October 27, 2007
Sham Marriage Allegations in Brownsville
The Associated Press reports:
Two Americans and two Israelis accused by immigration authorities of entering into sham marriages are scheduled to appear in court Monday.
Jessica Martinez, a U.S. citizen, and her Israeli husband Eldad Efraim; and Ray Richard Vega, a U.S. citizen, and his Israeli wife, Miri Smoler, are charged with "knowingly enter(ing) into a marriage for the purpose of evading a provision of immigration laws," according to court documents. The felony charge carries up to five years in federal prison and up to $250,000 in fines.
Both couples married in November 2004. U.S. Immigration and Customs Enforcement allege Efraim and Smoler paid Martinez and Vega $5,000 each to enter into fraudulent marriages. Click here for the full story.
Susan Gordon: U.S. Naturalization Policies
RESEARCH SEMINAR SERIES
Fall Quarter 2007
Integrating Immigrants or Testing for Citizenship? Reconciling Goals and Practices in U.S. Naturalization Policies
Political Scientist and Lectuer, Ben Gurion University (Israel); Guest Scholar, Center for Comparative Immigration Studies, UCSD
Tuesday, October 30, 3:00-5:00 p.m.
Eleanor Roosevelt College Administration Building
Conference Room 115, First Floor
Reception to follow
The issues of how to integrate immigrants and ensure the integrity of citizenship have become passionate topics of public discourse and policy debate in recent years in a number of immigrant receiving countries. Behind these debates are often unarticulated questions about how to ensure loyalty to the state and to particular conceptions of national identity among prospective citizens. These issues have been explicitly debated in the United States since the enactment of the first naturalization law in 1790, which requires that immigrants who wish to become citizens demonstrate their good moral character and attachment to the country. Dr. Gordon's talk will address the ways that these morality and loyalty requirements have historically been applied and institutionalized in US naturalization practice, as well as the role they have played in current debates and policy developments.
Susan M. Gordon is a political scientist at Ben Gurion University in Beersheva, Israel and a visiting scholar at University of California, San Diego's Center for Comparative Immigration Studies. She is the author of "Integrating Immigrants: Morality and Loyalty in U.S. Naturalization Practice" (Citizenship Studies, September 2007). Her dissertation, Immigrant to Citizen: U.S. Naturalization Education, 1914-1973 (University of Chicago, 2004) explores the history of United States government efforts to define and educate immigrants for citizenship.
These seminars are open to the general public. For directions to CCIS, visit our website. Parking permits can be purchased at the information booth on North Point Drive (north end of campus). Visitors may also use metered parking spaces (max. 2 hours) in the North side parking lot. Papers previously presented at CCIS seminars can also be downloaded from our website under “Working Papers.” For further information, please contact Ana Minvielle (E-mail: email@example.com, Tel#: 858-822-4447).
Center for Comparative Immigration Studies
9500 Gilman Drive
University of California, San Diego
La Jolla, CA 92093-0548
More From Prince William County
Phil Tajitsu Nash has an interesting piece in Asian Week about the political posturing about immigration in Northern Virginia. He begins: "In what could be a preview of politics in the 2008 presidential campaign, voters in Virginia are being bombarded with negative advertising that includes anti-immigrant bashing in the run-up to the state’s November 6 elections." An interactive documentary mentioned in the story, which includes some troubling testimony from the public about immigrants in Prince William County, can be found here.
October 26, 2007
Scary Political Prognosis: Lou Dobbs (the "pope of popularist politics") voters' will decide '08
Christopher Gacek of Politico.com has issued a frightening Halloween prediction:
"CNN anchor Lou Dobbs may be the most important person in the 2008 presidential election aside from the candidates themselves. The bundle of concerns that Dobbs and his audience have about globalization, trade, diminished American sovereignty and immigration will be ignored by politicians at their own peril. The elites of the Democratic and Republican parties don’t realize the deep political vein Dobbs has struck. In fact, they tend to be quite scornful of him. Nevertheless, the presidential candidate who pursues and captures the `Lou Dobbs voter' will win the 2008 election."
Gacek's prediction: "the next president will have the blessing of the pope of popularist politics (P-cubed), Lou Dobbs." (emphasis added).
Oh no, Mr. Bill!!!!!!!!!!!!
The Citizens Almanac
The U.S. Citizenship and Immigration Services has released "The Citizen's Almanac: Fundamental Documents, Symbols, And Anthems Of the US." As USCIS Director Emilio Gonzalez notes in his preface, "Naturalized citizens have played an important role in shaping this country. From Alexander Hamilton to Albert Einstein, foreign-born Americans have contributed to all aspects of society - literature, motion pictures, public service, and athletics, to name just a few." The Almanac includes much information about the rights and responsibilities of U.S. citizens, patriotic anthems and symbols of the U.S., Presidential and historical speeches (including Martin Luther King, Jr.'s "I Have a Dream" speech), fundamental documents of American democracy, landmark decisions of the U.S. Supreme Court, Presidential statements on citizenship and immiugration, and a list of prominent foreign-born Americans.
CRS On Cuban Migration Issues
The Congressional Research Service has issued a report on Cuban migration. It states, among other things, that "Since the last upsurge of `boat people' in the mid-1990s, the US and Cuba worked toward establishing safe, legal immigration, which include returning migrants interdicted by the US Coast Guard."
NOT ALL HISPANICS ARE UNDOCUMENTED!
FROM IMMIGRATION DAILY:
A graph entitled "The VDare.com Worker Displacement Index" in a recent Article differentiates between Hispanic employment and non-Hispanic employment and alleges that the difference between these two lines represents American worker displacement. To conclude that all Hispanics are immigrants or take away jobs from Americans is preposterous. Many Hispanics are American-born or naturalized citizens and some are legal immigrants. The undocumented are just one component measured as Hispanic by the Census Bureau. To say that if an American-born Hispanic or a naturalized Hispanic displaces an "American worker" when employed is ridiculous. The only correct conclusion that one can draw from the assumptions made in this graph is that it represents open xenophobia in that all Hispanics are considered as un-American. We regret that many in the general press refer to such xenophobes as "anti-illegal advocates". As the nomenclature on this graph shows, these advocates are anti-immigration advocates and are hiding behind the fig leaf of "anti-illegal". Let's call a spade a spade.
On Life, and Passing the Naturalization Exam
An email from a former undergrad student I thought I'd share:
Dear Professor Hing,
It's been months since we've last talked about naturalization and the possibility of changing names. I'd thought I should give you an update since then.
Neither my father nor I changed our names. My father simply decided not to. I was told by my interviewer that I had to go to court, made some notes on the application and continued on with the session. I'm still not sure if they've changed their policy on name changing, but oh well. It was still a great moment when we both passed.
Just as a side note: I know that those over 50 years of age are asked more history questions than about the government. However, even I, nevermind my father, could answer this on the spot: who was the second president of the United States? Then again, I wasn't surprised that I couldn't remember facts that I've last encountered in high school.
Our oath ceremony was yesterday morning. It was announced that there was over 1500 people to be sworn in and about 100 that never showed up. Overall, I felt like I was sitting still for too long. However, the video shown about Ellis Island was interesting. And apparently, America is not a melting pot or a salad bowl, but a stew pot. When the ceremony was over, everybody was rushing out the doors to deal with their social security and passports.
Then we celebrated over bowls of pho. It was delicious.
As for now, I've graduated and been unemployed for a month now, doing odd jobs for my parents. The current stunt is fence painting in 80 degree heat. I'll start looking for jobs again, when I give myself some motivation. Constantly hearing that I should find a job that pays at least $20 per hour is disheartening. I'm still trying to figure out a way to tell my mother that I will not become a financial analyst.
Have a good school year!
Legal Violence and Salvadoran and Guatemalan Immigrants
The Institute for the Study of Social Change presents:
Legal Violence and the Family Lives of Salvadoran and Guatemalan Immigrants
Thursday, November 8, 12:00-1:30 pm
ISSC Conference Room, 2420 Bowditch Street (at Haste), Berkeley, CA
Cecilia Menjívar, Associate Professor of Social and Family Dynamics, Arizona State University
with Ramón Grosfoguel, Associate Professor of Ethnic Studies, UC Berkeley, as respondent
This presentation will examine the effects of legal violence, created by federal immigration laws, local level ordinances, and special statuses that lead to liminal legality, on the lives of individuals and their families. The research is based on the experiences of Salvadorans and Guatemalans in different U.S. cities over the past 15 years. Long term family separations have detrimental consequences for the children who stay in the countries of origin as well as for family reunification in the United States . Legal status emerges as central in shaping the lives of immigrants, and it can constitute a new axis of social stratification.
Cecilia Menjívar, Associate Professor of Social and Family Dynamics, Arizona State University
Menjívar has been studying the effects of legal, social and economic exclusion on different spheres of social life among immigrants, such as social networks, family, gender relations, religious participation, and transnational ties, focusing primarily on Central American immigrants in the United States . She also is examining the militarization of the U.S. border and its effects for the immigrants who cross it (or perish in attempts to do so). She is the editor of When States Kill: Latin America, the US and Technologies of Terror (University of Texas Press 2005) and Through the Eyes of Women: Gender, Social Networks, Family and Structural Change in Latin America and the Caribbean (De Sitter Publications 2003) and author of Fragmented Ties: Salvadoran Immigrant Networks in America (University of California Press 2000).
Ramón Grosfoguel, Associate Professor of Ethnic Studies, UC Berkeley
Grosfoguel is the author of Colonial Subjects: Puerto Rico in a Global Perspective (University of California Press 2003). He is a senior researcher at the Maison des Sciences de l'Homme in Paris. He has published many articles on Caribbean migration to Western Europe and the United States and on Latin American/Caribbean development. He is coeditor of the volume Puerto Rican Jam! Beyond Nationalist and Colonialist Discourses (University of Minnesota Press 1997).
Co-sponsored by ISSC's Center on Culture, Immigration and Youth Violence Prevention, the Center for Latino Policy Research, and the Berkeley Diversity Research Initiative.
This colloquium is wheelchair accessible (please call one day in advance), free, and open to the public. Light refreshments will be provided.
For more information, please contact Usree Bhattacharya , Institute for the Study of Social Change, firstname.lastname@example.org or call (510) 642 0813.
San Diego Fire Impacts on Immigrants
The big story in the West this week has been the rash of wildfires in Southern California, which it appears are now under control.
Many immigrants live and work in the San Diego area and seek entry into the United States through that region. Like other residents of the area, immigrants have been affected by the firestorm. We previously have reported how immigrant communities have been affected by natural disasters, such as Hurricane Katrina. For stories of the impacts of the fires on immigrants and immigration, click here and here. Expect to hear more about the fires impacts on immigrants as the stories unfold.
CNN reports that, yesterday, the number of deaths attributed directly to the fires grew to seven, after the charred bodies of four people believed to be undocumented immigrants were found in a canyon east of San Diego. The first body was found by firefighters from Mexico, who had come to assist in the efforts to put out the San Diego fire. For a story about the Mexican firefighters, click here.
There has been reported that ICE has questioned some evacuees about there immigration status at Qualcom Stadium in San Diego. There also are reports that some undocumented immigrants have been arrested for taking supplies meant for evacuees.
UPDATE: Press Release: MALDEF ENCOURAGES ALL VICTIMS OF SAN DIEGO FIRES TO SEEK ASSISTANCE Los Angeles, CA – "The tragic fires that swept Southern California hit citizen and non-citizen alike. As the nation and community come together, there are vital relief services available to all victims, irrespective of their immigration status. We encourage anyone in need of assistance to contact the Federal Emergency Management Agency (FEMA) if they have suffered injury or property loss," said John Trasviña, President and General Counsel of MALDEF. “According to FEMA guidelines, any victim of a federal emergency may be eligible for Crisis Counseling or Disaster Legal Services and other short-term non-cash emergency aid regardless of immigration status. Receipt of these services does not affect Legal Permanent Residents’ later eligibility for citizenship.” While FEMA will not provide any cash assistance directly to undocumented immigrants, they will provide assistance to any family member who is eligible. Citizens and legal permanent residents qualify for assistance. Restrictions may apply to those with temporary status. If you do not have legal status, you can apply on behalf of your minor child (under 18 years of age) for FEMA cash assistance (Individuals and Households Program Assistance) if you live together. Your child must be a citizen or a legal permanent resident. You will not have to provide any information on your immigration status or sign any documents regarding your status. In those cases where no one in the family is eligible for federal funds, those families will be referred to state, local and private agencies that may be able to help. Even if you do not qualify for FEMA cash assistance (Individuals and Households Program Assistance), please call FEMA at 1-800-621-3362 or 1-800-462-7585 (TTY for hearing/speech-impaired) for information and to be referred to other programs that can assist you regardless of your immigration status. The FEMA assistance line provides Spanish language assistance. To report victim abuse and scams or to receive further information on numerous contractors, loan officers and other licensed professionals who can assist victims in rebuilding their property and lives, please call the California State and Consumer Service Agency at 1-800-952-5210. In response to both rumors and facts about U.S. Border Patrol enforcement activity at a relief site, MALDEF has been assured by U.S. Customs and Border Protection that the agency’s role is to provide assistance to firefighting and humanitarian relief, not to conduct enforcement operations. While one well publicized incident occurred, it appears to be isolated to particular circumstances. Community members may contact MALDEF should Border Patrol or ICE enforcement efforts interfere with humanitarian assistance or relief and should not let the incident keep individuals from seeking necessary assistance."
Immigrants Targeted for Crime in Wake of Anti-Immigrant Hysteria in Virginia
We recently (and here) reported on the immigration law passed in Prince William County. Latinos were particularly upset by the law's unanimous passage. As has been seen in the past, the anti-immigrant agitation for the law has had negative collateral effects on the immigrant -- lawful and undocumented -- community. The Washington Post reports that robbers have targeted immigrants for crime. This unfortunately is not surprising. My bet is that we will see an increase in the number of hate crimes against Latina/os and reports of discrimination against Latina/os in the wake of the passage of the Prince William County law. Sadly, it is as predictible as the sun rising in the morning.
The Ties that Bind? Immigrants Are Here -- and There
Immigrants have deeply complex ties with the United States and their native countries -- and the nature of those ties might be changing. For example, millions of Mexican migrants in this country for decades have sent money back home to villages, money that allows families to pay medical bills and school fees, build houses and buy clothes or maybe start a tiny business. But the amount of migrant money flowing to Mexico has stagnated. From 2000 to 2006, remittances grew to nearly $24 billion a year from $6.6 billion, rising more than 20 percent some years. In 2007, the increase so far has been less than 2 percent. According to the N.Y. Times, "Migrants and migration experts say a flagging American economy and an enforcement campaign against illegal workers in the United States have persuaded some migrants not to try to cross the border illegally to look for work. Others have decided to return to Mexico. And many of those who are staying in the United States are sending less money home."
Nonetheless, according to a new study of the Pew Hispanic Center, the majority of Hispanic immigrants maintain ties to their native countries by sending money, calling or traveling to their homelands. Nonetheless, most see their future in the United States despite these long-distance links. Just 9 percent of Latino immigrants are "highly attached" to their birth countries -- defined by researchers as doing all three "transnational activities": dispatching funds, phoning weekly or going home in the past two years. Most sustain moderate bonds by doing one or two. But those attachments fade with time, according to the new Pew Hispanic Center report based on a nationwide survey of Latinos. "What's striking is that although the long-term trend is toward disengagement . . . most immigrants are involved in some form of contact with the place which they're from," said Roger Waldinger, a UCLA sociology professor. "What we have is a population that, as we tried to describe, is between here and there." For a story about the report, click here.
Immigrant of the Day: Marion P. Primomo (Germany)
Dr. Marion P. Primomo, is a physician ath the Hospice and Palliative Medicine in San Antonio, Texas and a Professor in the Department of Family Practice at the University of Texas Health Science Center at San Antonio. Born in Germany, Dr. Primomo obtained her medical degree at Loyola University in Chicago. In 1978, she became medical director of San Antonio's first hospice at St. Benedict's facility. Today over 1,000 patients a day are served by San Antonio's 28 hospices, 5 of which named Dr. Primomo as their medical director.
Dr. Primomo has been recognized for her work in hospice and palliative care. She is a founding member of the Academy of Hospice Physicians, now known as the Academy of Hospice and Palliative Medicine, and the International Hospice and Palliative Care Institute. In 1998, Dr. Primomo developed and coordinated the Palliative Medicine Fellowship at at UT-San Antonio Health Center, the fourth such Fellowship Program in the United States. Presently, Dr. Primomo serves as Hospice Consultant to several San Antonio Hospices in addition to teaching.
October 25, 2007
Memphis Law Review: Call for Papers
I am writing to you today to inform you that the University of Memphis Law Review is dedicating its Spring Symposium to Issues in Immigration Law. We are seeking additional scholars who are interested not only in submitting articles for publication but also in serving as guest presenters for our live symposium, which will be held on February 15, 2008, at the FedEx Institute of Technology on the University of Memphis campus. Presenters currently include Prof. Brian G. Slocum of Florida Coastal School of Law and Ms. Shoba Sivaprasad Wadhia of the National Immigration Forum. Mr. Greg Siskind, founding partner of Siskind Susser Bland, is also assisting and advising us on the Symposium.
Attached to this email is our official Call for Papers in Word and PDF formats. We would be most grateful if you would post this to your ImmigrationProf Blog, as its prestige and wide readership are sure to attract the largest number of candidates possible. If you have any questions whatsoever, please do not hesitate to contact me either via email at email@example.com or by telephone at (901) 274-4175. I look forward to hearing from you.
S. Anthony Silva
ANNOUNCEMENT AND CALL FOR PAPERS
In recent times, arguably no legal topic has generated as much coverage or proven to be as socially divisive as immigration reform. Although the nation has recognized the great need to reform its immigration laws to reflect the needs, values, and safety concerns of our country, our lawmakers have struggled with great difficulty to agree upon such reforms. In the ever-increasing climate of economic, social, and cultural globalization, our nation must engage in earnest debate to find solutions to these issues.
The University of Memphis Law Review is pleased to announce its annual Spring Symposium to be held on Friday, February 15, 2008 at the University of Memphis in Memphis, Tennessee. This symposium will explore the myriad legal issues surrounding the controversies of immigration reform.
Although the University of Memphis Law Review invites articles on any subject related to immigration reform, suggested article topics include, but are not limited to, the following:
- Criticisms and analyses of currently proposed federal reforms
- The conflict between federal law and state attempts at regulation
- Novel ideas and solutions for immigration, with an emphasis on discrete aspects of immigration law (e.g., reforms to specific family-based or employment-based visas or related procedures, asylum, relief from removal)
- The effects of immigration reform on related areas of law such as labor/employment, civil rights, family law, criminal law, or economic analysis of current immigration laws and/or proposed reforms
Presenters will be reimbursed for reasonable travel expenses to attend the Symposium and papers will be published in the symposium issue of the University of Memphis Law Review. Although preference will be given to papers submitted by January 1, 2008, later submissions may be accepted on a case-by-case basis. Submissions may be sent via email attachment in Word or WordPerfect format or via regular mail to:
S. Anthony Silva
University of Memphis Law Review
Cecil C. Humphreys School of Law
3715 Central Avenue, Room 323
Memphis TN 38152
Guiliani Campaign Lands Law Prof Jan Ting (Temple) for Immigration Expertise
Last year, Temple University law professor Jan Ting was on the campaign trail, calling for tighter borders in an unsuccessful bid to unseat U.S. Senator Tom Carper. Today, Ting is working on the campaign of Republican presidential hopeful Rudy Giuliani. Delaware On-line reports that "Under attack from his GOP rivals for being soft on illegal immigration, Giuliani has tapped Ting and other anti-illegal immigration stalwarts for his campaign's immigration advisory board -- a move that many expect will boost his standing with hard-line Republicans concerned about the former New York City mayor's abortion- and gay-rights stances. Giuliani was familiar with Ting's U.S. Senate bid in 2006, when Ting ran on an anti-immigration platform, said Jeffrey Barker, spokesman for the Giuliani campaign." Click here for some of Jan Ting's immigration stances in last year's U.S. Senate race.
UNESCO's International Journal on Multicultural Societies (IJMS) entitled “Migrant Integration in Rural Areas - Evidence from New Countries of Immigration"
Vol. 9, No. 1 of the UNESCO's International Journal on Multicultural Societies (IJMS) entitled “Migrant Integration in Rural Areas - Evidence from New Countries of Immigration" is now available on-line at http://www.unesco.org/shs/ijms/vol9/issue1
Immigrant of the Day: Jose E. Martinez (Dominican Republic)
The Honorable Jose E. Martinez, U.S. District Judge for the Southern District of Florida, was confirmed as a federal judge by the U.S. Senate on September 13, 2002. Born in Santo Domingo, Dominican Republic, Martinez attended the University of Miami where he earned undergraduate and law degrees. Judge Martinez was a legal officer in the U.S. Navy and an assistant U.S. attorney for the Southern District of Florida. In July 1991, he joined the law firm now known as Gutierrez & Associates and became a name partner in September 1992. During a two-year leave from his firm, Martinez became the regional director for the Office for Drug Abuse Law Enforcement in the U.S. Department of Justice. Judge Martinez is a member of the American Bar Association, the Federal Bar Association, the Cuban American Bar Association, and the Hispanic National Bar Association.
ADL Report: "Immigrants Targeted: Extremist Rhetoric Moves into the Mainstream"
The Anti-Defamation League's new online report " Immigrants Targeted: Extremist Rhetoric Moves into the Mainstream" documents the rhetoric employed by groups that routinely position themselves as legitimate, mainstream advocates against undocumented immigration in America. A closer look at the public record reveals that many ostensibly mainstream anti-illegal immigration organizations – including those who testified before Congress or frequently appeared on news programs – promote virulent anti-Hispanic and anti-immigrant rhetoric. Some groups have fostered links with extremist groups. The groups highlighted in the ADL report include Mothers Against Illegal Aliens (Phoenix, AZ), the Federation for American Immigration Reform (Washington, DC), Choose Black America, You Don't Speak for Me, Americans for Legal Immigration Political Action Committee (Raleigh, NC), Grass Fire (Maxwell, IA) and The Dustin Inman Society (Marietta, GA).
For a link to the ADL press release about the report, and a link to it, click here.
October 24, 2007
Durbin v. Tancredo Re: DREAM Act
A side story on the DREAM Act involved Tom Tancredo's attack on Senator Dick Durbin for appearing at a presss conference with foreign students, who happened to be documented. Durbin told Tancredo, "have you no shame!"
Maple Brown reports:
Presidential candidate and Colorado Congressman Tom Tancredo blasted Senator Dick Durbin for what Tancredo says is “aiding and abetting illegal aliens” at his press conference yesterday on the DREAM Act.
Tancredo turned in Senator Durban’s event yesterday to immigration authorities for hosting the event in conjunction with discussion of the DREAM Act where illegal aliens were reported to be attending.
Tancredo said yesterday, “I call on the Immigration and Customs Enforcement Agency to detain any illegal aliens at this press conference. Just because these illegal aliens are being used for political gain doesn’t mean they get immunity from the law.”
“If we can’t enforce our laws inside the building where American laws are made, where can we enforce them?”
Today Tom Tancredo stepped up the rhetoric “Dick Durbin, by his own admission, brought in students who benefit from the DREAM Act for political gain,” said Tancredo. “Dick can split all the hairs he wants, but we all know the DREAM Act is designed to do one thing: benefit illegal aliens.” Click here and here for a couple stories.
SEIU Statement on the DREAM Act Vote
WASHINGTON, DC – This afternoon, the Senate voted down the DREAM Act, a bill that would help immigrant children who attend college or serve in the military legalize their status. This vote exposes the failed leadership of Senate Democrats and Republicans, who have allowed nativist anti-immigrant hate speech to overwhelm reason on the immigration reform debate. Below is a statement by SEIU Executive Vice President Eliseo Medina responding to the failed cloture vote.
“Today the dream is over for thousands of immigrant soldiers and college students who have fallen victim to a political hate storm. Instead of standing up for a smart, pragmatic bill that would give a break to deserving young people, Senate Republicans and Democrats caved to cowardice and fear.
“Before they took the dream away, striving young immigrants and patriots from across the country swarmed our nation’s capitol seeking reason and compassion. Instead, they found intolerance and partisanship.
“We applaud those 52 Senate leaders who voted in favor of this smart-minded bill. However, we need more courageous leaders to move past this futile deadlock. Congressional inaction just fuels anger and division on an issue that America is eager to solve.
“America became a great country because we gave opportunities to hard working newcomers and those willing to sacrifice for a dream. Today’s Senate vote does more than squash the dreams of thousands of deserving young people—it fosters hopelessness and despair in a nation in desperate need of progress.” ###
The 1.9 million member Service Employees International Union is the fastest-growing union in North America. Focused on uniting workers in three sectors SEIU is the largest health care union, including hospitals, nursing homes, and home care; the largest property services union, including building cleaning and security; and the second largest public employee union.