107B
AMERICAN BAR ASSOCIATION
ADOPTED BY THE HOUSE OF DELEGATES
FEBRUARY 9, 2015
RESOLUTION
RESOLVED, That the American Bar Association urges federal, state, local, territorial
and tribal governments to protect the integrity of criminal proceedings, in its truth
seeking function, by (1) seeking to hold accountable those who unlawfully intimidate or
tamper with victims and prosecution and defense witnesses by any source or means,
including the use of social media; and (2) examining practices, procedures, and training,
and revising them as needed to assure that victims and witnesses are not improperly
intimidated or tampered with by lawyers or law enforcement personnel, and that they
receive adequate protection against intimidation and tampering by any person.
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Report
Introduction
The resolution addresses the corrupting influence that unlawful and improper
intimidation can have on the testimony of witnesses, including victims, in criminal trials
and the reality that intimidation undermines the rule of law and the credibility of the
judicial process. The possibility that victims and witnesses will be targeted by
individuals who seek to influence their testimony is not new. It has been present since
the founding of the Nation. The Resolution deals with two related, but different,
problems: (1) illegal intimidation, and (2) improper intimidation and tampering.
Illegal Intimidation
In 2012, the House of Delegates approved [then-numbered] Report 107 B, which
called upon prosecutors to do more to address and prevent witness and victim
intimidation. The 2015 Resolution builds on the 2012 resolution in several ways. It does
not focus on prosecutors. Instead, it focuses on governments writ large. Experience has
demonstrated that one of the challenges to prosecuting illegal intimidation is persuading
the victims and witnesses who are targeted to come forward to report the intimidation.
Prosecutors cannot prosecute acts of which they are unaware.
The Resolution envisions that many governmental agencies can play a role in
making it more probable that those individuals who seek to intimidate victims and
witnesses will be discovered. For example, social service agencies may become aware of
acts of intimidation and may be able to persuade clients to report the acts if the agency
itself cannot report. Courthouses could display signs encouraging anyone with
knowledge of acts of intimidation to report them.
The goal is to expand the responsibility of dealing with intimidation beyond
prosecutors to all government actors who can assist with detection and reporting of illegal
acts of intimidation. Law enforcement agencies often have more contact with witnesses
than do prosecutors and can encourage victims and witnesses to come forward to
complain about illegal intimidation. They might set up hotlines for reporting of
intimidation.
The Resolution makes clear that the concern about intimidation of defendants and
defense witnesses is the same as the concern about victims and prosecution witnesses.
The integrity of criminal proceedings is threatened when any victim’s or witness’s
testimony is affected by threats, coercion, bribes or any other illegal means.
While in 1789, intimidation usually required personal contact or delivery of
written threats, with the development of the telephone, intimidation from a distance
became a new threat. In the current digital age, communication with victims and
witnesses is possible in an ever-expanding array of ways. And many victims and
witnesses have wittingly or unwittingly exposed a vast array of information about
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themselves on social media, making it easier for any one seeking to find them and
influence them, to attempt to do so.
Prosecutors and law enforcement have consistently reported that the highest rates
of witness intimidation exist in cases involving domestic violence, gangs and drug
dealing.1 However, witness intimidation can occur in any type of case, from white collar
crimes to petty offenses. Domestic and intimate partner violence cases arise from the
complex web of family and intimate relationships.
Witness intimidation comes most often directly from close family and friends
who are personally known to all parties. Ensuring the safety and cooperation of these
victims and witnesses present specific types of challenges. In cases of domestic abuse,
law enforcement officials have long observed a tragic pattern: a battered woman will
report abuse by her partner to authorities, only to later refuse to cooperate in the
prosecution of the abuser. The most common reasons given for withdrawing cooperation
include “safety, a desire to save the relationship and economic pressures.”2 Between 25
and 75 percent of women seeking help in shelters return to their partners shortly after
leaving.3 Unfortunately, women who drop charges against their abuser “are four times
more likely to suffer future violence than those who do not.”4 Although it is sometimes
possible to prosecute domestic violence cases even when a victim decides to withdraw
cooperation, it is often difficult. There is little that prosecutors can do when there is
insufficient evidence to support a conviction.
Gang and drug trafficking cases present a different dynamic and set of dangers to
victims and witnesses.5 Intimidation is a key feature of gang and drug-related violence.
Gangs, like other criminal enterprises, exist to accumulate power and profit. The
prosecution of any member, particularly for a serious offense, threatens all members.
Gang associates can be instructed to carry out orders of intimidation and retaliation
against witnesses, including orders of execution. In one example in Baltimore, a
convicted murderer ordered the execution of a trial witness as well as the witness’s
daughter and the daughter’s boyfriend.6
1
Kelly Dedel, Witness Intimidation, Problem Specific Guides Series No. 42, Center for Problem-Oriented
Policing, Office of Community Oriented Policing Services, U.S. Department of Justice (Jul. 2006), at 7.
2
Paula Reed Ward, Why do some victims of domestic violence refuse to testify? , Pittsburgh Post-Gazette,
(June 23, 2013) http://www.post-gazette.com/local/region/2013/06/23/Why-do-some-victims-of-domesticviolence-refuse-to-testify/stories/201306230145
3
Anna Aizer and Pedro Dal Bo, Love, hate and murder: Commitment devices in violent relationships, 93
Journal of Public Economics 412, 414 (2008).
4
Id. at 414.
5
John Anderson, Gang-Related Witness Intimidation , National Gang Center Bulletin , U.S. Department of
Justice Office of Justice Programs, Bureau of Justice Assistance and Office of Juvenile Justice Delinquency
Prevention (Feb. 2007), at 1.
6
MaryAnn Spoto, Killers Ordered Execution of Witness, Ocean Prosecutor Charges , NJ.com (Nov. 19,
2008), http://www.nj.com/news/index.ssf/2008/11/killers_ordered_execution_of_w.html (stating that two
gang members convicted of murder ordered the execution of a trial witness as well as the witness’s
daughter and the daughter’s boyfriend). APPVideo, Witness Tampering Murder Sentence (12/1/09),
YouTube (Dec. 1, 2009),
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Victims and witnesses who live near offenders are at a greater risk of intimidation
than those who live elsewhere.7 When gang members make a credible threat of violence,
including against the witness’s family, friends and loved ones, the threat becomes an
effective tool to wield against any potential witness. Additionally, in inter-gang violence,
the roles of offender, victim and witness are often interchangeable and revolving; the
same individual may, at different times, be a victim, a witness and an offender, and rather
than cooperate with law enforcement, he/she may choose to retaliate. In many cases
there is little that any government officer can do to persuade witnesses and victims to
report intimidation and enable prosecution. The goal is to arrive at new strategies using
an array of governmental offices and incentives to encourage reporting and cooperation
so that illegal intimidation can be prosecuted successfully.e resolution urges these
governments to examine practices, procedures and training to determine whether they are
doing all that is necessary and desirable to protect against victim and witness intimidation
and to revise practices, procedures and training as needed to assure that the protections
are adequate.
Illegal Intimidation and the New Challenges of Social Media
In 1895, the United States Supreme Court articulated the rights and obligations of
a crime witness. The Court wrote that “it is the duty and the right … of every citizen, to
assist in prosecuting, and in securing the punishment of any breach of the peace of the
U.S.” The court recognized that it is the duty of government to see that a witness may
pursue this right and duty freely, and “to protect him from violence while so doing, or on
account of so doing.”8 Thus, it is well established that a crime witness has both a right
and a duty to participate in the criminal justice system and should feel free to come
forward and to present evidence of criminal behavior without fear of harm or retribution.
It has been and remains the duty of government to protect witnesses, including victims
from intimidation that generates the kind of fear that discourages participation in the
criminal process or distorts the truth-finding goal of that process.
Social media has become a fundamental part of modern life, and it has increased
the difficulty of dealing with the problem of victim and witness intimidation. The most
commonly used social media websites – Facebook, YouTube, Instagram, Twitter,
Snapchat, and dozens of other multi-media social networking sites -- have become a
primary method for information-sharing and self-expression. Unfortunately, social
media also has a dark side, having become a simple and effective way to intimidate
witnesses.9
https://www.youtube.com/watch?v=rY1XIBaXRhE (stating that the gang members were convicted of
witness tampering).
7
. Robin Elliott, Vulnerable and Intimidated Witnesses: A Review of the Literature, Speaking Up for
Justice (1998), at 118.
8
In re Quarles, 158 U.S. 532, 536.
9
See generally Kevin Davis, Witness Harassment has Gone Digital, and the Justice System is Playing
Catch-Up, ABA Journal (Aug. 1, 2013).
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Social media has been used by defendants, their families, friends and associates to
attack potential witnesses in every imaginable way: publishing “tweets” aimed at a
named witness; lining up a series of cartoon ‘emoji[s]’ (i.e. a rat, a gunshot, and a gun) to
deliver a readily understood threat; and posting witnesses’ names and personal
information, some of which are accompanied by images of secret grand jury testimony
and police reports, and denouncing them as “snitches” deserving of general disdain and
retribution.10
Also, due to the public nature of social media, the threatening postings contribute
significantly to the chilling effect among other potential witnesses who can fully expect
similar treatment if exposed.11
Social media makes it easy to intimidate a witness. Individuals who might not
participate in physical attacks or deliver personal threats can now intimidate a witness
from the comfort of their own homes. Cellular networks provide Internet connectivity
virtually everywhere, enabling users to easily post threatening content instantly. User
accounts can be established under any name, real or fictitious, and within minutes, posts
are added and others can join in on the abuse with the click of a button. Cell phones and
smartphones that can convey threats or take pictures have become so problematic inside
courtrooms that a number of courts have adopted new, more restrictive cell and wireless
policies. The problem extends to prisons, where smuggled cell phones and smart phones
make it easy for inmates to harass their victims or accusers using e-mail, text and social
networks.12
Technology and social media have effectively nurtured and spread the anti-snitch
culture. The number of websites promoting the anti-snitch culture and the ferocity of its
message is a good indicator of just how dangerous this phenomenon has become. Antisnitch music videos and videos exposing snitches have proliferated on YouTube,
10
. See, e.g., Kim Ring, Holden teen awaits bail ruling in witness intimidation case, Worcester
Telegram & Gazette (Dec. 7, 2013), http://www.telegram.com/article/20131207/NEWS/312079888
Rebecca Hiscott, Yes Emoji Death Threats Are Admissible , Mashable (Jan. 16, 2014),
http://mashable.com/2014/01/16/emoji-death-threat/; Esteban Parra, Website that outed Wilmington
‘snitches’ removed , The News Journal (Jan. 17, 2014),
http://www.delawareonline.com/story/news/crime/2014/01/17/website-that-outed-wilmington-snitchesremoved-/4609399/; and James Staas, Man convicted of witness intimidation after grand jury testimony is
posted on Facebook, Buffalo News (Oct. 30, 2013), http://www.buffalonews.com/city-region/erie-countycourt/man-convicted-of-witness-intimidation-after-grand-jury-testimony-is-posted-on-facebook-20131030
11
Antisnitch problems worsen with Facebook, Eerie Times (Sept. 25, 2013),
http://www.timesleader.com/news/ouropinion/848368/OTHER-OPINION:-WITNESS-INTIMIDATIONAntisnitch-problems-worsen-with-acebook?template=art_smartphone.
12
AP, Inmates use Facebook to harass their victims, intimidate witnesses from behind bars, New York
Daily News (Nov. 21, 2011), http://www.nydailynews.com/news/national/inmates-facebook-harassvictims-intimidate-witnesses-behind-bars-article-1.980641
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amassing hundreds of thousands of views.13 YouTube videos of so-called snitches being
jumped and beaten are easily accessible. Facebook groups with names like “Snitches get
stitches,” “The snitch list,” and “Snitches R Us” are made with the dual purpose of
tampering with specific witness testimony and denouncing snitching in general.
Blogs such as “SnitchWire,” databases and other websites are gathering spaces for
users to post anonymous, threatening messages to expose anyone the users consider
“snitches.”14
As social media grows and the loss of privacy becomes more apparent, all
participants in the criminal justice system, including judges, attorneys, court personnel
and jurors as well as victims and witnesses, have become more concerned for their safety.
Identifying the source of illegally disseminated court documents and police reports alone
raises a number of difficult issues, including: access to, and security of, court records and
documents; the responsibility of attorneys and others when discovery documents are
posted on social media or copied and used to intimidate witnesses; the responsibility of
social media companies when their venues are used to commit a crime; and many more.
Prosecutors, law enforcement officials and defense counsel have good reason to
be concerned about witness intimidation. Where successful, witness intimidation results
in the frustration of a party’s search for the truth. Intimidation can lead to a variety of
outcomes. Persons known to have been present during a crime may refuse to speak with
investigators, claim to have seen nothing or deny having been present at a crime scene.15
When forced to testify, they may “forget” everything about the crime, claim a Fifth
Amendment privilege or actually testify falsely. They may simply disappear prior to
trial, or never come forward at all. In the most extreme cases, witnesses and at times,
their families, are executed — usually publicly and violently.16 In all instances, justice is
not served and the integrity of the judicial process is undermined.
As it becomes easier for those seeking to intimidate witnesses to find them and
communicate with them, the burden increases on governments to develop new ways to
. See, e.g., TheKeepitgutta, Keep it gutta presents. Daniel Schorn, Stop Snitchin’: Rapper Cam’ron:
Snitching Hurts His Business, “Code of Ethics”, CBS News (Apr. 19, 2007),
http://www.cbsnews.com/news/stop-snitchin/.
14
See, e.g., Mission Statement, SnitchWire, http://snitchwire.blogspot.com/ (stating the blog’s
Mission Statement: “SnitchWire exists solely for the purpose of investigating and objectively reporting on
the existence and actions of known informants, infiltrators, rats, snitches, and provocateurs. This blog is to
be used as a tool for people wishing not to associate with such unsavory, treacherous scum. Individuals
pursuing a ‘snitches get stitches’ policy do so on their own accord and are in no way affiliated with this
publication”).
13
See, e.g., David Kocieniewski, A Little Girl Shot, and a Crowd That Didn’t See, New York Times (Jul.
9, 2007), http://www.nytimes.com/2007/07/09/nyregion/09taj.html?pagewanted=all.
16
Press Release, U.S. Attorney’s Office, Eastern District of Pennsylvania, Drug Kingpin Kaboni
Savage and Sister Kidada Convicted of Arson Murders, Federal Bureau of Investigations (May 13, 2013)
(explaining they the defendant was convicted of witness intimidation and murder by ordering the
firebombing of the family home of a key eyewitness in his multiple murder trial).
15
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encourage victims and witnesses to cooperate with law enforcement and prosecutors.
Improper Intimidation and Tampering
Experience has shown that there are various kinds of intimidation. Threats of
harm or retaliation are perhaps the most obvious and egregious. They are also unlawful
and prohibited in every jurisdiction, as they should be. But there are instances in which
lawyers (both prosecutors and defense counsel) and their investigators may act in ways
that intentionally or unintentionally may improperly influence victim and witness
testimony. Law enforcement officers and prosecutors have authority entrusted to them
that defense counsel and defendants do not share. Prosecutors have the grand jury and
subpoena power. They have the right to confer immunity upon witnesses, the right to
offer plea deals in exchange for cooperation, and the right to increase the exposure of
uncooperative witnesses. All members of the bar share an interest is seeing that such
authority is exercised justly.
The vast majority of lawyers and investigators who work within the criminal
justice system do so with respect for victims and witnesses. Unfortunately,
there are a few who do not. The desire to make or defeat cases and the desire to win
cases that are tried may cause some attorneys and their investigators to use tactics that
threaten the integrity of witness testimony. Some conduct is unlawful, and some is
egregious. For example, in 2013, a high-profile defense attorney and former federal
prosecutor, Paul Bergrin, was convicted in federal court in New Jersey of conspiring to
kill a key government witness in his client’s drug-dealing case.17
Law enforcement can also be involved in witness tampering. In Santa Ana,
California, a trial court judge reprimanded prosecutors for “contemptible conduct toward
witnesses” and dismissed the securities violation case after the prosecutors called a
witness’s employer and “spread innuendo” that resulted in the witness losing her job.18
Afterward, the prosecutors “pressured her into pleading guilty” to an offense that
occurred seven years earlier, and conditioned the guilty plea on her “changing her story
to support the prosecution” in the securities violation case.87 In his reprimand, the judge
said he had “absolutely no confidence that any portion of [the witness’s] testimony was
based upon her own independent recollection of events as opposed to what the
government thought her recollection should be on these events.”19
Such examples are surely the exception rather than the rule. But, there are more
subtle ways in which lawyers and investigators can seek to affect what victims and
witnesses say. Lawyers are well advised to pay careful attention to the ABA Standards
17
Kate Zernike, New Jersey Lawyer Guilty of Murder, New York Times (Mar. 18, 2013),
http://www.nytimes.com/2013/03/19/nyregion/paul-w-bergrin-new-jersey-lawyer-convicted-ofmurder.html?pagewanted=all
18
Tim Lynch, Judge Dresses Down Federal Prosecutors, Cato Institute (Dec. 18, 2009),
http://www.cato.org/blog/judge-dresses-down-federal-prosecutors.
19
Id.
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on the Prosecution and Defense Function as well as the rules of professional conduct that
apply in their jurisdictions.
The undeniable fact is that lawyers, through their professional skill and status, and
investigators, through their skill and persuasiveness, may be able to affect victim and
witness testimony in worrisome ways, even without realizing that they are doing so. This
explains in large measure why lawyers cannot contact represented opposing parties
without permission of their counsel. One of the ways that prosecutors and defense
counsel and their investigators can protect against intimidating victims and witnesses is to
adopt a policy of telling them all the following: “You may be speaking to lawyers and
investigators as a case progresses. If anyone, including me, does or says anything that
causes you to think that that person is trying to get you to change testimony or to say
something that is not entirely truthful, tell that person, including me, that you believe you
are being pressured improperly. If it is a prosecutor or law enforcement officer you feel
has improperly pressured you, do not hesitate to report that to defense counsel or to the
prosecutor’s or law enforcement officer’s superiors. And if it is defense counsel or a
representative of the defense who has done so, do not hesitate to report that to the
prosecutor.”
Conclusion
The Resolution highlights the threat to the integrity of the criminal justice system
as a result of victim and witness intimidation. Meaningful participation in the criminal
justice system cannot exist when victims and witnesses are too fearful to come forward or
are afraid to tell the truth about what they know. When victims and witnesses are too
fearful to participate in the judicial process, the system of justice no longer retains
credibility within society and the rule of law as a great arbiter, withers and dies. The
Internet has created an explosion of new methods by which a victim or witness can be
intimidated with ease, thus making witness intimidation a graver problem than ever
before. The prevention of witness intimidation requires renewed, dedicated focus and
should be a high priority for all members of the criminal justice system. Legislatures
must assure that laws are updated and adequate to deal with new challenges, prosecutors
and defense counsel must be alert to the new dangers associated with social media. And
all participants in the criminal justice system must be aware of the various ways in which
victims and witnesses can feel that they are being improperly pressured. The most
egregious forms of intimidation must be investigated and prosecuted, but the more subtle
forms must not be ignored.
Respectfully submitted,
Jim Felman and Cynthia Orr, Chairs
Criminal Justice Section
February 2015
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GENERAL INFORMATION FORM
Submitting Entity: Criminal Justice Section
Submitted By: Jim Felman and Cynthia Orr, Chairs
1.
Summary of Resolution(s).
The resolution addresses the corrupting influence that unlawful and improper
intimidation can have on the testimony of witnesses, including victims, in
criminal trials and the reality that intimidation undermines the rule of law and the
credibility of the judicial process. The possibility that victims and witnesses will
be targeted by individuals who seek to influence their testimony is not new. It has
been present since the founding of the Nation. In 1789, intimidation usually
required personal contact or delivery of written threats. With the development of
the telephone, intimidation from a distance became a new threat. In the current
digital age, communication with victims and witnesses is possible in an ever
expanding array of ways. And many victims and witnesses have wittingly or
unwittingly exposed a vast array of information about themselves on social media,
making it easier for any one seeking to find them and influence them, to attempt
to do so.
2.
Approval by Submitting Entity. This resolution was approved by the Criminal
Justice Section Council at its Fall Meeting on October 25, 2014.
3.
Has this or a similar resolution been submitted to the House or Board previously? No
similar resolution has been previously submitted.
4.
What existing Association policies are relevant to this Resolution and how would
they be affected by its adoption? Approval of this resolution would expand the topics
covered in resolution 107B from the Annual Meeting 2012 by covering social media
and other topics.
5.
If this is a late report, what urgency exists which requires action at this meeting of
the House? Not applicable.
6.
Status of Legislation. (If applicable) Not applicable.
7.
Brief explanation regarding plans for implementation of the policy, if adopted by the
House of Delegates. The policy will be distributed to various criminal justice
stakeholders as a tool to offer guidance on the role of the prosecutor and defense
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counsel. The policy will also be featured on the Criminal Justice Section website
and in Section publications.
8.
9.
Cost to the Association. (Both direct and indirect costs) No cost to the Association
is anticipated.
Disclosure of Interest. (If applicable) None
10. Referrals.
At the same time this policy resolution is submitted to the ABA Policy Office for
inclusion in the 2015 Midyear Agenda Book for the House of Delegates, it is being
circulated to the chairs and staff directors of the following ABA entities:
Standing Committees
American Judicial System Standing Committee
Ethics and Professional Responsibility
Federal Judiciary
Legal Aid and Indigent Defendants
Professionalism
Special Committees and Commissions
Children and the Law
Coalition on Racial and Ethnic Justice
Commission on Domestic and Sexual Violence
Commission on Youth at Risk
Death Penalty Representation Project
Hispanic Legal Rights and Responsibilities
Sexual Orientation and Gender Identity
Sections, Divisions
Government and Public Sector Lawyers Division
Individual Rights and Responsibilities
Family Law
Judicial Division
Litigation
State and Local Government Law
Young Lawyers Division
11. Contact Name and Address Information. (Prior to the meeting. Please include name,
address, telephone number and e-mail address)
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Kevin Scruggs
Director, Criminal Justice Standards Project
American Bar Association
1050 Connecticut Ave. NW, Suite 400
Washington, DC 20036
Phone: 202-662-1503
Fax: 202-662-1501
Email: kevin.scruggs@americanbar.org
12. Contact Name and Address Information. (Who will present the report to the House?
Please include name, address, telephone number, cell phone number and e-mail address.)
Stephen A. Saltzburg, Section Delegate
George Washington University Law School
2000 H Street, NW
Washington, DC 20052-0026
Phone: (202) 994-7089; (202) 489-7464
Email: ssaltz@law.gwu.edu
Neal R. Sonnett, Section Delegate
2 S. Biscayne Boulevard, Suite 2600
Miami, FL 33131-1819
Phone: (305) 358-2000
Email: nrslaw@sonnett.com
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EXECUTIVE SUMMARY
1.
Summary of the Resolution
The resolution addresses the corrupting influence that unlawful and
improper intimidation can have on the testimony of witnesses, including victims, in
criminal trials and the reality that intimidation undermines the rule of law and the
credibility of the judicial process. The possibility that victims and witnesses will be
targeted by individuals who seek to influence their testimony is not new. It has been
present since the founding of the Nation. In 1789, intimidation usually required personal
contact or delivery of written threats. With the development of the telephone,
intimidation from a distance became a new threat. In the current digital age,
communication with victims and witnesses is possible in an ever expanding array of
ways. And many victims and witnesses have wittingly or unwittingly exposed a vast
array of information about themselves on social media, making it easier for any one
seeking to find them and influence them, to attempt to do so.
2.
Summary of the Issue that the Resolution Addresses
Prosecutors and law enforcement have consistently reported that the
highest rates of witness intimidation exist in cases involving domestic violence, gangs
and drug dealing. However, witness intimidation can occur in any type of case, from
white collar crimes to petty offenses. Domestic and intimate partner violence cases arise
from the complex web of family and intimate relationships.
3.
Please Explain How the Proposed Policy Position will address the issue
The Resolution highlights the threat to the integrity of the criminal justice
system as a result of victim and witness intimidation. Meaningful participation in the
criminal justice system cannot exist when victims and witnesses are too fearful to come
forward or are afraid to tell the truth about what they know. When victims and witnesses
are too fearful to participate in the judicial process, the system of justice no longer retains
credibility within society and the rule of law as a great arbiter, withers and dies. The
Internet has created an explosion of new methods by which a victim or witness can be
intimidated with ease, thus making witness intimidation a graver problem than ever
before. The prevention of witness intimidation requires renewed, dedicated focus and
should be a high priority for all members of the criminal justice system. Legislatures
must assure that laws are updated and adequate to deal with new challenges, prosecutors
and defense counsel must be alert to the new dangers associated with social media. And
all participants in the criminal justice system must be aware of the various ways in which
victims and witnesses can feel that they are being improperly pressured. The most
egregious forms of intimidation must be investigated and prosecuted, but the more subtle
forms must not be ignored.
4.
Summary of Minority Views
None are known.
12