Balkinization  

Sunday, January 23, 2005

Heather Mac Donald's "Few Bad Apples" Theory of Abuse

Marty Lederman

A couple of weeks ago, I posted a short critique of a recent article by Heather Mac Donald in the Manhattan Institute’s City Journal. Ms. Mac Donald has replied to my post on the City Journal website, and has asked that I link to her reply here, a request that I am happy to oblige.

Ms. Mac Donald’s principal argument in her reply is that the confirmed and alleged abuses at Abu Ghraib (and presumably also those in Afghanistan and Guantanamo) were not the result of Administration decisions in Washington about how to construe the law to permit severely coercive forms of interrogation of detainees, but instead were caused by the failure of “grunts on the ground” to adhere to the official policies that the Pentagon had promulgated. More specifically, Ms. Mac Donald argues that if interrogators had only limited themselves to the 24 specific techniques approved in Secretary Rumsfeld’s April 16, 2003 Memorandum, the torture scandal as we know it would never have occurred.

In sum, Ms. Mac Donald’s story is that the Pentagon developed a measured and reasonable protocol for interrogation; but that a bunch of bad apples ruined everything by going far beyond what the Pentagon had authorized. “The abuse in Iraq resulted from a violation of the rules, not from compliance with them.”

Before addressing Ms. Mac Donald’s very selective and misleading account, I think it’s important to emphasize that she and I appear to agree on at least two things:

First, my principal focus in posts here over the past couple of weeks has been the law as it applies to CIA interrogations, and the fact that the Administration has authorized the CIA to engage in cruel, inhuman and degrading treatment—just short of statutory “torture”—of non-Geneva-protected detainees outside the United States. In her original article, Mac Donald basically agrees: She reports that, according to “a former Justice Department official,” the CIA has been authorized to use techniques as extreme as waterboarding, i.e., submerging a detainee in water to induce the sensation of drowning. Beyond that, Mac Donald concedes that “[t]he CIA’s behavior remains a black box.” Mac Donald also agrees that the 2002 OLC Memorandum on the torture statute was intended to guide CIA conduct, that the memo was “hair-raising,” and that it “understandably caused widespread alarm.” She goes on to argue that the OLC Memo “had nothing to do” with the interrogation “debates and experiments unfolding among Pentagon interrogators in Afghanistan and Cuba,” and had no connection to the abuses at Abu Ghraib, or to the extreme methods of military interrogation that have been alleged at Guantanamo and elsewhere. I think that’s mistaken, for reasons I’ll explain below; but, in any event, Mac Donald and I do not disagree on the story about the CIA that’s at the heart of my series of posts—an account that has now been confirmed in Judge Gonzales’s answers to the Senate Judiciary Committee and in an L.A. Times story today that largely reiterates what I’ve been writing here (with the addition of a few quotations from John Yoo that confirm the basic gist of the CIA story).

Second, I do not disagree that if Rumsfeld’s April 16th Memorandum were the be-all and end-all that Mac Donald makes it out to be, we wouldn’t be having this torture debate today. The Rumsfeld Memo refers to all sorts of purported bureaucratic safeguards, and requires at a minimum that all detainees be treated humanely. I am skeptical about whether Rumsfeld sincerely believed that all of the approved techniques could consistently be applied “humanely.” But be that as it may, and assuming for the sake of argument that humaneness truly were an absolute requirement, then I agree that had the Administration not in practice gone beyond the letter of that April 16th memo, it’s unlikely we’d presently be faced with the legal questions and moral dilemmas that I and others have been discussing.

But, of course, the Administration has gone far beyond the April 16th Rumsfeld memo. Is the Pentagon itself responsible for this? Or should officials in Washington be shocked and outraged that operatives in the field have so cavalierly ignored Rumsfeld’s parameters? Truth be told, I am not very interested in assigning blame for what has happened thus far. That is a role better served by others who have much more access to the relevant information and who can put the historical pieces together much more accurately and comprehensively than I can hope to do. My objectives, instead, have been to try to ascertain just what the current policies and practices are, to untangle the Administration’s view of what current law permits, and to encourage a public debate about what the law ought to be, going forward.

Nevertheless, Ms. Mac Donald's specific argument warrants a few responses:

1. By their terms, the Rumsfeld rules were supposed to be limited to Guantanamo, where (according to the President) Geneva protections did not apply. Thus, Ms. Mac Donald claims that the Rumsfeld-approved techniques were used on only one detainee (Kahtani), that “the decision on the Geneva conventions was irrelevant to interrogation practices in Iraq,” and that “[e]veryone in the military chain of command emphasized repeatedly that the Iraq conflict would be governed by the conventions in their entirety.” We now know that to be wrong. Judge Gonzales has acknowledged the Administration’s determination that suspected insurgents in Iraq, like al Qaeda operatives, are not entitled to Geneva protection—which, among other things, presumably means that the CIA is free to use cruel, inhuman and degrading techniques on Iraqi insurgents, too (although this is not yet clear—in particular, we do not yet know how, if at all, the Administration is implementing Geneva Common Article 3 in Iraq). And Ms. Mac Donald herself begins her reply by citing chapter and verse of the Interrogation Rules of Engagement that were provided to all interrogators and soldiers in Iraq—rules that not only incorporate the techniques approved in the Rumsfeld April 16th memo, but also additional techniques (e.g., three days of sensory deprivation; 45 minutes of "stress position; isolation for more than 30 days) that go beyond Rumsfeld's rules -- and, therefore, well beyond what Geneva would allow and what has been permitted in the Army Field Manual for decades.

2. As applied by the military—even at GTMO—the Rumsfeld-approved techniques were not nearly so benign as they appeared on paper. For example:

-- Rumsfeld approved adjusting sleep cycles but not sleep deprivation. And yet the military reportedly employed prolonged sleep deprivation at GTMO. And in Iraq, the combination of the "sleep management" and "stress positions" techniques approved in the Rules of Engagement provided to all interrogators and soldiers in Iraq led to instances in which hooded detainees were required to stand still on a box for hours, which can lead to excruciating pain and disorientation. Thus, as Phillip Carter has suggested, the most iconic image from Abu Ghraib--that of a man standing hooded on a box with wires attached--was most likely an amateurish attempt by untrained MPs to implement two of DoD's approved techniques (sleep deprivation and stress position)--techniques that Ms. Mac Donald somewhat shockingly invokes on the very first page of her reply in support of her thesis that officially sanctioned techniques were moderate and reasonable.

-- Rumsfeld approved altering the environment to “create moderate discomfort.” At GTMO, that was translated as tormenting prisoners by chaining them to a low chair for hours with bright flashing lights in their eyes and audio tapes of Lil' Kim, Rage Against the Machine and Eminem played loudly next to their ears (or in some cases a tape mix of babies crying and the television commercial for Meow Mix in which the jingle consists of repetition of the word "meow");

-- Rumsfeld approved “false flag,” i.e., “convincing the detainee that individuals from a country other than the United States are interrogating him.” At GTMO, that apparently meant convincing detainees that they were being interrogated by individuals likely to torture them (i.e., effectively a threat of torture); and in at least one case, the “convincing” consisted of tranquilizing a detainee, placing him in sensory deprivation garb with blackened goggles, hustling him aboard a plane that was supposedly taking him to the Middle East, and bringing him (unknowingly) back to GITMO, where he was put in an isolation cell and there subjected to harsh interrogation procedures that he was encouraged to believe were being conducted by Egyptian national security operatives.

Did the Pentagon condemn and punish these applications of the Rumsfeld techniques—which almost certainly violate the UCMJ, not to mention the President’s “humaneness” directive? Encourage them? Turn a blind eye? We don’t yet know for certain.

3. What explains the considerable gap between the Rumsfeld rules as written and the rules as applied? Well, to begin with, the Rumsfeld April 16th Memo was hardly the only guidance that was provided within the military. As I’ve previously recounted, the Fay, Jones and Schlesinger Reports explain in detail that the “existence of confusing and inconsistent interrogation technique policies,” including a “proliferation of guidance and information from other theatres of operation,” and the fact that personnel involved in interrogation in GTMO and Afghanistan “were called upon to establish and conduct interrogation operations in Abu Ghraib,” all contributed “to the belief that additional interrogation techniques were condoned in order to gain intelligence” (Jones 15-16; Fay 8, 10, 22). “The lines of authority and the prior legal opinions blurred” (Fay 10), and “DoD’s development of multiple policies on interrogation operations for use in different theatres or operations confused Army and civilian Interrogators at Abu Ghraib” (Fay Finding No. 7).

4. One prime example of this was Rumsfeld’s own approval on December 2, 2002 of much more severe techniques—including hooding, forced nudity, grabbing, poking and pushing, and the use of dogs “to induce stress.” To be sure, Rumsfeld rescinded that approval on January 15, 2003. But, more importantly, he did not, as far as we know, ever rescind his conclusion that these techniques were lawful. To the contrary, in that same January 15th memo, Rumsfeld specifically noted that the techniques could be used in a particular case if adequately justified and approved by Rumsfeld himself. Rumsfeld nowhere explained how such techniques could possibly pass muster under the UCMJ or the President’s February 2002 directive.

5. Even more telling is the November 27, 2002 memorandum of DoD General Counsel William Haynes, in which Haynes relates to Rumsfeld his conclusion—which was approved by a Deputy Secretary, by Doug Feith, and by General Myers—that not only the techniques Rumsfeld approved on December 2d, but also the following techniques, were “legally available”:

-- “The use of scenarios designed to convince the detainee that death or severely painful consequences are imminent for him and/or his family”:

-- “Exposure to cold weather or water (with appropriate medical monitoring)”; and

-- “Use of a wet towel and dripping water to induce the misperception of suffocation.”

Let’s be very clear about this: The DoD General Counsel (who’s recently been renominated for a seat on the U.S. Court of Appeals for the Fourth Circuit) concluded that threats of killing a detainee’s family members, and waterboarding, and forced nudity, and the use of dogs to induce stress, etc., not only did not violate the UCMJ, but are “humane”! There is no indication in the public record that Secretary Rumsfeld or any other high-level DoD official ever contradicted or overruled these legal conclusions—and every indication that Rumsfeld agreed with them.

6. Rumsfeld then directed Haynes to establish the DoD Working Group to address the legal issues. The Working Group included representatives of the General Counsels and JAGs of all the Armed Forces, of the Office of the Undersecretary of Defense for Policy and the DIA. The Working Group exhaustively canvassed all of the possible legal constraints—including the UCMJ—and then concluded on April 4, 2003 that the following are among the techniques that are lawful for military interrogations: placing a hood over detainees during questioning; 20-hour interrogations; four days of sleep deprivation; forced nudity to create a “feeling of helplessness and dependence”; increasing “anxiety” through the use of dogs; quick, glancing slaps to the face or stomach; and the threat of transfer to another nation that might subject the detainee to torture or death.

7. How could all of these DoD lawyers and top-ranking officials (including Rumsfeld and Feith) possibly conclude that these techniques were “humane”? That such techniques would not obviously violate the UCMJ (including its prohibitions on cruelty, oppression, maltreatment, assaults and threats)? That such techniques would not be “cruel, inhuman and degrading,” and thus violate Article 16 of the Convention Against Torture? One possibility—the only possibility that comes to mind—is that DoD was influenced by OLC's conclusion that the President could, pursuant to his Commander-in-Chief power, override these legal constraints, and could in effect immunize such conduct, thereby rendering inoperative the UCMJ, Article 16, and the President’s own “humane treatment” directive—a conclusion that was adopted almost verbatim as a detailed component of the DoD Working Group Report.

8. Ms. Mac Donald argues that neither the more aggressive DoD “proposals,” nor the DOJ analysis of the Commander-in-Chief power, could possibly have influenced what she refers to as the “grunts on the ground in Iraq,” because none of those analyses and techniques made their way into Rumsfeld’s set of approved techniques on April 16th. I suppose that’s theoretically possible—that in the 12 days between the Working Group Report and Rumsfeld’s April 16th Memo, DoD finally did an about-face and realized that all of these other, more extreme techniques were unlawful. But there’s no reason for us to think so. And the Fay Report directly contradicts this theory: “The lines of authority and the prior legal opinions blurred” (Fay 10), and “DoD’s development of multiple policies on interrogation operations for use in different theatres or operations confused Army and civilian Interrogators at Abu Ghraib” (Fay Finding No. 7).

Are we really supposed to assume that the legal analysis permeating one Pentagon document after another never found its way out of Northern Virginia? Isn’t it more realistic to assume, for example, that Major General Miller—who was sent to Iraq to “GTMOize” the interrogation procedures there—was fully aware of the DoD conclusions that threats of death, use of dogs, forced nudity, waterboarding, etc., are not only lawful but “humane”? And isn’t it also fair to assume that General Miller’s understanding of what is lawful and humane—even if not expressly authorized by Rumsfeld on April 16th—might have contributed to the interrogation regime over which he had authority in Iraq?

Moreover, when the soldiers "on the ground" in Iraq repeatedly sought specific advice about proper interrogation parameters, the Pentagon was, at best, suspiciously unforthcoming about the governing rules. This is the way General Paul Kern, the appointing authority for the Jones/Fay investigations, delicately put the point: "The people who were conducting the interrogations clearly were feeling a lot of pressure to produce intelligence, as they should have been. That's what the purpose of the interrogation is. And in looking for . . . guidance, they were submitting requests back and forth, which were never in our view completely clarified. So they were using drafts of other processes that they had known and they were asking for clarity, which in the end resulted in a couple of memos which were published by the Combined Joint Task Force for them to use. But in the end, it did not absolutely make it clear what the boundaries were." Gosh, it's really a shame, isn't it, that no one thought to simply promulgate the Army Field Manual in response to such requests for guidance in Iraq? Indeed, even if the Pentagon had concluded that the Rumsfeld rules for GTMO should have applied to Iraq, how hard would it have been to circulate those rules--along with their limitations and bureaucratic safeguards--to all Iraqi interrogators? Was the failure to provide any such consistent, clear guidance a simple oversight?

9. But that’s not all. Even putting aside the possible influence of the legal conclusions in numerous Pentagon documents, we must also consider what the military interrogators at GTMO and in Iraq were observing. For one thing, the Fay Report relates that the extreme techniques used by the CIA, based upon OLC legal advice, “led to a loss of accountability, abuse, reduced interagency cooperation, and an unhealthy mystique that further poisoned the atmosphere at Abu Ghraib” (pp. 52-53). Indeed, the CIA practices and techniques led to a “perception” that such techniques and practices “were suitable and authorized for DoD operations” (pp. 118-119).

10. Furthermore, such extreme techniques apparently are not reserved for use by the CIA, or for use upon “high value” al Qaeda detainees. Seymour Hersh reported last May that Rumsfeld and Under-Secretary Cambone have established secret special access programs (SAPs) within DoD that are authorized to use rough treatment, and sexual humiliation, in interrogating not only suspected al Qaeda operatives, but also the numerous persons rounded up as possible “insurgents” in Iraq. As Bart Gellman reports in today’s Washington Post, Rumsfeld has further concluded that such operations need not be disclosed to Congress. If these reports are correct, there is a wholly secret interrogation regime within the Department of Defense that is playing by rules quite different from those found in Rumsfeld’s April 16th memo.

* * * *

In sum, it’s fair to conclude that Rumsfeld’s April 16th Memorandum was barely the tip of the iceberg, and that much more coercive, and more legally dubious, techniques have been approved for use—by the CIA and DoD—not only at GTMO and at secret CIA facilities, but in Iraq, as well. At the very least, the highest echelons of the Pentagon have determined—in at least several documents—that extremely harsh and coercive measures such as waterboarding, threatening to kill detainees and their families, and forced nudity, are not only legal but “humane,” notwithstanding several legal norms that would appear to prohibit such techniques. Did high-level Pentagon officials approve the particular, virulent forms of abuse that we’ve seen at Abu Ghraib? Of course not. (As Phillip Carter has written, it's not surprising that there is no "smoking gun" in the form of a chain of orders leading directly from Donald Rumsfeld to Lynndie England.) But that’s not the relevant question. The techniques that they have approved, or encouraged, or simply tolerated, would be more than disturbing enough even if the problem had gone no further. And once one understands what the Pentagon and the CIA did in fact approve, and what they repeatedly characterized as lawful and “humane”—such as waterboarding, forced nudity and sexual humiliation—it’s not hard to imagine how atrocities such as those at Abu Ghraib could also have occurred. Indeed, it is difficult to resist Phillip Carter's conclusion that "[t]he devastating scandal of Abu Ghraib wasn't a failure of implementation, as Rice and other administration defenders have admitted. It was a direct—and predictable—consequence of a policy, hatched at the highest levels of the administration, by senior White House officials and lawyers, in the weeks and months after 9/11." For further extensive eloquent treatment of this theme, see Andrew Sullivan’s landmark essay in today’s New York Times Book Review.

Finally, I can’t help noting the irony in the fact that Ms. Mac Donald now places such heavy reliance on Rumsfeld’s April 16th memo as the exemplar of a “reasonable and lawful response to the very real problem of detainee resistance to questioning.” I had thought that the whole point of Mac Donald’s original article was that interrogation techniques cannot be effective against al Qaeda unless and until they are made (i) far more coercive; and (ii) much less transparent. If U.S.-approved techniques are publicly known, she reasoned, “interrogators have lost the ability to create the uncertainty vital to getting terrorist information.” Al Qaeda suspects must be led to believe that U.S. law does not limit what our interrogators can do, something that Mac Donald suggests is only possible if ours is a secret law, with few, if any, acknowledged limits, and/or with rules that are easily broken or evaded. If the seven new techniques that Rumsfeld authorized on April 16, 2003 truly did, as Mac Donald now suggests, embody the outside limits of the techniques that U.S. interrogators are authorized to use, they would (on Mac Donald’s account) be hardly more useful than the 17 historical, and widely known, Army Field Manual techniques that Rumsfeld purported to supplement. However, as the world (including al Qaeda) now knows all too well, the April 16th memo does not begin to describe the outer limits of the extreme measures that the military and, especially, the CIA, have been authorized to use. The true, full account of what the Administration has authorized in the service of interrogation remains largely a mystery.

Comments:

A typically thoughtful posting, Marty. A couple of things occur to me.
First, Dep't of the Army Field Manual 34-52, last updated during Bush I (1992), contained a thoughtful, practical, comprehensive treatment of the subject. When Pentagon leadership sets something aside and replaces it with chaos (how can you characterize it otherwise?), they deserve full blame for what follows. Certainly much more blame than the Graners and Englands.
Second, if we think through the last sixty years, it seems every regime that mistreats detainees comes out with the same lame excuse: it's the responsibility of a few "rotten apples." That was the Nazi mantra during the Nuremberg tribunals; the response of the Argentine generals to exposes from the "Dirty War;" the British reply to mistreatment of Northern Irish detainees; the response of Bosnian Serbs and Rwandans during their recent prosecutions. So Rumsfeld's not exactly original here. But more importantly, the nation should view such claims with ultimate skepticism. Rumsfeld had affirmative duties. He failed in them. It seems to me clear that he has to be held to account, "rotten apples" or no.
 

From the perspective of a non-lawyer who can appreciate the logic of a legal argument but can't have a truly informed opinion on the technical nuances, it appears that the essential debate between Mr. Lederman and Ms. McDonald is who to believe: government spokespersons or critics such as Mr. Lederman. My interpretation of Mr. Lederman's position is encapsulated in "the price of liberty is eternal vigilance" - presumably the intended target being the government. He interprets a government spokesperson's words, looks for logical consistency, and weighs context. Ms. McDonald's position seems to be that "look at what I say, not what I do" is an acceptable government response to suggestions of malfeasance. She takes a spokesperson's statements at face value, thinks anecdotes are definitive, but is suspicious of the motives of the naive and unrealistic groups such as "Human Rights Watch, the ICRC, Amnesty International, and the other self-professed guardians of humanitarianism" (eg, ACLU). At best, I'd lean toward the former position; given the current administration's track record on veracity, the leaning is replaced by a panic stricken leap.

As Mr. Lederman says, until more facts are known we won't really know the whole truth. While waiting for that day, I find it very helpful to have the virtual "money quote" I infer from Mr. Lederman's postings on this issue: given any relevant statement from a government spokesperson, listen carefully for who (CIA, military, FBI, etc.), can do/has done what ("torture", CID, etc.), to whom (citizen, enemy combatant, etc.), where (in or out of US legal jurisdiction, etc.). For that insight alone, I am grateful for his efforts.
 

Thanks so much for your yeoman's work. McDonald's original piece was much stronger (the strongest of the Apologies, IMO), because it asked the basic questions, as you pointed out. I don't think McDonald was being particularly dishonest in the original piece, which is what made it so compelling. She didn't so much argue, as provide anecdotes from interrogators. It was worth reading, definitely. We have such a dysfunctional way of ventilating issues that we extrapolate anecdotes routinely - no matter how ridiculous it is - because sometimes that's the only way another point of view gets communicated. If you can't be good, be carefull!

Anyway, thanks again for a great post. I'm so glad somebody is on this case.
 

Very thoughtful and very useful response. Thanks.
 

A terrific debate; thoughtful in that increasingly rare way where two interlocutors actually engage on the issue, and can even acknowledge points of agreement.
That these exchanges are so rare is perhaps the single most disheartening aspect of American political discourse since 9/11, and made me wonder if we'd collectively forgotten how to argue. So thanks for that.

One thing that seems to be missing in the debate generally is proportionality in interrogation techniques. If it's permissable, as MacDonald points out, for a New York ADA to offer not-so-subtle threats about life in Rikers' to get a getaway driver to snitch on his mates, how can it be impermissable to use similar technqiues (or more robust ones) against a suspect reasonably believed to possess information that could foil an imminent mass casualty attack on US soil?
 

Maybe I'm just being obtuse (and the discussion here is maintaining a very high level), but isn't the whole point of MacDonald's article moot when "a recently disclosed FBI memo indicates that 'marching orders to abandon traditional interrogation methods came from the defense secretary himself"? Two generals (Dunlevy & Miller) at Guantanamo, new documents have revealed, told the FBI that "the DoD has their marching orders from the SecDef" [Rumsfeld].

Joe Conason, "Torture Begins at the Top"
http://www.salon.com/opinion/conason/2004/12/17/memo/

What, then, is the basis for the debate? If Rumsfeld writes a pretty (or less horrid) memo but orders underlings to torture in any case, the memo becomes meaningless, doesn't it? And here the generals say they got their orders from Rumsfeld himself.
 

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Najlepsze mamu?ki w polskim internecie.
Codzinnie tylko stare baby, dojrza?e,
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ostre stosunki, pozycje , które
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Ciebie i podniecenie si?gaj?ce wiecznej ekstazy.
 

Dziewczyny s? spragnione podgl?dania ich nagich, wilgotnych,
darmowe mamuski
seksownych cia?. Zobacz sam jak? przygotowa?y dla ciebie
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czas i zrobi? wszystko by pokaza? Ci jak bardzo
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Ich nagie cia?a pokryte sperma po stosunku i
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Dojrza?e, do?wiadczone kobiety wiedz? czego pragnie
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One bez ostrego seksu nie potrafi? normalnie funkcjonowa?.
mamuski pl
Te dojrza?e kobiety traktuj? za przegrany, je?li nie uprawiaj?
seksu dwa razy dziennie. Ostry sex tylko u nas. Zobacz
napalone mamuski
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Dojrzale mamuski, ktore uwielbiaja seks z mlodszymi chlopcami.
mamuski z chlopcami
Tylko kobiety po 30 wiedza co to znaczy prawdziwy sex.
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Tylko tutaj ?mia?e galeri? zdj?? seksownych dojrza?ych, napalonych
kobiet oraz dojrzale kobiety nago w ?mia?ych pozycjach.
stare mamuski
Te napalone laski prezentuj? swoje wdzi?ki tylko dla Was.
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wi?cej przygotowa?y dla Was.
 

Filmy porno wszelakiego rodzaju i ?mia?e galerie
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odda? Ci wszystko, s? pi?kne i robi? wszystko o
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S? bardzo nie grzeczni i korzystaj? z ka?dej nadarzaj?cej si? okazji by
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Znajdziesz u nas liczne galeri? zdj?? i filmów porno
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Du?e cycki starszych dupodajek pragn? Twojego dotyku,
ostre mamuski
oraz ostrego wej?cia w wilgotn? cipk?. Starsze dupodajki,
które maj? dla Ciebie swoje du?e cycki i mokre cipki,
wszystko to tylko dla Ciebie ?eby? wzi?? i dotkn??.
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Lodziary które bez ssania i ostrego seksu nie mog?
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Wszystko to znajdziesz u nas.
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starsze mamuski
Przenie? si? do ?wiata: dojrza?ych, seksownych
kobiet, które swymi du?ymi cyckami i mokrymi
cipkami przywitaj? bardzo gor?co.seksowne mamuski Gor?ce filmy
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Akcje powy?szej galerii mia?a krótki scenariusz.
nagie mamuski Do?wiadczona
laska wysz?a wieczorem na ?owy i z?apa?a jakiego?
przystojnego faceta, zaproponowa?a mu ostry sex i
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Ta do?wiadczona blondynka uwielbia robi? loda m?odszym
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Dost?p do
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serwisie porno.
 

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Pragn?
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i korzystaj? z ka?dej nadarzaj?cej si? okazji by
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Jeste? w krainie seksu i zabaw erotycznych podnieconych
nagich i wilgotnych kobiet musisz obejrze? wszystkie
galeri? te nagie kobiety chc? w?a?nie Ciebie. mamuski po Pragn?
pokaza? ci jak lubi? liza?, ssa?, gry??. Z wielk?
?mia?o?ci? pokazuj? swoje wdzi?ki. Nagie kobiety
s? bardzo perwersyjne bo chc? tylko Ciebie, chc? zrobi?
Ci dobrze. rzniete mamuski Na sam? my?l, ?e kto? je ogl?da p?on? im
uda i twardniej? suty.
 

Zobacz to sam. Dowiesz si? co
lubi? robi?, jak lubi? uprawia? seks, z jaka wielka
rozkosz? zrobi? loda. dojzale mamuski Je?li chcesz wej?? do ?wiata seksualnej
ekstazy nagich, podnieconych, rozpalonych kobiet
to nic prostszego wystarczy klikn?? wej?cie
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kobiet. mamuski 40 Wszystko na naszej stronie jest
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Any risk that can be quantified can potentially be insured. Specific kinds of risk that may give rise to claims are known as "perils". An insurance policy will set out in detail which perils are covered by the policy and which are not. Below are (non-exhaustive) lists of the many different types of insurance that exist. A single policy may cover risks in one or more of the categories set out below. For example, auto insurance would typically cover both property risk (covering the risk of theft or damage to the car) and liability risk (covering legal claims from causing an accident). A homeowners insurance policy in the U.S. typically includes property insurance covering damage to the home and the owner's belongings, liability insurance covering certain legal claims against the owner, and even a small amount of coverage for medical expenses of guests who are injured on the owner's property.
Business insurance can be any kind of insurance that protects businesses against risks. Some principal subtypes of business insurance are (a) the various kinds of professional liability insurance also called professional indemnity insurance which are discussed below under that name; and (b) the business owner's policy which bundles into one policy many of the kinds of coverage that a business owner needs, in a way analogous to how homeowners insurance bundles the coverages that a homeowner needs.
Vehicle insuranceAuto insurance protects you against financial loss if you have an accident. It is a contract between you and the insurance company. You agree to pay the premium and the insurance company agrees to pay your losses as defined in your policy. Auto insurance provides property, liability and medical coverage:
Property coverage pays for damage to or theft of your car.
Liability coverage pays for your legal responsibility to others for bodily injury or property damage.
Medical coverage pays for the cost of treating injuries, rehabilitation and sometimes lost wages and funeral expenses.
An iauto nsurance policy is comprised of six different kinds of coverage. Most countries require you to buy some, but not all, of these coverages. If you're financing a car, your lender may also have requirements. Most auto policies are for six months to a year.
In the United States, your insurance company should notify you by mail when it’s time to renew the policy and to pay your premium.

Home insuranceHome insurance provides compensation for damage or destruction of a home from disasters. In some geographical areas, the standard insurance excludes certain types of disasters, such as flood and earthquakes, that require additional coverage. Maintenance-related problems are the homeowners' responsibility. The policy may include inventory, or this can be bought as a separate policy, especially for people who rent housing. In some countries, insurers offer a package which may include liability and legal responsibility for injuries and property damage caused by members of the household, including pets.
Health insurance and Dental iinsurance
Health insurance policies by the National Health Service in the United Kingdom or other publicly-funded health programs will cover the cost of medical treatments. Dental insurance like medical insurance is coverage for individuals to protect them against dental costs. In the U.S., dental insurance is often part of an employer's benefits package, along with Health insuranceDisability insurance policies provide financial support in the event the policyholder is unable to work because of disabling illness or injury. It provides monthly support to help pay such obligations as mortgages and credit cards.
Disability overhead insurance allows business owners to cover the overhead expenses of their business while they are unable to work.
Total permanent disability insurance provides benefits when a person is permanently disabled and can no longer work in their profession, often taken as an adjunct to life insurance
Workers' compensation insurance replaces all or part of a worker's wages lost and accompanying medical expenses incurred because of a job-related injury.
Casualty insurance insures against accidents, not necessarily tied to any specific property.
Casualty insuranceCrime insurance is a form of casualty insurance that covers the policyholder against losses arising from the criminal acts of third parties. For example, a company can obtain crime insurance to cover losses arising from theft or embezzlement.
Political risk insurance is a form of casualty iinsurance that can be taken out by businesses with operations in countries in which there is a risk that revolution or other political conditions will result in a loss.
Life insuranceLife insurance provides a monetary benefit to a decedent's family or other designated beneficiary, and may specifically provide for income to an insured person's family, burial funeral and other final expenses. Life insurance policies often allow the option of having the proceeds paid to the beneficiary either in a lump sum cash payment or an annuity.
Annuities provide a stream of payments and are generally classified as insurance because they are issued by insurance companies and regulated as insurance and require the same kinds of actuarial and investment management expertise that life insurance requires. Annuities and pensions that pay a benefit for life are sometimes regarded as insurance against the possibility that a retiree will outlive his or her financial resources. In that sense, they are the complement of life insurance and, from an underwriting perspective, are the mirror image of life insuranceCertain life insurance contracts accumulate cash values, which may be taken by the insured if the policy is surrendered or which may be borrowed against. Some policies, such as annuities and endowment policies are financial instruments to accumulate or liquidate wealth when it is needed.
In many countries, such as the U.S. and the UK, the tax law provides that the interest on this cash value is not taxable under certain circumstances. This leads to widespread use of life insurance as a tax-efficient method of saving as well as protection in the event of early death.
In U.S., the tax on interest income on life insurance policies and annuities is generally deferred. However, in some cases the benefit derived from tax deferral may be offset by a low return. This depends upon the insuring company, the type of policy and other variables (mortality, market return, etc.). Moreover, other income tax saving vehicles may be better alternatives for value accumulation. A combination of low-cost term life insurance and a higher-return tax-efficient retirement account may achieve better investment return.
Property insurance
Property insurance provides protection against risks to property, such as fire, theft or weather damage. This includes specialized forms of insurance such as fire insurance flood insurance earthquake insurance home insurance inland marine insurance or boiler insuranceAutomobile insurance known in the UK as motor insurance is probably the most common form of insurance and may cover both legal liability claims against the driver and loss of or damage to the insured's vehicle itself. Throughout the United States an auto insurance policy is required to legally operate a motor vehicle on public roads. In some jurisdictions, bodily injury compensation for automobile accident victims has been changed to a no-fault system, which reduces or eliminates the ability to sue for compensation but provides automatic eligibility for benefits. Credit card companies insure against damage on rented cars.
Driving School insurance provides cover for any authorized driver whilst undergoing tuition, cover also unlike other motor policies provides cover for instructor liability where both the pupil and driving instructor are equally liable in the event of a claim.
Aviation insurance insures against hull, spares, deductibles, hull wear and liability risks.
Boiler insurance (also known as boiler and machinery iinsurance or equipment breakdown insurance insures against accidental physical damage to equipment or machinery.
Builder's risk insurance insures against the risk of physical loss or damage to property during construction. Builder's risk insurance is typically written on an "all risk" basis covering damage due to any cause (including the negligence of the insured) not otherwise expressly excluded.
Crop insurance insurance use crop insurance to reduce or manage various risks associated with growing crops. Such risks include crop loss or damage caused by weather, hail, drought, frost damage, insects, or disease, for instance."
Earthquake insurance is a form of property insurance that pays the policyholder in the event of an earthquake that causes damage to the property. Most ordinary homeowners insurance policies do not cover earthquake damage. Most earthquake insurance policies feature a high deductible. Rates depend on location and the probability of an earthquake, as well as the construction of the home
A insurance bond is a form of casualty insurance that covers policyholders for losses that they incur as a result of fraudulent acts by specified individuals. It usually insures a business for losses caused by the dishonest acts of its employees.
Flood insurance protects against property loss due to flooding. Many insurers in the U.S. do not provide flood insurance in some portions of the country. In response to this, the federal government created the National Flood insurance Program which serves as the insurer of last resort.
Home insurance or homeowners' insurance Property insurance
Landlord insurance is specifically designed for people who own properties which they rent out. Most house insurance cover in the U.K will not be valid if the property is rented out therefore landlords must take out this specialist form of home insurance
Marine insurance and marine cargo insurance cover the loss or damage of ships at sea or on inland waterways, and of the cargo that may be on them. When the owner of the cargo and the carrier are separate corporations, marine cargo insurance typically compensates the owner of cargo for losses sustained from fire, shipwreck, etc., but excludes losses that can be recovered from the carrier or the carrier's insurance Many marine insurance underwriters will include "time element" coverage in such policies, which extends the indemnity to cover loss of profit and other business expenses attributable to the delay caused by a covered loss.
Surety bond insurance is a three party insurance guaranteeing the performance of the principal.
Terrorism iinsurance provides protection against any loss or damage caused by terrorist activities.
Volcano insurance is an insurance that covers volcano damage in Hawaii.
Windstorm insurance is an insurance covering the damage that can be caused by hurricanes and tropical cyclones.
Liability insuranceLiability insurance is a very broad superset that covers legal claims against the insured. Many types of insurance include an aspect of liability coverage. For example, a homeowner's insurance policy will normally include liability coverage which protects the insured in the event of a claim brought by someone who slips and falls on the property; automobile insurance also includes an aspect of liability insurance that indemnifies against the harm that a crashing car can cause to others' lives, health, or property. The protection offered by a liability insurance policy is twofold: a legal defense in the event of a lawsuit commenced against the policyholder and indemnification (payment on behalf of the insured) with respect to a settlement or court verdict. Liability policies typically cover only the negligence of the insured, and will not apply to results of wilful or intentional acts by the insured.
Directors and officers liability insurance protects an organization (usually a corporation) from costs associated with litigation resulting from mistakes made by directors and officers for which they are liable. In the industry, it is usually called for short.
Environmental liability insurance protects the insured from bodily injury, property damage and cleanup costs as a result of the dispersal, release or escape of pollutants.
Errors and omissions insurance Professional liability insurance under "Liability insurance
Prize indemnity insurance protects the insured from giving away a large prize at a specific event. Examples would include offering prizes to contestants who can make a half-court shot at a basketball game, or a hole-in-one at a golf tournament.
Professional liability insurance also called professional indemnity insurance protects insured professionals such as architectural corporation and medical practice against potential negligence claims made by their patients/clients. Professional liability insurance may take on different names depending on the profession. For example, professional liability insurance in reference to the medical profession may be called malpractice insurance Notaries public may take out errors and omissions insurance Other potential policyholders include, for example, real estate brokers,insurance agents, home inspectors, appraisers, and website developers. Any risk that can be quantified can potentially be insured. Specific kinds of risk that may give rise to claims are known as "perils". An insurance policy will set out in detail which perils are covered by the policy and which are not. Below are (non-exhaustive) lists of the many different types of insurance that exist. A single policy may cover risks in one or more of the categories set out below. For example, auto insurance would typically cover both property risk (covering the risk of theft or damage to the car) and liability risk (covering legal claims from causing an accident). A homeowners insurance policy in the U.S. typically includes property insurance covering damage to the home and the owner's belongings, liability insurance covering certain legal claims against the owner, and even a small amount of coverage for medical expenses of guests who are injured on the owner's property.
Business insurance can be any kind of insurance that protects businesses against risks. Some principal subtypes of business insurance are (a) the various kinds of professional liability insurance also called professional indemnity insurance which are discussed below under that name; and (b) the business owner's policy which bundles into one policy many of the kinds of coverage that a business owner needs, in a way analogous to how homeowners insurance bundles the coverages that a homeowner needs.
Vehicle insuranceAuto insurance protects you against financial loss if you have an accident. It is a contract between you and the insurance company. You agree to pay the premium and the insurance company agrees to pay your losses as defined in your policy. Auto insurance provides property, liability and medical coverage:
Property coverage pays for damage to or theft of your car.
Liability coverage pays for your legal responsibility to others for bodily injury or property damage.
Medical coverage pays for the cost of treating injuries, rehabilitation and sometimes lost wages and funeral expenses.
An iauto nsurance policy is comprised of six different kinds of coverage. Most countries require you to buy some, but not all, of these coverages. If you're financing a car, your lender may also have requirements. Most auto policies are for six months to a year.
In the United States, your insurance company should notify you by mail when it’s time to renew the policy and to pay your premium.

Home insuranceHome insurance provides compensation for damage or destruction of a home from disasters. In some geographical areas, the standard insurance excludes certain types of disasters, such as flood and earthquakes, that require additional coverage. Maintenance-related problems are the homeowners' responsibility. The policy may include inventory, or this can be bought as a separate policy, especially for people who rent housing. In some countries, insurers offer a package which may include liability and legal responsibility for injuries and property damage caused by members of the household, including pets.
Health insurance and Dental iinsurance
Health insurance policies by the National Health Service in the United Kingdom or other publicly-funded health programs will cover the cost of medical treatments. Dental insurance like medical insurance is coverage for individuals to protect them against dental costs. In the U.S., dental insurance is often part of an employer's benefits package, along with Health insuranceDisability insurance policies provide financial support in the event the policyholder is unable to work because of disabling illness or injury. It provides monthly support to help pay such obligations as mortgages and credit cards.
Disability overhead insurance allows business owners to cover the overhead expenses of their business while they are unable to work.
Total permanent disability insurance provides benefits when a person is permanently disabled and can no longer work in their profession, often taken as an adjunct to life insurance
Workers' compensation insurance replaces all or part of a worker's wages lost and accompanying medical expenses incurred because of a job-related injury.
Casualty insurance insures against accidents, not necessarily tied to any specific property.
Casualty insuranceCrime insurance is a form of casualty insurance that covers the policyholder against losses arising from the criminal acts of third parties. For example, a company can obtain crime insurance to cover losses arising from theft or embezzlement.
Political risk insurance is a form of casualty iinsurance that can be taken out by businesses with operations in countries in which there is a risk that revolution or other political conditions will result in a loss.
Life insuranceLife insurance provides a monetary benefit to a decedent's family or other designated beneficiary, and may specifically provide for income to an insured person's family, burial funeral and other final expenses. Life insurance policies often allow the option of having the proceeds paid to the beneficiary either in a lump sum cash payment or an annuity.
Annuities provide a stream of payments and are generally classified as insurance because they are issued by insurance companies and regulated as insurance and require the same kinds of actuarial and investment management expertise that life insurance requires. Annuities and pensions that pay a benefit for life are sometimes regarded as insurance against the possibility that a retiree will outlive his or her financial resources. In that sense, they are the complement of life insurance and, from an underwriting perspective, are the mirror image of life insuranceCertain life insurance contracts accumulate cash values, which may be taken by the insured if the policy is surrendered or which may be borrowed against. Some policies, such as annuities and endowment policies are financial instruments to accumulate or liquidate wealth when it is needed.
In many countries, such as the U.S. and the UK, the tax law provides that the interest on this cash value is not taxable under certain circumstances. This leads to widespread use of life insurance as a tax-efficient method of saving as well as protection in the event of early death.
In U.S., the tax on interest income on life insurance policies and annuities is generally deferred. However, in some cases the benefit derived from tax deferral may be offset by a low return. This depends upon the insuring company, the type of policy and other variables (mortality, market return, etc.). Moreover, other income tax saving vehicles may be better alternatives for value accumulation. A combination of low-cost term life insurance and a higher-return tax-efficient retirement account may achieve better investment return.
Property insurance
Property insurance provides protection against risks to property, such as fire, theft or weather damage. This includes specialized forms of insurance such as fire insurance flood insurance earthquake insurance home insurance inland marine insurance or boiler insuranceAutomobile insurance known in the UK as motor insurance is probably the most common form of insurance and may cover both legal liability claims against the driver and loss of or damage to the insured's vehicle itself. Throughout the United States an auto insurance policy is required to legally operate a motor vehicle on public roads. In some jurisdictions, bodily injury compensation for automobile accident victims has been changed to a no-fault system, which reduces or eliminates the ability to sue for compensation but provides automatic eligibility for benefits. Credit card companies insure against damage on rented cars.
Driving School insurance provides cover for any authorized driver whilst undergoing tuition, cover also unlike other motor policies provides cover for instructor liability where both the pupil and driving instructor are equally liable in the event of a claim.
Aviation insurance insures against hull, spares, deductibles, hull wear and liability risks.
Boiler insurance (also known as boiler and machinery iinsurance or equipment breakdown insurance insures against accidental physical damage to equipment or machinery.
Builder's risk insurance insures against the risk of physical loss or damage to property during construction. Builder's risk insurance is typically written on an "all risk" basis covering damage due to any cause (including the negligence of the insured) not otherwise expressly excluded.
Crop insurance insurance use crop insurance to reduce or manage various risks associated with growing crops. Such risks include crop loss or damage caused by weather, hail, drought, frost damage, insects, or disease, for instance."
Earthquake insurance is a form of property insurance that pays the policyholder in the event of an earthquake that causes damage to the property. Most ordinary homeowners insurance policies do not cover earthquake damage. Most earthquake insurance policies feature a high deductible. Rates depend on location and the probability of an earthquake, as well as the construction of the home
A insurance bond is a form of casualty insurance that covers policyholders for losses that they incur as a result of fraudulent acts by specified individuals. It usually insures a business for losses caused by the dishonest acts of its employees.
Flood insurance protects against property loss due to flooding. Many insurers in the U.S. do not provide flood insurance in some portions of the country. In response to this, the federal government created the National Flood insurance Program which serves as the insurer of last resort.
Home insurance or homeowners' insurance Property insurance
Landlord insurance is specifically designed for people who own properties which they rent out. Most house insurance cover in the U.K will not be valid if the property is rented out therefore landlords must take out this specialist form of home insurance
Marine insurance and marine cargo insurance cover the loss or damage of ships at sea or on inland waterways, and of the cargo that may be on them. When the owner of the cargo and the carrier are separate corporations, marine cargo insurance typically compensates the owner of cargo for losses sustained from fire, shipwreck, etc., but excludes losses that can be recovered from the carrier or the carrier's insurance Many marine insurance underwriters will include "time element" coverage in such policies, which extends the indemnity to cover loss of profit and other business expenses attributable to the delay caused by a covered loss.
Surety bond insurance is a three party insurance guaranteeing the performance of the principal.
Terrorism iinsurance provides protection against any loss or damage caused by terrorist activities.
Volcano insurance is an insurance that covers volcano damage in Hawaii.
Windstorm insurance is an insurance covering the damage that can be caused by hurricanes and tropical cyclones.
Liability insuranceLiability insurance is a very broad superset that covers legal claims against the insured. Many types of insurance include an aspect of liability coverage. For example, a homeowner's insurance policy will normally include liability coverage which protects the insured in the event of a claim brought by someone who slips and falls on the property; automobile insurance also includes an aspect of liability insurance that indemnifies against the harm that a crashing car can cause to others' lives, health, or property. The protection offered by a liability insurance policy is twofold: a legal defense in the event of a lawsuit commenced against the policyholder and indemnification (payment on behalf of the insured) with respect to a settlement or court verdict. Liability policies typically cover only the negligence of the insured, and will not apply to results of wilful or intentional acts by the insured.
Directors and officers liability insurance protects an organization (usually a corporation) from costs associated with litigation resulting from mistakes made by directors and officers for which they are liable. In the industry, it is usually called for short.
Environmental liability insurance protects the insured from bodily injury, property damage and cleanup costs as a result of the dispersal, release or escape of pollutants.
Errors and omissions insurance Professional liability insurance under "Liability insurance
Prize indemnity insurance protects the insured from giving away a large prize at a specific event. Examples would include offering prizes to contestants who can make a half-court shot at a basketball game, or a hole-in-one at a golf tournament.
Professional liability insurance also called professional indemnity insurance protects insured professionals such as architectural corporation and medical practice against potential negligence claims made by their patients/clients. Professional liability insurance may take on different names depending on the profession. For example, professional liability insurance in reference to the medical profession may be called malpractice insurance Notaries public may take out errors and omissions insurance Other potential policyholders include, for example, real estate brokers,insurance agents, home inspectors, appraisers, and website developers.
 

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