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September 29, 2014

Notable new AG Holder memorandum on charging policies and plea negotiations

I learned over the weekend that last week Attorney General Eric Holder issued a short memo to DOJ lawyers to provide "Guidance Regarding § 851 Enhancements in Plea Negotiations."  This full one-page memo, which is dated September 24, 2014, can be downloaded below.  Here are its most notable sentences, with my emphasis added:

The Department provided more specific guidance for charging mandatory minimums and recidivist enhancements in drug cases in the August 12, 2013, "Department Policy on Charging Mandatory Minimum Sentences and Recidivist Enhancements in Certain Drug Cases."  That memorandum provides that prosecutors should decline to seek an enhancement pursuant to 21 U.S.C. § 851 unless the "defendant is involved in conduct that makes the case appropriate for severe sanctions," and sets forth factors that prosecutors should consider in making that determination. Whether a defendant is pleading guilty is not one of the factors enumerated in the charging policy. Prosecutors are encouraged to make the§ 851 determination at the time the case is charged, or as soon as possible thereafter.  An § 851 enhancement should not be used in plea negotiations for the sole or predominant purpose of inducing a defendant to plead guilty.  This is consistent with long-standing Department policy that "[c]harges should not be filed simply to exert leverage to induce a plea, nor should charges be abandoned to arrive at a plea bargain that does not reflect the seriousness of the defendant's conduct." "Department Policy on Charging and Sentencing," May 19, 2010.

While the fact that a defendant may or may not exercise his right to a jury trial should ordinarily not govern the determination of whether to file or forego an § 851 enhancement, certain circumstances -- such as new information about the defendant, a reassessment of the strength of the government's case, or recognition of cooperation -- may make it appropriate to forego or dismiss a previously filed § 851 information in connection with a guilty plea. A practice of routinely premising the decision to file an § 851 enhancement solely on whether a defendant is entering a guilty plea, however, is inappropriate and inconsistent with the spirit of the policy.

Download AG-Letter-Regarding-Enhancements-in-Plea-Negotiations

I am inclined to speculate that AG Holder felt a need to issue this short memo in part because of reports that some US Attorneys may have had a "practice of routinely premising the decision to file an § 851 enhancement solely on whether a defendant is entering a guilty plea."

September 29, 2014 at 06:59 PM | Permalink

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Comments

Well, how did this get past everyone for a full five days? Thanks for posting this.

It is such an obviously over used tool to assure that defendants are penalized for exercising their sixth amendment right to trial. Since less than 3% of defendants go to trial it is interesting that almost 100% of nonviolent marijuana offenders who receive sentences of life without parole exercised their sixth amendment right to trial.

Posted by: beth | Sep 30, 2014 12:00:36 AM

Not sure Holder's memo will change much -- even if all-powerful, apparently unaccountable federal prosecutors could be relied upon to embrace it. After all, it amounts to a suggestion that seems unfriendly to career efforts measured in convictions and long prison terms.

The feds don't need MMs or 851 enhancements to coerce confessions and chalk up severe sentences; not as long as they've got the vague, sweeping, pro-prosecutor statutes from the Nixon era and sentencing guidelines from the get-tough Reagan era (with potentially draconian prison terms for practically everything).

As long as AUSAs can plausibly threaten virtually any defendant with decades in prison through ordinary charge-stacking and manipulating guidelines (even if advisory), racking up confessions should continue to be a snap.

Still it's nice Mr. Holder says he feels bad to think the system might be abusing its power.

Posted by: John K | Sep 30, 2014 11:09:48 AM

I met inmates who had received section 851 enhancements and mandatory life sentences while I was incarcerated at USP - Big Sandy (Inez, Ky.) and USP-1, Coleman, Florida.

One 35-year old man had been caught with over 800 grams of methamphetamine, but refused to debrief about where he got it. The people he bought the meth from would have killed his entire family if he had talked. His prior felony drug convictions were just those of an addict, and included one state conviction for "possession of cocaine", which amounted to nothing more than residue on scales. As a result of his refusal to debrief (he did plead guilty), the Feds filed the section 851 enhancement papers and gave him a life sentence. His wife was also sentenced to prison, resulting in their 5 children being placed in Foster care. Giving him a life sentence was bad policy and is a waste of taxpayer monies.

At USP - Big Sandy, I met a 22-year old black inmate from D.C. who had received a section 851 enhancement and a mandatory life sentence. The total amount of drugs involved in his 3 felony drug crimes is 8 ounces of marijuana and 3 grams of heroin. His life sentence is such a tragic waste of a human life, and a waste of taxpayer monies, since he could easily live more than 50 years in prison. I think that if the general public ever learned about these kinds of individual cases, there would be a huge backlash and a call for their sentences to be commuted.

Ironically, the only real drug kingpin I ever met in Federal prison (a 35-year old Mexican man, who had operated out of Mexico and Belize) received only a 38 year sentence, not life. His relevant conduct was more than 350,000 kilos of cocaine. He refused to enter into a plea agreement with the Government that would have required him to debrief, as his family would have all been murdered if he had talked. Instead, he made a blind plea to the Court, with no agreement. By getting his 3 points subtracted for "acceptance of responsibility", he avoided the life sentence. The DOJ was so upset that they flew an attorney from D.C. to N.Y. to argue that he shouldn't get his acceptance of responsibility because he refused to debrief. The District Judge (who is now a 2nd Circuit Judge) read the Guidelines to the DOJ lawyer and reminded him that "acceptance of responsibility" only requires a timely guilty plea, not debriefing to the Government. The Federal criminal system can be incredibly perverse.

Posted by: Jim Gormley | Sep 30, 2014 3:45:09 PM

Jim Gormley, there was a time (maybe before I was born) when Presidents exercised their constitutional power to commute sentences, like the unjust ones you cite, and the many thousands of others that are regularly imposed. The cowards we have had in the past, and the coward we have now, speak platitutes but do nothing. It's a shame and a pity that so many lives are wasted in prison and that the lives of so many innocent family members are scarred and ruined.

Posted by: Michael R. Levine | Sep 30, 2014 5:25:13 PM

Obama's record in this regard is a disgrace. Here are the stats I found on line:

Thomas Jefferson

Democratic-Republican President Thomas Jefferson pardoned, commuted or rescinded the convictions of 119 people during his term.[3] Among them is:

David Brown – convicted of sedition under the Sedition Act of 1798 because of his criticism of the United States federal government, receiving the harshest sentence of anyone; pardoned along with all violators of the act

James Madison

Democratic-Republican President James Madison pardoned, commuted or rescinded the convictions of 196 people during his term.[3] Among them are:

William Hull – while Governor of the Michigan Territory, sentenced to death for surrendering Fort Detroit; pardoned
Jean Lafitte and Pierre Lafitte and the Baratarian Pirates for past piracy, granted due to their assistance during the War of 1812; granted February 6, 1815.[6]

James Monroe

Democratic-Republican President James Monroe pardoned, commuted or rescinded the convictions of 419 people during his term.[3] Among them are:

Numerous individuals convicted of piracy.[7]

John Quincy Adams

Democratic-Republican President John Quincy Adams pardoned, commuted or rescinded the convictions of 183 people during his term.[3] Among them are:

Captain L. O. Helland – arrested for having more passengers on board the vessel (Restauration) than were allowed by American law; pardoned
Wekau and Chickhonsic – Ho-Chunk leaders pardoned for their role in the Winnebago War[8]

Andrew Jackson

Democratic President Andrew Jackson pardoned, commuted or rescinded the convictions of 386 people during his term.[3] Among them is:

Martin Van Buren

Democratic President Martin Van Buren pardoned, commuted or rescinded the convictions of 168 people during his term.[3] Among them is:

William Lyon Mackenzie – violation of American neutrality laws; pardoned

William Henry Harrison

Whig President William Henry Harrison was one of only two presidents who gave no pardons. This was due to his death shortly after taking office.
John Tyler

Whig President John Tyler pardoned, commuted or rescinded the convictions of 209 people during his term.[3] Among them is:

Alexander William Holmes – sailor convicted of voluntary manslaughter (U.S. v. Holmes); pardoned

James K. Polk

Democratic President James K. Polk pardoned, commuted or rescinded the convictions of 268 people during his term.[3] Among them is:

John C. Frémont – convicted by court martial of mutiny. Frémont later became the 1856 Republican candidate for the Presidency of the United States.

Zachary Taylor

Whig President Zachary Taylor pardoned, commuted or rescinded the convictions of 38 people during his term.[3]
Millard Fillmore

Whig President Millard Fillmore pardoned, commuted or rescinded the convictions of 170 people during his term.[3] Among them are:

Daniel Drayton and Edward Sayres – convicted in the Pearl incident (transporting slaves to freedom); pardoned

Franklin Pierce

Democratic President Franklin Pierce pardoned, commuted or rescinded the convictions of 142 people during his term.[3]
James Buchanan

Democratic President James Buchanan pardoned, commuted or rescinded the convictions of 150 people during his term.[3] Among them is:

Brigham Young – pardoned for role in the Utah War.
Daniel Vandersmith - a former judge, pardoned for forgery.[9]

Abraham Lincoln

Republican President Abraham Lincoln pardoned, commuted or rescinded the convictions of 343 people during his term.[3] Among them are:

264 of 303 Dakota Indians who attacked white settlers in the Great Sioux Uprising of 1862.[10]
Clement Vallandigham - Copperhead sentenced for disloyalty; sentence commuted, and deported to the Confederacy[11]
Various men who enlisted in the army, but who were, among other circumstances, underage, bounty jumpers, or AWOL.[12]

Andrew Johnson

Democratic President Andrew Johnson pardoned about 7,000 people in the "over $20,000" class by May 4, 1866. More than 600 prominent North Carolinians were pardoned just before the election of 1865.[13] President Andrew Johnson pardoned, commuted or rescinded the convictions of 654 people during his term.[3] Among them are:

Confederate soldiers – unconditional amnesty to all Confederates on Christmas Day 1868; earlier amnesties requiring signed oaths and excluding certain classes of people were issued both by Lincoln and by Johnson. Among them were:
Charles D. Anderson
Richard H. Anderson
Alexander H. Stephens, Vice President of the Confederate States of America
Eli Metcalfe Bruce
Horatio Washington Bruce
Augustus Hill Garland
Samuel Arnold – charged with conspiring to murder Lincoln
Dr. Samuel Mudd – charged with conspiring to murder Lincoln
Edmund Spangler – charged with conspiring to murder Lincoln

Ulysses S. Grant

Republican President Ulysses S. Grant pardoned, commuted or rescinded the convictions of 1,332 people during his term.[3] Among them are:

Confederate leaders – All but 500 top Confederate leaders were pardoned when President Grant signed the Amnesty Act of 1872.

Rutherford B. Hayes

Republican President Rutherford B. Hayes pardoned, commuted or rescinded the convictions of 893 people during his term.[3] Among them is:

Ezra Heywood – Convicted of violating the 1873 Comstock Act; pardoned after 6 months

James Garfield

Republican President James Garfield was one of only two presidents who gave no pardons. This was due to his assassination shortly after taking office.
Chester A. Arthur

Republican President Chester A. Arthur pardoned, commuted or rescinded the convictions of 337 people during his term.[3] Among them is:

Fitz John Porter – Court-martialed for his actions at Second Bull Run; sentence commuted

Grover Cleveland

Democratic President Grover Cleveland pardoned, commuted or rescinded the convictions of 1,107 (est.) people during his two, non-consecutive terms.[3] Among them (in his first term) are:

James Brooks – Texas Ranger indicted for manslaughter; pardoned after lobbying from his fellow Rangers
Rudger Clawson – convicted of polygamy; pardoned
David King Udall – convicted on perjury charges; spent 3 months in a Federal Prison; received a full and unconditional pardon

Benjamin Harrison

Republican President Benjamin Harrison pardoned, commuted or rescinded the convictions of 613 people during his term.[3] Among them are:

Members of The Church of Jesus Christ of Latter-day Saints – Granted amnesty and pardon for the offense of engaging in polygamous or plural marriage to members of The Church of Jesus Christ of Latter-day Saints (LDS Church).[14]

Grover Cleveland (2nd term)

Democratic President Grover Cleveland pardoned, commuted or rescinded the convictions of 1,107 (est.) people during his two, non-consecutive terms.[3] Among them (in his second term) is:

"Billy Wilson" (David L. Anderson) – outlaw; pardoned

William McKinley

Republican President William McKinley pardoned, commuted or rescinded the convictions of 918 (est.) people during his term.[3] Among them are:

Alexander McKenzie – contempt of court; pardoned
Charles Chilton Moore – jailed for blasphemy; pardoned

Theodore Roosevelt

Republican President Theodore Roosevelt pardoned, commuted or rescinded the convictions of 981 (est.) people during his term.[3] Among them are:

Servillano Aquino – received death sentence for anti-American activities in the Philippines; pardoned after 2 years
Al Jennings – sentenced to life in prison for robbery; pardoned
Stephen A. Douglas Puter – convicted of land fraud; pardoned after 18 months so he could turn state’s evidence
Presidential pardons page at Almanac of Theodore Roosevelt

William Howard Taft

Republican President William H. Taft pardoned, commuted or rescinded the convictions of 758 people during his term.[3] Among them are:

John Hicklin Hall – role in the Oregon land fraud scandal; pardoned
Charles W. Morse – convicted of violations of federal banking laws; pardoned due to ill health (later found to be feigned)
Captain Van Schaick – pardoned after 3 ½ years in prison for the General Slocum steamship disaster of 1904

Woodrow Wilson

Democratic President Woodrow Wilson pardoned, commuted or rescinded the convictions of 2,480 people during his term.[3] Among them are:

Frederick Krafft – convicted for alleged violation of the Espionage Act. Only person convicted under this law to receive a full executive pardon.

Warren Harding

Republican President Warren G. Harding pardoned, commuted or rescinded the convictions of 800 people during his term.[3] Among them are:

Eugene V. Debs – convicted of sedition under the Espionage Act of 1917; sentence commuted
Kate Richards O'Hare – convicted of sedition under the Espionage Act of 1917; sentence commuted

Calvin Coolidge

Republican President Calvin Coolidge pardoned, commuted or rescinded the convictions of 1,545 people during his term.[3] Among them are:

Marcus Garvey – convicted of mail fraud; sentence commuted and deported
Lothar Witzke – German spy and saboteur; pardoned and deported

Herbert Hoover

Republican President Herbert Hoover pardoned, commuted or rescinded the convictions of 1,385 people during his term.[3] Among them are:

Warren T. McCray – Governor of Indiana convicted of Mail Fraud; pardoned after learning of the KKK's role in his arrest and conviction
Thomas W. Miller – conspiring to defraud the U.S. government; pardoned

Franklin Delano Roosevelt

Democratic President Roosevelt granted 3,687 pardons in his four terms in office.[3] Among them are:

George R. Dale – convicted of violating Prohibition laws; pardoned after the repeal of Prohibition
Roy Olmstead – convicted for violating the National Prohibition Act; appealed, arguing that the wiretapping evidence used against him constituted a violation of his constitutional rights to privacy and against self-incrimination; U.S. Supreme Court upheld the conviction in the landmark case of Olmstead v. United States; pardoned
Duncan Renaldo – arrested for illegal entry into the US; pardoned

Harry Truman

Democratic President Harry Truman pardoned, commuted or rescinded the convictions of 2,044 people during his term.[15] Among them are:

George Caldwell – income tax evasion; pardoned
Oscar Collazo – Collazo attempted Truman's assassination; Commuted death sentence to life sentence; also see listing under Carter
James Michael Curley – fraud and mail fraud; pardoned
Richard W. Leche – mail fraud; pardoned
Andrew J. May – accepting bribes; pardoned
Seymour Weiss – tax evasion and mail fraud; pardoned

Dwight D. Eisenhower

Republican President Dwight D. Eisenhower pardoned, commuted or rescinded the convictions of 1,157 people during his term.[15] Among them is:

Maurice L. Schick – military court-martial for brutal murder; death sentence commuted to life imprisonment, with the condition that he would never be released. Legal challenge went to the Supreme Court, questioning the constitutionality of the punishment "Life Imprisonment Without Parole". Decided in Schick v. Reed that to be so sentenced was constitutional. He was not paroled.

John F. Kennedy

Democratic President John F. Kennedy pardoned, commuted or rescinded the convictions of 575 people during his term.[15] Among them are:

First-time offenders convicted of crimes under the Narcotics Control Act of 1956 – pardoned all, in effect overturning much of the law passed by Congress.

Lyndon B. Johnson

Democratic President Lyndon B. Johnson pardoned, commuted or rescinded the convictions of 1,187 people during his term.[15] Among them are:

Frank W. Boykin – Congressman convicted of bribery; pardoned in 1964 at the request of departing Attorney General Robert F. Kennedy.
Maurice Hutcheson – contempt of Congress; pardoned

Richard Nixon

Republican President Richard Nixon pardoned, commuted or rescinded the convictions of 926 people during his term.[15] Among them are:

Jimmy Hoffa - convicted of fraud and bribery – sentence commuted (with conditions) on December 23, 1971
Angelo DeCarlo – convicted of extortion; served 1½ years; pardoned due to poor health
William Calley - convicted of murder for his involvement in the My Lai Massacre, pardoned in 1974 after serving 3 years' house arrest

Gerald Ford

Republican President Gerald Ford pardoned, commuted or rescinded the convictions of 409 people during his term.[15] Among them are:

Richard Nixon – Granted a full and unconditional pardon just before he could be indicted.
Robert E. Lee – full rights of citizenship were posthumously restored
Iva Toguri D'Aquino – "Tokyo Rose" – only U.S. citizen convicted of treason to be pardoned
Vietnam draft dodgers – Ford offered conditional amnesty to over 50,000 draft dodgers.
Ernest C. Brace – pardoned of his 1961 court-martial from the United States Marine Corps in light of his almost eight years as a POW in Vietnam.[16]

Jimmy Carter

Democratic President Jimmy Carter pardoned, commuted or rescinded the convictions of 566 people during his term.[15] Among them are:

Oscar Collazo – Attempted assassination on President Harry S. Truman; commuted to time served
G. Gordon Liddy – Watergate figure. Convicted for 20 years, commuted after serving 4½ years for conspiracy, burglary and illegal wiretapping.
Peter Yarrow – Singer-songwriter of Peter, Paul and Mary
Vietnam draft dodgers – Unconditional amnesty issued in the form of a pardon[17]
Jefferson Davis – President of the Confederate States of America.
Patty Hearst – Convicted of Bank Robbery; sentence commuted
Lolita Lebrón, Rafael Cancel Miranda, Irving Flores Rodriguez – machine-gunning the U.S. House of Representatives and wounding five Congressmen in 1954; clemency

Ronald Reagan

Republican President Ronald Reagan pardoned, commuted or rescinded the convictions of 406 people during his term.[15] Among them are:

W. Mark Felt and Edward S. Miller – FBI officials convicted of authorizing illegal break-ins. Mark Felt later in life admitted to being Deep Throat, the informant during the Watergate affair.
Junior Johnson – Moonshining; pardoned
George Steinbrenner – Was convicted of illegal Nixon campaign contributions and obstruction of justice; pardoned
Marvin Mandel – former Governor of Maryland convicted of mail fraud and racketeering; clemency; conviction later overturned in U.S. district court.

George H. W. Bush
Main article: List of people pardoned by George H. W. Bush

Republican President George H. W. Bush pardoned, commuted or rescinded the convictions of 77 people during his term.[15] Among them are:

For their roles in the Iran-Contra Affair
Elliott Abrams
Duane Clarridge
Clair George
Alan D. Fiers
Robert C. McFarlane – National Security Adviser to President Ronald Reagan
Caspar Weinberger – Secretary of Defense under President Ronald Reagan
Armand Hammer – CEO of the Occidental Petroleum Company, contributed $110,000 to the Republican National Committee just prior to his pardon. Pardoned for illegally contributing $54,000 to Richard Nixon's presidential campaign in 1972.[18]
Joseph Occhipinti – Federal drug agent convicted of violation of civil rights, perjury and depravation of rights. Commuted.[19]
Myra Soble – 1957 conviction for her involvement in the Rosenberg spy ring; pardoned

Bill Clinton
Main article: List of people pardoned by Bill Clinton

Democratic President William J. Clinton pardoned, commuted or rescinded the convictions of 459 people during his term.[15] Among them are:

Roger Clinton, Jr. – brother of Bill Clinton. After serving a year in federal prison for cocaine possession.
Almon Glenn Braswell – convicted of mail fraud and perjury; pardoned
Patty Hearst – Bank robbery. Prison term commuted by Jimmy Carter. She was released from prison in 1979. She was fully pardoned by Clinton in 2001.
Marc Rich, Pincus Green – business partners; indicted by U.S. Attorney on charges of tax evasion and illegal trading with Iran. Pardoned at the request of 3 Republicans including Lewis Libby.[20]
Dan Rostenkowski – Democrat from Illinois. Served his entire sentence, then pardoned.
Fife Symington III – Republican Governor of Arizona convicted of bank fraud; pardoned.[21]
Susan McDougal – partners with Bill Clinton and Hillary Rodham Clinton in the failed Whitewater deal. Guilty of contempt of court, she served her entire sentence and was then pardoned.
Henry Cisneros – Clinton's Secretary of Housing and Urban Development. Pleaded guilty to a misdemeanor count for lying to the FBI, and was fined $10,000.
Edward Downe, Jr. – wire fraud, filing false income tax returns, and securities fraud; pardoned
Elizam Escobar – seditious conspiracy; pardoned
Samuel Loring Morison – espionage and theft of government property; pardoned
Mel Reynolds – Democratic member of the United States House of Representatives.
Henry O. Flipper – The first black West Point cadet was found guilty of "conduct unbecoming an officer" in 1882.
John Deutch – Director of Central Intelligence, former Provost and University Professor, MIT
Rick Hendrick – NASCAR Team Owner & Champion; convicted of mail fraud; pardoned
FALN – commuted the sentences of 16 members of FALN, a violent Puerto Rican terrorist group that set off 120 bombs in the United States, mostly in New York City and Chicago. The 16 were convicted of conspiracy and sedition and sentenced with terms ranging from 35 to 105 years in prison.
Lyle Prouse - Pilot convicted of flying drunk

George W. Bush
Main article: List of people pardoned by George W. Bush

Republican President George W. Bush pardoned, commuted or rescinded the convictions of 200 people during his term.[15] Among them are:

Lewis "Scooter" Libby – Assistant to President George W. Bush and Chief of Staff to Dick Cheney was convicted of perjury in connection with the CIA leak scandal involving members of State Department who 'outed' CIA agent Valerie Plame. Libby received commutation, not a full pardon.
José Compeán and Ignacio Ramos – Two US Border Patrol agents who wounded drug smuggler Osvaldo Aldrete Dávila and tried to cover up the incident received commutation.[22]
Charles Winters – Posthumous pardon for smuggling three B-17 Flying Fortress heavy bombers to Israel in the late 1940s
Issac Robert Toussie – Convicted of making false statements to the U.S. Department of Housing and Urban Development; pardoned and the pardon revoked one day later
Edwin L. Cox Jr. – Convicted in 1988 for bank fraud
John Forté – Hip-hop singer and song writer sentenced for smuggling cocaine was commuted.[23]

Barack Obama
Main article: List of people pardoned by Barack Obama

Democratic President Barack Obama has pardoned or commuted the convictions of 61 people during his term of office, as of December 2013.[15][24][25] Among them are:

James Bernard Banks, of Liberty, Utah, sentenced to two years of probation in 1972 for illegal possession of government property.[26]
Russell James Dixon, of Clayton, Ga., sentenced to two years of probation in 1960 for a liquor law violation.[26]
Laurens Dorsey, of Syracuse, N.Y., sentenced in 1998 to five years of probation and $71,000 in restitution for conspiracy to defraud by making false statements to the Food and Drug Administration.[26]
Ronald Lee Foster, of Beaver Falls, Pa., sentenced in 1963 to a year of probation and a $20 fine for mutilating coins.[26]
Timothy James Gallagher, of Navasota, Texas, sentenced in 1982 to three years of probation for cocaine possession and conspiracy to distribute.[26]
Roxane Kay Hettinger, Powder Springs, Ga., sentenced in 1986 to 30 days in jail and three years of probation for conspiracy to distribute cocaine.[26]
Edgar Leopold Kranz Jr., of Minot, N.D., who received 24 months of confinement and a pay reduction for cocaine use, adultery and bouncing checks.[26]
Floretta Leavy, of Rockford, Ill., sentenced in 1984 to 366 days in prison and three years of parole for drug offenses.[26]
Scoey Lathaniel Morris, of Crosby, Texas, sentenced in 1991 to three years of probation and $1,200 restitution for counterfeiting offenses.[26]


Posted by: Michael R. Levine | Sep 30, 2014 5:35:06 PM

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