JURIST Supported by the University of Pittsburgh
PAPER CHASE ARCHIVEDigest RSS feedFull RSS feed
Serious law. Primary sources. Global perspective.
Listen to Paper Chase!


Legal news from Monday, July 12, 2010




Lawyers file complaint in Morocco seeking arrest of Israel officials
Dwyer Arce on July 12, 2010 3:33 PM ET

Photo source or description
[JURIST] A group of lawyers on Monday filed a complaint with a Morocco prosecutor seeking the arrest of several high ranking Israeli officials over their involvement in Operation Cast Lead [GlobalSecurity backgrounder; JURIST news archive]. The complaint names former Israeli prime minister Ehud Olmert, former foreign minister Tzipi Livni, and Defense Minister Ehud Barak [BBC profiles] for violating anti-terror laws [AFP report] and laws requiring the protection of civilians during the 22-day conflict in the Gaza Strip [BBC backgrounder]. If the complaint is accepted by the Rabat chief prosecutor, the Israeli officials would face arrest upon entering Moroccan jurisdiction. Israeli officials have faced several arrest threats following the operation in which an estimated 1,400 Palestinians and 13 Israelis were killed. In January, a military delegation canceled a trip to the UK [JURIST report] over fears that they would be arrested on war crimes charges for their involvement in the conflict under several British warrants. The arrest warrants were the result of Palestinian plaintiffs working with British lawyers to file charges against Israeli officials under universal jurisdiction [AI backgrounder], which allows a country to prosecute serious crimes against humanity no matter where the activity takes place. In December, Livni canceled a UK trip [JURIST report] after a British magistrate court issued, and later revoked, an arrest warrant for her on war crimes charges relating to the Gaza offensive.

Israel has faced mounting international pressure following the Gaza conflict. The Goldstone Report [text, PDF; JURIST news archive] accused both the Israel Defense Force (IDF) [official website] and Hamas [GlobalSecurity backgrounder] of war crimes during the conflict. Both Israel and Hamas conducted independent investigations into the incident after the UN General Assembly adopted a resolution [JURIST report] in November giving them three months to probe possible war crimes committed during the Gaza conflict. Hamas reported to the UN that its independent investigation had absolved Palestinian forces of any wrongdoing. Israel presented a report to the UN in February detailing its role in the conflict [JURIST report] and noting that two high-ranking Israeli officers were indicted for their actions during the incident. Rights groups have questioned the impartiality of the internal investigations. In April, Human Rights Watch (HRW) [advocacy website] accused both Israel and Hamas of failing to conduct credible investigations [JURIST report] into accusations of war crimes during the conflict. In February, HRW criticized Israel for failing to demonstrate that it would conduct a thorough and impartial investigation [JURIST report] of the alleged war crimes.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page


China expands income-reporting rules to fight corruption
Daniel Richey on July 12, 2010 3:28 PM ET

Photo source or description
[JURIST] The Chinese government instituted new regulations Sunday requiring a wide variety of government officials to disclose to the state details about their personal finances and the legal statuses of their family members. The new regulations [Xinhua report], which apply to county-level and higher-ranking political officials, party officers and employees of public institutions and state-held business entities, require individuals to disclose their family's investment holdings, property and income, as well as the marital statuses, employment statuses and whereabouts of all family members. The inclusion of detailed information about family members in the new disclosure requirements is intended to deter officials from hiding ill-gotten assets and bribes under family members' names, a practice the government believes to be widespread. While the regulations, enacted by the General Office of China's State Council [official website, in Chinese] and the General office of the Communist Party of China (CPC) [GlobalSecurity backgrounder], do not go so far as to require public disclosure of the financial information in question, feedback from Chinese citizens posted to state-run portals has shown the move to be well received [Xinhua report]. The regulations also institute stiffer penalties for failure to comply, with offenders now facing a range of disciplines from public sanction to removal from office.

The expanded regulations are the latest salvo by the Chinese government in a years-long battle against what is perceived to be pervasive corruption [JURIST news archive] in the state's various business and administrative bodies. Last week, the Chinese government executed [JURIST report] a top judicial official after a corruption probe in the southwestern city of Chongquing revealed he had taken nearly $2 million in bribes and had been protecting a number of organized crime gangs. In March, the Hebei Province People's High Court upheld a life sentence for the former vice president of China's Supreme People's Court (SPC), Huang Songyou, who had been convicted [JURIST reports] of bribery and embezzlement. Earlier that month, SPC president Wang Shengjun called for increased efforts to fight corruption [JURIST report] in the country's court system. In January, the SPC announced new anti-corruption rules [JURIST report] in an effort to increase public confidence in the rule of law. In October, two Chongqing courts sentenced [JURIST report] six individuals to death for their connections with organized crime gangs.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page


UK court sentences 3 in 2006 airliner bomb plot to life in prison
Daniel Richey on July 12, 2010 1:35 PM ET

Photo source or description
[JURIST] The UK Woolwich Crown Court on Monday sentenced three British Muslims [press release] charged in connection with a 2006 plot to blow up numerous transatlantic flights to life in prison. Ibrahim Savant, Arafat Waheed Khan and Waheed Zahman [GlobalSecurity backgrounders] were part of a conspiracy to detonate liquid bombs hidden in soft drink bottles on airliners bound for the US and Canada from London's Heathrow Airport [corporate website]. The plot was dismantled [JURIST report] after a raid carried out by London's Metropolitan Police Service (MPS) [official website]. During the raid, the police discovered a digital tape containing suicide videos for Savant, Khan and Zaman. All three claimed the videos were fake and pleaded guilty [JURIST report] to causing a public nuisance at a previous trial in 2008. Stuart Osborne, the MPS's senior national coordinator for counter-terrorism, said:
The martyrdom videos, the instructions left for the media to use them, passport applications, the loan applications and the forensic and surveillance ... all add up to a clear picture of intent. The length of the sentence reflects the severity of their crime. Sadly, this case also highlights that there are people out there who are intent on causing us harm.
The sentence requires each of the men to serve a minimum of 20 years.

The men were convicted last week [JURIST report] of conspiracy to commit murder. A total of 24 men were arrested during 2006's Operation Overt, one of the biggest raids ever executed by MPS, and 11 were charged [JURIST report] under the Terrorism Act of 2006 and Terrorism Act of 2000 [texts]--eight with conspiracy to commit murder and preparing acts of terrorism, one with possession of articles useful to a person preparing an act of terrorism and two with failing to disclose information of material assistance in preventing an act of terrorism. In September, three other men convicted of attempting to smuggle liquid explosives onto the airplanes were sentenced [JURIST reports] to life in prison by the same court.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page


Israel probe finds intelligence mistakes in Gaza flotilla raid
Drew Singer on July 12, 2010 1:05 PM ET

Photo source or description
[JURIST] An Israeli military probe found insufficient intelligence and planning in the May 31 raid on several Turkish ships bound for the blockaded Gaza Strip [BBC backgrounder] in a report released Monday [press release], but also concluded that no punishments were necessary. The Eiland Commission, which was formed last month [JURIST report] to investigate the raid, was composed of professionals outside of the chain of command for the flotilla raid and had been assigned to study the outcomes of the incident and "establish lessons." The commission declassified some sections of its findings, which concluded that the Israeli Navy failed to sufficiently consider the possibility that its troops could encounter violent resistance [AFP report]. The Israel Defense Forces (IDF) [official website] reported that the probe did not blame the soldiers, but rather the navy's intelligence officials, stating:
In terms of the intelligence effort, the team concluded that not all possible intelligence gathering methods were fully implemented and that the coordination between Navy Intelligence and the Israel Defense Intelligence was insufficient. At the same time, the team emphasized that it is not certain that an optimal intelligence effort would create a complete intelligence picture. The team also pointed out that the anticipated level of violence used against the forces was underestimated.
The report also pointed out the operation relied "excessively on a single course of action ... while no alternative courses of action were prepared for the event of more dangerous scenarios." It also went on to commend the actions of the soldiers and their commanders, who exhibited "correct decision making" and justifiably resorted to the use of their firearms.

Last month, Israeli Prime Minister Benjamin Netanyahu [official website; BBC profile] also established [JURIST report] a panel of jurists to investigate the attack independently from the IDF investigation. To head the probe, Netanyahu appointed former Israeli Supreme Court Justice Yakov Tirkel, who has since demanded [JURIST report] that the investigation be given the same authority as a state commission of inquiry. The internal probe, approved by the Israeli cabinet, did not have the power to subpoena witnesses or recommend sanctions, powers that official state commissions possess. If the probe is considered an official inquiry, witnesses would be required to give testimony under oath. Tirkel also wanted the size of the panel to increase from five members to seven. Netanyahu agreed to Tirkel's requests, avoiding Tirkel's threatened resignation. The panel has not yet completed its investigation. Israeli forces raided six ships attempting to deliver more than 10,000 tons of aid to Gaza in May. The raid left numerous wounded and resulted in the deaths of nine pro-Palestine activists - eight Turks and one American.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page


Khadr tells court he previously rejected plea deal
Hillary Stemple on July 12, 2010 1:00 PM ET

Photo source or description
[JURIST] Canadian Guantanamo Bay [JURIST news archive] detainee Omar Khadr [DOD materials; JURIST news archive] on Monday appeared at a pre-trial hearing and informed the court that he had previously rejected a plea deal offered by the US government. Under the plea agreement Khadr would have pleaded guilty to committing war crimes and been sentenced to 30 years in prison, with all but five years of the sentence suspended. Khadr told the court that the agreement was a ploy by the US government to look good in the eyes of the international community and that he would not be used to achieve US goals. He also said the agreement would have been used to excuse the torture and abuse of a child [Reuters report]. Khadr, who fired his American defense lawyers [AFP report] last week, also informed the US military tribunal that he will not be participating or offer a defense when his case goes to trial, saying that the will be the same regardless of whether he is represented at trial. When Judge Patrick Parrish asked Khadr if he would be representing himself, Khadr indicated that he would be present at trial, but would not participate because the process offers him no hope of justice. Khadr is facing murder and terrorism charges [JURIST report] for allegedly throwing a grenade that killed one US soldier and injured another. He faces a life sentence if he is found guilty at his trial before the US military commission, which is set to begin on August 10 [JURIST report].

Khadr's defense lawyers have repeatedly sought his repatriation [JURIST report] to Canada on the basis that the Canadian government's refusal to request repatriation from the US violates the Canadian Charter of Rights and Freedoms [text]. The Harper administration announced in February that they would not pursue Khadr's repatriation, after the Supreme Court of Canada ruled that the government was not obligated to seek his return [JURIST reports] to Canada despite having his Charter rights violated. In May, a UN official called on the US and Canada to respect international conventions [JURIST report] and release Khadr into Canadian custody. The UN claimed that since Khadr was 15 when he was captured, his detention would fall in line with the UN Convention on the Rights of the Child [text], which has been ratified by Canada, but not the US.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page


ICC charges al-Bashir with genocide
Dwyer Arce on July 12, 2010 12:28 PM ET

Photo source or description
[JURIST] Pre-Trial Chamber I of the International Criminal Court (ICC) [official website] on Monday charged Sudanese President Omar al-Bashir [case materials; JURIST news archive] with three counts of genocide [warrant, PDF] in relation to the Darfur conflict [BBC backgrounder]. The chamber found that there were reasonable grounds to conclude that Bashir had committed genocide against the Fur, Masalit and Zaghawa ethnic groups. The charges included "genocide by killing, genocide by causing serious bodily or mental harm and genocide by deliberately inflicting on each target group conditions of life calculated to bring about the group's physical destruction." The charges come after the Appeals Chamber reversed a prior decision [JURIST report] by the lower chamber denying the prosecutor's request for genocide charges. The Appeals Chamber found that the standard of proof applied by the lower chamber had been too high, and that there only needed to be a showing of reasonable grounds of a genocidal specific intent, a showing that had been met when the first arrest warrant was issued. The warrant alleges that the Sudanese government, using the national armed forces, police and the Janjaweed militia [BBC backgrounder], targeted ethnic groups for extermination that were believed to be close to armed opposition groups in Darfur as part of a counter-insurgency strategy, and that as commander-in-chief of Sudanese forces, Bashir "played an essential role in [its] coordinati[on]." The genocide charges have been added to seven counts of war crimes and crimes against humanity that were filed against Bashir [JURIST report] in March 2009.

ICC prosecutors appealed the decision [JURIST report] not to charge al-Bashir with genocide in July 2009. Bashir has eluded arrest since the issuance of the first warrant. In March, the president of the ICC said that Bashir will eventually face justice [JURIST report] in The Hague and compared the Bashir warrant with the successful surrender of former Serbian president Slobodan Milosevic [BBC obituary; JURIST news archive] and former Liberian president Charles Taylor [case materials; JURIST news archive] to the international criminal tribunals. The warrant has been controversial, with Egypt, Sudan, the African Union and others calling for the proceedings against Bashir to be delayed, and African Union leaders agreeing [JURIST reports] not to cooperate with the warrant.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page


India apologizes for improperly dumping waste related to Bhopal gas incident
Hillary Stemple on July 12, 2010 11:00 AM ET

Photo source or description
[JURIST] The Indian Environmental Minister Jairam Ramesh [official website] apologized Saturday for the government's role in the 2008 disposal of toxic waste from the 1984 Bhopal chemical spill disaster [BBC backgrounder], which he said was done secretly and in an improper manner. Bhopal victims groups and citizens living near the town of Pithampur, where the disposal occurred, have expressed concern [IANS report] that the improper disposal could have an impact on the environment and health of those living in the region and have called for it to be removed immediately. Nearly 350 tonnes of waste were collected following the disaster in which nearly 3,800 people were killed when toxic gas was accidentally released in the middle of the night by a chemical plant owned by a Union Carbide [corporate website] subsidiary company. Upwards of 15,000 others later died from exposure to the gas, and 50,000 were left permanently disabled. The government reportedly removed 40 tonnes of the waste [AFP report] to Pithampur for disposal, but failed to consider the environmental impact or notify the public about the disposal. Last month, a panel of Indian cabinet ministers announced the government would begin the process of cleaning up the disaster site [JURIST report] and would consider increasing compensation for victims of the disaster. Ramesh has promised that all further cleanup of the Bhopal site will be done in a transparent manner so the government can be held accountable.

Last month, an Indian court handed down the first convictions [JURIST report] related to the disaster, sentencing seven men to two years in prison as well as fines for their roles in the disaster. Union Carbide and the Indian government reached a settlement as to corporate liability in 1989 with the company paying USD $470 million to end its liability. The Indian government, however, has indicated it would be willing to revisit the settlement and possibly seek further compensation from Union Carbide. Dow Chemicals [corporate website], which purchased Union Carbide in 1999, contends that the settlement ended all possible claims against the company. In 2008, the US Court of Appeals for the Second Circuit [official website] reinstated a water pollution lawsuit [JURIST report] brought by disaster victims against Union Carbide. In 2004, groups representing Bhopal victims appealed a USD $330 million award [JURIST report] issued by the Indian Supreme Court, arguing that the award should be quadrupled to provide enough compensation for each of the 572,173 people that the court ruled were eligible.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page


ICC allows trial of accused Congo militia leader to continue
Dwyer Arce on July 12, 2010 10:59 AM ET

Photo source or description
[JURIST] The Appeals Chamber of the International Criminal Court (ICC) [official website] on Monday denied the stay of proceedings request [press release] of accused Congolese militia leader Germain Katanga [case materials]. Katanga filed the appeal in June seeking a stay of proceedings and a declaration of unlawful detention by the Democratic Republic of the Congo (DRC) [BBC backgrounder] before his transfer to the ICC. In upholding the November decision of Trial Chamber II, the Appeals Chamber held that the motion had been filed too late. Two dissenting appellate judges described the standard applied by the trial chamber as a retroactive one and a violation of the chamber's discretion. According to the dissent, the trial chamber had not properly weighed the procedural interests of the court against the Katanga's rights. Katanga and his co-defendant Mathieu Ngudjolo Chui pleaded not guilty at the start of their trial in November [JURIST report] to charges of three crimes against humanity and seven war crimes, including murder, sexual slavery, pillage, and the use of child soldiers. Katanga, a former commander in the Front for Patriotic Resistance of Ituri [IRIN backgrounder], and Ngudjolo Chui, a former commander in the Nationalist and Integrationist Front, allegedly led two groups of child soldiers and militia in the attack against the village of Bogoro. Bogoro is located in the DRC's mineral-rich Ituri province, which has caused the territory to be an ongoing point of contention between Congolese militias. The trial is only the ICC's second case since its formation since 2002.

In September, the Appeals Chamber upheld the admissibility [JURIST report] of the case against Katanga after he argued that charges of war crimes and crimes against humanity against him should be dropped because he was being tried for the same crimes in the DRC, violating the ICC principle of complementarity. The Appeals Chamber upheld the trial chamber's June 2009 dismissal of Katanga's challenge on the grounds that the there were no domestic proceedings against him at the time the charges were filed, and that subsequent investigations did not result in domestic charges. Noting that the aim of the Rome Statute [text, PDF] establishing the ICC is to ensure that "the most serious crimes of concern to the international community as a whole must not go unpunished." In September 2008, the trial chamber confirmed [JURIST report] the charges against Katanga. He surrendered to the ICC and was transferred to the detention facility in the Hague in October 2007 after a warrant [text, PDF, in French] was issued for his arrest in July 2007. Former rebel leaders Thomas Lubanga Dyilo and Jean-Pierre Bemba Gombo [JURIST news archives] are also on trial at the ICC for their alleged involvement in crimes committed in the DRC and neighboring Central African Republic [BBC backgrounder]. Lubanga's trial was suspended [JURIST report] by the ICC on Thursday, however. Another alleged rebel leader, Bosco Ntaganda [case materials], remains at large.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page


DOJ may consider second lawsuit against controversial Arizona immigration law
Hillary Stemple on July 12, 2010 9:49 AM ET

Photo source or description
[JURIST] US Attorney General Eric Holder [official website] said during an interview [transcript] Sunday on CBS's Face the Nation that the Department of Justice (DOJ) [official website] will continue monitoring the effects of Arizona's recently passed immigration bill [SB 1070 materials; JURIST news archive] and would consider filing a second lawsuit if implementation of the bill had a "racial profiling impact." The DOJ filed suit [JURIST report] last week seeking to permanetly enjoin [complaint, PDF] the controversial law from going into effect. The complaint states that the law is preempted by federal law and therefore violates the Supremacy Clause [text] of the US Constitution. The DOJ argues that the Constitution and federal law "do not permit the development of a patchwork of state and local immigration policies throughout the country." The agency also claims that the federal government has preeminent authority to regulate immigration matters and that the enforcement of the Arizona law is counterproductive to the national immigration policy. Holder indicated that the DOJ filed the initial suit based on preemption because they thought it was the strongest argument and presents the most serious problem with the law as it exists now. He noted, however, that racial profiling could become an issue if the law is allowed to go into effect and the government would consider a second suit based on possible violations of the Equal Protection Clause [text]. Arizona Governor Jan Brewer (R) [official website] has stated that she is certain the law can be enforced without racial profiling [AP report]. The legislation was signed into law [JURIST report] by Brewer in April and is set to take effect July 29.

The Arizona law criminalizes illegal immigration and requires police officers to question an individual's immigration status if the officer has a "reasonable suspicion" to believe an individual is in the country illegally. It has been widely criticized in regard to the law's constitutionality and alleged "legalization" of racial profiling. Earlier this month, the American Bar Association (ABA) [official website] filed an amicus curiae brief [JURIST report] urging the federal district court in Arizona to block the enforcement of the state's immigration law. The brief was filed in support of a class-action lawsuit [JURIST report] led by the American Civil Liberties Union (ACLU) [advocacy website]. The Mexican government has also filed an amicus curiae brief [JURIST report] supporting the ACLU suit, claiming a substantial interest in ensuring its "bilateral diplomatic relations" with the US remain "transparent, consistent and reliable, and not frustrated by the actions of individual US states." The government also claims an interest in ensuring that its citizens are "accorded human and civil rights when present in the US in accordance with federal immigration law." Brewer is also currently facing federal lawsuits filed by the National Coalition of Latino Clergy and Christian Leaders and several Tuscon police officers [JURIST reports], who claim they can not properly implement the law without racially profiling.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page


Zimbabwe court grants bail to rights activist investigating conflict diamonds
Dwyer Arce on July 12, 2010 9:26 AM ET

Photo source or description
[JURIST] A Zimbabwean court on Monday granted bail to human rights activist Farai Maguwu, who was being held for allegedly supplying false information about Zimbabwe's controversial diamond mining practices to the international diamond control body the Kimberley Process (KP) [official website]. In granting the bail request, Judge Mawadze Gurainesu rejected the prosecution's argument [AP report] that Maguwu would interfere with the investigation by contacting witnesses. Maguwu's release comes after a statement released Friday by the Movement for Democratic Change (MDC) [party website], currently part of the government of President Robert Mugabe [PBS profile; JURIST news archive] in a power-sharing agreement, which called Maguwu's detention [press release] a "major blemish on the rule of law and the reputation of the inclusive government." The statement went on to call for greater transparency in the activities of the government at the Marange diamond fields, where Maguwu alleged human rights abuses by Mugabe's Zanu-PF shortly before his arrest. Monday's hearing was Maguwu's third bail hearing after his first two were denied. In denying the second bail request [JURIST report], Judge Chinembiri Bhunu of the Harare High Court [GlobaLex backgrounder] cited the severity of the crimes, which he characterized as borderline treason. According to Maguwu's lawyer, he has been in declining health [VOA report] due to the temperature of his cell, which has caused him to develop throat and chest infections.

Maguwu was arrested [JURIST report] in early June. He faces charges of false information on killings, torture and the theft of state security documents, in violation of § 31 of the Criminal Law (Codification and Reform) Act [text, PDF]. An investigation was launched after he allegedly leaked to the KP a document compiled by the police [SW Radio Africa report] for the Joint Operations Command (JOC), a military-run security agency that was thought to be defunct. If convicted, Maguwu could face 20 years imprisonment. The ban on Zimbabwean diamonds is expected to be the focus of the upcoming KP meeting after last month's meeting failed to reach a consensus [AFP report] on the matter. Human Rights Watch (HRW) [advocacy website] has urged the body to remove Zimbabwe [JURIST report] from its membership. According to HRW, human rights abuses by the Zimbabwean government have persisted since the discovery of diamonds in the Marange fields. Civil society groups such as Global Witness, Partnership Africa Canada [advocacy websites] and Green Advocates, have also called for the suspension of Zimbabwe's international diamond trade due to the human rights violations [Telegraph report] allegedly committed by the Zimbabwean army against civilians and illegal workers in the Marange diamond fields.




Link | | subscribe | RSS feeds | latest newscast | archive | Facebook page

For more legal news check the Paper Chase Archive...


LATEST OP-ED

The War on Terror and the Need for Muslim Support
DOMESTIC
Faisal Kutty
Valparaiso University Law School

Get JURIST legal news delivered daily to your e-mail!

SYNDICATION

Add Paper Chase legal news to your RSS reader or personalized portal:
  • Add to Google
  • Add to My Yahoo!
  • Subscribe with Bloglines
  • Add to My AOL

E-MAIL

Subscribe to Paper Chase by e-mail. JURIST offers a free once-a-day digest [sample]. Enter your e-mail address below. After subscribing and being returned to this page, please check your e-mail for a confirmation message.


R|mail e-mails individual Paper Chase posts through the day. Enter your e-mail address below. After subscribing and being returned to this page, please check your e-mail for a confirmation message.

PUBLICATION

Join top US law schools, federal appeals courts, law firms and legal organizations by publishing Paper Chase legal news on your public website or intranet.

JURIST offers a news ticker and preformatted headline boxes updated in real time. Get the code.

Feedroll provides free Paper Chase news boxes with headlines or digests precisely tailored to your website's look and feel, with content updated every 15 minutes. Customize and get the code.

ABOUT

Paper Chase is JURIST's real-time legal news service, powered by a team of 30 law student reporters and editors led by law professor Bernard Hibbitts at the University of Pittsburgh School of Law. As an educational service, Paper Chase is dedicated to presenting important legal news and materials rapidly, objectively and intelligibly in an accessible, ad-free format.

CONTACT

Paper Chase welcomes comments, tips and URLs from readers. E-mail us at JURIST@jurist.org