BILLY J. WILLIAMS, OSB #901366 

United States Attorney 

District of Oregon 

HELEN L. COOPER, OSB #871957 

helen.cooper@usdoj.gov 

GAVIN W. BRUCE, OSB # 113384 

gavin.bruce@usdoj.gov 

Assistant United States Attorneys 

405 East 8th Avenue, Suite 2400 

Eugene, Oregon 97401-2708 

Telephone: (541) 465-6771 

Facsimile: (541) 465-6917 

Attorneys for the United States 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON

UNITED STATES OF AMERICA 

 v. 

JAMIE FAYE COBAT, 

 Defendant. 

3:16-CR-00187-MO 

GOVERNMENT’S SUPPLEMENTAL 

RESPONSE TO DEFENDANT’S 

MOTION FOR NEW TRIAL AND 

MOTION TO DISMISS 

 The United States of America, by Billy J. Williams, United States Attorney for the 

District of Oregon, through Amy E. Potter, Helen L. Cooper and Gavin W. Bruce, Assistant 

United States Attorneys, hereby submits this response to defendant’s motion for a new trial and 

motion to dismiss. Defendant’s motions should be denied 

INTRODUCTION 

A jury found defendant Jamie Cobat lied about where her son was living, where she 

lived, and with whom she lived. These lies were material because Cobat received Supplemental 

Security Income (SSI) benefits; food stamps or Supplemental Nutrition Assistance Program 

(SNAP) benefits; and Temporary Assistance for Needy Families (TANF) benefits premised on 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 1 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 2 

her false information. The lies about with whom she was living affected her eligibility for 

benefits. After her conviction and in response to Cobat’s claim that she did not actually receive 

TANF benefits, the government investigated her claim. Although the government confirmed that 

Cobat received TANF benefits, it also discovered that the specific TANF payments she received 

were funded by state funds. Absent a federal hook, the government promptly disclosed its 

discovery and moved to vacate the verdict on the TANF-related count (count three). 

 Nothing about this post-trial discovery undermines the jury’s finding that Cobat lied in 

several material respects to receive welfare benefits. Consequently, her bid for a new trial 

should be denied. Her alternative demand for dismissal should be rejected because there was 

nothing flagrant or outrageous about the government’s handling of this case. Her ineffective 

assistance of counsel claims are premature. Her motions should be denied. 

BACKGROUND 

 Defendant Cobat was charged with one count of wire fraud and three counts of theft of 

government funds based on her receipt of public assistance. (ECF No. 16). The core issue at 

trial was whether Cobat knowingly collected public assistance she was not entitled to receive 

because she lied about whom she was living with. There were three types of benefits at issue: 

SSI benefits, which were based on her son’s medical condition and defendant’s financial need; 

SNAP benefits; and TANF benefits. Her right to receive each type of benefit, and therefore her 

guilt as to each count, was linked by one common and critical question: who was living with 

Cobat? After hearing all the evidence, including the testimony of Cobat, the jury returned a 

guilty verdict on all four counts in the superseding indictment. (ECF Nos. 72, 75). 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 2 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 3 

 After trial, Cobat fired her lawyer, and the court appointed new counsel. In December 

2017, defense counsel began asking for additional information related to the TANF benefits. 

Defense counsel believed that the benefit Cobat received was not TANF but, rather, pre-SSI, and 

that Cobat was eligible to receive those benefits regardless of whether her son lived in the home. 

The defense theory appeared to be based on EBT logs that counsel or Cobat obtained directly 

from the Oregon Department of Human Services (DHS), which were not provided in discovery. 

(Exhibit A to Defense Motion for New Trial (hereinafter “MNT Ex.”)) 

The government followed up with investigators and received confirmation that all of the 

benefits alleged to be TANF were in fact TANF. (Exhibit 2 to Government’s Response to 

Motion for New Trial (hereinafter “Gov’t. Resp. Ex.”); see also Gov’t. Resp. Ex. 3, ¶ 4). The 

government also confirmed that these TANF-related benefits required that Cobat have a minor in 

the home in order to receive them. (Gov’t. Resp. Ex. 3, ¶ 4). 

Cobat filed a motion for a new trial and a hearing was held. (ECF Nos. 125, 132). After 

the hearing, the Court ordered additional discovery and briefing. During this process, the 

government determined that it had requested Cobat’s SNAP spending history in January 2017. 

(Declaration of AUSA Helen Cooper at ¶ 7 (hereinafter Decl. H. Cooper)).1

 In response to 

AUSA Cooper’s request, the government determined that DHS had provided the EBT logs via 

secure email. (Id. at ¶ 8). The government did not process them for discovery. (Id. at ¶ 10). 

While the government received the records, it has no record of downloading them or saving them 

 1

 AUSA Gavin Bruce, who served as AUSA Cooper’s trial partner for this case, did not 

join the case until February 23, 2017. (ECF No. 32). He did not participate in the grand jury or 

discovery process for this case. Decl. H. Cooper ¶ 4. At trial, he did not handle any of the SSA 

or DHS witnesses. 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 3 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 4 

for purposes of discovery. (Id.) When the government discovered this mistake, it turned over 

the email to defense counsel showing that the EBT logs had been sent to the government on 

January 10, 2017. (Id.at ¶ 20; see also MNT Ex. E). 

The government also turned over additional discovery including updated file narratives 

from DHS showing that Cobat contacted DHS on January 18, 2017, less than three months 

before trial, to follow up on a request for records she made in October 2016. (Exhibit 1 to 

Defense Motion to Dismiss (hereinafter “MTD Ex.”)). According to the January 2017 records, 

Cobat claimed that she was not receiving TANF, and confirmed that she had received the 

documents she needed. (Id.) 

During this post-trial process, the government discovered, for the first time, that the 

TANF/Pre-SSI program was not funded by federal funds. Because these benefits were not 

funded federally, the government recognized that it could not prove that Cobat had received over 

$1000 of federally-funded TANF benefits. As such, the government moved to vacate count 

three, which this Court granted. (ECF Nos. 137, 139). 

ARGUMENT 

A. A New Trial is Not Warranted in this Case 

A new trial is not warranted in this case because the jury’s verdict rested on 

overwhelming evidence that Cobat lied about several critical aspects of her living conditions that 

affected her eligibility for SSI and SNAP benefits. Nothing in the newly disclosed evidence 

relates to or undermines the verdict on those counts. 

/// 

/// 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 4 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 5 

1. Legal Background 

Federal Rule of Criminal Procedure 33 governs a motion for a new trial. “A defendant 

who seeks a new trial based on new or newly discovered evidence must show that (1) the 

evidence is newly discovered; (2) the failure to discover the evidence is not attributable to a lack 

of diligence by the defendant; (3) the evidence is material to the issues at trial; (4) the evidence is 

neither cumulative nor impeaching; and (5) the evidence indicates that a new trial would 

probably result in an acquittal.” United States v. Waggoner, 339 F.3d 915, 919 (9th Cir. 2003) 

(citations omitted). When a new trial is based on an allegation that the government violated its 

obligations under Brady v. Maryland, 373 U.S. 83 (1963), defendant bears the burden of proving 

that there has been a Brady violation that warrants relief. Strickler v. Greene, 527 U.S. 263, 289-

90 (1999). To meet this burden, Cobat must show that: (1) the undisclosed evidence was 

favorable to her; (2) the evidence was suppressed by the prosecution—either willfully or 

inadvertently; and (3) prejudice ensued. Id. at 281-82. 

Brady only applies to material information. Brady, 373 at 87. “Evidence is ‘material’ . . 

. when there is a reasonable probability that, had the evidence been disclosed, the result of the 

proceeding would have been different.” Cone v. Bell, 556 U.S. 449, 469-470 (2009) (citation 

omitted). A “reasonable probability” of a different result is one in which the suppressed 

evidence “undermines confidence in the outcome of the trial.” Kyles v. Whitley, 514 U.S. 419, 

434 (1995) (internal quotations and citation omitted); see also Turner v. United States, 137 S. Ct. 

1885, 1893 (2017). 

Brady is not implicated when the information is available to both parties or when it is 

publically available. If the defendant is aware of the “probability” that certain evidence exists 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 5 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 6 

and fails to request it through discovery, she cannot later claim a Brady violation. Raley v. Ylst, 

470 F.3d 792, 804 (9th Cir. 2006). Nor can a defendant allege a Brady violation when she 

makes statements and similarly fails to inform counsel or request them. Rhoades v. Henry, 638 

F.3d 1027, 1037-38 (9th Cir. 2011). 

 In determining whether the defendant was prejudiced, courts should evaluate the effect of 

the undisclosed evidence not in isolation, but in light of the rest of the trial record. United States 

v. Agurs, 427 U.S. 97, 112 (1976); United States v. Collins, 551 F.3d 914, 923 (9th Cir. 2009). 

Even if there is a Brady violation as to a single count, the law recognizes that counts may be 

severable and the non-affected counts may stand alone. United States v. Johnson, 592 F.3d 164, 

171 (D.C. Cir. 2010). “For each count, then, the court must evaluate each of the three 

components of a Brady violation.” Id. When the evidence as to the remaining counts is “so 

extensive” and “sufficiently strong,” reversal is not warranted. See United States v. Lazarenko, 

564 F.3d 1026, 1044-45 (9th Cir. 2009) (denying new trial on all counts based on prejudicial 

misjoinder because the evidence was sufficient on the remaining counts). To prevail on the 

remaining counts, a defendant must show that the evidence would have “buttress[ed] his version 

of events” as to those counts. See United States v. Lloyd, 71 F.3d 408, 412-13 (D.C. Cir. 1995) 

(rejecting defense argument that Brady violation corrupted his conviction on every count). 

2. There Was No Brady Violation Because the Records were Known and Available to 

the Defense and Were Not Exculpatory. 

Failure to provide Cobat’s EBT logs, which show the deposits and spending of her SNAP 

and TANF benefits, and the updated TRACS narratives, which show she contacted DHS in 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 6 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 7 

January 2017,2 does not constitute a Brady violation in this case. Cobat knew of the existence of 

the records and did not request them from the prosecution. See Decl. H. Cooper at ¶ 12. She 

also had the ability to obtain them herself. The records show Cobat contacted DHS for records 

in 2016, and received records in January 2017 from DHS that she said were sufficient. MTD Ex. 

1. Despite this, she testified that she never received records showing she received TANF. Trial 

Transcript at 329 (hereinafter “Tr.”). The government cannot be expected to constantly request 

agency records post-indictment to discern if a defendant is making statements to the agency that 

support her defense. Nor does the government commit a Brady violation by failing to obtain 

records when the defendant knows about them and could obtain or request them, but declines to 

do so. Raley, 470 F.3d at 804. 

Nor are any of these records exculpatory. The records establish that Cobat was receiving 

a TANF benefit until May 2013. She applied for the benefits, which were essentially a loan on 

her SSI, on a form with “Temporary Assistance for Needy Families” in the header. MNT Ex C. 

The form also notes it is her “family’s benefit,” suggesting that the benefits were not for 

individual adults. Gov’t Resp. Ex.3, ¶ 3-4; Tr. at 173. The EBT logs show that when she started 

receiving this TANF benefit in 2012, it came from an account listed as TANFSFP2. MNT Ex. 

A. The EBT logs simply show what account her TANF benefits were coming from. 

 2

 The records up until October 2016 were provided and were an exhibit at trial. See 

Government Trial Exhibit 31 (hereinafter “Tr. Ex.”). The updated records contain only two 

additional entries, both entered on January 18, 2017. MTD Ex. 1. 

 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 7 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 8 

Likewise, an entry regarding a single statement by Cobat to DHS in January 2017 does 

not change what the rest of the TRACS show—that Cobat was receiving TANF long after she 

claimed she stopped receiving it in April 2012. The TRACS show the following: 

 In May 2012, Cobat she submitted an application for TANF. Tr. Ex. 31, p. 108. 

 In October 2012, Cobat called and asked why she had not received more SNAP 

and TANF. Id. at 115. 

 In December 2012, her records reflect she was receiving a TANF grant. Id. at 

116. 

 In May 2013, Cobat re-applied for cash, medical and SNAP benefits and 

continued to report that her son was living with her. The TANF was discontinued 

when DHS determined that her son was not “deprived” of his father due to seeing 

him after school. Id. at 121. 

 

It is true that further questions from defense counsel about the type of TANF benefits 

Cobat was receiving post-trial prompted the government to ask DHS who funded the specific 

pre-SSI/TANF benefits. Decl. H. Cooper at ¶¶ 21-22. Although it is possible that the EBT logs 

and the TRACS narrative from January 2017 may have prompted this inquiry earlier, any 

prejudice has been corrected through the government’s voluntary motion to vacate the conviction 

as to the TANF benefits (count 3). 

3. Cobat Cannot Establish Prejudice as to The Remaining Counts 

Cobat seizes upon the government’s mistake regarding the source of the TANF funds in 

an attempt to discredit the entire trial and the jury’s verdict, but the factual record cannot support 

this overreach. Throughout the trial, the jury was presented with exhibits and testimony that 

highlighted Cobat’s many lies to SSA and DHS regarding who she was living with and where 

she was living. These lies yielded benefits she was not entitled to receive. There was not just 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 8 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 9 

one single statement or omission, but a pattern of calculated lies and inconsistent statements, 

which resulted in Cobat receiving benefits she was not entitled to receive. And her response to 

these arguments was simply to lay blame on everyone else for her own lies. 

As the representative payee for her son’s SSI benefits, Cobat submitted annual reports to 

SSA in 2012, 2013 and 2014, on which she wrote that her son lived with her in Lebanon. Tr. 

Exs. 9, 10, 11. Yet, her son testified—and school records confirmed—that, during that time, 

he was living with his father and attending school in Albany. Tr. at 87-89; Tr. Ex 15. Similarly, 

in 2013, she told DHS that she and her son lived in Lebanon and that her “friend” Fox was living 

with them. She then told DHS (but not SSA) in September 2013 that she had moved to 

Redmond. Tr. Ex. 24. However, on the stand she testified that she had not moved to Redmond, 

as she lived in Lebanon the entire time. Tr. at 351, 353. This was despite testimony that 

another couple rented the home in Lebanon during much of this time. Tr. at 138-40. 

Cobat took her story a step further during trial when she asserted that because she had 

legal custody of her son, she believed she could report he lived with her even when he was living 

with his father. Tr. at 322-23, 345-46. This was despite being put on notice by DHS in April 

2012, that her benefits would be affected if her son lived with his father. Tr. at 149-50; Tr. Ex. 

31, p. 105. She also claimed she spent all of the benefits on her son as she had certified. When 

confronted with SSI records showing how she had spent her son’s benefits, she claimed the trips 

to the liquor store were to buy him soda and the trips to Victoria’s Secret were to buy him 

cologne. Tr. at 361. 

Perhaps recognizing the overwhelming evidence against her, Cobat resorts to claiming 

that the records cast “serious doubt on the testimony of multiple government witnesses.” This 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 9 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 10 

argument has no merit. As to the government witnesses, only two witnesses testified regarding 

TANF benefits. Rebecca Hernandez’s testimony was focused on the time period before the 

indictment and involved the traditional TANF benefits. Tr. at 148-49. She was never asked if 

Cobat received TANF benefits from September 2012 until May 2013, what type of TANF it was, 

the source of those funds, or if Cobat had ever said that she believed she was not receiving 

TANF after April 2012. 

The DHS investigator, Karlene Austin, was asked about the benefits during the relevant 

time period and testified, correctly, that Cobat was receiving TANF benefits and that an adult is 

only eligible for TANF if there is a minor in the home. Tr. at 173, 177-78, 189. She was never 

asked if the benefits from September 2012-May 2013 were federally-funded. In fact, she clearly 

testified that there were two sources of funding for TANF: state and federal.3

 Tr. at 172. She 

was also never asked to describe if the benefits were pre-SSI benefits. This is not because Cobat 

was unaware of this argument—her counsel asked Cobat about it during her direct testimony. 

Tr. at 329-31. Similarly, Austin was never asked if Cobat contacted DHS to tell them she was 

not receiving TANF benefits. 

Nothing about the TANF funding source undermines the jury’s finding that she lied about 

where her son was living, how she spent the money, who she lived with, and where they lived.4 

 3

 Austin was the only DHS witness who testified in grand jury. In grand jury, she also 

testified that TANF was funded by state and federal funds. She was not asked what amount of 

Cobat’s TANF benefit was funded by the federal government. 

4 To be convicted, Cobat was not required to know that the money belonged to the 

government or the specific name of the benefit, only that she was receiving a benefit she was not 

entitled to receive. See United States v. Howey, 427 F.2d 1017, 1018 (9th Cir. 1970) (holding 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 10 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 11 

It was these repeated lies that resulted in her convictions. Her lies are just as apparent today as 

they were before the government discovered that her ill-gotten TANF benefits were state-funded. 

Cobat’s convictions for receiving SSI and SNAP she was not entitled to receive “stand on their 

own.” Lazarenko, 564 F.3d at 1047. Cobat’s motion for a new trial as to the remaining counts 

must be denied. 

B. Dismissal Of The Indictment Is Not Warranted 

Dismissal of the indictment is also not warranted because Cobat has failed to demonstrate 

that the prosecution acted in bad faith. To warrant dismissal of the indictment, Cobat must not 

only demonstrate a Brady violation occurred, she must show there was “flagrant misbehavior” by 

the prosecution, demonstrating a “reckless disregard” of its constitutional obligations. United 

States v. Chapman, 524 F.3d 1073, 1085 (9th Cir. 2008). A court may dismiss an indictment 

under its supervisory powers only in extremely limited circumstances: (1) in cases involving 

“flagrant prosecutorial misconduct,” and (2) when the defendant suffers “substantial prejudice,” 

and, significantly, (3) where “no lesser remedial action is available.” Id. at 1086-87. To 

determine if dismissal is warranted, a court should consider “the government’s willfulness in 

committing the misconduct and its willingness to own up to it.” United States v. Kojayan, 8 F.3d 

1315, 1318 (9th Cir. 1993). 

Even if Cobat could establish that she has suffered some prejudice as a result of the 

failure to discover the source of the TANF funding, she cannot demonstrate any “flagrant 

 

that government is not required to prove that defendant knew the stolen funds were federal 

funds). The source of the funding is a jurisdictional requirement. Id. 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 11 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 12 

prosecutorial misconduct” necessitating dismissal of the entire indictment. Chapman, 524 F.3d 

at 1085 (quotations and citation omitted). What happened in this case was a mistake—the 

government failed to clarify if over $1000 of the $2,845 in TANF funds Cobat received during 

the time period alleged in the indictment were federally-funded. The government charged the 

case based on the general understanding that TANF is a federally-authorized and funded 

program that provides cash assistance to certain low-income families. While the government 

was aware that some portion of TANF is funded by the state, it operated under the general 

assumption that TANF is predominately funded by the federal government. Decl. H. Cooper at 

¶¶ 3, 6. 

After defense counsel said that he believed the funds were not federally-funded, the 

government promptly reached out to DHS to verify the funding. Id at ¶ 22. DHS stated that preSSI TANF is initially funded by the state, and later reimbursed with federal funds when the 

recipient is awarded SSI. Id. The government followed up to determine why DHS showed that

Cobat had received notice of overpayment of TANF if the payments were funded by the state. 

Id. DHS responded that when writing the overpayment, they do not determine if “the case is 

federally funded, state funded or a mix. We don’t have any systematic way to capture funding 

types, only program codes.” Id. The government then determined that it should move to vacate 

count three, and after receiving the proper approvals, alerted defense counsel, and filed the 

motion to vacate. Id. at ¶ 23. 

The government did not, as Cobat alleges, repeatedly ignore issues with the TANF count 

during the case. The heart of this allegation is Cobat’s claim she was not receiving TANF and 

therefore, any claim during trial that she received TANF was false. But, as the government has 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 12 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 13 

demonstrated, she was, in fact, receiving a type of TANF that she was not eligible to receive. 

See Gov’t. Resp. Ex. 3 at ¶ 4. 

Cobat also seizes on a single comment during rebuttal that the first time she claimed she 

was not receiving TANF was at trial. The government’s single statement in rebuttal was true 

based on the evidence it had before it. It had no knowledge of Cobat’s January 2017 

conversation with DHS. See Decl. H. Cooper at ¶ 11. Cobat knew, however, that she had 

contacted DHS, and was free to testify to that effect or to request that the government check if 

there were records of that contact. She did neither. 

The government made a mistake about a jurisdictional issue: who funded the TANF 

benefits? 5 As soon as the government was aware of this issue, it promptly investigated and 

learned of the error. Id. at ¶¶ 21-22. This error did not result in any prejudice, though, because 

her conviction as to the TANF benefits has been vacated. ECF No. 139. Cobat was not 

convicted of SSI and SNAP fraud because of some misconduct by the government. She was 

convicted based on the multitude of false and inconsistent statements, many of which she made 

in writing. Her claim of confusion and that “everyone else is wrong” was rejected by the jury. 

Her motion to dismiss the indictment should be denied. 

C. Defendant’s Ineffective Assistant Of Counsel Claims Are Not Ripe 

The government has previously addressed defendant’s claims that she should receive a 

new trial because her counsel was ineffective. The government will not repeat all those 

arguments here, but does incorporate its prior response. Generally, the Ninth Circuit has 

 5

 Cobat did receive some federally-funded TANF benefits during the indictment period. 

See MNT Ex. A. 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 13 of 14
Government’s Supplemental Response to Motion for New Trial and to Dismiss Page 14 

“‘rejected the use of a Rule 33 motion for new trial based on ‘newly discovered evidence’ 

involving the ineffective assistance of counsel.” United States v. Allen, 153 F.3d 1037, 1045 (9th 

Cir. 2003) (citing United States v. Pirro, 104 F.3d 297, 299 (9th Cir. 1997)). For that reason, 

these claims should be rejected. 

Even if the Court were to entertain defendant’s claims at this juncture, she cannot show 

that her trial counsel’s representation fell below an objective standard of reasonableness and that 

she was prejudiced. Strickland v. Washington, 466 U.S. 668, 690, 694 (1984). Given the 

overwhelming evidence against her, even if counsel was deficient, she cannot establish a 

reasonable probability that the outcome of the proceeding would have been different. Id. at 694. 

CONCLUSION 

 The government did not commit a Brady violation and voluntarily moved to vacate count 

three when it realized it could not prove an element of the offense. No other remedy is 

warranted. Defendant’s motions for a new trial and to dismiss the indictment should be denied. 

 Respectfully submitted this 26th day of March 2018. 

 BILLY J. WILLIAMS 

 United States Attorney 

s/ Helen L. Cooper 

HELEN L. COOPER 

Assistant United States Attorney 

 s/ Gavin W. Bruce 

GAVIN W. BRUCE 

Assistant United States Attorney 

s/ Amy E. Potter 

AMY E. POTTER 

Assistant United States Attorney 

Case 3:16-cr-00187-MO Document 144 Filed 03/26/18 Page 14 of 14