney Rick French at (440) 826-1616

email: rick@airlawyer.com

EXPERIENCED AIR CRASH LITIGATOR!

GET THE JUSTICE YOU DESERVE!

GET THE COMPENSATION YOU DESERVE!

The AIRLAWYER is:
RICHARD H. FRENCH, JR. (RICK FRENCH)
THE FRENCH FIRM Co., L.P.A.
101 Seminary Street
Berea, Ohio 44017
Phone (440) 826-1616
Fax (440) 826-1617
e-mail: RICK@AIRLAWYER.COM

Attorney French is a pilot and an attorney licensed to practice law in Ohio, California, New York, Washington, DC, and licensed to practice law before the United States Supreme Court, various United States Courts of Appeals and various United States District Courts, and many special admissions to practice law for individual cases. He is a Federal Aviation Administration-licensed Commercial Pilot, with an Instrument Rating and over 1800 hours of flight time logged. Attorney French earned his first pilot's license in 1974.

Air crash litigation, the emphasis of Attorney French's law practice since 1980, is normally conducted by highly-trained, aviation litigators who commonly are also aeronautical engineers or pilots, such as Attorney French.

Attorney French has handled aviation law matters or aircraft crash litigation in federal and state courts around the United states, Canada and Europe while representing the United States Government, American and European aircraft, engine, avionics and component manufacturing and service organizations, pilots, passengers, ground victims, widows, orphans, and executors of innocent people killed or injured in air crash disasters.

THE GOVERNMENT'S AIR CRASH INVESTIGATION IS NOT SUFFICIENT FOR THE VICTIMS OF THE CRASHES!
When an air crash disaster strikes, the National Transportation Safety Board (NTSB) and/or the Federal Aviation Administration's (FAA) aircraft accident investigators go to the site of the accident and conduct an accident site and wreckage examination, commonly assisted by representatives of the aircraft manufacturer, engine manufacturer, subcomponent manufacturers or other technically oriented people whose employers may be target defendants by the victims of the tragedy. The FAA and NTSB do not investigate aircraft crashes for purposes of providing evidence in court for the victims of the crash. The victims' legal representatives perform that function, as well as suing the responsible party to obtain full, fair and adequate compensation for the innocent injured victims and the families of the victims killed in the crash. It is important for the victims to obtain their own attorney representative(s) who will work with technical representatives and investigators with the goal of assisting the victims of the crash. The government investigators have a goal of determining the "Probable Cause" of the crash for purposes of attempting to avoid future mishaps caused by the same thing. The victims' AIRLAWYER must prove to a reasonable degree of scientific certainty the cause of the crash, and that each injury sustained by the victim was proximately caused by the crash, and not by some other event or condition. It is a heavy burden of proof to sustain. The NTSB and FAA do not have a goal of proving the ACTUAL CAUSE of the crash, but merely the Probable Cause of the air crash disaster.

AIR CRASH VICTIMS NEED AN EXPERIENCED AVIATION ATTORNEY.
The victim is well advised to retain an attorney such as Attorney Richard H. French, Jr., the AIRLAWYER, a highly skilled, highly trained and experienced air crash litigation attorney who is capable and willing to represent the innocent victim of the tragedy against the people or companies that caused the preventable tragedy and who must compensate the victim(s) and their families under our system of aviation litigation laws in the United States of America.

MOST LAYWERS ARE NOT AVIATION LAW EXPERTS; RICK FRENCH IS AN AVIATION LAW EXPERT.
Few attorneys consistently spend much of their time in aircraft accident wrongful death, personal injury and damages investigation, discovery and litigation, defense of FAA-licensed airman certificate holders (such as pilots and aircraft mechanics).

The AIRLAWYER, Richard H. French, Jr. has devoted a substantial portion of his time over his entire career to aircraft crash litigation. Attorney French also handles vehicular crash cases (automobile accidents, truck crashes, motorcycle accidents, etc.), fire claims and general litigation.

Attorney French has handled claims or litigation arising from at least 75 separate aircraft crash disasters involving commercial jet aircraft, business jet aircraft, single-engine aircraft, multi-engine piston and jet, turbine-powered large and small airplanes, helicopters, gyroplane, kit plane and homebuilt aircraft.

Types of aviation disasters handled by the AIRLAWYER (including claims and/or litigation), RICK FRENCH have included:
1. Midair collisions;
2. Icing, including ground and in-flight engine and airframe icing;
3. Aircraft-truck collision;
4. Engine failures
5. Fuel system failures;
6. Mechanical and electronic failures;
7. Pilot negligence;
8. Weather;
9. Air Traffic Controller negligence;
10. Defective or illegal maintenance;
11. Bogus parts, and many other causes.

Some of the types of aviation disasters the AIRLAWYER has handled include:

1. Commercial jet transport aircraft crashes;
2. Charter aircraft accidents;
3. Business jet crashes;
4. Single-engine aircraft accidents;
5. Multi-engine airplane crashes;
6. Helicopter crashes;
7. Gyroplane crash;
8. Kit built aircraft crash;
9. Skydiver disaster;
10. Floatplane or seaplane crash;
11. Trainer airplane crashes;
12. High Performance airplane crashes;
13. Airliner (transport aircraft) crashes;

Some of the types of aviation clients who the AIRLAWYER has represented include:
1. Passengers in airplane crashes;
2. Ground victims of aircraft accidents;
3. Pilots;
4. Mechanics;
5. Air Traffic Controllers;
6. Flight Service Station Specialists;
7. Widows, orphans, administrator and executors of the estates of victims killed in aircraft accidents, family members, wives and husbands of air crash victims;
8. American and European aircraft manufacturers;
9. Aircraft Jet engine manufacturer;
10. The United States government;
11. Aircraft maintenance facilities; and
12. Aircraft avionics (electronics) facilities;

AIR CRASH INVESTIGATIONS:
Aircraft Accident Investigators work closely with AIRLAWYER French to determine the actual cause of the crash and to unravel the mysteries surrounding the reason(s) why the preventable tragedies occurred. The AIRLAWYER and private aircraft accident investigators such as those who work with AIRLAWYER French are responsible for helping and requiring aircraft manufacturers to build safer aircraft, pilots conducting safer flight operations, mechanics conducting more reliable maintenance and inspection procedures (a particularly important area where safety improvements are needed, considering the aging of the aircraft fleet and resulting higher aircraft maintenance requirements, along with many "Bogus Parts," components sold as aircraft parts, but which do not meet the FAA's strict requirements for aircraft parts because of poor quality, improper licensing or paperwork, improper quality of materials or workmanship, possible illegal recycling of unairworthy parts, etc.).

AIR CRASH LITIGATION
Lawsuits are filed in federal or state court (if a suitable settlement cannot be negotiated) against the people and companies responsible for causing the air crash tragedy by the AIRLAWYER, Rick French. The AIRLAWYER's goal is to obtain full and fair monetary compensation for the victims of air crash tragedies through the legal system. The AIRLAWYER believes that it is common that insurers and attorneys for the people and companies that caused the air crash disaster refuse to negotiate a settlement in good faith without the pressure, expense, time and inconvenience of major litigation. Defense attorneys, those who represent the people and companies who may have caused the aviation tragedy, are commonly paid by the hour for their legal services, offering a strong disincentive to defense counsel recommending an early settlement. Defense attorneys make more money if they bill out more hours. If a defendant settles early, the defense attorney cannot bill out as many hours as if a settlement is effectuated late in the life of the case. The defense attorney has no personal risk of losing a case until the trial. Thus, settlements immediately before, or during a trial are common.

AIR CRASH VICTIMS SHOULD HIRED SKILLED, EXPERIENCED AIR CRASH LITIGATIONS, LIKE RICK FRENCH.
Attorneys sometimes aggressively solicit the business of the victims of air crash disasters. Some of those attorneys are qualified to handle the air crash litigation; most are not. Many of the attorneys who are able to enter into a fee agreement (contract to provide legal services for the victim, commonly on a contingency fee basis - the attorney keeps a certain percentage of the money ultimately collected for the victims, and does not earn a legal fee if the attorney does not collect money for damages suffered by the victims) with air crash victims, their families or the executor of the Estate of the victim are not themselves experienced and skilled in air crash litigation. These non-aviation attorneys may then retain an experienced air crash attorney such as the AIRLAWYER, Rick French, and split the contingency fee with the aviation attorney. The AIRLAWYER and many of the AIRLAWYER's colleagues who handle air crash litigation accept cases with a "referring" non-aviation attorney.

AIR CRASH VICTIMS SHOULD DIRECTLY RETAIN RICK FRENCH.
Air crash victims can often arrange a more advantageous (to the victim) legal fee agreement directly with the experienced aircrash litigator who has knowledge of the special laws, science and physics of aircraft accident litigation and investigation, such as the AIRLAWYER, RICK FRENCH. This is because there is no need to pay a portion of the legal fee to the non-aviation "referring" attorney if the victim contracts directly with the aviation attorney. Just because an attorney can competently handle a divorce, an automobile accident, business, general or criminal litigation does not mean that the attorney is also qualified to handle an air crash claim and litigation.

RICHARD H. FRENCH, JR.'s Resume:

LEGAL EXPERIENCE:

1999 - Internationally Judicially Proclaimed Expert in United States Aviation Law.

1992 – Judicially Declared Expert In Major Tort Disaster Litigation.

1985 – Present: THE FRENCH FIRM CO., L.P.A. (Formerly French & Associates Co., L.P.A.), Berea, Ohio
Litigation Attorney - Civil litigation, emphasizing representation of plaintiffs. Full conduct of all phases of investigation, pretrial, discovery, negotiation, settlement, and trial in all courts.

1983 - 1985: GALLAGHER, SHARP, FULTON & NORMAN, Cleveland, Ohio: Litigation Attorney - Civil litigation, emphasizing defense of aviation-related matters. Full participation in all phases of pretrial, discovery, negotiation, settlement, and trial in state and federal courts.

1980 - 1983: FEDERAL AVIATION ADMINISTRATION, Washington, DC Trial Attorney - Air crash and administrative claims, participate in pretrial and discovery, conduct federal court and administrative trials. Draft Federal Aviation Regulations and federal Orders.

1979 - 1980: PRIVATE LEGAL PRACTICE, Los Angeles, California: Aviation and general practice, sole practitioner. 1979

SANTA MONICA AIRPORT ASSOCIATION, Marina del Rey, CA: Law Clerk - Prepare evidence and briefs in major aviation, constitutional law, and noise litigation. 1977 - 1978

TUCKER & CODDINGTON, Los Angeles, California: Law Clerk - Prepare pleadings and memoranda of law; analyze depositions in air crash litigation.

1976 - 1977: LOS ANGELES CITY ATTORNEY'S OFFICE, Los Angeles, CA: Legal Intern - Law Clerk to city attorney in aviation litigation for Los Angeles airports.

Bar Memberships: California; Ohio; Washington, D.C.; and New York. Admitted to practice law before the United States Supreme Court, numerous U.S. Courts of Appeal (federal appellate courts), numerous United States District Courts (federal trial courts) and eligible for one-time admissions to practice law in most of the United
States for a particular case.
EDUCATION:

SOUTHWESTERN UNIVERSITY SCHOOL OF LAW
Los Angeles, CA., Juris Doctor, 1978

UNIVERSITY OF SOUTHERN CALIFORNIA
Los Angeles, CA., Bachelor of Arts, 1974

PUBLICATION
CASES & MATERIALS ON AVIATION LAW
Sherman & French, 1978
Aviation law casebook.

PILOT EXPERIENCE
FAA-licensed Commercial pilot, instrument rated; Over 1800 hours of pilot flight time. Owned and operated Mooney M20E (high performance single-engine 4-seat aircraft) and Cessna 150 (two-seat, single-engine) aircraft for many years.

PROFESSIONAL AFFILIATIONS:
Aircraft Owners and Pilots Association (AOPA)
Legal Services Plan, Attorney Service Provider
Ohio State Bar Association
State Bar of California
Washington DC Bar Association
Bar of the State of New York
Ohio Academy of Trial Lawyers


DISCLAIMER:
This Web page is not intended to, and does not provide legal advice and it does not create an attorney-client relationship. This Web page is provided to offer a general overview of aircraft accident claims and litigation. Each crash is individual and unique, with many unique factual and legal issues, making the giving of aviation law advice specific to the reader of this Web page impossible.


ATTORNEY RICK FRENCH ON ABC's NIGHTLINE