PreLaw Magazine's Top Public Interest Schools

PreLaw magazine has an article discussing support for public interest work in law schools. Our town looks good: in the magazine's ranking, the UW is #8 and Seattle U is #16. Best Public Interest Law Schools, preLaw Magazine - Fall 2008, at 28.

Everett judge won't hear case of lab monkey's death

Pasado's Safe Haven tried to file a citizen's complaint against employees of an animal testing lab who scalded a monkey to death when they ran its cage through a washer. The Snohomish County prosecutor's office and the Everett City Attorney had declined to file charges, and Everett District Judge Roger Fisher declined to allow the citizen's complaint to go forward. Everett judge won't hear case of lab monkey's death | Seattle Times Newspaper, Oct. 30, 2008.

Pasado's was represented by Adam Karp, a UW grad who teaches animal law at the UW and Seattle U.

WSBA's YouTube Contest

The Washington State Bar Association invites you to create a short video (3 minutes max.) showing "your vision of justice for all as citizens of Washington state." Not only do you get to use your creativity and express yourself, but you also will be in the running for two $1000 prizes -- one to be selected by a panel of judges and one People's Choice winner. You might even get both!

Details about the contest are here. The deadline for posting entries on YouTube is June 15, 2009.

Alliance for Justice: Our Rights, Our Courts, Our Future

The Alliance for Justice held a day-long program, Our Rights, Our Courts, Our Future on Sept. 25. Now you can watch video of most of the speakers (and read a transcript of one speaker's remarks) here.

• Access Denied? Our Courts and Consumer Protection. Panel includes Diana Levine, the plaintiff in a case before the Supreme Court this Term (see Drug Label, Maimed Patient and Crucial Test for Justices, N.Y. Times, Sept. 18, 2008).
  
• Executive Privilege: Abuse of Presidential Power in the Bush Administration
• Repercussions of Judicial Selection in the Bush Administration.

Also available:

• transcript of May 28, 2008, luncheon speech by Hon. Patricia M. Wald (D.C. Cir.)
• Video, Supreme Injustices. (This is one of the films Abby Ginzberg recommended last week.)
• Herman Schwartz Distinguished Lecture (March 3, 2008) by Jeffrey Toobin (author of The Nine: Inside the Secret World of the Supreme Court, KF8748 .T66 2007 at Classified Stacks).
• Herman Schwartz Distinguished Lecture (July 25, 2007) by Sen. Richard Durbin.

Conference on Judicial Selection

A couple of weeks after the election, come to the UW for Selecting Judges in Washington -- Looking Back to 2008 and Forward to 2009, sponsored by the Judicial Selection Coalition and the University of Washington School of Law.

This conference is for anyone interested in the way we select judges in Washington. Conference speakers will discuss:

• What happened in Washington State judicial elections this year? Who ran, who contributed money, what happened? A panel discussion with:
  • Judge William Baker (Ret.), Chair of the Committee for Ethical Judicial Campaigns
  • Paul Fjelstad, webmaster for votingforjudges.org
  • Brad Shannon, Reporter for The Olympian
  • Sandra Driscoll, King County Municipal League
  
  
• What do Washington voters think about methods of judicial selection? A professional survey of several thousand randomly selected Washington voters has just been completed
  under the supervision of Professor David Brody, WSU. Professor Brody will summarize the results.


• Should Washington adopt public financing of judicial elections? A report on proposed legislation from Craig Salins, Executive Director, Washington Public Campaigns.


• Can judicial performance evaluations improve judicial elections? A panel discussion including Jordan Singer of the Institute for the Improvement of the American Legal
  System, and representatives of the King and Pierce County courts to comment on judicial performance evaluations conducted in those counties this year.


• What is happening in other states? A view from the national perspective by James Sample of the Brennan Center for Justice at NYU School of Law.

O'Scannlain on Statutory Construction

Ninth Circuit Judge Diarmuid O'Scannlain discusses competing schools of statutory construction -- textualism and purposivism -- and comes down squarely on the side of textualism. Hon. Diarmuid. E. O'Scannlain, Lawmaking and Interpretation: The Role of a Federal Judge in Our Constitutional Framework, 91 Marq. L. Rev. 895-915 (2008). Download a pdf here; listen to a webcast here.

Man who killed prowler says he aimed for legs

Man who killed prowler says he aimed for legs, Seattle P-I, Oct. 16, 2008. Prof. John Junker is quoted on the law of self-defense:

"In general, one has to have a reasonable belief that there is going to be a deadly attack by another person," said John Junker, criminal law professor at the University of Washington. "You can't shoot somebody for running away with your stuff."

But there have been a lot of cases, some stemming from police shootings, where the shooter mistakenly thought the other person was armed. Case law says the jury must judge the facts from the shooter's point of view and the information he had, Junker said.

"It's up to the lawyers to try to prove to the jury what really happened and whether it was reasonable for him to believe that," he said.

Weekly Skewers Judicial Election Process

This week's cover story in The Seattle Weekly is sharply critical of the judicial election process in Washington State: Damon Agnos, The Way We Elect Judges Is a Sham, Seattle Weekly, Oct. 15, 2008.

One resource Agnon mentions is VotingforJudges.org. This site pulls together candidate's statements, press, and ratings. You can click on a county to find all the candidates there.

Gallagher Blogs

Hey, there's a new blog in the neighborhood: Gallagher Blogs, from a group of us at the Gallagher Law Library, will have resources, tips, and items of interest to the law school community.

For the last few days as I've been highlighting documentaries in our collection, I've posted both here and there. I'm going to continue highlighting some documentaries on Gallagher Blogs but will stop the series here (unless there's something that cries out "Trial Ad" to me).

Brick by Brick: A Civil Rights Story

Brick by Brick: A Civil Rights Story follows three Yonkers families during a struggle over housing desegregation. It goes back decades to describe how a ghetto was created through public policies, so that people of color mostly lived in segregated neighborhoods with very poor schools. Members of the community organized to fight for change, and the film

tracks the resulting federal US v Yonkers litigation, which challenged neighborhood and educational discrimination. Coming back out of the courtroom into the community, the story describes the bitter local confrontation about race and the very concept of community that follows. From a first person perspective, characters weave a tale of years of work attempting to achieve justice, with a labyrinth of successes and setbacks that the struggle entails.

At its close, Brick by Brick shows what has happened both to a community and to individual citizens, committed to their city. It also illustrates the difference housing opportunity can make in a single family’s life. The story brings the fiery legal and political crucible of a contemporary city and its larger implications for our nation today onto the screen.

It's in the library: HD7288.76.U5 B75 2007 at Classified Stacks.

The print is too small to read here, but this KeyCite display will show you how complex the case's history is:

Dates range from 1995 to 2000.

KIND - Kids In Need of Defense

Microsoft and 25 law firms have just launched a project to provide legal representation to immigrant children who are in danger of deportation: KIND - Kids In Need of Defense. Two other corporate law departments are also involved.

Microsoft Corporation and the internationally acclaimed actress and UNHCR Goodwill Ambassador Angelina Jolie ask for your support in building a pro bono movement of law firms, corporate law departments and NGOs committed to providing fair, competent and compassionate legal counsel to unaccompanied immigrant children in the U.S. We're calling this new coalition KIND-but it's about more than compassion, it's about protecting the rights of children.

KIND has an ambitious but achievable agenda. By 2010, we intend to provide legal representation for 100% of unaccompanied children-approximately 2100 children a year-in those areas of the country where the need is greatest: Los Angeles, Seattle, Houston and the Northeastern corridor of the U.S. And we'll expand our operations throughout the country based on the "best practices" developed through this first critical phase of work.

Press:

• Microsoft set to help the littlest immigrants, Seattle Times, Oct. 17, 2008
• Microsoft sponsors legal aid plan for immigrant children, Seattle PI, Oct. 16, 2008
• Microsoft, 25 law firms and Angelina Jolie team up to represent immigrant children,, Nat'l L.J., Oct. 16, 2008.

Microsoft has already sponsored Volunteer Attorneys for Immigrant Justice, which represents unrepresented children in Washington State. Because of VAIJ, Washington is the only state where all immigrant children in the system are represented.

According to the P-I,

KIND will also provide fellowships to attorneys at legal aid organizations so they can exclusively represent immigrant children. The program will also pay for coordinators in the nine cities.

Kevin Coe Committed

Kevin Coe -- alleged to be Spokane's "South Hill rapist" but only convicted of four rapes and, after appeals, just one -- was found by jury yesterday to be a "sexually violent prdator" who should be indefinitely committed to a mental facility. SR.com: For some, Coe verdict represents simple justice; for others, it's a travesty, Spokesman Review (Spokane), Oct. 17, 2008.

The Spokesman Review has extensive coverage of the trial in this page with links to stories and videos and in this blog.

My earlier posts about the case are here.

Worker Safety Documentary

When filmmaker Abby Ginzberg visited the Law School this week, she donated to the library Those Who Know Don't Tell: The Ongoing Battle For Workers' Health. Narrated by Studs Terkel, this film

traces the history of the struggle to rid the workplace of occupational hazards. Using archival footage, union songs and interviews, it tells its story both from the point of view of the labor activists and those within the medical profession who became their advocates.

The fight for occupational health began almost one hundred years ago with Dr. Alice Hamilton's discovery of lead-caused industrial disease. She was followed by others such as Dr. Harriet Hardy of M.I.T., who discovered the dangers of beryllium. More recently, Dr. Irving Selikoff uncovered the danger of asbestos to workers and publicized his findings despite pressure from the asbestos industry to silence him.

Through tragedies such as the Triangle Shirtwaist Fire, unions and workers began effective organizing for occupational safety. This powerful discussion starter should be shown in courses dealing with labor, American history, community medicine and public health.

It's being processed, but it will soon be available at HD7654 .T57 1989 in the Classified Stacks.

J.L. Chestnut, Campaigning For Rights In Selma

This morning I listened to a wonderful interview: J.L. Chestnut, Campaigning For Rights In Selma : NPR, Fresh Air, Oct. 3, 2008. After Howard Law School, Chestnut returned home to Selma, the only black lawyer in a town where blacks didn't even serve on juries and the white bar leaders passed a resolution telling the town's banks not to lend him money to open his practice.

The interview was recorded in 1990, but rebroadcast recently because Chestnut just died. Here's an obituary: Bruce Weber, J.L. Chestnut Jr., Early Leader in Civil Rights Movement, Is Dead at 77, N.Y. Times, Sept. 30, 2008.

Chestnut's memoir, Black in Selma: The Uncommon Life of J.L. Chestnut Jr., is available through Summit.

The Judge and the Fanatic

Yesterday I promised to highlight some documentaries in our collection. Today's is The Judge and the Fanatic: Koranic Duels Against Terror, BL65 .T47 J83 2007 at Classified Stacks.

The interpretation of Islamic texts [is] the focus of Yemeni Judge Hamoud al Hitar and his Religious Dialogue Committee, which seeks to rehabilitate the most hardened Islamic radicals through a close reading of the Qur'an and the sunna (traditions from the life and teaching of the Prophet Muhammad). Tom Meffert's richly insightful documentary explains how agents of terrorism have systematically sought to change the meaning of Islam to suit their own ends. Far from being a fiery text full of blood and revenge, many of the Qur'an's 124 verses advocate tolerance, peace and hospitality, and advise that non-Muslims should be treated with charity and respect. It is this that the judge tries to make clear to the disaffected young men of his country turning to extremism. Yemen's war of words with the dark heart of terrorism has enormous implications, not just for that country, but the larger world as well.

-- description from Salt Spring Film Festival 2006

I didn't read the producer's description because it is in German, but I copied the photo (above) from that page. (Our library bought the English version of the film.)

Courts Give Addicts a Chance to Straighten Out

King County's Drug Diversion Court is featured in a New York Times story: Courts Give Addicts a Chance to Straighten Out - NYTimes.com, Oct. 14, 2008.

The program is at risk because of the county's dire budget situation.

County Executive Ron Sims office has budget information -- including links to news stories -- here.

Thanks: Alex Fleming Freeburg.

Suit against God thrown out over lack of address

Suit against God thrown out over lack of address | Seattle Times Newspaper, Oct. 15, 2008.

"Given that this court finds that there can never be service effectuated on the named defendant this action will be dismissed with prejudice," Polk wrote.

Chambers, who graduated from law school but never took the bar exam, thinks he's found a hole in the judge's ruling.

"The court itself acknowledges the existence of God," Chambers said Wednesday. "A consequence of that acknowledgment is a recognition of God's omniscience."

Thanks: Roxanne Eberle.

Asylum DVD

This week's Social Justice Tuesday speaker was Abby Ginzberg, a lawyer turned documentary filmmaker.

To follow up on the enthusiasm in the room, I'll feature some of films in our collection in the next several days. Today: Well-Founded Fear, a look at the system for granting asylum. KF4836 .W45 2000 at Classified Stacks.

At 3:30, there will be a showing of her film, Soul of Justice: Thelton Henderson's American Journey.

Eyewitness testimony still key to cases when there's no DNA

DNA exonerations led reporters from the Dallas Morning News to look into the use of eyewitness testimony in recent robbery trials. Eyewitness testimony still key to cases when there's no DNA | Dallas Morning News, Oct. 14, 2008.

See also: Wrongfully convicted cases cleared in Dallas County since 2001, Oct. 8, 2008.

This page has profiles of exonerees and links to other stories in the series.

Burien man who killed 3 for money sentenced to 97 years in prison

Burien man who killed 3 for money sentenced to 97 years in prison, Seattle P-I, Oct. 10, 2008.

After a two-month trial, the jury began deliberations, but on the second day, one juror asked to be excused because she could no longer abide by the court's instructions. The judge excused her and appointed an alternate.

But the defense attorney, Pete Connick, asked for a new trial. When the judge questioned the first juror, she said that she had felt like a token -- she was the only black on the jury for the trial of a black defendant. The alternate who replaced her was also black.

Other jurors provided statements saying they witnessed no racist remarks or bias. In a written decision, the judge concluded that Brown's difficulties stemmed from a disagreement with the other 11 jurors over how to apply the law.

The prosecutor was Senior Deputy Prosecuting Attorney Hugh Barber, who is also a UW Trial Ad instructor.

Vancouver asks for federal probe of police officer's firing

Vancouver, WA, settled a discrimination case brought by a police officer for $1.65 million. Responding to criticism of the city's handling of the case, the mayor is now asking the U.S. Attorney's office for the Western District of Washington to review it. Vancouver asks for federal probe of police officer's firing - Columbian.com, Oct. 11, 2008.

The mayor wrote to Assistant U.S. Attorney Kelly Harris, who is also a UW Trial Ad instructor.

Profile of Julia Gold

Check out the profile of Julia Gold, the director of the University of Washington's Mediation Clinic: Jessica Chiu, U.W. Clinic Has Touch of Gold, Bar Bull., Oct. 2008.

King County Budget Cuts

King County is facing a huge budget shortfall. Why? "Bottom line: higher costs, flagging revenues." Q&A | Dissecting King County's general-fund shortfall, Seattle Times, Sept. 29, 2008. County shortfall to trigger up to 255 layoff notices, Oct. 13, 2008.

Sheriff Sue Rahr has said she will have to eliminate deputy positions, likely cutting back the Marine Patrol and investigations of narcotics, organized crime, cold cases, domestic violence and thefts and vandalism.

Prosecutor Dan Satterberg has already reduced his staff and next Monday will begin filing many drug-possession cases and thefts or vandalism with losses below $5,000 as gross misdemeanors rather than felonies.

Q&A supra.

One article focuses on the county-supported programs that support victims of sexual assault: Many King County service providers face significant cuts, Oct. 13, 2008.

Their efforts are important not only because they help crime victims heal but because they play a key role in bringing sex offenders to justice.

Without public funding, said Mary Ellen Stone, executive director of the [Sexual Assault Resource Center], many victims of sex crimes are unable to stick with a case through trial. "Some people assume you just make a report. No. This turns your life upside down for a year and a half at least."

Senior Deputy Prosecuting Attorney Lisa Johnson, who heads the prosecutor's special-assault unit, said victim-advocate groups are "absolutely critical and vital" to successful convictions. "We couldn't do our cases without them."

Sheriff arrests parents in horrific child abuse case

Sheriff arrests parents in horrific child abuse case, Seattle P-I, Oct. 13, 2008. The facts as reported are very upsetting (a teenage girl starved and denied water over a period of years). Of interest for people thinking about trial work are the documents that the P-I has posted:

• Information
• Certification for Determination of Probable Cause
• Prosecuting Attorney Case Summary and Request for Bail and/or Conditions for Release

It's not that they're extraordinary documents -- just that law school reading doesn't often include documents like these, so you might not have seen them.

Help for Pro Se Divorce Petitioners

Washington Law Help now has an online "interview" to walk people through the process of filling out divorce forms. It only applies if the couple does not have minor children and if domestic violence is not an issue. It could be really helpful to someone overwhelmed by the standard forms.

Washington LawHelp

is a guide to free civil legal services for low-income persons and seniors in Washington. This site provides legal education materials and tools that give you basic information on a number of legal problems, and in some cases, detailed instructions and forms to help you represent yourself in court. You can also locate information on free legal aid programs in Washington, including basic eligibility and contact information.

This guide is a free service which is made possible through a grant from the Legal Services Corporation. The web site template was created by Pro Bono Net and is maintained by staff at the Northwest Justice Project in Seattle.

Most materials on the site were prepared by the Northwest Justice Project, but many are from other organizations, including Columbia Legal Services, the Northwest Women's Law Center, Washington Protection & Advocacy System, Child Advocacy Central, the ACLU of Washington, Washington Department of Social and Health Services, Northwest Immigrant Rights Project, Seattle Public Library, the Washington State Office of the Attorney General, the Tenants Union of Washington State, and more.

This site is a tremendous resource for the thousands of people who do not have access to lawyers. (It can also be a resource for law students and lawyers -- a good summary of the law or a good form are always welcome.)

Jury Symposium

The Northern Illinois Law Review recently (Summer 2008) had a symposium, The Modern American Jury:

• Paula L. Hannaford-Agor, Judicial Nullification? Judicial Compliance and Non-Compliance with Jury Improvement Efforts, 28 N. Ill. U. L. Rev. 407-424 (2008)
• Irwin A. Horowitz, Jury Nullification: An Empirical Perspective, 28 N. Ill. U. L. Rev. 425-451 (2008)
• Kirk W. Schuler, In the Vanguard of the American Jury: A Case Study of Jury Innovations in the Northern District of Iowa, 28 N. Ill. U. L. Rev. 453-501 (2008)
• Elizabeth Dale, People v. Coughlin and Criticisms of the Criminal Jury in Late Nineteenth-Century Chicago, 28 N. Ill. U. L. Rev. 503-536 (2008)
• Frank A. Perrecone & Lisa R. Fabiano, The Federalization of Punitive Damages and the Effect on Illinois Law, 28 N. Ill. U. L. Rev. 537-557 (2008)

Washington's First Native American Judge

On October 1, the State Supreme Court honored Judge James M. Phillips of Grays Harbor Superior Court, who is believed to be Washington's first Native American judge. He was on the bench from 1929 to 1950. Washington Courts press release, Sept. 23, 2008.

Learning Voir Dire From The O.J. Trial

Anne Reed, the lawyer and jury consultant who writes the Deliberations blog, has some great ideas for improving your voir dire skills. CNN posted the completed juror questionnaires from O.J. Simpson's robbery trial, and Anne suggests that you can, first, use the questionnaires to think about drafting your own, since some of the questions are "particularly well designed to get direct information about jurors' specific experiences and conduct." Deliberations: Learning Voir Dire From The O.J. Trial, Oct. 8, 2008.

Second, for as good a voir dire training exercise as you're ever likely to find, print the twelve questionnaires out and practice with them, with a group if possible. What if these twelve people were the venire instead of the final group, and you had to pick a jury of six?

If you're like most lawyers, this project will be harder than you expected.

For other juror questionnaires, see Deliberations' library of sample juror questionnaires -- a wonderful resource.

Civ Pro Rap

An artist named Notorious B.O.A.L.T. has rapped the Federal Rules of Civil Procedure:




I haven't listened to the whole thing. I'm told that it, like many raps, contains strong language and references that some people might find offensive. But it's art. About the Federal Rules of Civil Procedure. Wow.

Thanks: Pablo Sandoval.

Irate Judge Blasts Typos and Errors in Filing, Slashes Fees

Irate Judge Blasts Typos and Errors in Filing, Slashes Fees by $154K | ABA Journal - Law News Now, Oct. 8, 2008. Sloppy work has a cost!

For a similar example (from the same federal district court but a different judge), see this post. And for a a lot of examples (and tips on how to research them), see When Judges Scold Lawyers, 96 Law Libr. J. 557 (2004).

Thanks: Maureen Howard.

Some Recent Books on Judges

Interested in judges' lives and work? Here are some recent books (and one set of DVDs) for you:

G. Edward White, The American Judicial Tradition: Profiles of Leading American Judges, KF8744 .W5 2007 at Classified Stacks.
Publisher's note:

... G. Edward White updates his series of portraits of the most famous appellate judges in American history from John Marshall to Oliver W. Holmes to Warren E. Burger, with a new chapter on the Rehnquist Court. White traces the development of the American judicial tradition through biographical sketches of the careers and contributions of these renowned judges. [H]e argues that the Rehnquist Court's approach to constitutional interpretation may have ushered in a new stage in the American judicial tradition.

Mary L. Dudziak, Exporting American Dreams: Thurgood Marshall's African Journey, KSK2095 .D83 2008 at Classified Stacks. Publisher's description:

Thurgood Marshall became a living icon of civil rights when he argued Brown v. Board of Education before the Supreme Court in 1954. ... When in 1960 Kenyan independence leaders asked him to help write their constitution, Marshall threw himself into their cause. ...
... Mary Dudziak recounts with poignancy and power the untold story of Marshall's journey to Africa. African Americans were enslaved when the U.S. constitution was written. ...

Tinsley E. Yarbrough, Harry A. Blackmun: The Outsider Justice, KF8745.B555 Y37 2008 at Classified Stacks. Publisher's description:

Thoroughly researched, engagingly written, Harry A. Blackmun: The Outsider Justice offers an in-depth, revelatory portrait of one of the most intriguing jurists ever to sit on the Supreme Court. Relying on in-depth archival material, in addition to numerous interviews with Blackmun's former clerks, Yarbrough here presents the definitive biography of the great justice, ultimately providing an illuminating window into the inner-workings of the modern Supreme Court.

Richard A. Posner, How Judges Think, K2300 .P67 2008 at Classified Stacks. Publisher's Description:

A distinguished and experienced appellate court judge, Richard A. Posner offers in this new book a unique and, to orthodox legal thinkers, a startling perspective on how judges and justices decide cases.

Clarence Thomas, My Grandfather's Son, KF8745.T48 A3 2007 at Classified Stacks. Publisher's description:

Provocative, inspiring, and unflinchingly honest, My Grandfather's Son is the story of one of America's most remarkable and controversial leaders, Supreme Court justice Clarence Thomas, told in his own words.
...

Jeffrey Rosen, The Supreme Court: The Personalities and Rivalries That Defined America, KF8744 .R67 2007 at Good Reads, Classified Stacks. The publisher's description is here.

This book is a companion to the PBS series, The Supreme Court, KF8742 .S856 2007 at Classified Stacks (4 DVDs).






Matthew J. Streb, ed., Running for Judge: The Rising Political, Financial, and Legal Stakes of Judicial Elections, KF8785.A7 R86 2007 at Classified Stacks. The publisher's description is here.

Federal Way police want stiffer penalties for fake-gun users

Federal Way police want stiffer penalties for fake-gun users | TheNewsTribune.com | Tacoma, WA, Sept. 15, 2008. "Federal Way Police Chief Brian J. Wilson wants the Legislature to change second-degree assault so it includes the use of Airsoft-type pistols." On the one hand, someone brandishing a toy gun or paintball gun that looks like a real gun can create a dangerous situation: the police are more likely to fire, endangering the gun holder and bystanders.

But on the other hand,

[A] local defense attorney, Brett Purtzer of Tacoma, said the proposed change in the law isn’t a good idea.

“I think the statute is pretty clear it has to be a deadly weapon,” Purtzer said. “If you start adding things in there, where do you draw the line?”

I didn't find out how the city council voted.

Ex-judges sue Rossi, builders, challenge fundraising

Former state Supreme Court Justices Faith Ireland and Robert Utter are the plaintiffs in a lawsuit challenging campaign activities of the Building Industry Association of Washington. They allege that governor candidate Dino Rossi improperly participated in BIAW's actions. Ex-judges sue Rossi, builders, challenge fundraising | Seattle Times Newspaper, Oct. 7, 2008.

The Washington Outsiders blog reprints a press release from Ireland and Utter.

For more analysis of this case -- and cases brought by Attorney General Rob McKenna -- see David Brewster, The Screws of Buildergate Tighten on Dino Rossi, Crosscut, Oct. 6, 2008.