More Georgians refusing sobriety tests

By Jessica Towne

The number of people refusing the sobriety test in Georgia doubled, from 5,608 in 2008 to 11,480 in 2013.

The Georgia Health News service recently published an article that manged to turn this fact into the basis for calling for more DUI convictions. You see, the State of Georgia collects lots of tax money to fund various projects when someone is convicted of DUI. And MADD wants us to believe that DUI convictions are down because drivers are taking advantage of the legal system, when in fact, some drivers are exercising their constitutional and statutorily granted rights. MADD and Georgia prosecutors  think the conviction rate is down because more drivers are exercising their right to refuse a breath or blood test.

Perhaps more drivers are aware that they don't have to take field sobriety tests alongside the road when they're asked to step out of their cars those tests are voluntary. Most times, the evidence a driver "volunteers" is what gets one arrested, breath test or no breath test. 

I think the rest of the statistics in that article leave a lot of unanswered questions:

How many people were arrested for DUI in 2008, and how many in 2013?Of those arrested, how many were found to be unlawfully stopped?Of those arrested, how many were found to be unlawfully arrested?Of those arrested, how many were found not guilty after trial?

I understand that drunk drivers account for some accidents resulting in injuries and deaths on Georgia highways. But most DUI arrests do not involve crashes.  MADD and the other agencies that lobby legislative bodies should answer these questions before they decide that more and more of us ought to be convicted of DUI. Have they even considered that perhaps drivers are getting the message?  Maybe we simply don't drink and drive as much we used to. Did that statistical analysis consider that we instead call cabs, we designate drivers who stay sober, we use Uber and Lyft, and we don't let our friends drink and drive?

Statisticians, I'm all ears. 

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Field sobriety tests could impact you this weekend

A few weeks ago, we talked about the implied consent law here in Minnesota. Basically what this law means is that if you are legally arrested for driving under the influence, you must give a blood, breath or urine test. You do not have a right to refuse this. We bring this up because with the Labor Day weekend upon us, there will be plenty of people who are dealing with law enforcement over the weekend, and they need to know their rights.

Since Aug. 13, the police have been performing a massive crack down of drunk driving. You have probably seen ads or announcements for the "Drive Sober or Get Pulled Over" campaign during this time, and even leading up to this period of enforcement.

But this weekend, things will get serious as the Labor Day weekend is considered one of the most dangerous driving weekends of the year. Many people are traveling for vacation, and many people are enjoying a few drinks during this time. You shouldn't combine those two activities, but if you do, you still have rights.

Beyond the implied consent law, remember that you may be asked to perform a field sobriety test, may it be at a checkpoint or after a traffic stop. These field sobriety tests have come under scrutiny recently, as they involve the suspected person performing tasks that no person would ever perform, whether they are sober or not. Therefore, they are unlikely to fulfill or complete these tasks simply because they are foreign to them -- not necessarily because they are intoxicated.

Source: TSM, "Drive Sober or Get Pulled Over, Drunk Driving National Enforcement Crackdown, August 13 - September 1, 2014," Accessed Aug. 29, 2014

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Field sobriety tests aren't necessarily foolproof

When you are pulled over by the police and they believe that you have been driving while intoxicated, they will go through a number of steps to determine your inebriation. There's your standard field sobriety test, which involves an officer asking you to do a number of tasks. There is a breath test, which can be done by Breathalyzer. A blood or urine test may be required later.

But all of these tests have faults, may it be by the way the test is performed by an officer, or by the way the evidence is handled thereafter. Let's start with the first test, your standard field sobriety test.

The officer could ask you to perform a number of actions here, such as saying the alphabet backwards, walking in a straight line toe-to-toe, and touching your nose when your arms are initially extended outwards from your body. All of these actions are difficult for a sober person to pull off without the stress of a police officer watching them, let alone a possibly intoxicated person during a traffic stop. These tests have been ridiculed by many as not providing any proof of a person's sobriety or intoxication.

The breath test is a big one in the state of Minnesota. Under implied consent, you have to take a breath, blood or urine test to establish your blood alcohol level, though you can refuse an initial field sobriety test. However, the breath test could be improperly administered by the police, invalidating that evidence.

Under the same premise, the evidence garnered from a blood test could be mishandled or tainted. The test itself could even be botched by a lab technician.

Source: FindLaw, "Sobriety Tests," Accessed Oct. 23, 2014

Tags: Field Sobriety Tests

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Why I Would Not Take Field Sobriety Tests

tag:blogger.com,1999:blog-1587559881278326369.comments2014-12-02T03:13:46.253-08:00DGDAttorneyhttp://www.blogger.com/profile/07241517680791263522noreply@blogger.comBlogger0125

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How DUI field tests really work

DetailsCategory: DUI Blog

By Jessica Towne

Miranda warnings don't apply at the side of the road. The police do NOT have to read you the Miranda warning until you are in custody. When the police are talking to you at a traffic stop, they are gathering the evidence they need to determine if you can be arrested for DUI. They can, and will, ask you all kinds of questions during this process. Since you are not "in custody," they do not read the Miranda warning to you before they start asking you questions.

Officer Friendly knows how to make general statements designed to have you offer evidence in the spirit of cooperation. Thus you are not being questioned when Officer Friendly says "I'd like you to do these field sobriety tests to see if you're safe to drive." What he means is:

"I smell alcohol, but before I arrest you for DUI, I need more evidence.Will you admit that you've been drinking?Will you try these tests that have no correlation to driving that are designed for failure so I can capture you looking ridiculous on a camera that may or may not be working? Then, I'll have enough evidence to convict you of DUI."

Don't play along. Don't talk to Officer Friendly. Unless you really want to incriminate yourself.

What will the officer do when you refuse? He has a few choices.

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Why you should always refuse the Breathalyzer and the Standardized Field Sobriety Tests

Don't do it! As a defense attorney and DUI practitioner, I get asked a lot of questions by my clients, friends, and fellow attorneys. But no question is more common than, "should I refuse the breathalyzer and/or the field sobriety tests (FSTs)?"

Like most legal questions, this one is not easy to answer, either. Any attorney worth his salt will tell you to refuse both. But, States have a mechanism in place to "encourage" you to agree to blow into the machine, which we will discuss.

This blog post is devoted to explaining why it is beneficial for you and your case to politely refuse the police officer's request to blow into the machine (both portable and the one at the station) as well as to refuse the standardized FSTs.

In an ideal world, you would refuse both the breathalyzer and FSTs, and the government would have no case against you (except for the officer's testimony). However, last time I checked, we do not live in a Utopia. Therefore, we must deal with the facts.

If you have consumed alcohol, the officer will be alerted to your red, watery, and bloodshot eyes, smell of alcohol, and slurred speech. This gives him reasonable suspicion that a crime has been committed which opens the door to further investigation, but not probable cause to arrest...
This is where the police officer will request that you complete FSTs, and/or administer his Portable Breathalyzer Test (PBT). He has authority to give you the breath test per KRS 189A.103(3). You are to refuse both! I cannot emphasize this enough.But, what if you don't know this important piece of advice, and submit to them (like many people do on a day-to-day basis)? 

Let's see what happens.

Well, first, if you have indeed recently been drinking, and are possibly close to or over that magic 0.08 figure, and you blow into the PBT, you've just given the police officer the probable cause he needs to arrest you! He doesn't need anything else -- even if you refuse the FSTs, he now has the lawful right to arrest you right on the spot.

Furthermore, the FSTs, even though the National Highway Traffic and Safety Administration (NHTSA) claims that they are tests of "divided attention" (just like when you're driving you have to be able to steer, and change gears if its a manual, while paying attention to your surroundings), ask yourself the following question: how many years have you been driving? Now compare that experience to how many times you've done FSTs. Chances are you've never done them. Ever. How is that fair? Well, according to our government, it is. And if you refuse to complete them, the police officer cannot use it against you in court (but he will do everything in his power to find cause to arrest you -- because, if you were sober, why would you refuse such "simple" tests?)

The tests are designed to fail you. That is the reality of it. Don't let anyone fool you otherwise.

Now you're at the station. Let's say you've submitted to the PBT, and blew over a 0.08, but refused the FSTs. You are now confronted with the Intoxilyzer machine. Kentucky, like most jurisdictions, has an implied consent statute in place. That means that by virtue of the Commonwealth issuing you an operator's license and permitting you to drive your vehicle of choice on Kentucky's roads you have "impliedly consented" to a test of your blood, breath, or urine (KRS 189A.103(1)). Note: this statute applies even if you are dead or unconscious (KRS 189A.103(2)).

Now, you have two options: One, submit to the test and risk the result, or two, refuse to blow. If you submit to the Intoxilyzer, and blow over a 0.08 you've just given the Commonwealth two avenues of prosecution against you:

1) KRS 189A.010(1)(a) - the per se DUI (Intoxilyzer result over 0.08); and
2) KRS 189A.010(1)(b) - the opinion DUI (police officer's testimony).

Had you refused the machine altogether, the Commonwealth can only pursue you for the opinion DUI.

But there's a small catch. 

Did I say small catch?

Some would say it's a pretty big one.

Per KRS 189A.105(2)(a)(1), if you refuse to submit to the blood, breath, or urine tests, the effects are as follows:

1) the refusal may be used against you in court as evidence of violating KRS 189A.010 (the DUI statute); 
2) your driver's license will be suspended until the resolution of your case; 
3) if you refuse the tests and are subsequently convicted of DUI, you will be subjected to a mandatory minimum jail sentence which is twice as long as the mandatory minimum jail sentence imposed if you submit to the tests (which is 4 days instead of 2 for a first offense); and 
4) you will be unable to obtain a hardship license after the 30 day mandatory suspension period elapses (for first offense DUI).

Pretty harsh, huh?

As you can see, the Commonwealth has done everything in its power to scare you into taking a blood, breath, or urine tests. Nevertheless, despite these seemingly harsh consequences of refusal, it is still beneficial for you to refuse! It is harder to disprove a negative when the prosecution has the number that works against you, because people like to believe technology works properly. It is much easier to discredit a police officer on cross examination than to prove the a machine was faulty.

But aren't you forgetting something? What about the PBT, Mr. DUI Guy?

I'm glad you asked.

The PBT is inadmissible in Court. Per KRS 189A.104, no other breathalyzer machine except the one that is "installed, tested, and maintained by the Commonwealth ... at a police station or detention facility" is admissible in a court proceeding. So the PBT result must be excluded. A 2008 Kentucky Court of Appeals case explicitly stated that, "the pass/fail result of a PBT is admissible for the limited purpose of establishing probable cause for an arrest at a hearing on a motion to suppress." Greene v. Commonwealth, 244 S.W.3d 128 (Ky. Ct. App. 2008) (emphasis added). The prosecution cannot introduce the PBT result to the jury, and it is reversible error to do so.

If you refuse to do the FSTs and PBT roadside, your chances of getting arrested may not change. Even if you do get arrested, and continue to refuse to cooperate with any of the officer's requests to complete a breath, blood, or urine test as well as the FSTs, your Kentucky operator's license will be suspended while your case is pending (KRS 189A.107(1)). However! You've just significantly increased your chances of beating your DUI because the Commonwealth cannot pursue your case under the "per se" part of the DUI statute, namely the 0.08, and must rely on the opinion DUI -- which is based 100% on the police officer's testimony as to his observations and impressions of you, which is easier for an experienced DUI practitioner to attack and discredit on cross examination.

Thanks for reading, old friend.

Hope to see you again soon.

If you require assistance with a DUI, expungement, traffic ticket, or other criminal charges, please contact me or call me at (270) 945-2778.

The DUI Guy

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What Makes "Standardized Field Sobriety Tests" Standardized?

Throughout the course of this series we've discussed the differences between the FSTs (field sobriety tests) and SFSTs (standardized field sobriety tests). The three SFSTs are the horizontal gaze nystagmus, the walk and turn, and the one leg stand tests. The SFSTs have a level of validity other FSTs do not. "Standardized test" is defined by Wikipedia as "a test that is administered and scored in a consistent, or 'standard', manner." Clearly the goal is consistent and standard administration and evaluation in order to avoid bias and subjective determinations of impairment. The Standardized Field Sobriety Tests, touted by the National Highway Safety and Transportation Administration (NHTSA) and the International Association of the Chiefs of Police (IACP), are good but have their flaws. In this segment, we will look at the studies that make the SFSTs "standardized."

The cornerstone of the standardization is an objective, scientific level of credibility. In order to come into evidence, to be considered in a court of law, it must meet the Kelly-Frye Standard. The Kelly-Frye standard is from Frye v. United States (1923) 293 F.1013, and was adopted by the California Supreme Court in People v. Kelly (1976) 17 Cal.3d 24. The Kelly-Frye standard states that test results entered into evidence must be generally accepted within the relevant portions of the scientific community, and exclude from evidence any test results from scientifically unproven methods. Standardization, and the repeatable results that come with peer reviewed studies, is therefore very important for the credibility, acceptability, and getting the SFST results into evidence.

The SFSTs have peer reviewed studies- as a matter of fact they have three. The three studies are from 1995, 1997 and 1998. The 1995 test was completed out of Colorado, the 1997 test out of Florida, and the 1998 out of our own San Diego. Each one of the studies have a question to answer. Anyone familiar with scientific studies (or politics) also know that studies tend to answer said question in the direction the creator wishes it to. These studies are no different.

In 1995 the Colorado study was intended to answer the question, do experienced officers utilizing the walk and turn, horizontal gaze nystagmus, and one leg stand, in a laboratory and field setting, make correct arrest decisions? The study found that officers using the full battery of three tests made the correct arrest decision 93% of the time.

In 1997, the Florida study was to answer the question, are SFSTs valid and reliable indices for the presence of alcohol when used under present day traffic and law enforcement conditions? The Florida study, not surprisingly, found that the SFST full battery test is the only scientifically validated and reliable method for discriminating between impaired and unimpaired drivers. None of the other field sobriety tests (the handpat, fingercount, romberg, etc.) worked on the same level as the SFSTs. The correct arrest decision was made 95% of the time when all three tests were utilized.

Lastly, the 1998 San Diego study was to exam the new, nationwide blood alcohol content of .08% BAC - dropped from .10%. The question being, could the SFSTs discriminate at BACs less than .10%? The study found the three SFSTs could differentiate, and officers made the correct arrest decision 91% of the time. Interestingly, the study also found that three tests could differentiate to .04% and above.

The San Diego study was the first one to be exclusively a field study- not involving any laboratory testing. However, one of the problems with the study is that it involved experienced officers. It is not known what are the average years of service of the officers that took part in the study, nor what percentage of an average police force have the same level of experience as the officers that took part in the study. A more realistic look at the SFSTs would have examined all officer's arrest decisions, as opposed to just "experienced officers."

An examination of the studies shows that there is an internal bias, and there is room for subjective evaluation. Those will be discussed with each individual SFST, and each test will have their separate blog entry. It is important to note that NHTSA either fully or partially paid for all of the studies.

As a SFST instructor, I know the benefits and detriments of each one of these tests intimately. If done properly, they can be very accurate. However, it is the administration of these tests that are their great downfall in the average DUI arrest scenario. Invariably, officers deliver an abbreviated, or inaccurate SFST battery that leads to biased results. And it is only an experienced, properly trained attorney that can tell the difference. Please contact me here if you wish to have your DUI case evaluated.

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DUI Blood Tests Impacted by Lab Errors

More sloppy lab work leads to more uncertainty about DUI convictions.  This time it’s Colorado again:

At issue is the Colorado Department of Public Health and Environment’s testing for blood-alcohol content, which many law enforcement agencies rely on to establish if someone is over the legal limit for driving, .08 percent.

In early May, the Denver Post reported that the department’s forensic toxicology lab in Denver would retest 1,700 samples after learning that a former employee had failed to follow test protocols, opening the door for attorneys to challenge drunk-driving cases.

The lab has since reanalyzed 1,300 of the 1,700 samples and identified 11 samples with “significant” errors, all in the defendants’ favor, said David Butcher, the department’s director of laboratory services.

The lab technician blamed for the mistakes, Mitchell Fox-Rivera, was fired in March for unsatisfactory performance, his former supervisor said in an email obtained by The Gazette, and Butcher said the lab has moved to introduce peer-review measures in which lab technicians randomly retest each other’s samples for mistakes.

Some attorneys have had their clients’ samples retested at independent labs and the results have shown significant errors:

(Attorney Steven) Rodemer said preliminary results by ChemaTox Inc., a private lab certified through the Department of Public Health and Environment, came up with a result that was 19 percent lower for one client – dropping his BAC from .206 to .167 percent.

That meant his client was below two important legal thresholds that help determine penalties for drunken drivers, Rodemer said.

In Colorado, anyone convicted of drunk driving who scores above a .20 percent must serve 10 days in jail.

At .17 percent, a driver is considered a high blood-alcohol offender. Such drivers often end up with an ignition device on their vehicle for more than two years, at an expense that can top $2,000.

As we have discussed in many previous posts, the forensic labs carrying out DUI blood tests suffer from many problems which compromise the integrity of the evidence.  These problems include a lack of oversight, under-trained lab technicians, and overwhelming workloads.

If you have DUI blood test evidence against you, you should have your case reviewed by a qualified DUI attorney who has expertise in handling DUI blood cases.  If you are in Pennsylvania call The McShane Firm at 1-866-MCSHANE. Attorney McShane has lectured on DUI blood testing on several occasions and has written a number of publications on the subject as well. (See Attorney McShane’s Qualifications)

View the original article here

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DUI Myth Busters: Field Sobriety Tests are Meaningful

A widely held misconception, amongst both law enforcement and the general public, is that the standardized field sobriety tests are a valid method for determining impairment.  This just simply is not true.

Here are some simple questions that will show you why these field sobriety tests are meaningless:

Have you ever stumbled while walking?
Does that stumbling mean you were drunk?
If you can stumble while walking normally, what about when asked to perform the difficult and awkward task of walking heel-to-toe -the way nobody walks?

What about standing on one leg?
Is this something you practice often?
If you stumbled does that automatically mean you are drunk?

The fact of the matter is that doing poorly on these very difficult field sobriety tests can be attributed to a number of reasons like being:

ElderlyOverweightHaving a history of leg or back injuriesSuffering from an illness or weaknessWearing high heelsDownright clumsyExtremely nervous or scared

Despite these facts, there is too much emphasis put on these field sobriety tests during a DUI trial and because of this, many innocent people have been found guilty of DUI and especially of DUI-drugs (no testing is required at all, only the opinion of the officer is needed).

This is why you should always choose a DUI lawyer who is an expert in Field Sobriety Testing and can defend these issues in court.  This is an important part of properly representing your case and protecting your rights.

View the original article here

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Flawed DUI Tests Plague Several California Police Departments

By guest-writer
A few months ago, police officials in San Francisco faced a great deal of embarrassment when an investigation revealed that several breathalyzer tests administered to DUI suspects were flawed, a finding that threatened hundreds of DUI convictions.
This problem, however, does not seem to be isolated to San Francisco, as police departments across the country have experienced troubles with the reliability of their breathalyzer tests, according to a recent report from the San Francisco Chronicle.
An eerily similar situation happened in Philadelphia last year. There, the district attorney was forced to offer new trials to almost 1,500 people who had been convicted of driving under the influence of alcohol over a 15-month period.
This offer was made necessary by the finding in March 2011 that four different breath test machines used by the Philadelphia police department had not been adequately calibrated before their use.
San Francisco faced a similar problem with the calibration of their breathalyzer devices, but they used a different type of breath test, according to sources.
In addition to San Francisco, other California communities, such as those in Santa Clara County and Ventura County, have seen some dropped DUI convictions due to faulty breath tests, but not to the extent that San Francisco experienced.
In the city by the bay, the district attorney’s office is currently reviewing hundreds of cases dating back to 2006 to possible mismanagement of breath testing devices used by the city’s police department.
According to San Francisco Public Defender Jess Adachi, as many as 1,000 convictions could eventually be altered, although Adachi does have a bit of a skewed perspective, given that he stands to benefit from any overturned convictions.
Still, the fact that even hundreds of DUI convictions could be overturned is unnerving for judges and prosecutors alike, and it reveals the danger of relying on technology when identifying possible DUI offenders.
People who are arrested for a DUI should also note that there are a wide range of complications that could arise from a breath test, including the possibility of condensation in the device that skews the blood alcohol results, or simply misuse of the machines by poorly trained police.
A DUI arrest does not necessarily mean a DUI conviction, given the wide range of possible procedural violations or technological mishaps that sometimes plague DUI stops.
So, if you’ve been arrested for a DUI, remember that you are not necessarily convicted automatically. The court must still prove your guilt.

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Navy Will Soon Give Breathalyzer Tests to Sailors and Marines on Duty

By guest-writer

In a decision that may not be popular with sailors, the U.S. Navy will soon start administering breathalyzer tests to sailors and Marines who are reporting for active duty on ships and submarines, according to an announcement made recently by Secretary of the Navy Ray Mabus.

The new tests are a small part of the Navy’s 21st Century Sailor and Marine program, which is a multi-faceted initiative designed to improve the lifestyles of members of the military.

The new initiative promotes healthy lifestyles by promoting better nutrition, heightened fitness, and responsible alcohol use. The wide-ranging program also has zero tolerance for drug use, according to a report from Fox News.

Of course, the program is not just intended to limit certain activities. It also reportedly offers programs related to topics ranging from suicide prevention, financial planning, and family and personal counseling.

These programs may be welcomed by many soldiers, but the breathalyzer tests administered aboard ships is a new, and potentially unwelcome, development.

The program, though, is a direct response to alcohol-related incidents that can “end careers and sometimes end lives,” according to a Navy spokesperson.

Sources indicate that, currently, roughly 180 active duty sailors are arrested for a DUI each month. The military believes this number is too high.

According to Mabus, the new program “is not done to punish, but to help. We want to help sailors and Marines make good choices before something happens that can’t be undone.” He also said the military’s goal is to maximize sailors’ safety, fitness, and readiness.

In addition, the Navy is concerned about sailors’ long-term healthy. According to Mabus, when “a sailor’s or Marine’s time in the military ends, whether it is after four years or 40, we want your productive life to continue and for you to leave the service in better health, more trained and better educated than when you came in.”

Sources indicate that equipment designed for alcohol screening tests will start being installed on Navy ships this month, and will continue to be rolled out through the end of 2012.

And, in response to privacy concerns given by many sailors, the breathalyzer tests given on board Navy ships would not be legally admissible in a criminal trial.

Instead, the tests are simply designed to give commanding officers notice about potential problems related to alcohol. Sources say the tests are not intended to lead to punitive measures, or criminal convictions.

View the original article here

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Coercing Breath Tests With Threats of Pain

I’ve written in the past about the growing practice of forcibly taking blood from a drunk driving suspect, sometimes done by a cop in the field.  See, for example, Taking Blood by Force, Forced Blood Draws by Cops: Constitutional?, Forced Blood Draws by Cops Spreading, Blood Draws in the Back Seat by the Dashboard Light and Forced Blood Draws: Citizen Backlash?.   

Here’s a new tactic: threaten the suspect with strapping him down and painfully jabbing a needle into him (however many times it takes to get a blood sample)…unless he agrees to "voluntarily" take a breath test.

Texas Blood Test Aims at Drunk Drivers

Wall Street Journal, Dec. 11 —  Texans arrested for drunken driving should be prepared to give blood this holiday season.

Cities and counties across the state are increasingly demanding that drunken-driving suspects who refuse to take breathalyzer tests submit to blood tests that measure the amount of alcohol in their systems.

The blood-test policy—dubbed "no refusal" by law-enforcement officials, because it prevents drivers from refusing to provide evidence of intoxication—has grown from a novel procedure used in a few Texas jurisdictions to an initiative used by police statewide, particularly during weekends and holidays when drunken driving is most common. The no-refusal initiative has also caught on in other states, including Florida, Illinois, Louisiana and Missouri…

Texas courts have uniformly upheld the constitutionality of mandatory blood testing, attorneys said. But criminal-defense lawyers say such mandatory tests trample suspects’ rights to be free from unreasonable searches and seizures. "It’s an erosion of civil liberties," said Austin defense lawyer Samuel Bassett. "If we can poke people involuntarily for evidence, where do we draw the line?"…

Police are empowered to strap a suspect to a chair, if necessary, to obtain a blood sample. That allows blood to be drawn quickly—a key benefit to prosecutors because blood-alcohol concentrations dissipate over time…

In El Paso, police find that the policy actually encourages people to submit to breath tests. "We give people the option of blowing into a tube or getting poked with a needle," said Lt. Rod Liston. "People increasingly are going with the less painful option."…

Hmmm…Threatening to "poke" a suspect with a needle actually "encourages" him to submit to a breath test?  What a surprise!  But I guess this wouldn’t be "torture" using the Attorney General’s definition requiring organ failure.

So:  "Submit to a breath test…or we’ll strap you into a chair and jam needles into you."   Welcome to the War on Terrorism…I mean, Drunk Driving.

This entry was posted on Monday, December 12th, 2011 at 2:18 pm and is filed under Duiblog. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.

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