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ERRONEOUS SANDOVAL RULING REQUIRED REVERSAL.

The Second Department, reversing defendant’s conviction, over a dissent, determined the Sandoval ruling erroneously allowed cross examination about a prior crime. The defendant chose not to testify and the proof was deemed far from overwhelming. During the prior crime (robbery) defendant held a knife to the victim’s throat. In the rape trial at issue, it was alleged the defendant held a knife to the victim’s throat:

While we recognize that, under Sandoval and its progeny, the mere similarity of crimes or conduct to the charge for which a defendant stands trial does not automatically preclude inquiry, here, under the particular facts and circumstances of this case, a proper balancing of the probative value of the defendant’s prior conduct of placing a knife to the robbery complainant’s neck, in connection with the issue of credibility, against the risk of unfair prejudice to the defendant, should have resulted in a ruling precluding the People’s proposed line of questioning … . Moreover, the error was not harmless … . The proof of the defendant’s guilt was far from overwhelming, and the defendant was the only available source of material testimony in support of his defense (see People v Sandoval, 34 NY2d at 378). Inasmuch as the pretrial ruling affected the defendant’s decision whether to testify and denied the jury potentially significant material evidence, the Supreme Court’s Sandoval ruling cannot be considered harmless … . People v Calderon, 2017 NY Slip Op 00479, 2nd Dept 1-25-17

CRIMINAL LAW (ERRONEOUS SANDOVAL RULING REQUIRED REVERSAL)/EVIDENCE (CRIMINAL LAW, ERRONEOUS SANDOVAL RULING REQUIRED REVERSAL)/SANDOVAL (CRIMINAL LAW, ERRONEOUS SANDOVAL RULING REQUIRED REVERSAL)

FORMER GOLDMAN SACHS EMPLOYEE’S CONVICTION FOR UNLAWFUL USE OF SCIENTIFIC MATERIAL (COPYING PROPRIETARY COMPUTER SOURCE CODE) SHOULD NOT HAVE BEEN SET ASIDE, VERDICT REINSTATED.

The First Department, in a full-fledged opinion by Justice Richter, determined defendant’s conviction for unlawful use of secret scientific information should not have been set aside:

Defendant was formerly employed by Goldman Sachs as a computer programmer. Prior to leaving Goldman to work for a potential competitor, defendant made a digital copy of Goldman’s proprietary computer source code by uploading and saving it to a hard drive of a server located outside the Goldman network. After surreptitiously uploading the source code, defendant transferred copies of it to several of his personal computing devices, and subsequently shared it with his new employer. As a result, defendant was charged with unlawful use of secret scientific material (Penal Law § 165.07). After a jury convicted defendant of this crime, the trial court set aside the verdict.

In this appeal, we are asked to decide whether defendant’s actions constitute legally sufficient evidence to establish that he made a “tangible reproduction or representation” of the source code, and did so with the “intent to appropriate . . . [its] use,” within the meaning of the unlawful use statute. We conclude that, viewed in the light most favorable to the People, the evidence was legally sufficient as to both of these elements. Accordingly, we reverse the trial court’s decision, reinstate the jury’s verdict and remand the matter for sentencing. People v Aleynikov, 2017 NY Slip Op 00449m 1st Dept 1-24-17

 

CRIMINAL LAW (FORMER GOLDMAN SACHS EMPLOYEE’S CONVICTION FOR UNLAWFUL USE OF SCIENTIFIC MATERIAL SHOULD NOT HAVE BEEN SET ASIDE, VERDICT REINSTATED)/UNLAWFUL USE OF SCIENTIFIC MATERIAL (FORMER GOLDMAN SACHS EMPLOYEE’S CONVICTION FOR UNLAWFUL USE OF SCIENTIFIC MATERIAL SHOULD NOT HAVE BEEN SET ASIDE, VERDICT REINSTATED)/CODE (COPYING PROPRIETARY COMPUTER SOURCE CODE, FORMER GOLDMAN SACHS EMPLOYEE’S CONVICTION FOR UNLAWFUL USE OF SCIENTIFIC MATERIAL SHOULD NOT HAVE BEEN SET ASIDE, VERDICT REINSTATED)/COMPUTERS (COPYING PROPRIETARY COMPUTER SOURCE CODE, FORMER GOLDMAN SACHS EMPLOYEE’S CONVICTION FOR UNLAWFUL USE OF SCIENTIFIC MATERIAL SHOULD NOT HAVE BEEN SET ASIDE, VERDICT REINSTATED)

SEARCH NOT JUSTIFIED BY THE EMERGENCY DOCTRINE, INJURY NOT SUFFICIENT TO SUPPORT ASSAULT 2ND.

The Second Department, reversing and reducing defendant’s convictions, determined a gun found after the emergency which justified police entry into defendant’s home had abated should have been suppressed. The police forced the door open after receiving a report of an assault with weapons and after learning the defendant had run inside the home. After the defendant was handcuffed and the children secured in a bedroom, the police searched the basement a second time and found the gun. The Second Department also hed the injury suffered by the assault victim was not serious enough to meet the requirements for assault second:

… [W]e agree with the defendant that the hearing court should have suppressed the gun. Although “warrantless entries into a home are presumptively unreasonable'” … , a warrantless search and seizure in a protected area may be lawful under some circumstances pursuant to the emergency doctrine … . The emergency exception “sanctions warrantless searches and seizures in circumstances presenting an immediate danger to life or property” … . “This exception must be narrowly construed because it is susceptible of abuse and may be used to validate an otherwise unlawful arrest or seizure” … . The People have the burden of justifying the warrantless search … . Moreover, the scope and duration of the search must be limited by, and reasonably related to, the exigencies of the situation … .

Here, the initial entry by the police into the defendant’s home and the initial search for occupants and weapons was justified under the emergency doctrine … . However, once the police had the defendant in handcuffs and had secured all of the occupants of the home in the rear bedroom, the emergency had abated … . People v Williams, 2017 NY Slip Op 00329, 2nd Dept 1-18-17

 

CRIMINAL LAW (SEARCH NOT JUSTIFIED BY THE EMERGENCY DOCTRINE, INJURY NOT SUFFICIENT TO SUPPORT ASSAULT 2ND)/SEARCH AND SEIZURE (SEARCH NOT JUSTIFIED BY THE EMERGENCY DOCTRINE)/SUPPRESSION (CRIMINAL LAW, SEARCH NOT JUSTIFIED BY THE EMERGENCY DOCTRINE)/ASSAULT (INJURY NOT SUFFICIENT TO SUPPORT ASSAULT 2ND)/PHYSICAL INJURY (CRIMINAL LAW, INJURY NOT SUFFICIENT TO SUPPORT ASSAULT 2ND)

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WAIVER OF A-1 FELONY INDICTMENT INVALID, DESPITE GUILTY PLEA, WAIVER OF APPEAL AND FAILURE TO PRESERVE THE ERROR.

The Second Department determined the waiver of indictment, which included an A-1 felony, was invalid. The guilty plea, the waiver of the right to appeal and/or the failure to preserve the error did not preclude appeal of the issue:

CPL 195.10 provides, in relevant part, that “[a] defendant may waive indictment and consent to be prosecuted by superior court information when . . . the defendant is not charged with a class A felony punishable by death or life imprisonment.” Thus, the Court of Appeals has held: “[W]hen an accused is held for Grand Jury action upon a felony complaint that charges a class A felony . . . a waiver of indictment with respect to that felony complaint is unauthorized” … . Here, the felony complaint charged the defendant with criminal possession of a controlled substance in the first degree. That crime is a class A-I felony (see Penal Law § 220.21), which is punishable by an indeterminate sentence with a mandatory maximum term of life imprisonment (see Penal Law § 70.00[2][a]). Accordingly, the defendant could not waive indictment and agree to be prosecuted by superior court information … . People v Janelle,2017 NY Slip Op 00188, 2nd Dept 1-11-17

CRIMINAL LAW (WAIVER OF A-1 FELONY INDICTMENT INVALID, DESPITE GUILTY PLEA, WAIVER OF APPEAL AND FAILURE TO PRESERVE THE ERROR)/INDICTMENT, WAIVER OF (WAIVER OF A-1 FELONY INDICTMENT INVALID, DESPITE GUILTY PLEA, WAIVER OF APPEAL AND FAILURE TO PRESERVE THE ERROR)/APPEALS (CRIMINAL LAW, WAIVER OF A-1 FELONY INDICTMENT INVALID, DESPITE GUILTY PLEA, WAIVER OF APPEAL AND FAILURE TO PRESERVE THE ERROR)

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NO PROOF DEFENDANT WAS DEPRIVED OF HIS LIMITED RIGHT TO SPEAK TO COUNSEL BEFORE TAKING BLOOD-ALCOHOL TEST, SUPPRESSION SHOULD NOT HAVE BEEN GRANTED, APPLICABLE LAW EXPLAINED.

The Second Department determined defendant’s motion to suppress the results of the blood-alcohol test and his statement should not have been granted. Although the police learned the name and phone number of defendant’s counsel before the test was administered, there was no evidence of the source of that information and no evidence counsel “entered” the case such that defendant should have been allowed to talk to his attorney before taking the test. The Second Department offered a concise explanation of the applicable law:

In People v Gursey (22 NY2d 224), the Court of Appeals held in this context that the police “may not, without justification, prevent access between the criminal accused and his lawyer, available in person or by immediate telephone communication, if such access does not interfere unduly with the matter at hand” (id. at 227…). The police have no duty to warn a defendant of this limited right before asking the defendant to submit to a blood alcohol test … . Violation of the limited right to consult with counsel will result in suppression of the test results … . * * *

“[A]n attorney enters’ a criminal matter and triggers the indelible right to counsel when the attorney or a professional associate of the attorney notifies the police that the suspect is represented by counsel” (People v Grice, 100 NY2d 318, 324). Notification given to the police by a third party, such as a member of the defendant’s family, is not sufficient to establish counsel’s entry into the case (see id. at 322 …). Although the holding in Grice related to the triggering of the indelible constitutional right to counsel, we see no reason to apply a less stringent rule for triggering the more limited right to consult with counsel before deciding whether to refuse a blood alcohol test. Indeed, the reasons for applying this clear rule as to entry of counsel for purposes of the constitutional right to counsel …, apply with equal force to the more limited Gursey right. People v Lucifero, 2017 NY Slip Op 00190, 2nd Dept 1-11-17

 

CRIMINAL LAW (BLOOD ALCOHOL TEST, DWI, NO PROOF DEFENDANT WAS DEPRIVED OF HIS LIMITED RIGHT TO SPEAK TO COUNSEL BEFORE TAKING BLOOD-ALCOHOL TEST, SUPPRESSION SHOULD NOT HAVE BEEN GRANTED, APPLICABLE LAW EXPLAINED)/DRIVING WHILE INTOXICATED (NO PROOF DEFENDANT WAS DEPRIVED OF HIS LIMITED RIGHT TO SPEAK TO COUNSEL BEFORE TAKING BLOOD-ALCOHOL TEST, SUPPRESSION SHOULD NOT HAVE BEEN GRANTED, APPLICABLE LAW EXPLAINED)/ATTORNEYS (BLOOD ALCOHOL TEST, DWI, NO PROOF DEFENDANT WAS DEPRIVED OF HIS LIMITED RIGHT TO SPEAK TO COUNSEL BEFORE TAKING BLOOD-ALCOHOL TEST, SUPPRESSION SHOULD NOT HAVE BEEN GRANTED, APPLICABLE LAW EXPLAINED)/RIGHT TO COUNSEL (BLOOD ALCOHOL TEST, DWI, NO PROOF DEFENDANT WAS DEPRIVED OF HIS LIMITED RIGHT TO SPEAK TO COUNSEL BEFORE TAKING BLOOD-ALCOHOL TEST, SUPPRESSION SHOULD NOT HAVE BEEN GRANTED, APPLICABLE LAW EXPLAINED)/BLOOD ALCOHOL TEST (DWI, (BLOOD ALCOHOL TEST, DWI, NO PROOF DEFENDANT WAS DEPRIVED OF HIS LIMITED RIGHT TO SPEAK TO COUNSEL BEFORE TAKING BLOOD-ALCOHOL TEST, SUPPRESSION SHOULD NOT HAVE BEEN GRANTED, APPLICABLE LAW EXPLAINED)/SUPPRESS, MOTION TO (BLOOD ALCOHOL TEST, DWI, NO PROOF DEFENDANT WAS DEPRIVED OF HIS LIMITED RIGHT TO SPEAK TO COUNSEL BEFORE TAKING BLOOD-ALCOHOL TEST, SUPPRESSION SHOULD NOT HAVE BEEN GRANTED, APPLICABLE LAW EXPLAINED)

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DEFENDANT NOT ENTITLED TO JURY TRIAL ON MISDEMEANORS, DESPITE POSSIBLE DEPORTATION UPON CONVICTION.

The First Department determined defendant was not entitled to a jury trial on misdemeanor charges, even though conviction might result in deportation:

… “[A] defendant’s right to a jury trial attaches only to serious offenses, not to petty crimes, the determining factor being length of exposure to incarceration” … . “An offense carrying a maximum prison term of six months or less is presumed petty, unless the legislature has authorized additiona… l statutory penalties so severe as to indicate that the legislature considered the offense serious” … . Despite the gravity of the impact of deportation on a convicted defendant (see Padilla v Kentucky, 559 US 356 [2010]), deportation consequences are still collateral ,,, , and do not render an otherwise petty offense “serious” for jury trial purposes.

Furthermore, under defendant’s approach, in order to decide whether to grant a jury trial to a noncitizen charged with B misdemeanors, the court would need to analyze the immigration consequences of a particular conviction on the particular defendant, and we find this to be highly impracticable. We note that the immigration impact of this defendant’s conviction is unclear. He is already deportable as an undocumented alien, and only claims that the conviction would block any hypothetical effort to legalize his status. People v Suazo,  1st Dept 1-3-172017 NY Slip Op 00030

CRIMINAL LAW (DEFENDANT NOT ENTITLED TO JURY TRIAL ON MISDEMEANORS, DESPITE POSSIBLE DEPORTATION UPON CONVICTION)/DEPORTATION (CRIMINAL LAW, DEFENDANT NOT ENTITLED TO JURY TRIAL ON MISDEMEANORS, DESPITE POSSIBLE DEPORTATION UPON CONVICTION)/JURY TRIALS (CRIMINAL LAW, DEFENDANT NOT ENTITLED TO JURY TRIAL ON MISDEMEANORS, DESPITE POSSIBLE DEPORTATION UPON CONVICTION)

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TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA.

The Third Department, reversing defendant’s conviction, determined the motion to suppress drugs seized from defendant’s car should have been granted. The deputy stopped defendant’s car based solely on a temporary inspection sticker without any suspicion of criminal behavior. The court noted that the denial of the suppression motion was appealable because defendant did not waive his right to appeal, and the harmless error standard applied because defendant pled guilty after the motion was denied:

The deputy candidly admitted that he had no idea whether the sticker was valid when he made the stop, nor did he indicate that the temporary sticker gave him any other reason for suspicion. He instead stated that his “general practice” was to stop any vehicle he encountered with a temporary inspection sticker in order to “ensure [that the sticker had] not expired.” It is entirely proper to operate a motor vehicle with a temporary inspection sticker under certain circumstances and, as a result, the display of one does not constitute grounds for a traffic stop absent a “specific articulable basis” to believe that illegality is afoot … . The practice of stopping any vehicle with a temporary inspection sticker, without more, represents impermissible “idle curiosity” as to the sticker’s validity rather than the “reasonable suspicion” of illegality needed to effect a traffic stop … . People v Driscoll, 2016 NY Slip Op 08902, 3rd Dept 12-29-16

CRIMINAL LAW (TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/SUPPRESS, MOTION TO (TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/STREET STOPS (TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/SEARCH AND SEIZURE (TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/APPEALS (CRIMINAL, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/EVIDENCE (CRIMINAL LAW, TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)

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DEFENDANT’S STATEMENT DURING THE PLEA COLLOQUY THAT HE HAD NO MEMORY OF COMMITTING THE CRIME DUE TO DRUG USE REQUIRED FURTHER INQUIRY BY THE COURT, GUILTY PLEA SHOULD NOT HAVE BEEN ACCEPTED, NARROW EXCEPTION TO PRESERVATION REQUIREMENT APPLIED.

The Third Department determined defendant’s guilty plea to attempted robbery should not have been accepted by County Court. The error, although unpreserved, can properly be considered on appeal because defendant’s statement during the plea colloquy (that he had no recollection of committing the crime due to his drug use) raised the question whether he could have formed the intent to forcibly steal property:

Defendant’s sole contention is that his guilty plea was not knowing, voluntary and intelligent. Preliminarily, we note that, inasmuch as defendant failed to make an appropriate postallocution motion, this claim is unpreserved for our review … . Nevertheless, we find that the narrow exception to the preservation rule is applicable because defendant’s statement during the plea colloquy that he had no recollection of committing the crime due to drug use raises the unaddressed question of his ability to form the intent to forcibly steal property, an essential element of the crime of attempted robbery … . Under these circumstances, defendant’s statement “casts significant doubt upon [his] guilt or otherwise calls into question the voluntariness of the plea,” such that County Court was required to conduct a further inquiry to ensure that defendant’s guilty plea was knowing and voluntary … . People v Laflower, 2016 NY Slip Op 08899, 3rd Dept 12-29-16

CRIMINAL LAW (DEFENDANT’S STATEMENT DURING THE PLEA COLLOQUY THAT HE HAD NO MEMORY OF COMMITTING THE CRIME DUE TO DRUG USE REQUIRED FURTHER INQUIRY BY THE COURT, GUILTY PLEA SHOULD NOT HAVE BEEN ACCEPTED, NARROW EXCEPTION TO PRESERVATION REQUIREMENT APPLIED)/APPEALS (CRIMINAL LAW, DEFENDANT’S STATEMENT DURING THE PLEA COLLOQUY THAT HE HAD NO MEMORY OF COMMITTING THE CRIME DUE TO DRUG USE REQUIRED FURTHER INQUIRY BY THE COURT, GUILTY PLEA SHOULD NOT HAVE BEEN ACCEPTED, NARROW EXCEPTION TO PRESERVATION REQUIREMENT APPLIED)/GUILTY PLEAS (DEFENDANT’S STATEMENT DURING THE PLEA COLLOQUY THAT HE HAD NO MEMORY OF COMMITTING THE CRIME DUE TO DRUG USE REQUIRED FURTHER INQUIRY BY THE COURT, GUILTY PLEA SHOULD NOT HAVE BEEN ACCEPTED, NARROW EXCEPTION TO PRESERVATION REQUIREMENT APPLIED)

FOR CAUSE CHALLENGE SHOULD HAVE BEEN GRANTED, JUROR WAS A LONG-TERM FRIEND OF AN INVESTIGATOR WORKING ON DEFENDANT’S CASE.

The Third Department, reversing defendant’s conviction, determined defendant’s for cause challenge to a juror, who had been friends for 30 years with an investigator working on defendant’s case, should have been granted, despite the juror’s assurance he could be fair:

The juror’s mere status as a law enforcement officer, without more, would not necessarily have required his disqualification, nor would any relationship with a member of the District Attorney’s staff that was “little more than a nodding acquaintance” … . However, the juror described the investigator as a “friend,” and said that their social relationship had endured for more than 30 years and was sufficiently close to include the juror’s wife. While the juror did not specifically describe the recency or frequency of his contacts with this investigator, nothing in his description of their relationship suggested any recent lessening in the strength of this longstanding connection. Further, the investigator in question was working on defendant’s case, had already appeared in the courtroom by the time the juror was questioned and, according to the prosecutor, might continue to be present during the trial. People v Montford, 2016 NY Slip Op 08901, 3rd Dept 12-29-16

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VIOLATION OF SANDOVAL RULING REQUIRED A NEW TRIAL, DEFENDANT DID NOT OPEN THE DOOR TO THE IMPROPER QUESTIONS.

The Second Department determined the prosecutor’s violation of the Sandoval ruling required reversal. Defendant was charged with attempted burglary. The court ruled the defendant could be cross-examined about petit larceny and burglary convictions, but only to the extent he could be question about unspecified misdemeanor and felony convictions. When defendant testified he was repeatedly asked whether he had ever walked into a building which was closed to the public. The Second Department held that defendant had not opened the door to that line of questioning:

On cross-examination, the defendant testified that there were times in the past when he had been intoxicated and “ended up in the bushes” or “in the park” and that it was possible for a drunk person to end up in someone’s backyard. The prosecutor questioned the defendant as to other places he had been in the past, specifically asking if he had ever “enter[ed] a building that [he] had no permission to go?” The defendant initially denied entering a building, but after further questioning, which the Supreme Court allowed over defense counsel’s objection, he admitted that he had walked into a store that was closed but had people in it. The prosecutor pressed further, and later asked the defendant, “Have you ever walked into a building that was completely closed to the public with no people inside of that building?” and the defendant responded, “I don’t recall.” The prosecutor then asked if he had been convicted of a felony and the defendant replied affirmatively. The record reflects more than a half a dozen occasions when the People clearly violated the court’s Sandoval ruling by repeatedly questioning the defendant concerning the underlying facts of his prior burglary conviction.

Defendants who take the witness stand, like other witnesses, place their credibility in issue and, thus, may be cross-examined about past criminal or immoral acts relevant to their credibility … . The policy underlying Sandoval is that the accused has the right to make an informed choice concerning whether he or she should take the witness stand … . Thus, in the interest of fairness, a trial court’s authority to change its Sandoval ruling is limited once the defendant has decided to testify in good-faith reliance on the court’s pretrial ruling … . The defendant in this case was denied that right when, after making what he believed to be an informed judgment and taking the witness stand, the Supreme Court implicitly changed the ruling upon which he relied by allowing the prosecutor to continue her course of prejudicial questioning despite repeated objections from defense counsel. The court’s implicit change in its ruling after the defendant had already taken the witness stand deprived the defendant of a fair trial … . People v Mohamed, 2016 NY Slip Op 08885, 2nd Dept 12-28-16

 

CRIMINAL LAW (VIOLATION OF SANDOVAL RULING REQUIRED A NEW TRIAL, DEFENDANT DID NOT OPEN THE DOOR TO THE IMPROPER QUESTIONS)/EVIDENCE (CRIMINAL LAW, VIOLATION OF SANDOVAL RULING REQUIRED A NEW TRIAL, DEFENDANT DID NOT OPEN THE DOOR TO THE IMPROPER QUESTIONS)/SANDOVAL RULING (VIOLATION OF SANDOVAL RULING REQUIRED A NEW TRIAL, DEFENDANT DID NOT OPEN THE DOOR TO THE IMPROPER QUESTIONS)/CROSS-EXAMINATION (CRIMINAL LAW, VIOLATION OF SANDOVAL RULING REQUIRED A NEW TRIAL, DEFENDANT DID NOT OPEN THE DOOR TO THE IMPROPER QUESTIONS)

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