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King v. United States of America
Filing 625
PROPOSED FINDINGS AND RECOMMENDATION of the Magistrate Judge recommending that the 546 MOTION by Lois King to Vacate, Set Aside or Correct Sentence by a Person in Federal Custody pursuant to Title 28, United States Code, Section 2255, be denied. (A ttachments: # 1 United States vs. Smith) Cross Reference Criminal Case Number 6:04-cr-00127-08. This case no longer referred to Magistrate Judge Mary E. Stanley. Objections to Proposed F&R due by 6/22/2009. Signed by Magistrate Judge Mary E. Stanley on 6/5/2009. (cc: Petitioner, counsel of record) (jkk)
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF WEST VIRGINIA PARKERSBURG LOIS KING, Movant, v. Case No. 6:04-cr-00127-8 Case No. 6:07-cv-00447 UNITED STATES OF AMERICA, Respondent. PROPOSED FINDINGS AND RECOMMENDATION Pending before the court are Movant's Motion to Vacate, Set Aside, or Correct Sentence pursuant to 28 U.S.C. § 2255, filed on July 19, 2007 (docket # 546), and her Motion for Modification of Sentence pursuant to 18 U.S.C. § 3582, filed on November 16, 2007 (## 578, 584). Lois King (hereinafter "Defendant") has served a 41 month sentence imposed on April 25, 2005, following her conviction by a jury of engaging in a conspiracy with her son, Kirt R. King, to launder money, in violation of 18 U.S.C. § 1956(h). entered April 27, 2005, # 351.) year term of supervised release. unsuccessful. (Judgment She is currently serving a three Defendant's direct appeal was United States v. King, No. 05-4501, 199 Fed. Appx. 250 (4th Cir. July 20, 2006). Defendant's § 2255 Motion is supported by a memorandum (# 547) and by exhibits (# 547-2). Grounds six and seven were amended with The United States responded in supplemental authority (# 551). opposition (# 564), and Defendant submitted a reply (# 577). Facts of the Case The Fourth Circuit's decision affirming Defendant's and codefendant Nathan Hughes's convictions and sentences provides a brief synopsis of the government's evidence against Defendant: The charges arose in 2001 when the Drug Enforcement Administration and the Parkersburg Narcotics Violent Crimes Task Force ("Task Force") began an undercover investigation into cocaine trafficking in Wood County, West Virginia, targeting various individuals in the Parkersburg area including Appellant Hughes, as well as Kirt King and others. [Footnote: The Government introduced evidence at trial that Kirt King and Mario Mason joined forces to purchase cocaine from Columbus, Ohio, process it, and then resell it in the Parkersburg, West Virginia area. Testimony as to the amounts of cocaine purchased, processed, and redistributed by the conspiracy members was introduced by a number of witnesses.] * * * With respect to Lois King, the Government alleged that they found 116.5 grams of cocaine in Kirt King's residence, worth $26,000, and that Lois King, Kirt King's mother, owned the residence. Mario Mason testified that Kirt King would give large amounts of cash to Appellant King, and that he and Kirt King used the residence to store and prepare for resale cocaine they had purchased from sources in Columbus, Ohio. He further testified that Appellant King was in the residence during the time he and Kirt King used it to process cocaine. Mason attested that Appellant King was involved in taking the drug money she received from her son and putting it in assets, such as houses and cars. The Government presented additional evidence that Appellant King acquired and paid the land contract on one residence with a lump sum payment of $14,580 in cash, and that another property was purchased for $21,000, deeded, and being paid for by Appellant King, despite her lack of financial resources (as reported in her income tax records). Hughes, 199 Fed. Appx. at 251-52. One of the issues raised by Defendant on appeal concerned her attorney's performance. 2 King's final challenge on appeal is that her retained trial counsel rendered ineffective assistance. She asserts that her attorney's continuing disregard for the judge's instructions not to thank him regarding his trial rulings, his disregard for the judge's instruction not to inquire into details of pending charges relative to a Government witness, and his use of a pejorative relative to an Assistant United States Attorney in the presence of a juror prejudiced her case. She further claims that her attorney was admonished by the district court five times for statements he made during his opening statement, that he failed to present a defense on her behalf, that his questions on direct examination were met with repeated objections by other attorneys, and that his cross-examination of Government witnesses lacked all "rhythm or craft." King's claim of ineffective assistance of counsel must be brought in a collateral proceeding under 28 U.S.C. § 2255 (2000), unless it conclusively appears from the face of the record that her counsel was ineffective. United States v. DeFusco, 949 F.2d 114, 120-21 (4th Cir. 1991). Because the record does not conclusively establish ineffective assistance of counsel, we decline to consider this claim on direct appeal. Id., at 253. Grounds for Relief Defendant raises the following eleven grounds for relief: A. Ground one: Constructive amendment of the indictment and ineffective assistance of counsel. The government and the Court constructively amended the indictment by removing an essential element of the offense returned by the grand jury; Petitioner's counsel failed to challenge this due process violation. B. Ground two: Ineffective assistance of counsel, due to counsel's failure to challenge the willful blindness jury instruction. The government and the Court improperly gave a "willful blindness" instruction which removed an essential element of the offense and reduced the government's burden of proof; Petitioner's counsel, however, failed to challenge this improper instruction and amendment. 3 C. Ground three: Ineffective assistance of counsel, due to counsel's failure to challenge the sufficiency of the evidence on appeal. The evidence was insufficient to sustain Petitioner's conviction; Petitioner's counsel, however, failed to raise this issue on appeal. D. Ground four: Ineffective assistance of counsel, due to counsel's failure to properly argue Petitioner's motion to sever trials. Counsel filed a motion to sever Petitioner's trial. However, counsel failed to properly argue the spill-over effect and the need for Petitioner's co-defendant to testify, even though counsel was asked to do so. E. Ground five: Prosecutorial misconduct and ineffective assistance of counsel. The government committed prosecutorial misconduct by prosecuting Petitioner solely because Kirt King refused to enter a plea agreement with the government; Petitioner's counsel know of this misconduct but failed to bring it to the attention of the Court. F. Ground six: Denial of Petitioner's right to testify and ineffect[ive] assistance of counsel. Petitioner's counsel would not allow her to testify even though she repeatedly requested to be allowed to do so. In fact, counsel threatened to quit unless Petitioner followed his instructions to not testify. G. Ground seven: Ineffective assistance of counsel, due to counsel's failure to investigate, interview, present evidence, and call witnesses prior to and during trial. Petitioner had evidence of her innocence and asked counsel to present that evidence in her defense; Petitioenr also asked counsel to interview persons that would authen[t]icate her evidence and to call those persons as witnesses; Petitioner's counsel, however, failed to do so even though this evidence and testimony would have resulted in Petitioner's acquittal. H. Ground eight: Actual innocence. As seen by the evidence (Exhibits 2-18) presented in Ground Seven, Petitioner is actually and factually innocent of Count Sixteen. I. Ground nine: Brady violation by the government, and ineffective assistance of counsel, due to counsel's failure to challenge the Brady violation. The government 4 seized all of Petitioner's financial records during the June, 2004 search of her home. However, Petitioner's records for the years 1999 and 2000 were apparently lost by the government, according to Petitioner's counsel. Counsel, however, failed to make this known to the Court. J. Ground ten: Violation of Petitioner's due process rights due to counsel's failure to file for a petition of certiorari to the Supreme Court, or to notify Petitioner that he was not going to file. Petitioner asked counsel to file a petition for writ of certiorari to the Supreme Court. Counsel, however, failed to file and failed to notify Petitioner (or the Fourth Circuit) that he was not going to file, thereby preventing Petitioner from filing on her own. K. Ground eleven: Sentence imposed in violation of Petitioner's Fifth and Sixth Amendment rights/ineffective assistance. Petitioner's sentence was enhanced based on facts not included in the indictment, submitted to the jury, or admitted to by Petitioner, thereby violating her 5th and 6th Amendment rights under Blakely, Booker, and Cunningham. Petitioner's counsel, however, failed to raise this challenge at the district level or on appeal. (# 546, at 4-5, 7-8.) By Order entered May 8, 2009 (# 619), Defendant was asked if she wished to pursue all her grounds for relief in her § 2255 motion and her § 3582 motion. Defendant responded that she wishes to continue with all grounds for relief raised in her § 2255 motion, but that "there is no reason to continue the 3582 motion to modify my sentence for a compassionate release, being that I have already been released from prison" (# 622). Accordingly, it is respectfully RECOMMENDED that Defendant's § 3582 motion (# 578) be denied as moot. Ineffective Assistance of Counsel All but one (ground eight) of Defendant's grounds for relief 5 alleged that she was denied effective assistance of counsel. The Supreme Court addressed the right to effective assistance of counsel in Strickland v. Washington, 466 U.S. 668 (1984), in which the Court adopted a two-pronged test. The first prong is competence; movant must show that the representation fell below an objective standard of reasonableness. Id., at 687-91. There is a strong presumption that the conduct of counsel was in the wide range of what is considered reasonable professional assistance, and a reviewing court must be highly deferential in scrutinizing the performance of counsel. Id., at 688-89. In order to meet the first prong, movant must identify the acts or omissions of counsel that are alleged not to have been the result of reasonable professional judgment. The court must then determine whether, in light of all the circumstances, the identified acts or omissions were outside the wide range of professionally competent assistance. . . [C]ounsel is strongly presumed to have rendered adequate assistance and made all significant decisions in the exercise of reasonable professional judgment. Id., at 690. The second prong is prejudice; "[t]he defendant must show that there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome." Id., at 694. The court may determine the prejudice prong prior to considering the competency prong if it is easier to dispose of the claim on the ground of lack of prejudice. Id., at 697. 6 The undersigned will address Defendant's grounds for relief in light of the Strickland standard. Ground one - Constructive amendment of the indictment Count Sixteen of the superceding indictment (# 105, at 17-23) was the only charge faced by Defendant. It alleged that she and her son, Kirt King, engaged in money laundering in violation of 18 U.S.C. §§ 1956(a)(1)(B)(i) and (ii). Section 1956(a)(1)(B) sets forth two alternative crimes as follows: (a)(1) Whoever, knowing that the property involved in a financial transaction represents the proceeds of some form of unlawful activity, conducts or attempts to conduct such a financial transaction which in fact involves the proceeds of specified unlawful activity *** (B) knowing that the transaction is designed in whole or in part (i) to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity; or (ii) to avoid a transaction reporting requirement under State or Federal law. [Emphasis added.] Count Sixteen alleged particular transactions which were charged as concealing the proceeds of cocaine trafficking (titling real estate and motor vehicles in Lois King's name), and one transaction as avoiding a transaction reporting requirement (splitting a deposit between cash and a check to avoid the filing of a currency transaction report). At the close of the government's case, Defendant's attorney, David Perry, made a motion pursuant to Rule 29, Fed. R. Crim. P. (Tr. Trial, # 305-5, at 243-47.) The court remarked, "I don't see Id., at 249. Assistant U.S. any evidence of structuring here." 7 Attorney ("AUSA") Arnold agreed, and stated, "the United States does not mind if the Court wants to strike those portions relating to structuring." Id., at 249-50. Chief Judge Goodwin denied the motion, "except as to the allegation of structuring." Id., at 250. In other words, Chief Judge Goodwin struck from the indictment any allegation that Defendant had engaged in a violation of 18 U.S.C. § 1956(a)(1)(B)(ii), avoiding a transaction reporting requirement, leaving only the charge of concealing proceeds of an unlawful activity. In United States v. Perry, 560 F.3d 246 (4th Cir. 2009), the court addressed an argument similar to that raised by Defendant. In Perry, the defendant amended the argued that the The district Fourth court Circuit constructively disagreed. indictment. It is well established that when the Government charges in the conjunctive, and the statute is worded in the disjunctive, the district court can instruct the jury in the disjunctive. [Citations omitted.] The same holds true in the instant case. The indictment charged both predicate offenses, placing Perry on notice of the specific charges against him. * * * The instruction did not broaden the possible bases for conviction beyond those presented in the indictment, nor change the elements of the offense charged so as to result in Perry being convicted of a crime different from that charged in the indictment. Accordingly, the district court's disjunctive instruction as to the predicate offenses did not result in a constructive amendment of the indictment . . .. 560 F.3d at 256. In Defendant's case, the indictment charged two different 8 violations in the conjunctive ("and"): "to conceal and disguise the nature, location, source, ownership, and control of the proceeds of the unlawful sale and distribution of controlled substances, and to avoid a transaction reporting requirement under State or Federal law, in violation of 18 U.S.C. §§ 1956(a)(1)(B)(i) and (ii)." 105, at 17.) (# The statute is worded in the disjunctive ("or"): "(i) to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity; or (ii) to avoid a transaction reporting requirement under State or Federal law." Thus Defendant was on notice of both charges against her, but the government was only required to prove one of the charges. When Chief Judge Goodwin struck the references to structuring and the alleged violation of § 1956(a)(1)(B)(ii), he narrowed (not broadened) Count Sixteen, and he did not eliminate any essential element of the remaining charge of § 1956(a)(1)(B)(i). Thus there was no constructive amendment of the indictment, and Defendant was not prejudiced thereby. Defendant's argument in her reply that the government was required to prove both violations in Count Sixteen (# 577, at 4) is simply in error and violates the maxim of "charge in the conjunctive - prove in the disjunctive" which is confirmed in Perry. The Fourth Circuit addressed this argument concerning the alleged constructive amendment to the indictment in the direct 9 appeal of Defendant's son, Kirt King. While King is correct that the district court allowed the Government to redact that portion of the indictment regarding the illegal structure of financial transactions, that portion was a small part of the "Manner and Means of the Conspiracy" section of the indictment, and did not affect the elements of money laundering. King has not alleged, nor have we found, any prejudice as a result of the redaction of the language related to structuring, and we find that the evidence presented at trial did not alter the crime charged in the indictment, but rather effected a mere variance, which did not violate King's constitutional rights. See United States v. Randall, 171 F.3d 195, 203 (4th Cir. 1999). As the essential elements of the money laundering count were not affected by the redaction, the district court's decision to allow the redaction was not a constructive amendment of the indictment and thus, did not broaden the possible bases for conviction beyond those charged by the grand jury. Hence, King's claim is without merit. United States v. King, No. 05-4672, 239 Fed. Appx. 852, 856 (4th Cir. Sept. 10, 2007). The undersigned proposes that the presiding District Judge FIND that Defendant's first ground for relief is without merit, she suffered no prejudice, and thus she cannot satisfy the second prong of the Strickland test. Ground two - Willful blindness instruction Defendant argues that it was plain error for Chief Judge Goodwin to have given a willful blindness instruction because the government did not prove Defendant's knowledge of the specified unlawful activity. (# 547, at 12.) She contends that a willful blindness instruction is inconsistent with the essential elements of § 1956(a)(1)(B)(i), as charged to the jury, that "the 10 conspirators knew that property represented the proceeds of the distribution of cocaine;" and "the conspirators engaged in the financial transaction with the intent to conceal, disguise, and promote the carrying on of distribution of cocaine." 82.) The willful blindness instruction was read to the jury as follows: If you find that a defendant was willfully blind to the source of the proceeds of the alleged unlawful activity, then you may find the defendant had knowledge of the source of the proceeds of the alleged unlawful activity. I want to emphasize again in terms of the charge in Count Sixteen that you may not infer guilt of a defendant solely on the basis of his or her presence at the scene of the crime, his or her proximity to illegal activity, or his or her association with a person engaging in illegal activity. The Government must prove beyond a reasonable doubt that a defendant in Count Sixteen knowingly and intentionally, as I defined those, committed the crime knowingly and intentionally as I defined those terms earlier. Id., at 83-84. The government's response merely asserts that Defendant was convicted based on overwhelming evidence (# 564, at 7). In reply, (# 306-2, at Defendant contends that the willful blindness instruction amounted to an instruction that the jury should assume Defendant's knowledge. (# 577, at 5.) Defendant's son raised an issue on direct appeal as to the willful blindness instruction relative to the knowledge of his 11 mother, Lois King, of the illegal nature of the funds involved in the money laundering conspiracy. King, 239 Fed. Appx. at 856. The Fourth Circuit found no error in the instruction. King misconstrues the law for willful blindness, and its applicability to this case. The element of knowledge in the crime of conspiracy may be satisfied by a showing that a defendant acted with willful blindness, as willful blindness is a form of constructive knowledge which "allows the jury to impute the element of knowledge to the defendant if the evidence indicates that he purposely closed his eyes to avoid knowing what was taking place around him." United States v. Schnabel, 939 F.2d 197, 203 (4th Cir. 1991). Because willful blindness serves as a proxy for knowledge, there is nothing inconsistent in the determination that a defendant knowingly was part of a conspiracy even where willfully blind to the conspiracy's existence and purpose. See United States v. McIver, 470 F.3d 550, 563-64 (4th Cir. 2006). Hence, we find no abuse of the district court's discretion in granting the willful blindness instruction with regard to Lois King, even assuming, arguendo, that the Government failed to prove actual knowledge, nor was there any inconsistency in giving the willful blindness instruction to the jury and allowing the conspiracy charge against King to go to the jury. Id., at 856-57. The Fourth Circuit having ruled that the willful blindness was appropriate, the undersigned proposes that the presiding District Judge FIND that Defendant's second ground for relief is without merit, she suffered no prejudice, and thus she cannot satisfy the second prong of the Strickland test. Ground three: Sufficiency of the evidence Defendant contends that the evidence was insufficient to convict her, and that her attorney was ineffective because he did not raise sufficiency of the evidence as a ground on appeal. 12 (# 547, at 13-16. This argument is based on the willful blindness instruction, asserting that the instruction removed the essential element of knowledge from the government's burden of proof. at 15. The United States responded as follows: "With respect to the failure to argue the sufficiency of the evidence, it is obvious from the appellate record that counsel assessed the case and then argued the only grounds he felt would be meritorious." 11.) Defendant's reply disparages the government's response and claims that a sufficiency of the evidence argument on appeal would have been sustained due to the lack of proof of her knowledge as to the source of the proceeds of cocaine trafficking. (# 577, at 7.) (# 564, at Id., Kirt King raised on appeal a claim that Chief Judge Goodwin erred in denying his Rule 29 motion as to Count Sixteen, money laundering. Like his mother, King based his claim on "the perceived inconsistency between the district court's grant of the willful blindness jury instruction for Lois King and the element of knowledge required to establish a conspiracy." Appx. at 857. King, 239 Fed. The Fourth Circuit ruled that his claim had no merit, for the reasons set forth with respect to the willful blindness instruction. The Fourth to Id. having the ruled of that the the evidence was Circuit justify sufficient giving willful blindness 13 instruction, the undersigned proposes that the presiding District Judge FIND that Defendant's third ground for relief is without merit, she suffered no prejudice, and thus she cannot satisfy the second prong of the Strickland test. Ground four: Severence In this claim, Defendant states that her attorney filed a motion for severance, but that Chief Judge Goodwin never ruled on it. (# 547, at 17.) She asserts that Mr. Perry was ineffective because he did not properly present and argue the severance motion, and that Herbert L. Hively, Jr., her appointed appellate counsel, was ineffective because he did not raise the matter on appeal. Id. She claims that she was prejudiced by the spillover effect from her co-defendants, particularly her son, Kirt King, who was charged as her co-conspirator. Id., at 18. Defendant argues that the wealth of evidence against Kirt King led the jury to infer to her knowledge of the source of the money. Id., at 19. Finally she claims that Kirt King offered to testify on Defendant's behalf, but that Mr. Perry did not raise this issue before Chief Judge Goodwin. The United States failed to respond to this claim, which omission was duly noted by Defendant (# 577, at 8). Mr. Perry filed a motion for severance on October 28, 2004 (# 154), and a memorandum in support (# 155). a co-defendant's testimony might be His motion notes that to exculpate (# 154, necessary Defendant but would not be available with a joint trial. 14 at 2.) The memorandum argues that very little of the massive discovery from the United States pertained to Defendant, thus increasing the likelihood of spillover. (# 155, at 2-3.) It contends that the out-of-court statements by certain co-defendants may be admissible and implicate Defendant, but that the declarant may not testify. Id., at 4. The government responded in opposition to the motion (# 164). Defendant is correct that the docket sheet does not reflect a written order disposing of the motion. The undersigned contacted the court reporter of the hearing on pretrial motions which took place before Judge Goodwin on November 4, 2004 (# 174). provided the following excerpt from the hearing: THE COURT: Motion to sever is denied. The factors dictate a joint trial. The specified unlawful activity underlying the charge against your client is, in fact, the, according to the Government's proffer, the very evidence that they're going to introduce against the other defendants. I can hear your jury arguments fine. And certainly there may be cautionary instructions at some point you may wish to ask for. But there is no danger of unfair prejudice that's been shown to me that would justify severance in this case. It is well-established that defendants indicted together United She should be tried together, especially in conspiracy cases. States v. Harris, 498 F.3d 278, 291 (4th Cir. 2007). As Judge Goodwin noted, the money laundering count related to the same specified unlawful activity which Kirt King was charged with committing. 15 Defendant complains that Mr. Perry did not advise the court that Kirt King would exculpate his mother if he testified at a separate trial. The court notes that Kirt King attempted to plead guilty to the indictment on November 30, 2004, and informed Judge Goodwin that he wished to exonerate his mother. THE DEFENDANT: * * * But I did not launder no money with my mother. That's what this whole case is about, her property. * * * THE COURT: Did you take the proceeds of your drug dealing and engage in financial transactions like buy things for the house or put money in financial institutions or anything like that? THE DEFENDANT: I did without her knowledge or without her knowing anything I was doing. And I did it with other people, not her. (Tr. Plea Hr'g, # 520, at 25.) The plea was rejected as to the Id., at money-laundering and firearm charges faced by Kirt King. 43. The undersigned proposes that the presiding District Judge FIND that neither Mr. Perry nor Mr. Hively denied Defendant effective assistance of counsel with respect to the motion to sever and their performance was well within the wide range of reasonably competent assistance. Ground five: Prosecutorial misconduct Defendant claims that the prosecution engaged in misconduct by threatening, and then seeking and obtaining a superseding indictment against Defendant, with a forfeiture provision, in retaliation for Kirt King's refusal to plead guilty. 16 (# 547, at 23). She complains to Id. Judge that Mr. Perry in failed of to present these for allegations severance. Goodwin support the motion Defendant points to the affidavits signed by herself and Kirt King, (# 547-2, Exs. 2 and 22), and the trial testimony of Sherman Id. King as evidence in support of her contentions. The response of the United States is as follows: "[T]here is no evidence whatsoever that the Government acted improperly in any manner. The government's decision to seek an indictment against defendant was based on the overwhelming evidence against her, not of [sic] the basis of Kirt King's refusal to sign a plea agreement." (# 564, at 7-8.) Defendant asserts that the government's response is a material misrepresentation to the Court. (# 577, at 9.) She reiterates that both she and Kirt King have submitted affidavits in support of their position. Their affidavits (which are signed under penalty of perjury pursuant to 28 U.S.C. § 1746) state as follows: 5. [A]fter I was arrested, I was informed by my attorney that the Assistant U.S. Attorney had instructed him to relay a message to me, i.e., that unless I agreed to plead guilty to the one-count indictment, and agree to assist the government in the prosecution of my codefendants and others I may know, the United States was going to file a Superseding Indictment charging me with additional crimes, and that one of the new counts would also charge my mother for money laundering. In fact, according to my attorney, unless I plead guilty and cooperated, the government was going to put my mom away for a long time and take all of her houses. 6. After receiving this information from my 17 attorney, I informed my mom about it and asked her what I should do. My mom told me to do what I though[t] was right. More specifically, she told me that she had done nothing wrong so I shouldn't plead guilty just to protect her. My mom also told me that the government had made the same threats to my brother, Sherman King. 7. After discussing it with my attorney, who informed me that I should not plead guilty, I decided to proceed to trial. Following that decision, a Superseding Indictment was returned which included Count Sixteen, i.e., an allegation that I conspired with my mom to launder money. Notably, because my brother decided to plead guilty, he was not charged in Count Sixteen. 8. After the Superseding Indictment was returned, I told my attorney, my mom, and her attorney, that I was willing and, in fact, wanted to testify in my mom's defense. Had I been allowed to do so, I would have told the jury that my mom knew nothing about my activities and had no involvement in those activities. Moreover, I would have told the jury that I never gave my mom any proceeds from any illegal drugs, nor have I or anyone else ever used her house to make, store, package, or sell drugs, nor to store illegal money. In addition, I would have testified that my mom had worked two (2) jobs almost my whole life just to buy her rental houses, and that she had done all the repairs/remodeling of those houses by herself, except for help from my brother and myself. In sum, I would have told the jury the truth, i.e., that my mom was not guilty of money laundering or conspiring to launder money. Finally, I would testify to the same in any proceeding or trial. (# 547-2, Ex. 2, affidavit of Kirt King, ¶¶ 5-8, at 12-14.) Defendant's affidavit recites basically the same information. [F]ollowing the arrests of my sons, both of them told me that they had been told that unless they agreed to plead guilty and help the government, the Ass. U.S. Attorney was going to charge them with additional charges and charge me with laundering drug money. In addition, both of them told me that unless they cooperated I would be going to prison for a long time and that the government was going to take all my properties. I told both Kirt and Sherman that they did not have to plead guilty on my account because I had done nothing wrong. 18 (# 547-5, Ex. 22, affidavit of Lois King, ¶ 3 at 9.) Defendant has not submitted any declaration from Kirt King's attorney. In Bordenkircher v. Haynes, 434 U.S. 357 (1978), the Supreme Court held that it is not a violation of due process for a prosecutor to carry out a threat made during plea negotiations to have the accused reindicted on more serious charges on which he is plainly subject to prosecution if he does not plead guilty to the offense with which he was originally charged. In United States v. Goodwin, 457 U.S. 368 (1982), the Court held that a presumption of prosecutorial vindictiveness was not warranted when a defendant was indicted and convicted of a felony arising out of the same incident for which he had been charged with a misdemeanor, where there was no actual evidence of vindictiveness. A prosecutor should remain free before trial to exercise the broad discretion entrusted to him to determine the extent of the societal interest in prosecution. An initial decision should not freeze future conduct. As we made clear in Bordenkircher, the initial charges filed by a prosecutor may not reflect the extent to which an individual is legitimately subject to prosecution. 457 U.S. at 382. The Fourth Circuit has issued similar rulings based on Bordenkircher and Goodwin. In United States v. Williams, 47 F.3d 658, 662 (4th Cir. 1995), the court ruled that a prosecutor, in the context of plea negotiations, may threaten a defendant with a more severe prosecution and carry out those threats if the defendant refuses to cooperate with the police in the criminal investigation of another person. A defendant's cooperation with the police is a legitimate concession for a prosecutor to 19 seek during plea negotiations. * * * If it is constitutionally permissible to use the threat of more severe punishment to encourage a guilty plea, certainly it is legitimate to use the same tactics to encourage a defendant to cooperate with the authorities in the criminal investigation and prosecution of another. In United States v. Wilson, 262 F.3d 305, 314-15 (4th Cir. 2001), the court recited the requirements for showing prosecutorial vindictiveness: [A] defendant must show, through objective evidence, that (1) the prosecutor acted with genuine animus toward the defendant and (2) the defendant would not have been prosecuted but for that animus. See Goodwin, 457 U.S. at 380 n.12, 20 S. Ct. 2485 (noting that the charges must be brought "solely to `penalize' the defendant and could not be justified as a proper exercise of prosecutorial discretion"); United States v. Sanders, 211 F.3d 711, 717 (2d Cir. 2000). If the defendant is unable to prove an improper motive with direct evidence, he may still present evidence of circumstances from which an improper vindictive motive may be presumed. * * * Because the presumption of vindictiveness must be applicable to all cases presenting the same circumstances, it will rarely, if ever, be applied to prosecutors' pretrial decisions. The undersigned proposes that the presiding District Judge FIND that Defendant has failed to show through objective evidence that the prosecutor acted with genuine animus toward Defendant and that she would not have been prosecuted but for that animus. As set forth in Williams, it is constitutionally permissible to use the threat of more severe punishment to secure a guilty plea and to obtain a defendant's cooperation in the investigation and prosecution of another. The presiding District Judge should further FIND that Defendant's fifth ground for relief is without 20 merit, she suffered no prejudice, and thus she cannot satisfy the second prong of the Strickland test. Ground six: Testify in her own defense Ground seven: Failure to investigate, call witnesses Ground eight: Actual innocence Defendant complains that she repeatedly told Mr. Perry that she wanted to testify, but that Mr. Perry advised that she would not testify and that if she was not willing to follow his instructions, she should get another attorney. (# 547, at 25.) She asserts that she wished to present exhibits to demonstrate how she financed her properties and made repairs to them so as to demonstrate her innocence of money laundering. Id., at 26. She has submitted exhibits to establish that she purchased houses and cars through legitimate means. Id., at 28. Defendant states that she asked Mr. Perry to retrieve the financial records seized by the United States during a search of her residence, but he told her that some of the records had been lost and nothing could be done. Id., at 28-29. Perhaps her chief complaint is that Mr. Perry failed to present the documentary evidence which was available and which she believes would have exonerated her, notably evidence which proves how she purchased her properties and vehicles. at 29-32. Defendant's affidavit, Exhibit 22 to her § 2255 Motion, states as follows: 5. In June of 2004, my residence was searched and all my financial records were seized by the government. 21 Id., Numerous times prior to and during my trial, I told Mr. Perry that I needed my financial records to show that I had not received any monies from Kirt, or anyone else, that was not completely legal. When Mr. Perry finally showed me my documents, I discovered that my records for the years of 1999 and 2000 were missing. As a result, I asked Mr. Perry to get those documents from the government because they were also needed to prove my innocence. Mr. Perry, however, subsequently told me that the documents for 1999 and 2000 could not be found, and that both the U.S. Attorney's Office and the IRS denied having those records. 6. Both prior to and during trial, I repeatedly told Mr. Perry that I wanted to present the financial documents I did have to the jury, so they could see that I legally obtained the monies to purchase and repair my properties, and to trade and buy the vehicles the government accused me of buying with drug money. Mr. Perry assured me over and over that he would make sure that the jury would see these documents, because these records would "blow the government's case out of the water." However, Mr. Perry never did. After Mr. Perry rested my defense, I asked him why he had not used these records. In response, Mr. Perry said we didn't need them and that they would only confuse the jury. 7. Both prior to and during the trial, I told Mr. Perry that I wanted to testify in my defense, so I could tell the jury how and where I got the monies to purchase my properties and vehicles. Prior to trial, Mr. Perry told me that there was no way that he was going to allow me to testify. In fact, Mr. Perry told me that if I insisted on testifying that he would resign and I'd be left on my own to convince the Court to give me another attorney, which according to him the Court would not likely do. During trial, I again expressed my desire to testify to Mr. Perry. Specifically, I told him that in light of what the government's witnesses had said, I believed that I had to testify. The day before Mr. Perry rested my case, he told me that he had changed his mind and was going to allow me to testify. When that time came, however, Mr. Perry simply rested my defense without calling me to the stand. When I asked Mr. Perry why he had not allowed me to testify, he told me that it was unnecessary because the government had not proven its case. Notably, at no time did Mr. Perry ever inform me that the choice whether or not to testify was mine. Had 22 I been so informed, I would have insisted on testifying. Had I testified, I would have told the jury that I was innocent of Count Sixteen, and I would have explained how I got the monies to purchase my properties, how I performed almost all the repairs/remodeling myself, and how I was able to trade/buy the vehicles I was accused of buying with drug money. (# 547-5, Ex. 22, ¶ 5-7, at 10-11.) The United States did not respond to these claims other than to assert that they presented "overwhelming" evidence against Defendant. (# 564, at 7.) In her reply, Defendant notes the government's weak response, and asserts that the government's evidence against her was based only on inference. (# 577, at 11.) She contends that Exhibits 3- 14 to her § 2255 motion establish that she had $195,655.84 in loans relating to the purchase and upkeep of her properties,1 plus additional records which were lost by the United States. 12. Id., at Her point is that she had significant documentary evidence proving her innocence, but Mr. Perry chose not to present it, and not to allow her to testify. Id., at 13. Defendant argues that there is no plausible tactical or strategic reason that could justify Mr. Perry's decision to not submit the evidence presented herein; or to call the witnesses necessary to authenticate these documents; or to call Ms. King herself to testify. Had Ms. King testified, the jury would have been made aware that Ms. King owned 1110 38th Street since 1985; that she had worked two jobs and remodeled 1110 38th Street herself to build equity; that she used her credit and credit cards to purchase other properties; and that she had received numerous and significant insurance settlements to help purchase her Defendant amended her amount of indebtedness to the sum of $ 1 9 2 , 6 7 0 . 8 1 . (# 623.) 1 23 properties and vehicles. Id., at 14. The primary evidence presented by the United States against Defendant to prove her willful joinder in a conspiracy with her son Kirt King to launder his drug proceeds related to her purchase of the property at 1049 37th Street, Parkersburg, West Virginia (Kirt King's residence). Evelyn Moore, an accountant and tax preparer, testified that Defendant signed a land contract on March 21, 1997, to buy the property from William E. Brown, by paying $1,500 down, and the remainder in 118 monthly installments of $200 each. Trial, # 305, at 164-65.) (Tr. Ms. Moore stated that Defendant paid off the land contract in early October, 1999, by presenting Ms. Moore with $14,580.80 in cash, "fairly small bills rolled up and tied with rubber bands, . . . in a paper sack." Moore joked with Defendant that the Id., at 165-66. looked like Ms. drug money proceeds, although Defendant had claimed that the money was an insurance settlement. Id., at 167. Ms. Moore knew that an Id. insurance settlement should be in the form of a check. Defendant's Exhibits submitted with her § 2255 motion mostly relate to other properties and vehicles, not 1049 37th Street. Exhibit 9 is a Parkersburg Utility Board refund request for the 37th Street property, is dated 2002, and is thus irrelevant. 547-3, at 12.) (# Exhibit 12 is a check from Municipal Mutual Insurance Company dated 2003 and purportedly also related to the 24 37th Street property, and is also irrelevant. Id., at 19. None of these documents dispel the strong probative value of Ms. Moore's testimony that Defendant paid off the land contract on the 37th Street property in early October, 1999, with small bills in a paper sack. Defense Exhibit 3, a receipt dated October 3, 1999, and signed by William E. Brown, does not diminish the strength of Ms. Moore's testimony, because Ms. Moore handled Mr. Brown's financial affairs. The government presented evidence that Defendant reported modest income on her Federal income tax returns, yet acquired other properties and expensive vehicles which were titled in her name during the period 1997 to April, 2004. Defendant claims that she purchased these other properties and vehicles by incurring debt. Assuming that Defendant did incur debt in acquiring these properties, the fact remains that her cash pay-off of the land contract on the 37th Street property remains undisputed, and it alone is sufficient to support Defendant's conviction for moneylaundering. The court notes that the United States forfeited only one parcel of real estate: 1049 37th Street, which was the subject of an Agreed Order of Forfeiture and Release (# 588), and Final Order of Forfeiture (# 592). It is apparent that Mr. Perry made a strategic decision not to present documentary evidence regarding the significant assets titled in Defendant's name, such as the Lincoln Navigator (which 25 was also forfeited with the 37th Street property by agreement). Given the strength of the government's case against Kirt King with respect to his chronic unemployment, drug trafficking and access to expensive vehicles titled in his mother's name, Mr. Perry exercised the better part of discretion to avoid the topic and to focus on the lack of evidence of drug trafficking at Defendant's residence. Defendant argues vehemently that she should have had the opportunity to testify in her own behalf. In a decision concerning this issue, the Fourth Circuit held: . . . the advice provided by a criminal defense lawyer on whether his client should testify is "a paradigm of the type of tactical decision that cannot be challenged as evidence of ineffective assistance." Hutchins v. Garrison, 724 F.2d 1425, 1436 (4th Cir. 1983), cert. denied, 464 U.S. 1065, 104 S. Ct. 750, 79 L.Ed.2d 207 (1984); see also Jones v. Murray, 947 F.2d 1106, 1116 n.6 (4th Cir. 1991)(reiterating principle that advice to testify is paradigmatic of strategic decision); RogersBey v. Lane, 896 F.2d 279, 283 (7th Cir. 1990)(concluding that counsel's advice not to testify based in part on erroneous belief that defendant could be impeached by prior conviction, was not deficient performance); ReyesVejerano v. United States, 117 F. Supp.2d 103, 108-09 (D.P.R. 2000)("Absent evidence of coercion, legal advice concerning the defendant's right to testify does not constitute [ineffective assistance of counsel]"). Carter v. Lee, 283 F.3d 240, 249 (4th Cir. 2002). After review of the transcript, it is apparent that Defendant was vulnerable to cross-examination on several topics. defendants wish to take the stand and declare While many all the that government's witnesses have failed to tell the truth, the tactic is rarely successful and usually unpersuasive. 26 The undersigned proposes that the presiding District Judge FIND that Defendant's sixth, seventh and eighth grounds for relief are without merit, that she did not suffer any prejudice as a result of Mr. Perry's strategic decisions that she not testify and that he not present documents relating to transactions other than the 37th Street property, and that she is not actually innocent of money-laundering. Ground nine: Brady violation Defendant asserts that her financial records for 1999 and 2000 were seized by Federal agents during the execution of a search warrant for her home and were lost. (# 547, at 35.) She argues that Mr. Perry was ineffective because he did not file a motion relating to the government's alleged withholding of the 1999 and 2000 documents. Id., at 37. She contends that "this evidence would have rebutted the government's entire theory of prosecution." Id. The government's response states: Numerous financial records were obtained from defendant as a result of a search of her home. After a review of those records, agents from the Internal Revenue Service determined that they were of no evidentiary value. Therefore, all records obtained were returned in their entirety to defendant's trial counsel weeks prior to trial. (# 564, at 8.) Defendant's reply states: "The problem, of course, is that either the government's unverified assertions are not true, or Mr. 27 Perry falsely told Ms. King that the government had not returned them." (# 577, at 16.) Defendant has failed to identify any specific documents which she claims were withheld to her prejudice. The court notes that the documents concerning the 1999 pay-off of the 37th Street property land contract which were admitted into evidence were available from other sources, such as the bank and the Wood County Clerk's office. In fact, purchases of real estate and vehicles are typically accompanied by extensive documents which are maintained by third parties. In the absence of any specifically named missing documents, the court cannot determine whether such documents could have been obtained from another source. While the United States should have buttressed its position with a declaration from an agent responsible for the documents seized from Defendant's home, Defendant has failed to show that any material evidence was purposefully withheld or carelessly lost, and that she suffered any prejudice. The undersigned proposes that the presiding District Judge FIND that Defendant was denied effective assistance of counsel with respect to whether all of her documents were returned to her by the United States after their review was complete. Ground ten: Petition for writ of certiorari In this claim, Defendant contends that she was denied effective assistance of appellate counsel because she requested Mr. 28 Hively to file a petition for a writ of certiorari, he did not do so, and he did not tell her that he was not going to do so, thus depriving her of the opportunity to file a petition pro se. 547, at 38-42.) The government's response contends that Mr. Hively's (# responsibility ended with the appeal. Defendant's position. reply correctly (# 564, at 12.) disputes the government's (# 577, at 16-17.) The record reflects that Mr. Hively sent a letter dated August 21, 2006, to Defendant, enclosing the Fourth Circuit's decision affirming her conviction and sentence and advising her of the period in which to file a petition for a writ of certiorari with the Supreme Court. (# 564-2.) The letter reads as follows: Please find enclosed a copy of the Fourth Circuit decision denying your appeal. Pursuant to Rule 13 of the Rules of the Supreme Court of the United States, you have 90 days from July 20, 2006 to file your Writ of certiorari with the United States Supreme Court. Please note however I do not believe that avenue would be successful. It is extremely difficult for the United States Supreme Court to review it. However, I believe your most effective route would be to file a Writ of Habeas Corpus. This will allow you to argue directly ineffective assistance of your trial counsel. As you will read in the opinion, that is what the Court suggests. Please write if you have any questions. /s/ Herbert L. Hively, II Id. By letter dated September 11, 2006, Defendant replied to Mr. Hively, asking, "Why not do a writ of certiorari? will keep my direct appeal rights. 29 I understand it Isn't a writ of habeas corpus a last option?" (# 547-5, Ex. 19.) There is nothing in the record to indicate that Mr. Hively responded to this letter. By letter dated September 29, 2006, and sent certified mail, Defendant wrote to Mr. Hively again, advising, With help from my family, I have decided to file a writ of certiorari to the U.S. Supreme Court. My money laundering sentence was imposed in violation of my 6th amendment rights. I request my case be remanded in light of Cunningham v. California for resentencing. Also if this writ requires me to go out to court, I want to do it via video. (# 547-5, Ex. 20.) There is no indication that Mr. Hively responded to this letter. On November 16, 2006, Defendant wrote to the "Office of the Clerk" (it is not clear of which court), asking if Mr. Hively had filed a petition for a writ of certiorari, as she had not received one from him, nor an answer to her letters. Id., Ex. 21. By letter dated February 6, 2007,2 to the Clerk of this court, Defendant stated that "Mr. Hively failed to file a petition for a writ of certiorari to the Supreme Court after my direct appeal was denied, even though I specifically instructed him to do so." 529.) In the unpublished decision in United States v. Smith, No. 076358, 2008 WL 4951657 (4th Cir. Nov. 19, 2008) (attached to this Proposed Findings and Recommendation), the Fourth Circuit (# The court notes that the return address of this letter indicates it w a s sent by Kirt King at FCI Ashland, KY. The signature does not resemble the s i g n a t u r e s of Lois King on other documents received from her. 2 30 indicated the appropriate remedy in similar circumstances to the instant case, and declined to consider whether appellate counsel was ineffective. When appellate counsel has violated his duty under the CJA Plan to file a petition for certiorari requested by his client, or to file a motion to withdraw so that the client has adequate time in which to file a petition pro se, the Fourth Circuit will consider a motion to recall the mandate, to re-enter judgment, and to re-start the period of time within which to file a petition. September Smith, 2008 WL 4951657 *3. 2006 letter from The court notes that the to Mr. Hively is 29, Defendant sufficiently ambiguous that it is possible that he understood Defendant to be advising him that she was going forward with filing the petition pro se. Her subsequent letters clarify that she thought he would file the petition. Based on the Smith case, the undersigned proposes that the presiding District Judge FIND that the District Court has no authority to recall the mandate of the Fourth Circuit. Defendant must file a motion to recall the mandate with the Clerk of the Fourth Circuit. Ground eleven: Unreasonable sentence Defendant was sentenced on April 25, 2005 (# 347). The presentence report ("PSR") computed her guideline sentence as follows: 24. Base Offense Level: The guideline for this offense is found at U.S.S.G. § 2S1.1. The amount of monetary 31 value of the funds laundered by the defendant for which the government is seeking forfeiture is more than $30,000. Pursuant to the provision the base offense level is fourteen. U.S.S.G. §§ 2S1.1 and 2B1.1(b)(1)(D). 25. Specific Offense Characteristic: If the base offense level is established pursuant to U.S.S.G. § 2S1.1(a)(2), and the defendant knew or believed that any of the laundered funds were the proceeds of an offense involving the distribution of controlled substances, the offense level is increased by six. U.S.S.G. § 2S1.1(b)(1). 26. Specific Offense Characteristic: If the defendant is convicted under 18 U.S.C. § 1956, two levels are added. U.S.S.G. § 2S1.1(b)(2)(B). (PSR, ¶¶ 24-26, at 8.) No other adjustments were made to the With a offense level, so Defendant's Total Offense Level was 22. Criminal History Category of I, Defendant was sentenced at the bottom of the guideline range of 41-51 months. Defendant argues that her sentence "was based on and increased by facts not included in the charging instrument, proven beyond a reasonable doubt, or admitted to in any knowing or voluntary manner by Ms. King." (# 547, at 42.) Thus, she asserts that her Fifth She contends that her and Sixth Amendment rights were violated. attorney was ineffective for not raising this challenge to her sentence. Id., at 44. Even if her attorney was not ineffective, Defendant claims that her sentence violated her constitutional rights. Id., at 47. The United States responds that this argument was raised in Defendant's direct appeal and cannot be raised again on collateral attack (# 564, at 2-3, 5). 32 The Fourth Circuit upheld Defendant's sentence. King's first claim on appeal is that her sentence is unreasonable. After the Supreme Court's decision in United States v. Booker, 543 U.S. 220, 125 S. Ct. 738, 160 L. Ed.2d 621 (2005), a sentencing court is no longer bound by the range prescribed by the sentencing guidelines. See United States v. Hughes, 401 F.3d 540, 546 (4th Cir. 2005). However, in determining a sentence post-Booker, sentencing courts are still required to calculate and consider the guideline range prescribed thereby as well as the factors set forth in 18 U.S.C. A. § 3553(a)(West 2000 & Supp. 2005). Id. We will affirm a post-Booker sentence if it is both reasonable and within the statutorily prescribed range. Hughes, 401 F.3d at 546-47. As King's forty-one month prison sentence was within the properly calculated sentencing guideline range of 41 to 51 months' imprisonment, it is presumptively reasonable. United States v. Green, 436 F.3d 449, 457 (4th Cir.), cert. Denied, 547 U.S. 1156, 126 S. Ct. 2309, 164 L. Ed.2d 828 (2006). King has not rebutted that presumption as the district court appropriately treated the guidelines as advisory, calculated and considered the guideline range, and weighed the relevant § 3553(a) factors. King, 199 Fed. App'x at 253. The undersigned proposes that the presiding District Judge FIND that Defendant raised the reasonableness of her sentence on direct appeal and cannot raise it again on collateral review. It is respectfully RECOMMENDED that Defendant's § 2255 motion be denied. The parties are notified that this Proposed Findings and Recommendation is hereby FILED, and a copy will be submitted to the Honorable Joseph R. Goodwin, Chief United States District Judge. Pursuant to the provisions of Title 28, United States Code, Section 33 636(b)(1)(B), Rule 8(b) of the Rules Governing Proceedings in the United States District Courts Under Section 2255 of Title 28, United States Code, and Rule 45(c) of the Federal Rules of Criminal Procedure, the parties shall have ten days (filing of objections) and then three days (service/mailing) from the date of filing this Proposed Findings and Recommendation within which to file with the Clerk of this Court, specific written objections, identifying the portions of the Proposed Findings and Recommendation to which objection is made, and the basis of such objection. this time period may be granted for good cause shown. Failure to file written objections as set forth above shall constitute a waiver of de novo review by the District Court and a waiver of appellate review by the Circuit Court of Appeals. Snyder v. Ridenour, 889 F.2d 1363 (4th Cir. 1989); Thomas v. Arn, 474 U.S. 140 (1985); Wright v. Collins, 766 F.2d 841 (4th Cir. 1985); United States v. Schronce, 727 F.2d 91 (4th Cir. 1984). Copies of such Extension of objections shall be served on the United States Attorney, Chief Judge Goodwin, and this Magistrate Judge. The Clerk is directed to file this Proposed Findings and Recommendation and to mail a copy of the same to Defendant and to counsel of record. June 5, 2009 Date 34


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Internet Security Operations and Intelligence – a DA Workshop
July 19th, 2006 by SecuriTeam, Filed under: Cisco, Commentary, Culture, Insider Threat, Microsoft, Phishing, Spam, Virus, Web
the da workshop will be mostly on the subject of botnets, while touching phishing and ddos.
it will take place on august 10th, hosted by cisco in san jose with a dinner, sponsored by the isc.
participation is open only to members of closed and vetted mitigation and security operations groups.
main lineup:
"bot, botnets, sandbox, impact"
righard j. zwienenberg (norman)
"msrc malware/exploit zero day response – case studies"
greg galford (microsoft)
"the rough road around us in botnet tracking"
jose nazarijo (arbor)
"malcode toolkit profiteering:feeding the trend in m.o. from fame to fortune"
hubbard dan (websense)
case study: ***
levi gundert (us secret service)
"recent bots detection information from microsoft security products"
ziv mador (microsoft)
"security inside the router:how network gear handles ddos attacks"
barry raveendran greene (cisco)
"what keeps us up at night:
new & advanced difficult to mitigate ddos attacks"
darrel lewis (cisco)
"the global infection rate"
rick wesson (alice's registry)
"phishing and botnets organized crime:
globalization and tehnology intelligence update"
gadi evron (beyond security)
"fast-flux botnet c&c servers – detection & mitigation"
randy vaughn (baylor)
david ulevitch (everydns / opendns)
jerry dixon (dhs – us-cert)
paul vixie (isc)
the web site for the workshop is:
gadi evron,

subset: commoncrawl


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Official Name: Amazon.com, Inc.
1200 12th Ave. South, Ste. 1200
Seattle, Washington 98144
United States**
t: +1(206) 266-1000
f: +1(206) 622-2405
w: www.amazon.com
Amazon Kindle is a m2m/MVNO which uses Host network Vodafone
The Amazon Kindle is a series of e-book readers produced by www.amazon.com. Amazon Kindle devices enable users to shop for, download, browse, and read e-books,newspapers, magazines, blogs, and other digital media via wireless networking. The hardware platform, developed by Amazon.com subsidiary Lab126, began as a single device and now comprises a range of devices – most using an E Ink electronic paper display capable of rendering 16 tones to simulate reading on paper while minimizing power consumption.
This is how it works: when you buy a Kindle 3G you receive an eBook reader (or tablet as is the case with the Kindle Fire) with mobile data access enabled and ready to use. You can turn the Kindle 3G on, select a book online from the Amazon store using its browser and have it delivered in seconds, without ever coming close to a computer. This also includes subscriptions – newspapers, magazines and blogs.
At no moment you have to sign a contract with a mobile operator. You don't actually even need to know which mobile operator is your Kindle connecting to, or how much they charge for the content download (mobile data charges are already included in the book price). You don't have to insert a SIM card in your Kindle 3G (there isn't even a visible access to it). It's ready to use out of the box. All you know is that Amazon is sending the book to you "over the air", automatically charged to your Amazon account.
Amazon has relationships with more than one hundred operators all over the world, which deliver its e-books and other content to Kindles via their 3G networks. It's not the traditional MVNO relationship — Amazon only charges customers for the e-book download, not a monthly subscription fee — but it's an MVNO relationship just the same. It also happens to be the MVNO scenario that best fits Amazon's retail business strategy.
Amazon has outsourced all aspects of manufacturing for the Kindle in the UK to Qualcomm, including the MVNO management.
Amazon Kindle
Company Description: Amazon.com, Inc. (Amazon.com) operates retail Websites and offers programs that enable third parties to sell products on its Websites. The Company's retail Websites include www.amazon.com, www.amazon.ca, www.amazon.de, www.amazon.fr, www.amazon.co.jp, www.amazon.co.uk, www.joyo.com, www.shopbop.com and www.endless.com. Amazon.com also provides services for third-party retailers, marketing and promotional services, and Web services for developers. In addition, the Company operates other Websites, including www.a9.com and www.alexa.com that enable search and navigation and www.imdb.com, a movie database. Amazon.com has organized its operations into two principal segments: North America and International. The North America segment includes www.amazon.com and www.amazon.ca. The International segment includes www.amazon.co.uk, www.amazon.de, www.amazon.fr, www.amazon.co.jp and www.joyo.com. In May 2007, Amazon.com acquired www.dpreview.com, a site for digital camera information and reviews.
Mobile, VoIP, Fixed Line, IT Support, Mobile Broadband, Vodafone One Net, Vodafone One Net Express, Vodafone 'Red Business' mobile tariff, Vehicle Tracking and Mobile Tracking, Cloud computing – Microsoft 365
View Amazon Kindle's LinkedIN profile page
View Amazon Kindles tags on PrepaidMVNO
View Amazon Inc., Company's ZoomInfo Profile
Network: Vodafone
Services; N/A, Data Only
Status: Active


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Sci-Fi, Fantasy & Horror Reviews
Book Review: The Last Grave
By Sandy Amazeen Feb 27, 2013, 8:35 GMT
Samantha Ryan-homicide detective by choice, witch hunter by necessity-has left Salem for San Francisco, hoping a move will help her forget the horrors of her past. But she\'s about to discover that witches tempted by the dark side are everywhere.... Samantha is doing whatever she can to forget her terrible childhood in a coven destroyed by its members\' greed and lust for power. Now she\'s a San Francisco ...more
After Samanthas mother and fellow coven members nearly killed her in an attempt to raise a demon, the young witch swore off magic. As she grew to adulthood, Samantha became adept at hiding her background and began working for the Boston Police Department. Pressured to use her abilities on a case cost Samantha the trust of fellow officers and led to being reassigned to San Francisco. While investigating a bizarre murder, Samantha detects the use of black magic and as the investigation deepens, she encounters a powerful coven is responsible for a string of unusual earthquakes. Not only are they earthquakes in the classic sense but they also alter time. Pitted against an impossibly strong witch, Samantha is forced to rely on her considerable power but it comes with a price. To further confound things, Samantha keeps finding the words, the last grave wherever there has been strong magic use. With a powerful demon looking to escape his mountain cage, Samantha will have to look deep into her past and open doors best left closed if she is to assist another witch in defeating the covens plans and keeping the creature captive.
Viguies second installment of the Witch Hunt series will capture readers attention in the first chapter and builds from there. Although Samantha tries hard not to use magic, it appears the universe has other plans as she constantly faces difficult choices and not using her gifts could get people killed. The timequakes are an interesting addition, especially at the conclusion which throws a bit of a curve. Cat lovers will be jealous they cant conjure a Freaky Kitty of their own; he is a sweet little touch. Plenty of magical action, a few needy characters, Samanthas new partner and revelations behind the meaning of the last grave make for another strong addition to the series.
Like this article? Please share on Facebook and give Monsters & Critics a "Like" too!
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Pope Francis urges Christians to have joy over CrossMar 24, 2013 - 05:54 am .- Pope Francis declared on Palm Sunday that Christians must not be sad or discouraged but filled with joy because Jesus conquered evil and every sin "with the force of God's love."
Pope's retreat focuses on faces of God and manFeb 18, 2013 - 07:54 am .- Along with the rest of the Roman Curia, Pope Benedict XVI began his second day of spiritual exercises by reflecting on Psalm 119 and the "light that breaks the darkness, especially in today's culture."
Alligator OK to eat on Lenten Fridays, archbishop clarifiesFeb 15, 2013 - 04:05 pm .- Alligator is permissible to eat on Fridays of Lent, the archbishop of New Orleans assured a conscientious parishioner, and his approval has been backed by the national bishops' conference.
Benedictine abbot sees good reasons for moving Pope's MassFeb 13, 2013 - 04:05 pm .- Given the number of people that inevitably swarmed to the Holy Father's last public Mass, Benedictine Abbot Nokter Wolf understands why his monastery did not host the Pope.
Pope's last Mass will be on Ash Wednesday in St. Peter'sFeb 12, 2013 - 08:28 am .- Amid the buzz created by the Pope's announcement that he will retire, it could be easy to miss the fact that his last Mass will be on Ash Wednesday and not in the normal location for the first day of Lent.
Pope's Lent message: charity is extension of God's loveFeb 1, 2013 - 11:05 am .- Pope Benedict XVI's message for Lent is that when people are open to God's love, then they can "love with him, in him and like him."
CRS Rice Bowl program has new internet componentOct 18, 2012 - 02:03 am .- Catholic Relief Services has revamped its traditional Lenten anti-hunger Operation Rice Bowl program to allow participants to register their rice bowls on the internet as part of the campaign to feed the hungry.
Papal preacher's homily themes for Lent 2012 revealedMar 1, 2012 - 04:02 pm .- The Preacher to the Papal Household has revealed the topics for the four homilies he will preach to Pope Benedict XVI during Lent.
Pope says ashes symbolize austerity and resurrectionFeb 22, 2012 - 01:31 pm .- Like millions of Catholics around the world, Pope Benedict XVI received ashes on Ash Wednesday. He said that they become a "sacred symbol" of austerity which reflects both the "curse" of sin and the promise of the resurrection in a fallen world.
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Advice from three of our guy friends. This week they answer the following: "Is there such a thing as too much sex for a guy? Or will men generally be up for it whenever it's offered/available?"
Gay Single Guy (Daniel): THERE IS NO SUCH THING AS TOO MUCH SEX for a guy. Any man who claims the contrary might be asexual or LYING THROUGH THEIR TEETH. HOWEVER, that isn't the same as "We'll take it whenever it's offered/available." We DO have standards — even when drunk!
Straight Single Guy (Mark Luczak): I'll step past the "Too much sex? Impossible!" stereotype that guys are just one-track hornballs who don't think about anything other than where and how they can get some lovin', constantly hounding gals until they finally give it up. Hopefully we all know by now that the spectrum of sex drives runs the gamut independent of gender.
For the most part, hey, sex feels amazing, and as humans we're built to desire the connection, and the release, and everything that comes with it. So my initial thought is that "too much sex" would be a good problem to have, at least compared to "not enough sex," whatever those two relative phrases would mean to any given person. So in those contexts, I'll concede that guys will probably be generally up for it, as long as it doesn't start to negatively affect things like work and other life responsibilities – again, it's something we're designed to crave, but there has to be a balance.
Straight Married Guy (James Glazebrook): I know what my personal answer to this would be, but what if I'm abnormally low on testosterone, or technically a woman because of my tendency not to feel sexy enough, or just plain lazy? In the interest of impartiality, I opened up the question "Is there such a thing as too much sex for a guy" to readers of my blog Manflet. Unfortunately the insight of our typical reader ranged all the way from "in prison, mayhap" to a straight "no." So while I may not agree with the biological argument that men are hard-wired to screw around and women are designed to be faithful, my straw poll of "normal" guys indicates that — as suspected — they'll do it whenever, wherever, with who/whatever.
Our "guys" are a rotating group of contributors. This week's Straight Married Guy is James Glazebrook of Most Likely To; our Gay Guy is one-time stripper and sex columnist Daniel; and our Straight Single Guy is Mark Luczak, a tech geek at Carnegie Mellon University. To ask the guys your own question, click here.


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St Teilo's Church
June 2011
Hidden Splendour
Good morning. I can't stop long as there are many tasks to carry out this morning: light the incense, set up the processional cross, chalice and paten and get into 1520s costume. That itself is no mean feat, and I got up early to braid my hair medieval-style today, too. One of the Tudor Group showed me how when they were here over Easter, and she made it look really simple! I haven't quite got the hang of it, but it looks medieval enough. I hope to be up to speed for our Tudor Fashion event next month, so practice makes perfect.
Meanwhile, I am preparing a film of last year's re-enactment for the gallery's 1500-1700 exhibition. Some of my favourite Tudor objects from our collection are on display, including both surviving Rood figures from pre-reformation Wales. The Cemmaes (Kemeys) Rood was found hidden in a wall in the 1850s. Not much is known about how it came to be there. What is certain is that it's a very, very rare artefact relating to Wales' religious past.
Conservator and all-round Renaissance lady Penny Hill has worked on the sculpture, and will be joining us on Saturday to tell us more about this mysterious object. An expert on pigments and the colour of the past, Penny will be looking at the sculpture's links to places and people beyond the small parish where it was found.
I hope you'll join us on Saturday, 2pm, in Oriel 1 at St Fagans. More information is available, Monday to Friday, on 029 20 57 3424
Conserving Government Propaganda prints from the Great War
Historic Photography Project (Esmee Ffairburn)
Linking Natural Science Collections in Wales
Research in Norway and the Barents Sea
St Fagans National History Museum Making History Project
St Teilo's Church
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Dramatic upholstery-velvet in an ikat pattern of teals and light gray. Suitable for upholstery and other home decor applications.
Color: Teal
Width: 56"
Content: 32% COTTON, 50% ACRYLIC, 12% POLYESTER, 6% VISCOSE
Learn about fabric careHOW TO CARE FOR COTTON FABRICS: Machine-wash warm or cold, tumble dry. Pull straight from the dryer to prevent wrinkles, or iron while damp. Prewash cotton fabrics before cutting out your pattern Mood strongly recommends test-laundering a swatch, if you plan to wash your garment or home furnishings yourself.


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And now, it seems the red carpet is already being rolled out for baby Kimye.
Kim Kardashian and Kanye West are apparently planning to rent out an entire hospital floor when their baby is born in July...just like Beyoncé and Jay-Z did when Blue Ivy was born.
But that's not all...Kim has some additional demands for the delivery room.
A source tells the Daily Star that "Kim's been reading about how monumental the first few moments of a baby's life are and wants her child's entry to the world to be idyllic," so she's having her delivery room completely sound-proofed prior to her arrival.
The 32-year-old reality star also wants music and mood lighting for her special moment.
According to the source, "She plans to reflect the sounds of nature with a trickling water and soothing wind CD."
As for the lighting, Kim simply won't settle for the standard bright white hospital bulbs. She wants her room equipped with blue, green and purple lights to help create a more relaxing ambiance.
Do you think Kim's requests are a little over-the-top?
Gallery | Who's Got Style? Kimye Does!


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Djoudj National Bird Sanctuary World Heritage Site
Parc national des oiseaux du Djoudj, Senegal
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Parc national des oiseaux du Djoudj, Senegal
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The Djoudj National Bird Sanctuary (French: Parc national des oiseaux du Djoudj) lies on the southeast bank of the River Senegal in Senegal, in northern Biffeche, north east of St-Louis.
It provides a range of wetland habitats which prove very popular with migrating birds, many of which have just crossed the Sahara. Of almost 400 species of birds, the most visible are pelicans and flamingos. Less conspicuous are the Aquatic Warblers migrating here from Europe; for these, the park is the single most important wintering site yet discovered . A wide range of wildlife also inhabits the park, which is designated a World Heritage Site. The site was added to the list of World Heritage in Danger in 2000 due to the introduction of the invasive giant salvinia plant, which threatens to choke out the park's native vegetation. However it was removed from the list in 2006.
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Monday in photosMonday, November 4, 2013.
2 of 18
South Korean President Park Geun Hye passes the honor guards as she arrives at the Elysee Palace in Paris to meet France's President Francois Hollande, Monday, Nov. 4, 2013. Park arrived in France as part of her weeklong trip to Western Europe including Britain and Belgium. This is the first time Park has been to France in 39 years, when she returned after six months of studying upon the assassination of her mother, first lady Yook Young-soo, in 1974. (AP Photo/Michel Euler)
Photo by Michel Euler
Photo by Michel Euler
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The North Face Women's Stinson Rain Jacket
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Almost daily, I get email from friend-of-the-blog Lisa Simeone on novel ways that the national security state is eroding our liberties. But today, Lisa herself was the poster girl for the corrosion of liberty – and I read about it first on Alternet, then at War Is a Crime, not in one of Lisa's emails. It's typically, really, that Lisa is all about the principles while setting aside her private worries. Now, though, they've become a national cause celebre.
Lisa has been fired from her job as the host of the documentary program Soundprint, which is carried by NPR affliates. The reason? Her involvement in the October 2011 movement, a peaceful protest against militarism and corporate greed, which has joined forces with Occupy DC. Lisa was targeted by The Daily Caller, which accused her of conflict of ethics and possible ethics violations, suggesting she was bound by the NPR ethics code. But first, Lisa was only a freelancer, not an employee, and was evidently never warned that she could lose her job due to political activity. Moreover, Soundprint's statement seems to have a pretty tenuous relation to reality:
Soundprint is a journalistic program and Lisa's leadership role as a member of the steering committee and a spokesperson for the October 2011 protest activities, associated with the Occupy DC movement, conflicts with her role as the host of a documentary series. Soundprint adheres to the highest standards of journalism which include maintaining appropriate distance from marches, demonstrations and other political activity. These are standards held by many other journalism organizations, including National Public Radio.
Fine, but look at Soundprint's current program: the tale of a deaf septuagenarian who wants to learn to fly, and a tribute to Sir Edmund Hilary. It's obvious that Lisa couldn't be objective about Hilary! Never mind that he died three years ago; were he still with us, he'd definitely be in the 1%! Lisa introduces the story, and I'm listening really hard for her left-wing invective. Listening … oooh, straining a bit … Wait! She just called him a "humanitarian"! Surely that has a political subtext?
Lisa's other radio job, hosting the nationally-syndicated World of Opera program, is hanging in the balance as well, though so far it looks like its sponsoring station is resisting pressure from NPR.
Lisa points out in her interview with War Is a Crime that NPR is applying a wildly inconsistent standard, allowing some of their regular employees who actually report on current events to pontificate on Fox:
"I find it puzzling that NPR objects to my exercising my rights as an American citizen — the right to free speech, the right to peaceable assembly — on my own time in my own life. I'm not an NPR employee. I'm a freelancer. NPR doesn't pay me. I'm also not a news reporter. I don't cover politics. I've never brought a whiff of my political activities into the work I've done for NPR World of Opera. What is NPR afraid I'll do — insert a seditious comment into a synopsis of Madame Butterfly?
"This sudden concern with my political activities is also surprising in light of the fact that Mara Liaason reports on politics for NPR yet appears as a commentator on FoxTV, Scott Simon hosts an NPR news show yet writes political op-eds for national newspapers, Cokie Roberts reports on politics for NPR yet accepts large speaking fees from businesses. Does NPR also send out 'Communications Alerts' about their activities?"
Yep, knowing Lisa, I think Madame Butterfly is about to be Occupied. (But there likely won't be any tents involved. Like me, Lisa enjoys, needs, appreciates, and once again NEEDS a decent bed at night. I sometimes think a good mattress is one of the top three secret clues to vitality in one's 40s and beyond.)
But seriously: It remains a mystery how Soundprint arrived at the conclusion that Lisa's activism collided with the NPR ethics code. NPR denies having even contacted Soundprint. And vice versa. How to explain? Might I smell a whiff of Breitbart and his ilk? The earliest smear job I found on Lisa s a piece by Neda Samnani at Roll Call, dramatically dated "October 18, midnight," insinuating that of course Lisa committed an ethical breach, because if she's on radio, then she must be, well, a reporter.
Ethics codes have a place in journalism, but Lisa was not exactly committing journalism. Lisa was doing cultural programming. Nor are ethics codes the be-all and end-all of media ethics. If they're relevant to Lisa's current work, they must equally apply to Ira Glass and Garrison Keillor at Lake Woebegone. The last time we heard about Keillor's religious prejudices, there were consequences! ripple effects! an article in Salon … and not a blip in his contract.
So much still is shrouded in obfuscation. I am hoping Lisa will find time to fire off one of her emails, just like she does whenever she sees someone else's rights being abrogated. I'm sure she's pretty overwhelmed. There could also be a lawsuit brewing.
Given that we may need to wait on the facts, it's half-past midnight (see, we can do her detractors one better – nay, 30 minutes better!). It time to rally to her cause. I just wrote the following to NPR:
I know Lisa. She's whip-smart and highly principled. Her work is consistently thoughtful, fair, professional, and easy on the ears. I was thus dismayed to hear that Soundprint fired her for her engagement in October 2011. Despite her history of activism, she hasn't let her personal politics bleed into her professional work.
I'm so pleased that WDAV has not yet bowed to pressure to fire Lisa, who has done nothing wrong. Please support WDAV in their loyalty to Lisa. And while you're at it, might you ask Soundprint to reconsider their hasty decision to fire her? There's a difference between a reporter who covers hard news and a radio host of cultural programming. Lisa's work falls in the latter category. I respect the reasons why NPR has an ethics code (even though I also know that real media ethics are more complex than a mere set of rules). However, as a freelancer who didn't report on hard news, Lisa should not be muzzled in her private life as a citizen in the name of "objectivity." Doing so just makes her former employer/client appear petty and, frankly, scared of right-wing bloggers and pundits.
Bring back Lisa Simeone! [Okay, I admit to trying to play the diplomat. "Horseshit" tends not to fly as an actual argument, except from my dissertation advisor who made it work beautifully.]
You can contact NPR here. To their credit, WDAV seems to get it (way more than NPR does!), as you can read here. Thankfully, comments are running overwhelmingly in favor of Lisa. But don't hesitate to add yours, too, if you've appreciated her comments here or her work elsewhere.
And also: Hugs to you, Lisa. Count me among your friends and fans who love you and will stand with you – chin up and boobs out, as a friend of mine loves to say. Brava, for your passion, commitment, principles, and love of liberty. This panic from our overlords? I read it as a sign that we've got them rattled.
I hope you'll weigh in once the worst of the madness subsides. Until then, sending hugs and virtual chocolate while posting madly on Facebook about this travesty.


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It's more than a year since I last posted the PR38.
Well, here's my new Colnago..
Just can't deny the fact that nothing rides like a Colnago..
having ridden a significant fleet of high-end bikes, a Colnago's handling is simply top notch especially in smaller sizes.
here's the built list
1. Colnago C50 '08, size 51/ 52.7cm horizontal top tube / Carbon 75 fork
2. Campagnolo SR 2011 groupset
3. Selle Italia SLR C64
4. Colnago 28mm seatpost by WR Compositi
5. Easton EC90 in 42cm end to end.
6. Extralite OC 100mm stem
7. Chris King sotte voce 1 1/8inch/ black
8. BTP Cage
9. Look Keo Blade Ti
10. AX Orion
11. LW Std Gen III tubulars
12. Tune skewers
13. Cateye Strada Wireless
Total weight: 13.56lbs / 6150 grams.
Enjoy the pics.
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raid-1 on ubuntu 12.04
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9th December 2012, 23:41
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Join Date: Dec 2012
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adding main device into raid-array not working
This command is successful:
mdadm --create /dev/md0 --level=1 --raid-disks=2 missing /dev/sdb1
However when I am trying to add the main device with this command:
mdadm --add /dev/md0 /dev/sda1
I get an error message that the device is busy.
Should I execute the whole tutorial from a live cd ?? But then all the configurations would happen on the system of the live cd not the installed one...
Any tip would be greatly appreciated!
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text: Strict Standards: Redefining already defined constructor for class XML_Parser in /home/sites/www.americanpoems.com/web/store/aom/includes/os.php on line 1188 Strict Standards: Declaration of XML_Parser::raiseError() should be compatible with PEAR::raiseError($message = NULL, $code = NULL, $mode = NULL, $options = NULL, $userinfo = NULL, $error_class = NULL, $skipmsg = false) in /home/sites/www.americanpoems.com/web/store/aom/includes/os.php on line 1604 Strict Standards: Declaration of XML_Unserializer::startHandler() should be compatible with XML_Parser::startHandler($xp, $elem, &$attribs) in /home/sites/www.americanpoems.com/web/store/aom/includes/os.php on line 3503 Strict Standards: Declaration of Cache_Lite_File::get() should be compatible with Cache_Lite::get($id, $group = 'default', $doNotTestCacheValidity = false) in /home/sites/www.americanpoems.com/web/store/aom/includes/cache.php on line 1020 American Poems: DVD: Shutter Island [Blu-ray] Home Apparel Appliances Books DVD Electronics Home & Garden Kindle eBooks Magazines Music Outdoor Living Software Tools & Hardware PC & Video Games Search All Products Apparel Appliances Arts & Crafts Automotive Baby Beauty Books Computers DVD Electronics Gourmet Food Grocery Health Home & Garden Industrial & Science Jewelry Kindle eBooks Kitchen Magazines Miscellaneous Mobile Apps MP3 Downloads Music Musical Instruments Office Products Outdoor Living Pet Supplies Photo & Camera Shoes Software Sporting Goods Tools & Hardware Toys VHS Video On Demand PC & Video Games Watches Wireless Wireless Accessories Advanced Search Sitemap View Cart Checkout Location: Home » DVD » Shutter Island [Blu-ray] Shutter Island [Blu-ray] enlarge Director:Martin Scorsese Actors:Leonardo Dicaprio Ben Kingsley Emily Mortimer Mark Ruffalo Max Von Sydow Studio:Warner Bros. Category:DVD List Price: $9.98 Buy New: $3.98 as of 12/26/2014 05:56 EST details You Save: $6.00 (60%) In Stock New (33) Used (29) from $3.74 Seller:tvtop20 Sales Rank:7,455 Format:Multiple Formats, Blu-ray, NTSC, Widescreen Languages:English (Subtitled), French (Subtitled), Spanish (Subtitled), Portuguese (Subtitled), English (Original Language), French (Dubbed), Spanish (Dubbed), Portuguese (Dubbed) Color:color Media:Blu-ray Number Of Discs:1 Running Time:138 Minutes Rating:R (Restricted) Region:1 Discs:1 Aspect Ratio:1.77:1 Shipping Weight (lbs):0.2 Dimensions (in):6.8 x 5.3 x 0.4 Release Date:June 8, 2010 MPN:PTCA1000370186BR UPC:883929300860 EAN:0883929300860 ASIN:B00AEBBA68 Availability:Usually ships in 1-2 business days Features: Brand Name: Ingram Entertainment Mfg#: 883929300860 Shipping Weight: 0.37 lbs Manufacturer: Genre: MYSTERY/SUSPENSE All music products are properly licensed and guaranteed authentic. Similar Items: Inception (Blu-ray) Gangs of New York (Miramax Award-Winning Collection) [Blu-ray] The Departed [Blu-ray] The Prestige [Blu-ray] The Book of Eli [Blu-ray] Editorial Reviews: SynopsisShutter Island (BD) CERTAIN CONTENT THAT APPEARS ON THIS SITE COMES FROM AMAZON SERVICES LLC. THIS CONTENT IS PROVIDED 'AS IS' AND IS SUBJECT TO CHANGE OR REMOVAL AT ANY TIME. Brought to you by American Poems Categories •Apparel •Appliances •Arts & Crafts •Automotive •Baby •Beauty •Books •Computers •DVD •Electronics •Gourmet Food •Grocery •Health •Home & Garden •Industrial & Science •Jewelry •Kindle eBooks •Kitchen •Magazines •Miscellaneous •Mobile Apps •MP3 Downloads •Music •Musical Instruments •Office Products •Outdoor Living •Pet Supplies •Photo & Camera •Shoes •Software •Sporting Goods •Tools & Hardware •Toys •VHS •Video On Demand •PC & Video Games •Watches •Wireless •Wireless Accessories Related Categories •Movies Departments Movies & TV •Movies Blu-ray Custom Stores Specialty Stores Movies & TV •Drama Genre for Featured Categories Custom Stores Specialty Stores Movies & TV •Mystery & Thrillers Genre for Featured Categories Custom Stores Specialty Stores Movies & TV •All Titles Warner Home Video Studio Specials DVD Custom Stores Custom Stores •Drama Warner Home Video Studio Specials DVD Custom Stores Custom Stores •Blu-ray Formats DVD Custom Stores Custom Stores Specialty Stores •Movies & TV on DVD and Blu-ray Disc Trade-In DVD Custom Stores Custom Stores Specialty Stores Movies & TV


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