IN THE UNITED STATES COURT OF APPEALS
FOR THE ELEVENTH CIRCUIT
ATLANTA, GEORGIA
MICHAEL
HAROLD CHAPEL )
GDC
845840 )
Petitioner, Pro se )
Appeal No.
)
04-11939-B
v. )
)
)
HUGH
SMITH, Warden )
Georgia
State Prison )
Respondent )
MOTION
TO RECONSIDER, VACATE OR MODIFY THE COURT’S 23 AUGUST 2004 DENIAL OF
CERTIFICATE OF APPEALABILITY AND MOTION FOR LEAVE TO PROCEED ON APPEAL IN FORMA
PAUPERIS
CERTIFICATE OF INTERESTED PERSONS
Luther D. Thomas
Paula K. Smith
Thurbert Baker
Hugh Smith
Michael Chapel
Michael H. Chapel, Pro se
GDC 845840-B
Box 219 Wayne State Prison
Odum, GA 31555
CERTIFICATE
OF SERVICE
Mr. Hugh Smith, Warden
Georgia State Prison
Highway 147
Reidsville, GA 30499
Honorable Thurbert Baker
Attorney General
State of
Georgia
40 Capital Square SW
Atlanta, GA 30334
Respectfully Submitted this 10th Day of September 2004.
Michael H. Chapel, Pro se
GDC 845840-B
Box 219 Wayne State Prison
Odum, GA 31555
PLEADING
Now comes Michael H. Chapel, Appellant-Pro se, and files this motion for reconsideration, vacate or modify this Court’s order of 23 August 2004 by stating and showing the Court as follows:
This Court may issue a C.O.A. only if the Petitioner has “made a substantial showing of this denial of a constitutional right § 2253 © (2). This section codifies the standard originally set forth by the Supreme Court in Barefoot v. Estelle, 463 US 880 (1983). Slack v. McDaniel, 120 S.Ct 1595, 1603 (2000); Hardwick v. Singletary, 122 F.3d 935, 936, vacated in part on other grounds, 126 F.3d 1312 (CA11 1997).
Consequently, in order to obtain a COA, Petitioner must “Demonstrate that the issues are debatable among jurists of reason; that a court resolve the issues in a different manner; or that the questions are ‘adequate to deserve encouragement to proceed further.’” Lozada v. Deeds, 498 US 430, 432 (1991), (Quoting Barefoot v. Estelle): Accord Slack, 120 S.Ct at 1603-04; Henry v. Dept. of Corrections, 197 F.3d 1361, 1364-65 (11th Cir 1999).
If the Court has rejected the Petitioners Constitutional claims on the merits, a COA should issue if the Court’s assessment would be debatable among jurists of reasons. See Slack, 120 S.Ct at 1604.
If the Court has dismissed the petition on procedural grounds without reaching the merits, the Petitioner must not only show that the procedural ruling is debatable among jurists of reason, but also hat the petition arguably states a valid claim of the denial of a constitutional right Id.
This Court held in its 23 August 2004, order in relevant part:
Because his petition is plainly barred by § 2244’s one-year statute of limitations, Appellant has failed to satisfy the second prong of Slack’s test.
Appellant respectfully contends that he has satisfied the second prong of Slack’s test. Appellant contends that his § 2254 petition and brief in support and for reasons articulated below present issues that are debatable among jurists of reason.
Unlike Slack, the Appellant’s case shows substantial denial of constitutional rights, a denial of due process, and evidence of gross prosecutorial and police misconduct that rates prosecution in itself.
UNDERLYING
CONSTITITUTIONAL CLAIM
The merits of the underlying claim are as follows. New evidence, rescued from a complex cover-up since trial have never before been presented before a panel of jurors, reasonable or otherwise, and the state has at every point conducted illegal actions to maintain the state’s nefarious victory at trial. That per this Honorable Court’s own standards and those of the U.S. Supreme Court, rectifying these obvious errors and providing the basic constitutional rights to the Appellant’s pleadings seems essential.
This Court held in US v Reed[1]: “To hold that in order to obtain a new trial based on newly discovered evidence the Court must be satisfied that:
1) The evidence must be discovered following the trial[2].
On 06 March 1996, a child playing in the woods behind the trailer that the victim and her son had lived and in which the son continued to live for some time after the murder.
“Things to ask Mike[3] about:[4]”
· Describe his mother’s pocketbook.
Pocketbook was crème colored – 3 zipper – double strap over shoulder
Burgundy or black purse, snap open, and checkbook in wallet.
· Describe his mother’s jewelry. (None described in notes.)
The purse and its contents were identified as to have belonged to the victim. Also it should be noted from the investigators record above, police waited over a month to get around to asking what the description was of the alleged stolen purse. This delay was not unusual in this case that has best been described as rife with shoddiness to the point of being criminal.
Gwinnett County police and the Georgia State Crime Lab would go on to conduct extensive forensic tests on the purse and its contents[5]. The forensic information collected from the victim’s purse showed no latent prints that would link the Appellant to the crime. More importantly, no blood evidence of any kind was found on the purse or its contents, indicating the purse had been nowhere near the crime scene. At trial the missing purse would assume a massively important part of the Prosecution’s case.
From the first part of his closing came the following:
And
on the night of April the 15th, he lured her to the Gwinnco Muffler on the
pretense of continuing to work her case.
He was running the boo. And he
got her out there at about nine-thirty or nine-forty that night, and with two
shots, he ended her life. He stole her
money, and in the process of taking the money out of her purse, he transferred
her blood to the seat of his patrol car, and then he left. And he left and had the misfortune of
driving by Karl Kautter. He went on --
he got a call. He went on to the call, but
he left, saying he had problems of his own.
And he did.
And
within days -- as a matter of fact, the next day -- he was spending his
ill-gotten gains, which was in the form of hundred-dollar bills. He was spending it at car washes. He was buying T-shirts. He had money to spare. In fact, the evidence has shown there was
almost five thousand dollars. I said in
my opening statement twenty-three hundred, but the evidence has shown there was
almost five thousand dollars in unaccounted for funds that Michael Chapel had
in the week after the murder of Emogene Thompson.
And,
ladies and gentlemen, as we said in our opening statement, the state intended
to prove the guilt of the defendant beyond a reasonable doubt through the
presentation of credible, believable, convincing evidence. And when I come back and talk to you in the
last part of my argument, we'll go into that in detail, and we'll talk about
it, and you will be as sure as you can that the defendant is guilty beyond a
reasonable doubt. Thank you.
Mr. Porter put his prestige on the line when he maintained the purse not only contained the money alleged to have been stolen by the Defendant, but he, District Attorney Porter could find no other possible mechanism for the transfer of blood between the victim’s automobile and the Defendant’s police vehicle[6]. The effect upon the jury of this non-existent evidence was enormous, and this was not the only time that the DA used non-existent evidence to confuse then over-power his jury.
(State’s Closing, TR 6664 lines 18-22)
What better way to conceal a
crime? What better way to give you time to get away. To throw the gun[7]
away, to throw the purse away[8],
to pocket the money and leave the police with only evidence you can’t dispose
of, and that’s what happened on the night of the 15th.”
This Court said in Eyster: “Implying the existence
of additional evidence not formerly before the jury severely impairs the
likelihood of a fair trial.”
The finding of the purse is very material. It is the foundation of the state’s entire argument by trumpeting its existence under their imagined scenarios. Without the evidence, the Appellant had no right to rebut, confront or as the evidence shows, demonstrate the exculpatory conclusions the crime labs came up with. This behavior is compounded by the time it took for the police to make known to the Appellant the existence of this critical new evidence. The police were aware of it on 06 March 1996, some 6 months after the end of the trial, yet for some reason(s) did not make it known until 22 November 1966, and then only by accident.
This delay seems to be only to deny the Appellant due process and his constitutional rights. It seems no accident this critical evidence was withheld deliberately until after 24 April 1996 when A.E.D.P.A. was enacted. To which this count denies the Appellant final justice with:
If there is significant
chance that the withheld evidence developed by a skilled[9]
counsel would have induced a reasonable doubt in the minds of enough jurors to
avoid a conviction, then the judgment of conviction must be set aside. U.S.
v. Augurs 96 S.Ct. 2405.
This evidence, not heard by a jury exposed to the entirety of the trial, in itself raises questions of its probative value. The only measurement to date of it has been the Georgia Supreme Court’s brief opinion from 1998’s appeal. Even working with the weak petition of the Appellant’s counsel said:
The evidence provides some support for the Defense argument that Michael Thompson was involved in the murder. Chapel v. State, 270 151, 510 S.E.2d 802 (1998) p.4.
With this astute observation of the evidence by its own weight, the court omitted the major forensic scope: no blood evidence on the purse or contents.
Again, Chapel v. State, p.4: “The victim’s purse was found in 1996 where the victim and her son lived and had been searched by police in 1994 after Chapel’s incarceration.
The “search” testified to would prove to be typical of the quality of this investigation. It wasn’t until 06 Nov 2000 that scientific evidence was obtained through continued dilegnce of the Appellant in the form of a report from the U.S. Naval Observatory Astronomical Applications Department. This report states for 01 April 1994, the day the “search” was conducted for evidence of the crime behind the victim’s residence in the heavily wooded area (see S.H.C. photo evidence 7.01 and 7.02), the investigator stated in his report (see Ground VII S.H.C.] a “thorough” search was done by himself and one other of the large wooded area, to which the N.O.A.A. report for this day shows Sunset being at 6:57 PM and full dark (end of civil twilight) at 7:22 PM.
The search “team” that met approximately 2 miles from the search location at 1810 hours (6:10 PM). On arrival, the team canvassed both sides of the quarter mile long street first interviewing residents, then finally began a search of the five plus acre site which, by then, could have had to have been in complete darkness.
This does not surprise. It is this same attitude toward evidence that did not even ask for a description of the item of blood transfer, the purse, for a month after the crime. He same disregard of constitutional rights that allowed the most probable murder weapon to be destroyed while still untested, and the same criminal behavior that “lost” the .38 caliber shell found at the victim’s residence and who ordered processing of film from the Appellant’s intelligence operations only to “lose” the items. But all this was litigated in state courts, wrongly, but heard. The Appellant begs this Court to allow the new evidence to be heard by reasonable jurors along with the questionable evidence the state was allowed to prejudice the jury with at trial. As shown, the state used the purse as unseen evidence as this Court rule in US v. Mclain, US v. McLain 823 f.2d 1462 (11th Cir 1987) [2]. Appellant points out even the state recognized at trial the son’s involvement in crimes against his mother. In the States closing:
The events of April 1993
show clearly that Emogene Thompson had $14,000 that she hid away for whatever
reason and that half of it was stolen from her, probably by her son. I think
after hearing the testimony it is probably reasonable to believe that Michael
Thompson stole the money. You can almost that beyond a reasonable doubt.
Not only the prosecution, but the jury as well had its own misgivings right up to the last day of testimony. A Juror sent word to the judge and the trial halted to investigate possible jury misconduct. The juror stated she once heard others saying out loud on this last day of testimony during a break:
He commented that he thought
Mr. Chapel the Prosecution was being railroaded. [TR 6162, Line 19 – Juror
McAfee]
This Court saw in U.S. v. Blakely[10]:
The circumstances
surrounding the jury’s deliberations demonstrate the evidence of Blakely’s
guilt was not overwhelming when reviewed in the context of the entire trial. We
conclude that the Prosecution’s comments caused prejudice to Blakely and
requires a new trial. [1562]
The argument this Appellant makes is that this Court can and must assess the probative force of this newly presented evidence in connection with the evidence in connection with the evidence of guilt adduced at trial[11].
THE
STATE’S PLAN TO USE TELEPHONE RECORDS
One of the most bizarre aspects of this case was the state’s prompt recognition of the importance of telephone records that could presumably be used to incriminate the Appellant since according to the hearsay evidence elicited the Appellant used the telephone extensively to lure Mrs. Thompson to the Gwinnco Muffler Shop Driveway where he murdered and robbed her.
The following entries appeared in chief Inspector Burnette’s notes dealing with such telephone calls[12]:
Wednesday, 21 April 1993: 8:45 AM Talked to
Glen T. will check on the phone record.
Thursday, 29 April 1993 Got list at Fire 14 for subpoena.
(Capt. Davis to Glen)
10 May 1993 (35)
Check on the guy in social circle with Powell on telephone records.
Last Page (Get
officers home and business phone numbers. Check with Southern Bell about
subpoena notification.
16 Apr. 93 Subpoena
telephone records March – Present 932-1386.
Subpoenas were issued to Southern Bell Telephone for telephone records during that period for telephones in the Northside Precinct, phones located at the Fire 14 Firehouse, the Appellant’s home and place of business, Emogene Thompson’s home, and perhaps others as well. As an aside, these records showed no telephone contact between the Appellant and the victim, Emogene Thompson over any of this period. Once it because clear to District Attorney Danny Porter and others realized that the telephone records were if nothing exculpatory, most interest in any kind of plans to use the records against Chapel were abandoned, and the District Attorney would argue vociferously against the admission of the records into the records of the trial. These records were not only exculpatory, they indicated a range of bad news for the prosecution ranging from suspicious plots to what would turn out to be the impeachment at trial of critical prosecution witnesses. The original records from Bell South undoubtedly qualified as admissible “business records” and their full extent has never been realized. Yet they were never given to the defense, a pure Brady violation.
Appellant would ask this court to review
or allow an evidentiary hearing so as the Appellant might show what was denied
him at trial to present before his jury. That the state obviously held the
records in high importance as the above indicates, no jury or court should be
denied seeing these potentially startling results:
1.
No
telephone contact between the victim and Appellant occurred.
2.
There
are no telephone contacts reported between the victim and any hearsay witnesses
who testified under oath to extensive telephone conversations.
3.
The
victim’s son disavows any knowledge of a certain pager number, yet when
confronted by the Appellant about returning his mother’s money, the son dialed
that number continuously during the entire night. The son would again dial that
number several times on the night of his mother’s murder after the time the
state alleged the murder had taken place. Under oath, he would any making any
phone calls.
4.
On
08 April 1993, the Appellant was subject to an FBI/Police sting when offered
$20,000 at his place of business. Appellant followed correct police procedure
and reported the seeming bribery attempt even though no one except a former
colleague appeared to be available to take a report.
5.
On
th night of the murder, the Thompson neighbor, Amy Parker, reported that she
went to the Thompson’s to make a phone call. No such phone call was reported.
Keith Seay, Parker’s roommate verified this making Parker the last person see
the victim alive. Seay was not called at trial to testify to this.
This Court[13] has clearly indicated:
If the omitted evidence
creates a reasonable doubt that did not otherwise exist, constitutional error
has been committed. This means that the omission must be evaluated in the
context of the entire record. If there is no reasonable doubt about guilt
whether or not the additional evidence is considered, there is no justification
for a new trial. On the other hand if the verdict is already of questionable
validity, additional evidence of relatively minor importance might be
sufficient to create reasonable doubt.
Surely this Court sees the questionable validity of the new evidence unseen by jurors. When considered in context with the record, all presented here constitute major importance toward showing the Appellants actual innocence and his denial by the state of his constitutional rights.
Should the court reconsider the Appellants pleading and entertain these new evidence claims? Appellant prays this honorable court would review and see how error in the rulings of the fabricated raincoat evidence and suspicious 40 nanograms of the victim’s alleged blood was allowed to prejudice and taint the jury at trial.
THE LAW
First and
most important, Petitioner appears before this Honorable Court with “clean
hands”. The same cannot be said for those who for their own reasons seek to
keep Petitioner buried in prison where they believe he cannot damage them.
Second, Petitioner contends that the overwhelming sense of the case law
considered is that before a procedural default is considered, justice requires
judges, in order to avoid a miscarriage of justice, to seriously consider the
evidence brought to that court by the petitioner. Third, Petitioner has brought
a mountain of exculpatory evidence before these habeas courts and so far only
one ground, the ineffective assistance of the appellate counsel, has been
litigated. The remainder of this evidence has been dealt with by quips, sarcasm
or generalities like “just a rehash” which mean nothing. Not a single point
brought by Petitioner to these courts has been seriously challenged. Do the
courts not realize that their headlong dash to embrace the concept of “procedural
default” can result in their jobs being outsourced to India, or somewhere else
even more obscure, because the great skills and experience they bring to
judicial responsibility are not needed? Finally, Petitioner realizes that his
case is an anomaly and poses the question: “Can a conviction that is now proved
to have been obtained using criminal means, and only criminal means, remain
valid?”
Petitioner
can see no better way to support his cause then to repeat some of the legal
argument previously placed before the habeas courts for consideration.
PROCEDURAL
DEFAULT
In his Georgia state habeas corpus petition, Petitioner
submitted sixteen grounds and all save one, “Ineffective Assistance of
Appellate Counsel”, were procedurally denied because of relitigation
and failure
to raise bars. Now again, Petitioner’s federal habeas corpus
petition is in danger of denial because of the AEDPA procedural default. Such a
denial will render impotent the massive body of evidence, showing State and
other misconduct and other grounds, accumulated by Petitioner since the early
months of the year 2000 and is still under construction. Procedural denial then
seems to take precedent over the factual predicates of grounds of which
Petitioner was not aware until years had elapsed since his trial.
Writing in Massaro
v. United States[14][11], Justice Kennedy describes the
“procedural default” rule as an almost administrative function that could be
carried out by clerks if blindly followed. Although speaking of a claim of
ineffective assistance of counsel, his remarks doubtless can be extended to all
type of grounds:
The background for our discussion is the
general rule that claims not raised on direct appeal may not be raised on
collateral review unless the petitioner shows cause and prejudice. See 
United States v. Frady, 456
U.S. 152, 167-168
(1982); Bousley v. United States,
523 U.S. 614, 621-622
(1998). The procedural default rule is neither a statutory nor a constitutional
requirement, but it is a doctrine adhered to by the courts to conserve judicial
resources and to respect the law's important interest in the finality of
judgments. We conclude that requiring a criminal defendant to bring ineffective
assistance of counsel claims on direct appeal does not promote these
objectives.
Justice
Kennedy then Quotes Judge Easterbrook from Guinan:
As Judge Easterbrook has noted,
"[r]ules of procedure should be designed to induce litigants to present
their contentions to the right tribunal at the right time." Guinan,
supra, at 474 (concurring opinion). Applying the usual procedural
default rule to ineffective assistance claims would have the opposite effect,
creating the risk that defendants would feel compelled to raise the issue
before there has been an opportunity fully to develop the factual predicate for
the claim. Furthermore, the issue would be raised for the first time in a forum
not best suited to assess those facts. This is so even if the record contains
some indication of deficiencies in counsel's performance. The better reasoned
approach is to permit ineffective assistance claims to be brought in the first
instance in a timely motion in the district court under § 2255. We hold that an
ineffective assistance of counsel claim may be brought in a collateral
proceeding under § 2255 whether or not the petitioner could have raised the
claim on direct appeal.
Justice
Kennedy again goes on:
Even meritorious claims would
fail when brought on direct appeal if the trial record were inadequate to
support them. Appellate courts would waste time and resources attempting to
address some claims that were meritless and other claims that, though
colorable, would be handled more efficiently if addressed in the first instance
by the district court on collateral review. See, e.g., United States
v. Galloway, 56 F.3d at 1241 ("threat of . . . procedural bar has
doubtless resulted in many claims being asserted on direct appeal only to
protect the record . . . unnecessarily burden[ing] both the parties and the
court . . . "). This concern is far from speculative. The Court of Appeals
for the Second Circuit, in light of its rule applying procedural default to
ineffective assistance claims, has urged counsel to "err on the side of
inclusion on direct appeal," Billy-Eko, supra, at 116.
THE ENDS OF JUSTICE
[3](b) Unless it acts to
avoid a miscarriage of justice as defined by this Court's habeas
jurisprudence, a federal court of appeals abuses its discretion when it sua sponte recalls its mandate to revisit the merits
of an earlier decision denying habeas relief to a state prisoner. This [523 U.S. 540]
standard is altogether consistent with AEDPA's central concern that the merits
of concluded criminal proceedings not be revisited in the absence of a strong
actual innocence showing. The rules applicable in all cases where the court
recalls its mandate further ensure the practice is limited to the most rare and extraordinary case.
Moreover, like other applicable habeas standards, this rule is objective
in content, well defined in the case law, and familiar to federal courts. McCleskey,
499 U.S. at 496.
Pp. 558-559.References\mckleskey v zant
hearing.htm
JUSTICE POWELL, joined by
THE CHIEF JUSTICE, JUSTICE REHNQUIST, and JUSTICE O'CONNOR, delivered an
opinion with respect to Parts II and III, concluding that the Court of Appeals
erred in holding that the "ends of justice"
would be served by entertaining respondent's present "successive"
petition for habeas corpus, and
that the District Court and the Court of Appeals should have dismissed this
successive petition under 28 U.S.C. § 2244(b) on the ground that the prior judgment
denying relief on respondent's identical Sixth Amendment claim was final. Sanders v. United States
derived its "ends of justice" test directly from language of the
then-applicable statute, and left for another day the task of defining the
considerations that properly support a decision to entertain a successive
petition. Although § 2244(b) makes no reference to the "ends of
justice," that phrase still may be used generally to describe the standard
for identifying those cases where successive review may be appropriate. However, specific guidance should be given to the federal
courts as to the kind of proof that a state prisoner must offer to establish
that the "ends of justice" will be served by relitigation [477 U.S. 438] of claims
previously decided against him. Balancing the State's interests in finality of
convictions and the prisoner's interest in access to a forum compels the
conclusion that the "ends of justice" are served by successive review
only where the petitioner supplements his constitutional claim with a colorable
showing of factual innocence. The prisoner must make his evidentiary showing even though -- as
argued in this case -- the evidence of guilt may have been unlawfully admitted.
Here, the Court of Appeals conceded that the evidence of respondent's guilt
"was nearly overwhelming," and respondent's constitutional claim did
not itself raise any question as to his guilt or innocence. Pp. 444-455.
In decisions
of the past two or three decades construing the reach of the habeas
statutes, whether reading those statutes broadly or narrowly, the Court has
reaffirmed that "habeas corpus has traditionally been regarded as
governed by equitable principles." Fay v. Noia,
372 U.S. 391, 438
(1963), citing United
States ex rel. Smith v. Baldi, 344 U.S.
561, 573
(1953) (dissenting opinion). See
Stone
v. Powell, supra, at 478,
n. 11. The Court uniformly has been guided by the proposition that the writ
should be available to afford relief to those "persons whom society Fay v. Noia
has grievously wronged" in light of modern concepts of justice., supra, at 440-441.
See Stone v. Powell, supra, at 492,
n. 31. Just as notions of justice prevailing at the inception of habeas
corpus were offended when a conviction was issued by a court that lacked
jurisdiction, so the modern conscience found intolerable convictions obtained
in violation of certain constitutional commands. But the Court never has defined the scope of
the writ simply by reference to a perceived need to assure that an individual
accused of crime is afforded a trial free of constitutional error. Rather, the
Court has performed its [477 U.S. 448] statutory task through a sensitive weighing of the
interests implicated by federal habeas corpus adjudication of
constitutional claims determined adversely to the prisoner by the state courts.
E.g., Engle
v. Isaac, 456 U.S. 107, 126-129
(1982); See Stone
v. Powell, supra, at 489-495;
Fay v. Noia, supra, at 426-434.{8}
[3](b) Unless
it acts to avoid a miscarriage of justice as defined by this Court's habeas
jurisprudence, a federal court of appeals abuses its discretion when it sua sponte recalls its mandate to revisit the merits
of an earlier decision denying habeas relief to a state prisoner. This
[523 U.S. 540] standard is altogether consistent with AEDPA's central concern
that the merits of concluded criminal proceedings not be revisited in the
absence of a strong actual innocence showing. The rules applicable in all cases where the court
recalls its mandate further ensure the practice is limited to the most rare and
extraordinary case. Moreover, like other applicable habeas standards,
this rule is objective in content, well defined in the case law, and familiar
to federal courts.
McCleskey, 499 U.S. at 496.
Pp. 558-559.
1. To show
"actual innocence" one must show by clear and convincing evidence
that, but for a constitutional error, no reasonable juror would have found the
petitioner eligible for the death penalty under the applicable state law. Pp. 338-347.
[1](a)
Generally, a habeas petitioner must show cause and prejudice before a
court will reach the merits of a successive, abusive, or defaulted claim. Even if he cannot meet
this standard, a court may hear the merits of such claims if failure to hear
them would result in a miscarriage of justice. See,
e.g., Kuhlmann
v. Wilson, 477 U.S. 436. The
miscarriage of justice exception applies where a petitioner is "actually
innocent" of the crime of which he was convicted or the penalty which was
imposed. While it is not easy to define what is meant by "actually
innocent" of the death penalty, the exception is very narrow, and must be
determined by relatively objective standards. Pp. 338-341.
Michael H. Chapel, Pro se
GDC 845840-B
Box 219 Wayne State Prison
Odum, GA 31555
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