Hammond arson case

Hammond arson case
Date 2012
Location Harney County, Oregon
Cause Arson
Arrest(s) Dwight Lincoln Hammond, Jr.
Steven Dwight Hammond

The Hammond arson case was a court case culminating from 20-year-long legal disputes between Harney County, Oregon ranchers Dwight Lincoln Hammond, Jr., 73; his son Steven Dwight Hammond, 46; and federal officials.[1] In 2012, both Hammonds were charged with several counts in relation to two fires in 2001 and 2006, and eventually convicted of two counts of arson on federal land. They were sentenced to time in jail, which they served. In 2015, the United States Court of Appeals for the Ninth Circuit vacated these sentences because they were shorter than the statutory mandatory minimum. The Ninth Circuit remanded to the district court for resentencing. The district court subsequently re-sentenced both Hammonds to the mandatory minimum of five years in prison, with credit for time served.

By late 2015, the Hammond case had attracted the attention of Ammon and Ryan Bundy, who planned a protest against the re-sentencing, though the Hammonds rejected their assistance.[2][3] However, the protest still went into effect on January 2, 2016, and resulted in the Bundys and associates staging a 40-day armed occupation of the headquarters area of the Malheur National Wildlife Refuge.

Background

Location

Harney County is a rural county in eastern Oregon. The county seat is the city of Burns.[4][5] Although it is one of the largest counties by area in the United States,[4][5] its population is only about 7,700,[4] and cattle outnumber people 14-to-1.[4] About 75 percent of the county's area is federal land,[4] variously managed by the United States Bureau of Reclamation (USBR), the Bureau of Land Management (BLM), the United States Fish and Wildlife Service (USFWS), and the United States Forest Service (USFS).[6] Besides ranching and farming, forestry and manufacturing are important industries in the county.[5]

The Malheur National Wildlife Refuge, located in Harney County, was established in 1908 by President Theodore Roosevelt, a conservationist.[7] Located in the Pacific Flyway, and currently encompassing 187,757 acres (760 km2), it is "one of the premiere sites for birds and birding in the U.S.," according to the Audubon Society of Portland.[8] Tourism, especially birding, injects US$15 million into the local economy annually.[9]

Cattle ranching in Harney County

Cattle ranching in Harney County predates the 1908 establishment of the Malheur National Wildlife Refuge, with some cattle trails, including those used by the Hammond family, dating back to the 1870s. Disputes between cattle ranchers and the federal government over management of the Malheur National Wildlife Refuge have gone on for "generations" and the situation has regularly deteriorated to taunts and threats directed at federal officials from ranchers since at least the early 1970s.[10][11]

In an effort to address concerns of neighboring landowners and interests, the recent completion of a 15-year management plan for the refuge heavily involved various stakeholders, including ranchers, in its development process. The plan was completed in 2013 and won praise from some area ranchers for its collaborative approach.[12][13]

Early conflicts with federal land managers

In June 1994, the Malheur National Wildlife Refuge manager notified Dwight Hammond that his permit to graze his cattle and grow hay on the refuge was revoked. Two months later, Hammond and his son Steven obstructed the completion of a fence on the refuge boundary to keep their cattle out of the refuge's marsh and wetland, prompting their arrest by federal agents. According to federal officials, the fence was needed to stop the Hammonds' cattle from moving onto the refuge after the ranchers had repeatedly violated the terms of their special permit, which limited when they could move their cattle across refuge property.[11][14] Officials also reported that Dwight Hammond had made death threats against refuge managers in 1986, 1988, 1991, and 1994; and that Steven Hammond also made highly hostile remarks against them.[10][11][15] The Hammonds, had noted that the cattle trail in question was a historic route that had been continuously used since 1871.[11]

Following their release from jail on recognizance, a rally attended by 500 other cattle ranchers was held in support of the Hammonds in Burns, and then-U.S. Representative Robert Freeman Smith from Oregon wrote a letter of protest to the United States Secretary of the Interior, Bruce Babbitt.[11] Charges against the Hammonds were later dropped.[10]

In 1999, Steven Hammond started a fire with the intent of burning off juniper trees and sagebrush, but the fire escaped onto BLM land. The agency reminded Hammond of the required burn permit and that if the fires continued, there would be legal consequences.[16]

Arson case

Fires for which the Hammonds were convicted

Both Dwight and Steven Hammond later set two fires, one in 2001 and one in 2006, that would lead to convictions of arson on federal land:[17][18]

Mid-trial pre-sentencing agreement

In 2012, the Hammonds were tried in federal district court on multiple charges. During a break in jury deliberations, partial verdict were rendered finding the Hammonds not guilty on two of the charges, but convicting them on two counts of arson on federal land.[20] Striking a plea bargain, in order to have the four remaining charges dismissed and for sentences on the two convictions to run concurrently, the Hammonds waived their rights to appeal their convictions. This was with their knowledge that the trial would proceed to sentencing where the prosecution intended to seek imposition of the mandatory five-year minimum sentences.[20][24]

Sentencing hearing, appeals of the sentence, and re-sentencing

At sentencing, the federal prosecutors requested the five-year mandatory minimum under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).[23][25][26][27] U.S. District Judge Michael Robert Hogan independently decided that sentences of that length "would shock the conscience" and would violate the constitutional prohibition on cruel and unusual punishment. On his last day on the bench before retiring, October 31, 2012, Hogan instead sentenced Dwight Hammond to three months' imprisonment and Steven Hammond to a year and a day's imprisonment, which both men served.[28][29] In what was described by one source as a "rare" action,[30] the government (represented by the United States Attorney's Office for the District of Oregon, led by U.S. Attorney Amanda Marshall) successfully appealed the sentence to the United States Court of Appeals for the Ninth Circuit. It upheld the mandatory-minimum law, writing that "given the seriousness of arson, a five-year sentence is not grossly disproportionate to the offense." The court vacated the original sentence and remanded for re-sentencing. The Hammonds filed petitions for certiorari with the U.S. Supreme Court, which the court denied in March 2015.[22][25] In October 2015, Chief Judge Ann Aiken re-sentenced the pair to five years in prison (with credit for time served), ordering that they return to prison on January 4, 2016.[25][29]

Both of the Hammonds reported to Federal Correctional Institution, Terminal Island in California on January 4, as ordered by the court.[31] A few days earlier, the Hammonds also paid the federal government the remaining balance on a US$400,000 court order for restitution related to the arson fires.[23]

On January 25, it became known that Susan Hammond, the wife of Dwight Hammond, signed a document for participation in a so-called "citizen grand jury" and claimed that the paper would clear her husband of wrongdoing. The author of the paper was Joaquin Mariano DeMoreta-Folch, a Tea Party activist.[32] The self-styled "citizens grand jury" has no legal standing, but is rather linked to the fringe sovereign citizen movement, a conspiratorial movement which rejects federal authority.[33][34]

Aftermath of re-sentencing

Bundy in 2014.

After the U.S. Supreme Court declined to hear the Hammonds' appeal in March 2015, the Hammonds' case returned to federal district court where they were re-sentenced to the statutory minimum of five years, with credit for time served.[29] Meanwhile, the Oregon Farm Bureau circulated a petition seeking clemency from President Barack Obama;[35] it had gathered more than 2,000 signatures by October 2015.[29] Meanwhile, the Oregon Cattleman's Association, a trade group representing cattle ranchers in Oregon, established a fund to defray the Hammond's legal fees.[36]

About this time, the Hammonds' case attracted the attention of Ammon Bundy—a former car fleet manager from Phoenix, Arizona;[37] and the son of anti-government protester Cliven D. Bundy, the central figure of a standoff with the BLM in 2014—and Ryan Payne. In November 2015, Bundy and his associates began publicizing the Hammonds' case via social media.[38][39]

Over the ensuing weeks, Bundy and Payne met for approximately eight hours with Harney County Sheriff David Ward to detail plans for what they described would be a peaceful protest in Burns, as well as also requesting the sheriff's office protect the Hammonds from being taken into custody by federal authorities. Though Ward said he sympathized with the Hammonds' plight, he declined Bundy and Payne's request. Ward then said that he subsequently received death threats by email. Unbeknownst to Ward, Bundy and Payne were simultaneously planning a takeover of the Malheur National Wildlife Refuge. By late fall, local, state, and federal law enforcement agencies had become aware that members of anti-government militias had started to relocate to Harney County, and the USFWS began circulating a photograph of Ammon Bundy with instructions for staff to "be on the lookout."[18][40][41]

Despite several early meetings with Bundy and Payne, the Hammonds eventually rejected their offers of assistance, with Hammond attorney W. Alan Schroeder writing that "neither Ammon Bundy nor anyone within his group/organization speak for the Hammond family."[2]

By early December 2015, Bundy and Payne had set up residence in Burns. The same month, they organized a meeting at the Harney County Fairgrounds to rally support for their efforts. At the meeting, a "committee of safety" was organized to orchestrate direct action against the Hammond sentences.[18] According to that group's website, the Harney County Committee of Safety considers itself "a governmental body established by the people in the absence of the ability of the existing government to provide for the needs and protection of civilized society"[42] (during the American Revolution, committees of safety were shadow governments organized to usurp authority from colonial administrators).[43]

2016 occupation of the Malheur National Wildlife Refuge

On January 2, 2016, an armed group affiliated with the private U.S. militia movement held a peaceful march in protest of the Hammonds' prison sentences. Afterwards, several members of the group, consisting of Bundy, Payne, Jon Ritzheimer,[44] and armed associates separated from the protest crowd at some point during the day and proceeded to the Malheur National Wildlife Refuge, 30 miles (48 km) away. The militants settled into the refuge and set up defensive positions.[45][46] The Hammonds were convicted of arson on federal land,[47] sentenced to five years' imprisonment, and sought clemency from the U.S. president.[48]

Bundy said he began leading the occupation after receiving a divine message ordering him to do so.[49][50] The militant group demanded that the federal government of the United States cede ownership of the refuge,[51] and expressed willingness to engage in armed conflict.[52] For a time, the government and police did not engage directly with the militia.[53]

Dwight and Steven Hammond disavowed the occupation of the refuge.[54] They voluntarily reported to begin serving the remainder of their respective prison sentences.[55]

On January 26, Bundy and four other militants were arrested on U.S. Route 395 about 48 miles (77 km) north of the occupation. One militant was lightly wounded during the arrest,[56] and another, Robert "LaVoy" Finicum, was shot and killed by law enforcement officers while he was reportedly reaching for his gun.[57][58] Several other arrests followed,[59][60][61] and on February 11, the occupation ended when the last four militants surrendered to police.[62] A total of 26 people, including Bundy and Payne, were charged under federal law with a single count of felony conspiracy, though more charges may be brought in due course.[63][64]

References

  1. ↑ "Eastern Oregon Ranchers Convicted of Arson Resentenced to Five Years in Prison". United States District Attorney for the District of Oregon. October 7, 2015. Retrieved March 25, 2016.
  2. 1 2 Stack, Liam (January 2, 2016). "Militiamen Occupy Oregon Wildlife Refuge in Protest of Ranchers' Prison Terms". The New York Times. Retrieved January 3, 2016.
  3. ↑ Moore, Wanda; Lerten, Barney (January 4, 2016) [1st pub. January 3, 2016]. "Militia leader explains takeover, says group has name: Calling selves 'Citizens for Constitutional Freedom'". Bend, Oregon: KTVZ. Archived from the original on January 4, 2016.
  4. 1 2 3 4 5 Crombie, Noelle (January 3, 2016). "Where is Burns? Harney County home to more cattle than people". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Archived from the original on January 4, 2016.
  5. 1 2 3 "Harney County Transportation System Plan: Revised Final Draft" (PDF). Burns, OR: Harney County Planning Department. June 2001. pp. 9–10. Retrieved February 6, 2016.
  6. ↑ "Harney County with Township 8.5 x 11" (PDF). Harney County GIS Program. Burns, OR: Harney County Government. Retrieved January 2, 2016.
  7. ↑ Roosevelt, Theodore (August 18, 1908). Wikisource link to Executive Order 929. Wikisource.
  8. ↑ "Malheur National Wildlife Refuge". Portland, OR: Audubon Society of Portland. Retrieved January 12, 2016.
  9. ↑ Donahue, Bill (January 7, 2016). "How the West Wasn't Won". Bloomberg Businessweek (New York: Bloomberg L.P.). ISSN 0007-7135. Retrieved January 12, 2016.
  10. 1 2 3 Therialut, Denis C. (January 6, 2016). "Oregon militants: Death threats from ranchers reported years before standoff". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved January 6, 2016.
  11. 1 2 3 4 5 Durbin, Kathie (October 3, 1994). "Ranchers arrested at wildlife refuge". High Country News (Paonia, CO). ISSN 0191-5657. Retrieved January 3, 2016.
  12. ↑ Bernton, Hal (January 27, 2016). "The story behind the Malheur National Wildlife Refuge, ranchers and armed anti-government protesters". The Seattle Times (Seattle, WA: The Seattle Times Company). Retrieved February 7, 2016. Story originally published January 9, 2016, with title "Occupied Oregon wildlife refuge known for listening to ranchers."
  13. ↑ Parks, Randy (January 18, 2012). "Malheur wildlife refuge drafts CCP with the help of diverse stakeholders". Burns Times-Herald (Burns, OR). Retrieved January 15, 2016.
  14. ↑ St. Clair, Jeffrey (January 31, 2010). "Disquiet on the Western Front: Showdown in the Malheur Marshes". Salem-News.com (Salem, OR). Retrieved January 3, 2016.
  15. ↑ St. Clair, Jeffrey (January 31, 2010). "Disquiet on the Western Front: Showdown in the Malheur Marshes". Salem News. Retrieved January 3, 2016.
  16. 1 2 "10-30-2012 HOGAN HAMMOND SENTENCING FINAL - Transcript of Judges ruling.pdf" (PDF). October 30, 2012. Retrieved February 8, 2016. Reporter's transcript of United States v. Hammond, Case No. 6:10-cr-60066-HO (D. Ore.).
  17. ↑ Denson, Bryan (October 7, 2015). "Controversial Oregon ranchers in court Wednesday, likely headed back to prison in arson case". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved January 4, 2016.
  18. 1 2 3 Zaitz, Les (December 31, 2015). "Militiamen, ranchers in showdown for soul of Burns". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Archived from the original on January 3, 2016. Retrieved January 3, 2016.
  19. ↑ "Read: U.S. attorney statement on Oregon standoff". Chicago Tribune (Chicago, IL: Tribune Publishing). January 4, 2016. ISSN 1085-6706. Retrieved January 7, 2016.
  20. 1 2 3 4 5 "HammondGovBrief.pdf" (PDF). Retrieved February 8, 2016. United States' Supplemental Sentencing Memorandum (filed September 21, 2015), United States v. Hammond, Case No. 6:10-cr-60066-AA (D. Ore.).
  21. 1 2 Ditzler, Joseph (July 17, 2012). "Hammond Witness Describes Setting Fire In 2001". Portland, OR: Oregon Public Broadcasting. Retrieved January 4, 2016.
  22. 1 2 3 "hammond-cert2-br_in_opp-osg_aay_v2b.pdf" (PDF). Retrieved February 8, 2016. Brief for the United States in Opposition, Hammond v. United States, Docket No. 13-1512. Petition for certiorari denied on March 23, 2015. See: "Hammond v. United States : SCOTUSblog" and "Bloomberg Law - Document - United States v. Hammond, 742 F.3d 880 (9th Cir. 2014), Court Opinion" for related documents.
  23. 1 2 3 Zaitz, Les (January 5, 2016). "Oregon ranchers' fight with feds sparks militias' interest". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Archived from the original on January 8, 2016. Retrieved February 8, 2016.
  24. ↑ Manning, Jeff (January 16, 2016). "A harsh toll: How tough mandatory sentences inspired Harney County occupation". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved February 8, 2016.
  25. 1 2 3 "The feds' case: What they said of Hammonds' resentencing: Full text of U.S. Department of Justice news release". Bend, OR: KTVZ. January 4, 2016. Retrieved February 8, 2016.
  26. ↑ "Eastern Oregon Ranchers Convicted of Arson Resentenced to Five Years in Prison" (Press release). Eugene, OR: United States District Court for the District of Oregon. October 7, 2015. Retrieved February 8, 2016.
  27. ↑ Wm. Moyer, Justin (January 4, 2016). "The mysterious fires that led to the Bundy clan's Oregon standoff". The Washington Post (Arlington, VA: Nash Holdings LLC). ISSN 0190-8286. Retrieved February 8, 2016.
  28. ↑ Berman, Douglas A. (October 31, 2012). "Federal district judge refuses to apply arson mandatory minimum (on constitutional grounds?)". Sentencing Law and Policy (Blog). Retrieved January 12, 2016.
  29. 1 2 3 4 Perkowski, Mateusz (October 7, 2015). "Judge sends Oregon ranchers back to prison". Capital Press (Salem, OR: EO Media Group). Retrieved January 6, 2016.
  30. ↑ Dickinson, Tim (January 3, 2016). "WTF Is Happening in the Oregon Militia Standoff, Explained". Rolling Stone (New York). ISSN 0035-791X. Retrieved January 26, 2016.
  31. ↑ "Hammonds report to CA prison for arson". Portland, OR: KOIN. January 4, 2016. Retrieved January 4, 2016.
  32. ↑ Sepulvado, John (January 26, 2016). "Hammond Family Signs On To 'Citizens Grand Jury'". Portland, OR: Oregon Public Broadcasting. Retrieved January 29, 2016.
  33. ↑ Hammond, Betsy (January 12, 2016). "Self-appointed 'judge' arrives in Burns to ask local residents to charge government officials with crimes". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved January 30, 2016.
  34. ↑ Revesz, Rachael (January 18, 2016). "Oregon ranchers appoint conspiracy theorist 'judge' to help them send lawmakers to jail". The Independent (London: Independent Print Limited). ISSN 0951-9467. Retrieved January 30, 2016.
  35. ↑ "Sign petition to #SaveTheHammonds". Oregon Farm Bureau. Salem, OR. Retrieved March 21, 2016.
  36. ↑ "Up Front". Range Magazine. Winter 2015.
  37. ↑ Nagourney, Adam (April 24, 2014). "A Defiant Rancher Savors the Audience That Rallied to His Side". The New York Times (New York: The New York Times Company). p. A1. ISSN 0362-4331. Retrieved January 19, 2016.
  38. ↑ Bundy, Ammon (November 12, 2015). "Facts & Events in the Hammond Case". Bundy Ranch (Blog). Retrieved January 26, 2016.
  39. ↑ Santilli, Peter (host) (November 12, 2015). "Ammon Bundy – BLM Terrorizes Oregon Family". The Pete Santilli Show. Episode 1101. Retrieved January 26, 2016. On YouTube.
  40. ↑ Wilson, Jason (January 3, 2016). "Oregon militia threatens showdown with US agents at wildlife refuge". The Guardian (London: Guardian News and Media Limited). ISSN 0261-3077. Retrieved January 3, 2016.
  41. ↑ Brosseau, Carli (January 12, 2016). "Oregon occupation planned for months by Ammon Bundy and Montana militia leader". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved February 9, 2016.
  42. ↑ "Harney County Committee of Safety". Burns, OR. Retrieved January 3, 2016.
  43. ↑ Breen 2010, pp. 162, 186–189
  44. ↑ Zaitz, Les (January 3, 2016). "Militia takes over Malheur National Wildlife Refuge headquarters". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Archived from the original on January 3, 2016. Retrieved January 3, 2016.
  45. ↑ Zaitz, Les (January 5, 2016). "Militants continue occupation of Oregon refuge, police keep low profile". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Archived from the original on January 15, 2016. Retrieved February 9, 2016.
  46. ↑ Thomas, Judy L. (January 6, 2016). "Experts: Oregon standoff may be small, but it's just the tip of a growing militia iceberg". The Kansas City Star (Sacramento, CA: The McClatchy Company). ISSN 0745-1067. Retrieved January 20, 2016. The rally was peaceful, authorities said....But afterward, a group of armed militants split off, went to the wildlife refuge 30 miles away and took it over. Ammon Bundy has been acting as the group's leader, and they say they won't back down until the government relinquishes the federal refuge to the people.
  47. ↑ Terhune, Katie (January 6, 2016). "Inside the Hammonds' arson case at the center of the Oregon occupation". Portland, OR: KGW. Retrieved January 19, 2016.
  48. ↑ Bailey, Everton Jr. (January 5, 2016). "Oregon ranchers begin new prison term, hope to receive rare presidential clemency". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved January 19, 2016.
  49. ↑ Binder, Melissa (January 5, 2016). "Oregon militants: Why the Bundys' Mormonism matters". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved February 4, 2016.
  50. ↑ Sepulvado, John (January 4, 2016). Mormon Faith Serves As Powerful Symbol For Oregon Protesters. Interview with Audie Cornish. All Things Considered. NPR. Retrieved January 8, 2016.
  51. ↑ Petty, Terrence; Valdes, Manuel (January 7, 2016). "Oregon Tribe: Armed Group 'Desecrating' Their Land". ABC News (New York: American Broadcasting Company). Associated Press. Archived from the original on January 7, 2016. Retrieved February 4, 2016.
  52. ↑ Williams, Jennifer (January 26, 2016). "The Oregon militia standoff, explained". Vox (Washington, D.C.; New York: Vox Media). Retrieved February 5, 2016.
  53. ↑ Altman, Alex (January 4, 2016). "Why the Feds Have Not Ended the Oregon Militia Standoff". Time (New York: Time Inc.). ISSN 0040-781X. Retrieved January 18, 2016.
  54. ↑ "Oregon ranchers reject Cliven Bundy family occupation". CBS News (New York: CBS). Associated Press. January 3, 2016. Retrieved January 18, 2016.
  55. ↑ Bailey, Everton Jr. (January 5, 2016). "Oregon ranchers at center of militant standoff report to federal prison in California". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved February 9, 2016.
  56. ↑ Smith, Emily (January 28, 2016). "Malheur refuge occupation arrests: What happened and what happens next?". CNN (Atlanta, GA: Turner Broadcasting System). Retrieved February 5, 2016.
  57. ↑ Zaitz, Les (January 31, 2016). "Oregon standoff spokesman Robert 'LaVoy' Finicum killed, Bundys in custody after gunfight near Burns". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved February 5, 2016.
  58. ↑ Perez, Evan (January 28, 2016). "Oregon occupiers: What officials say happened at traffic stop". CNN (Atlanta, GA: Turner Broadcasting System). Retrieved January 27, 2016.
  59. ↑ Barr, Max (January 27, 2016). "Eight Oregon protesters arrested, one killed during confrontation with police". Portland, OR: KGW. Retrieved January 27, 2016.
  60. ↑ Friedman, Gordon; Stanglin, Doug (January 28, 2016). "FBI arrests 3 more Oregon protesters as standoff winds down". Cleveland, OH: WKYC. Retrieved January 28, 2016.
  61. ↑ Boydston, Morgan (January 28, 2016). "More arrests made in refuge takeover". Boise, ID: KTVB. Retrieved January 28, 2016.
  62. ↑ "Oregon standoff: 4 holdouts all in FBI custody as occupation ends". The Oregonian/OregonLive.com (Advance Publications). February 11, 2016. Retrieved February 1, 2016.
  63. ↑ Berman, Mark; Sottile, Leah (February 24, 2016). "Oregon refuge occupiers plead not guilty as prosecutors say more people could be charged". The Washington Post (Arlington, VA: Nash Holdings LLC). ISSN 0190-8286. Retrieved February 25, 2016.
  64. ↑ Bernstein, Maxine (March 10, 2016). "New six-count indictment unsealed in Malheur refuge occupation case". The Oregonian/OregonLive.com (Advance Publications). ISSN 8750-1317. Retrieved March 11, 2016.
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