Family Law Prof Blog

Editor: Margaret Ryznare
Indiana University
Robert H. McKinney School of Law

Saturday, July 22, 2017

Penn State Child Sex Abuse Admins Surrender for Jail Sentence

From The Los Angeles Times:

Two former high-ranking Penn State administrators surrendered Saturday morning to serve jail sentences for how they responded to a 2001 complaint about Jerry Sandusky showering with a boy.

Former university Vice President Gary Schultz and former Athletic Director Tim Curley turned themselves in, according to Lt. Michael Woods, the shift commander at the Centre County Correctional Facility. Wood confirmed their surrender, but said he was not authorized to release any other details from the jail, which is about 135 miles east of Pittsburgh. The lockup is about 7 miles northeast of Penn State's main campus.

Read more here.

July 22, 2017 in Child Abuse | Permalink | Comments (0)

Thursday, June 22, 2017

Ending Child Abuse in the U.S.

From Huffington Post:

According to recent data from the Massachusetts Department of Children and Families, one in 34 children is confirmed as abused or neglected in Massachusetts each year. That’s one case confirmed every 15 minutes.

To get a better picture of the issue, I sat down with Suzin Bartley, executive director of the Children’s Trust, an organization with a mission to stop child abuse in Massachusetts. Bartley also serves as a co-chair of the Massachusetts Legislative Task Force on the Prevention of Child Sexual Abuse. In our interview, we discuss some of the systemic contributors to child abuse, the costs that abuse incurs for the individual and the community, and the most effective ways to end the epidemic.

Does public understanding and definition of child abuse differ across culture and region?

Yes, cultural norms play an important role in shaping parenting practices.

There have been social workers or others who are not necessarily sensitive to cultural parenting practices like corporal punishment or non-Western medicine, and will call them child abuse.

Are they? Yes. Are they intentional or malicious? No.

The key is working with parents to help them create a toolkit of positive disciplinary techniques. Once parents see that those techniques are effective, they will use them. Most parents don’t want to hurt their child.

Read more here.

 
 

June 22, 2017 in Child Abuse | Permalink | Comments (0)

Tuesday, June 6, 2017

Family in Indiana Awarded $25M in Child Death Suit

From The Washington Post:

INDIANAPOLIS — Indiana officials have agreed to pay $25 million to a couple who was wrongfully accused in the death of their 14-year-old daughter.

The lawsuit filed by Jessica Salyer’s family was dismissed Wednesday after the settlement was reached.

Court documents allege the state Department of Child Services pursued a neglect case against her parents, Roman and Lynnette Finnegan, despite an investigation that showed Jessica died in 2005 from taking prescribed medications that had a fatal interaction.

The department removed two of the Finnegan’s other children from their home and placed them in foster care. The Finnegans were arrested, but the charges were later dropped. They then sued three of the department’s workers, an Indiana State Police detective and a doctor in 2008.

Read more here.

 

 

June 6, 2017 in Child Abuse | Permalink | Comments (0)

Saturday, May 27, 2017

Facebook's Manual on Child Abuse

From The Guardian:

At first, Facebook’s policies seem clear enough. Most start with a clear explanation of what it does and doesn’t tolerate. But often there are caveats. The Guardian has been told some moderators struggle to understand distinctions – and some feel overwhelmed by the task. Updates reflect shifting attitudes and political pressure but can further complicate the job.

Facebook’s policies on graphic violence, non-sexual child abuse and animal abuse reveal its attempts to remain open while trying to ban horrific images. Moderators remove content ‘upon report only’, meaning graphic content could be seen by millions before it is flagged. Facebook says publishing certain images can help children to be rescued. The Guardian is publishing a small selection of slides from the moderation manuals. Some use language we would not usually publish, but to understand Facebook’s content policies, we have decided to include it. See for yourself how Facebook polices what users post.

Read more here.

May 27, 2017 in Child Abuse | Permalink | Comments (0)

Sunday, May 21, 2017

Child Webcam Sex Bust Reveals Widespread Issue

From the Detroit News:

Mabalacat, Philippines — The suspected pedophile could see people banging on his front door through his security cameras. Were they neighbors? Cops?

One had letters on her jacket. As David Timothy Deakin googled “What is NBI?” from the laptop on his bed, the Philippines National Bureau of Investigation smashed their way into his cybersex den.

Children’s underwear, toddler shoes, cameras, bondage cuffs, fetish ropes, meth pipes and stacks of hard drives and photo albums cluttered the stuffy, two-bedroom townhouse. Penciled on the wall, someone had scrawled “My Mom and Dad love me” and a broken heart. In his computer were videos and images of young boys and girls engaged in sex acts.

“Why is everyone asking about children coming into my house?” said Deakin, 53, his wrists bound with a zip tie.

Deakin’s arrest on April 20 reveals one of the darkest corners of the internet, where pedophiles in the U.S., Canada, Europe and Australia pay facilitators on the other side of the world to sexually abuse children, even babies, directing their moves through online livestreaming services.

Read more here.

 

May 21, 2017 in Child Abuse | Permalink | Comments (0)

Saturday, May 6, 2017

Judge Shreds Wisconsin Law on Unborn Child Abuse

From Courthouse News Service:

Siding with a woman who spent weeks in jail after she was accused of abusing her unborn child, a federal judge struck down a Wisconsin law that purports to address pregnant women with “habitual lack of self-control.”

Passed in 1997,  Act 292 allowed the state to treat fetuses as children in need of protection or state services if their mothers demonstrate problems with drug or alcohol abuse.

Finding the law unconstitutionally vague on April 27, U.S. District Judge James Peterson rejected Wisconsin’s claims that the statute is merely written in plain English, eschewing “technical words and phrases.”

“The state’s dictionary-definition approach is a festival of circularity, in which the statutory terms are simply replaced with synonyms that add no real meaning,” the 40-page opinion states.

Read more here.

May 6, 2017 in Child Abuse | Permalink | Comments (0)

Saturday, March 4, 2017

What's behind Indiana's increase in child abuse reports?

From The Greensburg Daily News:

Shortly after an elementary principal alerted deputies something might be wrong with a child who had been absent from school for a few days, the frightened 9-year-old boy was laying in the fetal position in the lobby of the Johnson County Sherriff’s Office.

The boy’s pale face was bruised, scratched and cut. His eyes were partially shut and droopy, strained with broken blood vessels. Dried blood and drainage was coming from his ears. His neck was branded with ligature marks. He was shaking.

When a deputy tried to speak to him that night in October, the boy was disoriented. He couldn’t talk clearly and cried out that he was hungry and asked for food, according to court documents.

The boy’s mother demonstrated to police how she had intentionally and repeatedly hit her son in the groin three or four times, causing swelling, the documents said. She indicated she had lost control and knew it was wrong, but that she did it anyways. She didn’t send him or his brother to school because of their visible injuries.

The boy’s mother, Krystle Nikole Case, 31, was recently charged with two felonies: neglect of a dependent and battery resulting in serious bodily injury to a child. A judge issued a no-contact order that will keep her from seeing her son, even if she is released during her case.

This story is one of nearly 27,000 confirmed child abuse or neglect cases in Indiana each year.

The number of Hoosier child abuse and neglect cases has risen consistently since 2011, according to the Indiana Youth Institute’s annual KIDS COUNT in Indiana Data Book.

The report — which also gives data on homelessness, infant mortality, youth suicide and other topics — details how children are “surviving, not thriving” through 2015 statistics and year-to-year comparisons of the various challenges they face.

James Wide, deputy communications director for Indiana’s Department of Child Services, said although the number of child abuse reports are going up, it’s not for a bad reason. Wide attributes the increased number of reports to more cases being filed because of more awareness about child abuse issues, not necessarily because more incidents are occurring.

His office deals with all sorts of child welfare issues, including handling child support and protecting children from all types of abuse and neglect.

Before 2012, the state didn’t have a centralized child abuse and neglect hotline. Before the hotline, Wide said there were more than 300 numbers scattered across the state that weren’t always answered by a professional — or answered at all.

But the introduction of the Indiana Child Abuse and Neglect Hotline streamlined reporting. Anyone who calls 1-800-800-5556, any time, is connected to a trained family case manager to describe what they think might be going on with a child.

Read more here.

March 4, 2017 in Child Abuse, Resources - Child Custody, Resources - Children & the Law | Permalink | Comments (0)

Saturday, October 1, 2016

Court of Appeals finds parents unfit, affirms termination of parental rights

From The Indiana Lawyer:

The Indiana Court of Appeals affirmed Monday a decision to terminate parental rights after both parents failed to show evidence that allowing them to maintain their rights would be in the best interest of the children.

T.B. was born to the mother and father in 2009, then the mother gave birth to a second child, R.K., who had a different father who is now deceased, in 2010. After being convicted of multiple drug charges, the mother was incarcerated in 2013 and has not seen the children since. T.B. and R.K. were placed in the father’s care shortly thereafter.

After father reached out to the Department of Child Services for help in 2014, the department filed a children in need of services petition on behalf of T.B. and R.K. — as well as the father’s two older children — and the court found that the children could remain in the father’s care as long as a safety plan was developed.

A well-child check in May 2014 found R.K. with second-degree burns on his feet, which prompted his and T.B.’s removal from the home and placement in foster care. The children were subsequently adjudicated CHINS, and the father was ordered to participate in visitation, Fatherhood Engagement and individual therapy.

However, father was often vocal about his distrust of DCS and refused to participate in the department’s services. The mother was limited in her ability to participate in DCS services due to her incarceration.

In February 2016, the Tippecanoe Superior Court entered an order terminating the mother’ s parental rights to T.B. and R.K. and the father’s parental rights to T.B., prompting both parents to appeal.

Read more here.

October 1, 2016 in Child Abuse, Custody (parenting plans), Termination of Parental Rights | Permalink | Comments (0)

Monday, August 8, 2016

New York Law Requires Child Abuse Hotline to be Posted in Schools

From News10:

New York is now requiring that every public and charter school posts the phone number the the state's child abuse hotline. The post must be in a place where students can see the sign. The law requiring such action has resulted in calls from children "around the clock every day."

Read more here.

August 8, 2016 in Child Abuse | Permalink | Comments (1)

Friday, August 5, 2016

Child Maltreatment History Should Be a Bar to Being a Foster Parent

 From Youth Today:

It’s just common sense: An adult's past criminal history or history of child maltreatment is not to be balanced against the safety of a child. This is not to say a person with any criminal record should be barred as a foster parent, but certainly an applicant with a substantiated history of child maltreatment, no matter how far in the distant past, should be permanently barred.

Foster care agencies have a legitimate reason to inquire about a prospective foster parent’s criminal and child maltreatment history, be it an inquiry, arrest, charge or conviction. Why? Quite simply, the agency seeks to maximize child safety.

In addition, a good background check helps identify a superior applicant while simultaneously reducing the agency’s potential liability. In many states, the agency responsible for approving foster parent licenses is permitted to waive or not even take into account an applicant's child maltreatment or criminal history if the offense happened many years ago or if the agency's internal risk analysis indicates no cause for concern.

Read more here.

August 5, 2016 in Adoption, Child Abuse, Domestic Violence, Termination of Parental Rights | Permalink | Comments (0)

Wednesday, May 4, 2016

Germany Expresses Regret Over Failure to Stop Child Abuse at Nazi Nurse's Commune

From NBC News:

Germany's foreign ministry acknowledged Tuesday that its diplomats "looked away" and failed to prevent child abuse at a commune founded by a Nazi pedophile in Chile.

Paul Schaefer — a Nazi nurse who became a preacher — set up the secretive Colonia Dignidad commune in Chile after fleeing Germany for South America in 1961.

He died in a Chilean prison in 2010 at the age of 89 while serving a 20-year sentence for child abuse, arms possession and human-rights violations.

Children who lived at the Colonia Dignidad commune testified at trials of colony leaders about being sexually abused, enslaved and separated from their parents.

On Tuesday, German Foreign Minister Frank-Walter Steinmeier publicly expressed regret over any role his ministry had in the decades-long scandal.

"Over the course of many years, from the 60s to the 80s, German diplomats at best looked away," Steinmeier said.

He said it was "no glorious chapter" for Germany's embassy in Chile, adding that envoys "clearly did too little for the protection of their fellow citizens in this colony."

At its height in the 70s and 80s, Colonia Dignidad had some 300 Chilean and German residents. Most worked as farmers at the commune, which was guarded by barbed wire and watchtowers.

Women had to wear braided pigtails and colorful dirndls — a traditional German outfit — while men often were seen in lederhosen, the male equivalent.

The German parliament in 2008 released funds for projects supporting former commune members' reintegration into society.

Read more here.

May 4, 2016 in Child Abuse | Permalink | Comments (0)

Monday, April 25, 2016

UK Internet Charity Finds Fourfold Increase in Child Abuse Imagery

From Yahoo News:

The Internet Watch Foundation (IWF), an online child sex abuse charity, said on Thursday that the number of reports of images and videos containing child abuse had increased by 417 percent over the last two years.

In its annual report, the IWF said 68,092 reports had been positively identified as containing illegal child sexual abuse imagery and taken down.

That represented a 118 percent increase over the previous year, it said.

Prime Minister David Cameron gave his approval for the IWF to start proactively searching for online child sexual abuse imagery in April 2014.

From that time, IWF analysts could themselves search for child abuse imagery rather than just acting upon reports they received, prompting a dramatic increase in the number of images identified.

"By being allowed to actively search for these hideous images of children, we’ve seen a dramatic increase in the sheer number of illegal images and videos that we’ve been able to remove from the internet," IWF CEO Susie Hargreaves said in a statement.

Of the images discovered in 2015, 69 percent were of children aged 10 or under and 34 per cent were Category A which involves the rape or sexual torture of children, the IWF said.

Hargreaves said the IWF planned to increase the number of its analysts to 17 from 12.

 

Read more here.

April 25, 2016 in Child Abuse | Permalink | Comments (0)

Friday, April 22, 2016

Using Data to Predict Child Abuse

From Marketplace.org:

Doctors at Cook Children’s Medical Center in Fort Worth are used to treating cases of abuse. Dyann Daley, a pediatric anesthesiologist at Cook Children’s, remembers a tiny toddler who had been kicked by his father in the stomach. “We didn’t know exactly what the injury was when he came into the operating room," she said. "But he had come into the hospital awake.”

Although doctors tried to keep him alive, the injury just wasn't survivable. He bled to death during surgery. "It was an emotional time because of the type of injury he had and how close he was in age to my own children,” Daley said.

In 2013, more than 1,500 American children died from abuse and neglect. That's the most recent national info available. Last year in Texas, the Department of Family and Protective Services announced 170 children died. Tarrant County, which includes the city of Fort Worth, has one of the highest rates of abuse in the state. Dyann Daley, who runs Cook Children's Center for Prevention of Child Maltreatment,  says no one really knows why.

 "Some people say we’re better at catching it or better at reporting it," she said. "I’ve worked in a number of children’s hospitals in Texas and also in other places in the United States. And I’ve never seen as much physical abuse as I see here.”

 Daley has been on a mission to train doctors and nurses to recognize the signs of abuse early – like suspicious bruises or marks. But detecting abuse is hard. Especially for infants who may not interact with teachers or nurses familiar with the clues.

 What they’d really like to do is prevent it. So they're experimenting with “big data” technology that could help predict neighborhoods where kids are most likely to be abused.

 It's known as predictive analytics. “This technology has been used to predict where shootings would occur and other types of violent crimes, but no one had applied it to domestic violence, like child maltreatment before,” Daley said.

Read more here.

April 22, 2016 in Child Abuse | Permalink | Comments (0)

Monday, March 28, 2016

US Lacks Strategies to Lower Child Abuse Deaths

From ABC News:

The United States lacks coherent, effective strategies for reducing the stubbornly high number of children who die each year from abuse and neglect, a commission created by Congress reported Thursday after two years of sometimes divisive deliberations.

According to federal data, the number of such deaths has hovered at around 1,500 to 1,600 annually in recent years. But citing gaps in how this data is compiled, the report suggests the actual number may be as high as 3,000 a year.

Commission chairman David Sanders said a goal of zero maltreatment deaths was realistic.

"We looked at the airline industry — no one accepts a plane crash anymore. We can get that way with child fatalities," said Sanders, executive vice president of Casey Family Programs.

The report made dozens of recommendations, including expanding safe-haven programs for abandoned infants and enlisting a broader range of community organizations to help often-overburdened child protection service workers.

"We need a system that does not rely on CPS agencies alone to keep all children safe," the report said. "Other systems become key partners, including the courts, law enforcement, the medical community, mental health, public health, and education. Even neighbors who come into regular contact with young children and families are part of a public health approach."

Still, the commission, comprised of six members appointed by Congress and six by President Barack Obama, failed to reach consensus on some issues. Two members declined to approve the final report and wrote dissents criticizing one of the major proposals.

Read more here.

March 28, 2016 in Child Abuse | Permalink | Comments (0)

Sunday, March 20, 2016

Missouri Law Protects Children From Abuse By Children

From STLToday.com:

Last year, after testifying before Missouri legislators about her daughter’s alleged sexual abuse by another child, Becky Wekenborg’s Facebook page began to ping with messages from strangers asking for help.

She knew then, well before the bill expanding the scope of the Children’s Division was passed into law, that the state might be tackling something bigger than policymakers projected.

“Until people started contacting me, I didn’t realize that there was such a big problem,” she said. “I was just amazed at all these people who reached out to me who wanted advice and knew my name because of what my daughter had been through.”

In August, the new state law went into effect mandating that the Children’s Division perform family assessments when it receives child abuse hotline calls alleging inappropriate sexual behavior perpetrated by children on other children.

Prior to that, the state was only mandated to investigate allegations of child abuse involving people who have “care, custody or control” of a child. That ruled out state intervention in most complaints against minors and essentially excluded all children under 14.

Child advocates lauded the change. But even they failed to predict the extent of demand for the new services.

Read more here.

March 20, 2016 in Child Abuse | Permalink | Comments (0)

Sunday, March 13, 2016

Rising Cases of Horrific Abuse Push Valley Children's Hospital to Increase Care

From The Fresno Bee:

Dr. Philip Hyden has seen a lot over nearly 30 years of treating abused children, but nothing like what’s happening to kids in the Central Valley.

“I’ve lived in New York City, I’ve lived in L.A., I’ve lived in Hawaii, I’ve lived in Denver, I’ve lived in Florida and Illinois,” he says, “and I’m telling you that the amount of time I’ve been here and the amount of cases I see per year is bewildering. It’s just overwhelming, what I see.”

And Hyden, who took the helm of The Guilds of Valley Children’s Hospital Child Abuse Prevention and Treatment Center in 2010, says he’s seen “everything you can think of.”

“I’ve seen children sold for sex that are less than a year old. I’ve seen children sold for drugs. … I’ve seen kids tortured, tied in garbage bags, deprived of food to where they are actually skeletal, multiple contusions on them like hanger marks and extension cord marks, burns from cigarettes and other objects … burns from hot water and flames.”

These horrors are behind Valley Children’s recently expanded child abuse program. Officials say that of 483,000 reports of suspected child maltreatment made in California in 2013 – the most recent data available – 90,000 came from areas traditionally served by the hospital.

Many victims were previously sent to other facilities before Hyden joined Valley Children’s in 2010. His arrival marked the beginning of a new program with staff solely focused on evaluating and treating abused children. The work is largely funded by a $5 million endowment awarded by guilds that raise money for the hospital. The $5 million goal set in 2009 was reached last year.

The number of abused children seen at Valley Children’s continues to grow. The year before Hyden’s arrival, the hospital saw 159 abused children – 65 of them hospitalized for more severe injuries. Last year, the child abuse prevention and treatment center saw 974 children – 135 requiring hospitalization.

Hyden credits the growth to expanded services, along with a growing awareness of these services, but added that it “doesn’t look like child abuse is decreasing in the Valley at all.”

Read more here.

 

March 13, 2016 in Child Abuse | Permalink | Comments (0)

Friday, February 26, 2016

Reporting Error Inflates Maryland Child Abuse Cases

From The Baltimore Sun:

A recent report by the U.S. Department of Health and Human Services included a startling statistic: The number of abused or neglected children in Maryland in 2014 had climbed 27 percent, the second-sharpest increase in the nation.

But state officials say that the figure was inflated because of a reporting error. It turns out that the number of cases depends on how a state defines a victim.

The federal government has been gathering state-level child abuse and neglect data for more than two decades, tracking the time it takes for Child Protective Services to respond to a report of child abuse, for instance, and the number of cases that are substantiated after an investigation.

The most recent installment of that data, which was released in late January and covers 2014, identified 15,800 children in Maryland who were victims of abuse or neglect — up from just over 12,000 cases the year before. Only Massachusetts had a larger year-over-year increase in abuse cases.

But officials at the Maryland Department of Human Resources said the federal number should not include children who are assisted through a new effort to segregate "low-risk" cases and work with those families to improve the situation at home rather than conduct a formal investigation.

That effort, known as "alternative response," was fully implemented in Maryland in 2014.

"We have determined that Maryland should not have counted any of the children receiving alternative response as victims," DHR spokeswoman Paula Tolson said in a statement. "Maryland therefore will be resubmitting 2014 data to correct this error."

The alternative response approach is designed to lessen the adversarial relationship between families and caseworkers. While many child advocates regard it as a best practice, some critics question whether the two-track system does enough to keep children safe.

Read more here.

February 26, 2016 in Child Abuse | Permalink | Comments (0)

Tuesday, February 16, 2016

Catholic Bishops Not Obliged to Report Clerical Child Abuse, Vatican Says

From The Guardian:

The Catholic church is telling newly appointed bishops that it is “not necessarily” their duty to report accusations of clerical child abuse and that only victims or their families should make the decision to report abuse to police.

A document that spells out how senior clergy members ought to deal with allegations of abuse, which was recently released by the Vatican, emphasized that, though they must be aware of local laws, bishops’ only duty was to address such allegations internally.

“According to the state of civil laws of each country where reporting is obligatory, it is not necessarily the duty of the bishop to report suspects to authorities, the police or state prosecutors in the moment when they are made aware of crimes or sinful deeds,” the training document states. 

February 16, 2016 in Child Abuse | Permalink | Comments (0)

Monday, February 15, 2016

Congress Moves to Confront Military Child Abuse with Talia's Law

From Military Times:

The House on Tuesday passed a bill that would require anyone employed by the Defense Department to report cases of suspected child abuse on military installations to state child protective service agencies in addition to reporting such suspected crimes up their chain of command.

The legislation was approved by voice vote and sent to the Senate for consideration.

Called Talia’s Law, the bill is named for five-year-old Talia Williams who was tortured and beaten to death by her father — an active-duty Army specialist at the time — and step-mother in 2005 at Wheeler Army Airfield in Hawaii.

Talia’s mother, Tarshia Williams, sued the U.S. government in 2008 for what she argued were failures by military officials to report suspicions that her daughter was being abused. Williams was awarded $2 million in a settlement last May.

The Defense Department had signed a memorandum of understanding with the State of Hawaii in 2013 that said the state’s child welfare services agency was “primarily” responsible for handling instances of child abuse on military bases. But DOD also has its own parallel system for child and domestic abuse investigations.

Suspected cases of child abuse are reported to military police or the installation’s Family Advocacy Program, which work in coordination to identify and investigate instances of child abuse. Those mandated by law to report suspected child abuse are usually professionally involved with children, such as day-care workers and doctors.

The U.S. District Court of Hawaii, where Williams brought her suit, found that various individuals failed to report Talia’s case, including members of the military police, doctors, and an employee with the Family Advocacy Program – all covered by the House bill.

Read more here.

February 15, 2016 in Child Abuse | Permalink | Comments (0)

Sunday, January 31, 2016

Springfield Mom Creates Foundation to Fight Child Abuse

From Springfield News-Leader:

Cindy Dennis, author of child abuse prevention books, is creating the Give A Child A Voice Foundation.

By forming a nonprofit foundation, Dennis said she hopes to reach more children, parents, grandparents, foster parents and educators. As a foundation, she will be in a better position to raise funds and apply for grants. And she can get cheaper "nonprofit" publishing rates.

The Springfield mom presented her plans Wednesday at the 1 Million Cups meeting, where entrepreneurs pitch their business concepts to an audience.

"Our objective is to reduce and eventually end all forms of child abuse, neglect and molestation," she told the audience. "We will achieve this by teaching kids to stand up for themselves, be vigilant and become a crusader for their own well-being."

"Children will learn that their bodies are sacred and no one has a right to victimize them. They will learn tactics and strategies that can lead to prevention."

Dennis said as the foundation raises money, she will be able to create a high-quality video "that is engaging to children with animation and songs." Dennis also wants to distribute the book "Friend Manual" to kindergarten through third-grade classes, preschools and churches.  "Friend Manual" teaches kids about safety, the difference between good secrets and bad secrets, and what to do if a stranger approaches or tries to grab them.

Read more here.

January 31, 2016 in Child Abuse | Permalink | Comments (0)