IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF IOWA

EASTERN DIVISION


UNITED STATES OF AMERICA,                  )

                                                                      )

           Plaintiff,                                              )          No. CR 02-2030

                                                                      )

                       vs.                                          )          

                                                                      )  

EDDIE LOUIS DENTON, JR.,                       )          FINAL JURY INSTRUCTIONS

                                                                      ) 

           Defendant.                                         )          


 

 

 

 

      

 

 

          Members of the Jury: The instructions I gave you at the beginning of the trial and during the trial remain in effect. I will now give you some additional instructions.

           You must, of course, continue to follow the instructions I gave you earlier, as well as those I give you now. You must not single out some instructions and ignore others, because all are important. This is true even though some of those I gave you at the beginning of and during trial are not repeated here.

          The instructions I am about to give you now are in writing and will be available to you in the jury room. I emphasize, however, that this does not mean they are more important than my earlier instructions. Again, all instructions, whenever given and whether in writing or not, must be followed.

 

 

 

 

INSTRUCTION NO.

          In considering these instructions, attach no importance or significance whatsoever to the order in which they are given.

 

 

 

 

 

 

 

 

 

 

 

 

 

 











INSTRUCTION NO.


          Neither in these instructions nor in any ruling, action, or remark that I have made during this trial have I intended to give any opinion or suggestion as to what the facts are or what your verdict should be.

 

 

 

 

 

 

 

 

 

 

 

 

 












INSTRUCTION NO.____

          It is your duty to find from the evidence what the facts are. You will then apply the law, as I give it to you, to those facts. You must follow my instructions on the law, even if you thought the law was different or should be different.

          Do not allow sympathy or prejudice to influence you. The law demands of you a just verdict, unaffected by anything except the evidence, your common sense, and the law as I give it to you.




























INSTRUCTION NO.____

          I have mentioned the word "evidence." The "evidence" in this case consists of the following: the testimony of the witnesses; the documents and other things received as exhibits and the facts that have been stipulated.

           You may use reason and common sense to draw deductions or conclusions from facts which have been established by the evidence in the case.

          Certain things are not evidence. I shall list those things again for you now:

          1. Statements, arguments, questions, and comments by the lawyers are not evidence.
         2. Objections are not evidence. The parties have a right to object when they believe something is improper. You should not be influenced by the objection. If I sustained an objection to a question, you must ignore the question and must not try to guess what the answer might have been.
         3. Testimony that I struck from the record, or told you to disregard, is not evidence and must not be considered.

          4. Anything you saw or heard about this case outside the courtroom is not evidence.

          You will be instructed that some evidence was received for a limited purpose only, and you must follow those instructions.


INSTRUCTION NO. ______

 

          Exhibits have been admitted into evidence and are to be considered along with all the other evidence to assist you in reaching a verdict. You are not to tamper with the exhibits or their contents, and each exhibit should be returned into open court, along with your verdict, in the same condition as it was received by you.


INSTRUCTION NO.


          There are two types of evidence from which a jury may properly find the truth as to the facts of a case: direct evidence and circumstantial evidence. Direct evidence is the evidence of the witness to a fact or facts of which they have knowledge by means of their senses. The other is circumstantial evidence – the proof of a chain of circumstances pointing to the existence or nonexistence of certain facts.

          The law makes no distinction between direct and circumstantial evidence. You should give all evidence the weight and value you believe it is entitled to receive.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

INSTRUCTION NO. _____

          You have heard testimony that defendant Eddie Denton, Jr. made statements to law enforcement. It is for you to decide:

          First, whether Eddie Denton, Jr. made the statements, and

          Second, if so, how much weight you should give to them.

          In making these two decisions you should consider all of the evidence, including the circumstances under which the statement may have been made.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

INSTRUCTION NO. _____

          You have heard evidence that the defendant was previously convicted of a crime. You may use that evidence only to help you decide whether to believe his testimony and how much weight to give it. That evidence does not mean that he committed the crime charged here, and you must not use that evidence as any proof of the crime charged in this case.


INSTRUCTION NO.

          You have heard evidence that certain witnesses have pleaded guilty to a crime which arose out of the same events for which the defendant is on trial here. You must not consider those guilty pleas as any evidence of this defendant’s guilt. You may consider the guilty pleas of those witnesses only for the purpose of determining how much, if at all, to rely upon the testimony of those witnesses.


INSTRUCTION NO. _____

          The jurors are the sole judges of the weight and credibility of the testimony and the value to be given to each witness who has testified in this case. In deciding what the facts are, you may have to decide what testimony you believe and what testimony you do not believe. You may believe all of what a witness said, or only part of it, or none of it.

          In deciding what testimony to believe, consider the witness' intelligence, the opportunity the witness had to have seen or heard the things testified about, the witness' memory, any motives that witness may have for testifying a certain way, the manner of the witness while testifying, whether that witness said something different at an earlier time, the general reasonableness of the testimony, and the extent to which the testimony is consistent with any evidence that you believe.

          In deciding whether or not to believe a witness, keep in mind that people sometimes hear or see things differently and sometimes forget things. You need to consider, therefore, whether a contradiction is an innocent misrecollection or lapse of memory or an intentional falsehood, and that may depend on whether it has to do with an important fact or only a small detail.


INSTRUCTION NO.

          In the previous instruction, I instructed you generally on the credibility of witnesses. I now give you this further instruction on how the credibility of a witness can be “impeached” and how you are to consider the testimony of certain witnesses.

          A witness may be discredited or impeached by contradictory evidence; by a showing that the witness testified falsely concerning a material matter; by showing the witness has a motive to be untruthful; or by evidence that at some other time the witness has said or done something, or has failed to say or do something, that is inconsistent with the witness’ present testimony.

          You have heard evidence that certain witnesses have been convicted of crimes. A conviction of a crime is a factor you may consider in deciding whether to believe a witness and how much weight to give their testimony.

          You have heard that certain witnesses may receive benefits from the government in connection with their testimony and information in this case. When an informant is testifying for personal gain or advantage rather than for an independent law enforcement purpose, you may consider whether the witness is biased and whether his testimony is reliable. You may give testimony such weight as you feel it deserves. Whether or not the witness’ testimony may have been influenced by the benefit sought is for you to decide.

(CONTINUED)

 

 

INSTRUCTION NO. (Cont’d.)

          You have heard evidence that certain witnesses could receive a reduced sentence on criminal charges pending against the witness in return for the witness’ cooperation with the prosecution in this case. The witnesses have entered into “plea agreements” with the U.S. Attorney’s Office that provide that if the witness gives substantial assistance to the government in its investigation of federal crimes, the prosecutor could file a motion for a reduction of his or her sentence. Some of the witnesses are subject to a mandatory minimum sentence, that is, a sentence that the law provides must be of certain minimum length. The prosecutor can file in the court in which the charges are pending against the witness a motion to reduce his or her sentence below the statutory minimum and the applicable federal sentencing guideline range. The judge has no power to reduce a sentence unless the prosecutor files such a motion. If such a motion for reduction of sentence for substantial assistance is filed by the prosecutor, then it is up to the judge to decide whether to reduce the sentence at

 all, and if so, how much to reduce it. You may give the testimony of the witness such weight as you think it deserves. Whether or not the testimony of the witness may have been influenced by his hope of receiving a reduced sentence is for you to decide.


INSTRUCTION NO. ______

          The Indictment in this case consists of one charged offense:

          Count 1 charges that from at least early 1996 and continuing through at least December 2001, EDDIE LOUIS DENTON, JR., did knowingly and unlawfully combine, conspire, confederate and agree with other persons known and unknown to the Grand Jury to commit five separate offenses against the United States:

          1.       Distribution of 50 grams or more of a mixture or substance containing a detectable amount of cocaine base, commonly called “crack cocaine,” a Schedule II controlled substance;

          2.       Distribution of 500 grams or more of a mixture or substance containing a detectable amount of cocaine, a Schedule II controlled substance;

          3.       Distribution of a mixture or substance containing a detectable amount of marijuana, a Schedule II controlled substance;

          4.       Distribution of cocaine base, commonly called “crack cocaine,” a Schedule II controlled substance, within 1,000 feet of the real property comprising a playground, that is, Sullivan Park, located at East 4th Street and Ankeny Street in Waterloo, Iowa; and/or

          5.       Distribution of cocaine base, commonly called “crack cocaine,” a Schedule II controlled substance, at 220 Lewis Street, Waterloo, Iowa (a/k/a “Soulville;” a/k/a “The House on the Hill;” a/k/a “The Hill”), which is within 1,000 feet of a playground, that is, Highland Park, located between the 1100 and 1400 blocks of Vine Street in Waterloo, Iowa.

          

 

 

(CONTINUED)

 

 

 

INSTRUCTION NO. _____(Contd.)


          The defendant has pleaded not guilty to the crime with which he is charged.

          As I told you at the beginning of the trial, an Indictment is simply an accusation. It is not evidence of anything. To the contrary, the defendant is presumed to be innocent. Thus the defendant, even though charged, begins the trial with no evidence against him. The presumption of innocence alone is sufficient to find the defendant not guilty and can be overcome only if the government proves, beyond a reasonable doubt, each essential element of the crime charged.


INSTRUCTION NUMBER _____

          A reasonable doubt is a doubt based upon reason and common sense, and not the mere possibility of innocence. A reasonable doubt is the kind of doubt that would make a reasonable person hesitate to act. Proof beyond a reasonable doubt, therefore, must be proof of such a convincing character that a reasonable person would not hesitate to rely and act upon it. However, proof beyond a reasonable doubt does not mean proof beyond all possible doubt.


INSTRUCTION NO. ______

          The crime of conspiracy as charged in the Indictment has three essential elements which are:

One, that between about early 1996 and December 2001, two or more persons reached an agreement or came to an understanding to (1) distribute cocaine base (commonly called “crack cocaine”); (2) distribute cocaine; (3) distribute marijuana; (4) distribute cocaine base (commonly called “crack cocaine”) within 1,000 feet of Sullivan Park, a playground; and (5) distribute cocaine base (commonly called “crack cocaine”) within 1,000 feet of Highland Park, a playground;

 

Two, the defendant voluntarily joined in the agreement or understanding, either at the time the agreement or understanding was first reached, or at some later time while the agreement or understanding was still in effect; and

 

Three, that at the time the defendant joined in the agreement or understanding, he knew the purpose of the agreement or understanding.

 

          For you to find the defendant guilty of conspiracy, the United States must prove all of these essential elements beyond a reasonable doubt; otherwise, you must find the defendant not guilty under Count 1.

          To assist you in deciding whether there was an agreement or understanding to commit the crime of distributing a controlled substance, you are advised that the elements of this crime are set out in Instruction Number ____. To assist you in deciding whether there was an agreement or understanding to commit the crime of distribution of cocaine base (commonly called “crack cocaine”) within 1,000 feet of a playground, you

(CONTINUED)

 

INSTRUCTION NO. ______ (Contd.)

are advised that the elements of that crime are also set forth in Instruction Number ___.

However, keep in mind that Count 1 of the Indictment charges a conspiracy to commit the charged offenses and does not require the government to prove that the crime of

distribution of cocaine base, cocaine or marijuana, or the distribution of cocaine base within 1,000 feet of a playground was actually committed.

          Also keep in mind that the Indictment charges that the conspiracy involved in Count 1 had five objectives, that is that the defendant conspired to commit five separate crimes or offenses: (1) distribution of cocaine base (commonly called “crack cocaine”); (2) distribution of cocaine; (3) distribution of marijuana; (4) distribution of cocaine base (commonly called “crack cocaine”) within 1,000 feet of Sullivan Park, a playground; and (5) distribution of cocaine base (commonly called “crack cocaine”) within 1,000 feet of Highland Park, a playground. You are instructed that, under Count 1, it is not necessary for the government to prove a conspiracy to commit all five offenses. It would be sufficient if the government proves, beyond a reasonable doubt, a conspiracy to commit any one of the offenses. However, in that event, in order to return a verdict of guilty, you must unanimously agree upon which one or more of the offenses was the object of the conspiracy.



INSTRUCTION NO. _____

          In considering whether the government has met its burden of proving conspiracy as alleged in Count 1 of the Indictment, you are further instructed as follows:

          The government must prove that the defendant reached an agreement or understanding with at least one other person. It makes no difference whether that person is named in the Indictment.

          The “agreement or understanding” need not be an express or formal agreement or be in writing or cover all the details of how it is to be carried out. Nor is it necessary that the members have directly stated between themselves the details or purpose of the scheme.

          You should understand that merely being present at the scene of an event, or merely acting in the same way as others, or merely associating with others does not prove that a person has joined in an agreement or understanding. A person who has no knowledge of a conspiracy but who happens to act in a way which advances some purpose of one, does not thereby become a member.

          But a person may join in an agreement or understanding, as required by this element, without knowing all the details of the agreement or understanding, and without knowing who all the other members are. Further, it is not necessary that a person agree to play any particular part in carrying out the agreement or understanding. A person may become a member of a conspiracy even if that person agrees to play only

 

(CONTINUED)

INSTRUCTION NUMBER _____(Contd.)

a minor part in the conspiracy, as long as that person had an understanding of the unlawful nature of the plan and voluntarily and intentionally joins in it.

          In determining whether the alleged conspiracy existed, you may consider the actions and statements of all the alleged participants. The agreement may be inferred from all the circumstances and the conduct of the alleged participants. In determining whether the defendant became a member of the conspiracy you may consider only the acts and statements of the defendant.

          If you have found beyond a reasonable doubt that a conspiracy existed and that the defendant was one of its members, then you may consider the acts knowingly done and statements knowingly made by the defendant’s co-conspirators during the existence of the conspiracy and in furtherance of it as evidence pertaining to the defendant even though they were done or made in the abscence of and without the knowledge of the defendant. This includes acts done or statements made before the defendant joined the conspiracy, for a person who knowingly, voluntarily, and intentionally joins an existing conspiracy is responsible for all of the conduct of the co-conspirators from the beginning of the conspiracy.


AMENDED AND SUBSTITUTED INSTRUCTION NO.______

          The crime of distributing a controlled substance, charged as the first three objectives of the conspiracy under Count 1, has two essential elements, which are:

          One:   a person intentionally transferred a controlled substance to another person; and

 

Two:at the time of the transfer, the person transferring the controlled substance knew that it was a controlled substance.


          The crime of distributing cocaine base (commonly called “crack cocaine”) within 1,000 feet of a playground, charged as the fourth and fifth objectives of the conspiracy under Count 1 has three essential elements which are:

          One,             a person intentionally transferred cocaine base (commonly called “crack cocaine”);

 

          Two,             at the time of the transfer, the person transferring the controlled substance knew it was cocaine base (commonly called “crack cocaine”); and

 

          Three,           the transfer took place within 1,000 feet of the real property comprising a playground.


          A “playground” is defined as any outdoor facility, including any adjacent parking lot, intended for recreation, open to the public, and with any portion thereof containing

three or more separate apparatus intended for the recreation of children including, but not limited to, sliding boards, swingsets, and teeterboards. Children do not need to be near or around the playground at the time of the offense for the property to be a “playground”. The “playground” in question here is alleged to be Sullivan Park in Waterloo, Iowa, in the fourth objective of the conspiracy and Highland Park in Waterloo,

(Continued)

INSTRUCTION NO.______ (Contd.)

Iowa, in the fifth objective of the conspiracy. It is for you to determine whether Sullivan Park and/or Highland Park fits the definition of a “playground”.

          You must also decide whether the location at which the distribution of a controlled substance was to take or took place was within 1,000 feet of the “playground”. The 1,000 foot zone can be measured in a straight line from the “playground”, irrespective of actual pedestrian travel routes.

          The prosecution does not have to prove that the co-conspirators, or the defendant, agreed, knew, or intended that the distribution would take place within 1,000 feet of the “playground”. However, the prosecution must prove beyond a reasonable doubt that a location at which the co-conspirators agreed that the distribution would take place or did take place was within 1,000 feet of a “playground”.

          Evidence that distribution of a controlled substance pursuant to the conspiracy actually occurred at a location within 1,000 feet of a “playground” is evidence from which you may, but are not required to, find that a location at which the co-conspirators agreed that a distribution would take place was within 1,000 feet of a “playground”.

          The term “distribute” means to deliver a controlled substance to the possession of another person. The term “deliver” means the actual or attempted transfer of a controlled substance to the possession of another person. It is not necessary that money or anything of value change hands. The law prohibits the “distribution” of a controlled substance; the prosecution does not have to prove that there was, or was

intended to be, a sale of a controlled substance to prove a conspiracy to distribute a controlled substance.

INSTRUCTION NO. _____


          You are instructed as a matter of law that cocaine base (commonly called “crack cocaine”) and cocaine are Schedule II controlled substances. You are instructed as a matter of law that marijuana is a Schedule I controlled substance. You must ascertain whether or not the substance in question was cocaine base, cocaine, or marijuana. In so doing, you may consider all evidence in the case which may aid in the determination of that issue.

          In determining whether the defendant is guilty of conspiring to distribute cocaine base, conspiring to distribute cocaine, conspiring to distribute marijuana, and/or conspiring to distribute cocaine base within 1,000 feet of a playground, the government is not required to prove that the amount or quantity of the controlled substance was as charged in the Indictment. The United States need only prove beyond a reasonable doubt that there was a measurable amount of the controlled substance.

          If you find the defendant guilty of conspiring to distribute cocaine base or conspiring to distribute cocaine, you are being asked to make a quantity determination as explained in Instruction No. ____. You will make the quantity determination only if you find the defendant guilty of crime of conspiring to distribute cocaine base (commonly called “crack cocaine”) or conspiring to distribute cocaine.

 

 

 

 

 

INSTRUCTION NO. _____

 

          As to the first object of Count 1, the government need only prove that the offense involved a detectable amount of cocaine base (commonly called “crack cocaine”) in order for you to find the defendant guilty, provided you have found all the elements beyond a reasonable doubt. Similarly, as to the second object of Count 1, the government need only prove that the offense involved a detectable amount of cocaine in order for you to find the defendant guilty, provided you have found all the elements beyond a reasonable doubt.

          If you find the defendant guilty beyond a reasonable doubt under either the first or second objects of Count 1, you will then be asked to determine whether the government has proven the amount of cocaine base or cocaine involved in that particular object beyond a reasonable doubt and you will be asked to determine the amount of cocaine base (commonly called “crack cocaine”) or cocaine involved in that object of the conspiracy.

          For your information, one ounce equals 28.35 grams, and one pound equals 453.6 grams and one kilogram contains 1,000 grams.


INSTRUCTION NO. _____

 

          You will note that the Indictment charges that the offenses were committed “on or about” or “between about” certain dates. The government need not prove with certainty the exact date or the exact time period of an offense charged. It is sufficient if the evidence established that an offense occurred within a reasonable time of the date or period of time alleged in the Indictment.


INSTRUCTION NO. ______

 

          An act is done “knowingly” if the defendant realized what he was doing and did not act through ignorance, mistake or accident. The government is not required to prove that the defendant knew that his acts or omissions were unlawful. You may consider the evidence of the defendant’s acts and words, along with all other evidence, in deciding whether the defendant acted knowingly.

 


INSTRUCTION NO. ______

 

          Intent may be proven by circumstantial evidence. It rarely can be established by other means. While witnesses may see or hear and thus be able to give direct evidence of what a person does or fails to do, there can be no eyewitness account of the state of mind with which the acts were done or omitted. But what a defendant does or fails to do may indicate intent or lack of intent to commit an offense.

          You may consider it reasonable to draw the inference and find that a person intends the natural and probable consequences of acts knowingly done, but you are not required to do so. As I have said, it is entirely up to you to decide what facts to find from the evidence.

 

 

 

 

 

 

 

 











INSTRUCTION NO.______


          Throughout the trial, you have been permitted to take notes. Your notes should be used only as memory aids, and you should not give your notes precedence over your independent recollection of the evidence.

          In any conflict between your notes, a fellow juror’s notes, and your memory, your memory must prevail. Remember that notes sometimes contain the mental impressions of the note taker and can be used only to help you recollect what the testimony was. At the conclusion of your deliberations, your notes should be delivered to the court security officer for destruction.

 

 

 

 

 

 

 

 

 










INSTRUCTION NO. _____


          In conducting your deliberations and returning your verdict, there are certain rules you must follow. I shall list those rules for you now.

          First, when you go to the jury room, you must select one of your members as your foreperson. That person will preside over your discussions and speak for you here in court.

          Second, it is your duty, as jurors, to discuss this case with one another in the jury room. You should try to reach agreement if you can do so without violence to individual judgment, because a verdict - whether guilty or not guilty - must be unanimous.

          Each of you must make your own conscientious decision, but only after you have considered all the evidence, discussed it fully with your fellow jurors, and listened to the views of your fellow jurors.

          Do not be afraid to change your opinions if the discussion persuades you that you should. But do not come to a decision simply because other jurors think it is right, or simply to reach a verdict.

           Third, if the defendant is found guilty, the sentence to be imposed is my responsibility. You may not consider punishment in any way in deciding whether the government has proved its case beyond a reasonable doubt.

  

 

 

(CONTINUED)

 

INSTRUCTION NO. _____ (Contd.)

          Fourth, if you need to communicate with me during your deliberations, you may send a note to me through the marshal or court security officer, signed by one or more jurors. I will respond as soon as possible either in writing or orally in open court.

Remember that you should not tell anyone--including me--how your votes stand numerically.

          Fifth, your verdict must be based solely on the evidence and on the law which I have given to you in my instructions. The verdict, whether guilty or not guilty, must be unanimous. Nothing I have said or done is intended to suggest what your verdict should be - that is entirely for you to decide.
          Finally, the verdict form is simply the written notice of the decision that you reach in this case. Your foreperson will fill in the form, sign and date it, and advise the marshal or court security officer that you are ready to return to the courtroom.

 

 

 

 


 

 

 

 

 

INSTRUCTION NO. _____

          Attached to these instructions you will find a Verdict Form. The Verdict Form is simply the written notice of the decision that you reach in this case. The answers to the Verdict Form must be the unanimous decision of the jury.

          You will take this form to the jury room, and when you have completed your deliberations and each of you has agreed on the verdict, your foreperson will fill out the form, sign and date it, and advise the marshal or court security officer that you are ready to return to the courtroom.

          Finally, members of the jury, take this case and give it your most careful consideration, and then without fear or favor, prejudice or bias of any kind, return such verdict as accords with the evidence and these instructions.

 

 




















IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF IOWA

EASTERN DIVISION


UNITED STATES OF AMERICA,


                     Plaintiff,


          vs.


EDDIE LOUIS DENTON, JR.


                     Defendant.


)

)

)

)

)

)

)

)

)

)




No. CR 02-2030



VERDICT FORM







COUNT 1


          We, the Jury, find the defendant, EDDIE LOUIS DENTON, JR., _____________                                                                                                    guilty/not guilty

of Count 1.


          If the verdict for Count 1 is GUILTY as to EDDIE LOUIS DENTON, JR., please indicate which object(s) the conspiracy involved by placing a check mark on the line before the object or objects that has/have been proven beyond a reasonable doubt.


          1.        Distribution of cocaine base (commonly called “crack cocaine”)


          2.        Distribution of cocaine


          3.        Distribution of marijuana

 

          4.        Distribution of cocaine base (commonly called “crack cocaine”)

within 1,000 feet of Sullivan Park, a playground

 

          5.        Distribution of cocaine base (commonly called “crack cocaine”)

within 1,000 feet of Highland Park, a playground




DRUG QUANTITY DETERMINATION- Count 1


          If you found defendant EDDIE LOUIS DENTON, JR. guilty of either conspiring to distribute cocaine base (commonly called “crack cocaine”) (Count 1) or conspiring to distribute cocaine (Count 2), please indicate what quantity of cocaine base or cocaine you found was involved in the offense by placing a check mark on the line before the amounts you find have been proven beyond a reasonable doubt.


A.       Drug Quantity Determination - Object One (distribution of cocaine base           “crack”)

 

          ______         50 grams or more of a mixture or substance containing a detectable amount of cocaine base (commonly called “crack cocaine”)

 

          ______         at least 5 grams, but less than 50 grams, of a mixture or substance containing a detectable amount of cocaine base (commonly called “crack cocaine”)

 

          ______         less than 5 grams of a mixture or substance containing a detectable amount of cocaine base (commonly called “crack cocaine”)


B.       Drug Quantity Determination - Object Two (distribution of cocaine)

 

          ______         500 grams or more of a mixture or substance containing a detectable amount of cocaine

 

          ______         less than 500 grams of a mixture or substance containing a detectable amount of cocaine




                                                                                                                          

                                                                FOREPERSON

                                                                ______________________________

                                                                DATE