2005: The Art of Animal Advocacy: Using Litigation, Legislation, and Science to Advocate for Animals

For information on future Animal Law Conference dates and locations, visit animallawconference.org.

Friday, October 14
Registration: 2:00-6:00 pm

3:00-4:15
Room 7: Protecting Wildlife through Science and the Law
Daniel Rohlf, Corey Evans, and Geneva Page

Room 8: Legal Strategies to Combat Confined Animal Feeding Operations
Andrew Hanson

4:20-5:45
Room 7: Legal Strategies to Fight Animal Research
Corey Evans, Geneva Page, and Peter Petersan

Room 8: Evolving Legal Standards for Captive Exotic Animals
Nicole Paquette, and Jill Buckley

Pioneer Express Shuttles leave at 6:05 and 7:05

Evening Reception and Auction

Saturday, October 15
Registration 8:30-3:30
Vegan continental breakfast available.
Luggage storage in the Lezak Seminar Room.

9:30-10:45
Room 7: Protecting Animals on the Local Level: The Effect of Preemption on City Ordinances Peter Brandt and Orly Degani

Room 8: Advancing Humane Standards
Mindy Kursban and Carter Dillard

11:00-12:15
Room 7: Advancing Protections for Companion Animals
Christopher Green, Jill Buckley, Geordie Duckler, and Pamela Frasch

Room 8: International Protections for Wildlife
Kitty Block, Chris Wold and Adam Roberts

12:15-1:15
Vegan BBQ lunch in the Amphitheater

1:15-2:30
Room 7: Gaining Power for Animals in the Lawmaking Arena: Voting blocs, Lobbying, and Ballot Initiatives
Julie Lewin and Nancy Perry

Room 8: Animal Rescue in the Wake of Hurricane Katrina
Peter Brandt, Andrew Ireland Moore and Stephanie Engelsman

2:40-4:10
Room 7: Advancing Protections for Farmed Animals
David J. Wolfson, Nancy Perry, Carter Dillard, and Mariann Sullivan

Room 8: Legal Strategies to Promote Predator Recovery
Brent Foster, Tanya Shenk and Minette Johnson

Bus loads at main gate of undergraduate campus.

Retreat to
4:45 Bus leaves for The Inn at Otter Crest

7:30-9:30 Banquet at the Inn including a keynote address by Jonathan Lovvorn, Vice President of Animal Protection Litigation with The Humane Society of the United States

Sunday, October 16 at the Inn at Otter Crest

Breakfast and activities on your own.

Break out sessions:

Room A:
10:00: Careers in Animal Law
Led by Laura Ireland Moore, David J. Wolfson, Coby Dolan
11:00: Animal Law Student Organizations
Led by Katherine Lin, Matt Simpson, Laura Ireland Moore

Room B:
10:00: How to Incorporate Animal Law into your Practice
Led by Scott Beckstead, Corey Evans, Geneva Page, and Pamela Alexander
11:00: Animal Law State and Local Bar Sections
Led by Mindy Kursban, Mariann Sullivan, and Stephen Wells

Room C:
10:00-12:00: Voting Bloc/Lobby Training
Led by Julie Lewin

12:00 Address by Coby Dolan
Box lunches provided.

1:30 Bus leaves to Pioneer Courthouse Square downtown (4:00) and Airport (arriving at 4:30 pm)

Coast activities include surfing, hiking in the woods or on the beach, tours of Newport and Rogue River Brewery, and visiting beautiful parks.

Animal Law Conference Speaker Biographies

Pamela Alexander, Esq.

Pam is the Staff Attorney for the Animal Legal Defense Fund’s Animal Law Program. In this capacity, she works closely with law schools, law students and law professionals interested in the dynamic field of animal law. Prior to joining ALDF, she was in private practice and co-taught the first animal law course at the University of Wisconsin ”“ Madison. While Pam was in law school, she co-founded Wisconsin United for Furry Friends (WUFF), a nonprofit animal welfare organization dedicated to recognizing the role of companion animals in family violence. Through the SAAV (Sheltering Animals of Abuse Victims) Program, WUFF helps provide temporary, safe, and confidential shelter where domestic abuse victims can place their companion animals while fleeing from abusive relationships.

Scott Beckstead, Esq.

Scott has been a practicing lawyer since 1991. His practice is on the central Oregon coast in the small town of Waldport, where he also serves as the Mayor. Although his practice is varied and diverse, he also specializes in animal law. Scott advocates for animals in court and in the political arena. He has served as President of the Central Coast Humane Society and is a former director of Humane Oregon.

Kitty Block, Esq.

Kitty Block is the Director of Treaty Law Oceans and Wildlife Protection for The Humane Society of the US. She oversees efforts in international treaties and agreements including the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), International Whaling Commission (IWC), Inter-American Tropical Tuna Commission (IATTC), Cartagena Convention/Protocol to the Specially Protected Areas and Wildlife (SPAW), and the Convention on Migratory Species (CMS). Ms. Block actively lobbies member countries to the relevant agreements, drafts proscriptive language (resolutions, convention amendments etc.), presents policy papers and serves on oversight panels. Ms. Block provides legal analysis and drafts position papers on and international laws involving animals. Ms. Block serves on the International Review Panel of the IATTC.

Jill Buckley, Esq.

Jill Buckley is a graduate of the University of Denver College of Law. She has been a lawyer for the past 20 years, practicing in insurance defense and coverage, and is licensed to practice in both California and Colorado.

Ms. Buckley is presently the Western Region Legislative Liaison for the ASPCA. In this capacity, she is responsible for lobbying state legislators and key government officials pertaining to animal welfare legislation in 20 western states. She also responds to legal questions posed by individuals and works with the media to publicize legislative issues.

Ms. Buckley served on the Board of Directors of the Rancho Coastal Humane Society in Encinitas, CA from 1992-1999 serving as president from 1996-1999. She is active in her local community as an attorney and animal advocate. She is currently the president of the San Luis Obispo Women Lawyers’ Association, serves on the California State Bar Committee on Professional Liability Insurance and is a member of the San Luis Obispo Animal Coalition. Ms. Buckley also gives lectures to lawyers and law students on the emerging area of animal law.

Orly Degani, Esq.

Orly Degani is special counsel in the appellate department of Sedgwick, Detert, Moran & Arnold’s Los Angeles office. She holds a JD from Stanford University Law School and a BA from the University of California at Los Angeles (UCLA). As part of her practice, she represents a number of animal protection organizations and individuals engaged in litigation concerning animals, and is also actively involved in legislative efforts on behalf of animals. She is the founder and chair of the Los Angeles County Bar Association’s Animal Issues Committee and Los Angeles Lawyers for Animals, and has taught a course on Animal Law at The University of Southern California (USC) Law School. In 2005, she was recognized by the California Daily Journal as a “Top 20 Under 40” attorney. She was also named a “Southern California Super Lawyer-Rising Star” in 2004, and again in 2005, by the publishers of Los Angeles Magazine and The Journal for Law and Politics.

Carter Dillard, Esq.

Carter is a Staff Attorney with The Humane Society of the United States. Carter received his Bachelor’s degree from Boston College and JD from Emory University before serving as legal counsel to the U.S. Department of Justice in 1999 and U.S. Department of Homeland Security in 2003. Carter worked as Staff Attorney for Compassion Over Killing before joining the Animal Protection Litigation Department of The HSUS in spring of 2005.

Coby Dolan, Esq.

Coby Dolan is staff attorney for fish conservation with The Ocean Conservancy in their Washington, D.C. headquarters. Mr. Dolan has litigated on behalf of marine animals for the past six years in both federal and state courts, including efforts to protect Florida manatees, leatherback and loggerhead sea turtles, and a variety of fish species. He also helped to get an ESA listing for smalltooth sawfish, the first U.S. marine fish species listed under the Act. Mr. Dolan also lobbies Congress on ocean conservation issues and is an advocate before federal agencies with a focus on fish conservation under the Magnuson-Stevens Fishery Conservation and Management Act. Prior to coming to The Ocean Conservancy, Mr. Dolan was an associate attorney with Earthjustice Legal Defense Fund. Mr. Dolan received his J.D from Lewis & Clark Law School in 1999 and his BA from Duke University in 1989. He was also a 2-time Editor-in-Chief of the Animal Law Journal.

Geordie Duckler, Esq.

Geordie is an animal law attorney in Portland, Oregon. The majority of his clients are companion, domestic, and exotic animal owners, and a significant component of his practice revolves around litigation of animal-related injuries and issues. Geordie received his JD from Lewis & Clark Law School in 1987 and his doctorate in biology from UCLA in 1997. He currently teaches Animal Law at Lewis & Clark Law School.

Stephanie Engelsman, Esq.

Stephanie Engelsman received her JD and Certificate in Natural Resources from Lewis & Clark Law School in 2004. While in school, she was an Associate Editor and then Form & Style Editor of the Animal Law Journal, a member of SALDF, and runner-up at the first National Animal Advocacy Competition held at Harvard Law School. She is now Staff Attorney with the Animal Legal Defense Fund’s Anti-Cruelty office in Portland where she works on civil litigation, legislation and anti-cruelty efforts in order to advance the interests of animals. Stephanie’s article “World Leader” - at what price? A look at lagging American animal protection laws will be published this fall by Pace Environmental Law Review.

Corey Evans, Esq.

Corey is the founding partner of Evans & Page, a civil litigation animal law office located in San Francisco California. Mr. Evans graduated from Santa Clara University. Prior to starting Evans & Page, Mr. Evans worked as a corporate lawyer doing mergers, acquisitions, and stock offerings for Skadden Arps Slate Meagher & Flom LLP. Mr. Evans’ practice includes civil suits brought by nonprofits to stop the inhumane treatment of animals, civil suits brought on behalf of animal guardians whose animals have been wrongfully injured, free speech litigation, California Public Records’ Act litigation, and defending dogs in dangerous dog hearings. Mr. Evans was co-counsel in the recent animal cruelty case against Sonoma Foie Gras. Mr. Evans and Geneva Page will be teaching an Animal Law course at Santa Clara University in Spring 2006.

Pamela Frasch, JD

Pamela Frasch currently serves as a member of the Animal Legal Defense Fund’s management team which is responsible for program development, general marketing and communication strategies. She also serves as the director of the anti-cruelty division of the organization. She is a co-author of the Animal Law casebook and currently teaches animal law at Lewis & Clark Law School.

Brent Foster, Esq.

Brent Foster is the Executive Director of Columbia Riverkeeper and is an environmental attorney who has worked on a number of water quality and public lands issues, including wolf recovery in Oregon. In addition to his legal work, Brent has experience conducting gray wolf surveys in Montana and Washington State. He also serves as Conservation Chair for the Oregon Chapter of the Sierra Club.

Brent received his law degree from Northwestern School of Law of Lewis & Clark College in 1999 and has a BS in Ecology and a BA in Environmental Science from the University of California at Santa Barbara. His background includes work designing and implementing habitat restoration projects in riparian, oak woodland and native grassland habitats. Brent has published a number of legal journal articles on enforcement of state and federal environmental laws.

Chris Green, JD

Chris received his JD from Harvard Law School an is the author of The Future of Veterinary Malpractice Liability in the Care of Companion Animals, 10 Animal L. 163 (2004), said to be the most comprehensive and well researched paper on veterinary malpractice. Green frequently lectures on Civil Damages / Animal Valuation matters at veterinary colleges and legal conferences around the country. He also has consulted for both 60 Minutes and The Washington Post on veterinary legal issues. He was a participant of the California Veterinary Medical Association’s Non-Economic Recovery Task Force exploring legislative options available to the organization to address increasing liability exposure and a speaker at the American Veterinary Medical Law Association annual conference.

Andrew Hanson, Esq.

Andrew Hanson received his Juris Doctor with a Certificate in Environmental and Natural Resources Law at the Northwestern School of Law of Lewis & Clark College in 2001. Mr. Hanson served as an Equal Justice Works Fellow working with Midwest Environmental Advocates, and is currently an Environmental Leadership Program Fellow serving as a Staff Attorney for Midwest Environmental Advocates. He provides legal, organizing, and technical assistance to communities working for clean air and water. Mr. Hanson has focused for the past several years on using the law and community organizing to help rural communities control the air and water pollution generated by Concentrated Animal Feeding Operations, or otherwise known as livestock factories.

Andrew N. Ireland Moore, JD

Drew Moore received his JD and Certificate in Natural Resources and Environmental Law from Lewis & Clark Law School in 2004. As a student, he was co-president of L&C’s Student Animal Legal Defense Fund and was Articles Editor for two volumes of the Animal Law Review. He has worked with the Savannah Humane Society, and with the Oregon Humane Society (OHS). With OHS, he was an Investigations Officer and a founding member of their Technical Animal Rescue Team (OHSTAR). He is currently studying Fisheries & Wildlife Science at Oregon State University. Articles include Caging Animal Advocates’ Political Freedoms: The Unconstitutionality of the Animal & Ecological Terrorism Act, 11 Animal L. 255 (2004), and Defining Animals as Crime Victims, 1 J. Animal L. ___ (2005).

Laura Ireland Moore, Esq.

Laura is the founder and executive director of the National Center for Animal Law. The Center promotes legal education for animal advocacy to encourage and support students’ goals of becoming legal advocates for animals. She received her JD and certificate in Environmental and Natural Resources Law from Lewis & Clark Law School in 2001. As a student, she was Editor in Chief of the Animal Law Review, and director of the L&C chapter of the Student Animal Legal Defense Fund. In addition to her work with the Center, Laura is a practicing animal law attorney and a board member of Humane USA-Oregon. She teaches the Animal Law Clinical Internship Seminar at Lewis & Clark Law School.

Minette Johnson

Minette Johnson is Defenders’ Northern Rockies Representative based in Missoula, Montana. Minette has worked on wildlife conservation for 16 years, 11 for Defenders. In Montana, her efforts focus on grizzly bear conservation and recovery in the lower 48. Much of her time is spent on paying ranchers compensation when grizzly bears kill livestock and working in partnership with local landowners and state, tribal and federal officials to prevent bear/human conflicts. Minette has also helped restore on swift foxes, black-footed ferrets, buffalo and and prairie dogs to the Great Plains. Her previous jobs have ranged from being a field biologist studying coyotes in Yellowstone National Park to assisting in the creation of the first book published on global marine biodiversity. After growing up in New England and spending several years working in Washington, DC, she headed to Montana due to her fondness for large carnivores. Minette holds a Masters of Science in Environmental Studies from the University of Montana and a Bachelors degree from Connecticut College.

Mindy Kursban, Esq.

Mindy Kursban is Executive Director and General Counsel of the Physicians Committee for Responsible Medicine (PCRM), a nationwide group of physicians and laypeople based in Washington, D.C., that promotes preventive medicine through promotion of a plant-based diet, and advocates effective and ethical standards. Since joining PCRM in August 1999, she has focused on reforming nutritional policy and food industry practices and eliminating the use of animals in medical research. Current PCRM lawsuits include a negligent representation, product liability, and unfair and deceptive trade practices suit against Atkins Nutritionals based on the harmful health effects of the controversial high-protein, low-carbohydrate regimen; a suit against Merck & Co. for its wrongful reliance on tests showing Vioxx was safe in animals while ignoring mounting evidence that the drug is dangerous to humans; and a false advertising claim against dairy industry trade groups and dairy food manufacturers for making scientifically unsubstantiated claims about the effect of dairy products on weight-loss. Mindy holds a BS from the University of Maryland and a JD from the Emory University School of Law. She is a co-founder and current chair of the District of Columbia Bar Association’s Animal Law Committee.

Julie E. Lewin

Julie E. Lewin founded NIFAA: The National Institute for Animal Advocacy to empower animal rights and rescue advocates in the lawmaking arena. NIFAA’s three-fold mission is to create a strong political culture within animal advocacy, so we understand that political organizations at different levels of government are a mandatory, not optional, part of our advocacy; to train animal rescue and rights activists how to launch voting blocs for animals in their states, counties, cities and towns; and to develop political leadership to sustain these voting blocs. Julie gives workshops on why and how to launch voting blocs for animals around the US. She has received funding to write a political training manual for animal advocates and is in the second draft. Julie was a lobbyist with the Fund for Animals, a newspaper reporter, a nationally published magazine writer, and a criminal justice reformer.

Katherine Lin

Katherine is a second-year law student at Lewis & Clark. As a co-coordinator for SALDF, she enjoys spreading the good word on animal issues, veg-ism and how this and the fate of humanity are inextricably intertwined with the environment. She also is a student project coordinator with the Northwest Environmental Defense Center. In her spare time, she loves to run and bake original vegan treats.

Jonathan Lovvorn, Esq.

Jonathan Lovvorn is Vice President of Animal Protection Litigation for the Humane Society of the United States, Professorial Lecturer in Law at George Washington University School of Law, and Co-Director of the GW Animal Law Litigation Project-a joint HSUS/GW Law School Animal Law Clinic launched in 2005. Mr. Lovvorn has litigated extensively on behalf of animals in State and Federal Courts throughout the country. Prior to joining The HSUS, Mr. Lovvorn was a partner with Meyer & Glitzenstein — a public interest law firm in Washington, D.C. that specializes in environmental and animal protection litigation. During his tenure, he won numerous victories for animals in the courts, including a groundbreaking decision that prevented the federal government from capturing or killing more than 200 species of migratory birds in violation of international law. Mr. Lovvorn also spearheaded the legal campaign that facilitated the rescue of the “Suarez Seven” polar bears from a traveling circus in Puerto Rico. Other significant legal achievements under Lovvorn’s direction include federal court orders requiring the protection of California gray whales, Florida black bears, white-tailed deer, mute swans, endangered salmon, and the American bison. He has also successfully defended animal protection initiatives and referenda from legal attack in state and federal court. He has published several articles concerning animal protection and environmental policy, including a recent article on the mute swan controversy in the State of Maryland. Mr. Lovvorn is a 1995 graduate of Hastings College of the Law and holds an LLM in Environmental Law and Natural Resource Policy from Lewis & Clark Law School. Mr. Lovvorn also serves as an Advisor to the Animal Welfare Pro Bono Project at George Washington University Law School, and as a Visiting Professor of Animal Law at Lewis & Clark Law School.

Geneva Page, Esq.

Geneva is a partner at Evans & Page. Evans & Page is a civil litigation animal law office located in San Francisco California. Ms. Page graduated from Vermont Law School. Her studies at VLS focused on animal law, and shortly after graduating she began work at the Animal Protection Institute in Sacramento as their Government Affairs Coordinator. At API her responsibilities included lobbying state legislators, drafting proposed legislation, legal research and testifying at legislative hearings. Ms. Page received her Bachelor of Arts from San Francisco State University and has studied internationally in England and Costa Rica. Ms. Page and Corey Evans will be teaching an Animal Law course at Santa Clara University in Spring 2006.

Nicole G. Paquette, Esq.

Nicole G. Paquette is the General Counsel and Director of Legal and Government Affairs for the Animal Protection Institute, in Sacramento, CA. In this capacity, she oversees API’s litigation efforts and legislative efforts on the federal, state, and local levels; writes and introduces legislation; and lobbies Congress, State, and local governments on legislation affecting animals. In addition, she oversees API’s campaigns on captive wild animals. Nicole has assisted several states and cities with introducing and passing laws relating to private possession and prohibiting the display of exotic animals. Prior to joining the Animal Protection Institute, Nicole was an associate attorney in a small civil litigation firm in Washington, DC. Nicole is a 1998 graduate of Vermont Law School. She received a Bachelor of Arts in Political Science, with honors, in 1994 from San Francisco State University. She is a member of California, District of Columbia, and Massachusetts Bars.

Nancy Perry, JD

Nancy Perry is Vice President of Government Affairs for The Humane Society of the United States — the nation’s largest animal protection organization. On behalf of The HSUS, Ms. Perry organizes legislative, administrative, grassroots, and media efforts to protect animals at the state, federal, and local level; oversees statewide campaigns to enact citizen initiatives and referenda to protect animals; and supervises grassroots organization and fundraising efforts throughout the country. She is a graduate of Northwestern School of Law of Lewis & Clark College, where she founded the Student Animal Legal Defense Fund, the Animal Law Review (the nation’s first and only animal law review), and the annual Animal Law conference. Ms. Perry teaches the Animal and Wildlife Law Seminar at George Washington University Law School, and a summer intensive workshop entitled Animal Law: Legislation, Lobbying and Litigation at Lewis & Clark Law School. She currently serves as president for the National Center for Animal Law and a national advisor to the Animal Law Review.

Peter Petersan, Esq.

Peter is the deputy director of Animal Protection Litigation for The Humane Society of the United States. In addition to his legal work he supervises student interns and fellows. He received his JD from American University -Washington College of Law in 2003.

Adam M. Roberts

Adam M. Roberts is the Vice President of Born Free USA, a wildlife conservation and animal protection organization based in Washington, DC. Born Free USA is the American companion organization to the United Kingdom-based Born Free Foundation founded by the stars of the film Born Free. Prior to launching Born Free USA, Adam spent nearly 14 years With the Animal Welfare Institute and Society for Animal Protective Legislation. Adam also founded and runs The $10 Club, a philanthropic organization established to fund poverty alleviation projects across the globe. He is also on the Board of Directors of Humane USA PAC a national political action committee for animal protection. He lives in Washington, DC with his wife, Stephanie, daughter Mia, stepdaughter Bella, 3 dogs, 5 cats, and one very important Hamster.

Daniel Rohlf, Esq.

Dan Rohlf is a founder and Director of the Pacific Environmental Advocacy Center, an environmental clinic at Lewis & Clark Law School. Dan oversees its operations and leads the Environmental Clinic course. Dan also teaches courses in wildlife law, the Endangered Species Act, environmental litigation, and the intersection of ecology and the law, and he serves as an advisor to the Animal Law Review. Dan received his BA degree in geology from Colorado College and his JD from Stanford. After law school he served as a clerk for Justice Jay Rabinowitz of the Alaska Supreme Court.

Tanya Shenk

Ms. Shenk is a Wildlife Researcher for the Colorado Division of Wildlife, specializing in population dynamics of threatened and endangered species. She received her BS in Zoology from Ohio State University, and her M.S. and PhD. in Fishery and Wildlife Biology from Colorado State University. Her current projects include the demography and movement patterns of the Preble’s meadow jumping mouse and the reintroduction of Canada lynx to Colorado.

Matthew Simpson

Matt Simpson is a second year law student at Lewis & Clark. He is a co-coordinator of SALDF and articles editor on the Animal Law journal. Matt also enjoys long walks on the beach and throwing tennis balls with Howard and Bootsie, his friendly canine housemates.

Mariann Sullivan, Esq.

Ms. Sullivan is the deputy chief court attorney for the New York State Appellate Division, First Department. She is the former chair of the Committee on Legal Issues Pertaining to Animals of the Association of the Bar of the City of New York and a current member of that committee as well as of the Special Committee on Animals and the Law of the New York State Bar Association. She is co-author, along with David Wolfson, of “Foxes in the Henhouse: Animals, Agribusiness and the Law” in Animal Rights: Current Debates and New Directions (Oxford Univ. Press, 2004).

Stephen Wells

Stephen Wells currently serves as a member of the Animal Legal Defense Fund’s management team which is responsible for program development, general marketing and communication strategies. He is also the director of the Animal Legal Defense Fund’s Animal Law Program, responsible for managing programs that relate to the organization’s 300 attorney volunteers and 53 law student chapters nationwide. Stephen was previously the Executive Director of the Alaska Wildlife Alliance in Anchorage. A passionate advocate for animals and the environment, he has been interviewed by the New York Times, Good Morning America, NBC Nightly News, and CNN.

Chris Wold, Esq.

Chris is an Associate Professor of Law and Director of the International Environmental Law Project at Lewis & Clark Law School. His courses include International Environmental Law, Trade and the Environment, Ocean and Coastal Law, Comparative Environmental Law, and Marine Law and Ecology. He received a BA cum laude in 1986 from St. Olaf College, and JD Northwestern School of Law of Lewis & Clark College. Before coming to the law school, he was a staff attorney with the Center for International Environmental Law (CIEL), where he focused on international wildlife law issues and international financial institutions. He has traveled to Australia, Japan, Kenya, and Zimbabwe to participate in Meetings of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora and the International Whaling Commission (IWC).

David J. Wolfson, Esq.

David J. Wolfson is a partner in the Global Corporate group at Milbank, Tweed, Hadley & McCloy LLP. He represents a number of animal protection groups and has written extensively on animal protection law. He has taught animal law at Harvard Law School, Yale Law School and Benjamin N. Cardozo Law School, and is currently teaching animal law at Columbia Law School and NYU Law School. He is the author of a number of articles and a co-author of “Foxes in the Henhouse: Animals, Agribusiness and the Law” in Animal Rights: Current Debates and New Directions (Oxford Univ. Press, 2004).