In this last of a three part series on grand juries in the USA, Houston, Texas criminal attorney George Parnham explains a little understood part of our criminal justice system.
The United States is virtually the only common law jurisdiction in the world that continues to use the grand jury to screen criminal indictments, and the system is used on both federal and state levels. While all states in the U.S. currently have provisions for grand juries, only half of the states actually employ them and twenty-two require their use, to varying extents. Rather than using a grand jury, a more modern trend is to hold preliminary hearings before a trial court judge to determine probable cause that a defendant committed a serious felony.
In Texas (and Harris County particularly), the Texas grand jury system has come under scrutiny with allegations of witness intimidation and cronyism.
Grand juries are held in secrecy for good reasons: witnesses may hesitate to appear and deliver honest testimony if they are on public record, and defendants who are accused but not indicted could suffer consequences simply for being exposed to the process. But questions of transparency go beyond the secret nature of the hearings; it is difficult to know how often people with potential conflicts of interest are appointed to grand juries, whether they are racially and economically diverse or if witnesses are intimidated because much of the proceedings and documents are confidential.
Texas law allows judges in its 254 counties to decide for themselves
whether to have grand jurors chosen at random or selected by a "key man": a method frequently used by judges in Austin, Dallas and Houston.
Potential for abuse or manipulation increases as these judges do not select grand juries at random, instead appointing a commissioner who often turns to retired friends or connections in the legal and law enforcement community to find jurors sympathetic to their own attitude.
This “key man” system, used only in Texas and California, has faced several legal challenges with allegations that it can foster favoritism and taint grand jury makeup. Jurors are commonly drawn from particular segments of the community that may have strong ties with law enforcement officers, and may be more likely to enforce whatever the judge, prosecutor or officers say without proper scrutiny of facts. Texas defendants have challenged the racial composition of grand juries numerous times, and although the U.S. Supreme Court has upheld the constitutionality of the key man system they have warned that it is “highly subjective” and “susceptible of abuse.”
In this three part series on grand juries in the USA, Houston, Texas criminal attorney George Parnham explains a little understood part of our criminal justice system.
Grand Juries have recently made headline news in the USA after they have decline to indict police officers in cases which involved what many people consider unreasonable use of force.
On July 17, 2014, Eric Garner died in Staten Island, New York, after a police officer put him in a chokehold. Medical examiners concluded that Garner was killed by "compression of
neck (choke hold), compression of chest and prone positioning during
physical restraint by police", however the NYPD policy prohibits the use of chokeholds and law enforcement personnel contend that it was merely a "headlock".
On December 3, 2014 a grand jury decided not to indict officer Daniel Pantaleo, the NYPD officer accused of choking Garner to death. The event stirred numerous public protests and rallies with charges of police brutality. The Justice Department has announced an independent federal investigation.
On August 9, 2014 in the St. Louis suburb of Ferguson, Missouri, Michael Brown, an 18-year-old black man was fatally shot by Darren Wilson, 28, a white Ferguson police officer. The disputed circumstances of the shooting and the resultant protests and civil unrest received considerable attention in the U.S. and abroad, and sparked a vigorous debate about law enforcement's relationship with African-Americans, and police use of force doctrine in Missouri and nationwide.
The Prosecuting Attorney decided to bring the case in front of a grand jury to determine whether there was probable cause to indict Wilson for his actions. On November 24, it was announced that the jury had decided not to indict Wilson. Legal analysts raised concerns over the prosecutor's unorthodox approach, asserting that this process could have influenced the grand jury to decide not to indict, and highlighted significant differences between a typical grand jury proceeding in Missouri and Wilson's case.
Grand Juries almost always indict in criminal cases, with the common exception being cases which involve police officers. A recent Houston Chronicle investigation
found that “police have been nearly immune from criminal charges in
shootings” in Houston and other large cities in recent years. In Harris
County, Texas, for example, grand juries haven’t indicted a Houston
police officer since 2004; in Dallas, grand juries reviewed 81 shootings
between 2008 and 2012 and returned just one indictment.
There are at least three possible explanations as to why
grand juries are less likely to indict police officers; the
first is juror bias, in that jurors may tend to trust police officers even when the evidence says otherwise. Second is prosecutorial bias; because prosecutors depend on the
police while working on criminal cases, they may be inclined to present a less compelling
case against officers.
A third possible explanation may simply be that
prosecutors normally only bring a case to a grand jury if they think they can get an indictment.
But in high-profile cases such as a police shooting, public pressure can force them to bring charges even if the
case itself is weak.
The decisions by grand juries not to indict officers in these and other cases have spurred various proposals to reform grand
juries. One measure being considered by Congress would require that in an alleged crime involving a
police officer, the governor would appoint a special prosecutor to
conduct a public probable cause hearing that is open to the
public. If passed, law enforcement would
forfeit federal funding unless they adopt the new rules.
In Texas senators recently introduced bills to
eliminate what is referred to as the "key man" or "pick-a-pal" system, requiring the courts to randomly summon jurors instead of allowing a district judge to
pick three to five people to serve as grand jury commissioners, who are
then charged with finding 30 prospective grand jurors and selecting 12
who qualify. Critics have long argued that grand jurors in Texas are
often pulled from those with strong ties to the criminal justice system.
Some of the current proposals may deserve
consideration but they would have greater long-term impact and meaning
if they improve transparency within the criminal justice system more
generally, and are not limited to cases just involving police.
In this three part series on grand juries in the USA, Houston, Texas criminal attorney George Parnham explains a little understood part of our criminal justice system. In certain federal and state crimes, a grand jury is convened to review evidence
and hear witness testimony in order to determine if an individual
should be indicted. This process is a mystery to most defendants, and even many attorneys
are unfamiliar with how to handle the grand jury process.
The "grand jury" was instituted in England about
the middle of the twelfth century, intended to determine cause
for criminal prosecution. Though originally intended to hold the local community
responsible for bringing its malefactors to justice, it has come to
be regarded over the centuries as a safeguard against unwarranted
prosecution and was incorporated into the Fifth Amendment
to the United States Constitution, which provides that "No person shall be held to answer for a capital, or otherwise infamous crime, unless on a presentment or indictment of a Grand Jury, except in cases arising in the land or naval forces, or in the Militia, when in actual service in time of War or public danger..."
Individuals subject to grand jury proceedings do not have a constitutional right to counsel in the grand jury room, nor do
they have a right to confront and cross-examine
witnesses. Additionally, individuals in grand jury proceedings can be
charged with holding the court in contempt (punishable with
incarceration for the remaining term of the grand jury) if they refuse
to appear before the jury. All
evidence is presented by a prosecutor in a cloak of secrecy, as the
prosecutor, grand jurors, and the grand jury stenographer are prohibited
from disclosing what happened before the grand jury unless ordered to
do so in a judicial proceeding.
Grand jury proceedings are secret. No judge is present; the proceedings
are led by a prosecutor; and the defendant has no right to present his
case or (in many instances) to be informed of the proceedings at all.
While court reporters usually transcribe the proceedings, the records
are sealed. The grand jury can compel a witness to testify, but
the target of a grand jury investigation has no right to testify or put
on a defense.
The most persistent criticism of grand juries is that jurors are not a
representative sampling of the community, and are not qualified for
jury service because they do not possess a satisfactory ability to ask
pertinent questions, or sufficient understanding of local government and
the concept of due process. Unlike potential jurors in regular trials
grand jurors are not screened for bias or other improper factors. They
are rarely read any instruction on the law. The prosecutor drafts the charges and decides which witnesses to call, and is not obliged to present evidence in favor of those being investigated. The jurors job is only to judge on what the prosecutor produced.
According to the American Bar Association (ABA), the grand jury has come
under increasing criticism for being a mere "rubber stamp" for the
prosecution without adequate procedural safeguards. Critics argue that
the grand jury has largely lost its historic role of protecting citizens from unfounded accusations by the
government; they provide little protection to accused suspects
and are much more useful to prosecutors. Grand jurors often hear only the
prosecutor's side of the case and are usually persuaded by them: they almost always indict people on the prosecutor's recommendation.
If you have been accused of a serious crime in the state of Texas, you need a reliable and experienced attorney. Visit http://www.parnhamandassociates.com for information on your rights.
Age inappropriate: Texas must recognize 17-year-olds are teens, not adults deserving of prison time.
"In Texas, you have to be 21 to apply for a concealed handgun, 18 to play the lottery and 18 to get a body piercing without a parent's consent. Yet a nearly century-old Texas law treats a 17-year-old who shoplifts an iPhone as an adult criminal. He is held with adults in jail, tried in adult criminal court, sent to adult prison if incarcerated and issued a permanent adult criminal record. In 41 other states, such a youth would enter the juvenile justice system instead.
It's not just a question of whether 17-year-olds know the difference between right and wrong. Many teens that age have achieved the basic intellectual abilities of adults. With parental consent, 17-year-olds can enlist in the U.S. military. But according to behavioral research and brain science, the process of psychosocial maturation — in other words, development of the internal governor that compels us against engaging in risky behavior — is not complete until their adult years.
Not only brain science but a slew of depressing statistics supports the common-sense notion that 17-year-olds merit different treatment than adults.
Juveniles are five times more likely to be assaulted in adult rather than in juvenile facilities, often in the first 48 hours of incarceration, according to U.S. District Judge Reginald Walton, Chairman of the National Prison Rape Elimination Commission.
Youths under the age of 18 are 36 times more likely to commit suicide in adult institutions, says University of Texas professor Michele Deitch. Similarly, after their release, youths incarcerated in adult facilities are more likely to struggle to get a job or housing because of their adult criminal record.
The adult system does not offer the education, rehabilitative services or the strict probation rules that the juvenile system uses to hold younger teenagers accountable, reduce the likelihood that they will commit future crimes and help them turn their lives around. Interventions that incorporate substance-abuse treatment into community-based services and that emphasize school continuity may be particularly well suited to reduce recidivism among 17-year-olds, according to some experts.
Most of the crimes committed by 17-year-olds are nonviolent misdemeanors.
Everyone knows that prison is often a school for crime, where hardened criminals mold young people by their example. It is counterproductive and cruel to impose the lifelong collateral consequences of the adult criminal system on 17-year-olds who might respond to rehabilitation.
To remedy this inequity, the Legislature should expand the age of juvenile court jurisdiction to include 17-year-olds, except where special circumstances indicate adult-level supervision is required. Problems with implementation should not excuse inaction. Lawmakers can provide counties lacking juvenile facilities with the flexibility and funding to make alternative arrangements.
Seventeen-year-olds are not children. But they aren't adults, either, and it's time Texas stops treating them as such. We shouldn't throw away the key on a life yet to be lived."
The above editorial was published in the Houston Chronicle on Jan. 8, 2015.
Houston criminal attorney George Parnham has issued a response, stating that:
“I certainly do concur with the editorial opinion about raising the age of majority to at least 18. Medical science has proven that the frontal lobe of the brain, that portion that is responsible for ‘connecting the dots’ relative to risk assessment and decision making, is not fully developed at the age of 17. Ironically, the mid-twenties is more appropriate. A 17 year old who takes a car belonging to someone else does that act in all probability for the thrill of “joy riding.” Should that same car be taken by a 30 year old, the ultimate intent is to steal the car for one’s own use. I applaud the recent changes brought by the Supreme Court in dealing with juveniles and the death penalty, as well as life without parole. I would only hope that the State Legislature would follow the same impetus.”
Scott Panetti received his first diagnosis of schizophrenia in 1978 at the age of 20. Between 1981 and 1992, he was hospitalized 14 times at six different institutions for showing symptoms of psychosis characterized by tangential and circumstantial thinking, hallucinations, delusions, grandiosity, and paranoia. Extensive medical records chronicle these symptoms.
In 1986 Panetti experienced a psychotic episode during which he tried to "...wash the devil from the walls of his house" and buried the family's furniture in the backyard, believing the devil was in it. He nailed the curtains shut so that “the neighbors would not film him.” Shortly before the murders in September 1992 Sonja Alvarado tried to have him committed after he "...came after her with a knife". She took his guns to the local police but they simply returned them, claiming they had no legal right to prevent Panetti from having them.
At no point was there any suggestion that he is malingering or faking symptoms.
In July 1994 a competency hearing was scheduled to determine whether Panetti was fit to stand trial. In Texas, these hearings are held before a jury: in most other states a judge determines competency with input from psychiatric professionals. The jury was unable to come to a consensus, and the judge declared a mistrial. At a second competency hearing Panetti’s lawyer testified that in the previous two years he had had no useful communication with Panetti because of his client’s delusional thinking. A psychiatrist for the defense concluded that Panetti was not competent to stand trial; a psychiatrist for the prosecution agreed with the previous diagnoses of schizophrenia, and noted that Panetti’s delusional thinking could interfere with his ability to communicate with counsel. The same doctor reported that Panetti did not know what year it was and could not identify the president.
Yet he still concluded that Panetti was competent to stand trial, and the jury agreed.
At both competency hearings Panetti was medicated with large doses of antipsychotic drugs.
In 1995 Panetti experienced what he calls an “April Fool’s Day revelation”: he believed that God had cured his schizophrenia, and stopped taking his medications. He also became convinced that he could not trust his lawyers, whom he thought were conspiring with the police and the courts; after trying to fire them the judge apparently held no further competency hearing and allowed him to represent himself. When his trial began in September of that year court documents claim that his defense could be "...described charitably as bizarre"; in fact Scott Panetti conducted his defense dressed as a cowboy in a purple suit and a hat.
He attempted to call more than 200 witnesses, including John F. Kennedy, the pope, Anne Bancroft, and Jesus Christ. (The last he later recanted: “Jesus Christ, he doesn’t need a subpoena. He’s right here with me, and we’ll get into that,” Panetti said in court.)
He interrogated one prospective jury member as to whether the person had any “Indian blood,” before launching into a tirade about an event he called “Wounded Elbow”—conflating the battle of Wounded Knee with something to do with the Ayatollah Khomeini.
He cross-examined himself on the stand, addressing his alter ego “Sarge.”
He disposed of documents prepared for him by backup counsel, convinced that the prison guards were colluding against him. He presented no
mitigating evidence.
The judge declined to accept crucial medical records because Panetti had drawn all over them.
A psychiatrist who had assessed Panetti prior to trial and witnessed the proceedings says Panetti was “acting out a role of an attorney as a facet of the mental illness, not a rational decision to represent himself at trial.” After less than two hours of deliberation, the jury found Panetti guilty of murder and recommended capital punishment. (Life without parole was unavailable in Texas at the time.) In post-conviction proceedings the judge determined that he was incompetent to waive counsel.
Panetti v. Quarterman:
In 2007 Panetti’s case went to the U.S. Supreme Court, which held that the 5th Circuit Court of Appeals’ standard for assessing his competency for execution was unconstitutional. In Panetti v. Quarterman(2007), the court emphasized that evaluating Panetti’s factual understanding of the meaning of his execution and its consequences was not sufficient in light of his severe mental illness. The objectives of capital punishment, the court wrote, are not served “if the prisoner’s mental state is so distorted by a mental illness that his awareness of the crime and punishment has little or no relation to the understanding of these concepts.” Both the district court and the 5th Circuit ignored the court’s direction. Neither attempted to reconcile how a severely mentally ill man like Panetti, whose delusions and reality are so intertwined that he believes the judges and the State of Texas are conspiring with Satan to execute him, can possess a rational understanding of the connection between his crime and death sentence.
The District Court showed a fundamental misunderstanding of the nature of delusions when it found that Panetti’s delusions were not “constant,” citing an earlier visit between Panetti and his parents. Panetti’s parents would have no reason to “press his buttons” or place him under stress with challenging questions, unlike the experts who are tasked with evaluating competency. In any event, the district court overlooked evidence that Panetti did, in fact, speak of his delusions with his parents: he spoke repeatedly of his efforts to fulfill his destiny and bring the word of god to the men on death row.
For example, Panetti called the trial judge in his case a “devil worshipper” and explained: “Some of (these Death Row inmates) are possessed with devils. They’re anti- Christian, Satanists. So that’s why I’m here to deal with that.”
On appeal the 5th Circuit upheld this limited understanding of competency for execution. Under the 5th Circuit’s view, if a court can single out any shred of evidence that appears to show a prisoner’s rational understanding of the reason for his punishment, his delusional belief system and decades of severe mental illness are simply irrelevant.
The state does not dispute that Panetti believes that he would be executed for saving souls on death row, not for murder. It cannot be said that such a prisoner has the capacity to accept responsibility for his crime. If he doesn’t have a rational understanding of the link between his crime and his execution, the death penalty fails to serve its purpose as a punishment.
The courts should listen to the doctors who study psychotic disorders. The district court and the 5th Circuit’s reasoning downplays Panetti’s severe mental illness and how his delusions control his mind.
Request for Clemency:
In October 2014, a district judge signed a warrant setting Scott Panetti's execution date for December 3, 2014. Panetti’s attorneys only discovered this when they read it in the newspaper two weeks later; the office of District Attorney Bruce Curry did not notify them, as is the pattern and practice of capital law in Texas. Panetti’s attorneys might have used that time to attempt to save his life. Texas has been scheduling executions in 2015: they pushed Panetti’s ahead so it can happen in 2014.
Petitions from over 50 national evangelical leaders as well as former Congressman Dr. Ron Paul are being submitted to the Texas Board of Pardons and Parole and State Governor Rick Perry requesting them to consider granting Scott Panetti’s clemency petition and commute his death sentence to life in prison. The petitions claim that: "The execution of Scott Panetti would be a cruel injustice that would serve no constructive purpose whatsoever. When we inflict the harshest punishment on the severely mentally ill, whose culpability is greatly diminished by their debilitating conditions, we fail to respect their innate dignity as human beings."
The U.S. Supreme Court should take Panetti’s case and clarify a precise standard for determining a prisoner’s competency for execution. Current law has left the lower courts with unfettered discretion in determining which prisoners will be executed. If we want to live in a just, humane society, we cannot continue to fail to protect people with severe mental illness from execution.
Houston criminal attorney George Parnham is an expert on the defense of individuals with mental illness and a passionate advocate for legal reform of their treatment in the criminal justice system.
As computers have become a part of daily life, so have prosecutions involving the use of computers as a vehicle for child pornography.
Otherwise innocent people may find themselves caught up in overzealous
government investigations of internet sex crimes.
Internet sex crimes such as possession of child pornography or
online solicitation make media headlines, especially when business
owners, teachers, or other prominent citizens are facing these
accusations. Using the internet to solicit sexual acts from a minor is
an incredibly serious offense. Any sex crime charge, even if false, can
be extremely damaging. That's why it's important to seek immediate and
aggressive legal representation.
Some pornography web sites can install software on your computer or come
looking for you without your knowledge, and can then send you to
another web site containing potentially illegal content. In addition
police officers often pose as minors and seek to entice visitors to
Internet chat rooms. In many of these situations, there are several
legal means by which to challenge the legality of the this
process.
Federal law defines “child pornography” in 18 USC Section 2256(B) (8): as "any visual depiction, including any
photograph, film, video, picture, or computer or computer-generated
image or picture, whether made or produced by electronic, mechanical, or
other means, of sexually explicit conduct, where—
(A) the production of such visual depiction involves the use of a minor engaging in sexually explicit conduct;
(B) such visual depiction is a digital image, computer image, or
computer-generated image that is, or is indistinguishable from, that of a
minor engaging in sexually explicit conduct; or
(C) such visual depiction has been created, adapted, or modified to
appear that an identifiable minor is engaging in sexually explicit
conduct."
In addition, the Texas Penal Code Section 43.26 states that a person commits an offense if "the person knowingly or intentionally possesses visual material
that visually depicts a child younger than 18 years of age at the time
the image of the child was made who is engaging in sexual conduct; and... the person knows that the material depicts the child".
Strict child pornography laws are important in the fight to keep our children safe from predators and others who attempt to exploit their innocence for criminal purposes. But because the laws are overly broad, they often have the opposite result and can easily be used to convict innocent people.
One example is a fad among teenagers known as "sexting", which involves sending or receiving sexually explicit text messages or photos via cell phones. Although most people understand the difference between a teen's poor decision and an adult exploiting a child for sexual purposes, the law makes no such distinction; in fact, even if the minors consensually shared personal images, both the sender and receiver can end up in
juvenile jail and be forced to register as sex offender for the rest of their lives. In addition to identifying the child to the public, sex offender registration will impact their ability to
get a job, live in certain areas and travel freely throughout their adult life.
Another commonly held assumption by law enforcement is that if a pornographic file shows up
on your computer, it must be yours. In reality, that isn't necessarily the case and with proper legal defense it can be difficult for the prosecution to provethat the file was yours.
In fact there are multiple ways for media to to be downloaded to a person's computer without their knowledge. One of the most obvious, of course, is simply for another user to download files on a shared hard disk drive. But with the expansion of the internet and related technology, especially P2P or file sharing software such as BitTorrent and Limewire, people are increasingly at risk of not only unintentionally downloading illegal materials but also sharing them over the P2P network. A common example is the downloading of multi-part file packages such as .zip, .rar or .7z. These are compressed directories containing multiple files, and although the downloader may only be interested in part of the content they seldom know exactly what the package contains. Additionally, files from anonymous sources may often be intentionally mislabeled or misidentified.
Another possible means of unknowingly spreading or accepting illegal digital media is through computer viruses or hacking. Illegal "botnets" have become a serious internet issue and can be used to literally take over a computer without the owner's knowledge or consent.
When a user's computer is infected with certain types of malicious software, or "malware" -which may lurk in virtually any email, website or digital file- modules are installed which allow the computer to be surreptitiously controlled by a third party. These robot networks of infected computers, or "botnets" can then be directed to connect to IRC channels, download and disseminate files, send mass email messages (spam), or to repeatedly connect to a specific URL, instigating a denial of service (DDOS) attack. In some cases the hacker may even take command of peripheral devices such as a connected webcam, all without the knowledge of the computer's owner.
Serious issues are also connected with the way your computer records and stores the media files that your web browser encounters while you're surfing the internet. Unbeknownst to many people, older versions of browser software such as Internet Explorer and Firefox can, by default, automatically download and save a copy of every media instance -digital photograph, "Flash" video, and graphic- that they encounter. These may include pop-up and pop-under advertisements that the user doesn't actually see. Although modern web browsers include better controls over what the user allows to be saved by default, they are often complicated to use and poorly documented. These images may stay in your browser history indefinitely without your knowledge.
One tool that a defense attorney may use in fighting child pornography charges is metadata- information attached to every digital file which can be used to trace its origin. .JPEG images, a popular file format, usually contains a wide variety of information
including the camera's make and model, focal and aperture information, timestamps and sometimes even GPS coordinates.
Internet crime cases are often highly complex and technical. The specific penalties that a defendant faces for a federal computer crime conviction will vary depending upon the particular offense: imprisonment may be a common denominator for all computer crimes, heavy fines and victim restitution are likely in a case involving fraud and sex offender registration is mandatory in a case involving child pornography.
Criminal defense strategies applied in these situations need to be created for the particular offense, evidence involved and based upon the defendant’s needs. Contact Parnham & McWilliams today at (713) 224-3967 or click here for our convenient online submission form.
We will work tirelessly to ensure the best possible outcome for your case.
"Domestic violence" is physical or threatened violence and abuse occurring within a relationship between married or cohabiting couples, couples who have a child in common, persons who were formerly married to one another or basically any couple who are in a relationship or who have had a former relationship.
A domestic violence charge in the state of Texas is extremely serious; it often carries a restraining order which may require you to
leave your house immediately and stay away from the person who accused
you of domestic violence. Even if you own the house or pay for it, you
will have to leave. In addition, you will likely face jail time,
probation, counseling and more.
There are graduated penalties for these types of offenses depending on
the particular circumstances of the event and the history of the
individuals involved. Many, if not most, of the penalties are severe.
Even sentences of Probation can, and often do, come with special
conditions that make successful completion more expensive, time
consuming and difficult.
In addition to the criminal charge itself, Domestic Violence cases carry
many far-reaching collateral consequences, which, in many cases, may be
more severe than the criminal penalty itself. The consequences include
but are not limited to: your ability to own and possess a firearm, serve
in the military, your ability to live in your home or maintain contact
with your children.
The potential consequences for non-U.S.
citizens are of particular importance; federal law can characterize these offenses as “Aggravated
Felonies”, “Crimes of Violence” and “Crimes of Moral Turpitude” even
when the criminal charge itself is only a misdemeanor. As a result,
these charges can and often do result in deportation, denial of
naturalization and exclusion from admission to the United States. A
person charged with these types of offenses may be subject to these
collateral consequences even where they received deferred adjudication, a
petition for non-disclosure, or an expunction.
Being charged with domestic violence does not mean you are
automatically convicted. Many domestic assault cases rely solely on an
accusation from the victim with no corroborating witnesses, and we may
be able to challenge the accuser’s credibility. Contact Parnham & McWilliams today at (713) 224-3967 or click here for our convenient online submission form.
Depending on the circumstances, we have many options in mounting a strong defense for you.
