A Legal Note: Brett Kimberlin is an Adjudicated Pedophile the Same Way the Amityville Horror House is Haunted

This is the latest post in what I half-jokingly call The Kimberlin Saga^®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that Kimberlin has been harassing me for over two years, his worst conduct being when he attempted to frame me for a crime.   I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave him, and for that, he is suing myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, James O’Keefe III, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson, Breitbart.com, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  Simon and Shuster alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

Donate to BomberSuesBloggers
and enjoy a big box of popcorn!

First, let me bring up, again, my plea to you to donate to Bomber Sues Bloggers.  As you know, we won in the Maryland State Court and we have ordered the transcript.  It is going to cost $880 to get it, total, with us having deposited the majority of that money already.  And of course the trial audio cost money, too.  And while we can’t play the audio for you (due to a standing court order pertaining to all audio), we will publish the transcript.  So if you want to read all of it, donate to Bomber Sues Bloggers!

It is totally Popcorn-Worthy!^®

Blegging aside, a number of legally inclined types have written asking me exactly how I draw the conclusion that Brett Kimberlin is an “adjudicated pedophile,” as the title of my last post suggests.  Now, first, admittedly I chose that title in part to parallel the language I used in another post called “Brett Kimberlin is a Pedophile” which was found not to be defamatory last Tuesday.  There, I announced that I had drawn that conclusion that he was a pedophile based on a number of piece of evidence that I shared with you.  But, you might ask, all that was found is that he failed to prove it was false.  Is that the same as saying it is true?

In my legal opinion, yes.  To make this point, let me share with you another case, Stambovsky v. Ackley (1991).  It is a boring case involving the sale of real estate without proper disclosures.  What did they fail to disclose?  Some termites?  Some chipped paint?  Ah, well, no, not exactly.  They didn’t tell the new owners that the house was kind of famous:

Brett Kimberlin is an Adjudicated Pedophile

This is the latest post in what I half-jokingly call The Kimberlin Saga^®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that Kimberlin has been harassing me for over two years, his worst conduct being when he attempted to frame me for a crime.   I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave him, and for that, he is suing myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, James O’Keefe III, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson, Breitbart.com, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  Simon and Shuster alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

This was actually cited as
evidence of my supposedly
evil intent.  I am not joking

Update: Thanks to all the nice people who pointed out the very bad typo in the original version of the post.  As Murphy's law had it, I was at breakfast and my home internet was down when I first realized the error, so I asked a friend to borrow my login credentials and fix it and I am thankful for him for doing so.

Tuesday in Maryland free speech won and Brett Kimberlin lost.  And so did the safety of children.  I have not blogged about the case as much because our able attorney, Patrick Ostronic, Esq., did ask us not to publish much of the documents, as an application of the Napoleonic principle of not interfering with one’s enemy while they are making a mistake.  As the mantra has been for a while: case first, blog second.

And before I get further in it, let me do a bleg.  After our victory in Maryland, we need a transcript of the trial.  It is going to cost an estimated $880 to get it.  We have ordered it, and Bomber Sues Bloggers, our defense fund is willing to pay for it, but we need the money to fully pay for it.  So please donate to Blogger Sues Bloggers today and if you do, I promise we will share a copy with you!

(Though we reserve the right to redact some information to protect the innocent.)

So let’s play a little catch up.  At this point, the case was about defamation and false light, essentially the claim that we have been saying false things about Kimberlin.  While there are technically six defendants in the case, the trial was only between Brett as the plaintiff and myself, John Hoge, Stacy McCain and Ali Akbar.  The other two defendants, whom Brett accused of being KimberlinUnmasked, was Lynn Thomas and Peter Malone.  They are father and daughter.  If we lost they would be tried later.  Now, it appears that the case against them should go away on collateral estoppel.

BREAKING: Judge Hazel Issues a String of Denials in Convicted Terrorist Brett Kimberlin’s Silly RICO Suit

And Great Minds Think Alike...

This is the latest post in what I half-jokingly call The Kimberlin Saga^®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that Kimberlin has been harassing me for over two years, his worst conduct being when he attempted to frame me for a crime.   I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave him, and for that, he is suing myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, James O’Keefe III, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson, Breitbart.com, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  Simon and Shuster alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

This is probably going into Brett's
latest filing/butthurt report.

Admittedly, this will not be the most thunderous of news in the case, but still let me go over the latest “dispatches from the front.”

Yesterday, as John reported over at Hogewash, Brett filed another spate of filings.  As you might remember, last time Judge Hazel gave Brett the right to seek a preliminary injunction to try to silence us, again.  Mind you, that is only the right to ask and I think in time the judge will realize this entire thing was a waste of time.  So his first filing was to say to the court, “gee, your honor, can I have more time to file my response?  I kinda have this vacation coming and...”

You cannot make this stuff up, folks:

Judge Hazel Calls Bull on Convicted Perjurer Brett Kimberlin

And Other Developments in the Silly RICO Case

Always enjoy fresh popcorn
while watching vexatious
litigants get bench-slapped!

This is the latest post in what I half-jokingly call The Kimberlin Saga^®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that Kimberlin has been harassing me for over two years, his worst conduct being when he attempted to frame me for a crime.   I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave her, and for that, he is suing myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, James O’Keefe III, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson, Breitbart.com, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  Simon and Shuster alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

So, again, we have some catching up to do.  Last week Lynn Thomas and Peter Malone made an appearance in the KimberlinUnmasked copyright case pointing out that Brett forged some more documents, which I blogged about, here.

Well, that got Brett into full stompy-foot mode.  Every now and then he files a motion that I read almost as like a “primal scream.”  I mean it is the kind of stuff that one might write in an email if annoyed and hit send imprudently,* but if you had to go to the trouble of printing it out and delivering it to the court or to a mailbox, you would probably think twice about it.

And we got three of them.  First, in the Copyright case, via Hogewash, we see a filing he made to sanction Thomas and Malone.

In Convicted Document-Forger Brett Kimberlin’s Frivolous Copyright Suit, Lynn Thomas and Peter Malone Pay Mike Smith the Ultimate Compliment

This is the latest post in what I half-jokingly call The Kimberlin Saga^®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that Kimberlin has been harassing me for over two years, his worst conduct being when he attempted to frame me for a crime.   I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave her, and for that, he is suing myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, James O’Keefe III, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson, Breitbart.com, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  Simon and Shuster alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

Always have lots of popcorn
while watching a copyright
troll midget get slapped down!

Update: As promised, below I have embedded the Motion for Default that prompted Thomas and Malone’s reply.

Well, let’s play a little catch up, shall we?  One part of the story of Brett’s ongoing lawfare that has been neglected is the third suit he has filed, a patently bogus copyright action, also in Federal Court.  Originally it was against “KimberlinUnmasked” ("KU”) the writer or writers of the now-defunct blog and not-defunct twitter account dedicated to unmasking Brett Kimberlin.  He has named who he claims is this person or persons in all three suits.

(Now is a good time to add a disclosure.  I have been in communication with one or more people who claim they write as KimberlinUnmasked.  We have in the past entered into an attorney-client relationship (pro-bono).  As you might imagine, then, I know more than I can say.  And you might reasonably wonder if that representation leads to bias in his/her/their favor.  I would like to think not, but I report, you decide.)

And yes, the copyright suit is bogus.  For instance, here’s a line from the current complaint:

Letter Order A Mixed Bag in Convicted Terrorist Brett Kimberlin’s Silly RICO Suit (Updated with All Documents)

This is the latest post in what I half-jokingly call The Kimberlin Saga^®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that Kimberlin has been harassing me for over two years, his worst conduct being when he attempted to frame me for a crime.   I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave her, and for that, he is suing myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, James O’Keefe III, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson, Breitbart.com, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  Simon and Shuster alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

Mmm...  popocorn is good
when reading Aaron's blog

Update: As promised, I have added additional documents below.  Enjoy!

Usually, dear reader, when I write these things I want to put all the pieces into place into one cohesive package.  I recognize that I am just a guy on the internet.  I know I have integrity and I tell the truth, but how do you know this, dear reader?  You don’t, that’s how.  So, when I do original reporting, I “show you my work” as much as possible.  I share the original documents, recordings, videos, even right in the piece.  That way I minimize as much as possible how much you have to “take my word for it.”

And I will with this latest reportage.  Eventually.  But this time much of the source documents will not be in this post.  The whys of this will have to be left to another time, but I have family coming over in a bit and that will reduce my time to report.  So in other words, instead of showing you what has been filed, I am going to tell you what has been filed.  And then at some point in the future, JohnHoge (check his site often) or I will add the original documents so you can see for yourself.

My (Revised) Motion to Dismiss Convicted Terrorist Brett Kimberlin’s Silly RICO Suit

This is the latest post in what I half-jokingly call The Kimberlin Saga^®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that Kimberlin has been harassing me for over two years, his worst conduct being when he attempted to frame me for a crime.   I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave her, and for that, he is suing myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, James O’Keefe III, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson, Breitbart.com, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  Simon and Shuster alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

Always keep popcorn on hand
when dealing with RICO madness!

Well, dear reader, as you know I have been on blogging hiatus as I worked on documents for court, primarily among them my revised motion to dismiss, which I am sharing with you, now.

As you may recall the last time I shared Judge Hazel’s order that Brett will be allowed to amend his complaint.  One thing I held back from my analysis last time was what I thought of this line from the judge’s order: “Defendants are free to renew their motions to dismiss by separate filing, or, to the extent they wish to revise their previously filed motions to dismiss, they may do so.”  I read that as an invitation to do one of two things.  The first is to file a short motion to dismiss that merely said, “for the reasons stated previously (see documents x, y and z) we hereby move to dismiss,” or to file the same motion, but revised.  Or, certainly we could file a completely new motion.  And, maybe we could file a motion that says “for all the reasons stated previously (see old documents) and now the new reasons in this new memorandum, please dismiss the case.”

But I also see the judge as taking the attitude of wanting to start the new case from scratch and a wise lawyer tries to heed the unstated desires of a judge as much as the stated ones.  So giving the judge a document that says “go back and read these previous documents” didn’t seem like the best approach.  So as much as possible I decided to avoid that.  Now, on the other hand, to pretend nothing happened in the case before today only benefits the unscrupulous, so you will see where I necessarily reference earlier documents.  But still the idea is that for the most part the judge will be able to read one document, in isolation, to see why he must dismiss the whole case.  Update: I will add that this shouldn't imply that you are mostly reading the same document.  I would say that around 60% of it is wholly new, and 40% from the original.  Sorry if that makes it less interesting but there are only so many different ways to say the same thing.

Since the judge allowed that amendment, we have seen motions to dismiss from 1) Twitchy and Michelle Malkin; 2) Erick Erickson, Redstate, James O’Keefe and Simon and Shuster; 3) Glenn Beck, the Blaze and Mercury Radio Arts; DB Capital Strategies; and John Hoge.  And now you are getting mine.

So I am giving you two documents, technically, below the fold.  The first is the “rump” motion to dismiss that basically says “for the reasons stated in the attached memorandum, please dismiss this dead dog of a case.”  Here’s that “rump:”

Judge Hazel Wipes the Slate Clean in Convicted Terrorist Brett Kimberlin’s RICO Suit

And: “I Get Results! (Not really!)”

This is the latest post in what I half-jokingly call The Kimberlin Saga^®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that Kimberlin has been harassing me for over two years, his worst conduct being when he attempted to frame me for a crime.   I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave her, and for that, he is suing myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, James O’Keefe III, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson, Breitbart.com, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  Simon and Shuster alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

Update: I had to fix a bad embed of a letter.  Fixed now!

Well, Murphy’s law can be a real bastard at times, can’t it?  I was all ready to post on today’s events, when we had a game changer.  So I will try to adapt what I said to the news.

I have been on blogging hiatus for a while.  The principle is, after all, “case(s) first, and blog second” and I have been pretty busy behind the scenes in those twin lawsuits against me.  As mentioned in my standard blurb in the last paragraph, we have two suits going on: 1) a Maryland state case where he is claiming that I, John Hoge, Stacy McCain, Ali Akbar and whoever KimberlinUnmasked is, mostly centering around his sexual abuse of his wife, discussed here, and 2) a federal case claiming that a long list of defendants are engaged in organized crime to call him a SWATter.

To update you some, there is going to be a hearing on July 1 in the state case regarding several motions for summary judgment and a related motion to dismiss for failure to comply with discovery.  My attorney has asked me not to share very much about that for fear of educating the midget...

He is looking buff...

...so I won’t.  I will simply say that legally we should prevail and if the judge follows the law, the entire case will be thrown out.  But then again, if the law was followed, we wouldn’t have gotten this far, so we’ll see how it goes.

Oh, and none of that tells you about the Copyright case that John has filed against Bill Schmalfeldt (a.k.a. “Baghdad Blob”).  You can read several of the documents he filed recently in this case, here.  In the name of brevity I won’t discuss that in detail, but basically John has alleged that the Blob has been ripping off his copyrighted work and that of another blogger, and there will be a hearing for a preliminary injunction to stop that this coming Thursday.  And I don’t think I have updated you about the case Schmalfeldt filed against ten bloggers or internet commenters and then dropped literally two days later.

But it’s in the RICO case that we got the big news.

BREAKING: Blubber (Counter) Sues Bloggers

This is the latest post in what I half-jokingly call The Kimberlin Saga^®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that Kimberlin has been harassing me for over two years, his worst conduct being when he attempted to frame me for a crime.   I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave her, and for that, he is suing myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, James O’Keefe III, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson, Breitbart.com, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  Simon and Shuster alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

Of course the title is a kind of an in-joke, that I will untangle briefly.

As you might remember when Brett Kimberlin first started off this most recent spate of lawsuits starting with suing me for represented a another client, in this case his wife, we created a legal defense fund at the site Bomber Sues Bloggers—which you can still donate to!  Then when Bill Schmalfeldt threatened to sue various bloggers, in February (you have to be specific, because he is always threatening to sue people), I joked that we might have to start up “Blubber Sues Bloggers.”  You know, because Bill Schmalfeldt is very, very fat.

Hey, just because I’m a Yalie, doesn’t mean every joke has to be erudite, okay?

Anyway, in the last few weeks we saw that Blubber seemed to finally make good on his threat to sue various people in a laughably incompetent complaint he filed in U.S. District Court.  Then he claimed he spoke to his doctor who suggested he doesn’t need the stress and so he withdrew the complaint.  You can read all about that at Blubber Sues Bloggers, a site which I think constitutes great minds thinking alike, in terms of its title.  I should stress that “Blubber” is not a fundraising site, unlike Bomber Sues Bloggers.  It’s a news and mockery site.

So anyway, as you also might know, John Hoge has also sued Schmalfleldt in federal court for a violation of his copyrights, and also the copyrights of the anonymous blogger known as Paul Krendler, who sold the rights to him for the purpose of stopping Schmalfeldt from ripping off his copyrights.

Well, I have just heard from John that Schmalfeldt has answered the suit and counterclaimed in it.  In it he has added to counter-defendants: Chris Heather who is allegedly the twitterer known as “GunTotingTeaBag” and Paul Krendler.  John said he didn’t have much time to look at it, yet, but he did say that there was also a motion to get immediate discovery, most likely of one or more of their identities (it depends on whether he is actually sure Heather is the right guy.

Surely you will see more at Hogewash as this develops.  I will share what I know as I learn, though as always, my motto is “case first, blog second.”

Still, you might want to start popping the popcorn right now, because I am willing to bet this is a pretty awful one.

Bond v. U.S.: Analysis: John Roberts Knows What Chemical Weapons Are When He Sees Them

Or: “Can an International Treaty Make Barack Obama President For Life?”

First, a programming note.  As often is the case, much of my writing energy has been consumed as of late in court documents that have not yet been released on the internet (indeed in many case, have not yet been filed.)  But I am on break and in that break, I can talk about other things.  I will also catch up on the big legal occurrences last week shortly.

Today the Supreme Court handed down its opinion in Bond v. U.S., and while the decision was unanimous, it was a surprisingly contentious unanimity.  But first a little background.

There is an infamous line in the otherwise unnotable opinion on obscenity from Justice Potter Stewart.  First Amendment doctrine has long held that “obscenity” (more or less, hard core porn) is an exception to freedom of speech or the press that can therefore be banned, even with criminal consequences.  Of course anyone with basic Google skills can quickly discover that such bans are like the proverbial finger in the dam as it bursts, but whether such bans are of any practical use or not is beside the point.  They exist and therefore the Supreme Court had to wrestle with how to define that term: obscenity.

So Jacobellis v. Ohio (1964) is mostly unremarkable.  It involved a movie called The Lovers, which I have never viewed but you can read a review here, but to be blunt nothing said in the opinion was too unusual.  It was from the time when the Supreme Court felt that the way to manage the issue of obscenity was to personally review every single allegedly obscene movie, book, exposing these justices to whatever deleterious social effects these movies supposedly have.  Still, it was a pretty straightforward application of the prevailing legal standard at the time: whether to the average person, applying contemporary community standards, the dominant theme of the material taken as a whole appeals to prurient interest, so long as it was utterly without redeeming social importance.  In other words movies you watch just to see people having various kinds of sex, with no attempt to have a plot, characters, social significance, etc.  Which still doesn’t really tell you where the line between the good stuff is and the stuff that can be banned, does it?

Again, all of this is actually not remarkable for the doctrine at the time and the case is pretty much forgotten except for what Justice Stewart wrote in his concurrence: