Investigation Report of Oasis Plc

Forensic Accounting
4/27/2010 Student number 2606062 ALI A SYED

Contents
Contents......................................................................................................................................2 Introduction................................................................................................................................3 Fact of the case.......................................................................................................................4 Analysis .....................................................................................................................................5 Roles and Responsibilities of the employees ........................................................................5 Stages of In estigation ..............................................................................................................! "re#in estigation ....................................................................................................................! In estigation...........................................................................................................................$ % idence.............................................................................................................................$ Inter ie&.............................................................................................................................' Reporting .............................................................................................................................(( )ista*es of %mployees....................................................................................................(2 %mployees &ea*nesses.....................................................................................................(2 Recommendation..................................................................................................................(3 Conclusion................................................................................................................................(4 +ibliography.............................................................................................................................(5

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Beyond reasonable doubt

Introduction
Every essential element of the crime charged must be proved by the government beyond reasonable doubt in order to convict and punish a defendant for the crime charged. The requirement of proof beyond a reasonable doubt is one of the most familiar legal standards in our society. However, courts and legal scholars have not reached a consensus on the e act definition of that important term! -.. /. 0ardner 1 Anderson 22234. 5asis is a public limited company6 and o&ns se eral media businesses6 such as ne&spapers6 radio station and maga7ines. It operates in many large mar*ets in Canada and 8nited States. .he company has managed to e9pand its operation by ac:uiring different business in past (2 years and still uses se eral of ac:uired business systems. ;ast year6 the company has centralised all its account payable operation6 &hich includes endor maintenance6 in oice processing6 purchase orders and chec* printing. +efore the centralisation6 the company had eight separate departments throughout subsidiaries that processed appro9imately $222 transactions per months. After the centralisation6 5asis made a cut do&n in staff members6 &hile the transaction being processed &as almost the same amount. In order to complete the centralisation process the company ac:uired the latest technology. .o be able to use this technology the entity held training session to ensure that management could use technology in an efficient and effecti e manner. .he technology includes database soft&are pac*age6 &hich allo&s the matching of purchase orders &ith in oices6 generating reports6 signature dollar limits6 segregation of processing duties and controlled endor list. % erything &as running smoothly for 5asis "lc6 until the fraud hotline recei ed a call from an anonymous caller &ho tip off that there is something fishy going on in the company<s higher le el of hierarchy.

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I am &riting this report on behalf of the fraud in estigators6 e9plaining the different issues6 problems and the e idence &hich &ere collected in order to come to a conclusion &hether the call &as a pran* call or it &ould really lead the in estigators to certain point &here they can =ustify their in estigation. .he in estigation &ill in ol e analysing the accounts payable department6 collecting the e idences -for e.g. chec*ing in oices6 purchase orders6 ban* statements and chec* printing4 and inter ie&ing employees. .he aim of the in estigation is to find out if the embe77lement really e9isted or some anonymous caller &as =ust &asting our time. If the embe77lement really e9ist ho& much damage has it done to the company> And &hat measure can be ta*en in the future to pre ent such from happening.

Fact of the case

Sandy +lan:uet is a senior manager in 5asis "lc and super ises accounts payable process. Sandy &as a financial controller at one of the ac:uisitions of 5asis "lc called ?aily ne&s6 he &as offered an opportunity to ta*e part in the centralisation process of 5asis6 &hich means Sandy6 *ne& the company accounts department inside out. Sandy maintained a high standard of li ing@ he dro e a nice car and li ed in a flashy home. .he anonymous caller is not sure &hether the embe77lement has been really done. .he person simply rang the hotline and mentioned Sandy<s name6 saying that he &anted to process an in oice from a company called ?esigning "lu76 but he &as rushing to get the &or* done insisting to o erride the normal &ay of processing these in oices.

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Analysis
Roles and Responsibilities of the employees
.he first part of in estigation in ol es analysing the accounts payable department6 this &ill in ol e finding out about the duties and roles of employees6 &or*ing in this department. .o &hat le el an indi idual is authorised and &ho are they reporting to. .he analysis sho&s that Sandy +lan:uet is a senior manager and he manages 22 employees through 4 super isors6 his responsibility is basically to manage the entire department. Ais =ob also included signing the chec*s of o er B5222 but belo& B52222 because abo e this amount Cice president<s signature is re:uired. ?espite managing the entire department6 Sandy<s system had fe& restrictions6 he &as not able to access the accounts payable data6 could not process any transaction6 edit endor list or print che:ues. As mentioned earlier he had to sign the che:ues for o er B52226 so in order to that he had to re ie& all oucher pac*ages re:uiring his signature. /ac* Cross is a senior associate at 5asis "lc and his =ob is to loo* after appro ed endor lists. If the department comes across a ne& endor its /ac*<s responsibility to erify this endor by completing the erification form6 and phoning the endor to erify their e9istence. )abali Smith is a accounts payable associate and she is responsible for processing in oices. And ensuring the signatures on the in oice are from an authorised person6 by chec*ing it from authorisation limits file. She reports to her senior associate Chris .opper6 &ho re ie&s her ouchers for posting. /uan Dam*aps is a super isor in the accounts payable department6 and is responsible for re ie&ing all the purchase order matching e9ceptions and to super ise fi e associates. /uan had the authority to o erride the matching e9ceptions. Similarly6 ?arlene +eau is also an employee at 5asis and her =ob is to print and to run afternoon chec* for all the oucher pac*ages.

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Rachel Dic*i is an associate and her responsibilities include processing supply in oices6 for paper6 in* and press materials. Aer =ob also included chec*ing the in oices in the system in order to ensure that the in oice is authorised by the correct person.

Stages of Investigation
.he stages of in estigation &ill in ol e the follo&ing@ "re In estigation In estigation Reporting Recommendation

Pre-investigation
"re#in estigation in ol es loo*ing for the documents directly related to the case. .he documents such as in oices6 purchase orders6 erification forms of ne& endors6 old and recent ban* statements and the endor list of 5asis "lc. .hese documents &ere supplied to us by arious members of staff of 5asis "lc. Since the anonymous caller mentioned the name of the company6 I had to filter the documents and narro&ed it do&n to the ones related to ?esigning "lu7. /ac* pro ided the in oice of ?esigning "lu7 &hich he had posted on the system6 I then got in touch &ith )abali Smith to get the same in oice in order to cross erify6 that the in oice &hich &ere gi en to me by both the employees had the same amount &ritten on it. I made a note of the ".5. +o9 number on that in oice. .he ne9t step &as to get hold on the ban* statement to chec* the irregularities in transfers. And finally I re:uired the purchase order of ?esigning "lu7 to find out &hat *ind of ser ices or in entory 5asis "lc had ac:uired from ?esigning "lu7. +ut there &as a t&ist in the story6 none of the staff members *ne& about the purchase order and no one in the management had e er seen the purchase order from ?esigning "lu7. .his is

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the point I realised that the phone call &as not a pran*6 but there &as something more to it6 then I started my in estigation. 5asis case is ery similar to the case of Robert and Eathy ;ang Albright &ho o&ned Atrium Foliage6 the company manufactured hi#end fau9 plants for hotels6 furniture stores6 offices and other customers. .he boo**eeper they hired as a regular employee6 and heFshe embe77led as much as B'526222 from their company. In order to in estigate the embe77lement Robert and Eathy ;ang Albright gathered hundreds of pages of chec*s6 bills purchase orders and in oices for the police and in estigators to sol e this matter. Eathy Albright says embe77lers are financial assassins6 and the term &hile collar criminal is too innocuous -)cClatchy 22(24.

Investigation
Aa ing completed the pre#in estigation6 my ne9t step &as to plan the field &or* associated &ith the in estigation itself. .his &ill in ol e re ie&ing internal control system6 coordinating acti ities &ith the client and obtaining necessary information from other specialists as appropriate6 throughout the in estigation process6 &hile being a&are of the right of the alleged perpetrators and personnel &ithin the scope of the in estigation and the reputation of the organisation -/ordan 22(24. Evidence I started my in estigation by first en:uiring about the ".5 +o9 &hich &as mentioned on that in oice6 I got in touch &ith the post office and tried to in:uire about the registration details of the ".5 +o9 mentioned on the in oice6 I &as told that this ".5 +o9 is registered on Sandy +lan:uet<s name. )y in estigation &as narro&ing do&n6 and I begun to collect the e idences beyond reasonable doubt. .he ne9t step &as to trac* do&n the purchase order from ?esigning "lu76 but after chec*ing the computer entries and paper&or* I failed to find the purchase order. .his &ould lead to an incomplete accounting entry &here goods or ser ices had been paid for but there &as no e idence of purchasing those goods or ser ices. After trying hard I couldn<t trac* the purchase order do&n6 so I decided to analyse the ban* statements in detail in order to find out6 &here &as the amount of B32452 transferred to> It &ould =ust say on the ban* statement6 the name of the endor ?esigning "lu76 I &anted to *no& bit more than that.

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So I decided to call the ban* on behalf of 5asis plc and find out about the transaction &ith ?esigning "lu7. .he ban*<s helpline told me it is a business account but it<s registered under the name of Sandy +lan:uet. Ghen I hung up I realised that my in estigation &as narro&ing do&n a bit more. +ut there &as more to it6 if the ban* account is under Sandy<s name6 ho& did he manage to get the chec* out of the door of 5asis "lc> Ae doesn<t ha e the authority to process in oices6 edit endor list or print che:ues> I began thin*ing to myself is there someone else in ol e in this apart from Sandy> A related case e9ample can be &here6 Dorth Caroline Central 8ni ersity has turned an ongoing internal audit o er to state regulators after disco ering e idence that a former uni ersity employee embe77led funds from a pro=ect funded in part by federal and state grants. DCC8 has found that the former director of the Aistorically )inority Colleges and 8ni ersities Consortium6 for &hich DCC8 &as a member and fiscal agent6 funnelled some of its funds into a personal ban* account -E. 0ardner 22(24. Interview In order to find out if someone else &as in ol ed in this case I had to inform the employees6 of 5asis<s accounts payable department6 that there &ill be an inter ie& held for 4 of the staff members directly related &ith this case. I made sure that I &as ta*ing notes &hile inter ie&ing these employees and also I ha e my oice recorder on6 =ust to ensure that I had maintained the le el of accuracy -+rennan 1 Aennessy 222(4. Jack Cross .he first employee I inter ie&ed &as /ac* Cross. Ae said &hen Sandy first came to him &ith the ?esigning "lu7 in oice@ he =ust as*ed him &hether the ?esigning "lu7 &as an appro ed endor. /ac* repliedH no they are not6 but do you &ant me to add them to endor list> Sandy said yes. )y ne9t :uestion to /ac* &as6 ho& did he *ne& that ?esigning "lu7 &as a erified endor did he chec* it out> /ac* replied6 usually &e follo& the normal procedure of filling in the erification form and calling the endor in order to erify their information6 +ut in ?esigning "lu7 case Sandy as*ed me not to bother filling in the erification form.

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.he second inter ie&ee &as )abali Smith. She says &hen Sandy approached her des*6 she &as on the phone to her husband6 and she got confused &ith Sandy<s presence and hung up. Sandy as*ed her to appro e an in oice from a Cice president in ;os Angeles6 she said she is not familiar &ith the signature of the Cice president. She began to run the authorisation limits file but Sandy stopped her6 by saying if he is a C" he is authorised up to B52222. She :uic*ly processed the in oice6 and said she &ill put this in Chris<s -)abali<s senior4 inbo9 and let him *no& it<s a rush =ob. She says Sandy stopped her from putting into Chris<s inbo9 and said that he &ill as* /uan to post it as he is &al*ing to&ards /uan<s cubicle. /uan Dam*aps In the inter ie& /uan said he has been &or*ing &ith Sandy for almost 5 years6 and &hen Sandy came to his cubicle they started the con ersation &ith casual greeting6 and then Sandy as*ed him to post an in oice from C" in ;os Angeles. /uan says &hen he attempted to post the in oice@ he didn<t find the matching purchase order for it. /uan said6 Sandy got irritated from the C" in ;A and as*ed /uan to o erride the purchase order matching process and post it. /uan says he listened to Sandy<s command and did e9actly the &ay Sandy &anted. ?arlene +eau ?arlene says@ Sandy phoned her and informed her that there &ill be a special che:ue in the afternoon run and since it &ould re:uire Sandy<s signature6 he &ould sa e her time by re ie&ing the oucher pac*age himself. ?arlene says she than*ed Sandy and didn<t bother re ie&ing the oucher pac*age herself as she *ne& it &as already re ie&d by Sandy. Rachel Dic*i Rachel said in her inter ie& that6 Sandy rushed into her cubicle6 and as*ed her to process an in oice from ;A printing site. She also said that he interrupter her in the middle of processing an in oice. She says she finished up &ith &hat she &as doing and as*ed6 &hy the rush> Sandy replied some C." in ;A printing site &ants it processed as soon as possible. Ghile studying the in oice6 she begun to open the authori7ation limit file but Sandy stopped her by saying that he does not ha e time for this. +ut didn<t stop the process6 and &hile it &as scanning she as*ed Sandy &hose signature is it Sandman or Iach an> Sandy replied that he appreciated Rachel<s insisting on processing this 3,"age

by the boo*6 but I really need this processed no&. .a*e my &ord for it6 he<s authorised. Rachel replied JGhen I process something6 my initials are input into the data record and I don<t put my name on anything unless it<s by the boo*K. She says@ Sandy snatched the in oice and &al*ed a&ay before she could finish. .he process of inter ie&ing the staff members6 &hile in estigating for embe77lement is often used by many fraud in estigators6 for e.g. Dorthern %9posure -&as a gentleman<s club featuring e9otic dancers. Its primary re enue sources &ere co er charges and food6 beer6 and li:uor sales. .his bar generated huge amounts of cash as there &ere no credit cards or che:ues accepted6 but the +ar 5&ner ;arry S&enson &asn<t happy &ith the margins of (2L6 he hired t&o fraud e9aminers in order to determine &hy the bar &as not generating 35L margins that he e9pected -+uc*off 1 Clifton 22(24. +y inter ie&ing the staff members at Dorthern %9posure6 the fraud in estigators learned that cash flo&ed into the business as follo&s@ Customers paid a B! co er charge to enter the club. Do receipt &as gi en6 nor &as a head count made. Customers placed orders for food or be erages &ith the ser ers. .he ser ers started out &ith B42 in a cash pouch. .hey paid the bartenders for their orders from this6 and then collected payment from the customer. At their shift<s end6 the ser er ga e the initial B42 bac* to the manager and *ept the difference as tips. At the end of the night6 the manager counted the cash and closed out the cash registers@ the cash &as deposited by the manager the ne9t morning. Changes in beer and li:uor in entory &ere not reconciled to the drin*s rung into the cash register6 nor &ere the register tapes reconciled to deposits listed on the ban* statements -+uc*off 1 Clifton 22(24. After inter ie&ing these employees one thing &as for sure that Sandy had manipulated these employees and used his in oice to be processed by different staff members. .his part of the case has many similarities &ith the Aendric* Aealth System -AAS4 embe77lement case &here the fa*e in oices &ere created. According to 8.S. Attorney Richard +. Roper6 52#year# old ;aura )inor # a former Aendric* employee and Abilene resident and 4'#year#old Sheri ;ynn )itchell # o&ner of a physician recruiting business6 engaged in a fa*e in oice scheme and defrauded Aendric* out of Mhundreds of thousands of dollars. )itchell &ould submit in oices to Aendric* Aealth System -AAS4 for physician recruiting ser ices that &ere not pro ided. )inor &ould cause the in oices to be paid by AAS. )itchell &ould then *ic*bac* to )inor amounts ranging from one#third to one#half of the payment. (2 , " a g e

)inor is alleged to ha e recei ed B2'36(2! in *ic*bac*s from )itchell6 &ho li es in Cle eland6 .enn. .he alleged embe77lement occurred bet&een April 2222 and Do ember 222$ &hile )inor &or*ed as an assistant in physician relations and later as director of physician recruiting for Aendric*. )itchell o&ned and ran "hysician Source6 a physician recruiting business -De&s 222'4

Reporting
.his section &ill focus on upon the *ey factors establishing ho& the embe77lement &as committed6 &ho committed and ho& much &as the damage to the company. I &ill also identify the &ays in &hich the embe77lement could ha e been a oided in future. Ghere there ha e been brea*do&ns in internal control or lac* of controls these could be highlighted and re ie&ed for future purposes. I ha e managed to collect e idences &hich are beyond reasonable doubt. Firstly6 the in oice &hich mentions the ".5 +o9 is registered on Sandy<s name. Secondly6 the ban* statements pro e that the amount ha e been transferred to Sandy<s cFo ?esigning "lu7 business account. And lastly6 the employees ha e clearly said in their inter ie& that Sandy has used his position and po&er to o errule the employees &or*ing under him and managed to embe77led the amount of B32452. A related e9ample of embe77ling the money can be &here6 former secretary at a +urns ille ?ry&all Company has been charged &ith embe77ling more than B$26222 from her employer through a ariety of means6 including &riting company chec*s to her mother. )ullen had a criminal history includes multiple con ictions for chec* forgery in ?a*ota County and Florida. She &as also charged the ;a*e ille &oman &ith t&o counts of chec* forgery and one count of financial card transaction fraud6 all felonies -)elo "ioneer 22(24. According to the in estigation Sandy has managed to beat the system by manipulating the employees &or*ing under him6 and ma*ing them do the tas*s6 o erriding the normal procedures. +ut at the same time /ac* Cross6 )abali Smith6 /uan Dam*aps did not follo& the normal procedures.

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ista!es of Employees /ac* Cross 5beyed Sandy<s command and failed to fill the erification form6 &here he could ha e called the number on in oice and erify the endor<s information. Ae added ?esigning "lu7 to the list &ithout e en gi ing it a second thought6 that there is no harm in chec*ing6 because if something goes &rong he might also get in trouble.

)abali Smith Firstly6 she &as ma*ing personal phone call at &or*6 noticing the presence of Sandy got her confused and in this confusion she honoured his command by not running the authorisation limits file to ma*e sure that the in oice &as appro ed. Secondly6 she didn<t put the in oice in Chris<s inbo96 for him to re ie& the ouchers for posting. /uan Dam*aps /uan also failed to &or* by the boo*s6 and he o errode the purchase order matching e9ceptions due to Sandy<s influence. Employees wea!nesses All the four abo e mentioned employees &ere &ea*ened because6 they &ere told to certain =obs by the head of their department. And since there &as no fraud policy introduced in the company on formal basis6 it &ouldn<t ha e clic*ed on any employee<s mind that not follo&ing the normal procedures and listening to their head of the department &ill cause financial damage to the company. .he employees &ere not trained enough to deal &ith such situation6 and &ere mislead by the higher authority thin*ing that the manager is more e9perienced and &ill al&ays tell his employees to do the right thing. If all of the employees &ho &ere in ol ed in this case should ha e follo&ed Rachael Dic*i<s strategy of &or*ing by the boo*s this embe77lement &ould ha e ne er ta*en place. Recent studies indicate that employee embe77lement has become so rampant that it accounts for the ma=ority of ordinary business losses suffered by employers. Some estimates indicate that more than B422 billion is stolen annually by employees in the 8nited States. Research has also sho&n that incidents of employee embe77lement are common regardless of a particular companyNs si7e or sophistication -Geinstein 1 R.Carnie 22(24. (2 , " a g e

Recommendation
If the company had the fraud policy &here they could ha e made their employees a&are off6 the employee &ouldn<t ha e made a mista*e of not doing their &or* by the boo*s. .he company should also ma*e all the employees a&are of the fraud hotline by ad ertising the hotline number. .his &ill create a&areness of and all the employees &ill thin* t&ice before o erriding the set procedures. Do&adays6 the fraud hotline is ery effecti e in order to pre ent fraud from happening or to in estigate fraud6 for e.g. .he Australian 0o ernment Ser ices Fraud .ip#off ;ine pro ides people &ith a place to report suspected fraud against Centre lin*6 )edicare6 the "harmaceutical +enefits Scheme or the Child Support Agency. )ost people are honest and use 0o ernment ser ices fairly6 but if a caller has information about someone &ho is misusing these ser ices they can contact .ip#off line. .he caller can remain anonymous6 and the information heFshe pro ide &ill assist in ensuring the ser ices support those &ho really need them -0o ernment 22(24. I &ould li*e to recommend 5asis plc@ they should ma*e their employees a&are from the induction day6 that each and e ery member of staff has to follo& the rules and regulations of the company6 and should process the in oices6 purchase orders and che:ues in a standard &ay. .hey shouldn<t rush themsel es =ust because they are recei ing an e9treme pressure from a senior member of staff. .he internal control should be more strong and there should be someone higher than Sandy in the Accounts payable department6 so if in future if the employees come across something similar they can report to the higher authority or as* their senior to get the appro al from higher le el of hierarchy.

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Also =ob rotation is ery important because &or*ing under the same manager and department creates familiarity threat and an unusual trust bet&een the manager and employee6 because /uan had been &or*ing &ith Sandy for so long6 he didn<t thin* that Sandy might get his &or* done by manipulation. If6 the company introduces =ob rotation6 for e.g. if there &as a ne& employee on /uan<s place he might not ha e listened to Sandy and &ould ha e not o erride the purchase order matching e9ception. Also the re ie& of ne&ly installed system is highly recommended6 because the system should not allo& /uan or anyone else to o erride the "urchase order matching e9ception. .he in oices &hich are being recei ed should be able to match the purchase order@ other&ise if the purchase order is missing the in oice should not be posted into the system. .his &ill gi e transparency in the department and &ill also pre ent from the embe77lement ta*ing place in the future.

Conclusion
According to the e idences gathered6 I ha e come to a conclusion that the funds of B32452 ha e been embe77led from the company. And the e idences gathered from this in estigation are beyond reasonable doubt and can be presented in the court to support the case of embe77lement of money from 5asis "lc. .he phone call to the fraud hotline pre ented the repetition of such embe77lement &hich &as suppose to be the amount of B(2345. In order to a oid such from happening in the future the company should re ie& the recommendation mentioned in this report and should introduce strict procedures.

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"ibliography
+rennan6 D. 1 Aennessy6 /.6 222(. "orensic #ccounting6 Round Aall ;td. +uc*off6 .. 1 Clifton6 /.6 22(2. %9otic %mbe77lingH In estigating off#boo* fraud schemes. $ar Theft. A ailable atH httpHFF&&&.bartheft.comFpostF%9otic#%mbe77ling# In estigating#5ff#+oo*#Fraud#Schemes.asp9 OAccessed April 2$6 22(2P. 0ardner6 E.6 22(2. DCC8 audit sho&s suspected embe77lement. %ocal &ews. A ailable atH httpHFF&&&.&ral.comFne&sFlocalFstoryF$345534F OAccessed April 2$6 22(2P. 0ardner6 ../. 1 Anderson6 ..).6 2223. 'riminal Evidence6 Cengage ;earning. 0o ernment6 A.6 22(2. Aendric* embe77lement caseH Fa*e in oices created. 'entrelin(. A ailable atH httpHFF&&&.centrelin*.go .auFinternetFinternet.nsfFaboutQusFfraudQho&.htm OAccessed April 256 22(2P. /ordan6 +.6 22(2. In estigation. )eloitte. A ailable atH httpHFF&&&.deloitte.comF ie&FenQDIFn7Fser icesFforensicsF'e'!2de3c$efd((2CgnC C)(22222ba42f22aRCR?.htm OAccessed April 256 22(2P.

)cClatchy6 C.6 22(2. +usiness Are prey to embe77lement. $loomberg $usiness wee(. A ailable atH httpHFFin esting.business&ee*.comFresearchFstoc*sFne&sFarticle.asp> docEeyR!22#22(22322(!33ER.RI+QQ+8SD%GSQ((323#(1paramsRtimestamp,, 23F22F22(2L224H33L22")L22%.,,headline,,+usinessesL22areL22preyL22to L22embe77lementL3AL22A/CL22e9clusi eL3AL22StrugglingL22company L22staggersL22fromL22theftL22O.heL22AtlantaL22/ournal#ConstitutionP,, docSource,,.heL22)cClatchyL22Company,,pro ider,, ACS8IR%)%?IA1tic*erRAT"H8S OAccessed April 256 22(2P. )elo "ioneer6 F.6 22(2. Secretary charged &ith embe77lement. #ll business. A ailable atH httpHFF&&&.allbusiness.comFcrime#la&Fcriminal#offenses#propertyF(425532!#(.html OAccessed April 2!6 22(2P. De&s6 R.6 222'. Aendric* embe77lement caseH fa*e in oices created. *eporter &ews your abilene online. A ailable atH httpHFF&&&.reporterne&s.comFne&sF222'F5ctF($Findictment#details#releasedF OAccessed April 2!6 22(2P.

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Geinstein6 ?. 1 R.Carnie6 +.6 22(2. In estigating %mployee %mbe77lement. "ind%aw. A ailable atH httpHFFlibrary.findla&.comF2223FFebF('F(32552.html OAccessed April 2$6 22(2P.

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