Feb. 9
NIGERIA:
Buhari explains why he executed drug peddlers and journalists
Former military ruler, Major General Muhammadu Buhari on Sunday defended some
of the most controversial actions of his regime and accepted responsibility for
them.
Gen. Buhari, who is the presidential candidate of the main opposition party,
the All Progressives Congress (APC), said that his military regime took those
actions to clean up the country and restore dignity to the citizenry.
The Buhari junta, which was in power between 31 December 1983 and 27 August
1985, attracted criticisms for executing drug convicts with retroactive laws
and for jailing journalists under a decree that made it an offence to publish a
report that could embarrass the government, whether true or false.
The military regime executed Bernard Ogedegbe (29), Bathlomew Owoh (26) and
Lawal Ojuolape (30) for dealing in drugs. The case of Owoh drew particular
global attention because at the time the offence was committed, the maximum
punishment in the country's legal code was 6 months imprisonment. The Buhari
government enacted a Decree 20, which had a retroactive effect and carried the
death penalty.
Also, under Decree No. 4 of 1984, the Buhari military government jailed 2
reporters, Tunde Thompson and Nduka Irabor for publishing reports that it
considered embarrassing to government officials. His question-and-answer
session with the Al Jazeera television, went thus:
People accuse your leadership during that regime of cracking down on civil
rights, of executing people who had not committed cap???ital offences.
We said we suspended parts of the constitution and we made laws before we sent
people on trial. So, we accept responsibility for whatever opinion and whoever
is expressing it. The question of executing people was about people dealing in
drugs. We said cocaine and associated drugs were not developed or produced in
Nigeria. People who want to make money at the expense of health, lives of
people go to the countries that produce these substances and make Nigeria a
transit camp for drugs, destroying Nigerian communities and extend the
destruction even to developed countries just to make money. We were concerned
that if people want to make money, they should go out and work hard and make
money, not to go and bring drugs, sell it and destroy our youth, sell it and
destroy other countries just to make money. We made the law, that whoever did
it should be executed. Let him go and make the money elsewhere, not in Nigeria.
The 2nd accusation that you made on the trampling on human rights is about the
Nigerian Press. We said we cannot stop the press from criticizing people or
institutions. But please, let them have investigative journalism. Let them try
and verify facts before they accuse government of offence and others of
misdemeanor to spoil their names and reputations. We never held any secret
tribunal. The tribunals, 6 of them throughout the country, we got the
intelligence community, Navy, Army, Air Force, Police, national security
organisations, to form the investigative panel that based on documentation,
people were charged, military tribunals, they were tried. There was nothing
secret about it.
You've managed to attract the support of fairly significant political figures
in Nigeria. Wole Soyinka the widely internationally acclaimed writer and former
President (Olusegun) Obasanjo, former President (Ibrahim) Babangida. They've
all come out very strongly against the presidency of Goodluck Jonathan and
thereby support your candidacy. But nobody has come out with a real endorsement
of Muhammadu Buhari as the right man and the perfect man to be the President of
Nigeria.
If people don't like Buhari's face for what he did as a military Head of State,
let them join either the ruling party or any of the mushroom parties and vote
against me and persuade their constituencies to vote against me. It is as
simple as that. I keep maintaining that Nigerians will be amazed how physically
Nigeria can be secured if people are allowed to choose whoever they want to
represent them as members of legislature, as Governors and as President. We
will be amazed.
Can I, with respect, put to you another criticism that is levelled against you,
General Muhammadu Buhari and that is: You are a very popular figure in the
North but that popularity doesn't extend beyond. You've been accused of being
the leader of the North, and somebody who doesn't extend that appeal to the
other parts of the country. In fact, you've been accused of not really
respecting the diversity of Nigeria. What would you say to that?
(source: Segun Adio, spyghana.com)
IRAQ:
Saddam Hussein noose going up for auction
The noose used to hang Saddam Hussein in 2006 is being auctioned as a piece of
art. It is currently in the possession of former Iraqi official Movafagh
Al-Rabi'i, who has put the noose around a bronze bust of Hussein and exhibits
it in his home.
An unidentified Iraqi politician has told the daily Alarabiya Aljihad that
several collectors and buyers from Israel, Iran and Kuwait have made offers to
by the rope used to hang Saddam Hussein, and the highest bid has so far been 7
million dollars.
The report indicates that Al-Rabii expects to get even more for it. The Iraqi
government has said that if the rope is indeed sold, legally the money should
be handed over to the Iraqi treasury.
Saddam Hussein was hanged in 2006, and Al-Rabi'i was present as an Iraqi
government security official.
He told Al-Jazeera that Saddam Hussein was calm at the time of his hanging and
held a Quran in his hands. They read the death sentence to him, and "like a
broken man", he surrendered to his fate, said his last prayer without any
anxiety and put his head in the noose.
(source: Radio Zamaneh)
EGYPT:
Fears for Irish teen as Egypt 'sham trial' postponed
Amnesty has said it is gravely concerned about Irish teenager Ibrahim Halawa
after the latest postponement in Egypt of what the organisation has called his
"sham trial".
Ibrahim, 19, along with his 493 co-defendants, is now scheduled to face trial
on March 29, by which time he will have spent more than a year and 7 months
behind bars.
The Minister for Foreign Affairs, Charlie Flanagan, also expressed disquiet
over the latest developments in Cairo.
"I am disappointed to learn of the further delay today and concerned that the
Egyptian authorities continue to consider Ibrahim's case as part of a group
trial," said Mr Flanagan.
"I have personally raised the Government's concerns about this case with my
Egyptian counterpart on a number of occasions."
Dublin-born Ibrahim and the other detainees are jointly charged with murder,
attempted murder, and taking part in illegal protests after peaceful
demonstrations he had attended were broken up by the Egyptian military in
August 2013 while he was on holiday in Cairo awaiting the results of his
Leaving Cert.
The detainees could face the death penalty if they are convicted yet, so far,
all attempts to stage a trial have ended in farce, with no court room big
enough to hold the full group and with no clear structure to the proceedings in
place.
Colm O'Gorman, executive director of Amnesty International Ireland, called for
renewed focus by the Government here and by the EU on getting Ibrahim home to
Ireland.
"We have examined the case files and there is no evidence of any of the violent
charges that have been made against Ibrahim. He faces, frankly, a sham trial,"
said Mr O???Gorman.
"In other such cases we have seen mass death sentences handed down for similar
'cut and paste' charges made against large groups of people so we're gravely
concerned about the situation."
Mr O'Gorman said calls by the Government and the EU for Ibrahim to be afforded
a fair trial made no sense in a country where the criminal justice system was
not functioning to any agreed international standards.
"It is absolutely vital that all steps be taken to apply pressure on Egypt to
ensure Ibrahim's immediate and unconditional release," said Mr O'Gorman.
"There is absolutely no point in calling for Ibrahim to be granted due process
or a fair trial. There is no prospect of him getting due process or a fair
trial."
One of Ibrahim's sisters, Nosayba Halawa, and the Irish ambassador to Egypt,
Isolde Moylan, were in court when yesterday's proceedings were adjourned.
Mr Flanagan said officials in Dublin and Cairo were working actively on
Ibrahim's case.
"My department will continue to take all appropriate action to ensure Ibrahim's
welfare, and to seek a review of his case, his release and return to his family
and his studies," said Mr Flanagan.
(source: Irish Examiner)
PAKISTAN/UNITED KINGDOM:
UK government fights to keep links to Pakistan executions secret
A case concerning whether the UK overnment should be allowed to keep secret
evidence which could show it has contributed to executions in Pakistan will be
heard on 9 February 2015 by the Information Rights Tribunal (IRT).
The legal charity Reprieve has warned ministers that, by funding organisations
such as Pakistan's Anti-Narcotics Force ??? which cites the number of death
sentences it secures as a key 'achievement' - public money could be helping
support executions overseas. (http://www.ekklesia.co.uk/node/21155)
This is directly at odds with the UK's long-standing policy of opposition to
the death penalty. Reprieve has asked the Government what safeguards (if any)
it has in place to prevent public money from funding executions in Pakistan,
and what assessments it has carried out.
However, ministers have refused to provide any detail, beyond pointing to the
existence of guidance on Overseas Justice and Security Assistance (OSJA).
The OSJA is a wide-ranging piece of guidance which requires ministers to
consider whether UK support for policing and security operations could lead to
complicity in serious human rights abuses, such as torture and the death
penalty.
However, ministers have rebuffed Freedom of Information requests from Reprieve
asking whether they had sought reassurances from the Pakistani authorities that
UK support would not contribute to the imposition of death sentences for drugs
offences. The questions have become more pressing since Pakistan lifted a
moratorium on executions in December 2014.
The UK previously ceased funding to Iranian counter-narcotics programmes
because of concerns that doing so was contributing to executions. Nevertheless,
despite Pakistan resuming executions - and the country's imposition of the
death penalty for non-violent drugs offences - it has yet to take similar steps
with regard to that country.
In addition, Reprieve says it has established that a number of people facing
execution on drugs charges in Pakistan are British citizens.
Reprieve is also concerned by the UK government's attempts to impose yet more
secrecy on the process - insisting that the vast majority of the case is heard
in secret, without Reprieve, the organisation's lawyers, or even a
government-appointed, security-cleared lawyer known as a 'Special Advocate'
allowed to be present.
* Reprieve http://www.reprieve.org.uk/
* European Aid for Executions here: http://www.reprieve.org.uk/case-study/safe/
* Information Rights Tribunal (Ministry of Justice):
http://www.informationtribunal.gov.uk/Public/search.aspx
(source: ekklesia.co.uk)
JAPAN:
Pacific Journal, Vol. 13, Issue 6, No. 3, February 9, 2015.----Will Wrongful
Convictions Be a Catalyst for Change in Japanese Criminal Justice?
The Asia Pacific Journal presents a link to an extraordinary 12-minute video by
Matthew Carney of the Australian Broadcasting Corporation discussing the death
penalty and the problem of wrongful convictions in Japanese criminal justice.
This video explains what went wrong in 3 cases involving men who were
victimized in the worst kind of way by Japan's criminal justice system, and it
raises the possibility that these cases could stimulate reform in Japan's
system of capital punishment and in the criminal justice system more generally.
In the ABC video, Hakamada Iwao can be seen pacing in his sister Hideko's home
and referring to himself as "God the undefeated emperor" after being released
from death row following 48 years of incarceration - almost all of it in
solitary confinement. Hakamada confessed to 4 murders in 1966 after being
interrogated by police and prosecutors for more than 264 hours over a 23-day
period - an average of 11 hours and 30 minutes per day. My own article in this
issue of Asia Pacific Journal presents more details about the police and
prosecutor misconduct that led to Hakamada's wrongful conviction and delayed
his release for nearly half a century (see "An Innocent Man: Hakamada Iwao and
the Problem of Wrongful Convictions in Japan"). Most notably, when concerns
arose about the strength of the state's case against Hakamada during the 1st
several months of his trial, it appears that police planted 5 articles of
bloody clothing at the scene of the crimes in order to bolster their case for
conviction. In 2007, 1 of the 3 judges (Kumamoto Norimichi) who originally
convicted Hakamada and condemned him to death publically stated for the 1st
time that he had always believed in Hakamada's innocence but had been outvoted
by 2 senior judges on the Shizuoka District Court in 1968. Kumamoto's repeated
pronouncements helped lead to the judicial decision by 3 different judges of
the Shizuoka District Court that freed Hakamada from death row in March 2014
and ordered his retrial.
Ishikawa Kazuo spent more than 10 years on death row following his conviction
for the murder of 16-year-old Nakata Yoshie in Sayama City in Saitama
Prefecture in 1963. Ishikawa confessed after long and brutal interrogations
that included punches to the head and prolonged sleep deprivation. The Urawa
District Court that convicted him also concluded that he was the author of a
ransom note related to this slaying even though he was almost illiterate.
Ishikawa was from a community that historically has been subject to great
prejudice and discrimination. As a burakumin, he had to forego formal education
beyond primary school in order to help his family make a living. The ABC video
makes no mention of this important aspect of "The Sayama Case," but more
information about it can be found in John H. Davis, Jr.'s fine chapter
"Courting Justice, Contesting 'Bureaucratic Informality': The Sayama Case and
the Evolution of Buraku Liberation Politics" (in Going to Court to Change
Japan: Social Movements and the Law in Contemporary Japan, edited by Patricia
G. Steinhoff, Ann Arbor: Center for Japanese Studies, The University of
Michigan, 2014, pp.73-100). Ishikawa's death sentence was reduced to life
imprisonment by the Tokyo High Court in 1974, and he was released on parole in
1994. Since then, he and his supporters have been pushing for a retrial that
could formally declare his innocence.
Sugaya Toshikazu is the 3rd man victimized by wrongful conviction who is
portrayed in the ABC video. In what came to be known as the "Ashikaga
Incident," Sugaya was convicted in 1991 of the murder of a 4-year-old girl
based on his own coerced confession and what turned out to be a primitive DNA
test. In 2007 the journalist Shimizu Kiyoshi revealed problems in the DNA
testing method, and in 2009 a new DNA test conclusively showed that Sugaya was
innocent. (The same DNA test that was used to wrongfully convict Sugaya was
also used to convict Kuma Michitoshi of 2 murders in Iizuka, Fukuoka prefecture
in 1992, but Kuma was hanged in 2008 despite serious concerns about his
innocence; see here.) Sugaya was released after 17 years of imprisonment, and
in 2010 he was formally declared innocent at a retrial in which prosecutors
admitted that the police had forced him to confess. In 2011 Sugaya was awarded
the equivalent of about 1 million U.S. dollars in compensation by the Japanese
government. While Sugaya was in prison under a life sentence, 2 other young
girls were killed near Ashikaga City, and 2 more were killed in Ohta City, on
Gunma Prefecture's border with Ashikaga. Wrongful convictions are tragic for
many reasons, and 1 of the least appreciated is the fact that while the wrong
person is in custody, the real offender remains free to commit more crimes.
The ABC video also shows scenes from a press conference attended by Hakamada,
Ishikawa, Sugaya, and two other victims of wrongful conviction: Sugiyama Takao
and Sakurai Shoji, who were sentenced to life imprisonment in 1970 for a
robbery-murder in the town of Fukawa in Ibaraki prefecture in 1967. The 2
victims of wrongful conviction in this "Fukawa case" were released on parole in
1996 and declared not guilty in a retrial that ended in 2011. Like most other
victims of wrongful conviction in Japan, Sugiyama and Sakurai both falsely
confessed after long and coercive interrogations, and police and prosecutors
failed to disclose to the defense many pieces of evidence that pointed to their
innocence. It took nearly 45 years to exonerate them, and in 2012 they each
received 130 million yen (about $1.6 million) in compensation from the state.
The ABC video includes compelling testimony from former prosecutor Ichikawa
Hiroshi about the pressures police and prosecutors feel to produce confessions
and convictions even when they are inconsistent with the truth. The conclusion
of the video also raises the "hope" that the revelation of wrongful convictions
could be a "catalyst" for change in Japanese criminal justice. But recent
history suggests that positive change will be far from automatic. In the 1980s,
4 men were released from death rows in Japan because of evidence of their
innocence (see Daniel H. Foote, "From Japan's Death Row To Freedom," Pacific
Rim Law & Policy Journal, Vol.1, No.1 (Winter 1992), pp.11-103). Thereafter,
there was much discussion about the need for reform in Japanese criminal
justice and capital punishment, yet few meaningful reforms were implemented.
Two decades later, even the advent of a lay judge system of civilian
participation (in 2009) has had little effect on Japanese conviction rates or
death sentencing practices. In the United States, the revelation of wrongful
convictions has helped drive death sentences and executions down by more than
1/2 since they peaked in the late 1990s and has contributed to the abolition of
capital punishment in 6 states since 2007 (New Jersey, New York, New Mexico,
Illinois, Connecticut, and Maryland). For similar reforms to occur in Japan, an
entrenched "culture of denial" will need to be challenged and changed. The
contours and consequences of this culture of denial are described in another
article published in this issue of Asia Pacific Journal: "Wrongful Convictions
and the Culture of Denial in Japanese Criminal Justice" (by David T. Johnson).
That article concludes with these lines:
"...Japanese prosecutors are still appealing the decision to grant Hakamada
[Iwao] a retrial, and police are on their side. Their stance has two main
causes: a desire to save face, and a tendency toward tunnel vision which leads
them to dismiss evidence that is inconsistent with their preferred outcome
("guilty!") as irrelevant, incredible, or unreliable. If you recognize that
errors are inevitable, you will not be surprised when they occur and you will
have plans in place to correct them. Conversely, if you refuse to admit to
yourself or the world that mistakes do occur, then every wrongful conviction
becomes stark and embarrassing evidence of how wrong you are (Tavris and
Aronson, 2007, p.156). Japan's culture of denial is toxic to justice, and so is
the certainty of criminal justice officials about the propriety of their own
conduct. Doubt is a skill they still need to learn, and error is a reality they
must learn to acknowledge..."
This is part 1 of a 3 part series curated and written by David T. Johnson on
The Death Penalty and the Miscarriage of Justice in Japan.
Recommended citation: "Will Wrongful Convictions Be a Catalyst for Change in
Japanese Criminal Justice?", The Asia-Pacific Journal, Vol. 13, Issue 6, No. 3,
February 9, 2015.
(source: David T. Johnson is Professor of Sociology, University of Hawaii at
Manoa and an Asia-Pacific Journal contributing editor. He is co-author (with
Franklin E. Zimring) of The Next Frontier: National Development, Political
Change, and the Death Penalty in Asia (Oxford University Press, 2009),
co-author (with Maiko Tagusari) of Koritsu Suru Nihon no Shikei [Japan's
Isolated Death Penalty] (Gendai Jinbunsha, 2012), and former co-editor of Law &
Society Review----Japan Focus)
ETHIOPIA:
Andy Tsege case: Ethiopia refuses to allow access to imprisoned British citizen
---- Dissident was kidnapped in Yemen last June and now is facing the death
penalty
Ethiopia has refused to allow a delegation of parliamentarians to visit a
British dissident facing the death penalty in the African country.
Andy Tsege, who is the secretary-general of a banned Ethiopian opposition
movement, was sentenced to death at a trial held in his absence in 2009. He was
travelling from Dubai to Eritrea last June when he disappeared during a
stopover in Yemen, in what campaigners regard as a politically motivated
kidnapping. Weeks later, he emerged in detention in Ethiopia.
A delegation led by Jeremy Corbyn, Mr Tsege's constituency MP, was to visit
Ethiopia in a bid to secure his release. But the trip was abandoned after a
meeting with Ethiopian ambassador Berhanu Kebede in London last week.
Mr Corbyn told The Independent: "We had made plans to go and see him next
weekend and they said we would be refused admission to the detention facility."
Lord Dholakia, the vice-chairman of the all-party parliamentary group on
Ethiopia, who was due to travel out with Mr Corbyn, said it was made clear that
they would not be welcome. Mr Corbyn is demanding that the Ethiopian government
allows Mr Tsege's lawyer, Clive Stafford-Smith, the director of Reprieve, to
visit him and will raise the issue in the Commons this week. The Ethiopian
embassy in London has accused Mr Tsege - who came to Britain as a political
refugee in 1979 - of being a member of a "terrorist organisation" which wants
to "overthrow the legitimate government of Ethiopia".
A spokesman for the Ethiopian embassy said: "The ambassador advised the
parliamentarians that there was no need for them to go to Ethiopia as the case
is being properly handled by the courts."
Last night, Yemi Hailemariam, Mr Tsege's partner and mother of their three
children, accused the ambassador of being "a mouthpiece for his bosses who have
no regard for basic human rights". Mr Tsege's family will go to Downing Street
today - which is his 60th birthday - to hand in a petition calling on David
Cameron to demand his return. It can also be revealed that the Foreign Office
minister Tobias Ellwood broke a promise to Mr Tsege's family that his case
would be raised during the African Union summit in Ethiopia last month.
Mr Ellwood had pledged that senior officials would raise the case. But in an
email sent to Ms Hailemariam last week, a government official admitted: "Access
to Ethiopian ministers is extremely limited during the summit and so it wasn't
possible to have a bilateral meeting with senior officials who might have
influence over the case."
A spokesman for the Foreign Office said: "We remain deeply concerned about
Ethiopia's refusal to allow regular consular visits to Mr Tsege and his lack of
access to a lawyer, and are concerned that others seeking to visit him have
also been refused access."
(source: The Independent)
LEBANON:
Should Lebanon execute convicted terrorists?
"An eye for an eye and a tooth for a tooth." This is how Jordan retaliated for
the execution of Jordanian pilot Muath al-Kasasbeh, who was brutally murdered
by the Islamic State (IS). Jordan has executed 2 Iraqi prisoners: Sajida
Rishawi and Ziad Karbouli. This was the 1st retaliation of its kind by a
country threatened by IS.
After Jordan executed 2 Iraqi prisoners in response to the brutal killing of a
Jordanian pilot by the Islamic State, a debate arose in Lebanon about why the
government does not do the same when the organization kills one of the Lebanese
soldiers it is holding captive.
There is no doubt that the [crime shown in the] video released by IS calls for
a maximum punishment against this unjust organization. Nevertheless, there have
been diverse reactions to Jordan's actions. Some believe that the state's
decision is a normal reaction to assert the stature of the state before its
people in the face of IS. Meanwhile, others reject retaliating with the same
level of brutality as the execution of Kasasbeh.
This development has caused a stir in Lebanon, which has witnessed the
slaughtering or shooting of its soldiers at the hands of IS without retaliating
by executing some of the organization's prisoners to restore the prestige of
the Lebanese state.
A constitutional source asked, "Is there a state in the first place?" He said,
"The state has been beheaded by the absence of a president of the republic,
which is as serious as the executions carried out by IS. Only when a president
is elected and its prestige restored can the state deal with sub-issues and
decide whether or not to execute IS prisoners who killed our soldiers."
In response to the question, Can't the government replace the president? The
source answered, "The current government is interim, and the state is headless.
Those who are demanding that the state restore its prestige have to first get a
new head of state. They should demand the election of a president first and
foremost to embark on the path of having a prestigious state."
Former president of the Supreme Judicial Council, Judge Ghaleb Ghanem,
expressed his respect for the sovereignty of the Jordanian state, courts and
judges. He stressed, however, "According to Lebanese law, the death penalty
should be in response to a certain event, especially if such an event has
occurred outside Lebanon."
Despite the fact that Ghanem is inclined toward applying the law and strict
prosecutions, he rejects the death penalty. "We cannot emulate the acts of
outlaws and fight them with the same evil. The rule of law ought to be our
ultimate reference," he said to An-Nahar.
Asked what would happen if a death sentence is issued against one of the IS
detainees, Ghanem answered, "It is up to the Lebanese state and the judicial,
executive and security authorities to choose the right time to carry out the
sentence, so that it does not look like a reaction or a retaliation that is not
provided for by the judiciary.
"I stress the need to preserve and prioritize the prestige of the state and
comply with the law and provisions, but I am personally against death
sentences," Ghanem added. For his part, Maj. Gen. Yassin Sweid believes,
"Although Jordan is entitled to reciprocate IS' crime, Lebanon should not do
the same, given that there are Lebanese soldiers kidnapped by IS and Jabhat
al-Nusra. The execution of any member of the organization may be met with the
killing of 10 Lebanese soldiers. Therefore, Lebanon should distance itself from
this losing battle." Sweid added, "It is impossible to respond to IS so long as
the soldiers are still held captive. The decision to respond is in the hands of
IS because it is an immoral and ruthless organization."
Asked if there should be a response if IS executes another soldier, Sweid
answered, "It is a hellish phase, and if Lebanon were dragged into it, then
this would lead to regrettable massacres, and we cannot keep pace with IS when
it comes to these grievances." Sweid wondered, "What could we possibly do if
they reciprocate by killing soldiers? What would be our position toward the
relatives of the kidnapped?"
Sweid believes that "the state's prestige starts by retrieving the soldiers,
waging a war and then invading terrorist-controlled areas." He noted, "No one
can respond to them at the moment. Even Arab countries do not reciprocate with
death. It is true that Jordan responded because it is IS that started it, but
nothing stops IS from killing any Jordanian and going on a killing streak. This
is why this organization must be fought instead of reciprocating with the
killing of its members."
In addition to the aforementioned opinions, waves of popular anger emerged on
social networking sites in Lebanon in the hours following the execution of the
Jordanian pilot and the official reaction to it. Many asked the Lebanese state
to execute the convicted terrorists in response to IS' execution of a Lebanese
soldier. But will these demands remain restricted to an outburst of anger as
they collide with difficult and complicated Lebanese facts?
(source: al-monitor.com)
_______________________________________________
DeathPenalty mailing list
DeathPenalty@lists.washlaw.edu
http://lists.washlaw.edu/mailman/listinfo/deathpenalty
Search the Archives: http://www.mail-archive.com/deathpenalty@lists.washlaw.edu/
~~~~~~~~~~~~~~~~~~~~~~~~~~~
A free service of WashLaw
http://washlaw.edu
(785)670.1088
~~~~~~~~~~~~~~~~~~~~~~~~~~~
