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IN THE SUPREME COURT OF FLORIDA CASE NO.: SC (L. T. Case No.: 4D ) ON APPEAL FROM FOURTH DISTRICT COURT OF APPEAL
- Warren Logan
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1 IN THE SUPREME COURT OF FLORIDA STATE OF FLORIDA, Petitioner, CASE NO.: SC (L. T. Case No.: 4D ) vs. GLENN KELLY, Respondent. / ON APPEAL FROM FOURTH DISTRICT COURT OF APPEAL ANSWER BRIEF OF RESPONDENT FRANK A. MAISTER, ESQ. GARRETT ELSINGER, ESQ. Attorney for Respondent Attorney for Respondent 315 Southeast 7 th Street 633 Southeast Third Avenue Suite 302 Suite 4F Fort Lauderdale, Florida, Fort Lauderdale, FL Telephone: (954) Telephone: (954) Facsimile: (954) Facsimile: (954) Florida Bar No Florida Bar No
3 TABLE OF CITATIONS Cases Page(s) Alexander v. Anchorage, 490 P.2d 910, 913 (Alaska 1971).20 Alabama v. Shelton, 535 U.S. 654, 122 S.Ct (2002)..17,18,19,20,21,22 Andres v. State, 898 So.2d 256 (Fla. 4 th DCA 2005) 22 Argersinger v. Hamlin, 407 U.S. 25, 92 S.Ct (1972)..19 Baldasar v. Illinois, 446 U.S. 222, 100 S. Ct (1980).. 10,15 Brunson v. State, 182 Ind.App. 146, 149, 394 N.E.2d 229, 231 (1979).20 Case v. State, 865 So.2d 557 (Fla. 1 st DCA 2003) 21 Hlad v. State, 585 So.2d 928 (Fla. 1991) ,16 Kirby v. State, 765 So. 2d 723 (Fla. 1 st DCA 1999) ,16,17 Nichols v. United States, 511 U.S. 738, 114 S. Ct (1994) 10,15,16,17,18,19,20,21 New Jersey State v. Hrycak, 184 N.J. 351, , 877 A.2d 1209 (N.J. Jul 20, 2005). 21 Parson v. State, 913 So.2d 1270 (Fla.4 th DCA 2005) 22 Perry v. State, 900 So. 2d 755 (Fla. 4 th DCA 2005) Perriello v. State, 684 So.2d 258, 260 (Fla. 4th DCA 1996)
4 State v. Beach, 592 So.2d 237 (Fla. 1992)...10,16,17 State v. Douse, 448 So.2d 1184 (Fla. 4th DCA 1984) State v. Hermanns, 278 N.J.Super. 19, 29, 650 A.2d 360, 366 (1994)...20 State v. Kirby, 761 So. 2d 332 (Fla. Feb. 11,2000) 15 State v. Kirby, 767 So. 2d 461 (Fla. June 21, 2000) State v. Rodriguez, 575 So.2d 1262, (Fla.1991). 19,21 State v. Woodruff, 676 So. 2d 975 (Fla. 1996) Tracy v. Municipal Court for Glendale Judicial Dist., 22 Cal.3d 760, 766, 150 Cal.Rptr. 785, 587 P.2d 227, 230 (1978). 20 Traylor v. State, 596 So.2d 957, 967 (Fla.1992) United States v. Watts, 519 U.S. 148, 157, 117 S.Ct. 633, 136 L.Ed.2d 554 (1997)..18 Williams v. New York, 337 U.S. 241, 69 S.Ct. 1079, 93 L.Ed (1949)..18 MISCELLANEOUS Ala.Code 13A-6-22, 13A-5-7(a)(1), 13A-5-12(a)(1) (1994).17 Ala.Code (1995)..17 Ala.Code (1995)...17 Cal.Penal Code Ann. 686 (West 1985) Del.Code Ann., Tit. 29, 4602 (1997)...20 D.C.Code Ann (West 2001). 20 4
5 Florida Constitution, Article I, Section Florida Statute Florida Statute Florida Statute Florida Rule of Criminal Procedure ,12,22 Florida Rule of Criminal Procedure ,22 Florida Rule of Criminal Procedure Haw.Rev.Stat (1999).. 20 Ill. Comp. Stat., ch. 725, (1992)...20 Ind. Const., Art. I, Ky.Rev.Stat. Ann (4)(b), (1) (West 1999) La. Const., Art. I, Mass. Rule Crim. Proc. 8 (2001) Minn. Rule Crim. Proc. 5.02(1) (2001).. 20 N.C. Gen.Stat. 7A-451(a)(1) (1999) Neb.Rev.Stat (1995). 20 N.J. Stat. Ann. 2A:158A-5.2 (1985)...20 N.Y.Crim. Proc. Law (3)(c) (West 1993). 20 Okla. Stat., Tit. 22, A (West Supp.2002).21 Ore.Rev.Stat. Ann (4) (Supp.1998) Tenn. Sup.Ct. Rule 13(d)(1) (2001) 21 5
6 Tex.Code Crim. Proc. Ann., Art (b)(3) (Vernon Supp.2002)...21 Va.Code Ann , (2000).21 Vt. Stat. Ann., Tit. 13, 5201 (1998) Wash.Super. Ct.Crim. Rule 3.1(a) (2002)..21 W. Va.Code (2000)..21 Wis. Stat (1998)..21 Wyo. Stat. Ann (2001)..21 6
7 PRELIMINARY STATEMENT Petitioner, the State of Florida, was the prosecution and Respondent was the Defendant in the trial court, the Circuit Court of the Seventeenth Judicial Circuit, in and for Broward County, Florida. In the brief, the parties will be referred to as they appear before this Honorable Court of Appeal, except that Petitioner may also be referred to as the State and Respondent as the Defendant. The following symbols will be used: R= Record T=Transcript 7
8 STATEMENT OF THE CASE AND FACTS On or about January 18, 2003, the Defendant, GLENN KELLY, was arrested for the offense of Driving Under the Influence of Alcohol. [R. 1] On or about February 14, 2003, the State filed an Information in County Court charging the Defendant with one Count of Driving Under the Influence of Alcohol. [R. 152] A year later, the State entered a nolle prosse on the misdemeanor case and on April 26, 2004, refiled in Circuit Court alleging a Felony DUI. [R. 4, 152] The Felony Driving Under the Influence count alleged that the defendant had been thrice previously convicted of Driving Under the Influence of Alcohol; on October 27, 1987, on March 2, 1995, and on September 18, 1997, all in Broward County, Florida. [R. 4] On October 21, 2005, the Defendant filed a Motion to Dismiss for Lack of Jurisdiction of the Circuit Court, arguing that his 1995 and 1997 convictions for DUI could not be used to enhance the pending DUI charge to a felony. Attached to the Motion was an affidavit, executed by the Defendant establishing that at the time he pled to those two DUIs, the charges were punishable by more than six months imprisonment, he was 8
9 indigent, counsel was not appointed and he did not validly waive his right to counsel. [R ] An evidentiary hearing was held on February 24, 2006, at which time it was established that at an arraignment on March 2, 1995, the Defendant pled no contest in Broward County Court to a charge of Driving Under the Influence of Alcohol. [T. 21] This was his second conviction for DUI and thus this charge was punishable by more than six months imprisonment. The Defendant was indigent at the time of the plea, counsel was not appointed and the defendant did not validly waive his right to counsel. The Defendant signed a plea form which incorrectly advised him that he was entitled to a court appointed attorney if he could not afford one and if the Judge is considering a jail sentence on this charge. (emphasis added) [T. 24] It was also established that at his arraignment on September 18, 1997, the Defendant pled no contest in Broward County Court to a charge of Driving Under the Influence of Alcohol. This was his third conviction for DUI and thus this charge was punishable by more than six months imprisonment. The Defendant was indigent at the time of the plea, counsel was not appointed and the defendant did not validly waive his right to counsel. The Defendant again signed a plea form which again incorrectly 9
10 advised him that he was entitled to a court appointed attorney if he could not afford one and if the Judge is considering a jail sentence on this charge. (emphasis added) [T. 26] He had received a similar admonition in 1987 when he pled to his first DUI uncounselled and at arraignment. [T. 29] On February 24, 2006, after hearing argument of counsel and reviewing the case law submitted, [T. 41] the trial court entered a written order granting the Defendant s Motion to Dismiss. [R. 181] The State appealed. On appeal, the Fourth District affirmed based on this Court s decisions in Hlad v. State, 585 So.2d 928, (Fla. 1991) and State v. Beach, 592 So.2d 237 (Fla. 1992), but did note that those decisions had relied in large part upon the United States Supreme Court s decision in Baldasar v. Illinois, 446 U.S. 222 (1980). The Fourth District recognized that Baldasar was overruled by the United States Supreme Court in Nichols v. United States, 511 U.S. 738, 114 S. Ct (1994), but that Nichols explicitly left the states free to guarantee a right to counsel for indigent defendants charged with misdemeanors who are not imprisoned, and held that the trial court was correct to follow Hlad. Accordingly, the Fourth District affirmed the trial court s ruling granting the Defendant s Motion to Dismiss, and certified the issue to this Court. 10
11 SUMMARY OF THE ARGUMENT The certified question must be answered in the negative. Florida has granted to its citizens greater protections under its Constitution and by statute than the United States does under the Sixth Amendment. Florida cases recognize a distinct guarantee in the Florida Constitution of appointed counsel under certain circumstances. Florida has decided based on the Constitution and public policy that counsel should be available for all indigent defendants charged with misdemeanors. 11
12 ARGUMENT THE QUESTION CERTIFIED BY THE FOURTH DISTRICT COURT OF APPEAL MUST BE ANSWERED IN THE NEGATIVE. UNDER ESTABLISHED FLORIDA LAW AN UNCOUSELED PRIOR CONVICTION IN WHICH THE DEFENDANT COULD HAVE BEEN INCARCERATED FOR MORE THAN SIX MONTHS, BUT WAS NOT INCARCERATED FOR ANY PERIOD, CANNOT BE USED TO ENHANCE A CURRENT CHARGE FROM A MISDEMEANOR TO A FELONY In relevant part, Article I, Section 16 of the Florida Constitution, entitled Rights of accused and of victims, grants to the citizens of Florida the right to counsel in all criminal prosecutions. In all criminal prosecutions the accused shall, upon demand, be informed of the nature and cause of the accusation, and shall be furnished a copy of the charges, and shall have the right to have compulsory process for witnesses, to confront at trial adverse witnesses, to be heard in person, by counsel or both, and to have a speedy and public trial by impartial jury in the county where the crime was committed... Furthermore, in Florida Rule of Criminal Procedure 3.111(b)(1), the legislature has mandated that, Counsel shall be provided to indigent persons in all prosecutions for offenses punishable by incarceration including appeals from the conviction thereof. In the discretion of the court, counsel does not have to be provided to an indigent person in a prosecution for a misdemeanor or violation of a municipal ordinance if the judge, at least 15 days prior to trial, files in the cause a written order of no incarceration certifying that the defendant will not be incarcerated in the case pending trial or probation violation hearing, or as part of a sentence after trial, guilty or nolo contendere plea, or probation 12
13 revocation. This 15-day requirement may be waived by the defendant or defense counsel. (emphasis added). And in Florida Rule of Criminal Procedure 3.160(e) the legislature has provided that, (e) Defendant Not Represented by Counsel. Prior to arraignment of any person charged with the commission of a crime, if he or she is not represented by counsel, the court shall advise the person of the right to counsel and, if he or she is financially unable to obtain counsel, of the right to be assigned court-appointed counsel to represent him or her at the arraignment and at all subsequent proceedings. The person shall execute an affidavit that he or she is unable financially or otherwise to obtain counsel, and if the court shall determine the reason to be true, the court shall appoint counsel to represent the person. (emphasis added). If the defendant, however, understandingly waives representation by counsel, he or she shall execute a written waiver of such representation, which shall be filed in the case. If counsel is appointed, a reasonable time shall be accorded to counsel before the defendant shall be required to plead to the indictment or information on which he or she is to be arraigned or tried, or otherwise to proceed further. Pursuant to these statutes, the appointment of counsel is a compulsory act in all misdemeanor cases, an act which the trial court must perform and which can only be waived in a misdemeanor case upon the filing of either a written certification by the Judge that the Defendant shall never be incarcerated in the case, or if after a thorough colloquy by the Court and a finding that the Defendant understands his rights, the Defendant executes a written waiver of his rights. See, e.g. Perry v. State, 13
14 900 So. 2d 755 (Fla. 4 th DCA 2005); Perriello v. State, 684 So.2d 258, 260 (Fla. 4th DCA 1996) the language of rule 3.172(c) is mandatory. The rule does not permit a written plea agreement to substitute for an on-the-record plea colloquy. Obviously, a waiver form which misinforms a criminal defendant of his right to counsel, cannot provide the basis for an understanding waiver of that right. Finally, Florida Statute Section provides that: (1) The public defender shall represent, without additional compensation, any person determined to be indigent under s and: (a) Under arrest for, or charged with, a felony; (b) Under arrest for, or charged with: 1. A misdemeanor authorized for prosecution by the state attorney; 2. A violation of chapter 316 punishable by imprisonment; 3. Criminal contempt; or 4. A violation of a special law or county or municipal ordinance ancillary to a state charge, or if not ancillary to a state charge, only if the public defender contracts with the county or municipality to provide representation pursuant to ss and The public defender shall not provide representation pursuant to this paragraph if the court, prior to trial, files in the cause an order of no imprisonment as provided in s Interestingly, and perhaps in acknowledgement of the particular complexity of DUI cases, section specifically mandates that the 14
15 Public Defender shall represent persons facing imprisonment under chapter 316, Florida Statutes. In Kirby v. State, 765 So. 2d 723 (Fla. 1 st DCA 1999), rev granted in State v. Kirby, 761 So. 2d 332 (Fla. Feb. 11, 2000), rev. denied by State v. Kirby, 767 So. 2d 461 (Fla. June 21, 2000), the Defendant appealed his felony conviction for Driving Under the Influence. He filed a Motion to Dismiss in the Circuit Court, accompanied by an Affidavit that asserted that his 1982 misdemeanor conviction met the criteria enunciated in State v. Beach, 592 So.2d 237 (Fla. 1992). See Kirby at 724. In Kirby, the First District considered Beach s continued viability after the United States Supreme Court s decision in Nichols v. United States, 511 U.S. 738, 114 S. Ct (1994). Id. at 723. In Kirby, the State contended that Kirby s allegation that the offense in question was punishable by more than six (6) months of imprisonment was insufficient, and that actual incarceration must be imposed to meet the appropriate criteria. The Kirby Court agreed with the State s premise that Nichols expressly overruled Baldasar v. Illinois, 446 U.S. 222 (1980) to remove any Federal constitutional impediment to using Mr. Kirby s 1982 conviction as a predicate for the conviction under review. Id. at 724. The 15
16 Kirby Court pointed out, however, that Nichols made it clear that, States may decide based on their own constitutions or public policy, that counsel should be available for all indigent defendants charged with misdemeanors, Nichols at 748, n. 12, and went on to elucidate that, cases recognize a distinct guarantee in the Florida Constitution of appointed counsel under certain circumstances. See Traylor v. State, 596 So.2d 957, 967 (Fla.1992) ( In all criminal prosecutions, the defendant may choose to be heard either by himself or through counsel. ) (paraphrasing article 1, section 16 of the Florida Constitution); State v. Douse, 448 So.2d 1184 (Fla. 4th DCA 1984). Id. at 725. Ultimately the Kirby Court held that, we do not read the decision in Nichols as authority to disregard our own Supreme Court s decision in Beach but did certify the following question to this Court: DOES STATE V. BEACH, 592 So.2d 237 (Fla. 1992), ARTICLE I, SECTION 16 OF THE FLORIDA CONSTITUTION, SECTION FLORIDA STATUTES (1997), FLORIDA RULE OF CRIMINAL PROCEDURE 3.111, OR ANY COMBINATION THEREOF PRECLUDE USING UNCOUNSELED CONVICTIONS AS PREDICATES FOR A FELONY CONVICTION EVEN THOUGH THE UNCOUNSELED CONVICTION DID NOT RESULT IN INCARCERATION AT THAT TIME? This Court initially accepted review of Kirby but then subsequently denied review, letting stand the holding in Kirby that Florida Courts were not free to disregard Beach and Hlad, even after Nichols. 16
17 Respondent reiterates the Kirby Court s analysis that individual States confer greater protection in regards to these issues in their State Constitutions than those contained in the Federal Constitution and that Florida s Constitution protects those who meet the Beach criteria regardless of the issue of actual incarceration. Nichols itself acknowledged that many, if not a majority, of States guarantee the right to counsel whenever imprisonment is authorized by Statute, rather than [only when] actually imposed. Nichols at 748. The issue as to when an indigent accused may be convicted of a criminal offense without counsel was revisited when the United States Supreme Court decided Alabama v. Shelton, 535 U.S. 654, 122 S.Ct (2002). After representing himself at a bench trial in the District Court of Etowah County, Alabama, Shelton was convicted of third-degree assault, a class A misdemeanor carrying a maximum punishment of one year imprisonment and a $2,000 fine, Ala.Code 13A-6-22, 13A-5-7(a)(1), 13A-5-12(a)(1) (1994). He invoked his right to a new trial before a jury in Circuit Court, Ala.Code (1995), where he again appeared without a lawyer and was again convicted. The court repeatedly warned Shelton about the problems selfrepresentation entailed, see App. 9, but at no time offered him assistance of counsel at state expense. The Circuit Court sentenced Shelton to serve 30 days in the county prison. As authorized by Alabama law, however, Ala.Code (1995), the court suspended that sentence and placed Shelton on two years' unsupervised probation, conditioned on his payment of 17
18 court costs, a $500 fine, reparations of $25, and restitution in the amount of $ Justice Ginsburg, writing for the majority in Shelton noted that the particular question the Court had decided in Nichols was: whether the Sixth Amendment barred consideration of a defendant's prior uncounseled misdemeanor conviction in determining his sentence for a subsequent felony offense. 511 U.S., at 740, 114 S.Ct Nichols pleaded guilty to federal felony drug charges. Several years earlier, unrepresented by counsel, he was fined but not incarcerated for the state misdemeanor of driving under the influence (DUI). Including the DUI conviction in the federal Sentencing Guidelines calculation allowed the trial court to impose a sentence for the felony drug conviction 25 months longer than if the misdemeanor conviction had not been considered. Id., at 741, 114 S.Ct We upheld this result, concluding that an uncounseled misdemeanor conviction, valid under Scott because no prison term was imposed, is also valid when used to enhance punishment at a subsequent conviction. Justice Ginsburg continued that: Nichols is further distinguishable for the related reason that the Court there applied a less exacting standard consistent with the traditional understanding of the sentencing process. 511 U.S., at 747, 114 S.Ct Once guilt has been established, we noted in Nichols, sentencing courts may take into account not only a defendant's prior convictions, but... also [his] past criminal behavior, even if no conviction resulted from that behavior. Ibid. Thus, in accord with due process, Nichols could have been sentenced more severely based simply on evidence of the underlying conduct that gave rise to his previous conviction, id., at 748, 114 S.Ct (emphasis added), even if he had never been charged with that conduct, Williams v. New York, 337 U.S. 241, 69 S.Ct. 1079, 93 L.Ed (1949), and even if he had been acquitted of the misdemeanor with the aid of appointed counsel, United States v. Watts, 519 U.S. 148, 157, 117 S.Ct. 633, 136 L.Ed.2d 554 (1997) (per curiam) 18
19 That relaxed standard has no application in this case, where the question is whether the defendant may be jailed absent a conviction credited as reliable because the defendant had access to the guiding hand of counsel, Argersinger, 407 U.S., at 40, 92 S.Ct (internal quotation marks omitted). The fact pattern which led to the result in Nichols, is therefore framed entirely as an issue of sentencing, and Federal sentencing at that. The prior uncounseled conviction at issue in Nichols did not become relevant in the case until Nichols was convicted for his current charge. At that point the sentencing Court was free to consider that conviction, just as the Court would have been free to consider uncharged or non-criminal conduct relevant in any sentencing proceeding. In the case at bar, however, Kelly s prior uncounseled convictions become relevant at the time the instant charges are filed, by conferring jurisdiction on the Circuit Court, and turning a misdemeanor into a felony. 1996), As this Court wrote in State v. Woodruff, 676 So. 2d 975 (Fla. We reject the district court of appeal's determination that the only difference between the two offenses is the severity of punishment. Felony DUI requires proof of an additional element that misdemeanor DUI does not: the existence of three or more prior misdemeanor DUI convictions (2)(b), Fla.Stat. (1991) (sic); see also State v. Rodriguez, 575 So.2d 1262, (Fla.1991)... Felony DUI is therefore a completely separate offense from misdemeanor DUI, not simply a penalty enhancement. 19
20 Id. at 977. (emphasis added). Thus, there can be no such relaxed standard for the consideration of Kelly s priors as there was for consideration of the Defendant s priors in Nichols. In the Petitioner s brief, Petitioner claims that since Nichols, the trend has been for other states to follow Nichols, however as Justice Ginsburg noted in Shelton, [m]ost jurisdictions already provide a state-law right to appointed counsel more generous than that afforded by the Federal Constitution. All but 16 States, for example, would provide counsel to a defendant in Shelton's circumstances, either because he received a substantial fine FN7 or because state law authorized incarceration for the charged offense FN8 or provided for a maximum prison term of one year. FN7. See N.J. Stat. Ann. 2A:158A-5.2 (1985); State v. Hermanns, 278 N.J.Super. 19, 29, 650 A.2d 360, 366 (1994); N.C. Gen.Stat. 7A-451(a)(1) (1999); Vt. Stat. Ann., Tit. 13, 5201 (1998). FN8. See Alexander v. Anchorage, 490 P.2d 910, 913 (Alaska 1971) (interpreting Alaska Const., Art. I, 11, to provide counsel when punishment may involve incarceration); Tracy v. Municipal Court for Glendale Judicial Dist., 22 Cal.3d 760, 766, 150 Cal.Rptr. 785, 587 P.2d 227, 230 (1978) (Cal.Penal Code Ann. 686 (West 1985) affords counsel to misdemeanor defendants); Del.Code Ann., Tit. 29, 4602 (1997); D.C.Code Ann (West 2001); Haw.Rev.Stat (1999); Ill. Comp. Stat., ch. 725, (1992); Brunson v. State, 182 Ind.App. 146, 149, 394 N.E.2d 229, 231 (1979) (right to counsel in misdemeanor proceedings guaranteed by Ind. Const., Art. I, 13); Ky.Rev.Stat. Ann (4)(b), (1) (West 1999); La. Const., Art. I, 13; Mass. Rule Crim. Proc. 8 (2001); Minn. Rule Crim. Proc. 5.02(1) (2001); Neb.Rev.Stat (1995); N.Y.Crim. Proc. Law 20
21 170.10(3)(c) (West 1993); Okla. Stat., Tit. 22, A (West Supp.2002); Ore.Rev.Stat. Ann (4) (Supp.1998); Tenn. Sup.Ct. Rule 13(d)(1) (2001); Tex.Code Crim. Proc. Ann., Art (b)(3) (Vernon Supp.2002); Va.Code Ann , (2000); Wash.Super. Ct.Crim. Rule 3.1(a) (2002); W. Va.Code (2000); Wis. Stat (1998); Wyo. Stat. Ann (2001). Thus, more recently, the Supreme Court of New Jersey declined to follow Nichols on State law grounds: To be sure, the United States Supreme Court has made it clear that federal law does not prohibit the use of a prior uncounseled conviction for enhancement of a subsequent conviction. Nichols, supra 511U.S at , 114 S. Ct. at Despite the Nichols holding, we continue to adhere to our position set forth in Rodriquez that an uncounseled indigent defend[a]nt should [not] be subjected to a conviction entailing imprisonment in fact or other consequence[s] of magnitude [.] Supra, 58 N.J. at 295, 277 A.2d 216. New Jersey State v. Hrycak, 184 N.J. 351, , 877 A.2d 1209 (N.J. Jul 20, 2005). Florida Courts have addressed the scope of the right to counsel under Florida law post-nichols and Shelton. The defendant in Case v. State, 865 So.2d 557 (Fla. 1 st DCA 2003), was charged with first time DUI carrying a possible sentence of six months in jail. The trial judge accepted the defendant s plea without signing an order of no incarceration and imposed a term of probation. Subsequently, the defendant argued he was entitled to withdraw his plea, because the trial judge did not secure a waiver of the right to counsel. In reviewing the trial 21
22 court s denial of the motion to withdraw, the circuit court held (like the State s argument at bar) that there was no need to establish a waiver because the defendant had no right to counsel since he was not sentenced to an actual jail term. On appeal, the district court reversed, holding: A defendant who is charged with a misdemeanor punishable by possible imprisonment is entitled to counsel unless the judge timely issues a written order guaranteeing that the defendant will never be incarcerated as a result of the conviction. See Alabama v. Shelton, 535 U.S. 654, 122 S.Ct. 1764, 152 L.Ed.2d 888 (2002); see also Fla. R.Crim. P (a) & (b); 3.160(e). Id. at 558. Courts have held a criminal defense attorney s failure to object based upon the fact that his or her client s prior misdemeanor DUI convictions were uncounseled and could not be used to enhance the current DUI to a felony, if true, would constitute ineffective assistance of counsel. Andres v. State, 898 So.2d 256 (Fla. 4 th DCA 2005). See also, Parson v. State, 913 So.2d 1270 (Fla. 4 th DCA 2005) (Failure to investigate and advise defendant that prior convictions could not be used to enhance sentence constituted ineffective assistance of counsel). 22
23 The case at bar presents a perfect example of the reason why prior uncounseled convictions should not be used to enhance subsequent offenses. The rights waiver forms Kelly signed on all three occasions affirmatively misadvised him about his right to counsel. The plea forms state that he is entitled to court appointed counsel if he is indigent and if the Judge is considering jail in his case. He was entitled to court appointed counsel if he was indigent, regardless of whether the Judge was considering incarceration in his case. 23
24 CONCLUSION Wherefore, based on the foregoing arguments and authorities, the decision of the Fourth District Court of Appeals should be AFFIRMED and the certified question answered in the negative. Respectfully Submitted, FRANK A. MAISTER, ESQ. GARRETT ELSINGER, ESQ. Florida Bar No Florida Bar No Attorney for Respondent Attorney for Respondent 315 Southeast 7 th Street/Suite Southeast 3 rd Avenue/Ste. 4F Fort Lauderdale, Florida, Fort Lauderdale, FL Telephone: (954) Telephone: (954) Facsimile: (954) Facsimile: (954) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Answer Brief of Respondent was sent by U.S. Mail, postage prepaid to Mitchell Egber, Esq, Assistant Attorney General, 1515 North Flagler Drive, Suite 900, West Palm Beach, Florida, 33401, this day of June, FRANK A. MAISTER, ESQ. Attorney for Appellee Florida Bar No
25 CERTIFICATE OF TYPE SIZE AND FONT I hereby certify that in accordance with the Florida Supreme Court Administrative Order, issued on July 13, 1998, and modeled after Rule 28-2(d) Rules of the United States Court of Appeals for the Eleventh Circuit, counsel for the respondent hereby certifies that the foregoing brief has been prepared with 14-point Times New Roman type, a font that is not spaced proportionally. FRANK A. MAISTER, ESQ. Attorney for Appellee Florida Bar No
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Sands Manukau, 37 Hope Farm Avenue Pakuranga Manukau 2010

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from £56 / night help Price for guests, Nights
Postira 01815-01 – Home 1406318 House
- 4 bedrooms
- 7 sleeps
- min stay varies
Postira 01815-01 – Home 1406318
- House
- 4 bedrooms
- 7 sleeps
- min stay varies
House / 4 bedrooms / 1 bathroom / sleeps 7
Key Info
- Nearest beach 0.2 km
- Child friendly
- Air conditioning
- Ask about pets
Description from owner
House is for exclusive use and
the house is entirely fenced.
House is located in Postira on the island of Brac, on property cca 1000 sqm. There is one private parking place right beside the house. There is garden with barbeque and terrace with chairs and table.
AP1 sleeping room with 2 single bed, sleeping room with 2 single bed, sleeping room with 1 single bed, kitchen + living room, couch for 2 children, bathroom + WC
- Great for children of all ages
- Some pets are welcome - please contact the owner
Bed & bathroom
- 1 Family bathroom
- Air conditioning
- Balcony or terrace
- Sea view
- Fridge
- Washing machine
More Less
- Parking
- Not suitable for wheelchair users
- Payment
- This rental can only be paid for online through Holiday Lettings using your credit/debit card or PayPal (never by bank or wire transfer).
- Smoking
- Yes, smoking allowed
- Cancellation policy
View Policy
About the owner
Ivo Klicinovic (Property Manager APROPOS TRAVEL AGENCY)
- Calendar updated:
- 04 Jun 2015
- Years listed:
- 2
- Based in:
- Croatia
Languages spoken: English, German, Italian
This House has 4 bedrooms, 1 bathroom and sleeps 7. It's been listed on Holiday Lettings since 25 Feb 2014. Located in Brac Island, the average weekly rate is £388.
The property's calendar was last updated on 04 Jun 2015.
Map and how to get there
Guest reviews
Help other travellers decide where to stay
This holiday home hasn't got any reviews yet. The average rating on Holiday Lettings is four out of five. This place could be newly added or perhaps it's a well kept secret. Either way, it's time to reveal all.
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Gun people
Started by Badsmerf , Aug 01 2012 08:28 PM
4 replies to this topic
Posted 01 August 2012 - 08:28 PM
So I'm considering getting a handgun and wanted some input. I really like the Ruger SR40c or SR9c. Anyone shot them? I had shot a M&P 40, which is very similar and like it except a little part by my thumb that I think will rub and bother me. So anyway, just putting it out there to see if there is any input.
Posted 01 August 2012 - 08:38 PM
Need more info on what you're planning to use it for in order to give any semblance of advice. Carry weapon? Target shooting? Something to have around the house?
Posted 01 August 2012 - 08:54 PM
The Twins have been bad, but let's not go overboard here.
Posted 02 August 2012 - 05:25 AM
I've contacted homeland security. By the way if you ever use a gun in a situation where a criminal is killing people talk radio has taught me that you will accidently murder at least 4 people. I've also learned from talk radio that the picture on a movie screen is constantly black and contains no light. Nor does a gun shot have any sound or light. Guns are bad man.
Posted 02 August 2012 - 06:27 AM
Smerf, your best bet is to go find a shooting range that rents guns and try a few out. I'm a Glock guy myself but that's because they just fit my hand better than other firearms. I like the weight and feel of the gun. Your mileage will vary based on your particular needs.


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Low-Cost Kitchen Crafts
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Polaroid Magnets
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Click here to view your Craft Projects.
These cute Polaroid Magnets are great kitchen crafts for kids and adults of all ages. Perfect for decorating everything from refrigerators to lockers, these polaroid style magnets are a fun and clever way to show off your family and friends. Since each magnet has a place to write and personalize, these magnets would also make great party favors for weddings, baby showers, birthday parties and more!
You can find this project, as well as many others, in our free downloadable eBook, Fuse Creativity System Project Guide: Fun Party Themes, Ideas for Handmade Cards, and More Paper Crafts from Fiskars!
- Fuse Creativity System® Starter Set
- Medium Design Set 100790 – Square
- ProCision™ Rotary Bypass Trimmer (12")
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First, use the Square Design Set to cut shapes from your magnetic sheets.
Next, take some of your favorite photos and trim them to 3.25" by 2.5".
Using a permanent glue stick or tape runner, adhere the photos to the magnetic squares.
In the typical 'polaroid' style, you will have space at the bottom of the magnet to write a little note about the photo. Use a permanent marker or even a dry erase pen if you'd like to switch up the messages now and again.
- That's it! They're all ready to decorate your fridge.
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Welcome to St. George Island, Florida, the vacation jewel of the Florida Panhandle. Over twenty-five miles of white sand beaches await you and your family for a chance to experience the natural beauty of this barrier island. Fishing, birding, boating, beachcombing, trail hiking and water sports are a few of our major attractions.
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BECAUSE THE BEACH IS MORE FUN WITH FREE GEAR!When you make a reservation with Resort Vacation Properties of St. George Island, you now receive a credit towards FREE beach gear. Best of all, it is delivered to the front door of your vacation home before you even arrive!CLICK HERE to learn more.A NEW "LEAVE NO TRACE" ORDINANCE IS NOW IN EFFECT FOR FRANKLIN COUNTYFor more information, please CLICK HERE.To report injured or disoriented sea turtles, call (850) 445-4047VISIT US ON FACEBOOK!With 15,000 "Fans" and counting, we won't be complete until you join us. Share stories, photos and meet new friends on our Facebook Page! CLICK HERE to "like" us if you haven't already!
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I'm going to be watching this with a group of liberals tomorrow. How do I best go about planting seeds?
Draw attention to how boring they are and how they all agree. How rehearsed they sound.
Explain alternatives to propositions.
Ex. - "Free college" Say that by removing government subsidies from the college and university system competition will increase and tuition will literally SLAM down.
That sounds boring, tbh fam. Just keep asking your friends for free money since you are so poor and need to pay for food.
Show full support for Ben Carson
don't be a pussy OP he is infallible just do some research
well yes but they have beer
That's why you keep asking, instead of using the money on food just get booze instead and ask for more money. They obviously don't need it, and what better way to plant seeds then to teach them first hand what they are doing.
Yfw, this whole debate is about Donald Trump.
Carson as well, considering how much he's been attacked lately.
Ask them why the panel is full of a bunch of old, rich white people saying they know what's best for minorities
This is Webb's chance to get some attention. My dream is a Trump versus Webb election where the outcome is a win either way.
Just do a shot everytime some one says "free" when they mean "bought with loans secured on your future tax dollars". You should be blacked out 15 minutes into it.


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Many layers, colors and changes happened before this piece was completed. I wanted to accomplish a complex combination of iridescent effects, texturing and depth. Drips of red and purple create an elegant darkness to the painting making all bright colors come to life. Very striking piece with lots of movement, depths and texture.
Additional Info:
All my artwork is on gallery quality heavy duty stretched and triple primed cotton canvas and ready to hang. I include a certificate of authenticity that lists the materials as well as when the painting was completed. Fine high quality materials such as Golden and Sennelier products are used and UV protective enamel for sunlight protection.
Each painting is carefully packed and padded for a safe delivery. Paintings shipped with a tracking number.
Please send me a message for any further questions!
Plaster, gesso, Golden and Sennelier acrylics. UV protected gloss coating.


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text: Twitter tipster and developer LlabTooFeR managed to get the device images for Google's new Pixel and Pixel XL smartphones and has made them available for download. This is not going to be useful for the general public or even folks who want to try to flash them onto their device as they will only work on the Pixel devices. However, this does mean developers can start to dig into the software included on the new phones, so we should have some interesting findings to surface while buyers wait for their new devices to arrive. Read more


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Tom Kerridge Restaurant
Try this Cheat's Chocolate Tart recipe by Chef Tom Kerridge. This recipe is from the show Tom Kerridge's Best Ever Dishes.
BBC Food - Recipes - Tom Kerridge's spaghetti Bolognese
Christmas side dishes courtesy of Tom Kerridge Cooks Christmas.... Bacon wrapped stuffing
TOM KERRIDGE'S MUSHROOM & HAM PIE ~~~ the only thing that swerves a bit off path from that of tom's classic share is the crust's construct... and it is w-a-a-a-y beyond awesome... in fact, i would say it is baller and then some. recipe gateway: this post's link AND tom's original http://www.gloucestercitizen.co.uk/Gloucester-s-Tom-Kerridge-shares-recipe-perfect/story-25912743-detail/story.html [England] [Tom Kerridge] [milk-and]
Top chef Tom Kerridge shares his tips for creating the ultimate crispy roasties. Find out how he gets that perfect crunch...
Tom Kerridge date and toffee pudding recipe with rum and treacle toffee sauce on Tom Kerridge's Proper Pub Food
Roast pork with rhubarb sauce, photographed by John Carey
Beef and ale stew with dumplings, Tom Kerridge (Carby?? Use only 750ml broth, use only 2 apples. OK to sub GF bread crumbs, 1Tbsp dried parsley, and melted coconut oil instead of suet.)
Proper baked beans on soda bread toast from Tom Kerridge's Proper Pub Food
Tom Kerridge serves up hardcore coleslaw for crowd pleaser on Tom Kerridge's Best Ever Dishes. Tom says: "Coleslaw is such a versatile side dish, perfect for summer barbecues and works just as well made with winter vegetables and served alongside roast pork."


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Despite Critics, Gore 'Proud' to Invest in Green Firms
Responding to criticism that his investments profited richly from the stimulus package, Al Gore defended himself Nov. 3.
"I am proud to put my money where my mouth is for the past 30 years," Gore said during an interview on ABC Morning News, reports UPI. He also appeared later that day on the David Letterman show, promoting his book, "Our Choice: A Plan to Solve the Climate Crisis."
A day earlier, media outlets seized upon revelations that a Silicon Valley firm Gore invested will benefit from smart grid projects that received more than $530 million in a recent stimulus package grant, as reported in a New York Times article.
Gore said that he believes in investing in accordance with his beliefs and values, but that he's not a "carbon billionaire" as the NYT article portrayed him.
The NYT dug up details about Gore's relationship with Silver Springs Networks, which makes smart grid equipment. Last year, Silver Springs sought and received $75 million in venture capital funding from a firm that Gore is affiliated with, Kleiner Perkins Caufield & Byers.
In a recent round of $3.4 billion in smart grid financing from the federal government, more than $560 million went to utilities which have contracts with Silver Spring, according to NYT.
Gore, who has earned millions in speaking fees and other deals since leaving office, has invested in firms that deal in carbon trading markets, solar cells and waterless urinals, among others.
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PowerGenix, Original Power Bring GreenCell® Rechargeable Batteries to Portable Lawn and Garden Tool
PowerGenix, manufacturer of safe, non-toxic, rechargeable nickel-zinc (NiZn) batteries, today announced that it has entered into a multi-year supply agreement with Original Power, a specialist in AC/DC power solutions for cordless outdoor power equipment.
Lightweight, compact Nickel-Zinc to Phase-out Industry Standard, Nickel-Cadmium Batteries, Due to Toxicity Issues and Dramatic Power Improvements
San Diego - June 4, 2008 - PowerGenix, manufacturer of safe, non-toxic, rechargeable nickel-zinc (NiZn) batteries, today announced that it has entered into a multi-year supply agreement with Original Power, a specialist in AC/DC power solutions for cordless outdoor power equipment. Under the agreement, PowerGenix will supply its patented NiZn Sub-C cell battery packs for introduction into multiple key Original Power product lines beginning in 2009.
Original Power will offer a new GreenLink® line of interchangeable cordless tools exclusively featuring PowerGenix's NiZn battery packs, as well as incorporating the technology into its current lawn and garden power tool lineup. Utilizing PowerGenix's rechargeable battery packs, the new line of environmentally friendly cordless products will bear the GreenCell® trademark indicating inclusion of the clean, rechargeable and recyclable NiZn battery chemistry.
"As part of Original Power's ongoing commitment to offer customers the best in lawn and garden power tools we feel a responsibility to uphold the highest safety and environmental standards. Our partnership with PowerGenix highlights a calculated move forward in this direction," said Kirk Turner, Founder and President, Original Power. He added, "No other battery chemistry on the market today fulfils all the durability and performance demands of garden power equipment while also being affordable, safe, and containing no environmentally harmful chemicals."
In Original Power product testing, PowerGenix's NiZn cells were more durable, robust and offered up to 50% more power than the same size NiCd cells. PowerGenix's battery packs supply bursts of high power for extended periods of time with rapid recharge capability, attributes particularly suited as a power solution for lawn and garden applications. Nickel-Zinc batteries are also inherently nontoxic and contain no lead, cadmium or mercury. Joining a growing list of manufacturers and retailers, Original Power will phase out all nickel-cadmium powered lawn and garden products by the end of 2010.
"Original Power is cognizant of the concerns within today's battery market and has recognized consumer demand for cleaner battery alternatives. PowerGenix's patented Nickel-Zinc chemistry is the first rechargeable battery technology to significantly out perform existing alkaline rechargeables while addressing increasing environmental restrictions," said Dan Squiller, CEO of PowerGenix.
About PowerGenix
PowerGenix has developed and patented a high-energy density, high-cycle life and low-cost Nickel-Zinc battery targeting the market for energy intensive electronics and hybrid electric vehicles (HEVs). Specifically designed to utilize existing Nickel-Cadmium manufacturing processes, techniques and equipment, PowerGenix offers the supply chain scaling and security OEMs require. With its patented rechargeable Nickel-Zinc battery technology, PowerGenix is pursuing applications to replace existing Nickel-Cadmium and Nickel-Metal Hydride batteries in the multi-billion dollar rechargeable battery market.
About Original Power
Founded in 1996, Original Power, Inc. has been the leading innovator in energy efficient consumer power conversion products with several "first to market" Energy Star approved products. Additionally, the Company's cordless garden tools, available at major retailers, have helped change the way American's take care of their yards. For more information on Original Power, Inc. please visit, www.originalpower.com or contact President Kirk Turner at (770) 418-1850 x104.
Media Contact:
Skye Laudari, Antenna Group (for PowerGenix)
415-977-1925, email@example.com
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Beck Reed Riden LLP's lawyers have years of experience at large law firms, working with clients ranging from Fortune 500 companies to start-ups and individuals.
We focus on business litigation and labor and employment.
We are experienced litigators and counselors, helping our clients as business partners to resolve issues and develop strategies that best meet our clients' legal and business needs – before, during, and after litigation.
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provided by bestlawyers.com. The fact that a lawyer has been voted by his or her peers into Best Lawyers in a legal practice area does not signify that the lawyer has been
certified by a state board of legal specialization in that practice area or specialty. A listing in Best Lawyers does not guarantee a desired legal result.


text:
Fantastic service. Goods were delivered on time and fresh fruit was exceptional. Thanks
When the Disney hotel I was staying at couldn't find my order, someone from Garden Grocer called them to tell them where to look. Garden Grocer then called me back to let me know everything was all set. Bell services brought my order a short time later. Garden Grocer customer service was outstanding!
Good was fresh, delivered promptly, and was appropriately handled based on its required temperature. Such a convenient service ! Highly recommend !


text:
On Friday, 14 October, 2016 07:29, Thom Wharton <twhar...@northpointdefense.com> wrote:
> I have a table of records in a Sqlite DB. It contains 5 records. Each > record has a time-stamp which is not guaranteed to be unique. To > preserve order (which is important in my project), I've given the table > an integer primary key (called ID) that is auto-increment. Let's say I > have the following table... > ID Date Type Size Data > 1 10OCT-08:13:47 Ether 28 sddsgsd... > 2 10OCT-08:13:52 Ether 77 fdasfdsdsddssdg... > 3 10OCT-08:13:52 Ether 44 zeasfkkfa... > 4 10OCT-08:13:57 Ether 33 dartdg... > 5 10OCT-08:14:03 Ether 51 afafsfafa... > I want to be able to programmatically insert a new record anywhere in > that table. Let's suppose I want to create a new record between the > records whose ID are 2 and 3. This new record would need to take the ID > of 3, and all subsequent records would need to have their primary keys > updated. > Is there a way to do this automagically (like a specialized INSERT > command?) in Sqlite? Unfortunately no, there is no way to do this on *ANY* database that uses the relational database model. You see, in the relational database model there is no such things as "records". What you have above (a table) consists of a "bag of tuples". There is no order to them. They are merely a "bag" (known mathematically as a set). When you issue a query (SELECT) you project sets and conditions and obtain a set of data as a result (another bag of data). If you wish an order, you tell it what order to put it in (using an ORDER BY clause). Due to the inherently sequential nature of modern computing technology most programming languages are unable to deal with the data in its native form (a set) and therefore you retrieve and work on them one after each, in forward order only, in the order you requested presentation using the ORDER BY clause. The "integer primary key" (whether you use autoincrement of not) is simply a unique key in each record that is derived sequentially (unless you provide it) based on the previous (or biggest ever previously used, if you use autoincrement) number in that field, to uniquely identify the contents of that tuple. It does not contain any useful information which you should be manipulating in any way other than using it as a linkage to perhaps other related tuples in other tables. See https://en.wikipedia.org/wiki/Relational_model > Thanks, > Thom Wharton _______________________________________________ sqlite-users mailing list firstname.lastname@example.com http://mailinglists.sqlite.org/cgi-bin/mailman/listinfo/sqlite-users


text:
Jesus Begins God's Work
Written by Carol Christian
Illustrated by Francis Phillipps, Francis Phillips
Part of the Macmillan Bible Stories Series
Lovereading4kids Price £3.80
£4.75 saving £0.95 (20%)
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Jesus Begins God's Work by Carol ChristianThis text, as part of the Macmillan Bible Stories series, retells the familiar bible story of Jesus beginning his work on behalf of God. The book aims to encourage children to put themselves back into the places and times the stories portray, and is graded on level two.
About the Author
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Book Info
48 pages
Carol Christian
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Publication date
9th February 1996
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text:
Vodka On My Wheaties is like no other book you have ever read. The events that have happened to Ann Lloyd are only seen on the silver screen, but all of her stories are non-fiction. Her book reads like a novel even though it's an autobiography. Vodka On My Wheaties is filled with a humorous potpourri of real life happenings for a wide range of people to enjoy. The beginning chapters reveal that Ann was programmed from birth to march to the beat of a different drum. She was the only child of neurotic parents and it was not in her nature to follow the herd. Married at eighteen to a prominent drug store magnate twice her age, she finds herself, at the age of twenty-two, a widow. From her sudden dramatic exposure to a life of opulent wealth and world travels, Ann and her second husband settled down to build an exclusive out-island scuba diving resort in the Bahamas, which attracted the rich and famous. As a self-appointed, liberated female the adventures do not stop there. Join in Ann's kaleidoscopic journey down one of life's most unusual paths and her ability to qmake things happen.q Ann's story is bursting with romance, adventure, mystery, celebrities, substance abuse, and much more! Publishers Weekly Review: Lloyd's unconventional memoir is told with gusto and packed with honest, entertaining episodes. Raised by qintense and neuroticq parents, the quirky narrator with a qmind and a will of [her] ownq endures a lonely childhood and tumbles through her colorful life. Tying the knot with her handsome boyfriend results in a dangerous marriage that threatens her life. Her second marriage leads the author to support her new husband's many qfailed business enterprisesq and then maintain a resort in the Bahamas. Her brief third marriage leads to substance abuse, as she starts qdrowning her depression in vodka.q Eventually Lloyd discovers a 12-step program to maintain sobriety, filling the qempty void left by the removal of alcoholq with the qfruits of spirituality.q But the onset of an autoimmune disease changes everything and forces Lloyd to remake her life yet again.Visitors balked at the bare metal sheet side panels, along with the aged wooden- framework ceiling showing the network of dangling wires giving electricity to ... In 1989, after having lived in Seagoville for almost three years in my shabbily foiled trailer with the doors almost falling off, ... Praying that my new red Toyota pickup, now a 1978 in better condition than the 1977 I had been tootling around in, would anbsp;...
|Vodka on My Wheaties
|Ann Lloyd
|Biographical Publishing Co. - 2011-03-17


text:
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Washington Pavement Company repaved our cracked, potholed driveway. The owner, Joe, went the extra mile to make sure the job was done right. When the weather didn't cooperate, at one point he came to us and said part of the job didn't turn out to his standards, and he re-did it for free without us having ot say a word. Customer service like this is a rarity these days, Washington Pavement's hard-working and do-it-right attitude is a breath of fresh air.
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Do they replicate the mydomain.com so they have a local copy?
the issue you might have is that the settings on the mydomain.com are too short for the Expiry i.e. they replicate the zone, but the default expiry on the mydomain.com zone is 1day such that once the DNS server went down, the mydomain.com copies expired after a day.
You could configure the remote DNS servers to only query your corporate DNS when requests are for mydomain.com
Not sure what types of requests you were seeing.


text:
The Memorial Hospital West Children's Emergency Department helps ease the fears children often associate with a trip to the emergency room. Contributing to the lighthearted atmosphere are electric trains, a water-filled bubbling window, TVs, VCRs, games and color murals. These help distract kids from the serious work of the pediatric emergency physicians and registered nurses who work around-the-clock, every day of the year. Our pediatric emergency department is complete with technology and is affiliated with the renowned Joe DiMaggio Children's Hospital at Memorial Regional Hospital in Hollywood.
The children's emergency department is staffed 24 hours a day with dedicated physicians, nurses and support staff, specially trained in pediatric emergency medicine. It is separate from the adult emergency department and has its own emergency entrance, triage, waiting and treatment rooms.


text:
FMSPy Publisher's description
from Andrey Smirnov
Flash Media Server in Python using Twisted Framework
FMSPy is a Python library that provides implementation of RTMP protocol upon Twisted Framework. On top of protocol implementation it builds server for Flash/Flex clients.
At the moment FMSPy supports:
* basic RPC support;
* application plugin infrastructure (applications are designed as FMSPy plugins);
* application API.
Plans include:
* live webcam audo/video streaming;
* streaming from disk and writing streams to disk;
* shared object support;
* monitoring and load analysis;
* clustering.
Plugin applications may use full power of Twisted, for example: memcached protocol, database connections, RPC-over-HTTP, object persistence etc.
System Requirements:В· Python
Program Release Status:
Program Install Support: Install and Uninstall


text:
Law & Order: Criminal Intent 2007 | TV Show Watchlist
Season 6, Episode 15 Brother's Keeper
First Aired: February 20, 2007
An investigation into the murder of the wife of a televangelist (Tom Arnold) leads to the discovery of a seedy relationship he had with a hustler that may have contributed to the crime. Meanwhile, Goren runs into his brother (Tony Goldwyn) while visiting his ailing mother (Rita Moreno).
Guest Cast
Tony Goldwyn Michael Goren
Theresa Randle ADA Patricia Kent
Next On TVSee all »
Thu Oct 27 11:00am
The ConsolerSeason 10, Episode 2 WEI'll Watch1043 Watching
Cast & Details See all »
- Premiered: October 4, 2007
- Rating: TV-14
- Premise: This second 'Law & Order' spin-off focuses on New York detectives known as the Major Case Squad, which handles high-profile and unusually difficult investigations. Its storytelling differs from the original series in that it presents the criminal's perspec… (more)
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The Blacklist10:00 pm | NBCI'll Watch326 Watching
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By Universal StudiosBuy New: $18.60
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Why and how did samual praise swamis father?
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Why and how did samual praise swamis father? resources. Garden of Praise: The Wright Brothers Biography. At biography.com search for The Wright Brothers.
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61 %
Samuel received a basic education at a school run by a Mr. Jackson in ... George S. Memoir of Samuel Slater: The Father of American Manufactures (1836 ...
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58 %
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... and thou shalt sleep with thy fathers, ... (2 Samuel 12:5). The law certainly did not pronounce ... The death of this child came as no surprise to ...
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61 %
Where did Samuel Adams grow up? ... His father, Samuel "Deacon" Adams, was a political leader, a staunch Puritan, and a wealthy merchant.
Read more
56 %
2 Samuel 6:21 Parallel Verses ... we need not heed reproach. Piety will have its praise: ... and he did not further reprove or blame Michal's insolence; ...
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42 %
He was practically saying, "You did it, ... the world will see and glorify our Father in heaven. • Give Praise ... Taken from How to Live for God's ...
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19 %
Samuel de Champlain ... His education did not include Ancient Greek or Latin, ... Samuel de Champlain: Father of New France Little Brown, ...
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61 %
DAVID PRAISED GOD "IT'S THE HEART" part ... he asked her why? She deceived her father ... worst experiences move you to praise God? They did David. That is ...
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60 %
The biblical King David of Israel was ... to the prophet Samuel in Ramah. David returned briefly to ... David swore to this, but it did not stop Saul ...
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55 %
... (2 Samuel 14:20) 8. Why did ... for why then should you bring me to your father?"" (1 Samuel ... It was through beautiful songs of praise to ...
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48 %
Samuel Adams was born in Boston, son of a merchant and brewer. He was an excellent politician, ... Samuel was a very visible popular leader who, ...
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38 %
... education, accomplishments, family, Samuel Adams quotes, ... Samuel Adams is sometimes called the "Father of the American Revolution ... Did he see ...
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25 %
Saul was a descendant of one of these 600 men and his father ... he did not wait for Samuel at ... praise" monument to himself, Samuel was about to ...
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9 %
Samuel Slater has been called the "father of the American factory system." He was born in Derbyshire, England on June 9, 1768. ... He did so covertly: ...
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David's father was named ... be, but he did not yet know. We follow with Samuel to ... unto the Lord and to praise Him with ...
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The family returned to their home in Ramah and in time Hannah did have a baby boy. She named him Samuel, ... Lord Hannah did not ... a father for bread he ...
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10 %
... Facts and Information . ... How did Michal help David to escape from her father when he was trying to kill David? ... Why did Saul, who owed David ...
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1 Samuel 16 - God Chooses David . A. Samuel anoints David as king. ... why did He send a distressing spirit upon Saul? ... He is the Father of lights, ...
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text: Quickly Install the Best Open Source Apps with WinLibre and MacLibreAdam Pash1/08/08 2:00pmFiled to: Featured DownloadAutomationDownloadsInstallerMac OS XTopWindows232EditPromoteDismissUndismissHideShare to KinjaToggle Conversation toolsGo to permalink Windows/Mac OS X only: Free, open source applications WinLibre and MacLibre install and update a handful of some of the best open source applications available for Windows and Mac OS X, respectively. These are the kind of apps that make setting up a fresh system a breeze—just download, choose the apps you want, install, and you've got most of the software you'd need to get things done. You can re-run the app periodically to check for updates and install newer versions if the apps you're running don't update themselves. Expect most of the obvious favorites, like Firefox, Thunderbird, VLC, Gimp, and Handbrake, along with a few others you may not have known about. Both applications are free. For another Windows alternative, check out previously mentioned InstallPad. Thanks Stephen! WinLibre MacLibreGear from Kinja DealsYour Pick For Best Kitchen Trash Can: SimplehumanBestsellers: Mohu LeafSunday's Best Deals: Kindle Biographies, Alfred Hitchcock, PS4 Media RemoteReply23 repliesLeave a reply


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Год издания: 2004
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Как только книга Peasants' Movements in Post-Colonial India станет доступна для заказа в одном из интернет-магазинов, Вам на e-mail будет отправлено уведомление.Укажите e-mail для связи:
Book DescriptionThis is an investigation of the anatomy and internal dynamics of peasant movements in India. It makes a comparative analysis of the Tebhaga (Bengal, 1946-47), Telengana (Andhra, 1948-52) and Naxalite (North Bengal, 1967-71) movements to study the ways in which grassroots mobilizations transform and institutionalize themselves, forge new collective identities and articulate new strategies for survival and resistance. The author uses empirical data and secondary research to argue that radicalism in peasant movements is in inverse proportion to institutionalization. As spontaneous expressions of discontent against oppression and marginalization become institutionalized movements, the space for radical challenge shrinks. Therefore, in Bengal, the co-option of the peasant movement by the ruling communist party and the state has largely killed the scope for radical action. In Andhra Pradesh on the other hand, the relative independence of the grassroots...


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