Ed Brayton is a journalist, commentator and speaker. He is the co-founder and president of 
Ed Morrissey of the extremely popular Hot Air blog, who can sometimes be a perfectly reasonable guy -- he recently wrote that the GOP needs to get over its obsession with gays -- and sometimes can be downright irrational, goes the irrational route in this post containing rather blatant distortions about ACORN and prosecutions of its canvassers.
First of all, he does what conservatives always do and conflates voter registration fraud with voter fraud. They are not the same thing. If a canvasser turns in a registration with Mickey Mouse's name, or 25 canvassers all turn in a registration for the same name, that doesn't mean Mickey Mouse is showing up to vote or that the person registered 25 times gets to vote 25 times. That's why we have well-defined procedures for county clerks to follow before someone goes in to the state's Qualified Voter File.
As the elections chief for one of Michigan's largest counties told me last week for a story I published this morning at the Michigan Messenger:
"Emphatically no, we have had no instances of voter impersonation or any instances of deceased voters voting. You see that with petition drives, folks are going to pad their numbers to get more pay, but that does not translate into fraudulent voter activity by any means."
Republicans in Michigan are similarly obsessed with voter fraud and similarly conflate registration fraud with actual voter fraud. Yet when I called our Republican Secretary of State, her spokesman said that he could not recall a single case of actual voter fraud in this state -- despite all the wailing and gnashing of teeth during the 2008 election about bad registration cards turned in by ACORN.
Morrissey is writing about a set of indictments handed down in Wisconsin for voter registration fraud involving two ACORN employees. And he begins with this highly dishonest statement:
Today, Van Hollen announced indictments in five cases -- including two felony indictments against ACORN for scheming to have registrants vote multiple times in November 2008.
There are two major distortions in that sentence. The first is that ACORN was not indicted at all; two former ACORN employees were indicted -- for stealing from ACORN by getting paid for turning in duplicate and fraudulent registration cards. He even quotes from a press release from the Wisconsin AG's office that quite clearly documents this fact:
According to the criminal complaints, Miles and Clancy served as Special Registration Deputies ("SRD") for the City of Milwaukee in advance of the 2008 Presidential Election. Each worked for the Association of Community Organizations for Reform Now ("ACORN"). Miles and Clancy are each charged with the felony offense of Falsely Procuring Voter Registration as Party to a Crime. The complaint alleges that Miles and Clancy submitted multiple voter registration applications for the same individuals, and also were part of a scheme in which they and other SRDs registered each other to vote multiple times in order to meet voter registration quotas imposed by ACORN...Miles indicated that at one point, Gabriele Robinson began sleeping with their supervisor, Edward Williams. Miles stated she would go to Robinson's residence and hang out for the day. She stated at the end of the day, Williams signed off as though they had turned in their 20 signatures for that day, giving them their pay. Miles stated that she and Robinson did this at least once a week, and that they received payments for those days when they did not turn in registrations because Robinson was sleeping with Williams.
Miles also advised the agents that the individuals would travel in groups and, if and individual registered a citizen to vote, the other SRDs would tell the citizen, "It doesn't hurt if you sign this one also." Thus, multiple SRDs recorded a signature from the same person. Miles stated that they were "all hoodlums" working for ACORN and they all had criminal histories, and that they were going to "do whatever they had to do" to be able to gain their money at the end of the day.
So you have employees of ACORN conspiring to make sure they got paid despite not doing their job. If an employee of K-Mart was found to have faked his time cards to get paid for work they did not do and got indicted for it, would Morrissey claim that K-Mart was indicted? Of course not. K-Mart is the victim, not the perpetrator.
Now, to be fair, I do think ACORN can justifiably be criticized for having such quotas for their canvassers and for putting such a focus on hiring ex-cons and people with drug problems (that is part of their mission, to help those people become productive citizens again).
But the other side of that coin, as anyone who has ever been involved in any kind of canvassing operation (petition drive, fundraising drive, voter registration drive, etc) can tell you, is that if you don't set a quota, the workers will goof off and do nothing. If you do set a quota, some people will work harder to meet it and others will try to find a way to scam the system.
Every single petition drive that has ever been mounted has faced this dilemma and had this problem. That's why the rule when you start a petition drive is to make sure you have at least 25% more signatures than are required, because it is inevitable that a certain percentage of those names will be bad. The people who do this kind of work, whether for ACORN or anyone else, are not exactly the cream of the crop. And this problem has plagued every petition drive of any kind forever.
The second distortion is his claim that ACORN was "scheming to have registrants vote multiple times." But there is nothing in those indictments that supports that claim. The fact that a bunch of canvassers may have one registrant sign up with all of them has nothing to do with anyone voting multiple times.
Does Morrissey really think that the county clerk is going to add the same person to the QVF 25 times in a row? Does he really think that the QVF system would allow that? Does he really think that no one would notice the same person going through the line to vote 25 times? He must think our election workers are total morons.
In fact, there was an indictment for double voting that he refers to -- but the two people who did it had nothing to do with ACORN. They filed an absentee ballot and then showed up to vote on election day as well. And guess what? They got caught. And they're being indicted. Which shows just how difficult actual voter fraud is to pull off.
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Comments
Looks like he has added updates to his posts to correct both the claim about indictments and the claim about voter fraud.
Posted by: Jim Lippard | March 10, 2010 9:46 AM
The people who do this kind of work, whether for ACORN or anyone else, are not exactly the cream of the crop.
A few years ago, I worked for a local restaurant, at a point when the local unemployment rate was under 1%. A few of the more senior workers noted that there was a reason some of the new hires had been unemployed....
Posted by: abb3w | March 10, 2010 9:49 AM
Now, to be fair, I do think ACORN can justifiably be criticized for having such quotas for their canvassers and for putting such a focus on hiring ex-cons and people with drug problems (that is part of their mission, to help those people become productive citizens again).
Well, no, I don't think they could justifiably be criticized for that. You either agree with their mission or not, and I doubt making these people productive citizens again is a mission that most people would argue against. And I don't even think that people can argue against having ex-cons and people with drug problems contribute to society in a useful way. The only problem is if the workers cheat, which is a) a problem for ANY organization, b) not a problem if there are adequate mechanisms to catch cheating, which I think there are.
Not sure what the point here is.
Posted by: gwangung | March 10, 2010 10:48 AM
Ed: Several months back, you alluded to issues with ACORN that you DO have. Is it just the bit about inadequately screening their canvassers, or is there something else?
Posted by: xebecs | March 10, 2010 11:06 AM
gwangung
if they DID have "adequate mechanisms" then ACORN would have caught these long before they were turned in, instead of turning them in and having the government investigate and prosecute them. There would be no prosecution if ACORN had adequate mechanisms to catch fraud, because the fraudulent registrations would not have been handed in.
Posted by: plutosdad | March 10, 2010 11:16 AM
if they DID have "adequate mechanisms" then ACORN would have caught these long before they were turned in, instead of turning them in and having the government investigate and prosecute them.
Methinks you're not familiar with the law, because ACORN was required, by law, to turn in ALL registrations, even if they thought they were pretty obviously fradulent.
Or are you in favor of a catch-22 situation for organizations like that?
Posted by: gwangung | March 10, 2010 11:23 AM
This is 100% wrong. ACORN is required by law to turn in each and every voter registration form it receives. They do sort them into groups of "probably legitimate", "questionable", and "probably bogus" when they submit them, however, and that's exactly how most of these issues have been caught- by ACORN itself.
Of course, since the forms must still be submitted despite being red-flagged by ACORN, the right-wing propaganda machine still seizes upon them as if they were evidence of a conspiracy.
Posted by: DaveL | March 10, 2010 11:26 AM
xebecs-
I do have some problems with them. I think they do a pretty poor job of hiring and supervising people. A lot of that stems from the fact that they are so adamant about hiring people with criminal backgrounds, drug problems and so forth. I understand why they want to do that; they're trying to give people a second chance. But a lot of those people are just scumbags and that obviously creates some problems.
And those O'Keefe videos -- regardless of how fair they were or whether he actually wore a pimp suit -- show that this goes beyond the canvassing crew. The moment someone mentions that they want to bring in underage girls from Central America, whoever they were talking to should have ended the conversation and reported it to the police. This is a training issue. I do not think, as so many right wingers do, that ACORN is deliberately trying to break the law or anything. But I think they've got some serious training issues. Their people should know how to respond when someone comes in looking for advice on how to break the law, and at least some of them don't seem to know that.
Some of these problems may simply have to do with the scope of their work. As I said in the post, every canvassing operation in history has faced similar problems, but few such operations are as large as the one ACORN pulled off in 2008 with their voter registration drive. Most similar operations, like petition drives to put a referendum on the ballot, are a few dozen people; they were hiring thousands of people for a nationwide voter registration drive that took months and months. Especially given their desire to hire people with suspect histories, the scope of that project was inevitably going to include a lot of bad apples.
Posted by: Ed Brayton | March 10, 2010 11:27 AM
plutosdad is absolutely wrong. As DaveL pointed out, they are required by law to turn in every single application they get, including the bad ones. This is for the obvious reason that you don't want private organizations deciding who is and is not a legal voter, you want election officials to do that. Otherwise, a private group on a voter registration drive could just decide to turn in only Republican applications, or only Democratic applications. Anyone who takes voter registration applications must,by law, turn in every single card that they collect.
ACORN does have quality control in place to catch duplicate, inaccurate, illegible and fraudulent applications. When they send a bundle of applications to the county clerk's office, any cards that are suspect for any reason are separated from the others, with a cover letter on top explaining why they think each one might be suspect. And they give the identities of the canvasser that took each one so that the government can pursue legal action for truly fraudulent applications (most of the "bad" applications are not fraudulent, they're just duplicates - someone isn't sure that they're registered, so they go ahead and fill out a registration card; most of the non-duplicates are illegible, not fraudulent).
Posted by: Ed Brayton | March 10, 2010 11:54 AM
All of this is sad and despicable, but unfortunately, Morrisey's point is no more to accurately report a legitimate grievance than the point of all that Republican volderol during the election was to prevent the corruption of our democratic process. Morrisey is propagandizing. He is taking real, non-damning events, building atop them a huge heap of lies, and then putting that structure out there to be consumed by an audience that will uncritically treat his assertions as true because they've already decided that guys like him are right, that ACORN is a Dem-backed conspiracy to give minorities more votes than they deserve, and that liberals are inveterate scofflaws. Its sad to see people take their loyalty to a party or cause as a just reason to be willfully dishonest, but there you are.
Having said that, its vital to the health of our system that such acts of dishonesty be pointed out, if only for the small group of folks actually willing to see reality past their ideology.
Posted by: Julian | March 10, 2010 12:11 PM
Ed, just in case you're not aware, the ACORN videos were doctored. I don't know what parts were real and what parts were fiction, but thus far ACORN has been cleared of any criminal wrongdoing, and O'Keefe's credibility is in the toilet.
Posted by: Steve Reuland | March 10, 2010 12:28 PM
This is one of the best take-downs of an ACORN critic I’ve read. I do have a question.
The word lie is often used casually in political discourse, but I wonder if we can always distinguish lies from failures in reasoning attributable to partisanship. The former is a deliberate misrepresentation of what one believes to be true; the latter can be a false assertion made in good faith. The distinction makes a world of difference in how I judge a person. I like to know whether I’m dealing with a liar, or an otherwise intelligent person whose reasoning processes have failed, or someone who isn’t very bright. As far as I’m concerned, purposely injecting poisonous lies into a discussion is thoroughly contemptible.
I don’t know anything about Morrissey, but since Ed says that he’s perfectly reasonable sometimes, we can probably rule out across-the-board stupidity. When Morrissey is unreasonable, is it because his partisanship is causing a glitch in his reasoning processes, or does Morrissey knows exactly what he is doing, selectively and intentionally using faulty reasoning to serve a political purpose? Is he reasonable on issues related to gays because he thinks it’s a losing position for conservatives, but deliberately unreasonable when he discusses ACORN because he sees it as a winning issue?
I think you can draw these distinctions sometimes if you follow people over a period of time. For example, I believe that Dick Morris is a lying opportunist. I also believe that some birthers are basically honest, but stupid, and/or warped by ideology—which isn’t to dismiss the possibility of insanity in certain notable cases.
I see that Julian thinks that Morrissey is propagandizing, which can involve deliberate lying or, more often, deliberate lying by omission. The latter can look exactly like confirmation bias. How do you know which one explains Morrissey?
Attribution bias: I was mistaken; you told a lie.
Posted by: Dr X | March 10, 2010 1:13 PM
Ed: Thanks for your response to my question. Now a couple of followups.
1. Do you believe that on the whole ACORN is a good organization that benefits our society?
2. Do you believe that some of the things ACORN does are things that they should just not be involved in?
3. If the answer to #2 is yes, are those things that someone should be doing (but not them) or are they things that simply should not be done?
I ask only because you seem to know a lot about ACORN and I value your opinion. The questions are blunt and bald, but that's just because I'm in a hurry and I would rather be clear than otherwise.
Posted by: xebecs | March 10, 2010 3:11 PM
xebecs-
I really can't answer that question. ACORN is a massive organization that does a huge number of things, a coalition of dozens of other organizations that all have their own agenda. And frankly, I'm not familiar with most of what they do. I know they do a lot of work in terms of low income housing. I think they manage some housing projects but I'm not sure. I just don't have a basis for making that judgment.
Posted by: Ed Brayton | March 10, 2010 3:17 PM
Thanks Ed. Now I know where the sidewalk ends.
Posted by: xebecs | March 10, 2010 3:24 PM
Dr. X @ 12:
I'm struggling to distinguish the difference when it comes to someone making a false claim. Should it matter? Shouldn't we have a standard that requires a person is able to validate a provocative claims prior to making such claims?
I like to use the term "lie" liberally and advocate we all do. I think people should be careful in making arguments, where one's argument doesn't extend far beyond the evidence and one should insure the evidence leveraged for their argument is true. If they make a dishonest statement that was avoidable and not plausibly inadvertent, than why parse the difference?
Certainly I agree it's interesting and very worthy to discern the root causes for people making untrue claims. However, I'd still argue lying is lying.
E.g., The Texas AG and Governor recently challenged the federal government in regards to their state having to comply to upcoming EPA regulations for carbon dioxide. They claim the science is suspect so they don't want to spend the money. Their citations validating that global warming is not well-supported is some poorly written U.K. newspaper articles.
From my vantage point they lied. They should be competent enough to get a position for their state based at least on what Texas climate scientists concur, which we recently learned is universally in support of the rest of the relevant scientific community in acceptance to the theory of AGW.
I fail to understand why we would partially justify someone making false statements by not claiming they're lying merely because they're partisan to the point of demonstrated dishonesty. I find such analogous to excusing the man who beats his wife because he was drunk. Certainly we want to understand why people get drunk and why some of these drunks get violent, but that shouldn't preclude our arresting and convicting him for abusing his wife. Such people should bear the burden of shame every bit as much as the sober wife-beater.
Posted by: Michael Heath | March 10, 2010 3:27 PM
Michael Heath, #16: I like to use the term "lie" liberally and advocate we all do.... If they make a dishonest statement that was avoidable and not plausibly inadvertent, than why parse the difference?
I agree. There are some people who have don't really care what the truth is and refuse the look into the facts themselves and refuse to believe anything that is contrary to what they want to believe. I think people who are "willfully ignorant" are no better than out and out liars.
Also, there are some people who are simply incapable of thinking about certain subjects in any rational matter. They may not really be liars and I think that we may consider their moral culpability to be less, but we can still classify them among the people who are not to counted as credible sources of information or suitable for public office because of their inability to distinguish fact from fiction.
Someone who is not a liar would be someone who, when confronted with the facts, will rcognize that he or she is wrong, apologize for the mistake, issue a good-faith retraction, and take measures so that his or her fans, campaign workers, and sycophants won't be repeating the same errors over and over again.
Posted by: Chiroptera | March 10, 2010 3:37 PM
Please note that Ed Morrissey made important corrections to his original post, thanks to Brad Friedman
http://www.bradblog.com/?p=7734
Quotes from Ed:
Update IV: Brad from Brad's Blog takes me to task - rightly - for some very sloppy writing in my second paragraph. The indictments were not filed against ACORN, but against two of their employees. That's not the same thing, and I've corrected the paragraph to make it more specific and accurate. I apologize for the confusion that caused anyone.
Update V: The crimes related to registrations, not actual voting; I’ve amended that paragraph to show that.
------------
Also, Brad has several posts about ACORN and the deliberate distortions in the O'Keefe videos.
Posted by: DaleP | March 10, 2010 5:48 PM
@chiopetra
I was about to say that I agree with this statement, but I was going to ask if Morrissey meets the conditions you’ve set down. We’ve got a hypothesis and a conclusion about Morrissey in this thread, but I didn’t see the hypothesis tested.
Now I see that, according to Dale, Morrissey has issued a retraction and an apology for the false statement about the criminal charges. Shouldn’t we hold ourselves to the same standards that we apply to others? When we have gaps in our knowledge of something like intent, should we not first give the benefit of the doubt and investigate or test further to fill in the narrative gaps? We easily fall prey to the tendency to fill in those gaps with our own biases. Fundamental Attribution Bias: overvaluing dispositional explanations for the behavior of others. A corresponding bias: we attribute our own errors to situational factors. He’s a liar: I made an honest mistake. What makes filling the gap with “liar!” not itself a lie?
To address Michael’s question about whether this distinction really matters, I would answer: yes, it does matter. I’ll skip over a lengthy discourse on the responsibility to get our facts straight before making a particularly strong moral accusation and get to the more practical aspects of the question. When a person presents a view in good faith, responding to them with a character attack is more likely to throw them into an irrational defensive mode. Instead of discussing the facts, they’ll be busy defending their character with a counter-attack on the accuser’s character.
This dynamic is almost a cognitive reflex and we all fall prey to it (on both ends of dynamic) from time to time. But in our sane moments, should we really be advocating ad hominem attack before we have sufficient evidence to back our accusations? Again, am I not the liar, if it turns out that my accusation of lying proves to be unfounded? I’d answer by saying sometimes yes, and sometimes I’ve simply fallen into a trap sprung by my own biases.
Posted by: Dr X | March 10, 2010 7:10 PM
Dr. X @ 19:
My challenge to you never mentioned a context with an opponent making a "character attack" to rebut false assertions. I was putting the onus on the speaker/writer, not on members of his audience to play nice, that's a distraction to the point raised. I also tried to be precise: if a person makes provocative assertions that they do not confidently know are true in order to buttress their argument, that's as good as lying if they turn out not be true. One should not be making assertions as fact without knowing whether they are in fact true.
You appear to be arguing its unfair for us to call a false statement a lie if the speaker/writer were ignorant of the very assertions they used to buttress their arguments. I would argue they are wholly responsible and this is a very good example of one form of lying. Especially since the result is the same regardless of whether they were ignorant or not on the assertions.
Of course some people will make what are obviously inadvertent mistakes. But my experience is that the people who consistently get their facts wrong out of ignorance are also serial liars. Sean Hannity, Mona Charon, Cal Thomas, Rush Limbaugh, Thomas Sowell, and George Will are all people I encounter weekly who are obviously ignorant on that upon which they expound, yes even the revered Mr. Sowell. They make really bad arguments because their assertions are wrong. In fact if they used accurate assertions they wouldn't have a very compelling argument. It's like they're rewarded for remaining willfully ignorant on the very assertions they use to support their arguments. Why wouldn't I call that lying?
I do not find it difficult to not make false assertions. It's really not that hard; and I don't make a living speaking or writing like the people I name here. Ed writes several blog posts a day and rarely has to correct the record.
I do want to add Dr. X, I really appreciate your contributions to this blog forum. I especially like your comments regarding psychology given I have virtually no education in that area; so I always get a lot of insight that would be impossible for me to gather on my own. So hopefully my disagreement with you on this one matter isn't taken personally. Especially since I've previously encountered plenty of resistance from others on this very topic. Therefore, I understand my definition of lying is broader than many people's; however I've also never encountered an argument I believed was compelling or convincing enough for me to adapt my position.
Posted by: Michael Heath | March 10, 2010 7:50 PM
It's meta-lying. When a person makes a categorical factive statement, they're not only expressing the explicit content of the statement, they are also asserting a certain amount of certainty or knowledge about that content. Liars of the kind we're discussing may not know their statements are untrue, but they cannot avoid knowing that their implicit claim to knowledge is blatantly false.
In other words, they're not honest people who may speak falsely by mistake, they're dishonest people (who, if they speak truthfully, do so by accident) and should be exposed and treated as such.
Posted by: DaveL | March 10, 2010 8:23 PM
Not in the least, Michael. I enjoy the discussion here because the sad fact is that there aren't that many other blogs that have so many intelligent, well-informed commenters who reliably comment in good faith. The evidence for that is that people here sometimes change their minds, admit error and admit room for uncertainty. We have our trolls, but they don't run the joint.
There's a nice a collaborative process in these threads, even if we don't always end up in the same place.
Posted by: Dr X | March 10, 2010 8:27 PM
DaveL - excellent point and one I hadn't realized. I keep a file defining and naming bad arguments, rhetorical fallacies and such. I updated my point on this topic to the following, love your feedback on whether I captured it:
BTW and FWIW, I link-cite to where I discover gems like yours for proper attribution. This description happens to be broader than your point since its modifying a previously stated point where I'm trying to capture this type of lying in its entirety.
Posted by: Michael Heath | March 10, 2010 8:59 PM
First, thanks to DaleP @ 18 for pointing out that I was able to help get Morrissey to correct his blatantly inaccurate piece, and wrote about same yesterday:
http://www.bradblog.com/?p=7734
My thanks also to Ed for covering this issue as well, and offering the specifics of Morrissey's mangling of facts, since I've done so many time at this point on The BRAD BLOG, I don't have the patience to do it in each and every article! :-)
With that said, Ed notes @ 8:
I might suggest you look at bit closer. These two posts, one in some detail from today:
http://www.bradblog.com/?p=7707
...And another, a bit shorter from a few days ago, showing a specific example of how O'Keefe/Giles and Breitbart manipulated what was seen in the tapes:
http://www.bradblog.com/?p=7725
...will both be highly instructive and insightful as to how you, Ed, may have been manipulated by the highly-doctored and heavily-overdubbed tapes exactly as even the NYT (who now refuses to correct their erroneous reporting!) was.
Please feel free to touch base if you have any questions, and thanks for highlighting the entire scam here!
Posted by: Brad Friedman | March 10, 2010 11:26 PM
From the UK it seems a little strange that voter registration is handled by a private organisation at all. Here maintaining the electoral register is a state responsibility. Each household is sent a registration form annually which must be filled in with all resident UK commonwealth and EU citizens. Potentially there is a fine of up level 3 on the standard scale (currently £1,000) for failing to fill in the form or submitting false information.
Posted by: Brett Dunbar | March 11, 2010 10:48 AM
Brett: the private organization does not "handle voter registration;" they merely encourage people to fill out the registration forms, offer help in the process, provide the forms, collect the forms after they're filled out, and pass them on to the (state) government organization that actually vets the forms, verifies the information, and manages the electoral register.
Here in the US, private organizations like ACORN are needed, not to actually register voters or manage the database, but simply to help individuals manage the process, because the state organizations keep minimal hours, are generally lame and unresponsive, and are deliberately structured to be unhelpful to people who actually work for a living.
Posted by: Raging Bee | March 11, 2010 11:05 AM
It still seems bizarre that a private organisation is needed to do this. In the UK the electoral registration office sends the forms out to every household annually filling it in isn't difficult. You just check the pre-printed list of names currently registered at that address, make any emendations, sign and return.
Posted by: Brett Dunbar | March 11, 2010 3:17 PM
not sure if Ed is still monitering thes posts but as a former ACORN worker (that worked during both the Voter Reg campaign and the scandal - recently and unfortunately laid off) I can tell you that while we do often give the people that we hire a second chance and do not discriminate against workers with unsavory pasts - it is NOT a requirement or something that we LOOK for in a worker. We do want people that feel comfortable in traditional ACORN neighborhoods (read: low income, crime, urban decay, etc) and mirror the neighborhood in some way. We also tend to have a high turnover because if we see fraud or obvious duplicates we fire you immediately so we need workers that can start and get out on the streets quickly. We hired plenty of wonderful workers that busted their asses to help people in blighted neighborhoods have a voice. It really does come down to that. And it's a BS statement to say that we are a Dem-backed org. We stayed non partisan so that we could yell at both sides. And we often did. Dem's and Rep's supported us on various issues (b/c as you noted - we did a far and wide spectrum of things) partly because they knew that ACORN members are informed on issues and VOTE. If we were a Dem-backed org we would have had more support in Sept when we were steamrolled by a juvenile prank. We had neither the capacity or the support to survive those assaults.
I am proud of the work I did and I miss it greatly. Our communities are the ones that will truly suffer when they have less abililty to organize their neighborhoods into better, more humane places to live.
Posted by: tupre | March 11, 2010 7:52 PM