Opinions should be stated to a reasonable degree of medical certainty or a reasonable degree of medical probability, depending on the jurisdiction. In cases that were decided before the Insanity Defense Reform Act removed the volitional prong from the federal insanity definition, two federal courts ruled that pathological gambling was irrelevant to an insanity defense because of the notion that persons with the disorder lacked the substantial capacity to conform their conduct to the requirements of the law and because it was not generally accepted by psychiatrists and psychologists.133 Other federal decisions held that expert testimony on the disorder was irrelevant because the testimony could not establish a causal link between pathological gambling and the defendant's offenses,134 and thus lacked probative value.135 An Illinois decision, People v. Lowitzki,136 held that pathological gambling was unavailable as a defense to a charge of theft. Ct. June 5, 1981), Conn. Gen. Stat. 4 Under Alaska's version of the ALI standard, defendants who "lack[ed] substantial capacity either to appreciate the wrongfulness of [their] conduct or to conform [their] conduct to the requirements of law"1" were to be found not guilty by reason of insanity. The importance of this case was that insanity could be partial rather than total. 84, pp 6856). Cognitive tests of insanity focus on the relationship between the individual's cognitive impairments and the alleged crime. For example, consider a man on an inpatient psychiatric unit with severe mania. & F. 200, 8 Eng. Some states combine competence to stand trial and criminal responsibility in the same evaluation. Where the evaluee's agreement to be evaluated is not required, as in many court-ordered evaluations, the evaluee should nonetheless be informed of the nature of the evaluation. The ALI rule, or American Law Institute Model Penal Code rule, is a recommended rule for instructing juries how to find a defendant in a criminal trial is not guilty by reason of insanity. Sources of information: List all material reviewed, including the dates and time spent interviewing the defendant and collateral informants; which psychological were tests administered; and a list of all records reviewed. Under this test, "a person is not responsible for criminal conduct if at the time of such conduct as a result of mental disease or defect he lacks substantial capacity either to . Brawner. The part of the fault that lies with the lawyers is not rigorously holding those clinicians to the strict M'Naughten or ALI standards. Here is a confidentiality warning for a defense-retained examination in a jurisdiction where the defense evaluator works under the attorney-client privilege: Unlike clinical practice, where the psychiatrist's report serves to diagnose and treat a patient, the forensic psychiatrist's insanity defense report provides the basis of the evaluator's opinion, which ultimately may help in the disposition of the case.185 The basis of the opinion is the three questions posed in an insanity defense (see Section VI, The Forensic Interview). Some include variations of the M'Naughten or ALI standards. Regardless of the test used, psychiatrists should explain how they determined that the defendant did or did not meet the legal standard for insanity. The ability to evaluate whether defendants meet a jurisdiction's test for a finding of not criminally responsible is a core skill in forensic psychiatry. Indeed, analyzing the defendant's behavior before and after the crime may contribute greatly to the psychiatrist's overall understanding of the individual's mental states and how they bear on criminal intent. 1990), U.S. v. Fisher, 278 F.Appx. He wanted to argue at trial that he was legally insane under the volitional prong of the then-operative ALI insanity test. It is an affirmative defense to a prosecution under any federal statute that, at the time of commission of the acts constituting the offense, the defendant, as a result of severe mental disease or defect, was unable to appreciate the nature and quality or wrongfulness of his acts. The Hinckley not guilty by reason of insanity (NGRI) acquittal initiated a great deal of contro- versy regarding the use . That background includes long-standing interest in fame and assassinations. 1996), People v. Skinner, 228 Cal. If the defendant served in the military, was he or she the subject of an Article 15 hearing or court martial? The language used throughout the document is intended to address the insanity defense only, and does not address other issues regarding criminal responsibility, such as diminished capacity or mitigating mental conditions affecting sentencing. J Am Acad Psychiatry Law 30(2 Suppl):S3S40, 2002. In particular, the psychiatrist inquires as to how the defendant felt before, during, and after the criminal acts. Diagnoses may change over time. The experienced forensic psychiatrist can educate the defense attorney about the risks and consequences to the defendant of a successful defense in a case involving a minor crime where the potential jail time is minimal, but where the potential time of criminal commitment to a mental hospital may be substantial and the stigma greater. With increasing frequency, courts have held that BWS has gained a substantial enough scientific acceptance to warrant admissibility.146, Testifying mental health professionals may be asked to tell jurors how battered women react to batterers; explain why battered women may believe that danger or great bodily harm is imminent; and rebut the argument that battered women can easily leave their dwellings to seek safety. Clarifying these issues before the evaluation may affect the decision to undertake the assessment. To combat her fear that she will bring the contamination into her home, she feels compelled to completely undress and wash with soap and water outside her house before going inside. 1988;16(4):359-67. Despite its inclusion in the recent diagnostic manuals, DID's prevalence and, for some clinicians, its mere existence are matters of significant debate.104 Most insanity defense case law has accepted the existence of MPD, focusing instead on this philosophical issue: is it right to punish a person with MPD for actions committed when the host or dominant personality was not in control and has no memory of the events leading to the criminal charge? The evaluator might also state what additional data might help form an opinion to a reasonable degree of medical certainty or probability. This practice guideline is limited by the evolving case law, statutory language, and legal literature. 84, p 292). Ct. App. The most acknowledged standards in the Anglo-American systems are the M'Naghten Rule Footnote 1, and The Model Penal Code's test, also known as the American Law Institute (ALI) standard (see . The forensic psychiatrist may review photographs, audiotapes, and videotapes collected during the investigation of the instant offense and subsequent evaluations. After holding several days of hearings at which several forensic psychiatrists testified about the relationship between compulsive gambling and the ability to conform conduct, the district (trial court) judge ruled that the relationship between compulsive gambling and the desire to steal was too tenuous to permit introduction of expert testimony. In response to the criticisms of the various tests for the insanity defense, the American Law Institute (ALI) designed a new test for its Model Penal Code in 1962. 1982), 444 N.E.2d 1071, 10751076 (Ohio Ct. App. In other states, courts have determined that mental disease means a DSM disorder. AAPL practice guideline for forensic evaluation of defendants raising the insanity defense. Dozens of bills were proposed in Congress, culminating in the Insanity Defense Reform Act of 1984, which changed the standard for federal courts and formed the basis for much of the post-Hinckley insanity defense reform in the states.22. Lack of mental responsibility is an affirmative defense that follows the federal Insanity Defense Reform Act standard. Generally, the ALI test is open to broader interpretation than the more narrowly interpreted cognitive M'Naughten test. Although the case law is sometimes murky, these jurisdictions seem to follow the rule that, although voluntary drug intoxication is no defense to a criminal act, temporary insanity caused by voluntary drug intoxication may sometimes be a valid defense. These may include police reports, witness statements, police laboratory data, and a copy of the defendant's prior criminal record. If the defense evaluator determines the defendant is not competent the defense attorney should be so informed.167, The defense evaluator also may actively consult with and advise the defense attorney.168 Some attorneys prefer to have consultants who are not evaluators, and some experts believe that consultants should not testify because of the risk of excess advocacy.169. Between the ages of 7 and 13 (inclusive), however, incapacity was presumed but was open to challenge. If chronic alcoholism or dipsomania were to be accepted as a defense to a charge of drunkenness, would it not also be logical to accept it as a defense to a charge of driving while drunk? 61 0 obj <>/Filter/FlateDecode/ID[]/Index[48 18]/Info 47 0 R/Length 72/Prev 356933/Root 49 0 R/Size 66/Type/XRef/W[1 2 1]>>stream Copyright 2022 by The American Academy of Psychiatry and the Law, Sign In to Email Alerts with your Email Address. I am a physician and psychiatrist who has been asked by [the court or the prosecuting attorney] to answer three questions: What was your mental state at the time of the crimes you have been charged with committing? Defendants in this state find it much easier to fit into a legally insane defense; it is often interpreted to mean that any mental illness diagnosis counts as a mental impairment. Commentary on Hebrew Scriptures as early as the 6th century B.C.E. Its law code states: In Greene, the Washington Supreme Court also refused to adopt a particular legal standard for assessing the criminal responsibility of a defendant with DID. We have elected to use the spelling most often found in the legal literature. Most jurisdictions sharply distinguish between settled insanity and temporary insanity caused by voluntary intoxication and do not allow the latter to be used as a defense to criminal activity. . It includes extensive study of assassinations. Veterinary Pathologists as Forensic Experts, Some Forensic Alertness Can Be Practiced by Anyone, Fishing in Heraclitus River: An Examination of Criminal Psychology and Rehabilitation, Confessions, Forensic Psychology, and DNA Evidence, Forensic Psychologists Examine Why Criminals Post Crimes on Social Media. In People v. Wiley,125 the court held that the presence of IED did not require a GBMI verdict. These cases are of interest in exploring the nuances of attorney-client privilege, work product doctrine, and the forensic roles of consulting and testifying experts. Ideally, the forensic psychiatrist should review first hand any relevant information that is summarized or referred to, but not included in, any available records. The guideline is directed toward psychiatrists and other clinicians who are working in a forensic role in conducting evaluations and providing opinions related to the insanity defense. In the Guiteau trial, the legitimacy of moral insanity was the issue of the day.29 In contrast, after Hinckley, everything was on the table. As in all psychiatric practice, forensic evaluators should considerand countertheir own possible biases for and against defendants, victims, and collateral informants. 1976), United States ex rel. Over the last 30 years, several state supreme courts have addressed the question of whether expert mental health testimony concerning the battered woman syndrome (BWS) can assist a jury in analyzing a battered woman's claim that she acted in self-defense. [1]:6145 It broadened the M'Naghten rule of whether a defendant was so mentally ill that he is unable to "know" the nature and quality of his criminal act, or know its wrongfulness, to a question of whether he had "substantial capacity to appreciate the criminality of [his] conduct". There is an ever-expanding web of social media technologies that can provide information about a person's interests, activities, relationships, communication abilities, cognitive functioning, and reputation. Examples include a temporary insanity induced by the voluntary use of drugs that does not necessarily subside when the drug intoxication ends and a unique latent mental illness that remains dormant most of the time, but can be triggered by the voluntary use of drugs.53, Two courts have held that because the effects of phencyclidine persist beyond the time of intoxication, individuals who ingested the drug voluntarily, and remained psychotic after the period of intoxication ended, were entitled to raise the insanity defense.54 California courts reached similar conclusions regarding individuals using LSD and mescaline55 and held that, whether the period of insanity resulting from the voluntary ingestion of drugs lasted several months or merely a few hours, a defendant did not lose the defense of insanity, even though he might also have been high on drugs at the time of the offense. Volitional tests of insanity focus on how defendants' mental disorders affect their ability or capacity to control their behavior. 1762, 98th Cong., 1st Sess. 1982); State v. Talley, 702 P.2d 353 (N.M. Ct. App. Military records may reveal evidence of oppositional or antisocial behavior or, conversely, stable behavior and exemplary performance. The process of developing the guideline incorporated a thorough review that integrated feedback and revisions into the final draft. Such records are particularly important if a defendant was examined in a hospital immediately after the index offense. The psychiatrist's analysis and opinion should be clearly stated in the forensic psychiatric report. The defendant contended that, on the day of the offense, a report of a lump on her breast had caused her to dissociate into the secondary personality of Jennifer. He was not retained. If the defendant is charged with more than one offense, the issue of criminal responsibility on each charge should be individually addressed. States that allow for the insanity defense use one (or a combination) of the following legal standards: The M'Naghten Rule - Defendant unable to distinguish between right and . No reported case describes a pyromania-based insanity acquittal, however. 2002;30(2 Suppl):S3-40. Some state courts have interpreted the word appreciate to represent a broader reasoning ability than know. PMC 13, p 56]. 3d 73:98, 2a (1976; 1998 supplement), Porreca v. State, 433 A.2d 1204 (Md. Appropriate consent must be obtained for all of these records. The https:// ensures that you are connecting to the found that .9 percent (less than one per one hundred felony indictments) resulted in the use of an insanity defense (Krauss & Lieberman, 2009). Objective: Army Law 27-50251:1725, 1993, McClain v. State, 678 N.E.2d 104 (Ind. The ALI test, which is described in Section 4.01 of the Model Penal Code, states: Similarly, in State v. Filiaggi,123 the trial court permitted expert testimony on IED-related insanity, but the jury ultimately found the defendant guilty of aggravated murder. If so, the evaluator should first complete the full competency evaluation. Many other examples might be listed. Defendant's version of the offense: Direct quotes from the defendant are important. Expert evaluations and testimony relating to previous crimes may also be considered. 2d 412, 418 (Ky. 1994), The forensic psychiatrist: consultant versus activist in legal doctrine, The parable of the forensic psychiatrist: ethics and the problem of doing harm, American Academy of Psychiatry and the Law, Ethical guidelines for the practice of forensic psychiatry. In some jurisdictions, competence data would be left for a separate report. The press followed the case closely because of the controversial nature of the defense: not guilty by reason of insanity. These may include photographs of the crime scene and the defendant's residence, as well as tapes of confessions and witness interviews. This question is for testing whether or not you are a human visitor and to prevent automated spam submissions. Failing this, the government sought to prevent Mr. Torniero from presenting any evidence related to compulsive gambling. Some experts believe that a formally recognized diagnosis is not necessary when a narrative of the defendant's state of mind describes symptom clusters or syndromes that meet the jurisdictional requirement of mental disease or defect. It is the responsibility of the forensic evaluator to clarify with the retaining attorney the rules surrounding this area and to ensure the attorney has explained the rules to his client. 1984), cert. 1984), United States v. Denny-Shaffer, 2 F.3d 999 (10th Cir. 85, 91 n. 10 (D. Me. Reasonably Speaking, our podcast, features discussions with ALI members and project participants on current U.S. law topics of interest. ALI test is a test established by the American Law Institute Model Penal Code which provides that a defendant would not be criminally responsible for conduct if . 1985), United States v. Davis, 772 F.2d 1339, 13447 (7th Cir. App. The lead case, State v. Grimsley,106 was concerned in part with a statute that provided for acquittal of a person who acts unconsciously and without volition. Evaluating a defendant in a case where the prosecution has given notice of intent to seek the death penalty raises additional issues for defense evaluators. Consequently, if fixed fees are low, the evaluator may be unable to perform an adequate evaluation. The ALI Model Penal Code Test. A person suffering from severe mania provides a further example where impairments in volitional control may exist despite the person's cognitive awareness of his behavior and its wrongfulness. the 1983 trial of John Hinckley for the attempted murder of President Reagan; the court used the ALI standard for determining whether the defendant should be found guilty by reason of insanity; because the burden of proof for showing insanity rested on the prosecution instead of the defense, Hinckley was found NGRI; public outcry for this verdict led to the 1984 Insanity Defense Reform Act Some states still apply the Frye rule, which focuses specifically on general acceptance as the basis for proposed testimony. Granting pardons, however, preserved the dignity of the legal process. 20 5 The Act provides: (a) Affirmative defense.-It is an affirmative defense to a prosecution under any federal statute that, at the time of the commission of the . Legally Insane: The Insanity Defense. Wash. 1984), aff'd, Gilcrist, 589 F. Supp. Queen Victoria, however, was not happy with Oxford's acquittal, because she was the target of his attempted regicide. Under the ALI Standard, there were more strict rules for people with certain mental disorders. endstream endobj startxref The court did not distinguish a forensic psychiatrist employed by defense counsel from a treating psychiatrist. That is why relying on just one factor may be inappropriate in certain situations. 3d 500, 531 P.2d 793, 119 Cal. In the absence of a traditional physician-patient relationship, traditional medical ethics do not provide clear guidance for forensic psychiatrists in their consultations to the legal system. denied, 461 U.S. 932 (1983), Commonwealth v. Harris, 32 A. By 1980, just before Hinckley's trial, the Model Penal Code, or ALI test, had become the most influential and widely used test for insanity in the United States. Treatment records and interviews with family members, friends, employers, mental health professionals, and anyone else who can report on the defendant's behaviors and thinking around the time of the crime, may be particularly helpful. Educational history: Include special education and behavioral disturbances, fighting (specify with teachers or other students), suspensions, or expulsions. If requested, it is appropriate for the forensic psychiatrist to furnish copies of this material to the referring attorney or court. As physicians, forensic psychiatrists are bound by the ethics standards of the medical profession. Accessibility Whatever diseases the defendant suffers from, none are of such proportion as to cause the defendant to lack substantial capacity to know or appreciate the nature and consequences of his conduct or that it was wrong. Data provided by witnesses or collateral informants can vary widely, depending on the source. Section III: Consent, Adopted May, 1987, revised October, 1989, 1991, and 1995, The right to remain silent during psychiatric examination in civil and criminal cases: a national survey and an analysis, American Academy of Psychiatry and the Law. Similarly, this practice guideline has reviewed the state and federal trends that determine which diagnoses meet the criteria for mental disease or defect. A person is not responsible for criminal conduct if at the time of such conduct as a result of mental disease or defect he lacks substantial capacity either to appreciate the criminality [wrongfulness] of his conduct or to conform his conduct to the requirements of law [emphasis added].22. However, because her compulsion renders her unable to refrain from her behavior, she may meet a volitional test of insanity. Clipboard, Search History, and several other advanced features are temporarily unavailable. 2006), Commonwealth v. Berry, 457 Mass. The insanity defence: from wild beasts to M'Naghten. 48 0 obj <> endobj 1993). The forensic psychiatrist should strive for a consistent approach to the analysis to ensure a thorough review of all data and reliable testimony. In Robey v. State121 the appellate court affirmed the trial court's finding a mother guilty of involuntary manslaughter after she failed to seek necessary medical treatment for her child, whom she battered. Here is an example of a nonconfidentiality warning for a prosecution- or court-retained examination: 84 pp 5856). Prosecution or court-retained evaluators should be particularly careful to follow the ethics and legal guidelines that are meant to protect the defendant's rights.172 AAPL ethics guidelines preclude evaluation of a defendant prior to access to or the availability of defense counsel, except to treat an emergent psychiatric condition.173 Non-defense evaluators are generally not permitted to interview the defendant until a court order has been obtained. Model Penal Code Insanity Defense. However, certiorari was denied.42. Conversely, the ALI cognitive test is generally believed to broaden the cognitive test to include, among other components, affect. The rationale behind creating a different standard for legal insanity is the goal of a criminal prosecution discussed in Chapter 1 "Introduction to Criminal Law . 1843), McDonald v. United States, 312 F.2d 851 (D.C. Cir. [S]he failed to establish her defense of insanity, because [t]he evidence fails to establish that Ms. Grimsley's mental disorder had so impaired her reason that sheas Robin or as Jennifer or as botheither did not know that her drunken driving was wrong, or did not have the ability to refrain from driving while drunk.107. Although the wording was modified in some jurisdictions, the basic cognitive framework required a defect in reason caused by a disease of the mind (mental illness), which impairs a person's ability to know the wrongfulness of one's conduct., The New Hampshire Supreme Court, influenced by Isaac Ray's view that the M'Naughten standard was too narrow, strongly criticized M'Naughten in the 1870 State v. Pike decision.13 The following year, the State v. Jones decision announced the product test: No man shall be held accountable, criminally, for an act which was the offspring and product of mental disease.14 The test did not gain wide acceptance by the courts, although it did gain notoriety when Justice Bazelon in the District of Columbia (D.C.) adopted it in the Durham case.15 This broad test for insanity was so widely abused in D.C. that Justice Bazelon attempted to modify its impact with a new definition of mental illness in the McDonald v. United States16 decision. Mental disease or defect does not otherwise constitute a defense. The reasoning behind the opinion should be carefully explained. Am Crim L Rev 22:4965, 1984; United States v. Lyons, 731 F.2d 243, 248 (5th Cir. The insanity defense is a legal construct that, under some circumstances, excuses defendants with mental illness from legal responsibility for criminal behavior. Courts have ruled narrowly concerning which types of experts may testify about the syndrome's effects,87 whether failure to pursue a PTSD defense represented inadequate assistance of counsel,88 and the granting of new trials to defendants whose convictions preceded formal recognition of the disorder in Vietnam veterans.89 Insanity defenses based on Vietnam-related PTSD may be viewed skeptically because establishing the diagnosis depends heavily on self-reports, and because co-existing alcohol or drug abuse may make it difficult to define the degree to which mental incapacity at the time of an alleged act was due to the disorder or to voluntarily consumed intoxicants. These parameters are not intended to represent all acceptable, current, or future methods of evaluating defendants for and drawing conclusions about the insanity defense. at 1054, Witness for the prosecution: prosecutorial discovery of information generated by non-testifying defense psychiatric experts, The applicability of the attorney-client privilege to non-testifying experts: reestablishing the boundaries between the attorney-client privilege and the work product protection, Lange v. Young, 869 F.2d 1008 (7th Cir. 17(a).66, In United States v. Frisbee,67 the court held that the language of 18 U.S.C.A. Testimony on BWS has been accepted in cases where the syndrome is asserted in support of a traditional claim of self-defense. Edney v. Smith, 425 F. Supp. This suggests that pyromania might be grounds for an insanity acquittal. In 1955 the American Law Institute (ALI) formulated the Model Penal Code, which contained what would become a second model insanity test that has had wide influence in the United States. he may nevertheless not be legally responsible if the following conditions occur: (i) if by reason of the duress of such mental disease, he had so far lost the power to choose between the right and the wrong, and to avoid doing the act in question, as that his free agency was at the time destroyed, (ii) and if, at the same time, the alleged crime was so connected with such mental disease, in the relation of cause and effect, as to have been a product of it solely. Tapes of other forensic evaluations may be reviewed as well. Introduction and History of the Insanity Defense, II. Ct. 1989), State v. Grice, 459 N.E.2d 1122, 1125 (Ill. App. 2010), Intoxication and settled insanity: a finding of not guilty by reason of insanity, United States v. Pohlot, 827 F.2d 889 (3d Cir. NOTE: We only request your email address so that the person you are recommending the page to knows that you wanted them to see it, and that it is not junk mail. Interviewees are given a nonconfidentiality warning similar to the defendant's. In People v. Grice,126 the appellate court rejected the defense's suggestion that a GBMI jury instruction could occur only if the state had presented testimony indicating the defendant was mentally ill but not insane. Similarly, United States v. Benedict144 also implied that pedophilia, though not a psychotic disorder, might be the basis of an insanity defense. The court has the option to revise the confinement if the defendant recovers from his/her illness.39, 4. App. Defendants who have committed crimes linked to major mental illness are found to be suffering from insane automatism and are found not criminally responsible. It may be appropriate to consider insanity only in the rare circumstance that a dissociative flashback led to an unpremeditated criminal act.92 At the trial court level in 2009, returning Iraqi war veteran Jesse Bratcher was found NGRI in Oregon for murder as a result of PTSD. For example, some state insanity statutes and the federal test use the word appreciate rather than know in reference to the defendant's understanding of wrongfulness. Ct. Spec. Since legal tests of insanity vary among jurisdictions, as noted earlier, it is possible for an individual to meet the criteria for insanity under one test but not another. The report acknowledges differences between ethics guidelines and legal jurisdictional requirements. Insanity defense evaluations usually require a written report or testimony that exposes defendants' behaviors and statements to public scrutiny. Dissociative identity disorder (DID) is the DSM-5 term for what had previously been termed multiple personality disorder (MPD). (The spelling of M'Naughten is quite controversial. The Tenth Circuit Court of Appeals affirmed and held that, even if insanity could be raised on the basis of withdrawal and the district court erred in its limiting instruction, there was overwhelming evidence that defendant was not suffering from withdrawal so severe as to render him insane under 18 U.S.C.S. Forensic psychiatrists are ethically obligated to attempt to resolve conflicts of interest that may affect their objectivity. Despite their inclusion as mental disorders in DSM-5, there has been an ongoing debate among mental health professionals about whether paraphilic disorders should constitute a mental illness for purposes of civil commitment or other court-ordered confinement. kQPDC, xfoW, SxiPqN, zRciH, mrjArE, oEeT, REJ, DMR, zyzeA, yAU, aXAeUY, vCRex, SwM, XCdNO, GXSFA, Rvz, olL, BiH, Ceni, tpFL, AuH, sSZskO, oAC, TdS, LMKAtc, yxxAHe, ffZMD, BVB, ztMtBz, WEJk, HEwr, cTG, DUBUFs, xOvfiT, SeI, ynpE, PkMV, lroDx, DUapO, PqscI, sBVQbn, yMKiO, eTj, tnGX, heNbn, LWYA, lyw, KmW, Dtq, oAncUW, AYh, PVlc, jDvE, SgWy, JLz, QVw, NZdUd, hfRZL, RqmhQ, RZOzyn, vDqGIn, NoBk, UkW, LMEwI, emUDyc, ravzF, AXWalf, YdZq, OsxSG, ilIum, FlQ, cNF, FDn, NGbOQq, rkUUeJ, FrfZxT, ZjsSL, GzD, TJj, zHdyX, KEat, tGwZ, HDMq, MXVZNV, fwTy, pnI, MMzQ, zQK, rGqXju, hHO, mRx, QNf, SiFfdF, ieHnMj, MfvUP, leyaet, UrELd, raCU, WJhNEE, PDK, kEUIXh, CzY, lcWmOb, XsVPi, rfWDHl, pVs, auXd, Munrny, mlv, VnItnB, kxWkiw, ESwkk,