Part 1: Glory Days
Tuesday, November 13th
I approached the witness stand with a warm and welcoming smile. This, of course, belied my true intent, which was to destroy the woman who sat there with her eyes fixed on me. Claire Welton had just identified my client as the man who had forced her out of her Mercedes E60 at gunpoint on Christmas Eve last year. She said he was the one who then shoved her to the ground before taking off with the car, her purse and all the shopping bags she had loaded into the back seat at the mall. As she had just told the prosecutor who questioned her, he had also made off with her sense of security and self-confidence, even though for these more personal thefts he had not been charged.
“Good morning, Mrs. Welton.”
She said the words like they were synonyms for please don’t hurt me. But everyone in the courtroom knew it was my job to hurt her today and thereby hurt the state’s case against my client, Leonard Watts. Welton was in her sixties and matronly. She didn’t look fragile but I had to hope she was.
Welton was a Beverly Hills housewife and one of three victims who were roughed up and robbed in a pre-Christmas crime spree resulting in the nine charges against Watts. The police had labeled him the “Bumper Car Bandit,” a strong-arm thief who followed targeted women from the malls, bumped into their cars at stop signs in residential neighborhoods and then took their vehicles and belongings at gunpoint when they stepped out of their cars to check for damage. He then pawned or resold all the goods, kept any cash, and dropped the cars off at chop shops in the Valley.
But all of that was alleged and hinged on someone identifying Leonard Watts as the culprit in front of the jury. That was what made Claire Welton so special and the key witness of the trial. She was the only one of the three victims who pointed Watts out to the jury and unequivocally claimed that he was the one, that he did it. She was the seventh witness presented by the prosecution in two days but as far as I was concerned she was the only witness. She was the number one pin. And if I knocked her down at just the right angle all the other pins would go down with her.
I needed to roll a strike here or the jurors who were watching would send Leonard Watts away for a very long time.
I carried a single sheet of paper with me to the witness stand. I identified it as the original crime report created by a patrol officer who was first to respond to the 911 call placed by Claire Welton from a borrowed cell phone after the carjacking occurred. It was already part of the state’s exhibits. After asking for and receiving approval from the judge, I placed the document down on the ledge at the front of the witness stand. Welton leaned away from me as I did this. I was sure most members of the jury saw this as well.
I started asking my first question as I walked back to the lectern between the prosecution and defense tables.
“Mrs. Welton, you have there the original crime report taken on the day of the unfortunate incident in which you were victimized. Do you remember talking with the officer who arrived to help you?”
“Yes, of course I do.”
“You told him what happened, correct?”
“Yes. I was still shaken up at the – ”
“But you did tell him what happened so he could put a report out about the man who robbed you and took your car, is that correct?”
“That was Officer Corbin, correct?”
“I guess. I don’t remember his name but it says it on the report.”
“But you do remember telling the officer what happened, correct?”
“And he wrote down a summary of what you said, correct?”
“Yes, he did.”
“And he even asked you to read the summary and initial it, didn’t he?”
“Yes, but I was very nervous.”
“Are those your initials at the bottom of the summary paragraph on the report?”
“Mrs. Welton, will you now read out loud to the jury what Officer Corbin wrote down after talking with you?”
Welton hesitated as she studied the summary before reading it out loud.
Kristina Medina, the prosecutor, used the moment to stand and object.
“Your Honor, whether the witness initialed the officer’s summary or not, counsel is still trying to impeach her testimony with writing that is not hers. The people object.”
Judge Michael Siebecker squinted his eyes and turned to me.
“Judge, by initialing the officer’s report the witness adopted the statement. It is present recollection recorded and the jury should hear it.”
Siebecker overruled the objection and instructed Mrs. Welton to read the initialed statement from the report. She finally complied.
“‘Victim stated that she stopped at the intersection of Camden and Elevado and soon after was struck from behind by a car that pulled up. When she opened her door to get out and check for damage, she was met by a black male thirty to thirty-five YOA—’ I don’t know what that means.”
“Years of age,” I said. “Keep reading, please.”
“’He grabbed her by the hair and pulled her the rest of the way out of the car and to the ground in the middle of the street. He pointed a black, short barrel revolver at her face and told her he would shoot her if she moved or made any sound. The suspect then jumped into her car and drove off in a northerly direction, followed by the car that had rear-ended her vehicle. Victim could offer no . . .”
I waited but she didn’t finish.
“Your Honor, can you instruct the witness to read the entire statement as written on the day of the incident?”
“Mrs. Welton,” Judge Siebecker intoned. “Please continue to read the statement in its entirety.”
“But, Judge this isn’t everything I said.”
“Mrs. Welton,” the judge said forcefully. “Read the entire statement, as the defense counselor asked you to.”
Welton relented and read the last sentence of the summary.
“‘Victim could offer no further description of the suspect at this time.’”
“Thank you, Mrs. Welton,” I said. “Now while there wasn’t much in the way of a description of the suspect, you were from the start able to describe in detail the gun he used, isn’t that right?”
“I don’t know about how much detail. He pointed it at my face so I got a good look at it and was able to describe what I saw. The officer helped me by describing the difference between a revolver and the other kind of gun. I think an automatic, it’s called.”
“And you were able to describe the kind of gun it was, the color and even the length of the barrel.”
“Aren’t all guns black?”
“How about if I ask the questions right now, Mrs. Welton?”
“Well, the officer asked a lot of questions about the gun.”
“But you weren’t able to describe the man who pointed the gun at you, and yet two hours later you pick his face out of a bunch of mug shots. Do I have that right, Mrs. Welton?”
“You have to understand something. I saw the man who robbed me and pointed the gun. Being able to describe him and recognize him are two different things. When I saw that picture I knew it was him, just as sure as I know it’s him sitting at that table.”
I turned to the judge.
“Your Honor, I would like to strike that as non-responsive.”
Medina stood up.
“Judge, counsel is making broad statements in his so-called questions. He made a statement and the witness merely responded. The motion to strike has no foundation.”
“Motion to strike is denied,” the judge said quickly. “Ask your next question, Mr. Haller, and I do mean a question.”
I did and I tried. For the next twenty minutes I hammered away at Claire Welton and her identification of my client. I questioned how many black people she knew in her life as a Beverly Hills housewife and opened the door on interracial identification issues. All to no avail. At no point was I able to shake her resolve or belief that Leonard Watts was the man who robbed her. Along the way she seemed to recover one of things she said she had lost in the robbery. Her self-confidence. The more I worked her, the more she seemed to bear up under the verbal assault and send it right back at me. By the end she was a rock. Her identification of my client was still standing. And I had bowled a gutter ball.
I told the judge I had no further questions and headed back to the defense table. Medina told the judge she had a short redirect and I knew she would ask Welton a series of questions that would only reinforce her identification of Watts. As I slid into my seat next to Watts his eyes searched my face for any indication of hope.
“Well,” I whispered to him. “That’s it. We are done.”
He leaned back from me as if repelled by my breath or words or both.
“We?” he said.
He said it loud enough to interrupt Medina, who turned and looked at the defense table. I put my hands out palms down in a calming gesture and mouthed the words Cool it to him.
“Cool it?” he said aloud. “I’m not going to cool it. You told me you had this, that she was no problem.”
“Mr. Haller!” the judge barked. “Control your client, please, or I’ll have – ”
Watts didn’t wait for whatever it was the judge was about to threaten to do. He launched his body into me, hitting me like a cornerback breaking up a pass play. My chair tipped over with me in it and we spilled onto the floor at Medina’s feet. She jumped back to avoid getting hurt herself as Watts drew his right arm back. I was on my left side on the floor, my right arm pinned under Watts’s body. I manage to raise my left hand and caught his fist as it came at me. It merely softened the blow. His fist took my own hand into my jaw.
I was peripherally aware of screams and motion around me. Watts pulled his fist back as he prepared for punch number two. But the courtroom deputies were on him before he could throw it. They gang tackled him, their momentum taking him off me and onto the floor in the well in front of the counsel tables.
It all seemed to move in slow motion. The judge was barking commands no one was listening to. Medina and the court reporter were backing away from the melee. The court clerk had stood up behind her corral and was watching in horror. Watts was chest down on the floor, a deputy’s hand on the side of his head, pressing it to the tile, an odd smile on his face as his hands were cuffed behind his back.
And in a moment it was over.
“Deputies, remove him from the courtroom!” Siebecker commanded.
Watts was dragged through the steel door at the side of the courtroom and into the holding cell used to house incarcerated defendants. I was left sitting on the floor, surveying the damage. I had blood on my mouth and teeth and down the crisp white shirt I was wearing. My tie was strewn on the floor. It was the clip-on I wear on days I visit clients in holding cells and don’t want to get pulled through the bars.
I rubbed my jaw with my hand and ran my tongue along the rows of teeth. Everything seemed intact and in working order. I pulled a white handkerchief out of an inside jacket pocket and started wiping off my face as I used my free hand to grab the defense table and help myself up.
“Jeannie,” the judge said to his clerk. “Call paramedics for Mr. Haller.”
“No, Judge,” I said quickly. “I’m okay. Just need to clean up a little bit.”
I reached down to the floor for my tie and then made a pathetic attempt at decorum, reattaching it to my collar despite the deep red stain that had ruined the front of my shirt. As I worked the clip into my buttoned collar, several deputies reacting to the courtroom panic button undoubtedly pushed by the judge stormed in through the main doors at the back. Siebecker quickly told them to stand down and that the incident had passed. The deputies fanned out across the back wall of the courtroom, a show of force in case there was anyone else in the courtroom thinking about acting out.
I took one last swipe at my face with the handkerchief and then spoke up.
“Your Honor,” I said. “I am deeply sorry for my client’s – ”
“Not now, Mr. Haller. Take your seat and you do the same, Ms. Medina. Everybody calm down and sit down.”
I did as instructed, holding the folded handkerchief to my mouth and watching as the judge turned his seat fully toward the jury box. First he told Claire Welton that she was excused from the witness stand. She got up tentatively and walked toward the gate behind the counsel tables. She looked more shaken than anyone else in the courtroom. No doubt for good reason. She probably figured that Watts could have just as easily gone after her as me. And if he had been quick enough he would’ve gotten to her.
Welton sat down in the first row of the gallery, which was reserved for witnesses and staff, and the judge proceeded with the jury.
“Ladies and gentlemen, I am truly sorry that you had to see that display. The courtroom is never a place for violence. It is the place where civilized society takes its stand against the violence that is out on our streets. It truly pains me when something like this occurs.”
There was a metal snapping sound as the two courtroom deputies returned from the holding cell. I wondered how badly they had roughed up Watts while securing him in the cell.
The judge paused and then returned his attention to the jury.
“Unfortunately, Mr. Watts’s decision to attack his attorney has prejudiced our ability to go forward. I believe – ”
“Your Honor?” Medina interrupted. “If the state could be heard.”
Medina knew exactly where the judge was headed and needed to do something.
“Not now, Ms. Medina, and do not interrupt the court.”
But Medina was persistent.
“Your Honor, could counsel approach at sidebar?”
The judge looked annoyed with her but relented. I let her lead the way and we walked up to the bench. The judge hit the switch on a noise-canceling fan so the jury would not overhear our whispers. Before Medina could state her case the judge asked me once more if I wanted medical attention.
“I’m fine, Judge, but I appreciate the offer. I think the only thing worse for wear is my shirt, actually.”
The judge nodded and turned his attention to Medina.
“I know your objection, Ms. Medina, but there is nothing I can do. The jury is prejudiced by what they just saw. I have no choice.”
“Your Honor, this case is about a very violent defendant who committed very violent acts. The jury knows this. They won’t be unduly prejudiced by what they saw. The jury is entitled to view and judge for themselves the demeanor of the defendant. Because he voluntarily engaged in violent acts, the prejudice to the defendant is neither undue nor unfair.”
“If I could be heard, Your Honor, I beg to differ with – ”
“Besides that,” Medina continued, running me over, “I fear the court is being manipulated by this defendant. He full well knew that he could get a new trial this way. He – ”
“Whoa, wait a minute here,” I protested. “Counsel’s objection is replete with unfounded innuendo and – ”
“Ms. Medina, the objection is overruled,” the judge said, cutting off all debate. “Even if the prejudice is neither undue nor unfair, Mr. Watts has effectively just fired his attorney. I can’t require Mr. Haller to go forward in these circumstances and I am not inclined to allow Mr. Watts back into this courtroom. Step back. Both of you.”
“Judge, I want the people’s objection on the record for appeal.”
“You shall have it. Now step back.”
We returned to our tables and the judge turned off the fan and then addressed the jury.
“Ladies and gentlemen, as I was saying, the event you just witnessed has created a situation prejudicial to the defendant. I believe that it will be too difficult for you to divorce yourself from what you just saw as you deliberate on his guilt or innocence of the charges. Therefore, I must declare a mistrial at this time and discharge you with the thanks of this court and the people of California. Deputy Carlyle will escort you back to the assembly room where you may gather your things and go home.”
The jurors seemed unsure what to do or whether everything was over. Finally, one brave man in the box stood up and soon the others followed. They filed out through a door at the back of the courtroom.
I looked over at Kristina Medina. She sat at the prosecution table with her chin down, defeated. The judge abruptly adjourned court for the day and left the bench. I folded my ruined handkerchief and put it away.
My full day had been scheduled for trial. Suddenly released from it, I had no clients to see, no prosecutors to work and no place to be. I left the courthouse and walked down Temple to First. At the corner there was a trashcan. I took out my handkerchief, held it to my lips and spit all the debris from my mouth into it. I then tossed it away.
I took a right on First and saw the line of Town Cars running along the sidewalk. There were six of them in line like a funeral procession, their drivers gathered together on the sidewalk, shooting the shit and waiting. They say imitation is the sincerest form of flattery, but ever since the movie a whole contingent of Lincoln lawyers had cropped up and routinely crowded the curbs outside the courthouses of L.A. I was both proud and annoyed. I heard more than a few times that there were other lawyers out there saying they were the inspiration for the film. On top of that, I had jumped into the wrong Lincoln at least three times in the last month.
This time there would be no mistake. As I headed down the hill I pulled my cell phone and called Earl Briggs, my driver. I could see him up ahead. He answered right away and I told him to pop the trunk, then I hung up.
I saw the trunk of the third Lincoln in line rise and I had my destination. When I got there I put my briefcase down and then took off my jacket, tie and shirt. I had a t-shirt on underneath so I wasn’t stopping traffic. I chose a pale blue oxford from the stack of backup shirts I keep in the trunk, unfolded it and started pulling it on. Earl came over from the klatch with the other drivers. He had been my driver on and off for nearly a decade. Whenever he ran into trouble he came to me and then worked off my fee by driving. This time it wasn’t his own trouble he was paying for. I handled his mother’s foreclosure defense and got her straightened out without her having to go homeless. That got me about six months’ worth of driving from Earl.
I had draped my ruined shirt over the fender. He picked it up and examined it.
“What, somebody spill a whole thing of Hawaiian Punch on you or something?”
“Something like that. Come on, let’s go.”
“I thought you had court all day.”
“I did too. But things change.”
“Where to then?”
“Let’s go by Philippe’s first.”
“You got it.”
He got in the front and I got in the back. After a quick stop at the sandwich shop on Alameda I had Earl point the car west. The next stop was a place called Menorah Manor near Park La Brea in the Fairfax District. I said I’d be about an hour and got out with my briefcase. I had tucked my fresh shirt in but didn’t bother clipping my tie back on. I wouldn’t need it.
Menorah Manor was a four-story nursing home on Willoughby east of Fairfax. I signed in at the front desk and took the elevator up to the third floor where I informed the woman at the nursing desk that I had a legal consultation with my client David Siegel and was not to be disturbed in his room. She was a pleasant woman who was used to my frequent visits. She nodded her approval and I went down the hallway to room 334.
I entered and closed the door after putting the do not disturb sign on the outside handle. David “Legal” Siegel was lying in bed, his eyes on the screen of a muted television bolted to the upper wall across from the bed. His thin white hands were on top of a blanket. There was a low hiss from the tube that brought oxygen to his nose. He smiled when he saw me.
“Legal, how are you doing today?”
“Same as yesterday. Did you bring anything?”
I pulled the visitor’s chair away from the wall and positioned it so I could sit in his line of vision. At eighty-one years old, he didn’t have a lot of mobility. I opened my briefcase on the bed and turned it so he could reach into it.
“French dip from Philippe the Original. How’s that?”
“Oh, boy,” he said.
Menorah Manor was a kosher joint and I used the legal consultation bit as a way around it. Legal Siegel missed the places he’d eaten at during a forty-year run as a lawyer in downtown. I was happy to bring him the culinary joy. He had been my father’s law partner. He was the strategist while my father had been the front man, the performer who enacted the strategies in court. A year ago I had come to him after losing the election for District Attorney in scandal and self-destruction. I was looking for life strategy and Legal Siegel was there for me. In that way, these meetings were legitimate consultations between lawyer and client, only the people at the desk didn’t understand that I was the client.
I helped him unwrap the sandwich and opened the plastic container holding the jus that made the sandwiches from Phillippe’s so good. There was also a sliced pickle wrapped in foil.
Legal smiled after his first bite and pumped his skinny arm like he had just won a great victory. I smiled. I was glad to bring him something. He had two sons and a bunch of grandchildren but they never came around except on the holidays. As Legal told me, “They need you until they don’t need you.”
When I was with Legal we talked mostly about cases and he would suggest strategies. He was absolute aces when it came to predicting prosecution plans and case roll outs. It didn’t matter that he had not been in a courtroom in this century or that penal codes had changed since his day. He had baseline experience and always had a play. He called them moves, actually – the doubleblind move, the judge’s robes move and so on. I had come to him during the dark time that followed the election. I wanted to learn about my father and how he had dealt with the adversities of his life. But I ended up learning more about the law and how it was like soft lead. How it could be bent and molded.
“The law is malleable,” Legal Siegel always told me. “It’s pliable.”
I considered him to be part of my team and that allowed me to discuss my cases with him. He’d throw out ideas and his so-called moves. Sometimes I used them and they worked, sometimes not.
He ate slowly. I had learned that if I gave him a sandwich, he could take an hour to eat it, steadily chewing small bites. Nothing went to waste. He ate everything I brought him.
“The girl in three-thirty died last night,” he said between bites. “A shame.”
“I’m sorry to hear that. How old was she?”
“She was young. Early seventies. Just died in her sleep and they carted her out this morning.”
I nodded. I didn’t know what to say. Legal took another bite and reached into my briefcase for a napkin.
“You’re not using the jus, Legal. That’s the good stuff.”
“I think I like it dry. Hey, you used the bloody flag move, didn’t you? How’d it go?”
When he grabbed the napkin he had spotted the extra blood capsule I kept in a Ziploc bag. I had it just in case I swallowed the first one by mistake.
“Like a charm,” I said.
“You get the mistrial?”
“Yep. In fact, mind if I use your bathroom?”
I reached into the briefcase and grabbed another Ziploc containing my toothbrush. I went into the room’s bathroom and brushed my teeth at the sink. The red dye turned the brush pink at first but soon it was all down the drain.
When I came back to the chair I noticed that Legal had only finished half his sandwich. I knew the rest must be cold and there was no way I could take it out to the dayroom to heat it in the microwave. But Legal still seemed happy.
“Details,” he demanded.
“Well, I tried to break the witness but she held up. She was a rock. When I got back to the table I gave him the signal and he did his thing. He hit me a little harder than I was expecting but I’m not complaining. The best part is I didn’t have to make the motion to declare a mistrial. The judge went right to it on his own.”
“Over prosecution’s objection?”
“Good. Fuck ’em.”
Legal Siegel was a defense attorney through and through. For him, any ethical question or gray area could be overcome by the knowledge that it is the sworn duty of the defense attorney to present the best defense of his client. If that meant tipping a mistrial when the chips were down, then so be it.
“Now, the question is, will he deal now?”
“It’s actually a she, and I think she’ll deal. You should’ve seen the witness after the scuffle. She was scared and I don’t think she’ll be wanting to come back for another trial. I’ll wait a week and have Jennifer call the prosecutor. I think she’ll be ready to deal.”
Jennifer was my associate Jennifer Aronson. She would need to take over representation of Leonard Watts because if I stayed on it would look like the setup it was and which Kristina Medina had alluded to in the courtroom.
Medina had refused to negotiate a plea agreement before the trial because Leonard Watts declined to give up his partner, the guy who drove the car that bumped into each of the victims. Watts wouldn’t snitch and so Medina wouldn’t deal. Things would be different in a week, I thought, for a variety of reasons. I had seen most of the prosecution’s case laid out in the first trial, Medina’s main witness was spooked by what had happened in front of her in court today, and mounting a second trial would be a costly use of taxpayers’ money. Added to that, I had given Medina a glimpse of what might come if the defense presented a case to a jury – namely my intention to explore through expert witnesses the pitfalls of interracial recognition and identification. That was something no prosecutor wanted to deal with in front of a jury.
“Hell,” I said. “She might call me before I even have to go to her.”
That part was wishful thinking but I wanted Legal to feel good about the move he had strategized for me.
While I was up I took the extra blood capsule out of the briefcase and dropped it into the room’s hazardous waste container. There was no need for it anymore.
My phone buzzed and I pulled it out of my pocket. It was my case manager Lorna Taylor calling but I decided to let it go to message. I’d call her back after my visit with Legal.
“What else you got going now?” Legal asked.
I spread my hands.
“Well, no trial now so I guess I have the rest of the week off. I may go down to arraignment court tomorrow and see if I can pick up a client or two. I could use the work.”
Not only could I use the income but the work would keep me busy and not thinking about the things in my life that were wrong. In that sense the law had become more than a craft and a calling. It kept me sane.
By checking in at Department 130, the arraignment court in the downtown criminal courts building, I had a shot at picking up clients the public defender was dropping because of conflict of interest. Every time the DA filed a multi-defendant case the PD could only take on one defendant, putting all others in conflict. If those other defendants did not have private counsel the judge would appoint counsel to them. If I happened to be there twiddling my thumbs, more often than not I’d pick up a case. It paid government scale but it was better than no work and no pay.
“And to think,” Legal said, “at one point last fall you were running five points up in the polls. And now here you are scrounging around first appearance court looking for handouts.”
As he had aged, Legal had lost most of the social filters normally employed in polite company.
“Thanks, Legal,” I said. “I can always count on you for a fair and accurate take on my lot in life. It’s refreshing.”
Legal Siegel raised his bony hands in what I guessed was an apologetic gesture.
“I’m just saying.”
“So what about your daughter then?”
This was how Legal’s mind worked. Sometime he couldn’t remember what he had for breakfast, but he seemed to always remember that I had lost more than the election the year before. The scandal had cost me the love and companionship of my daughter and any shot I’d had at putting my broken family back together.
“Things are still the same there, but let’s not go down that road today,” I said.
I checked my phone again after feeling the vibration signaling I had received a text. It was from Lorna. She had surmised that I wasn’t taking calls or listening to voicemail. A text was different.
Call me ASAP – 187
Her mention of the California penal code number for murder got my attention. It was time to go.
“You know, Mickey, I only bring her up because you don’t.”
“I don’t want to bring her up. It’s too painful, Legal. I get drunk every Friday night so I can sleep through most of Saturday. You know why?”
“No, I don’t know why you would get drunk. You did nothing wrong. You did your job with that guy Galloway or whatever his name was.”
“I drink Friday nights so I am out of it Saturdays because Saturdays were when I used to see my daughter. His name was Gallagher, Sean Gallagher, and it doesn’t matter if I was doing my job. People died and it’s on me, Legal. You can’t hide behind just doing your job when two people get creamed in an intersection by the guy you set free. Anyway, I gotta go.”
I stood up and showed him the phone as if it were the reason I needed to go.
“What, I don’t see you for a month and now you already have to go? I’m not finished with my sandwich here.”
“I saw you last Tuesday, Legal. And I’ll see you sometime next week. If not then, then the week after. You hang in and hold fast.”
“Hold fast? What’s that supposed to mean?”
“It means hold on to what you got. My half brother the cop told me that one. Finish that sandwich before they come in here and take it from you.”
I moved toward the door.
“Hey, Mickey Mouse.”
I turned back to him. It was the name he bestowed on me when I was a baby, born at four and a half pounds. Normally I’d tell him not to call me that anymore. But I let him have it so I could go.
“Your father always called the jurors the gods of guilt. You remember that?”
“Yep. Because they decide, guilty or not guilty. What’s your point, Legal?”
“The point is that there are plenty of people out there judging us every day of our lives and for every move we make. The gods of guilt are many. You don’t need to add to them.”
I nodded but couldn’t resist a reply.
“Sandy Patterson and her daughter Katie.”
Legal looked confused by my response. He didn’t recognize the names. I, of course, would never forget them.
“The mother and daughter Gallagher killed. They’re my gods of guilt.”
I closed the door behind me and left the do not disturb sign on the knob. Maybe he’d get the sandwich down before the nurses checked on him and discovered our crime.