and Wyoming.
Through its residential, vocational rehabilitation, children's services, transportation, and community services programs, the agency helps to enhance the lives of more than 800 community members who rely on services each year.25 May 2020 | claudio_carvalho

6 | Cliché, but Entertaining

After a burglary in their house in London, Liza (Katie Holmes) and her son Jude (Christopher Convery) are traumatized: Lisa becomes frigid with her husband Sean (Owain Yeoman) and Jude a speechless boy. Liza and Sean decide to rekindle their lives moving to a house in the countryside nearby the Heelshire Mansion and Jude's psychiatrist Dr. Lawrence (Anjali Jay) agrees that it would be benefit for him. While walking through the woods with Liza, Jude finds a buried porcelain doll and decides to keep it. Then they meet the groundkeeper Joseph (Ralph Ineson) and his dog Oz that walks with Liza and Jude home. Jude becomes obsessed for the doll that he calls Brahms and shows rules to be followed


by the family that Brahms told him. Further, he changes his behavior and weird things happen in the house.

"The Boy" (2016) is a surprisingly good horror film. The sequel "Brahms: The Boy II" (2020) is inferior to the original film but is a decent horror movie that uses many clichés, but startles in many scenes and entertains. The performances are good, the atmosphere is creepy, and the screenplay is acceptable. My vote is six.

Title (Brazil): "Brahms: Boneco do Mal II" ("Brahms: Evil Doll II")In Re Grammar, Roberts's Stance Is Crystal Clear

John G. Roberts Jr. could have easily ignored the letter from E.F.W. Wildermuth that came across his desk in December 1982. The correspondent, an octogenarian lawyer from New York, made an obscure procedural point about the Senate's jurisdiction based on his interpretation of the 17th Amendment; it was not the sort of question that would typically require serious attention from the White House counsel's office, where Mr. Roberts worked at the time.

But rather than dismiss the letter as the work of a curmudgeon, Mr. Roberts seized on it with delight.

Acknowledging that the White House usually ignored such mail, he wrote to his superior, Fred F. Fielding, the White House counsel, "Anyone who can quote inspiring passages from Plato and Webster, however,


grammarian more evident than in his memorandums from the Reagan era, when, as a lawyer in the counsel's office, he frequently peppered notes and documents with minor syntax corrections even when the basic legal arguments were sound. If Judge Roberts is confirmed, and his word-consciousness follows him to the court, it will put him in the upper tier of justices who have put a premium on the English language.

At a minimum, his arrival would add a formidable Scrabble talent to the bench.

Careful wording is "part of his approach to the practice of law," said David G. Leitch, the general counsel to the Ford Motor Company, who overlapped with Mr. Roberts at the law firm Hogan & Hartson and at the Justice Department in the 1990's. Something as minorletter from David T. Willard, an elementary school superintendent in Illinois who opposed the administration's education policies, Mr. Roberts again concluded that no legal issues needed to be addressed by the White House counsel. But he took the opportunity to note, "The letter is very sarcastic, although Willard inadvertently proves our point about the quality of public education by incorrectly using 'affect' for 'effect."'

Those sorts of mistakes, common among casual writers, are pointed out repeatedly in his commentary. He suggests swapping the word "voluntarism" for "volunteerism" and offers "ensuring" for "insuring." He corrects the spelling of the country "Namibia" (someone had written "Nambia"); demands consistency in first-, second- and third-person references; and rejects a colleague's attempt to use the word "plurilateral," replacing it with "multilateral."

History is also not


determine the issues raised by the petition and answer.

4
After hearing, a report was filed by the special master. The report recited that on or about July 22, 1952, Lena Leveen, the alleged bankrupt, was the record owner of two parcels of land with buildings thereon situated in Nantucket; that Lena Leveen, being then hopelessly insolvent, by deed dated July 22, 1952, and recorded the following August 5, conveyed both parcels of land, without consideration, to her sister Esther Leveen; that testimony was given by Esther Leveen, and by another sister Caroline Leveen, to the effect that the parcels of land so conveyed were not the property of Lena Leveen, who held no more than the bare legal title thereto, the true beneficial ownership being vested in the saidEsther Leveen. The special master's report also recited:

5
"Evidence was introduced that Lena Leveen gave a mortgage on this property to one Theodore Karp on January 24, 1952 to secure the payment of $5,000.00. This mortgage was given about seven (7) months before the transfer of the property by Lena to Esther. Further, on May 15, 1952, about two (2) months before the said transfer Lena Leveen borrowed $1300.00 from a Mr. Goodwin and in a written statement to him stated, among other things, `I also am owner of a house on Nantucket Island'. Neither of these debts had been paid at the time of the transfer of the property to Esther Leveen by Lena Leveen and as far as the evidence went still remain unpaid."

6
The special master expressed


the opinion that, without determining whether Esther was the real owner of the property, she was in any event estopped to assert such ownership. "Ostensible ownership in the land in Lena was created by the act of Esther. Until the time of the conveyance by Lena to Esther, Lena had such an interest in the property that she could convey and give good title to the same." As a conclusion of law, the special master reported that the conveyance by Lena to Esther on July 22, 1952, "was a conveyance of her property fraudulent under the provisions of section 67(d) (1) of the Bankruptcy Act"; that this conveyance was with the intent on Lena's part to hinder, delay or defraud her creditors or any of them; that EstherOntario health officials reported 100 new cases of COVID-19 in the province on Wednesday and four new deaths, taking the tally of cases including deaths and recoveries to 688.

It's the highest daily increase in active cases since the outbreak reached the province in late January.

Ontario reported 85 new infections on Tuesday.

The new tally includes Ontario’s ninth death, confirmed to have occurred late Tuesday at a hospital in Niagara. An individual in their 80s who was a resident of Ina Grafton Gage Village died 11 days after testing positive for COVID-19.

Officials said the person had close contact with a family member who recently travelled to Europe.

On Wednesday afternoon, Ontario reported four more fatalities, bringing the death toll to 13.

Toronto's medical officer of health Dr. Eileen de Villa said there


are three more COVID-19 deaths in the city -- an elderly man with pre-existing condition who was tested at North York General Hospital and two residents of Seven Oaks long-term care in Scarborough.

Ottawa reported their first COVID-19 death on Wednesday evening. Ottawa public health said a man in his 90s with no travel history died in hospital.

Ontario now has 671 active novel coronavirus cases, eight patients who have made full, clinically-confirmed recoveries and thirteen deaths.

Public health units in Durham and Hamilton confirmed Ontario’s seventh and eighth deaths from the virus earlier on Tuesday.

Health officials said that of the 100 new cases, five patients required hospitalization.

They include a man and woman in their 50s from the Porcupine (northeastern Ontario) health unit, a woman in her 80s in London Middlesex,a woman in her 70s from Halton Region who recently returned from Spain and a woman in her 20s in Peel Region.

Thirty of the cases were tied to recent travel to locations including the United States, the Dominican Republic, Spain, Britain, Egypt, Peru, Mexico, the Philippines, the Bahamas and France.

Twenty-two cases were attributed to close contact with a previously confirmed case, while the cause of the remaining 48 was listed as under investigation.

The increased case growth comes as Canada’s chief medical officer said Tuesday that nearly half of the country’s reported COVID-19 infections in recent days were caused by community transmission.

Of the 69 patients where the province disclosed at least some case particulars, 21 were from Toronto, 13 were from Peel, 5 were from Kingston, Frontenac, Lennox and


Sar or Fabien Barthez. When there is only one shirt up for grabs in the starting eleven, it can be a genuine occupational hazard.

Longing for Red, Blue or Orange
Iker Casillas has been a permanent fixture between the posts for Spain since he graduated with flying colours in the 2002 FIFA World Cup Korea/Japan™ and forced a talented generation of Spanish custodians to settle for the glory at club level. While his understudy Pepe Reina relieves his international frustration by shining brightly for Liverpool, the red door remains firmly closed for Andres Palop, whose brilliance between the posts helped Sevilla win back-to-back UEFA Cups in 2006 and 2007, or Victor Valdes, who makes do with chasing titles with Barcelona. The current Villarreal shot-stopper, Diego Lopez, is another to havebeen affected by the immovable Casillas. Despite his undoubted talent, the Galician found waiting for his chance at Real Madrid so infuriating that he opted to change clubs rather than wait for the Spanish captain to suffer a loss of form.

Sometimes, even being allocated the No1 is not enough to guarantee a starting berth. Take Fabien Barthez, who chose number 16 before entrenching himself in the French goal shortly before the 1998 FIFA World Cup France. He consigned Bernard Lama to the bench or unimportant games and closed the door to the youngsters for eight long years. Gregory Coupet, in particular, had good reason to toast Barthez's retirement. Despite six consecutive league title wins with Olympique Lyonnais, Coupet had to wait until he was 33 to become the


first choice international keeper with France. His big chance came at UEFA EURO 2008, but his international career ended somewhat disappointingly at the age of 36.

Just the opposite was the case for the gifted Ed de Goej, the winner of the Netherlands' Golden Boot in 1994. While he defended the Dutch goal at the 1994 FIFA World Cup USA, there was huge competition on the bench to take his place. Edwin Van der Sar has been lord and master of the Dutch goal since 1995, with De Goej acting as his substitute in the national team at the next three major international tournaments. The latter's move from Feyenoord to Chelsea was one of the landmarks signings in the 1997 transfer market, and he went on to make 179appearances for the Blues, keeping 71 clean sheets. Another Dutchman left in the shadow of the great Van der Sar was Ruud Hesp. Despite the fact that he was a member of the national squad for EURO 96 and France 1998, he never got to defend his national colours, earning his international successes at Barcelona, where he won two La Liga titles, one Copa del Rey and one UEFA Super Cup.

The outstanding Jens Lehmann was forced to look on from the sidelines when Oliver Kahn was at the height of his powers. The rivalry between these two goalkeeping giants ended with a touch of poetic justice when Jurgen Klinsmann opted to hand Lehmann his place in the starting line-up for 2006 FIFA World Cup Germany. Yet the collateral


damage from this duel produced two victims in Hannover's Robert Enke and Hoffenheim's Timo Hildebrand, who could never get a firm grip on the Mannschaft shirt. They pair were deemed too inexperienced to challenge in the Kahn-Lehmann era, then too 'old' on its conclusion, by which time the up-and-coming Rene Adler had moved ahead of them in the pecking order.

It has become a fact of life in Germany that each generation must witness a battle of titans for the goalkeeper's jersey. Bodo Illgner and Andreas Kopke generously shared both the position and the titles, with the former starting at the 1990 FIFA World Cup and the latter at EURO 96. The 1980's rivalry between Harald Schumacher and his substitute Ulrich Stein was a little fiercer, while even SeppMaier, the great hero of the 1970's, cast a long shadow over the international career of another great, Wolfgang Kleff, who made just six appearances for Germany.

A 'lucky' injury
In the decade or so Gianluca Pagliuca and Gianluigi Buffon have been keeping goal for Italy, two hugely talented players have come and gone. Angelo Peruzzi held the goalkeeping position at EURO 96 and looked likely to do so again at France 1998 when an ill-timed injury handed the gloves to Pagliuca. Unwilling to sit on the bench, Peruzzi refused to travel to Korea/Japan 2002, and when he returned to the Italian squad in 2004, it was as understudy to Buffon. Francesco Toldo got his chance at EURO 2000, where Italy were runners-up to France, but only then after injuries


to Peruzzi and Buffon.

Argentinian talent Sergio Goycochea also seemed destined for a non-playing part during Italy 1990 thanks to the solid Nery Pumpido. But Pumpido fractured his tibia and fibula in a group qualifying game against the USSR, and Goyco took over and proved himself to be an expert penalty-saver. His performances against Yugoslavia in the quarter-finals and against the hosts in the semis made him a national hero, but lady luck deserted him in the final, when he failed to save the Andreas Brehme penalty that crowned West Germany world champions.

The list of goalkeepers that have lived outside the limelight is a long one. Take the promising English custodian Nigel Martyn, who was David Seaman's deputy for most of his career. Then there were the Mexicans AdolfoEthiopia. KA-HDSS was established in 2009 home-based under the School of Public Health in Mekelle University. It is led by the university's Research and Community Services Directorate and College of Health Sciences with the central research motivation of generating population-based health and demographic-related longitudinal information to support evidence-based decision making. It started its surveillance by enumerating and recording data from 66,438 individuals who were living in 14,453 households. These households were located in 10 kebelles, and only one of the 10 kebelles is urban. According to the Ethiopian government administrative structure, kebelles are the smallest administrative units with an average population of 5,000--6,000.

KA-HDSS collects data on vital events (birth, death, and migration in and out), pregnancy outcome, causes of death and marital status, which change on a continuous


third physician assigned a cause of death different from assigned causes by either of the first two physicians, the cause of death was classified as "indeterminate".

In this study, premature mortality from NCDs was defined as the relative proportion of NCD death in the 15--64 age group. The cut-off of age 65 years was used in accordance with the estimated life expectancy for Ethiopia \[[@pone.0188968.ref015]\]. A similar definition was also used by Streatfield et al. \[[@pone.0188968.ref058]\]. Moreover, in each household, one person was defined as the head of a given household. In the context of the study area, the husband is usually the head of the household. If the husband is dead, then the husband's wife, the mother, is usually the head of the household. The relationship of householdA systematic review of topical skin care in aged care facilities.
This systematic review aimed to evaluate the best available evidence regarding the effectiveness of topical skin care interventions for residents of aged care facilities. Natural changes to skin, as well as increased predisposition to pressure sores and incontinence, means residents of aged care facilities readily require topical skin care. A range of interventions exist that aim to maintain or improve the integrity of skin of older adults. Pubmed, Embase, Current Contents, CINAHL and The Cochrane Library databases were searched, as well as Health Technology Assessment websites up to April 2003. Systematic reviews and randomized or non-randomized controlled trials were evaluated for quality and data were independently extracted by two reviewers. The effectiveness of topical skin interventions was variable


easier to achieve.

Good health is something we now almost take for granted, but even in the West this is a recent expectation. Only 40 years ago it was common for schoolchil-dren to have uncorrected squints, infectious diseases such as scarlet fever or impetigo, discharging ears and the scars of mastoid operations. Their parents suf-fered from hernias, varicose veins, prolapses and piles. In 1850 the average life expectancy was 30 years, and even at the turn of the century it was only 46. Now in most Western countries it is around 70 for men and 75 for women.

Improvements in health care

The dramatic improvements in health over the last century have been largely the result of successful battles against infectious diseases. One hundred years ago the foremost causes of deathFor every 10 learners leaving private schools before matric, two do so to leave the country, data from Advtech shows.

A large number of South African families are emigrating , seeking opportunities abroad, leaving behind a country mired in unemployment, endless political wrangling, and corruption that has hampered economic growth.

According to American think tank, Pew Research, at least 900,000 people born in South Africa were currently living in other countries as of 2017.

And learner data as provided by private school companies along with house-selling data from FNB, shows a quite a dramatic increase in emigration-related motivations.

According to the lender, emigration-driven sales now account for 14.2% of all sales, a big jump from 10% in 4Q18.

Removals firm, Elliott Mobility, said it facilitated 2,500 moves abroad in 2018, and is expecting


an approximately 20% increase in 2019. Similarly, Stuttaford Van Lines pointed to a 15% increase in families emigrating in 2018.

Key among the reasons for people wanting to leave South Africa is a deterioration in sentiment, FNB said – exacerbated by things like the country’s power crisis, load shedding, and political instability.

Another most-cited reason for moving is family, the companies said, noting that emigrants are looking for a better quality of living, better healthcare, and better education.

Private schooling

The emigration trend is also clearly seen in the number of children who are being pulled out of private schools.

In its latest annual results, published in March 2019, Advtech noted an increase in the number of learners it has lost due to emigration and financial constraints.

According to the group, 979 learners leftits schools explicitly due to emigration (3.7% of the starting total), while a further 1,880 learners had to leave due to financial troubles (7%). Both of these numbers were up from the year before.

Excluding matriculants that left, the group lost about 16% of its learner total during the year – however this was offset by 7,000 new additions, and 3,155 learners joining as part of the group’s acquisitions.

At the start of 2019, Advtech had 30,538 learners.

Curro

Listed education group Curro, also saw 5,954 – around 18% – of its learner base at the end of 2018 leave the private school group (excluding matriculants), however the group did not give a breakdown of reasons why the learners left.

BusinessTech reached out to the group for the reasons behind the departure, but


traders, tourists, workers, and other folks in the financial district and plan to hold an assembly in Liberty Square later.

Background: On March 16, we attempted to peacefully re-occupy Liberty Square (formerly Zucotti Park), the small park just south of Wall Street that had become home to Occupy Wall Street exactly six months earlier. The NYPD had other plans. They attacked us once again. When many homeless Occupiers were left with nowhere to go, many went north to Union Square in midtown Manhattan. Union Square, which has been a central point in popular struggle in New York City for over a century, quickly became an important hub for the Occupy movement as well.The all-inclusive St. Patrick’s Day Parade in Sunnyside and Woodside kicked off with kids dancing and elected officials speaking this past Sunday afternoon at the corner of Skillman Avenue and 47th Street.

The Celtic Dream Irish Dancers, a group from P.S. 59 in the Bronx, performed traditional Irish dances. True to the parade's theme, the group is made up of Latino, Indian and African-American children who performed for the crowd.

Mayor Michael Bloomberg, made his way to his second St. Patrick’s Day parade in two days on Sunday. “By order of the mayor, everybody is a little bit Irish,” he said to the crowd.

Just as in the Rockaways the day before, Sunnyside resident Kristina Ippolito said she heard Bloomberg being booed when he took the stage.

Speaker and openly gay mayoral


I began contributing to the Fedora Project as a packager in late 2007 (I was sponsored in early 2008). I soon stopped being able to find packages that I knew how to work with and started diving into other parts of Fedora, notably the Art Team (now the [[Design|Design Team]]). From there I became more and more involved and, as they say, the rest is history. (You may now remove your cliché-blocking sunglasses.)

+

I began contributing to the Fedora Project as a packager in late 2007 (I was sponsored in early 2008). I soon stopped being able to find packages that I knew how to work with and started diving into other parts of Fedora, notably the Art Team (now the [[Design|Design Team]]). From there I became more andthe film.
While conventional cartridge designs of the latter species have been satisfactory, problems have been encountered in providing a reliable means for the projector operator to urge the film along its path of travel, with reliable closure of the hinged cover or separable portion, and in providing a means to prevent inadvertant film removable from the cartridge.
The present invention provides a filmstrip cartridge having an improved means to allow the projector operator to manually urge the film along its path of travel, and improved means to insure reliable cover closure, and an improved film engaging lock to prevent inadvertant film removable.


to control the recording apparatus is arranged on the plane in the vicinity of a carriage including lines parallel to the traveling direction of the carriage, and then, this board and the main control electric circuit board (a second electric circuit board) are connected by means of bundled wires.
2) A comparatively small-sized electric circuit board such as used for a printer or arranged for an apparatus whose size itself is small. For a recording apparatus of the type, a small electric board (that is, a first electric circuit board) to control the recording apparatus is arranged in a plane in the vicinity of a carriage including lines parallel to the traveling direction of the carriage.
The first electric circuit boards of the structures referred to in the preceding paragraphssandwiched by the boards from above and below; thus making it necessary for the harnesses to avoid standing in the way of the passage planes of the document and sheet. Also, the harnesses thus connected tend to serve as antenna to generate a considerable amount of emitting noises. Hence there is a fear that a radio or television receiver nearby is affected by such noises.
Also, in the structures 1) and 2) of the conventional recording apparatus described above, the following problems are encountered:
At first, in the structure described in the paragraph 1), the bundled wires are used to connect the first electric circuit board, which is arranged in the vicinity of the carriage, with the second electric board long way from the first board. Therefore, it is easier


the sheet feeding path is present between the first electric circuit board arranged in the vicinity of the carriage and the second electric circuit board.
In other words, the bundled wires which connect the first and second electric circuit boards should detour the sheet feeding path to a considerable extent. This unfavorably brings about a further mixture of noises. Also, the longer the bundled wires, the more the costs are increased. Also, on the subject of costs, the first electric circuit board arranged in the vicinity of the carriage is as if to function as a relaying board in this respect, which fundamentally constitutes an excessive part, a factor which results in an increase in costs.
Also, from the viewpoint of costs, even if a flexible cable is drawn aroundWorld Indigenous Games wraps up in Brazil amid controversy over land demarcation proposal

Indians from various ethnic groups run at the start of the men's swimming event during the World Indigenous Games in the Taguarussu River in Palmas, Brazil, Friday, Oct. 30, 2015. Organizers billed the nine-day-long event as a sort of indigenous Olympics. (AP Photo/Eraldo Peres)
(The Associated Press)

Competitors from Finland, front, and Brazil compete in the canoeing competition on the Taguarussu River at the World Indigenous Games in Palmas, Brazil, Friday, Oct. 30, 2015. Organizers billed the nine-day-long event as a sort of indigenous Olympics. (AP Photo/Eraldo Peres)
(The Associated Press)

Swimmers hold on to the side of firefighters' boat in the Taguarussu River after they pulled out of the women's swimming event during the World Indigenous Games in Palmas,


Brazil, Friday, Oct. 30, 2015. Organizers billed the nine-day-long event as a sort of indigenous Olympics. (AP Photo/Eraldo Peres)
(The Associated Press)

PALMAS, Brazil – The first edition of the World Indigenous Games, which brought nearly 2,000 delegates representing first nations from around the globe to this remote outpost in the heart of Brazil, is wrapping up Saturday after nine colorful days of traditional sports, dancing, trading and cultural exchange.

The games were billed as indigenous peoples' answer to the Olympics, although the focus shifted from sports to politics after a Brazilian congressional committee approved a proposal on demarcating tribal lands that native Brazilians say would be catastrophic to their traditional ways of life.

"We see this whole thing (the games) as a tool to pull the wool over our eyes," saidAntonio Apinaje, a leader of the Apinaje people, who declined to take part in the event despite living in the host state of Tocantins.

Sporadic protests erupted throughout the games, with President Dilma Rousseff drawing boos at the Oct. 21 opening ceremony and a crowd of several hundred demonstrators streaming into the arena one afternoon and forcing the suspension of the 100-meter dash competition.

The land proposal must clear several more legislative hurtles and also be signed by Rousseff in order to become law, and she has vowed she won't do that.

Many in the foreign delegations, hailing from such far-flung nations as the Philippines and Ethiopia, supported the Brazilian protesters, but others voiced disapproval for mixing politics and sports.

The cost of the games, too, irked some, with critics insisting the


sole Russian delegate drew stares for bravely defying the heat in a fur-and-rhinestone cat suit.

Everyone was constantly snapping photos of everyone else, and it wasn't unusual to see people from one indigenous group sporting the accoutrements of another.

The sporting events were restricted to activities that have traditionally formed part of native peoples' lives. In addition to archery, which caused controversy by being restricted to only men, the games included short- and middle-distance runs, tug-of-war, river swimming and canoeing, soccer, spear throwing and a log-carrying race.

Safety was a concern at Friday's swimming events, in which dozens of competitors threw themselves into the water at once, trying to swim across an arm of the Tocantins River and back. Goggles weren't allowed, and many participants didn't appear to be strong swimmers.At least a half-dozen competitors in the women's race ended up clinging to the side of a first aid boat and the winner had to be taken to a hospital.

Carol Guerreira, the winner of the women's 100-meter foot race, collapsed at the finish line. As she was bustled out of the arena on a stretcher, members of her Pataxo nation followed after, recording the scene on a tablet.

Organizers say the next edition of the World Indigenous Games will take place in Canada, though a date has yet to be set.


declined over that period,from 723,000 to 681,000, at a time when many state child-protection agencieswere experiencing tight budgets and heavy caseloads.

Virtually every state has laws outlining who is required toreport instances of suspected child maltreatment. Most states designate certainprofessions — notably law enforcement personnel, social workers, teachers andother school personnel, doctors and other health care workers, and child-careproviders. However, 18 states have laws requiring any person who suspects childabuse to make a report.

Sociologist David Finkelhor, director of the University of NewHampshire's Crimes Against Children Research Center, said some members of thepublic may make calls that are far too vague for an agency to pursue.It's sometimes easy to forget that games are made by people. Game developers, for the most part, aren't particularly visible, and aside from a few big names, most players don't associate specific designers with specific games. The aptly titled feature documentary Indie Game: The Movie is looking to change that by telling the stories of some of the most acclaimed indie games of recent years, and showing just what it takes to create them. The film just recently successfully completed a second round of funding through Kickstarter, and the creators hope to have it completed this fall.

The project was inspired mainly by a trip to the 2009 Game Developer's Conference. James Swirsky and Lisanne Pajot, the duo behind the film, were sent to GDC on an assignment for


New Media Manitoba to cover local game developers, and quickly became fascinated by the indie game development scene they encountered. Later on, the two created a series of documentaries for the Manitoba government, including one on Winnipeg's Alec Holowka, co-creator of Aquaria, and the positive response they received inspired them to get to work on IGTM early last year.

The film has remained true to the original vision, showcasing indie developers, but the structure has changed along the way. Originally planned to be a essay-style documentary, things eventually shifted towards a focus on narrative. Though this was what the team always wanted to do, they didn't originally think it was possible.

"We were quite uncertain if you can actually make a watchable film of someone making a game," Swirsky toldbe used to enhance what they already have, which includes a soundtrack by Jim Guthrie, the composer behind the iPad hit Superbrothers: Sword & Sworcery EP. The project has clearly struck a chord with the gaming community, as the two successful Kickstarter campaigns attest, but the hope is that it will also reach a much broader audience as well.

"At its core, it's a film about making stuff and putting it out there," Pajot told Ars. "It's about working hard on something and then seeing if people heard you and understood what you're trying to say.

"It's a film about creators."

Listing image by Image of Braid creator Jonathan Blow courtesy Indie Game: The Movie


was at turns defensive and defiant and bucket-list ticking, talking about her excitement at taking a plane to London to attend Margaret Thatcher’s funeral, her co-sponsorship of the 37th attempt to overturn Obamacare (“which passed in the House”), and her philosophically contradictory commitment to bring federal tax dollars to her district to build a regional airport and rebuild a bridge. Note to Bachmann: you didn’t build that.

Over her eight years in congress, Bachmann quickly achieved notoriety because of her cavalier disregard of facts (her staff told me she gets most of her information from WorldNetDaily) and her impulse to play mini-McCarthy (routinely accusing political opponents of being anti-American) and then turn around and play the victim card to raise millions of dollars online from a national conservative populistNairobi thought why not to break it up once and open up further networks.

Hence they are inviting the renowned British DJ/producer Rob Smith from Bristol and Dirty Paraffin’s Okmalumkoolkat from Johannesburg to Nairobi! Rob Smith is one of the veterans of the Drum & Bass/Jungle sound in Europe and has been of huge influence both as DJ and with his band Smith & Mighty. He is currently on the Grand Central Records independent record label, playing Breakbeat Hip Hop, Dub and Reggae-influenced music.

Okmalumkoolkat is one half of South Africa’s up and coming music duo, Dirty Paraffin. Their lyrically witty and clever primer stove music is making waves on the local and international music scene. Some call their music electronic-kwaito, other call it trap, but they prefer to not


Margaret Yvonne King, 48 years of Harmony Hall, St. Lawrence, Christ Church, was arrested and charged for the offences of possession, trafficking, possession with intent to supply, trafficking and importation of 29 pounds of cannabis on September 12, 2012.
King is employed as a Clerical Officer with the Customs Department. She went to the Port to clear two barrels which were inspected by Customs officials. The inspection revealed 39 packages of cannabis concealed in boxes of foodstuff and detergent. She was detained and the drugs seized.
King appeared today Thursday September 13, 2012 at the Oistins Magistrate Court and was not required to plea to the charges. She was granted bail in the sum of $100,000 with one surety to return to the District A Magistrate Court on September 17,MIDTOWN, Manhattan (WABC) -- Firefighters say there were no sprinklers in the apartment where a fire broke out in Trump Tower on Saturday night In fact, fire safety experts say that is pretty common. It's because Trump Tower was built before new laws went into place about 20 years ago - new laws that grandfathered pre-existing residential high rises from requiring sprinklers.It was what was known as the 'Macaulay Culkin Fire' that pushed through new regulations. The actor's family owned an apartment on West 60th Street where a fire broke out killing four people.Jerome Ross, a neighbor of one of those victims became the chief advocate for sprinkler requirements. Ross says real estate developers lobbied against him because it was too costly to implement. Ross says leading that


as alternative programming to any plans to storm the base on Sept. 20 despite officials' warnings.

With just over a week to go until the event, Roberts and the host town's website are both comparing Alienstock to the Fyre Festival, which was supposed to be held in April and May of 2017 in the Bahamas but became synonymous with "epic failure" and led to a fraud conviction. Roberts has pulled his name and support from the three-day gathering in Rachel, Nevada, but the owner of a motel in the town who had signed up as a partner plans to go ahead.

"There's no safety or security that can really be promised," Roberts told The Post on Tuesday, calling the event a potential "humanitarian disaster." "I didn't feel comfortable with invitingthe inn owner who they say was handling most of the logistics and became increasingly evasive about her preparations as the big date approached. Little A'Le'Inn proprietor Connie West accuses them of betrayal, saying she has lined up the necessary infrastructure and support staff, confirmed performers and sold 2,400 camp sites.

Two documents shown on a local news program as evidence of her efforts were apparently completed the day Roberts said he had pulled out. A $17,500 check for security services is dated Sept. 8; so is West's signature on an agreement for medical services.

West did not immediately respond to an inquiry from The Post.

Roberts, a 21-year-old from Bakersfield, California, propelled to minor fame by the Area 51 phenomenon, said he got cold feet after DiMaggio, a more experienced


that Guardian Medical enlisted DiMaggio's help because West had "lost control" of the event.

Scheller confirmed that he connected West and DiMaggio, another client of his, because he thought it could be a "great partnership" (DiMaggio had been denied a permit for his competing Peacestock 51 event in the area). Asked if he had doubts about West's preparations, Scheller declined to comment.

Roberts, who was expecting about 10,000 people to attend Alienstock before his break with West, said the falling-out does not mean Area 51 fans need to stay home. They can head to Las Vegas instead for an "Area 51 Celebration" at a downtown events center. Organizers for that alternative Sept. 19 gathering invited Roberts on Monday to join them.

It's not clear how many people could still show upPRESENTED
The basic question in this case is whether the State of Washington may prosecute Petitioner Martin Shaw Pang for four counts of murder in the first degree and one count of arson in the first degree when the Federal Supreme Court of Brazil, ruling on the State's petition for extradition, granted his extradition for prosecution in the State of Washington "for the crime of arson in the first degree, resulting in four deaths .... without the additional charge of four counts of first degree murder." To answer the basic question, we must answer these additional questions:
(1) Does Petitioner Pang have standing to object to violation by the State of Washington of the terms of the order on extradition issued by the Federal Supreme Court of Brazil?
(2) Did the


United States of Brazil explicitly or implicitly waive any objection it could have made to prosecution by the State of Washington of Petitioner Pang for murder in the first degree contrary to the specific terms of the extradition order issued by the Federal Supreme Court of Brazil?
(3) Does the "specialty doctrine" in international extradition law prohibit the State of Washington from prosecuting Petitioner Pang for crimes specifically excluded in the extradition order?
(4) Does the Extradition Treaty between the United States of America and the United States of Brazil prohibit the State of Washington from prosecuting Petitioner Pang for crimes not authorized in the extradition order?
(5) Is the State of Washington obligated to follow the decision of the Federal Supreme Court of Brazil which ruled that, as a conditionfor extraditing Petitioner Pang to the State, he can be prosecuted only "for the crime of arson in the first degree resulting in four deaths .... without the additional charge of four counts of first degree murder"?

STATEMENT OF FACTS
On January 5, 1995, four firefighters died while fighting a fire at the Mary Pang Products, Inc. warehouse at 811 Seventh Avenue South in Seattle, Washington.[1] Fire investigators later determined the fire had been deliberately set. Martin Shaw Pang became a suspect. A fugitive warrant was issued for his arrest.[2] On March 3, 1995 the King County Prosecuting Attorney by Information charged Petitioner Pang with four counts of murder in the first degree as follows:

COUNT I
I, Norm Maleng, Prosecuting Attorney for King County in the name and by the authority


of the State of Washington, do accuse MARTIN S. PANG of the crime of Murder in the First Degree, committed as follows:
That the defendant MARTIN S. PANG, together with another, in King County, Washington on or about January 5, 1995, while committing and attempting to commit the crime of Arson in the First Degree, and in the course of and in furtherance of said crime and in immediate flight therefrom, did cause the death of Lieutenant Walter Kilgore, a human being who was not a participant in the crime, and who died on or about January 5, 1995;
Contrary to RCW 9A.32.030(1)(c), and against the peace and dignity of the State of Washington.

COUNT II
And I, Norm Maleng, Prosecuting Attorney aforesaid further do accuse MARTIN S. PANG of the crimeof Murder in the First Degree, a crime of the same or *1296 similar character as another crime charged herein, and committed as follows:
That the defendant MARTIN S. PANG, together with another, in King County, Washington on or about January 5, 1995, while committing and attempting to commit the crime of Arson in the First Degree, and in the course of and in furtherance of said crime and in immediate flight therefrom, did cause the death of Lieutenant Gregory A. Shoemaker, a human being who was not a participant in the crime, and who died on or about January 5, 1995;
Contrary to RCW 9A.32.030(1)(c), and against the peace and dignity of the State of Washington.

COUNT III
And I, Norm Maleng, Prosecuting Attorney aforesaid further do accuse MARTIN S. PANG


of the crime of Murder in the First Degree, a crime of the same or similar character as another crime charged herein, and committed as follows:
That the defendant MARTIN S. PANG, together with another, in King County, Washington on or about January 5, 1995, while committing and attempting to commit the crime of Arson in the First Degree, and in the course of and in furtherance of said crime and in immediate flight therefrom, did cause the death of Firefighter James T. Brown, a human being who was not a participant in the crime, and who died on or about January 5, 1995;
Contrary to RCW 9A.32.030(1)(c), and against the peace and dignity of the State of Washington.

COUNT IV
And I, Norm Maleng, Prosecuting Attorney aforesaid further do accuse MARTINS. PANG of the crime of Murder in the First Degree, a crime of the same or similar character as another crime charged herein, and committed as follows:
That the defendant MARTIN S. PANG, together with another, in King County, Washington on or about January 5, 1995, while committing and attempting to commit the crime of Arson in the First Degree, and in the course of and in furtherance of said crime and in immediate flight therefrom, did cause the death of Firefighter Randall R. Terlicker, a human being who was not a participant in the crime, and who died on or about January 5, 1995;
Contrary to RCW 9A.32.030(1)(c), and against the peace and dignity of the State of Washington.
NORM MALENG
Prosecuting Attorney
By: [s] Marilyn B. Brenneman

MARILYN B. BRENNEMAN, WSBA


of a common scheme or plan, and which crimes were so closely connected in respect with time, place and occasion that it would be difficult to separate proof of *1297 one charge from proof of the other, committed as follows:
That the defendant MARTIN S. PANG in King County, Washington on or about January 5, 1995, did knowingly and maliciously cause a fire or explosion located at 811 Seventh Avenue South (the Mary Pang Warehouse), Seattle, which was manifestly dangerous to any human life, including firemen;
Contrary to RCW 9A.48.020(1)(a), and against the peace and dignity of the State of Washington.[[6]]
In July 1995 the United States of America requested the United States of Brazil to extradite Petitioner Pang to the State of Washington for trial on four counts of murderin the first degree and one count of arson in the first degree.[7] The Affidavit in Support of Request for Extradition states:
STATE OF WASHINGTON
COUNTY OF KING
I, MARILYN B. BRENNEMAN, being duly sworn, hereby depose and say:
1. I am a citizen of the United States and a resident of the State of Washington.
2. I have been engaged in the practice of law in the State of Washington since 1980.
3. Since May 1, 1980 I have been employed by the King County Prosecuting Attorney's Office as a Deputy Prosecuting Attorney. I was appointed Senior Deputy Prosecuting Attorney on January 2, 1985. My duties are to prosecute persons charged with criminal violations of the laws of the State of Washington. In the course of such prosecutions, I have become knowledgeable about


the state criminal statutes and case law, including those related to the crime of Murder in the First Degree and Arson in the First Degree. I am responsible for prosecuting the case of State of Washington vs. Martin Shaw Pang, King County Superior Court Cause Number XX-X-XXXXX-X. I am therefore familiar with the evidence and charges in this case and the contents of the relevant files of the King County Superior Court and the Office of the King County Prosecuting Attorney.
4. On March 3, 1995, an Information was filed in King County Superior Court charging the defendant with the crimes of Murder in the First Degree, Counts I, II, III, and IV, Class "A" Felonies, carrying the potential penalty of life imprisonment. On March 17, 1995, an Amendedthe allegations in the offenses are not time barred.
9. The Information charges that the defendant Martin Pang, together with another, in King County, Washington on or about January 5, 1995, while committing or attempting to commit the crime of Arson in the First Degree, and in the course of and in furtherance of said crime and in immediate flight therefrom, did cause the deaths of Lieutenant Walter Kilgore, Lieutenant Gregory A. Shoemaker, Firefighter James T. Brown, and Firefighter Randall R. Terlicker.
10. According to the Certification for Determination of Probable Cause filed in this case the Seattle Fire Department responded to a fire on January 5, 1995, at the Mary Pang Products warehouse in Seattle, King County, Washington. While attempting to extinguish the fire, several firefighters entered the first


floor of the engulfed warehouse. Without warning, the floor collapsed, dropping the firefighters to the sub-basement. Some of the firefighters were able to escape the buildingfour were not. Lieutenant Walter D. Kilgore, Lieutenant Gregory A. Shoemaker, Firefighter James T. Brown, and Firefighter Randall R. Terlicker died in the fire. The King County Medical Examiner has determined that Lieutenant Shoemaker died from smoke inhalation, and the other three died from suffocation.
On December 13, 1994, Special Agent Sheryl Bishop of the United States Bureau of Alcohol, Tobacco and Firearms ("ATF") was contacted by a citizen/witness who told her that Mary Pang's business, located in the warehouse, was in decline, and that the warehouse was to be "torched" sometime between December 16, 1994 and December 18, 1994.
On December 14, 1994, [Agent]Bishop met with another witness who stated that on several occasions in the month prior to December 14, 1994, the defendant told the witness that the warehouse was going to burn down and advised the witness to get personal items out of the warehouse. On other occasions during the month, the defendant told the witness how the warehouse would be burned down. His scenarios of how it would happen, which the witness diagrammed for [Agent] Bishop, almost exactly described how the fire actually occurred.
On another occasion, in the month prior to the fire, the defendant spoke with yet another witness and cryptically suggested the witness remove personal items from the warehouse. That witness also helped the defendant remove the defendant's personal items from the warehouse and transport them


to storage lockers that he had rented on November 11, 1994.
On January 21, 1995, a search warrant was served on the defendant's storage lockers. Inside the lockers, investigators found many personal items belonging to the defendant, including photographs, trophies and awards, family mementos, and financial records. The investigators, based on their training and experience, indicate that persons who intend to burn down *1300 their homes or businesses often remove items which cannot be replaced, such as photographs and personal momentos.
In December 1994, the defendant took a close friend and confidant to the warehouse. The defendant told the witness that the business (Mary Pang's Food Products, Inc.) had lost major clients and was not doing well. He complained that his parents were old and feeble, yet would not sellthe business. He went on to tell the witness that the warehouse would burn down in the next month, and that it would look like transients set the fire.
Yet another witness and the defendant have been friends for about six years. During the summer of 1994, the defendant told the witness that he would like to have the business burn, and that it would go up like a tinderbox. The defendant also said that he thought about doing it. The defendant also indicated to the witness that if the business burned down "it would kill my parents."
On numerous other occasions over the last six years, the defendant has told friends of his that the warehouse would be burned down. These friends have detailed the defendant's statements in their


statements given to investigators. Several witnesses have given detailed, independent statements that the defendant asked them to burn the Mary Pang warehouse, as recently as last year.
During conversations with witnesses immediately after the fire, the defendant told them how a person he described as a transient must have lighted the fire in the warehouse. The defendant's description of how the fire must have been lighted describes how the fire actually occurred and was made prior to the expert's determination that the fire had been deliberately set.
After the fire, the defendant told a witness his scenarios of how the fire must have been lighted. The witness then gave the information to homicide investigators. The fire investigators assigned to identify the cause of the fire had just begun sifting theremains of the business. They did not reach, or announce, their conclusions as to how the fire started until several days after the defendant described his scenarios of how the fire must have been lighted. The fire investigators were not told by homicide investigators about the scenarios that the defendant described to the witness.
The day after the fire a different witness had a conversation with the defendant in which the defendant asked the witness if a transient had started the fire at the warehouse would it be considered homicide? The defendant also attempted to throw suspicions on his ex-wife Rise Pang and her current husband, Joseph. The witness noticed throughout their conversation that the defendant appeared very nervous and worried about criminal charges.
The defendant later telephoned this witness


and said that he had been "framed" for the fire and was going to take a "long vacation". The defendant began crying, and told the witness that he (defendant) would never see his friends again. The defendant continued to claim that he had been set up by Joseph, and then said to the witness, in a very strained voice, "Nobody was supposed to get hurt, the building was just supposed to burn down."
The day after the fire, the ATF National Response Team, in conjunction with the Seattle Fire Department's Fire Investigation Unit, began investigating what caused the warehouse fire. The ATF National Response Team is composed of ATF agents who are Certified Fire Investigators. They have become Certified Fire Investigators by completing hundreds of hours of training insaw nothing to indicate a fire. A witness whose band rented space in the warehouse basement, entered the basement shortly before 7:00 p.m. and saw thick smoke. He removed some items from his space, then ran to a telephone booth to call 911. When fire units arrived shortly thereafter, the basement area was fully engulfed in flames. The investigators estimate, based on training and experience, that it took approximately twenty minutes from the time this fire was lit to the time the basement was fully engulfed. This indicates that the arsonist was probably familiar with the warehouse and the occupants' schedules.
The investigators have interviewed dozens of defendant's friends and business associates. Through these interviews the investigators have learned that the defendant has, for the most part, been supported


by his parents. Other than a time spent working for his parent's business, the defendant has been frequently unemployed. His parents paid for defendant's short-lived auto racing career, and were helping support him while he pursued an acting career. They gave him gifts of money on all major holidays, paid for his cars; paid for his house and made his child support payments. The defendant had access to, and used checks and credit cards belonging to the business.
Additionally, as described above, the once-successful business, in the last several years, had been failing. Several major accounts, such as Safeway Stores, had been lost. Suppliers indicate that checks written on company accounts, some for as little as $150 would bounce. When that happened the suppliers would have to contact thedefendant's parents, who would provide a personal check to cover the amounts owed. The defendant repeatedly expressed to friends and associates his frustration with both the business's decline as well as his parents' continual refusal to sell it or relinquish control to him. The defendant's parents have two children, the defendant and his sister Marlys. Marlys is estranged from the family and has not spoken with them for many years. Harry and Mary Pang, both in their 70's, have no life insurance, their policy having recently lapsed. However, the business, although failing, was well insured. Additionally, the defendant had expressed to various friends over years his plans to use the warehouse property, valued at over $400,000 for his own business.
According to statements made by the defendant to numerous


witnesses, he fled the state to avoid prosecution in this matter. One witness has given a statement that the defendant was researching countries without extradition treaties with the United States.
11. On March 3, 1995, the defendant was charged in the above King County Superior Court cause with the crimes of Murder in the First Degree, Counts I, II, III, and IV, and a warrant was issued for his arrest setting bail in the amount of $5,000,000.00. Martin Pang is identified as an Asian male; Date of Birth: November 12, 1955; Place of Birth: Hong Kong; Citizenship: United States citizen; Height: 6'0"; Weight 175 lbs [sic]; Black hair; Brown eyes; Scar below his throat.

*1302 12. On March 16, 1995, the defendant was arrested in Rio de Janeiro, Brazil, andis currently being held in that jurisdiction pending extradition proceedings. On March 17, 1995, an Amended Information was filed in the above cause adding an additional charge of Arson in the First Degree, Count V.
13. The defendant fled the United States to avoid prosecution and was arrested by Brazilian authorities in Rio De [sic] Janeiro on March 16, 1995. Two agents from the United States Federal Bureau of Investigation accompanied Brazilian authorities during the arrest. The defendant immediately initiated conversation with Special Agent Schoenlein enroute to the Brazilian police station. Agent Schoenlein answered questions the defendant had about extradition and the defendant then initiated conversation about the arson of Mary Pang's in Seattle. Agent Schoenlein advised the defendant that they could discuss those matters later at the police


station if the defendant chose to do so. Agent Schoenlein also advised the defendant of his Miranda rights. The defendant told Agent Schoenlein that he wanted to waive his Miranda rights to tell his "side of the story".
14. At the police station the defendant once again indicated his desire to speak with Agents Schoenlein and Burroughs and he signed a form that listed and waived his Miranda rights. After conversation in which the defendant attempted unsuccessfully to convince Agents Schoenlein and Burroughs he had nothing to do with the arson the defendant was advised by the agents to tell the truth. At that point the defendant admitted starting the fire on January 5, 1995 at the Mary Pang business. The defendant gave a four page statement describing hisWashington, U.S.A., as the perpetrator of four acts of murder in the first degree "by committing and attempting to commit the crime of arson in the first degree and in the course of and in furtherance of such crime, as well as in immediate flight therefrom." A charge was later added, accusing the person being sought of arson in the first degree as well, a class A felony.
3. Inasmuch as the acts are covered under two distinct offenses, the majority of the Court decided, for purposes of the extradition, that the case is one of arson in the first degree under the law of the requesting State, corresponding in the Brazilian Penal Code to the crime of arson defined in Article 250, combined with its Paragraph 1, Section


tried and judged according to the charge and addendum, under U.S. law. It did not stipulate any reservation.
7. Lastly, the decision of the Court did not include any restriction as to the possibility of life imprisonment.

DECISION
The case files having been reviewed and the case stated and discussed, the Justices of the Federal Supreme Court, meeting in plenary session and acting by majority vote in accordance with the minutes of the judgment and the transcript thereof, grants the extradition in part, on the grounds that the charges of arson in the first degree and murder in the first degree, as described in the extradition request, correspond in Brazil to the single crime that is defined in the main part of Article 250 and in Article 258 of the BrazilianThe letter, which mentioned "arson," but did not mention "murder," stated:
The Government of the United States respectfully requests that, pursuant to Article XXI of the Extradition Treaty between Brazil and the United States of America, done at Rio de Janeiro on January 13, 1961, or any other legal basis, the Government of the Federal Republic of Brazil provide written authorization, to the United States to prosecute MARTIN SHAW PANG in accordance with the revised code of Washington, Title 9A, Sections 48.020 and 32.030(1)(C), which provide for the punishment of an individual who commits arson, and in the course of that crime, causes the death of a person who was not a participant in the crime. As recognized by the Brazilian Supreme Court, these provisions of the Revised Code


of Washington criminalize the same conduct as described in Sections 250 and 258 of the Brazilian Penal Code.[[13]]
By letter of February 27, 1996 the Brazil Ministry of Foreign Affairs denied the request, indicating it did not have jurisdiction to interfere with the extradition order of the Federal Supreme Court of Brazil.[14] After reiterating a portion of the ruling of the Federal Supreme Court, the letter read:
The Ministry of Foreign Affairs points out to the Embassy of the United States of America that, pursuant to the provisions of the Federal Constitution on the separation of powers in the government, the Executive Branch does not have jurisdiction to interpret or establish limits regarding the scope of the decision handed down by the Judicial Branch, which has exclusive jurisdiction with respectto any interpretation of judicial acts.[[15]]
On February 28, 1996, Petitioner Martin Shaw Pang was surrendered by Brazil into custody of United States of America authorities. He was immediately returned to the United States and the State of Washington.[16]
The United States appealed to the Federal Supreme Court of Brazil seeking clarification of the extradition order.[17] The appeal states in its Summary:
By granting extradition only on the basis of the Washington arson statute, the Brazilian Supreme Court's decision in the case of Martin Shaw Pang would have the unfortunate effect of preventing United States authorities from prosecuting Mr. Pang for the consequences of the arson; namely, the resulting deaths. The arson statute in the State of Washington is equivalent only to Article 250 (simple arson) of the Brazil Penal code;


legal systems were to result in a severe injustice. The United States therefore respectfully requests that the Court clarify its ruling, so as to permit the prosecution of Pang for the two Washington State offensesarson and felony murderthat most closely correspond to Article 250 and 258 of the Brazilian Penal Code.[[18]]
On March 27, 1996, the Federal Supreme Court rejected the appeal, holding that its extradition order unambiguously excluded the charges of murder in the first degree from the grant of extradition.[19] The court stated:
SUMMARY. [1.] Extradition. Appeal for clarification.
2. U.S. citizen charged, in the State of Washington, U.S.A., with the crime of arson in the first degree and with four acts of murder in the first degree, the victims being firefighters who assisted in fighting the fire.
3. Byadopted in the decision now being appealed does not encompass the resulting deaths, only the threat against the life of any person or firefighter. [The decision held that] the crime of arson in the first degree, according to the Revised Code of Washington, is equivalent solely to the crime of arson in Article 250 of the Brazilian Penal Code and does not include the hypothesis found in Article 258 of said Code. The appeal for clarification further argues that the crime of arson in the first degree and the crime of murder in the first degree (termed "felony murder") are considered by the Revised Code of Washington as being independent criminal offenses and that the latter is equivalent to the crime described in Article 258 of the Brazilian


extradition with respect to the charges of the four crimes of murder in the first degree is demonstrated in the terms of the decision, which did not consider the facts, as described in the request, as characterizing independent crimes of arson in the first degree and murder in the first degree. The extradition was granted without any restrictions as to the possibility of life imprisonment; but only on the crime of first-degree arson with the results it produced (four deaths) and all the consequences thereof pursuant to United States law without, however, the added charge of four counts of murder in the first degree.

8. Nor is there any contradiction in the decision under appeal. The contradiction would have to have arisen unexpectedly among the parts of the judgmentrequired under the treaty.
We have not given up on either the diplomatic or legal avenues to correct this injustice.
Arraignment will be scheduled within two weeks from today.[[21]]
On April 5, 1996 the King County Prosecuting Attorney filed in the King County Superior Court the Affidavit of Timothy A. Bradshaw in Support of the State's Response to Motion to Dismiss which states:
STATE OF WASHINGTON COUNTY OF KING
I, TIMOTHY A. BRADSHAW, Senior Deputy Prosecuting Attorney for King County, hereby declares and says:
1. I am familiar with the facts in this matter. As one of the two Senior Prosecutors assigned to this case, I have been in routine contact with the United States attorneys assigned to this extradition matter of Martin Shaw Pang. I have also been advised about the actions of


the United States government pertinent to the extradition of the defendant.
2. As a member of the United States delegation to Brazil, I obtained direct knowledge of Brazilian Jurisprudence and extradition procedures applicable to the Pang case. The delegation was comprised of United States Ambassador [Melvyn] Levitski [sic:] [Levitsky], U.S. Justice Department Attorneys Gregory Stevens and Thomas Snow, U.S. State Department Legal Advisor Paulo Di Rosa, and myself.
3. On January 23, 1996, the delegation met personally with the Brazilian Minister of Justice, Nelson Jobim. In that meeting, the Minister stated his position, as a representative of the Executive, on the Pang extradition, and requested (and received) my personal assurance that [Mr.] Pang would be taken from his country by March 01, 1996.

4. Justice Minister Jobim stated that Brazil hasto the United States, a local TV station caught up with Minister Jobim at the University of Texas Law Center. [Justice Minister] Jobim stated for the news camera that "[Mr.] Pang's extradition was granted, he has been returned, and he is now subject to American Law."

8. On March 27, 1996, The Brazilian Supreme court ruled on the Embargo de Declaracao. The Court voted unanimously to deny the request for clarification. The American Embassy of Brazil has informed us of the following specifics. The Court ruled that its original decision required no clarification. Several Justices noted that the decision was procedurally dictated; that is, the Court could not now address the merits of the case, just the technical issue of clarification. Several Justices also expressed regret if the Court's


court by the King County Prosecuting Attorney.[23] However, on November *1311 12, 1996, the State withdrew the affidavit from the Court's consideration, stating that because the "United States, [sic] has been provided written authorization, a signed document from the Minister of Justice from Brazil, it's no longer necessary to attempt to prove a non-objection or acquiescence from verbal statements.... [W]e'd be happy to withdraw that affidavit from the Court's consideration on the motion today."[24] Even though this affidavit was previously withdrawn, it was submitted to the Supreme Court as a supporting document on January 8, 1997.[25]
The Honorable William J. Clinton, President of the United States of America, on May 21, 1996 wrote to the Honorable Fernando Henrique Cardoso, President of the United States of Brazil, seeking his "personalpurpose. Should you be unable to provide us with such a statement, as an alternative please consider providing a more limited written statement simply saying that your government would not object to [Mr.] Pang's prosecution on all charges.[28]
On September 26, 1996, Minister of State for Justice Nelson A. Jobim wrote to United States Attorney General Janet Reno stating:[[29]]
In response to the inquiry by the Department of Justice, I am writing to Your Excellency to discuss the extradition proceeding of U.S. citizen Martin Shaw Pang.
In Brazil, as in the United States of America, the concept of the separation of the three branches of the national government derives from the text of the Federal Constitution itself. Under this system, the Judicial Branch alone is responsible for interpreting any legal instrument


regarding possible limits on the requesting State's right to punish vis-à-vis the extradited defendant, it should be emphasized, on the basis of fundamental precepts of public international law, that legally binding international acts are the only legal instrument capable of binding two or more sovereign States together. Thus, provided that the terms of the Treaty of Extradition between Brazil and the United States of America of January 13, 1961, are respected, it will be incumbent upon the justice system of the United States of America to establish a suitable punishment for the crime of arson in the first degree, resulting in four deaths and the consequences thereof, under U.S. law. It goes without saying that the precise interpretation of this language, used by the Brazilian court in itsdecision, and the determination of how it might best be adapted to U.S. law, are for the justice system of your country to decide.

Very truly yours,
[Signature]
Nelson A. Jobim
Minister of State for Justice
On October 25, 1996, the King County Prosecuting Attorney filed a second amended information. Most significantly, it changed the wording of the charge of arson in the first degree in Count V of the amended information to include reference to subsection (d) of the arson statute and to add new assertions. It states:
I, Norm Maleng, Prosecuting Attorney for King County in the name and by the authority of the State of Washington, do accuse MARTIN S. PANG of the crime of Arson in the First Degree, committed as follows:
That the defendant MARTIN S. PANG in King County,


Washington on or about January 5, 1995, did knowingly and maliciously and with intent to collect insurance proceeds cause a fire or explosion on property valued at ten thousand dollars located at 811 Seventy [sic] Avenue South, Seattle (the Mary Pang Warehouse), which was manifestly dangerous to human life, including firemen;

Contrary to RCW 9A.48.020(1)(a) and (d), and against the peace and dignity of the State of Washington.[[30]]
Other changes in the second amended information included the order of the counts. Count I was assigned to the charge of arson in the first degree and Counts II-V were assigned to the charges of murder in the first degree. There was also deletion of the phrase "together with another" in the charges of murder in the first degree, thus making PetitionerPang solely responsible.
By letter of October 29, 1996, President Cardoso responded to President Clinton's letter of May 21, 1996, stating that in Brazil the executive branch could not alter the scope of the extradition decision of the Federal Supreme Court.[31] The letter stated:
Despite the personal interest I took in the issue, the consideration of the alternatives at hand clearly indicated that room for action by the Executive branch is very limited, since a decision has already been taken by the Supreme Court.
I have referred the case back to Minister of Justice Nelson Jobim, who recently wrote to Attorney General Janet Reno on the subject. I understand his letter provides the American government with a broad and clear picture of the Brazilian legal position on the issue.[[32]]
On November 12,


1996, the Honorable Larry A. Jordan, King County Superior Court, denied a motion by Petitioner Martin *1313 Shaw Pang to dismiss or sever the murder charges from the arson charge which Petitioner urged was required by the limitation in the extradition order issued by the Federal Supreme Court of Brazil and denial of the appeal by the United States of America for clarification. In rendering his decision, Judge Jordan stated "it appears to this Court reasonably clear that Brazil did not extradite for felony murder."[33] However, he held that because of Brazil's implicit waiver, Petitioner Pang lacked standing to assert a violation of Article XXI of the Treaty in his effort to limit his prosecution to arson in the first degree. In denying Petitioner Pang's motion, Judge JordanAdditionally, the Minister told me, `If I were you, I would prosecute on homicidethe justice system of the United States should decide.'"
On November 12, 1996, adopting the theory of the Prosecutor's Office, Judge Larry A. Jordan interpreted the fourth paragraph of the letter that Your Excellency forwarded to the Attorney-General as implicit permission, from the Brazilian Executive Branch to the American justice system, to transgress Article 21 of the Treaty of Extradition and Additional Protocol between Brazil and the U.S.A.ratified by Brazil on August 25, 1964thus permitting a violation of the extradition order issued by the Federal Supreme Court.[[38]]
By letter of February 26, 1997, Brazil Minister of Justice Jobim responded to the September 26, 1996 letter from Dr. Spitzcovsky and Dr. Dias (da Silva) stating:
With reference to the


affirmatively declined in no uncertain terms the request of President Clinton that Brazil waive its right to object to prosecution *1318 of Petitioner Pang by the State of Washington for murder in the first degree following the extradition order.
The State's insistence that Justice Minister Jobim waived objection on behalf of Brazil to the State of Washington charging Petitioner Pang with murder distorts the facts established in this case. The letter from Minister Jobim to Attorney General Reno merely reiterated that Petitioner Pang was extradited to stand trial "for the crime of arson in the first degree, resulting in four deaths and the consequences thereof under U.S. law."[50] This is only a portion of the words used in the extradition order issued by the Federal Supreme Court of Brazil.offense for *1319 which the person would not have been extradited."[58]
"`As a matter of international comity, "[t]he doctrine of `specialty' prohibits the requesting nation from prosecuting the extradited individual for any offense other than that for which the surrendering state agreed to extradite."'"[59] "To guarantee limited prosecution by nations seeking extradition of persons from the United States, the United States has guaranteed, pursuant to the treaty, that it will honor limitations placed on prosecution in the United States."[60]
In United States v. Rauscher,[61] the United States Supreme Court addressed the question whether the extradition treaty between England and the United States prohibited prosecution of the defendant for a crime other than that for which he was extradited. This was the first case in which the Supreme Court recognized the


specialty doctrine. In that case an American merchant ship officer had been extradited from Great Britain, under an extradition treaty, to be charged with murder of a crew member. He was subsequently convicted of assault and inflicting cruel and unusual punishment, neither of which were listed as extraditable offenses in the treaty. The Court held the defendant could be tried only for the offense "with which he is charged in the extradition proceedings, and for which he was delivered up."[62]
The Court in Rauscher was guided by principles of comity which prevailed in the absence of treaties, under which a receiving country would not prosecute a fugitive for any offense other than those for which the fugitive had been surrendered by the asylum country.[63] The Court rejected the argumentof jurists. In part, the court considered the Revised Statutes §§ 5272, 5275, which dealt with this country's roles as both requested state and requesting state in extradition proceedings. Section 5275 is now codified in 18 U.S.C. § 3192 and differs only in that the words "crimes or offences" have been replaced with the word "offenses." It provides as follows:
Whenever any person is delivered by any foreign government to an agent of the United States, for the purpose of being brought within the United States and tried for any offense of which he is duly accused, the President shall have power to take all necessary measures for the transportation and safekeeping of accused person, and for his security against lawless violence, until the final conclusion of his trial


extradition petition (the content of which is within the sole discretion of the requesting state). The defendant has the right to "be tried only for the offence with which he is charged in the extradition proceedings and for which he was delivered up."[70] "It is unreasonable that the country of the asylum should be expected to deliver up such a person to be dealt with by the demanding government without any limitation, implied or otherwise, upon its prosecution of the party."[71] The doctrine of specialty was not explicitly stated in the treaty between the United States and Great Britain. The court in Rauscher interpreted in treaty with consideration of the specialty doctrine which had previously been recognized in international law.[72]
The Court examined the treaty and the history ofrelations between the United States and Great Britain to determine whether the parties, in the absence of express incorporation, nevertheless intended the doctrine of specialty to be part of the treaty.[73] Under Rauscher the specialty doctrine may be implied where a treaty is silent on the issue and there is no reason to assume the signatory nations did not abide by the principles of comity.
Petitioner Pang argues that, because the extradition order specifically excluded the charges of murder in the first degree requested by the State of Washington, under the specialty doctrine the State may not prosecute him on these charges. He argues that under Rauscher the specialty doctrine is implied in every treaty.[74]
The State argues that any limitations on post-extradition prosecution are defined only by the terms


Treaty may not be tried or punished by the requesting State for any crime or offense committed prior to the request for his extradition, other than that which gave rise to the request, nor may he be re-extradited by the requesting State to a third country which claims him, unless the surrendering State also agrees or unless the person extradited, having been set at liberty within the requesting State, remains voluntarily in the requesting State for more than 30 days from the date on which he was released. Upon such release, he shall be informed of the consequences to which his stay in the territory of the requesting State would subject him.
This provision, read in conjunction with Articles I and II, requires that the crime must be enumeratedof murder in the first degree."[81] The Court

granted extradition without any restriction as to the possibility of life imprisonment; but only on the crime of first degree arson with the results it produced (four deaths) and all the consequences thereof pursuant to United States law without however, the added charge of four counts of murder in the first-degree.[[82]]
After considering the appeal for clarification from the United States, the Federal Supreme Court of Brazil unanimously denied it, stating,
The absence of any doubt or obscurity as regards the denial of the extradition *1322 with respect to the charges of the four crimes of murder in the first degree is demonstrated in the terms of the decision, which did not consider the facts, as described in the request, as characterizing independent


crimes of arson in the first degree and murder in the first degree.[[83]]
King County Superior Court Judge Jordan in his oral decision stated, "it appears to this Court reasonably clear that Brazil did not extradite for felony murder."[84] He was absolutely correct in that conclusion. But he was in error in his conclusion that Brazil had "implicitly waived" any objection to the State of Washington ignoring the order on extradition. Under the treaty and the doctrine of specialty, King County may not prosecute Petitioner Pang for any crime but arson in the first degree as specified in the extradition ruling by the Federal Supreme Court of Brazil. "The doctrine of specialty is satisfied if the extraditing country honors the limitations placed on the prosecution by the surrendering state."[85]

EXTRADITIONprosecuted only "for the crime of arson in the first degree resulting in four deaths .... without the additional charge of four counts of first degree murder"?
Under all the established facts in this case and the application of international law, treaty law, United States law, Washington law, and common logic, we must give good faith recognition to the lawful determination of the Federal Supreme Court of Brazil, the highest court of that sovereign democracy, that Petitioner Martin Shaw Pang was extradited only for prosecution in the State of Washington for the crime of arson in the first degree, resulting in four deaths, but not for prosecution for the four charges of murder in the first degree. We therefore answer the question in the affirmative.

SUMMARY AND CONCLUSIONS
(1) Petitioner Pang


has standing to object to violation by the State of Washington of the terms of the order on extradition issued by the Federal Supreme Court of Brazil. The only firm decisions on the issue of standing agree that an extraditee may raise any objection the surrendering State could make, as long as that country has not waived its right to object. From the entire record in this case, we cannot conclude that the United States of Brazil has said, done or implied by words, action or inaction, anything which would require this Court to deny Petitioner Pang the right to make post-extradition objections to his prosecution by the State of Washington in violation of the conditions of his extradition from Brazil.
(2) The United States of Brazil did notcrimes specifically excluded in the extradition order. In this case the doctrine is incorporated into the Treaty through Article XXI. The doctrine of specialty is satisfied if the extraditing country honors the limitations placed on the prosecution by the surrendering state.
(4) The Extradition Treaty between the United States of America and the United States of Brazil prohibits the State of Washington from prosecuting Petitioner Pang for crimes not authorized in the extradition order. Good faith must be maintained in interpreting the terms and conditions of an extradition proceeding between signatory nations to a treaty. We conclude that under the Treaty, Brazil, as the requested state, has sole authority to determine whether a particular offense is extraditable.
(5) The State of Washington is obligated to follow the decision of the


Federal Supreme Court of Brazil which ruled that, as a condition for extraditing Petitioner Pang to the State of Washington, he can be prosecuted only "for the crime of arson in the first degree resulting in four deaths .... without the additional charge of four counts of first degree murder."
We reverse the King County Superior Court which denied the motion of Petitioner Martin Shaw Pang to dismiss or sever four counts of murder in the first degree from one count of arson in the first degree. The trial court erroneously concluded that the record in this case establishes Brazil Minister of Justice Nelson A. Jobim implicitly waived the provisions of Article XXI of the Treaty, thus depriving Petitioner Pang of standing to assert a violation of Article XXIand allowing the State of Washington to proceed to trial on all counts, including the four counts of murder in the first degree. The State may proceed to trial only on Count I of the second *1326 amended information which charges Petitioner Martin Shaw Pang with the crime of arson in the first degree alleged to have been committed in King County, Washington on or about January 5, 1995.
GUY, JOHNSON, SMITH, MADSEN and SANDERS, JJ., concur.
DURHAM, Chief Justice (dissenting).
Four Seattle firefighters died while fighting a fire at Pang's parents' warehouse. After fire investigators determined that the fire had been deliberately set, a fugitive warrant was issued for Martin Pang, who fled to Brazil. Pang was charged with first degree arson and four counts of first degree felony murder,


and the United States requested that Brazil extradite him on these charges. However, the Brazilian Supreme Court determined that Pang's alleged act would be classified in Brazil as the single crime of aggravated arson. Therefore, Brazil granted extradition on the arson count alone.
The question before us is whether the State may prosecute Pang for the felony murder given that Brazil extradited him only for arson. The plain language of the United States/Brazil extradition treaty expressly permits prosecution for offenses included in the extradition request. Yet, the majority erroneously concludes that a doctrine of international law called specialty prohibits the State from prosecuting Pang for anything other than the arson count for which he was extradited. The majority's conclusion is based on a misunderstanding of the specialty doctrine andis inconsistent with the vast weight of authority, which holds that the scope of any specialty limitations on prosecution is determined solely by the language of the applicable treaty.
Unless Pang is prosecuted for murder, he cannot be punished for the firefighters' deaths because the codification of the "real facts doctrine" in our state sentencing laws excludes from sentencing consideration facts that establish the elements of a more serious crime. Thus, the majority's decision not only violates the State's unambiguous rights under the treaty, but also fails even to effectuate Brazil's expectation that Pang will be held accountable for the deaths he may have caused.

ANALYSIS
THE SPECIALTY DOCTRINE
Absent a treaty, the obligation to surrender a fugitive has never been recognized as a principle of international law.[1] In order to ensure


the specialty doctrine, the asylum country dictates the scope of permissible prosecution by its grant of extradition. It was this version of the rule that was applied in the Supreme Court's first specialty doctrine case, Rauscher, and the rule that the majority erroneously suggests is implied in every extradition treaty to which the United States is a party.
Although some nations adhere strictly to this version of specialty in all extradition matters, "[i]n other states, including the United States, the prosecution may go forward *1327 if it is based on the same facts as those set forth in the request for extradition."[3] Nations adopting this variation of the specialty doctrine retain control over the scope of prosecution rather than allowing the asylum country to dictate its scope. It isthis version of the specialty doctrine that is expressly incorporated into the United States/Brazil extradition treaty: "A person extradited by virtue of the present Treaty may not be tried or punished by the requesting State for any crime or offense committed prior to the request for his extradition, other than that which gave rise to the request."[4] But both versions of the rule accomplish the purpose of the specialty doctrine: protection against indiscriminate prosecution of separate crimes unrelated to the extradition request.
In suggesting that the specialty doctrine must be implied into the United States/Brazil extradition treaty, the majority assumes, without support, that the specialty doctrine is solely defined as limiting prosecution to offenses for which extradition was granted. But, as the First Circuit Court of Appeals pointed out:
Specialty


THE FACE OF EXPRESS LIMITATIONS INCLUDED IN THE TREATY
The majority relies on United States v. Rauscher, 119 U.S. 407, 7 S.Ct. 234, 30 L.Ed. 425 (1886) for the proposition that an implied term of every extradition treaty is that an extradited fugitive may be prosecuted only for crimes for which he was surrendered. Yet, the majority, by its own analysis, demonstrates that Rauscher is not applicable in the present case.
In Rauscher, an American merchant ship officer who was accused of murdering a crewmember fled to Great Britain. The United States, pursuant to its first extradition treaty, requested the fugitive's extradition for murder; the request was subsequently granted. The defendant, however, was subsequently tried and convicted of inflicting cruel and unusual punishment instead of murder. The Supreme Court vacatedthe sentence and held that the defendant could be tried only for an offense "with which he is charged in the extradition proceedings and for which he was delivered up...."[6] Moreover, the Court rejected the State's argument that the treaty's silence on the issue indicated that the United States and Great Britain intended that there be no limitations on prosecution. Instead, the Court implied such a limitation into the treaty.
*1328 At first blush, it might appear as though the Court had announced a rule that such a limitation is implied in all extradition treaties as a matter of course. Yet, the Court strictly limited its holding as an interpretation of the extradition treaty with Great Britain:
"The right of one government to demand and receive from another the custody


of an offender who has sought asylum upon its soil, depends upon the existence of treaty stipulations between them, and in all cases is derived from, and is measured and restricted by, the provisions, express or implied, of the treaty."[[7]]
Consistent with the rule that the treaty defines the scope of the specialty doctrine, the Court initially looked to the text of the treaty itself.[8] It was only after determining that the treaty was silent on this issue that the Court looked beyond the express treaty terms to determine whether the parties intended to limit the scope of post-extradition prosecution. Thus, it was only in the absence of express specialty provisions that the Court turned to the comity principles in general, the specific history between the United States andGreat Britain on this issue in particular, and the statutory references to limitations on prosecution, in order to resolve this question.
The majority correctly identifies a treaty's silence on the issue as an essential prerequisite for the Court to inquire beyond the language of the treaty itself. "The Court examined the treaty and the history of relations between the United States and Great Britain to determine whether the parties, in the absence of express incorporation, nevertheless intended the doctrine of specialty to be part of the treaty."[9] Crucial to the Court's decision was the fact that the very issue had been the subject of much dispute between the nations, with Great Britain making very clear that it expected that the scope of prosecution would be limited by the grant


of the same facts for which his extradition was granted. However, the court clarified that that holding was based on the more expansive version of the specialty doctrine expressly incorporated into the treaty at issue in that case.[34]
Thus, an extraditee may challenge his prosecution for crimes other than those for which extradition was granted when the express specialty provisions limit prosecution to those offenses. When the extradition treaty expressly provides for lesser protection, however, the extraditee may assert only the limits of any rights as expressed in the treaty. Since the United States requested that Pang be extradited on four felony murder counts as well as arson, and the extradition treaty with Brazil limits the offenses that may be prosecuted only to those "which gave rise to therequest," there is simply no violation of the treaty terms.
A GOOD FAITH READING OF THE UNITED STATES/BRAZIL EXTRADITION TREATY IS CONSISTENT WITH THE PLAIN MEANING OF THE EXPRESS SPECIALTY TERMS
I agree with the majority that we must interpret treaties in good faith.[35] However, the Johnson Court's admonition that we construe extradition treaties in good faith is fully met by giving effect to the plain language of the United States/Brazil extradition treaty.
In Johnson, the defendant was indicted on federal charges of fraud and conspiracy to commit fraud; yet, the United States proceeded upon only the conspiracy charge. After the defendant was convicted, he fled to Canada and the United States requested his extradition. Canada refused to extradite, having determined that conspiracy to commit fraud was not an extraditable offense.


The United States recharged the substantive fraud count, requested extradition for that offense, and Canada extradited the fugitive. The United States then imprisoned the defendant for the conspiracy conviction. In affirming a lower court order discharging the defendant, the Supreme Court emphasized that an extradition treaty:
should be construed in accordance with the highest good faith, and that it should not be sought by doubtful construction of some of its provisions to obtain the extradition of a person for one offense and then punish him for another and different offense.[[36]]
The Court was rightly concerned with the government's blatant manipulation of the extradition process to obtain extradition for one offense as a ruse for obtaining jurisdiction for another that "is entirely different from the one for which he was extradited."[37]a sentence that has not or may never be imposed is dicta of the first order and should not be a part of either the majority or dissenting opinion.

OPINION APPENDIX A

FEDERAL SUPREME COURT
11/30/95
FULL SESSION
EXTRADITION No. 00006541/120
ORIGIN: UNITED STATES OF AMERICA
ASSIGNED: JUSTICE NÉRI DA SILVEIRA
REQUESTED BY: THE GOVERNMENT OF THE UNITED STATES OF AMERICA
PERSON SOUGHT: MARTIN SHAW PANG
REPORT
JUSTICE NÉRI DA SILVEIRA (ASSIGNED): The Embassy of the United States of America contacted the Brazilian Government through the Ministry of Foreign Affairs, and citing Diplomatic Note No. 083, of March 7, 1995, as well as The Brazil-United States Extradition Treaty of January 13, 1961 Article VIII and Additional Protocol of June 18, 1962, requested the provisional arrest, for extradition purposes, of MARTIN SHAW PANG, a.k.a. MARK WONG, a.k.a. SUEN HING WAH,


in the fire.
On December 13, 1994 an agent of the Bureau of Alcohol Tobacco and Firearms (ATF) was contacted by a witness who said that the "Mary Pang" warehouse was going to be "burned". The witness told the agent that Pang was advised to remove his personal belongings from the warehouse.
On another occasion, Pang told the witness, in detail, how the fire would occur and it really happened that way. On another occasion, Pang also removed his personal belongings from the building.
In December, Pang took a close friend to the warehouse and told him that the food company was not doing well. He said that the warehouse would burn down in January and that it would look like transients set the fire. Pang told a number of otherpeople that the warehouse would burn down.
Translator's Note: This is an obvious typing error in the original. It should read: 1995.
"Judge" Bill Stream should instead be identified as "Deputy Clerk Bill Stream."
After the fire Pang told another witness that it looked like some transient had set the warehouse on fire and described how it had happened. Pang described how the fire happened even before the information had been announced by the investigators. Inevitably, Pang's statements to his friends came very close to a confession. Arson Investigators announced that the fire had been intentionally set, causing the death of four fire-fighters.
Murder is described in Article II Paragraph I of the Treaty of Extradition Between the United States of America and the United States of Brazil. Seizure of Assets is


Maleng, Prosecuting Attorney for King County, in the name and by the authority of the State of Washington, do accuse MARTIN S. PANG of the crime of Murder in the First Degree, committed as follows:
That the Defendant MARTIN S. PANG, together with another, in King County, Washington, on or about January 5, 1995, while committing and attempting to commit the crime of Arson in the First Degree, and in the course of and in the furtherance of said crime and in immediate flight therefrom, did cause the death of Lieutenant Walter Kilgore, a human being who was not a participant in the crime, and who died on or about January 5, 1995; *1337 Contrary to RCW 9A.32.030 (1)(c), and against the peace and dignity of the State ofWashington.
And I, Norm Maleng, Prosecuting Attorney aforesaid further do accuse MARTIN S. PANG of the crime of Murder in the First Degree, a crime of the same or similar character as another crime charged herein, and committed as follows:
That the defendant MARTIN S. PANG, together with another, in King County, Washington, on or about January 5, 1995, while committing and attempting to commit the crime of Arson in the First Degree, and in the course of and in the furtherance of said crime and in immediate flight therefrom, did cause the death of Lieutenant Gregory A. Shoemaker, a human being who was not a participant in the crime, and who died on or about January 5, 1995;
Contrary to RCW 9A.32.030 (l)(c), and against the peace and dignity of


the State of Washington.
And I, Norm Maleng, Prosecuting Attorney aforesaid further do accuse MARTIN S. PANG of the crime of Murder in the First Degree, a crime of the same or similar character as another crime charged herein, and committed as follows:
That the Defendant MARTIN S. PANG, together with another, in King County, Washington, on or about January 5, 1995, while committing and attempting to commit the crime of Arson in the First Degree, and in the course of and in the furtherance of said crime and in immediate flight therefrom, did cause the death of Fire-fighter James T. Brown, a human being who was not a participant in the crime, and who died on or about January 5, 1995;
Contrary to RCW 9A.32.030 (1)(c), and against the peaceand dignity of the State of Washington.
And I, Norm Maleng, Prosecuting Attorney aforesaid further do accuse MARTIN S. PANG of the crime of Murder in the First Degree, a crime of the same or similar character as another crime charged herein, and committed as follows:
That the defendant MARTIN S. PANG, together with another, in King County, Washington, on or about January 5, 1995, while committing and attempting to commit the crime of Arson in the First Degree, and in the course of and in the furtherance of said crime and in immediate flight therefrom, did cause the death of Fire-fighter Randall R. Terlicker, a human being who was not a participant in the crime, and who died on or about January 5, 1995;
Contrary to RCW 9A.32.030 (1)(c), and


Criminal Law Code, in Arts. 121, as to Murder, "caput" [first sentence]Intentional Homicide, and 250, "caput" Intentional Fire-Setting.
In a preliminary manner, after the fire and death of the fire-fighters, who intervened while carrying out their duties, occurred, at the beginning of January of the year mentioned, there is no [reason] here to talk about extinction of punishment, through the imposition of punitive action, whether according to State of Washington legislation, or Brazilian criminal law. The State of Washington sentencing guidelines, according to the Revised Code of Washington are found in fls. 356-358. References concerning the Brazilian Criminal Law Code, are found in Article 109, I, as to the homicide found in Article 121, "caput", and in Article 109, III, for Intentional Fire-Setting (Article 250).
Arson in the First Degreeagreed with his vote. I thought it would be prudent to ponder on the quaestio juris, regarding the restriction issue, as to the life sentence allowed by the criminal laws of the Requesting Member-State.
To refresh the memory of the [members] of the Plenary as to the facts, I indulge in reading Diplomatic Note No. 83, contained in fls. 5-6 of PPE 217, enclosed:
The facts of this case indicate that on January 5th, 1995, a little after 19:03, the Seattle Fire Department responded to a fire at the Mary Pang Food Warehouse, Inc. While fighting the fire several firemen got to the first floor in the flooded warehouse. Without any warning, whatsoever, the floor gave in, tumbling the firemen to the basement. Four firemen died in the fire.
On December