Dallas Criminal Defense Lawyer Blog

Kaufman Bar Meeting- 9/15

2010-09-01T14:59:33Z

The Kaufman County Bar will have it's next meeting on 9/15 in the law library. Chris Souza will present one CLE hour worth of criminal appellate updates. We also have some bar business to discuss. Here are the agenda items-

1. Xmas party. Tracy Booker and Houston Smith are on the committee, we can always use more volunteers.
2. Philanthropy- The last two years have been mostly about getting the bar back to basics with monthly CLE meetings. It's time to take off the training wheels and discuss a project to give back to the community.
3. Shreveport CLE- October 14-15 there is a CLE in Shreveport.
4. November is officer elections. I've been VP for 18 months, and now P. I'm a firm believer in term limits. Ergo, it's time for new leadership and new ideas. I don't want to be the FDR of the bar association. Anyone want to run?

Muni Court Giveup

2010-08-06T18:51:27Z

Last night was the showdown, the State of Texas vs. Robert Guest. Allegedly, I was speeding through some godforsaken town on I-45. The citizens of this horrible city have decided to forsake gainful enterprise and instead steal money from commuters. Theft, not industry or commerce, that's their tax base. To that end, the city has unleashed an army of rabid officers to prey upon, and cite with reckless abandon, the driving public.

As I have blogged before, the whole muni court process is about stealing your money and inducing massive give up among defendants. Tickets have nothing to do with justice, little even to do with public safety. Instead, cops act as tax agents and harass hard working otherwise law abiding commuters, like me.

Really, should speeding a few miles over the limit be a criminal offense? If so, should it require a $200 donation to some municipality? Who set that amount? That's not justice, that's extortion.

Muni courts know that commuters have jobs, and lives. So they try and maximize time waste in order to make defendants beg for mercy and hand over their hard earned cash.

My first court appearance-
I received the ticket and decided to call the court and ask for deferred adjudication. I'm busy. I don't have time to waste on a traffic ticket. I'm told that to get deferred I have to appear in person.

So I show up at court for a "pre trial" hearing, and expect to work this out with the prosecutor/city attorney. (City attorneys prosecute in muni court. Most small towns farm this work out to Dallas firms. Blog idea- I should get the contract between the city and city attorney and see if there are any incentives to maximize revenue.)

Only the city attorney isn't there. That's right. The city has no lawyer present to dispense justice at this "hearing." Instead, plea bargains are to be struck with court personnel and/or the judge herself. Practicing law without a license is still a crime in this state. And I can't see how one can plea bargain a case and not be practicing law. But I digress.

My court helper decides I can't have deferred because, allegedly, I was going too fast. One hour of my life wasted, never to return. So I ask if I can call the city attorney and work this out. I was informed that I can not have the city attorney's name or number.

So I set the case for jury trial which was supposed to be last night. 20 something defendants appeared and we finally met the elusive city attorney. Mr. City Attorney informed us that a) if our cop didn't show up our case was dismissed and b) if your case isn't dismissed you will have a trial that night. And, by the way, last time we had trials until 1am so if you really want a jury trial you'll have to sit around for another 6 hours.

But..... if you want to discuss a plea bargain he has 15 minutes to talk before the jury gets here. Nice. The old "your money, or (6 hours of) your life" routine.

Ok. I'll play along. I speak with Mr. City Attorney and show him some case law that shows his case is FUBAR. No gray area here. What I provide is 100% on point, from our State's highest criminal court. I win, you lose, game over.

His reply. "That's an appellate issue. Our judge will let the evidence in. But if you want to plea I'll offer you deferred and lower the fine."

So my options are-
1. Appeal the case, make another appearance in a county court and then get the case dismissed;
2. Have my trial, see if the judge really does ignore the law and appeal if I lose,
3. Pay this reduced fine, take deferred, and leave.

The opportunity costs of fighting this ticket are reaching epic proportions. I kiss the ring, pay my fine, and plead no contest to a very beatable case. Just another day in muni court.

Muni Court 1, Robbie 0.

Two Months, One Bust

2010-08-03T12:43:41Z

This story from the Terrell Tribune highlights the problem with cannabis prohibition and opportunity costs.

From the TT

DRUG SELLING OPERATION INTERRUPTED
Authorities arrested Kristi Rene Resendez, 29, of Kaufman, for delivery of marijuana.
Published: Tuesday, July 27, 2010 4:08 PM CDT

KAUFMAN - After a two-month long undercover operation by Kaufman County Narcotics investigators, along with the cooperation of Kaufman Police Department, another drug dealer has been arrested for selling drugs in the city limits of Kaufman.

Kristi Rene Resendez, age 29, of Kaufman, was arrested on July 23. Resendez was taken to the Kaufman County Law Enforcement Center and charged with two counts of delivery of marihuana more than 1/4 oz. and less than 5 lbs.

Bond was set at $5,000 for each count

Two months, to take down one meaningless alread replaced dimebag dealer? What's next, a 2 week investigation into a possible seatbelt violation in Mabank?

Think, for a moment, if the cops who spent two months on this bust had spent those same two months solving a real crime, that is, one with a victim? Is that a better use of our limited law enforcement resources? Or do you feel safer knowing that it's was, for a few moments, marginally harder to buy weed in Terrell, Texas?

Opportunity costs are real. Taxpayers and LEO will never get those two months back. By keeping cannabis a class B misdemeanor and banning recreational/medicianal use Texans are choosing these two months pot stings over other law enforcement priorities.

Finally, can we quit calling pot "drugs". It's intellectually laziness to lump all contraband substances in one category. I know journalism trends towards sensationalist headlines . "Low level Cannabis Retailer Arrested", wouldn't get as much reader attention. But if we are going to make progress and change our State's inane drug laws, we could start by actualling differentiating between the drugs that can kill you, and the non toxic plant that can't.

Kaufman County Bar Meeting- 8/18 @ Noon

2010-08-03T12:41:01Z

The next Kaufman County Bar meeting is nigh upon us. I'll be speaking on Open Records Advocacy and we will discuss setting up a faster courthouse wifi network, inter alia.

My 1 hour Open Records seminar is CLE certiified, so if you're short on hours, or just want to learn how to get the government's secrets, come on down to K-Town.

Bigger, Better, Faster, More

2010-07-22T20:01:18Z

My blog has been void of new content lately. This is in large part to a just completed reworking of Guest Law Firm PC. We're going paperless. My intern, David Ruff a brilliant law student at OCU, has been studiously scanning every file and organizing our database. I know it sucks to scan files all day, but I've been mixing in some exciting courtroom action to make it worthwhile. Office work may not be intellectually challenging, but he's getting some lessons in law office management that will pay off much more that punching out Pro Doc boilerplate all day.

The end result of David's hard work is that GLFPC made the switch from Elawsoftware to CLIO. Elaw was a cutting edge program 4 years ago, but we've grown frustrated by the complete lack of updates and the fact that Elaw ONLY works with internet explorer (Chrome all the way).

Elaw has a few features I really miss (automatic court appearance letters etc), but it had reliability problems that drove me batshit crazy at times. It was designed in Texas for criminal defense lawyers and I still recommend it to my PC bound friends.

CLIO is cleaner, faster, more reliable, easier to navigate and... built for civil firms that bill hourly. I'm shoe horning in my criminal practice to fit the CLIO system but I can't complain.

It's been two months since the switch and I've noticed a huge increase in my personal productivity. Guest Law Firm PC is a hyper efficient justice machine; lubricated by technology and managed by my brilliant super hot CEO/wife.

Going paperless removed another barrier to my creativity and work product- the paper file. With my Ipad I have my firm with me whereever I go. I get a suppression idea- I get on CLIO and review the discovery, add some notes to the client's online file or go straight to Lexis to research it. Elizabeth and I spend less time managing my practice, and I can spend more time just practicing law.

Did I mention my Ipad?
I made the plunge into the Ipad a month ago. My files were scanned so I can access everything on the Ipad without the need for bulky tree killing paper files.

It works almost flawlessly (the Kaufman County Courthouse is a 3g dead zone) and I should quit bringing paper files to court any day now.

What's interesting is the reaction the Ipad received. The legal profession is facing a revolution of technological change and some lawyers are scared. My Ipad has been mocked and ridiculed in open court. I've heard more than a few lawyers opine on the merits of the old fashioned pen and paper practice. Most lawyers have been receptive, but the Ipad is rorsach test for how an attorney views the technolegal revolution.

Lawyers who are either unwilling, or incapable of embracing the wireless/paperless future will be at a competitive disadvantage. The market is going to weed out the Luddites and reward the Jetsons. The business reality is that I can do more better work because I'm not digging through paper files or confied by my law office.

I don't have to bring a file home to work on it. If an idea hits me at 11pm I have instant access to every case I have. This helps me realize my full potential as a lawyer, and find my best ideas to each case.

The old business model- Law office full of huge paper files with law library; Lawyer, Paralegal, Secretary- is dead. The law office has been reduced meeting clients and a focused place to work. It's no longer necessary for quality legal work.

This is frightening and threatening to many of my friends who have had the same business model for years, if not decades.

Potential clients should be aware that technological savvy does not mean someone is a great lawyer. It does mean that you may be paying more for their inefficiency and overhead, and that this lawyer may not be able to handle a larger caseload as well.

LEAPing with the Rotarians

2010-07-16T20:01:56Z

I had my first speaking gig for LEAP today. I've been a member of Law Enforcement Against Prohibition for a few years now and I was excited at the opportunity to present some our ideas to the Richardson Rotary Club.

First, I'd like to thank the Rotarians for the opportunity. Really nice people and very receptive to the discussion. I should join the Rotary club someday. The Rotarians mission of service and promoting peace and goodwill actually lines up quite well with the LEAP message.

On a technical note, I used Keynote on the Ipad for the first time. Better to test it out with a non jury audience before taking it to court. It worked fine, but the Ipad doesn't have a remote control for Keynote- FAIL. You can use your Iphone as a remote if you have a wifi connection. But the Ipad needs a bluetooth remote post haste. I had to stand next to my Ipad and touch the screen to change slides. Not horrible, but it really cuts down on my ability to work the room.

As for the substantive discussion, I first detailed why the status quo must end. Skip ahead if you've heard this before.

1. The War on Drugs is over, drugs won. Drug use has not plummeted and denabd remains largely unaffected despite spending over a $1T and arresting over 39M.
2. Prohibition gives the market over to cartels. At least $20B in monopoly profits. Cartels use these profits to wage war in Mexico (over 20,000 deaths in the last 3 years) and bribe our cops.
2a. Opportunity costs are real; the time we waste busting pot smokers (at the alarming rate of 100 per hour) could be better spent improving the clearance rate of real crime (rape, murder etc).
3. We can win the drug war in 3 easy steps.
Step 1, legalize, regulate, and tax cannabis for medical/recreational use. Pot is 60-80% of cartel profits. That move alone would save thousands of lives in Mexico.
Step 2, take back the addict market. Given away free heroin to addicts under a doctor's supervision. We reduce disease and death, and put more drug dealers out of business.
Step 3. Create a legal market for recreational drugs. People wouldn't smoke meth if we had some legal form of Aderrall available. People wouldn't smoke crack as much if we had the Original Coca Cola back.

That's it. You've put every cartel out of the drug business, and you've given back millions of law enforcement hours and billions of law enforcement dollars to solving crime, not busting addicts and college kids with joints.
The reaction was largely positive. I was asked how we can end the WOD when our politicians lack the will to even discuss the issue. I explained that Rotarians are leaders, not fringe anarchists or economic eggheads (we've got those supporters in spades). Start by talking with your friends, and then emailing your reps in Congress. Tell them we want a new approach, something that works. The subject is still taboo in many circles and we need to change the stigma associated with advocating for regulating, controlling, and legalizing drugs.

One thing I learned is that most people don't spend any time researching this issue. They are busy, and operate on the assumption that the government wouldn't spend so much time and money on the WOD if it wasn't a good idea.

I assume, because I read libertarian/defense blogs frequently, that everyone knows what I know about the WOD and cannabis prohibition. Not so much. The audience are shocked by the fact that over 20,000 Mexicans have been killed in cartel warfare in the last 3 years, that 100 pot smokers are arrested every hour, that the clearance rate for rape is 40% (largely because of the resources wasted on drug cases). Presented with the evidence most will admit the WOD is FUBAR and we need a fresh approach.

To that end, I'm looking for more speaking gigs. Want me to speak at your next event re: ending the failed drug war? Email me directly, or contact LEAP (leap.cc).

Kaufman County Bar Gets Libertarian President

2010-06-27T21:29:00Z

I'd like to take this opportunity to thank outgoing Kaufman County Bar President Keena Greyling for her service as Commander in Chief. Three years ago our local bar was a cluster of epic proportions.

Now, thanks to the hard work of our past two presidents we've got a thriving local bar association. Keena has been an outstanding Chief Executive and her dedication and hard work will be missed.

President's Greyling's resignation has left the current VP, me, as the new P. This is a historical moment as I'm pretty sure this is the highest office a Libertarian has ever held in Kaufman County. (Ok, these are non partisan elections, but still, we Libertarians need all the victories we can get).

What's my small government personal liberty agenda for the Kaufman Bar? Here is my radical hope and change agenda.

1. Have a monthly CLE meetings with lunch provided.
2. Have an awesome Christmas Party.
3. Clean up the gulf oil spill.

1 and 2 seem pretty easy, 3 may not get done during my administration.

In other bar news; there is no meeting in July. It's too damn hot to think, much less have CLE. I'm speaking in August, probably about open records. Also in August we are going to discuss upgrading the law library WiFi so that it penetrates the bomb shelter thick walls of County Court at Law.

Joe Barton wants the feds to arrest medical marijuana patients

2010-06-11T21:15:40Z

As a cannabis legalization advocate I often email my pols and ask them to consider supporting various common sense reform measures. One recent email to Joe Barton sought support for a measure to end the federal prosecution of state sanctioned medical marijuana patients. Being as the Republican party is, or was, the party of state's right, local control, and limited government, I was sure that Joe Barton would gladly support this common sense measure. Or maybe not.

Here's Mr. Barton in his own words.

Dear Mr. Guest:
Thank you for contacting me regarding your support for legalizing marijuana for medical use. I appreciate hearing from you on this matter.

Congressman Barney Frank has introduced H.R. 2835, the Medical Marijuana Patient Protection Act. This legislation would allow for the medical use of marijuana in accordance with the laws of the various States. H.R. 2835 has been referred to the Energy and Commerce Committee.

I am opposed to the legalization of marijuana under any circumstances. The greatest myth about marijuana is that it is harmless. America needs to realize that despite the claims of marijuana advocates, the volume of medical knowledge about the dangers of marijuana continues to grow.

Marijuana increases the heart rate as much as 50%, increases blood pressure in susceptible individuals, and reduces the amount of blood pumped by the heart. Current research also indicates that marijuana may interfere with the body's immune response to various infections and diseases. Additionally, marijuana seriously impairs the ability of individuals to think rationally, react to outside forces, and function properly.

When an individual uses drugs and then proceeds to operate a motor vehicle, they are not only putting themselves at an increased risk, they are endangering the lives of others. Often the fight against drugs focuses on the detrimental effects such substances can have on the user's physical and mental health, but we also must consider entirely different group innocent individuals who find themselves in the destructive path of a drug user.

Again, thank you for sharing your thoughts with me. Although we disagree on this matter, your thoughts are important to me, and I hope you will continue to let me know about matters of importance to you.

Sincerely,

Joe Barton
Member of Congress

I'd like to thank Mr. Barton for responding. So many pols send meaningless canned responses that don't even address the issue. Senators are especially obtuse. Someone on Joe's staff at least read my letter and noted the exact bill I'm asking about.

Let me disagree with a few of Joe's points. I'm not sure if anything is "harmless". But should that be our standard for liberty? American adults may only engage in completely benign activities or risk federal prosecution? That doesn't sound like a limited government idea.

Why won't Joe apply the same standard to the police state, that he does to plants? SWAT teams routinely murder dogs and occasionaly kill humans, drug cartels murder Mexicans en masse with cannabis profits. You can't die from smoking weed. You can die from a home invasion SWAT raid.

Joe then quotes some really scary information about cannabis use hurting your heart. I'm not a doctor. I'm pretty sure Joe isn't a doctor either. But these groups, which probably include some really smart doctors, do advocate for patient access to doctor prescribed medical cannabis.

The American Medical Association
The American College of Physicians - America's second largest physicians group
Leukemia & Lymphoma Society - America's second largest cancer charity
American Academy of Family Physicians
American Alliance for Medical Cannabis
American Public Health Association
American Psychiatric Association
American Nurses Association
British Medical Association
AIDS Action
American Academy of HIV Medicine
Lymphoma Foundation of America
Health Canada

I'll take their word for it.

Then Mr. Barton sets up the ultimate straw man- stoned killers behind the wheel. DWI is a favorite fall back argument for prohibitionists. You don't support intoxicated drivers killing innocent Americans do you?

Two problems with that logic. First, people already drive stoned because the product is deregulated. Really, unregulated means anyone can buy it whenever they want.

Second, this study, and this study, both say stoned drivers aren't all that bad at driving. This meta analysis shows that any comparison between drunk and high driving are misguided.

Finally, with law enforcement freed from arresting every dime bag carrying college kid they could spend that time on..... DWI enforcement.

If we apply Joe's logic to booze, the the 21st Amendment was a mistake. It's people like Joe that have to be convinced Prohibition was a failure. It may not be possible to reach people who are so blinded by the status quo. But I can try.

Lessons from the Pot Smuggling Police Chief

2010-06-10T19:17:50Z

Everyone is presumed innocent even cops accused of smuggling weed. But ask yourself this, where do drug dealers get the money to bribe law enforcement? Why would a cop risk his career and freedom to help them? The answer- pot prohibition profit$.

I'm amazed at how many Texans believe the negative externalities of prohibition (corruption, inter alia) are somehow caused by the drugs, or the people selling them.

When we choose to make pot illegal, we choose the corruption of our police officers. Think about it. Drug cartels have a billion dollar monopoly on the Texas cannabis market. What's easier than thinking up schemes to avoid getting caught and sending mules out who could get caught and lose their precious cargo?

Bribing law enforcement. Cops are a good investment for drug cartels.

DALLAS DALLAS (AP) -- The police chief of a small Texas town near the Mexican border faces federal charges of conspiracy to distribute marijuana and possession of marijuana.
The indictment unsealed Thursday charges Sullivan City Police Chief Hernan Guerra with one count of conspiracy to distribute more than 1,000 kilograms and four counts of possession with intent to distribute between 100 kilograms and 1,000 kilograms of marijuana. Guerra's attorney did not immediately return a message left by The Associated Press.

Guerra was arrested as part of a Justice Department probe called Project Deliverance, a 22-month investigation targeting Mexican drug trafficking organizations in the United States. More than 2,000 people were arrested, including 400 on Wednesday, when FBI agents raided Guerra's office.

He has been the police chief of the tiny community since 2004.

More and more Texans are starting to get it. Here's a group of concerned Texas parents calling for the regulation of the marijuana market to protect their children from drug dealers. They get it. Prohibition is the problem. We made a policy mistake and it's time to fix it. Or we can keep arresting cops corrupted by cartel cash. The choice is ours.

Plano Police Make Meaningless Celebrity Pot Bust

2010-06-04T21:21:44Z

Apparently Plano PD didn't get the memo that 69% of Texans want some form of legalized marijuana. Otherwise, they wouldn't waste their time with meaningless "look I found a joint!" busts.

The latest victim of our inane cannabis war is Chace Crawford. Allegedly, Chace is some sort of TV star (Gossip Girl?) who was hanging out in Plano at Ringo's Pub when the fuzz found an "unlit joint". I feel safer.

Remember opportunity costs? Violent crime in Plano is up over 50% from 2009. IWhat do you want Plano PD working on? Keeping Ringo's Pub free of unlit joints? Or solving and preventing real crime (the kind with victims)?

Don't consent to searches. Not guilty edition

2010-05-27T20:50:23Z

I got a not guilty today on a marijuana bench trial. In large part this was due to the work of the citizen accused who did not waive his rights on the side of the road.

Remember, if the police ask you about anything illegal; drugs, guns, drinking and driving, murder, steroids, illegal poker rooms- ask for a lawyer.

If the police ask you to search your car- always say no and ask for a lawyer.

If the police search anyway, and if they are lacking in probable cause, and if they can't meet one the many exceptions for drug searches*; then your lawyer can ask the court to suppress whatever they find.

* Our appellate courts have bent over backwards to uphold drug searches in recent years. The 4th Amendment is on life support, but not completely dead yet.
Remember, just say no, to consent searches.

Terrell Texas Marijuana Grow Bust- Point/Counterpoint

2010-05-25T19:08:19Z

I'll be the first to admit that news site comments are not the highest form of debate. However, they can be a useful gauge of how some members of the public feel on an issue. So how do the conservative readers of the TT feel about cannabis prohibition?

Here is a recent news story from Terrell, Texas courtesy of the Terrell Tribune.

Marijuana growing operation discovered off Lawson Road

A combined effort involving Kaufman County Sheriff;s Office investigators and the Department of Public Safety located a marijuana plant growing operation on the western edge of Kaufman County.

According to KCSO spokesperson Pat Laney, the highly developed growing operation was located in the Lawson Road area just off of U.S. Highway 80.

Authorities seized 7,125 marijuana plants. It appears that the illegal growing venture had just been started.

The street value of the marijuana plants after harvest is estimated to be in excess of $71,000, Laney said.

Nothing sexy. Just a typical cops find weed and dig it up story. To my surprise, this bust generated a lot of comments for a benign "crime" story. Instead of reposting them I invite you to head on over to the Terrell Tribune (they wrote the story and deserve the hits). Read the comments and ask yourself, which side of the debate has more logic and intellectual depth? And which side is ad hominem nonsense?

I'll make a few quick points that I've already covered in the past.
1. Opportunity costs- every minute we make cops spend digging up plants is not spent on solving and preventing real crime.
2. Marijuana can't kill you. It's non toxic.
3. There wouldn't be grow operations all over the place if weed was legal. Are there moonshine stills all over the place?

I don't blame law enforcement for this bust. Law enforcement by definition, enforces laws. But turning cops into lawn care men with guns is a bad investment that makes us less safe.

Faulty Eyewitness ID = Wrongful Conviction

2010-05-23T12:37:46Z

DMN has a piece on Dallas County's DNA exoneration team. The goal now is move to non DNA cases where, undoubtedly, dozens if not hundreds of innocent defendants have been convicted over the years.

DNA cases are the low hanging fruit of wrongful convictions. Why are so many people wrongfully convicted? One reason is that eyewitnesses can be pretty lousy when it comes to identifying a suspect in court. Here's a quote from DMN

Ware, prosecutor Cynthia R. Garza, investigator James Hammond and paralegal Jena Parker - the four members of the conviction integrity unit - say they are using the lessons learned from the certainty of the wrongful convictions in the DNA cases to guide them.
They question the reliability of eyewitness identification, and while it's not always incorrect, Ware says it is not the "gold standard" that prosecutors and juries once believed it to be.

An investigation by The Dallas Morning News in 2008 showed that all but one of the DNA exonerations involved faulty eyewitness identification.

If you are a juror, and the State's best evidence is a witness ID; you can and should still have a reasonable doubt as to guilt. Every exoneration case save one had a person stand up and ID the wrongfully convicted defendant as the perpetrator.

Still, most Texas police departments refuse to update their witness ID practices to help prevent wrongful convictions.

Kaufman District Attorney Job Opening

2010-05-06T19:44:29Z

From TDCAA.com-

ADA needed for felony court in Kaufman County. Must have 1-2 years of felony experience as a prosecutor at a district attorney's office. Duties will include intake, grand jury, handling of felony docket, and trial of felony cases. Great work environment with plenty of support from staff and fellow prosecutors. Two prosecutors assigned to each of the two District courts. Coat and tie only required for docket and trials. Salary is $73,954. Contact Michelle Stambaugh at (972) 932-0262 or send resume to michelles ( a t ) kaufmancounty ( d o t ) net or fax (972) 932-0357.

True that. The Kaufman county DA's office is a great place to work. Nice people, good judges, manageable caseloads and you get to work out cases with me. What more could you want? The only downside is the lunch options are pretty limited and it's far from Dallas.

Home Invasion SWAT raid of the day

2010-05-05T12:38:34Z

Marijuana prohibition has turned our nation's peace officers into violent paramillitary predators. If you still support arresting pot smokers watch this video. This Missouri SWAT team invades the home at night, shoots the family dogs (with the children present), discover a misdemeanor amount of marijuana, and charge the parents with child endangerment!

Let's get this straight; parents keeping a few ounces of a non toxic plant at home = child endangerment. A home invasion SWAT raid breaking into said home to shoot the family pets and scare the shit out of these poor children = proper police work.

We can change this system at any time. Outlawing home invasion SWAT raids would be a good start. Legalizing the products that these dangerous narco warriors are looking for, would also work.