Category Archives: Protest

Crime Won’t Decrease, Until Oppression Decreases

St. Louis has the highest murder rate in the country. Unfortunately, it seemed as long as murders were only being committed within certain neighborhoods, no one outside the community really cared. Once murders and shootings began occurring in the Central West End, Downtown and other areas a crisis was declared. The speed in which suspects were found when the victim was white, was amazing and reflects an urgency disparity.

Greater concern, effort, and resources are expended when the victim is white. The media uses a different vocabulary to describe white victims and seldom are drugs or illegal activity mentioned. When a black shooting victim states they don't know why they were targeted, their integrity is questioned along with the possibility of the incident being drug or gang related. White victims appear to be instantly believed, even when their stories seem bazaar.

I am fifty years old, and during my lifetime, there have been 9,415 murders in St. Louis; an average of 188 per year. Among those victims were my brother-in-law and nephew. I don't know any black family that hasn't been touched directly or indirectly by murder. There was no crisis declared, no end violence initiatives by news channels until multiple white people became victims.

Ironically, some people seem to think that before channel 4's #EndViolenceSTL, that no one was concerned or addressing violence in our community. There have been multiple attempts to raise awareness and end violence, the most notable recent attempt was a Call to Oneness.

Unfortunately, a 16-year-old was killed just hours after the Call to Oneness event.  There was a "Clergy call for citywide prayer to end violence in St. Louis", months before Michael Brown. Until the  root causes of crime are addressed, various forms of oppression, it will continue and we are all at risk to falling victim to it.

War on drugs

The war on drugs was waged almost exclusively against black and brown people. After a new drug crisis was declared when methamphetamine and heroin began affecting white communities, no new drug war was declared. In fact, once large numbers of white kids became addicted to drugs, the country suddenly started to realize that the war on drugs was too harsh and unfair. Instead of calling for incarceration of these new white addicts, medical treatment was prescribed for their "illness".

American Drug War:The Last White Hope (a kevin booth film)

Visit Los Angeles, New York, Chicago or any other major city in the United States and you'll discover a statistical anomaly; each of these cities contains impoverished areas that are overwhelmingly black or brown. Unless you're prepared to say that black and brown people are less ambitious, less intelligent or inferior; you must come to the realization that those groups are artificially held back by institutionalized oppression and discrimination.

The sad reality is that many people  have been conditioned to believe that something is wrong with black and brown people. Unfortunately, some black people even believe this myth. Some have even convinced themselves that because they achieved some measure of success, they are somehow the exception to the rule. They don't seem to understand that when they move into an all-white community or attend white schools, that standard is applied to them and they are considered by those around them as less than. If you indict a group of people and you are a member of that group, you cannot escape the indictment.

Until systemic oppression and inequality ends, including; abusive policing, government policy, inferior education, business practices, media bias, resource distribution, unfair court practices, mass incarceration, and employment discrimination, crime will continue to rise and will spill over into communities that had previously been considered immune or safe.  Increasingly, criminals are beginning to realize it is more profitable to target people with more resources.

“Where justice is denied, where poverty is enforced,  where ignorance prevails, and where any one class is made to feel that society is an organized conspiracy to oppress, rob and degrade them, neither persons nor property will be safe” – Frederick Douglass

Crime and Poverty

Both the United Nations and the World Bank indicate  poverty, oppression, inequality and lack of economic opportunities results in increased criminal activity. When inequalities are great, crime goes through the roof. When people see vast wealth differences, especially if the wealth disparity is based on injustice, crime becomes even worse.

According to the U.S. Census  Bureau, in the United States, there were 46.7 million people in poverty in 2014. The official poverty rate was 14.8 percent. Contrary to some common stereotypes about America’s poor, which included 25,659,922 Whites, 11,197,648 Hispanics, 9,472,583 Blacks, and 1,899,448 Asians; poverty affects all groups.

At least 4.2 million, one-third of the 13 million children living in poverty are white, 27% of Latino children (4 million), 33% of black children (3.6 million), 12% of Asian children (400,000) and 40% of American Indian (200,000). Source National Center for Children in Poverty.

Even Elvis' recognized this when he recorded, "The Ghetto" in 1969. This song is about poverty, describing a child who can't overcome his surroundings and turns to crime, which leads to his death. It was the first song Elvis recorded with a socially-conscious message. He was reluctant to do it for that reason.


Maslow's Hierarchy of Needs Theory

Just about every college student will learn about a motivational theory developed by Abraham Maslow in the 1940's. His theory is taught in a variety of subjects including education, psychology, business management and marketing.

Abraham Maslow's hierarchy of needs theory proposed that motivation is the result of a person's attempt at fulfilling five basic needs: physiological, safety, social, esteem and self-actualization.

Physiological needs are those needs required for human survival such as air, food, water, shelter, clothing and sleep. A person will do just about anything to meet these needs.

Safety needs include those needs that provide a person with a sense of security and well-being. Personal security, financial security, good health and protection from accidents, harm, and their adverse effects are all included in safety needs.

Social needs also called love and belonging, refer to the need to feel a sense of belonging and acceptance. Social needs are important to humans so that they do not feel alone, isolated and depressed. Friendships, family, and intimacy all work to fulfill social needs.

Esteem needs refer to the need for self-esteem and respect, with self-respect being slightly more important than gaining respect and admiration from others.

Self-actualization needs describe a person's need to reach his or her full potential. The need to become what one is capable of is something that is highly personal. While I might have the need to be a good parent, you might have the need to hold an executive-level position within your organization.

I remember watching the Hurricane Katrina news coverage and wondering if the government was purposefully trying to create a Maslow situation to cause people to act on their survival instincts to show images of blacks behaving like animals. How else could the government's lack of aid to such an enormous disaster be described?

The opposite occurred and the people of New Orleans displayed exceptional amounts of humanity towards one another.


Food Stamps

In many countries that do not provide an adequate safety net, kidnapping and other crimes that target well-off citizens are common. What many people do not seem to understand is that social programs such as food stamps, section 8 and others that help people meet basic needs, prevents people from being forced to turn to crime to meet those needs.

Use a simple common sense approach. What would you do if after following all the rules, you could not afford to provide for the basic needs of your family and your children are hungry? If you do not have family or friends who can help; and if there is no outside assistance available, many people would do things they would not have considered doing previously.

The media has demonized the Supplemental Nutrition Assistance Program (SNAP) — formerly known as "food stamps" over the years, often portraying the recipients as lazy, dependent, or unwilling to work.

Most SNAP recipients don’t rely exclusively on the benefits for food – only 22 percent of the program’s 47 million beneficiaries in 2013 had zero gross income. Many recipients have recently lost their jobs, are low wage earners or employed part time. Among those 22 percent with zero gross income are children, elderly, people affected by disasters, injured or too ill to work.

As pointed out in Maslow's Hierarchy of Needs, when a person can't feed themselves or their family, they will do whatever is necessary to fulfill that need.  Oxford University and the Pew Research Center have estimated that half of all job that exists today will be gone within ten years. The irony is that as computerization and robotics displace large numbers of workers; the very people complaining about these benefits today, will be the same ones that the benefits will not available for tomorrow.

Recent profiles of successful individuals illustrate how SNAP helps disadvantaged people achieve success.

Famous People who were on Food Stamps

When Jan Koum sold his company, WhatsApp, to Facebook for $19 billion on February 19, 2014, he signed the paperwork against the front door of the welfare office where his family used to collect food stamps. After the sale of WhatsApp, the Huffington Post profiled a number of prominent people who have had to rely on food stamps, including:

President Barack Obama and his mother Ann Dunham received food stamps when the future president was a baby.

Musician Bruce Springsteen received food stamps during the earlier parts of his career. I have always respected the fact that Springsteen recorded "American Skin (41 Shots)" is a song inspired by the police shooting death of Amadou Diallo.

For those not familiar with Amadou Diallo

Dr. Ben Carson, in his book "Gifted Hands", wrote, “By the time I reached ninth grade, mother had made such strides that she received nothing but food stamps," …"She couldn’t have provided for us and kept up the house without that subsidy.”

Craig T. Nelson who was once helped with food stamps seemed to be making an argument against government assistance for others.

Other notable food stamp recipients

Olympic speed skater Emily Scott was forced to apply for food stamps when her monthly Olympic stipend was cut to just $600.

Viola Davis, Actress – grew up in extreme poverty and stated, "I Have Stolen, Jumped in Garbage Bins With Maggots For Food"

Scarlett Johansson – She stated, “My family grew up relying on public assistance to help provide meals for our family”.

Taraji P. Henson,  – Was on welfare after the tragic death of her husband

Kelly Clarkson – grew up poor living on food stamps.

Oprah Winfrey, – her mother had to rely on welfare to feed her family.

J.K Rowland – “Harry Potter” author argues government assistance helped her survive in her early years.

Whoopi Goldberg – became a mother at 17 and relied on welfare until she was able to do better.

Iyanla Vanzantraised in a family that relied on welfare to get by.

Tobey Maguire "As a kid, I was very poor. I mean, it's all relative, but we would get groceries from neighbors. I always had a roof over my head, but I slept on couches of relatives, and some night we wandered into a shelter. My family had food stamps and government medical insurance.

I've often wondered if we as a society have failed to properly educate and support a child who would have cured cancer.


Five Hour Energy Billionaire Trying to Make a Difference in the lives of the poor

President Obama’s 50th Anniversary ‘Bloody Sunday’ Selma Speech

President Obama delivered a magnificent speech at the 50th aniversary of  'Bloody Sunday' in Selma, Alabama at the Edmond Pettus Bridge. The President mentioned the Ferguson Protest in the same spirit as Selma and discussed the DOJ Ferguson Investigation report.

Rep. John Lewis, D-Ga., John Lewis returned to Selma to speaks at the 50th anniversary of “Bloody Sunday”. 50 years after John Lewis was beaten, he introduced President Obama on the very bridge where he was beaten.


The History of "Bloody Sunday"

The three Selma to Montgomery marches in 1965 were part of the Selma Voting Rights Movement and led to the passage that year of the Voting Rights Act, a landmark federal achievement of the 1960s American Civil Rights Movement. Activists publicized the three protest marches to walk the 54-mile highway from Selma to the Alabama state capital of Montgomery as showing the desire of black American citizens to exercise their constitutional right to vote, in defiance of segregationist repression.

A series of discriminatory requirements and practices disenfranchised most of the millions of African Americans across the South since the turn of the century. The African American group known as The Dallas County Voters League (DCVL) launched a voters registration campaign in Selma in 1963. Joined by organizers from the Student Nonviolent Coordinating Committee (SNCC), they began working that year in a renewed effort to register black voters. Finding resistance by white officials to be intractable, even after the Civil Rights Act of 1964 ended segregation, the DCVL invited Rev. Martin Luther King Jr. and the activists of the Southern Christian Leadership Conference (SCLC) to join them. SCLC brought many prominent civil rights and civic leaders to Selma in January 1965. Local and regional protests began, with 3,000 people arrested by the end of February.

On February 26, 1965, activist and deacon Jimmie Lee Jackson died after being mortally shot several days earlier by a state trooper during a peaceful march in Marion, Alabama. To defuse and refocus the community's outrage, SCLC Director of Direct Action James Bevel, who was directing SCLC's Selma Voting Rights Movement, called for a march of dramatic length, from Selma to the state capital of Montgomery. Bevel had been working on his Alabama Project for voting rights since late 1963.

The first march took place on March 7, 1965. Bevel, Amelia Boynton, and others helped organize it. The march recently gained the nickname "Bloody Sunday" (a term more commonly applied to an analagous incident in Northern Ireland dating from 1972) after its 600 marchers were attacked at the Edmund Pettus Bridge after leaving Selma; state troopers and county posse attacked the unarmed marchers with billy clubs and tear gas. Law enforcement beat Boynton unconscious; media publicized a picture of her lying wounded on the bridge worldwide.

The second march took place March 9. Troopers, police, and marchers confronted each other, but when the troopers stepped aside to let them pass, King led the marchers back to the church. He was seeking protection by a federal court for the march. That night, a white group beat and murdered civil rights activist James Reeb, a Unitarian Universalis minister from Boston, who had come to Selma to march in the second march. Many other clergy and sympathizers from across the country also attended the second march.

The violence of "Bloody Sunday" and of Reeb's death led to a national outcry and some acts of civil disobedience, targeting both the Alabama state and federal governments. The protesters demanded protection for the Selma marchers and a new federal voting rights law to enable African Americans to register and vote without harassment. President Lyndon Johnson, whose administration had been working on a voting rights law, held a televised joint session of Congress on March 15 to ask for the bill's introduction and passage.

With Governor Wallace refusing to protect the marchers, President Johnson committed to do so. The third march started March 21. Protected by 2,000 soldiers of the U.S. Army, 1,900 members of the Alabama National Guard under Federal command, and many FBI agents and Federal Marshals, the marchers averaged 10 miles (16 km) a day along U.S. Route 80, known in Alabama as the "Jefferson Davis Highway". The marchers arrived in Montgomery on March 24 and at the Alabama State Capitol on March 25. With thousands having joined the campaign, 25,000 people entered the capital city that day in support of voting rights.

The route is memorialized as the Selma To Montgomery Voting Rights Trail, and is a U.S. National Historic Trail.


For those that think it's too much trouble to protect and preserve your rights in court, consider how much trouble those that came before us went through that fought and died so that you could have privileges that you now take for granted.

Eight days after "Bloody Sunday", President Lyndon Johnson addressed Congress and the American People and delivered his Voting Rights Speech.

 

Pattern of Civil Rights Violations by the Ferguson PD

Watch the video of Attorney General Eric Holder discussing DOJ Ferguson investigation findings

 

The DOJ Ferguson Investigation Report (PDF) Format | The DOJ Michael Brown Death, Darren Wilson Shooting Investigation Report (PDF)

Justice Department Finds a Pattern of Civil Rights Violations by the Ferguson Police Department

The Justice Department announced the findings of its two civil rights investigations related to Ferguson, Missouri, on Wednesday March 4, 2015.  The Justice Department found that the Ferguson Police Department (FPD) engaged in a pattern or practice of conduct that violates the First, Fourth, and 14th Amendments of the Constitution.  The Justice Department also announced that the evidence examined in its independent, federal investigation into the fatal shooting of Michael Brown does not support federal civil rights charges against Ferguson Police Officer Darren Wilson.

“As detailed in our report, this investigation found a community that was deeply polarized, and where deep distrust and hostility often characterized interactions between police and area residents,” said Attorney General Eric Holder.  “Our investigation showed that Ferguson police officers routinely violate the Fourth Amendment in stopping people without reasonable suspicion, arresting them without probable cause, and using unreasonable force against them.  Now that our investigation has reached its conclusion, it is time for Ferguson’s leaders to take immediate, wholesale and structural corrective action.  The report we have issued and the steps we have taken are only the beginning of a necessarily resource-intensive and inclusive process to promote reconciliation, to reduce and eliminate bias, and to bridge gaps and build understanding.” 

“While the findings in Ferguson are very serious and the list of needed changes is long, the record of the Civil Rights Division’s work with police departments across the country shows that if the Ferguson Police Department truly commits to community policing, it can restore the trust it has lost,” said Acting Assistant Attorney General Vanita Gupta of the Civil Rights Division.  “We look forward to working with City Officials and the many communities that make up Ferguson to develop and institute reforms that will focus the Ferguson Police Department on public safety and constitutional policing instead of revenue.  Real community policing is possible and ensures that all people are equal before the law, and that law enforcement is seen as a part of, rather than distant from, the communities they serve.”

Attorney General Holder first announced the comprehensive pattern or practice investigation into the Ferguson Police Department after visiting that community in August 2014, and hearing directly from residents about police practices and the lack of trust between FPD and those they are sworn to protect.  The investigation focused on the FPD’s use of force, including deadly force; stops, searches and arrests; discriminatory policing; and treatment of detainees inside Ferguson’s city jail by Ferguson police officers.

In the course of its pattern or practice investigation, the Civil Rights Division reviewed more than 35,000 pages of police records; interviewed and met with city, police and court officials, including the FPD’s chief and numerous other officers; conducted hundreds of in-person and telephone interviews, as well as participated in meetings with community members and groups; observed Ferguson Municipal Court sessions, and; analyzed FPD’s data on stops, searches and arrests.  It found that the combination of Ferguson’s focus on generating revenue over public safety, along with racial bias, has a profound effect on the FPD’s police and court practices, resulting in conduct that routinely violates the Constitution and federal law.  The department also found that these patterns created a lack of trust between the FPD and significant portions of Ferguson’s residents, especially African Americans. 

The department found that the FPD has a pattern or practice of:

  • Conducting stops without reasonable suspicion and arrests without probable cause in violation of the Fourth Amendment;

  • Interfering with the right to free expression in violation of the First Amendment; and

  • Using unreasonable force in violation of the Fourth Amendment.

The department found that Ferguson Municipal Court has a pattern or practice of:

  • Focusing on revenue over public safety, leading to court practices that violate the 14th Amendment’s due process and equal protection requirements.

  • Court practices exacerbating the harm of Ferguson’s unconstitutional police practices and imposing particular hardship upon Ferguson’s most vulnerable residents, especially upon those living in or near poverty.Minor offenses can generate crippling debts, result in jail time because of an inability to pay and result in the loss of a driver’s license, employment, or housing.

The department found a pattern or practice of racial bias in both the FPD and municipal court:

  • The harms of Ferguson’s police and court practices are borne disproportionately by African Americans and that this disproportionate impact is avoidable.

  • Ferguson’s harmful court and police practices are due, at least in part, to intentional discrimination, as demonstrated by direct evidence of racial bias and stereotyping about African Americans by certain Ferguson police and municipal court officials.

The findings are laid out in a 100-page report that discusses the evidence and what remedies should be implemented to end the pattern or practice. The findings include two sets of recommendations, 26 in total, that the Justice Department believes are necessary to correct the unconstitutional FPD and Ferguson Municipal Court practices.  The recommendations include: changing policing and court practices so that they are based on public safety instead of revenue; improving training and oversight; changing practices to reduce bias, and; ending an overreliance on arrest warrants as a means of collecting fines.

The Justice Department will require that the recommendations and other measures be part of a court-enforceable remedial process that includes involvement from community stakeholders as well as independent oversight.  The Justice Department has provided its investigative report to the FPD and in the coming weeks, the Civil Rights Division will seek to work with the City of Ferguson and the Ferguson community to develop and reach an agreement for reform, using the recommendations in the report as the starting point.      

The federal criminal investigation into the fatal shooting of Michael Brown sought to determine whether the evidence from the events that led to Brown’s death was sufficient to prove, beyond a reasonable doubt, that Wilson’s actions violated federal civil rights laws that make it a federal crime for someone acting with law enforcement authority to willfully violate a person’s civil rights.  As part of the investigation, federal authorities reviewed physical, ballistic, forensic, and crime scene evidence; medical reports and autopsy reports, including an independent autopsy performed by the U.S. Department of Defense Armed Forces Medical Examiner Service; Wilson’s personnel records; audio and video recordings; internet postings, and; the transcripts from the proceedings before the St. Louis County grand jury.  Federal investigators interviewed purported eyewitnesses and other individuals claiming to have relevant information.  Federal prosecutors and agents re-interviewed dozens of witnesses to evaluate their accounts and obtain more detailed information.  FBI agents independently canvassed more than 300 residences to locate and interview additional witnesses.

The standard of proof is the same for all criminal cases: that the defendant committed the crime beyond a reasonable doubt.  However, unlike state laws, federal criminal civil rights statutes do not have the equivalent of manslaughter or a statute that makes negligence a crime.  Federal statutes require the government to prove that Officer Wilson used unreasonable force when he shot Michael Brown and that he did so willfully, that is, he shot Brown knowing it was wrong and against the law to do so.  After a careful and deliberative review of all of the evidence, the department has determined that the evidence does not establish that Darren Wilson violated the applicable federal criminal civil rights statute.  The family of Michael Brown was notified earlier today of the department’s findings. 

Due to the high interest in this case, the department took the rare step of publicly releasing the closing memo in the case.  The report details, in over 80 pages, the evidence, including evidence from witnesses, the autopsies and physical evidence from the analysis of the DNA, blood, shooting scene and ballistics.  The report also explains the law as developed by the federal courts and applies that law to the evidence.

 

Black Concentration Camps?

Food for thought

In anticipation of the Darren Wilson grand jury decision, the governor has declared a state of emergency, photos of hidden federal police vehicles parked at a hotel garage were posted on social media resulting in the firing of the hotel employee who posted the pictures, the national guard has been activated and a general sense of apprehension has gripped the area.

The video below which discusses the controversial "King Alfred Plan" a plan to control and or eliminate black and other people during civil unrest is offered as food for thought especially concerning the recent militarized police response to a mostly peaceful protest.

I am not certain when this lecture was given, but the reference to Colin Powell being the current Secretary of State, suggest during the Bush administration. Bush accepted Powell's resignation in November 2004, so this video is most likely more than a decade old. Compare the predictions with what is happening in response to the Ferguson Protest.

Rex84

Rex 84, short for Readiness Exercise 1984, was a classified scenario and drill developed by the United States federal government to detain large numbers of American citizens deemed to be "national security threats", in the event that the President declared a "State of National Emergency". The plan was first revealed in detail in a major daily newspaper by reporter Alfonso Chardy in the July 5, 1987, edition of the Miami Herald.

The existence of a master military contingency plans (of which REX-84 was a part), "Garden Plot" and a similar earlier exercise, "Lantern Spike", were originally revealed by journalist Ron Ridenhour, who summarized his findings in an article in CounterSpy. Rex 84 was similar to a plan in a 1970 report written by FEMA chief Louis Giuffrida, while at the Army War College, which proposed the detention of up to 21 million "American Negroes" if there were a black militant uprising in the United States.

Transcripts from the Iran-Contra Hearings in 1987 record the following dialogue between Congressman Jack Brooks, Oliver North's attorney Brendan Sullivan and Senator Daniel Inouye, the Democratic Chair of the joint Senate-House Committee: 

[Congressman Jack] Brooks: Colonel North, in your work at the N.S.C. were you not assigned, at one time, to work on plans for the continuity of government in the event of a major disaster?
Brendan Sullivan [North’s counsel, agitatedly]: Mr. Chairman?
[Senator Daniel] Inouye: I believe that question touches upon a highly sensitive and classified area so may I request that you not touch upon that?
Brooks: I was particularly concerned, Mr. Chairman because I read in Miami papers, and several others, that there had been a plan developed, by that same agency, a contingency plan in the event of emergency, that would suspend the American constitution. And I was deeply concerned about it and wondered if that was an area in which he had worked. I believe that it was and I wanted to get his confirmation.
Inouye: May I most respectfully request that that matter not be touched upon at this stage. If we wish to get into this, I'm certain arrangements can be made for an executive session.

Contingency plans by the US Government for rounding up people perceived by the government to be subversive or a threat to civil order have existed for many decades.[8] For example, from 1967 to 1971, the FBI kept a list of over 100,000 people to be rounded up as subversive, dubbed the "ADEX" list.

Public Policy Memorandum 23 (PP23)

Memo by George Kennan, Head of the US State Department Policy Planning Staff. Written February 28, 1948, Declassified June 17, 1974. George Kennan

National Security Study Memorandum 200

National Security Study Memorandum 200: Implications of Worldwide Population Growth for U.S. Security and Overseas Interests (NSSM200) was completed on December 10, 1974, by the United States National Security Council under the direction of Henry Kissinger. It was adopted as official U.S. policy by President Gerald Ford in November 1975. It was originally classified but was later declassified and obtained by researchers in the early 1990s.

The basic thesis of the memorandum was that population growth in the least developed countries (LDCs) is a concern to U.S. national security because it would tend to risk civil unrest and political instability in countries that had a high potential for economic development. The policy gives "paramount importance" to population control measures and the promotion of contraception among 13 populous countries. This is to control rapid population growth which the US deems inimical to the socio-political and economic growth of these countries and to the national interests of the United States, since the "U.S. economy will require large and increasing amounts of minerals from abroad", and these countries can produce destabilizing opposition forces against the United States.

It recommends that U.S. leadership "influence national leaders" and that "improved world-wide support for population-related efforts should be sought through increased emphasis on mass media and other population education and motivation programs by the UN, USIA, and USAID."

Named countries

Thirteen countries are named in the report as particularly problematic with respect to U.S. security interests: India, Bangladesh, Pakistan, Indonesia, Thailand, the Philippines, Turkey, Nigeria, Egypt, Ethiopia, Mexico, Colombia, and Brazil. These countries are projected to create 47 percent of all world population growth.
The report advocates the promotion of education and contraception and other population control measures, stating for instance that "No country has reduced its population growth without resorting to abortion". It also raises the question of whether the U.S. should consider the preferential allocation of surplus food supplies to states that are deemed constructive in the use of population control measures.

Presidential Review Memorandum 46 

The document on the Jimmy Carter Presidential Library website is purported to be a forged document, titled Presidential Review Memorandum 46.