Opposition Brief — Brett A. Bogle, Petitioner v. Florida

DOCKET NO. 20-5065

IN THE SUPREME COURT OF THE UNITED STATES

BRETT A. BOGLE,

Petitioner,

vs.

STATE OF FLORIDA,

Respondent.

BRIEF IN OPPOSITION TO PETITION FOR WRIT OF

CERTIORARI TO THE FLORIDA SUPREME COURT

ASHLEY MOODY

ATTORNEY GENERAL

STATE OF FLORIDA

CAROLYN M. SNURKOWSKI*

Associate Deputy Attorney General

Florida Bar No. 158541

*Counsel of Record

TIMOTHY A. FREELAND

Senior Assistant Attorney General

Florida Bar No. 0539181

Office of the Attorney General

Capital Litigation

PL-01, The Capitol

Tallahassee, Florida 32399

Telephone: 850-414-3300

carolyn. snurkowski@myfloridalegal .com

timothy . freeland@myfloridalegal.com

capapp@myfloridalegal.com

COUNSEL FOR RESPONDENT

In 1991 deceased victim Margaret Torres, her skull crushed

with a piece of cement, was found behind a Hillsborough County

bar. DNA analysis of semen found inside her body matched Brett

Bogle, a man who had been dating the victim’s sister, Katie

Alfonso, and who was not known to be on good terms with the

victim. Bogle’s frequent arguments with Torres had grown more

violent as his relationship with Alfonso deteriorated. Two weeks

after Alfonso terminated their relationship, Bogle encountered

Torres inside Club 41, and some hours later her body was

discovered behind the bar. Part of the evidence linking Bogle to

the homicide included testimony from FBI Analyst Michael Malone,

who concluded that a pubic hair found on Bogle’s clothing could

have come from the victim. Post-trial mitochondrial DNA testing

confirmed Malone’s testimony.

Bogle has long been critical of the State’s hair comparison

evidence. Of particular relevance to the instant petition is

Bogle’s unsuccessful 1997 postconviction motion challenging the

validity of Malone’s conclusions. Florida’s high court affirmed

the postconviction court’s determination that the claim lacked

materiality, and this Court declined to grant certiorari review.

Some years later, the Justice Department released a memo in

2013 that harshly criticized Malone and suggested that his

testimony exceeded the bounds of science. Bogle filed a

successive postconviction motion citing to the 2013 report and

once again asserted, as he did in 1997, that Malone’s testimony

was unreliable. The postconviction Benes, noting that the two

claims were substantially the same, denied relief on procedural

grounds, a determination that the Florida Supreme Court

affirmed. Bogle now seeks certiorari review.

Bogle’s petition gives rise to the following questions

before this Honorable Court.

ii

QUESTIONS PRESENTED FOR REVIEW

[Capital Case]

I.

Whether this Court should review the correctness of

Florida’s decision to apply a state procedural bar

because a substantially identical claim was previously

rejected on the merits?

Il.

Whether Brady v. Maryland, 373 U.S. 83 (1963),

mandates relief where the information in question, the

DOJ’s 2013 review of Malone’s testimony, did not exist

at the time of Bogle’s 1992 trial, was never withheld

from the defense by the State, and in any event did

not prejudice Bogle?

iii

TABLE OF CONTENTS

QUESTIONS PRESENTED FOR REVIEW ......ccseeeceeeee ccc eeeeeeceue iii

TABLE OF CONTENTS 1... cece ce eee cece eee nee e eee e eee eeeeeeeeees iv

TABLE OF CITATIONS 2... ee cece cece een ence cence teen eee eennees Vv

PARTIES TO THE PROCEEDINGS ...... ec ee cc cece cece eeeeeeteeeeeenee 1

CITATION TO OPINION BELOW ...... 0. eee eect eee ete e eee eeees 1

STATEMENT OF JURISDICTION 21... . eee eee c cece e ence eet eeneeeeee 1

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED ............05. 2

STATEMENT OF THE CASE 00... eee cece c cece cece teen cece eeeeeeenes 3

REASONS FOR DENYING THE WRIT 2... cece cece cece cece ce neee ce eenees 7

I.

Whether this Court should decline to review the

correctness of Florida’s decision to apply a state

procedural bar where an identical claim was previously

rejected on the Merits? 2... cece et cee eee 7

iL

Whether Brady v. Maryland, 373 U.S. 83 (1963) mandates

relief where the information in question, the DOJ’s

2013 review of Malone’s testimony, did not exist at

the time of Bogle’s 1992 trial, was never withheld

from the defense by the State, and in any event did

not prejudice Bogle? ... cece ccc eee wee ee cee ew eee eens 12

CONCLUSION 2... ccc ccc eee eee eee ee ete eee tee eee tee e eee 16

CERTIFICATE OF SERVICE ......c0eeeeee Error! Bookmark not defined.

RESPONDENT’S APPENDIX Ao... ce ec ee ec cee ee te te te ee eee 17

iv

TABLE OF CITATIONS

Cases

Bogle v. Florida,

138 S. Ct 738 (2018) wo... eee eee ee eee eect eens

Bogle v. Florida,

516 U.S. 578 (1995) Lec ccc ec ce eee ee ee ee cee wees

Bogle v. State,

213 So. 2d 833 (Fla. 2017) wo. ccc ccc cece ee ee eee eee 6, 9, 13

Bogle v. State,

288 So. 3d 1065 (Fla. 2019) wc... cc eee ee ee ee 6, 9, 11, 12

Bogle v. State,

655 So. 2d 1103 (Fla. 1995) ... cee cee ce ee eee eee 3,

Brady v. Maryland,

373 U.S. 83 (1963) woe eee ccc ec ee ccc eee ee ee eee ns passim

Braxton v. United States,

500 U.S. 344 (1991) ce. ee ccc ee ec te ce eet eee eee

Giglio v. United States,

405 U.S. 150 (1972) Lec ccc cc ee cc tee et teens 7, 14

Tlliinois v. Gates,

462 U.S. 213 (1983) cee cee cc te ewe ee eee ee ee eee

Jones v. State,

7O1 So. 2d 512 (Fla. 1998) cli. cc tw ee ew cee eee

Rice v. Sioux City Memorial Park Cemetery, Inc.,

349 U.S. 70 (1955) .......... eee eee rere ee 15

Rockford Life Insurance Co. v. Illinois Dept. of Revenue,

482 U.S. 182 (1987) wo. ec ee ee eee ee ete eee eens

Schwab v. State,

969 So. 2d 318 (Fla. 2007) .. cc ee ew ww ce tees

Texas v. Mead,

465 U.S. 1041 (1984) .. cee cee cc eee eee e ees 15

United States v. Johnston,

268 U.S. 220 (1925) occ cc ccc cee ce ee wee ee ee ee ee eee ees 15

Webb v. Webb,

451 U.S. 493 (1981) coc cc cc te we ee ee teas

Other Authorities

28 U.S.C. § L254(1) LoL ce cw we ee te etter caer.

Fla. R. Crim. P. 3.851 (e€) (2) .. ccc cee ce eee eee eee

vi

PARTIES TO THE PROCEEDINGS

The following were parties in the proceedings below:

1) Brett A. Bogle, Petitioner in this Court, was the

appellant below.

2) State of Florida, Respondent in this Court, was the

appellee below.

CITATION TO OPINION BELOW

The published opinion of the Florida Supreme Court is

reported at Bogle v. State, 288 So. 3d 1065 (Fla. 2019).

STATEMENT OF JURISDICTION

The judgment of the Florida Supreme Court was entered on

December 19, 2019, and Petitioner’s motion for rehearing was

denied on January 3, 2020. (Pet. Appendix A). Respondent submits

that any jurisdiction this Court may have over the Florida

Supreme Court arises out of 28 U.S.C. § 1254(1). However, this

Court’s jurisdiction is limited to federal constitutional issues

which were properly presented and considered by the Florida

Supreme Court below. Illinois v. Gates, 462 U.S. 213, 217-19

(1983); Webb v. Webb, 451 U.S. 493, 496-97 (1981). As will be

addressed more fully in the argument section of this brief, this

Court does not have jurisdiction over the questions presented in

Bogle’s petition because they arise entirely out of a claim that

was deemed untimely and procedurally barred by the state court

and there is no federal constitutional dimension.

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

Respondent accepts Petitioner’s statement regarding the

applicable constitutional and statutory provisions involved.

STATEMENT OF THE CASE

Petitioner, Brett A. Bogle, a counselled Florida prisoner

under sentence of death for the murder of Margaret Torres, seeks

certiorari review of the Florida Supreme Court’s decision

affirming denial of Bogle’s successive postconviction claim

because it had already been rejected on the merits and was

therefore procedurally barred.

In Bogle v. State, 655 So. 2d 1103 (Fla. 1995), the Florida

Supreme Court provided the following summary of the facts:

Margaret Torres (the victim) was the sister of Katie

Alfonso and stayed at Alfonso's house four or five

nights a week. In June 1991, Bogle met Alfonso and

shortly thereafter he moved in with Alfonso and the

victim. Bogle and the victim did not get along and

Alfonso eventually asked Bogle to move out. The

following week, Bogle, Alfonso, the victim, and

another person went out together and things seemed to

be going better. During the outing, however, Bogle and

the victim began to argue again. Subsequently, Alfonso

and the victim refused to allow Bogle intc Alfonso's

house. Bogle then broke through the screen door of

Alfonso's house, grabbed Alfonso's neck to push her

out of the way, grabbed the victim's arm to remove the

telephone from her hand as she tried to call 911,

pulled the telephones out of the kitchen and bedroom,

and took clothing from the house. As he left the

house, Bogle told the victim that she would not live

to tell about it if she called the police and pressed

charges. In response to the victim's uncompleted call

to 911, a deputy sheriff arrived shortly after Bogle

left. The deputy referred the matter to the state

attorney's office. Several days later, Bogle called

Alfonso and again threatened the victim, stating that,

if the victim pressed charges, she would not live to

tell about it.

About two weeks later, Bogle called Alfonso to ask if

he could come over to her house. The victim was out

for the evening. When Alfonso told Bogle that he could

not come over, he became furious and hung up. Later

that night, Bogle and the victim ran into each other

at a bar called Club 41. Witnesses saw them talking

briefly. Witnesses also noticed that Bogle was clean

and had no noticeable injuries of any kind when he

arrived at Club 41. The victim left Club 41 at about 1

a.m.; Bogle left approximately five minutes later.

About forty-five minutes after that, Bogle approached

a car outside Club 41 and asked for a ride. At that

time, his forehead was scratched, his clothes were

dirty, and his crotch was wet.

The next day, the victim's nude and badly beaten body

was found outside an establishment located next to

Club 41. Her head had been crushed with a piece of

cement, and she had died of blows to the head.

Additionally, she had semen in her vagina and trauma

to her anus consistent with sexual activity that was

likely inflicted before death. The DNA extracted from

the semen was consistent with Bogle's DNA (12.5% of

Caucasian males could have contributed the semen), and

a pubic hair found on the crotch area of Bogle's pants

matched the victim's.

Bogle put on no evidence in his defense. The jury

found him guilty of burglary of Alfonso's home with

force, retaliation against the victim as a witness to

that burglary, and first-degree murder of the victim.

A penalty phase proceeding was held on the firstdegree murder conviction, and the jury recommended

death by a seven-to-five vote. The trial judge,

however, granted a new penalty phase proceeding after

determining that improper rebuttal evidence had been

presented by the State.

At the second penalty phase proceeding, the State

presented the same evidence it relied on in the guilt

phase. Bogle put on eight witnesses who testified that

Bogle had been subjected to physical and mental abuse

as a child, had used drugs at his father's urging from

the time he was five or six years old, was under the

influence of alcohol at the time of the murder, had a

personality disorder and suffered from some mental

4

disturbance at the time of the murder, was kind to

others, and had been injured in an automobile accident

a week before the murder. The jury recommended death

by a ten-to-two vote. The trial judge subsequently

sentenced Bogle to death, finding four aggravating

circumstances: (1) previous conviction of a violent

felony (burglary with force on Alfonso and the victim

two weeks before the murder); (2) the murder was

committed while engaged in the commission of a sexual

battery; (3) the murder was committed for the purpose

of avoiding arrest; and (4) the murder was heinous,

atrocious, or cruel (HAC). In mitigation, the trial

judge gave some weight to the statutory factor of

impaired capacity but stated that substantial

impairment had not been proven; gave substantial

weight to Bogle's family background; little weight to

his alcohol and drug abuse; gave some weight to his

good conduct during trial; gave some, but not a great

deal, of weight to his kindness to others; and gave no

weight to his involvement in an automobile accident.

Bogle also received consecutive sentences of life in

prison for the burglary-with-assault-or-battery

conviction and five years in prison for the

retaliation-against-a-witness conviction.

Bogle v. State, 655 So. 2d 1103, 1105-06 (Fla.), cert. denied,

516 U.S. 978 (1995).

Direct Appeal

The Florida Supreme Court affirmed his conviction and death

sentence in Bogle v. State, 655 So. 2d 1103 (Fla. 1995). This

Court denied certiorari review. Bogle v. Florida, 516 U.S. 578

(1995).

State Postconviction Proceedings

Bogle filed his initial postconviction motion in 1997. He

raised (among other things) a challenge to the FBI’s hair and

fiber expert Michael Malone, claiming that the State violated

Brady! when it failed to disclose Malone’s bench notes which, in

Bogle’s view, would have indicated a lack of precision in his

method. Florida’s high court affirmed the postconviction court’s

Order finding that the notes lacked materiality. Bogle v. State,

213 So. 2d 833, 844 (Fla. 2017). Certiorari review was denied.

Bogle v. Florida, 138 S. Ct 738 (2018).

Bogle’s next challenge to Malone’s testimony, filed in

2014, came after the U.S. Department of Justice, in a report

released in 2013, concluded that some of Malone’s' hair

comparison testimony was overstated and “exceeded the bounds of

science.” The lower court found that the DOJ’s new report

contained nothing that was not previously known to Bogle, any

flaws in Malone’s analysis and testimony lacked materiality, and

because Bogle could have pursued his 2014 claims in his first

postconviction motion, his successive claim was procedurally

barred under Florida law. The Florida Supreme Court agreed.

Bogle v. State, 288 So. 3d 1065 (Fla. 2019). Bogle now seeks

certiorari review.

1 Brady v. Maryland, 373 U.S. 83 (1963).

6

REASONS FOR DENYING THE WRIT

I.

Whether this Court should decline to review the

correctness of Florida’s decision to apply a state

procedural bar where an identical claim was previously

rejected on the merits?

Bogle advances two claims in his Petition. First, he

asserts that the Florida Supreme Court erred in rejecting on

procedural grounds his postconviction Giglio? and Brady claims.

Secondly, he contends that the State violated Brady by failing

to disclose impeachment evidence he could have used to challenge

the hair comparison testimony adduced at Bogle’s trial. Review

of both claims should be denied.

This Court reserves its certiorari jurisdiction primarily

to resolve conflicts among the United States courts of appeal

and state courts “concerning the meaning and provisions of

federal law.” Braxton v. United States, 500 U.S. 344, 348

(1991). Bogle’s argument is of extremely limited scope, does not

identify any federal or state court conflict, and instead

amounts to little more than his disagreement with the Florida

Supreme Court’s resolution of his postconviction claims. In

short, there is no federal constitutional question here and no

reason for this Court to grant review.

Cases that do not divide the federal or state courts or

2 Giglio v. United States, 405 U.S. 150 (1972).

7

that do not present important, unsettled questions of federal

law usually do not merit certiorari review. Rockford Life

Insurance Co. v. Illinois Dept. of Revenue, 482 U.S. 182, 184,

n. 3 (1987). See also Supreme Court Rule 10. None of these

considerations apply to the claims advanced by Bogle, however,

and his request for Certiorari review should be denied.

Bogle’s argument before this Court arises out of the

testimony of Michael Malone, an FBI hair comparison analyst who

testified that pubic hair found on Bogle’s pants was consistent

with and therefore could have come from the victim. The U.S.

Department of Justice (DOJ) conducted a review and in 1999

released a report critical of Malone. Among other things, the

DOJ concluded that Malone failed to adequately document his

analysis in his bench notes, thus calling into question the

scientific validity of his testimony. Bogle unsuccessfully

challenged Malone’s testimony in his initial postconviction

motion in 1997. When the DOJ released another report in 2013

indicating that Malone’s testimony overstated the significance

of his findings and “exceeded the bounds of science,” Bogle

sought to use it as the basis for a successive postconviction

claim. Review of the lower court’s rejection on procedural

grounds is the subject of the instant petition.

Florida rejected Bogle’s claim because it was procedurally

barred and lacked merit. Florida imposes strict limits on

successive postconviction motions, and prohibits a defendant

from advancing a claim that was raised, or could have been

raised, in a previous proceeding. In Bogle’s case, the court

found that he had already raised a substantially similar

challenge to Malone’s testimony in his initial postconviction

motion which was denied on the merits and affirmed on review.

See Bogle v. State, 213 So. 3d 833 (Fla. 2017) at 844. Florida

law does not permit Bogle to raise the same claim twice, and the

procedural bar was properly applied here. See Fla. R. Crim. P.

3.851(e) (2), Schwab v. State, 969 So. 2d 318 (Fla. 2007).

In the alternative, Florida’s high court also rejected

Bogle’s successive claim on the merits. As newly discovered

evidence, Florida requires the defense to establish that the new

evidence could not have been discovered with diligence at the

time of trial, and it must be of such a character that it would

likely produce an acquittal. Jones v. State, 701 So. 2d 512

(Fla. 1998). Bogle’s postconviction court found that the 2013

report did nothing more than amplify what was already known at

the time of his initial postconviction motion, and was not newly

discovered evidence. Bogle v. State, 288 So. 3d 1065 at 1068.

In rejecting Bogle’s subsidiary claim that the State also

violated Brady by failing to disclose the 2013 report, the

postconviction court noted that because it did not exist at the

time of Bogle’s trial, the DOJ report could not have been

suppressed or withheld by the State.

On review, Florida’s high court agreed, saying that the

2013 report merely documented the opinions of other DOJ experts

and was not evidence. And, the court found that Bogle’s claim

lacked materiality. While Malone testified that the pubic hair

found on Bogle’s pants was consistent with and therefore could

have come from the victim, Malone also admitted on cross that

hair comparison cannot be used as a basis for establishing

“absolute personal identification.” The Florida Supreme Court

found that while the 2013 report criticized Malone for

overstating the significance of his findings as a means of

identifying the source of a given strand of hair, his crossexamination testimony redeemed him. Indeed, the 2013 report did

little more than amplify Malone’s cross examination testimony.

And Bogle suffered no prejudice. While he complains about the

alleged flaws in Malone’s hair analysis that linked him to the

murder, he inexplicably ignores the fact that his semen was

found in the victim’s body. The Florida Supreme Court found the

DNA evidence to be strongly persuasive. The presence of his DNA,

the Court concluded, “overwhelms the significance of Malone's

testimony” in terms of establishing Bogle’s guilt. Bogle v.

10

State, 288 So. 3d at 1069.

Bogle also spends considerable time complaining about what

he calls the “false and misleading” hair analysis testimony, and

he infers that but for Malone, he would not have been found

guilty or sentenced to death. Bogle ignores the fact that posttrial testing of the pubic hair’s mitochondrial DNA confirmed

that the hair found on Bogle’s pants was consistent with having

come from the victim. If Bogle were retried without Malone, the

mitochondrial DNA still establishes that the hair most likely

came from the victim. A copy of the test results is attached as

Appendix A. As Malone told Bogle’s jury, microscopic hair

analysis is not as conclusive as fingerprinting, but narrows the

field of individuals from whom the hair could have come.

Mitochondrial DNA is similarly not conclusive, but is the

functional equivalent of Malone’s analysis and equally probative

of Bogle’s guilt.

Bogle next faults the Florida Supreme Court for failing to

consider all admissible evidence in assessing the strength of

his newly discovered evidence claim. Bogle, perhaps

deliberately, ignores express language in the Florida high

court’s opinion that a correct evaluation of Bogle’s newly

discovered evidence claim requires consideration of all

admissible evidence that could be introduced in the event of a

11

retrial. Bogle, 288 So. 3d at 1069. While the opinion does not

contain any specific discussion of evidence, it is incorrect to

say that the court failed to consider the admissible evidence in

denying Bogle’s claim, particularly when the Court’s recitation

of the applicable law documents the analysis used in assessing

the strength of Bogle’s claim. Bogle’s complaint in this regard

lacks merit.

Bogle’s argument before this Court merely reflects his

personal disagreement with the Florida Supreme Court’s

resolution of his claim. The lower court correctly applied this

Court’s precedent and to the extent that it relied upon Florida

law to reject Bogle’s claims, did not violate his constitutional

rights. Certiorari review is not warranted here.

Il.

Whether Brady v. Maryland, 373 U.S. 83 (1963) mandates

relief where the information in question, the DOJ’s

2013 review of Malone’s testimony, did not exist at

the time of Bogle’s 1992 trial, was never withheld

from the defense by the State, and in any event did

not prejudice Bogle?

In his second claim, Bogle asserts that the State violated

Brady v. Maryland when it failed to timely disclose the 2013 DOJ

report. In rejecting this claim, the Court concluded not only

that the claim was procedurally barred under Florida law, but

also that the 2013 report contained nothing substantive that was

12

not previously known at the time Bogle advanced his initial

postconviction motion. The Court specifically noted a DOJ report

released in 1999 that strongly criticized Malone for failing to

document his analysis; indeed, the DOJ found, his bench notes

were so inadequate that it was impossible to assess whether his

analysis was scientifically reliable.

Significantly, Bogle’s initial postconviction claim

asserted that counsel was ineffective for failing to secure

Malone’s bench notes and take other steps to impeach Malone’s

reliability. Bogle v. State, 213 So. 3d 833 (Fla. 2017). His

2014 claim merely restated his earlier one by citing to the 2013

report’s criticism that Malone’s testimony that hair found on

Bogle’s pants “matched” known hair belonging to the victim; this

testimony, according to the 2013 report, “exceeded the bounds of

science.”

Even if this Court were to conclude that Bogle’s 2014

motion contained new claims, Florida’s high court found that the

1999 DOJ report adequately outlined the flaws in Malone’s work

product, was in Bogle’s possession at the time of his initial

postconviction motion,? and provided the basis for every argument

advanced in his 2014 postconviction motion. In short, to the

3. The postconviction court also found that Bogle received the

2013 DOJ report in September of the same year it was released.

Any prejudice that Bogle claims to have suffered because the

State allegedly suppressed or withheld it is de minimus.

13

extent that any new claims were raised, Bogle could have drafted

and filed the motion at issue here while his initial

postconviction motion was still under consideration.

Accordingly, Bogle’s assertion that the State’s alleged

delay in providing him with the 2013 report fails because Bogle

has not established that he was prejudiced. And, regardless of

when he actually received it, Bogle could not advance the claim

raised in his 2014 motion under Florida law because it amounted

to nothing more than a restatement of previous argument. For

that reason, Florida’s correct determination that Bogle’s 2014

motion was procedurally barred similarly precludes a finding

that the State violated Brady; if Bogle was barred from raising

the claim because it was available but omitted from his initial

1997 postconviction motion, he suffered no prejudice even if we

were to agree that the State withheld the 2013 report.

On this record, the Florida Supreme Court's application of

Brady and Giglio was correct. Even if this Court were inclined

to grant review, Bogle’s claims would require this Court to

engage in fact-specific examination of a routine and meritless

claim focusing primarily on how Florida applied its own state

law regarding procedural bars. The law is well-settled that this

Court does not grant certiorari “to review evidence and discuss

specific facts.” United States v. Johnston, 268 U.S. 220, 227

14

(1925); Texas v. Mead, 465 U.S. 1041 (1984). This Court is

“consistent in not granting the certiorari except in cases

involving principles, the settlement of which is of importance

to the public as distinguished from that of the parties.” Rice

v. Sioux City Memorial Park Cemetery, Inc., 349 U.S. 70 (1955).

Accordingly, Bogle’s request for certiorari review should be

rejected.

15

CONCLUSION

Based on the foregoing, Respondent respectfully requests

that this Court deny the petition for writ of certiorari.

Respectfully submitted,

ASHLEY MOODY

7

CAROLYN M. SNURKOWSKI*

Associate Deputy Attorney General

Florida Bar No. 158541

*Counsel of Record

TIMOTHY A. FREELAND

Senior Assistant Attorney General

Florida Bar No. 0539181

Office of the Attorney General

Capital Litigation

PL-O1, The Capitol

Tallahassee, Florida 32399

Telephone: 850-414-3300

carolyn.snurkowski@myfloridalegal.com

timothy. freeland@myfloridalegal.com

capapp@myfloridalegal.com

COUNSEL FOR RESPONDENT

16