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Saturday, October 16, 2004

More re Andrea Mackris' sexual harassment claims against Bill O'Reilly and Fox, and their preemptive extortion claims

Switching from presidential to sexual politics, I'll post a few comments to supplement those in my previous post about the litigation involving Fox News, Bill O'Reilly, and Andrea Mackris.

First and foremost:  Obviously, I have zero personal knowledge of any of the relevant facts, nor of the individuals directly involved, nor of their counsel.  I know nothing beyond what I've read in their respective complaints (here and here) and some media accounts, and all of that I take with a large grain of salt.  My previous and current comments are made solely as punditry from a lawyer unconnected with the case.  I'm by no means a full-time specialist in this complicated and fast-changing area of the law, although I have represented both defendants and plaintiffs on fairly similar claims in presuit negotiations, administrative proceedings, and lawsuits.  And I've not tried such a case myself to a conclusion before a judge or jury, but I'm generally aware of the statutes and caselaw, and of the range of outcomes from such cases around the country.


John Derbyshire's post on NRO's "The Corner" blog is fairly typical of the skeptical reaction many folks, including some of my readers (via email), have had to Ms. Mackris' claims.  (Mr. Derbyshire refers to having read Ms. Mackris' "deposition," by which I think he means her unsworn complaint, rather than the transcript of an oral examination of her under oath.)  I've heard similar arguments on talk radio, and I'm sure there are scads of blog posts on this general topic that I frankly haven't bothered to look for.

The fact that Mr. O'Reilly is not alleged to have had literal, physical sexual contact with Ms. Mackris is indeed important, as are the facts that she apparently suffered no adverse career consequences, made no complaints to Fox's management, returned to work for Mr. O'Reilly after her stint at CNN, voluntarily accompanied him to dinner on many occasions, didn't hang up on the phone calls, and so forth.  The degree to which she expressly and impliedly objected to, tolerated, or invited Mr. O'Reilly's conduct is likely to be a key factual issue.  So, too, will be the issue of whether Ms. Mackris was "setting up" Mr. O'Reilly and Fox.  The defendants will argue that she invited, even planned, all this; she'll argue, no doubt, that she was coerced into acquiescence and participation through explicit or implicit threats to her continuing employment, career, and reputation.

At a minimum, all these facts have a huge effect on the potential damages that she could reasonably hope to obtain, whether from Mr. O'Reilly or the other defendants.

Some of these facts are also keenly relevant to various defendants' potential liability for any damages.  To oversimplify a bit, if Fox — as the employer of both Mr. O'Reilly and Ms. Mackris — indeed (as claimed) had in place extensive policies prohibiting sexual harassment and requiring its employees to report its occurrence, that may end up negating Fox's liability, either under a "hostile work environment" theory or a respondeat superior-type (employer being liable for its employees' acts in the course and scope of their employment) theory.  Plaintiffs in Ms. Mackris' position oftentimes argue, sometimes successfully, that such policies were pretextual and ineffective, and that employers, through officers and supervisors of the alleged offender, knew or should reasonably have known of on-going violations.  Again, this is all grist for the mill of the pretrial discovery process for both sides, and ultimately for the jury.  The various witnesses' credibility, tested against the jury's common sense, is key.


The interests of an employer and its employee accused of sexual misconduct can often sharply diverge.  There's almost always at least a potential conflict of interest that legal counsel should explain fully to both; and quite often, there's an actual conflict of interest, with the employer not only distancing itself from its employee and his actions, but actively pointing the finger at the employee as having violated company policies and concealed his doing so.  Obviously it's in the interest of the plaintiff's counsel to be aware of the conflicts, and it's quite common for plaintiff's counsel to actively encourage them, especially when the employee is himself a "deep pocket."  Were I involved on the defense side of this case, I'd insist that Fox and Mr. O'Reilly have separate defense counsel of record — even if Fox, at least initially, may end up paying for Mr. O'Reilly's separate counsel, and even if all of the defendants hope and expect to cooperate closely and present coordinated defenses.

I stand by my earlier criticism of Fox's pre-emptive legal strike.  It bears all the hallmarks of clients who are letting short-term public relations considerations override long-term strategic and tactical legal judgments.

But I do not mean to imply by that criticism that I think Fox or Mr. O'Reilly should necessarily roll over and play dead — get out their checkbooks and write the eight-figure checks Ms. Mackis and her lawyer are demanding.  I seriously doubt that their inflated presuit demand constitutes criminal or civil extortion, strictly speaking, but that doesn't mean that the demand was reasonable, even if the quotations and conduct attributed to Mr. O'Reilly are factually accurate.  That there are counterpunches, and perhaps even knockout punches, that may be thrown still doesn't mean you should lead with your chin, and that's what I think Fox and Mr. O'Reilly have done here.


Finally:  I've been fascinated with sexual harassment claims for almost as long as I've been fascinated with sex.  The seminal (don't snicker) book on the topic was Catherine MacKinnon's Sexual Harassment of Working Women in the late 1970s, on which I commissioned what turned out to be a very fine, substantive book review (briefly abstracted here) from UC-Berkeley Law Professor Herma Hill Kay when I was the book review editor of the Texas Law Review in 1980.  A quarter century later, there's often still a profound disconnect between folks' real-life experience and what happens in the courtroom on these matters.  "I see this every day" and "I've endured worse and never complained" and "Of course some co-workers are going to have romantic encounters" are heartfelt and widely shared sentiments.  Artful flirting is the seed for every romance, and there are huge risks, in and out of the workplace, for artless misinterpretations.  And political correctness can be, and often is, carried too far.

But sex, money, and power are potent motivators and, sometimes, weapons — sometimes weapons of mass confusion.  The same folks who'll make the above-listed sorts of arguments around the water cooler or calling in on a talk radio show often find themselves magically, mystically transformed when they're ushered into the cool marble sanctuaries of a courtroom, solemnly sworn to follow the court's instructions, and then set to deliberating on particular factual situations.  Very often the decisions in these cases — and as a result, the terms on which the vast majority of such cases are settled before trial — reflect not what actually is common in the workplace, but what we, collectively, as a society aspire to see in the future.

If the quotations and conduct attributed to Mr. O'Reilly are accurate (a huge if), and if he knew or should have known that they were unwelcome (another huge if, and one that seems to me to be more likely to be hotly disputed), then he's very likely — under current law, and by an average jury interpreting it — to be found liable for at least some amount of damages under one legal theory or another.   Even if his words and conduct were invited — even if she "set him up" — then he's at fault for "falling for it," for putting himself in a horribly embarrassing and likely a career-destroying situation.  Yes, workplace romances and sexual situations are dirt common in the real world in which we all live.  But whether this was one or not, there are, and there have been, terribly exploitative situations that the courts are now addressing.  Anyone in a supervisory position over a co-worker is playing with fire when he — or she — initiates or responds to sexual or romantic overtures.  If the quotations attributed to him are in fact on tape, then the question probably isn't whether Mr. O'Reilly's going to get burned, but rather, how badly, and who else will get burned with him.


Update (Sat Oct 16th at 1:20pm):  A thoughtful emailer sent me these questions that I'll try to answer here, rather than in comments.

1 - Has there ever been a winning quid pro quo case where the sex was telephone sex?  I was thinking that Clinton's defenders supported the argument that what he engaged in with Lewinsky was not sex.  Telephone sex would seem to be one step further removed from whatever the definition of sex is.

I don't know if there's precedent on phone sex, but I can't see how it could be distinguished from other verbal harassment.  Sexual harassment laws prohibit more than just offensive physical touching.  But obviously, the type of conduct and its circumstances are going to be highly relevant to damages, and probably also to liability (e.g., if openly displayed in front of co-workers, it's more likely to support a hostile work environment claim because that will tend to show that the employer knew or should have known it was going on).

2 - her (repeatedly) stating that she answered/returned O'reilly's afer-hours calls to her cell phone, etc. because she thought they were work related.  Is this likely an attempt to transform acts that took place outside work into a work-related event?  I've never known a sexual harassment claim that targeted activity that took place solely outside the workplace and outside the work day - does there have to be some tie-in other than the fact that the complainant and respondent both work together?

I'm sure you're correct that Ms. Mackris will argue that the nature of her job had her "on call" outside normal office hours and outside the workplace.  Her position will certainly be that Bill O'Reilly and Fox expected her to be available for work-related phone calls that she accepted, only to learn to her chagrin that they were personally and sexually oriented.  My guess is that she'll be able to prove the former, probably through admissions from the defendants, but the latter will be a hotly contested issue of fact.  If, as she has claimed and will continue to claim, Mr. O'Reilly as her supervisor was trying to leverage his way into phone sex or more through explicit or implicit threats, the fact that his efforts took place outside normal business hours and outside the workplace isn't going to be an effective defense.  The defendants can be expected to dispute this vigorously, however, and they will indeed argue that the after-hours and non-workplace nature of the contacts is more consistent with consensual or invited activity.

3 - you make reference to whether he was set up.  I wondered the same thing when I read the complaint, but why would it matter?  Is there a entrapment defense in civil matters?

It's not entrapment as such, not in the same sense that term is used in criminal law as a defense.  But having sex (or sexual contact or conversations) with a co-worker isn't per se sexual harassment.  (It's just per se risky, especially if one's a supervisor and the other's a subordinate.)  If the quotations in Ms. Mackris' complaint are genuine, then the only way that I see for Mr. O'Reilly (as opposed to Fox and the other defendants, who are differently situated) to win an outright verdict of no liability would be to prove that the contacts and language were consensual and invited (even if not reciprocated), freely and without coercion — in which case it's not actionable.  If the jury concludes that her motive was to set up a bogus lawsuit, they may conclude as a subsidiary finding that she did consent to and invite the conduct.  Technically speaking, this wouldn't be an "affirmative defense," but rather evidence tending to negate a point on which the plaintiff has the burden of persuading the jury by a preponderance of the evidence. 

And even if the jury doesn't conclude that she was setting him up, but faults her for overreacting or harboring unreasonable and exaggerated fears of retaliation, this same evidence that's been offered in an attempt to circumstantially prove her consent may also affect the jury's liability findings on punitive damage questions, and also its setting of appropriate monetary awards for both "actual" damages (which includes "mental anguish") and punitive damages.  It's quite conceivable to me, for example, that a jury might end up holding Mr. O'Reilly liable, but award only very nominal damages — perhaps $1.  That's a classic way that juries communicate their disapproval of both sides' conduct (although it sometimes has an effect, unanticipated by the jury, of making the defendant liable for all of the plaintiff's attorneys' fees).

Hence her repeated allegations in the complaint — which she can be expected to repeat under oath — that she clearly and repeatedly communicated to Mr. O'Reilly that his conduct and language were unwanted.  If it were to turn out, for example, that Mr. O'Reilly said and did everything alleged, but that it was intermixed with her frequently saying, "Oh yeah, baby, I love it when you talk dirty to me, keep going, keep going!" — the jury would almost certainly conclude that the conduct and language wasn't unwanted harassment.  Of course, a scheming vixen (or were the roles reversed, Lothario) might well contrive to ensure that such encouragement didn't appear in any of the audiotapes, even if she gave such encouragement at other times or in other situations.  In short, it's an issue that's ripe for a proverbial swearing match.

This stuff isn't unique to civil law.  There are criminal law parallels in rape cases — just ask Kobe Bryant, or watch or read To Kill a Mockingbird.

Posted by Beldar at 09:03 AM in Law (2006 & earlier), Mainstream Media | Permalink


Other weblog posts, if any, whose authors have linked to More re Andrea Mackris' sexual harassment claims against Bill O'Reilly and Fox, and their preemptive extortion claims and sent a trackback ping are listed here:

» Bill O'Reilly's Sexual Harrassment Case from Amy Ridenour's National Center Blog

Tracked on Oct 16, 2004 8:09:40 PM

» O'Reilly roundup from Overlawyered

Tracked on Oct 18, 2004 1:54:17 PM


(1) Sue Bob made the following comment | Oct 16, 2004 9:44:56 AM | Permalink


These suits really bother me. For most of my adult life I have worked mainly with men. I have heard all sorts of things akin to what Mackris is talking about, but I never got my back up about it. I thought that I was just getting more information about men. I also knew that if I didn't like it, I had the option of quitting and going somewhere else--an option every American has.

The only thing that ever made me mad was when they wouldn't let me go on the firm dove hunt. So, I simply took matters into my own hands and crashed it.

I conclude by saying--if I had a female lawyer who couldn't handle WORDS--I sure wouldn't trust her with my multi-million-dollar lawsuit. And, I have a feeling that Mackris has stupidly destroyed her career over this.

I've always heard that you shouldn't keep women on a jury if you represent a woman claiming sexual harassment. My post is probably why.

(2) Joan made the following comment | Oct 16, 2004 11:22:57 AM | Permalink

I've only a brief acquaintance with the "details" of this case, which appears to boil down to, "O'Reilly said some obnoxious things to me, and I don't like it."

As a woman who survived a 15-year in software development, let me say that this kind of thing irritates me to no end.

If Mackris thinks O'Reilly was a boor (a supposition that surprises no one, I'm sure), why didn't she speak up about it?

It is horrifying to me the example suits like this one set: portray yourself as a victim -- or even worse, actually allow yourself to become one -- and get rich and famous as a result!

It's probably not fair, but on the face of it, I don't believe Mackris's claims. I resent women like her that are too spineless to stick up for themselves (what's the deal with going to CNN and then coming back?), who then turn to the courts for "protection."

I've been watching O'Reilly for years and while he drives me crazy with his feigned "neutrality," I have noted that the man is emphatically Not Stupid. One thing he seems to possess is common sense; maybe that doesn't extend to his working relationships. That would be disappointing.

But the consequence for guys who say piggish things shouldn't be 8-figure settlements. And the consequence for women who file for 8-figure settlements when they're too passive to stand up for themselves should be substantially harsh.

Mackris will now be enshrined in the hall of public shame, along with the Palm Beach County DA who is ruining his own career by targetting Rush Limbaugh, and Mary Mapes et al who manufactured a story (if not actual documents) trying to smear Bush's Guard service.

"The ends justifies the means" isn't such an effective technique when the blogosphere is around to shine the bright light on all the despicable "means."

(3) Roundguy made the following comment | Oct 16, 2004 12:42:28 PM | Permalink

Alas. I'm convinced. Leaving this country is the only sure way to avoid a lawsuit. I actually did sexually harrass an employee a long time ago. Well sorta. Anyway, after telling me to shove it (not the exact words) that was the end of the story. We both lived happily ever after save my bruised ego.

Moral of the story: vote Republican.

One other word of advice: Never talk down attorneys...you never know who might be defending you.

(4) heather made the following comment | Oct 16, 2004 1:13:49 PM | Permalink

Having participated in the "woman's movement" back in 1968-1972, I know that the idea was that women should be treated with fairness in the work place, according to our qualifications and abilities.

Now, it seems, the 'movement' has decided that women are Victorian hysterics, fluttering our lacy handkerchiefs, helpless in the face of 'attacks' from the Big Bad Master.

Honestly. That Catherine McKinnon person ought to be smacked in the kisser with a wet mackerel.

(5) Beldar made the following comment | Oct 16, 2004 1:14:38 PM | Permalink

Roundguy, if you misinterpreted the signals and made a clumsy verbal pass that was rejected, that's not a problem. If the pass was physical, that could've been.

(6) Beldar made the following comment | Oct 16, 2004 1:50:26 PM | Permalink

Heather, Ms. MacKinnon is a famous zealot on this issue. Professor Kay's review of her book, as I recall it, was a measured and sometimes skeptical assessment of her arguments. The courts have refused to accept quite a few of Ms. MacKinnon's more extreme arguments. Whether one thinks she's more akin to John Brown or Martin Luther King, however, she's clearly been a causal factor in the development of sexual harassment law. Is that a good thing? Generally speaking, I'd say "yes," but in any given specific case, my answer has to be, "It depends."

(7) ed made the following comment | Oct 16, 2004 2:10:14 PM | Permalink


1. I wonder if the whole sexual harrassment threat has an effect on personal relationships? I work in a company that employs a large number of attractive single women, a cross to bear I assure you, but I have avoided "playing the field" so to speak. I enjoy my career and don't want to poison my work environment.

A lot of people complain of how difficult it can be to find a significant other. Perhaps that difficulty is made worse by an excessive sensitivity to sexual harrassment. This isn't to condone such behavior, but the line can be very very blurry sometimes and, for a single man, the thought of damaging a career over a misunderstanding isn't a very palatable one.

2. The timeline given, as I understand it, is:

a. Mackris worked for O'Reilly for 4 years.
b. Mackris left FNC for CNN in January of 2004.
c. Mackri's boss was canned for sexual harrassment in April of 2004 and she was let go.
d. Mackris returned to work for O'Reilly in July of 2004.
e. Mackris made her allegations and sought compensation in September of 2004.

So why was Mackris's CNN boss fired and was she involved? You'd think if her boss was fired it wouldn't directly affect her, unless she was involved in some way. Did that experience also give her ideas on how to make a buck?

I've searched around but I can't find out anything about that firing at CNN.

(8) GSBaker made the following comment | Oct 16, 2004 2:53:17 PM | Permalink

Ed asks if the threat of sexual harrasment suits has an adverse effect on personal relationships. Ans.; it certainly does, not only especially on romantic but also on normal interpersonal relationships. As a professor and an administrater at the university level I can attest to the fact that it has a deadening influence on mentoring relationships both between faculty and between faculty and student and makes it foolhardy to attempt to befriend or assist any one in accademic and/or emotional trouble. The only assistance I felt safe to render was a kleenex and that from the safety of a desk visible from the hall.

(9) Dan made the following comment | Oct 16, 2004 3:02:49 PM | Permalink

Oh, sorry. I saw "sexual politics" and thought maybe Clinton was jumping into the race!

(10) Birkel made the following comment | Oct 16, 2004 3:38:19 PM | Permalink


Not only is Catherine MacKinnon a zealot she's also a bit of a loon. I took a class with her and she basically wants to redefine all logical thought to her own end. And I'm quite serious about this point; everything from Aristotle to Plato is up for her feminist critique regardless of the logical consequences. She's the classic self-annointed liberal who deems herself better than everyone else.

But to her credit she was also quite pleasant, if brusque, in conversations I had with her after class.

Thankfully the economics and the law crowd has pushed beyond the mushy type of thinking she does and brought some foundation to legal thinking in many of the areas she contaminated. Thanks Coase, Shavell, et al.

(11) Veeshir made the following comment | Oct 17, 2004 8:56:08 AM | Permalink

He should use the Clinton/NOW argument, you get one free sexual harassment.

(12) Patrick R. Sullivan made the following comment | Oct 17, 2004 1:44:10 PM | Permalink

"I have noted that the man is emphatically Not Stupid."

I'd have to dissent from that judgment. He's the kind of stupid you get from egomaniacs, which would serve well a woman who was intent on manufacturing a sexual harrassment claim.

(13) vlad made the following comment | Oct 17, 2004 5:04:50 PM | Permalink

I have heard that Andrea Mackris works for Russian FSB or KGB,maybe its truth.

(14) John Foster made the following comment | Oct 18, 2004 8:27:49 AM | Permalink

One point that is not clear to me: You refer to her "unsworn complaint," and, indeed, the copy of the complaint at The Smoking Gun ends with the lawyer's signature. The first page of the complaint, however, describes the complaint as "verified," which, under NY practice, would mean that the final page of the complaint is a sworn verification by the plaintiff. Is there a page missing from the Smoking Gun copy? Or did the plaintiff's lawyer draft the complaint poorly?

(15) Joshua Chamberlain made the following comment | Oct 18, 2004 2:05:37 PM | Permalink

Beldar, there is one thing missing from your post: $60 million. That's what Bendict Morelli demanded to keep the suit out of the news, even though he has a terrible case. I'm liking O'Relly's odds on the extortion suit, and I'm also liking that O'Reilly will be able to get Makris's suit kicked on a summary judgment motion. But you're right about one thing: this is definitely crisis litigation, where you're moving quickly to achieve political and public relations goals, even if you haven't done full discovery and are taking some risks that things will turn up that surprise you. However, in a media cultural where people's reputations can be totally destroyed in a few minutes, what else is one to do? I think the assumption that Ron Green is doing something against his better judgement because O'Reilly is making him isn't credible. Green's already got plenty of money; he really doesn't need this job.

(16) ed made the following comment | Oct 19, 2004 11:51:32 AM | Permalink


Now it is starting to get interesting:

NY Daily News

Interesting quote:

Paratore suggested that Mackris may have been motivated to file suit because of her proposed book.

"He told us that Mackris confided in him that she wrote a book and the purpose of it was to take down Bill O'Reilly and Fox News," said O'Reilly's lawyer Ronald Green. "She spoke to a well-known publisher in January this year. She was told it had to have more impact, she had to do more to make the book more interesting and exciting."

That ties into the timeline rather nicely. If you're writing a tell-all book that's going to cause unholy havoc, then it's best if you've already left for another job. That way you can have a better chance of beating the "disgruntled employee" rap. What might have caused her to reappraise everything is her termination at CNN in April and the need for more dirt. Since her publisher, allegedy/supposed/speculation, told her she needed more exciting stuff, she then decided to try and return to O'Reilly in order to acquire it during another period of employment at FNC.

So the question is: Why was she let go from CNN in April?

Did she quit? Was she fired? Was she involved in the sexual harrassment case that got her boss fired? Did she learn how much more money there was in a sexual harrassment case than in publishing a book? That suing for harrassment and THEN writing a tell-all book gives you the best of all worlds?

Who was the litigant's lawyer in that CNN sexual harrassment case? Morelli? Is this how they hooked up?


Just speculation on my part but it really is starting to appear that the whole thing was either a setup from the beginning or a romance that turned sour, and then turned into a setup.

I think Ms. Mackris is going to have her head handed to her by O'Reilly.

(17) cj made the following comment | Oct 20, 2004 12:04:37 AM | Permalink

Well, I don't buy the "entrapment" argument (on its face) -- I can see reasonable doubt that somebody would want to record those messages to prove a case, without "creating" the case, so to speak. What I never, ever, understand is the argument that women have to "return" to the scene of the crime (I think this applied to Anita Hill, who followed C. Thomas to another position.) That, to me, substantially weakens the case for sexual harrassment -- purely on a "reality" basis, not a "letter of the law" basis (which I know not).

(18) ed made the following comment | Oct 20, 2004 3:59:46 PM | Permalink


Well it's gotten even stranger. Mackris went and told her friends that she was fired from FNC then went and cleared her desk out. After she did that then her lawyer amended their lawsuit to include damages for her getting fired.

But the lawyers for FNC claim that FNC didn't fire her and that she was being paid while she stayed home during this lawsuit. In fact the lawyers for FNC made a motion to see if they could in fact fire her without incurring any penalties as firing whistleblowers is heavily penalized in NYC.

So. She claims she was fired, acts like she was fired and then uses that firing to amend her lawsuit for even more money?

IMHO her case is looking more and more like the emenations of a crackpipe.

(19) Mike Harris made the following comment | Oct 22, 2004 4:41:59 PM | Permalink

I'm curious as to why anyone could believe that O'Reilly will "hand anyone their head" over this. I agree that the "tell all book" deal is the most likely explanation for all this and that she *was* probably setting him up, though of course I could be completely wrong.

Now I know that democrat adultery (ala Clinton - also set up by a similar wannabe tell all book) is always much much more serious - treasonous really- than Republican adultery. Still its hard to see how O'Reilly comes out of this smelling like a rose.

If tapes exist that prove O'Reilly said what's alleged, they will almost certainly become public. When that happens he will be awfully embarrassed won't he? Might he not even lose his job, since that's what he's always advocated for others in this situation? Of course Rush always advocated prison for drug offendors too and his audience doesn't seem to have a problem with this either, so maybe I'm way off base here.

Still, it seems to me that even if his audience, which seems to be quite prurient when it comes to evaluating the sins of others, isn't put off by the seduction attempt (and yes I know that they tend to be very forgiving when its their guy's hormones that go a bit out of whack), what about all those hundreds of O'Reilly's recorded statements about what an absolutely inhuman scumbag Bill Clinton is for displaying similar sexual urges? These will be played over and over again in the media -juxtaposed with the telephone recordings - and I don't think the'll make him look like quite the hero he likes to portray himself - at the very least - with those of us who aren't big fans.

I think things look awfully bad for O'Reilly and I'll bet he's sweating like a stuck pin in anticipation no matter what the legal outcome is.

And I really feel so awfully bad for him too.

- Mike

(20) Chickcharney made the following comment | Oct 24, 2004 12:28:51 PM | Permalink

I predict O'Reilly will come out of this smelling like a...loofa.

(21) M. Visek made the following comment | Oct 30, 2004 12:23:37 AM | Permalink

How do they evaluate/price these kinds of cases. Is it so much per occurrence or is it solely based on the amount of insurance funds available divided by the number of offenders? Thanks.

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