Standard of Care Consultants: 81

James M. Wheeler, MD, MPH, JD, magna cum laude in Biology / Psychology from Harvard, is an OB/GYN trained at Baylor, with subspecialty training in Reproductive Endocrinology / Infertility at Yale. He is also a graduate of the Robert Wood Johnson Clinical Scholars Program at Yale, focusing upon clinical epidemiology and biostatistics and health policy. He also earned his MPH at Yale majoring in Biostatistics, minoring in Maternal/Child Health. He graduated from the University of Houston Law Center with a JD in 2005, and was invited to join the Health Law division there. He has completed ADR training, having completed training programs separately in mediation, and arbitration.

Dr. Wheeler is a former national officer of the American College of Obstetricians and Gynecologists (ACOG), and served on several of their health policy committees including the Health Care Commission and the Hysterectomy Committee. He has published over 40 peer-reviewed papers on a wide array of topics in ob/gyn, with a particular emphasis on methodology. He has given over 200 invited lectures to ob/gyns, reproductive endocrinologists, radiologists, midwives, nurses, surgical technologists, law students et al. He sees himself first and foremost as a caregiver, and second to only that, as a teacher.

Dr. Wheeler has consulted in several hundred medicolegal matters for over 20 years, mostly in ob/gyn, but including family practice, internal medicine and several of its subspecialties, general surgery and several of its subspecialties, and dermatology. He has been a testifying expert before the FDA for drugs and devices, and has testified before U.S. Congressional staffers on health policy issues. He reviews for attorneys from both plaintiff and defense bars, as well as insurance companies (e.g. Pro-Assurance), and health plans (e.g. Harvard Community Health Plan). He has helped with Board of Medicine reviews, and constructing/defending class action suits. The combination of his training in medicine, basic and clinical research, clinical epidemiology, biostatistics and law make him a uniquely qualified person to review the complex issues of medicolegal cases.

Dr. Wheeler is a qualified first-reviewer, and a convincing expert during testimony. He has never been excused from a case as insufficiently expert.

Areas of expertise:

Gynecologic surgery Forceps / Vacuum Uses/ Complications Fetal Stress vs. Distress Cesarean vs. Vaginal Birth Shoulder Dystocia Pregnancy induced Hypertension / HELLP Syndrome Hysterectomy: Indications and Complications

Preterm Labor Incompetent Cervix Endometriosis Pelvic Adhesions Leiomyomata Uteri Infertility Advanced Reproductive Technology (IVF)

Clinton F. Merrill, Jr., MD, has over 35 years of experience in clinical Internal Medicine and 28 years of experience in Medical Oncology and Hematology. Dr. Merrill is experienced in the diagnosis and treatment of all solid tumors as well as the full range of hematologic malignancies. He has special expertise in benign hematology including: anemias, low blood cell counts, iron overload disorders, bleeding and clotting disorders. Litigation Support - Dr. Merrill offers expert witness services to counsel representing Plaintiff and Defendant. His services include medical record review, written reports, depositions, and trial testimony. Dr. Merrill takes pride in providing thorough record review, meticulously researched reports reflecting unbiased opinions, and excellent communication skills with the ability to make the complex understandable. Areas of Expertise:

Breast Cancer Colon Cancer Lung Cancer Tumors Leukemias Lymphomas

Myeloma Myeloproliferative Disorders Myelodysplastic Syndromes Benign Hematology Anemia Bleeding and Clotting Disorders

Jeffrey Phillip Weinstein, AIA, a California licensed Architect and Construction Project Manager since 1982, with a Masters Degree in Real Estate Development from USC, is actively involved with development, design and construction management. Mr. Weinstein provides preconstruction (entitlements, plans, permits) through on-site construction administration services (change order analysis, cost evaluation) on a wide range of building types. 

Expertise: Mr. Weinstein has extensive experience in real estate development, acquiring government approvals, entitlements and permits, architect's standard of care, construction management, claims & defects, and A/E/C agreements. His expertise includes scope of services and design fees, zoning and building codes, errors/omissions, construction defects, destructive testing and repairs. 

Previous positions include Director of Operations, Preconstruction Director, Senior Project Manager, Construction Manager and Administrator for Nadel and Callison Architects, Tishman Construction, Trammel Crow Company, California State University and Goleta Valley Cottage Hospital.

 Project Experience: Mr. Weinstein's project experience includes high-rise residential and mixed-use developments, multi-family residential podium-type apartments and condominiums, retail, big box, neighborhood shopping centers and regional malls, corporate and tenant improvements, hospitality including wineries and breweries, themed resorts and casinos, K-12 and university buildings, hospitals and medical facilities, custom and production homes. 

Professional Licenses / Certifications / Affiliations:

• California Registered Architect, License #12822
• AIA Certified in Construction Management, Contract Administration and Specifications
• Member, American Institute of Architects, Urban Land Institute, Construction Specification Institute
• Member, North Santa Barbara County Board of Architectural Review

Professional Services Include:

• Architectural, Engineering and Construction (A/E/C) Project Management
• Owner’s Representative / Real Estate Development / LEED Design-Build
• Director of Operations and Pre-Construction Services / Construction Administrator
• Forensic Architect / Construction Expert Witness

View Jeffrey Weinstein's Expert Witness Profile.

Tracy L. Skaer, PharmD, FASHP, FASCP is a Professor Emeritus of Pharmacotherapy with over 30 years of pharmaceutical experience. Dr. Skaer's research and professional experience include pharmacy practice, chronic pain, mental health, substance abuse, and complementary and alternative medicine. She is licensed pharmacist in California, Idaho, and Washington.

Dr. Skaer’s current research involves the use of mindfulness and multiple family group problem solving for the Treatment of Chronic Pain in those with high risk of Opioid Use. Her plans are to expand this intervention to manage chronic insomnia and post-traumatic stress disorder in children and adolescents, American Indians, veterans, and other populations. Other research interests include chronic pain, comorbid mental illness in chronic disease, depression, anxiety disorders, insomnia, mindfulness, complementary and alternative medicine, and pharamcoeconomics and pharmacoepidemiology. Her research has been supported by over $3.2 million in grants from foundations and pharmaceutical industry.

Dr. Skaer has published 110 professional abstracts, 82 research papers, 43 review articles, and 6 book chapters. She serves on the editorial boards of 3 medical professional journals, Clinical Therapeutics, Journal of Sleep Medicine and Disorders, and Pain Studies and Treatment. Dr. Skaer's publications have appeared in numerous journals including, Drugs, Clinical Drug Investigation, PharmacoEconomics, Journal of Clinical Pharmacy & Therapeutics, American Journal of Medicine, Harvard Review of Psychiatry, and the New England Journal of Medicine among others.

View Dr. Skaer's Expert Witness Profile.

Dan W. Wall, BSME is a Mechanical Engineer who specializes in the fields of Accident Reconstruction, Biomechanics and Motor Vehicle Injury Causation, Human Factors, and Injury Prevention in Motor Vehicle Design. Mr. Wall offers his consulting services to attorneys, vehicle manufacturers, insurance companies, cities, states, counties, and individuals, both nationally and internationally.

Background Experience:

Wall Accident Reconstruction, Inc., 1996-Present, Investigation and reconstruction of traffic collisions, highway traffic safety, biomechanics of impact trauma, injury causation, engineering analysis of design and design failure, statistical analysis, human factors, slip and falls and expert witness testimony.

For more information, visit www.wallaccidentreconstruction.com

Also view Dan Wall's article in Attorney At Law Magazine at http://attorneyatlawmagazine.com/phoenix/2014/01/17/accident-reconstruction-expert-dan-wall/

Cromack Engineering Associates, Inc., Tempe, AZ, 1987-1998, Investigation and reconstruction of traffic collisions, product liability, biomechanics, and expert witness testimony.

Martin Marietta Aerospace, Denver, CO, 1980-1987, Senior Engineer, Design and analysis of aerospace systems. Projects included Man Maneuvering Unit with special recognition by NASA, Titan 34D Missile Systems, and Strategic Defense Initiative.

Summary of Experience:

Building & Roadway Construction & Design Automotive Technology Aircraft Technology and Maintenance Motorcycle Technology and Experience Off-road Experience and Design ATV Technology and Experience Slip and Fall Heavy Vehicle Trailer Design Commercial Trailer Under-ride Guard Design

FMVSS Standards Vehicle Design and Performance Tire Design and Failure Analysis Crash Worthiness Roadside Design Signage, Lighting, and Conspicuity Environmental Conditions and Effects Animation and Computer Simulations Crash and Acceleration Testing Low Speed Vehicle Collision Testing

View Dan Wall's Expert Witness Profile.

Bill Choby DMD PC provides a state-of-the-art facility for the highest quality Dental Care available. Modern dental technology allows them the opportunity to provide high quality solutions to oral health care whether complex oral reconstruction with implants or a simple dental examination. Services Provided:

• Implants - Dental Implants, Mini Implants
• Cosmetic Dentistry - Lumineers, Veneers, Whitening, Bonding
• Endodontics - Root Canal, Apicoectomy
• Restorative Dentistry - Bridges, Crowns, Dentures, Bonding
• Periodontics - Bone Grafting, Gum Grafting, Crown Lengthening, Frenectomy, Occlusal Adjustment, Osseous Grafting, Scaling / Root Planing
• Oral Surgery - Extractions, Bone Grafting, Facial Trauma, Oral Pathology, Sleep Apnea
• Orthodontics - TMJ, Night Guards

Principal, Willeam A. Choby, DMD, MPA, MAGD, FICCMO, DICOI, has over 40 years of experience Dentistry and Oral Surgery. He is a Board Certified Implant Dentist that perfoms both the Surgery and the Restoration of Implant Teeth. A “Master” in the Academy of General Dentistry (MAGD), Dr. Choby has been recognized by other general dentists as a leader and an example to other dentists of the importance of quality continuing dental education to patient care. Masters have accepted the charge to keep abreast of advances in dentistry for the benefit of patients and the betterment of dentistry. Dr Choby is also a Fellow in the International College of Cranio-Mandibular Orthopedics (FICCMO), earned a Masters of Public Administration (MPA), and is a Diplomate of the International Congress of Oral Implantologists (DICOI). Dr. Choby is recognized as One of America's Top Dentists by the Consumers Research Council of America. He recently demonstrated an innovative root canal system before the American Association of Endodontists in Washington DC. View Dr. Choby's Expert Witness Profile.

Richard M. Teichner, CPA, ABV, CVA, MAFF, CFF, CRFAC, CRFAU, DABFA, FCPA, CGMA, CDFA, licensed in both Nevada and California, has over 45 years of experience in public accounting, and for approximately 25 of those years his areas of practice have been primarily providing expert services and consulting services in business litigation and family law matters. With offices in Reno and Las Vegas, Nevada, Mr. Teichner's practice extends to various jurisdictions throughout the United States.  Although Mr. Teichner's services are mainly weighted toward complex business litigation and divorce matters, they also include performing valuations of businesses and business interests for estate tax and gifting purposes and for buy-sell situations. Clients have been both businesses and individuals involved in various industries, such as manufacturing, distribution, retail sales, construction, real estate development, and transportation, and in professional practices, e.g. medical, law and accounting, and other service businesses.

Litigation Matters - Expert services are provided to business litigation and family law litigation attorneys representing either plaintiffs or defendants. Presently, Mr. Teichner has testified 50 times at trial and 47 times at depositions. He has been engaged as a testifying expert or consultant in a variety of complex business litigation and family law matters. Such matters have involved forensic accounting, damages claims; contract disputes; disputes among business owners; fraud, including white collar crime; breaches of fiduciary duty; standards of care; and personal injury and wrongful death.  Family law matters have involved property division, tracing, marital waste, alimony, business valuations, and tax implications of divorce.

Additionally, Mr. Teichner provides receivership services.

Areas of Expertise:

Economic Damages / Lost Profits Forensic Accounting Financial Fraud Personal Injury / Wrongful Death Damages Divorce and Family Law Matters

Business Valuations / Appraisal Franchise Valuation Intangible Assets Appraisal White Collar Crime Standards of Care; Breach of Fiduciary Duties

Reno Office 3500 Lakeside Ct, Suite 210 Reno, Nevada, 89509 Telephone: (775) 828-7474 or (775) 530-5106

Las Vegas Office 8275 S. Eastern Avenue, Suite 200 Las Vegas, Nevada 89123 Telephone: (702) 724-2645 or (702) 467-8335

Roy G. Taylor is a current Chief of Police with over 40 years of experience in a wide-range of federal, state, local, and private criminal justice positions. He delivers comprehensive and intelligent Law Enforcement and Security Services to federal, state, and local governments, and is authorized to work on private or government properties including parks, any government owned buildings, land, public housing communities, hospitals, schools, or similar areas. 

Dr. Taylor's experience and expertise includes use of force and firearms instruction; recruiting, selection and assignment; employee supervision, evaluation and retention; curriculum development; policies and procedures design and implementation; canine utilization; budgeting; public relations; and emergency management. 

Current Positions:

• Chief of Police Blue Ridge Public Safety (2014)
• President/CEO Signal 88 Security of Charlotte (2012)
• President/CEO Capitol Special Patrol (2012)
• Chief of Police Capitol Special Police (2002)
• LT. Colonel – Provost Marshal, Army National Guard (2000)
• Antiterrorism / Emergency Management Branch Chief DoD (2007)
• Provost Marshal Joint Civil Support Task Force, Joint Chiefs of Staff (2014)

Specific Services:

Mobile Patrol Stationary Guard Alarm Response Residential and Commercial Business Checks ATM / Bank Escorts VIP / Management Escorts Investigations Arrest of Violators

Hostile Employee Terminations Emergency Response Planning Site Security Assessments Crime Prevention Seminars Anti-Terrorism Instruction Community Policing Programs In-Service Law Enforcement Training Public Relations

View Roy Taylor's Expert Witness Profile.

Suzanne Dupée. MD is a triple-board certified Child, Adolescent, and Forensic Psychiatrist practicing in Manhattan Beach in Los Angeles County, Southern California.  She specializes in a wide range of psychiatric services for children, adolescents, adults and families.

Dr  Dupée completed her general psychiatric residency at Cedars Sinai Medical Center in Los Angeles.  She furthered her training by studying Child & Adolescent Psychiatry at the University of California, San Diego.  She then moved to New York City to complete a Forensic Psychiatric Fellowship at New York University.

In private practice in Los Angeles since 2002, Dr. Dupée's practice includes treating children, adolescents and adults for Medication Management.  She specializes in the diagnosis and treatment of Attention Deficit, Hyperactivity Disorder, Depression, Anxiety, and other Psychiatric Conditions in children, adolescents and adults. 

Dr. Dupée is invited to speak to at presentations and trainings for mental health and legal professionals.  Her Manhattan Beach office is located one block from the beach and one block from the pier in beautiful Manhattan Beach, CA.  Her office provides a warm, comfortable, child-friendly relaxing atmosphere for her patients and evaluees.

Dr. Dupée is currently authoring several chapters in the seminal forensic psychiatric textbook, Principles and Practice of Forensic Psychiatry.  Dr. Dupée taught forensic psychiatry trainees at UCLA for over 10 years until the Forensic Psychiatry program ended.  She is an Associate Clinical Professor at the University of California, Irvine where she trains forensic psychiatry trainees.

View Dr. Dupée's Expert Witness Profile.

Sunset Consultants is an Architectural and Engineering Management firm that provides professional strategic planning and management consulting services for various entities, including those that need help with planning or architectural projects. Sunset's clients include well-established design firms and new professionals learning the basics of running an independent business. Sunset provides the following services:

Project Management Profit and Loss Analysis Business Development

Merger and Acquisition Analysis Sales and Marketing Advice Strategic Planning

Principal, David J. Brotman, FAIA, is an accomplished Senior Executive with a proven career and solid experience in all aspects of Architectural and Engineering Firm Management. Mr. Brotman's skills include all facets of Architectural Practice. His worldwide, multi-million dollar project experience includes retail, office, hotel, institutional, and mixed-use. 

Mr. Brotman has a successful track record and expert qualifications in improving quality of work, market share, delivering strong revenue, and profit gains. His experience encompasses start-up, turnaround, high-growth, and multi-national operations. David Brotman holds a reputation among colleagues, subordinates, and associates for creative imagination, vision, team building, and leadership skills. He specializes in envisioning an end-result, then leading a management team to realize that result with marked improvements along the way.

 View David Brotman's Expert Witness Profile.

William B. Stetson, MD specializes in Sports Medicine with an expertise in Arthroscopic and Reconstructive Surgery of the shoulder, knee, elbow and ankle. He has first hand knowledge of athletic injuries and the desire that all of us have to “get back in the game”. He is an associate clinical professor of orthopedic surgery at the USC Keck School of Medicine and is the team physician on the USA Men’s and Women’s volleyball teams and was with both teams in London, England for the 2012 Summer Olympics. 

Dr. Stetson utilizes leading edge diagnostic solutions to assess and repair knee injuries, shoulder injuries, elbow injuries, and conditions relating to Arthritis . State-of-the-art, minimally invasive surgery techniques such as arthroscopic surgery means faster recovery times.

Areas of Orthopedic and Sports Medicine Specialization:

Knee Arthroscopy Shoulder Arthroscopy Rotator Cuff Repair ACL Reconstruction Treatment of Arthritis

Knee Ligament Reconstruction Recurrent Shoulder Dislocation Shoulder Impingement / Bursitis Meniscus Repair and Meniscectomy Elbow Arthroscopy

Dr. Stetson has traveled extensively throughout the world teaching and lecturing about shoulder arthroscopy and recently returned from Romania and Beijing, China where he lectured about the latest techniques of shoulder arthroscopy. He has started a non-profit organization, Operation Arthroscopy, whose mission is to bring orthopaedic surgery and arthroscopy to countries and communities in need.

View Dr. Stetson's Expert Witness Profile.

Elliott M. Stein, MD is a Geriatric Psychiatrist with over 45 years of experience caring for the elderly. Dr. Stein is Board Certified by the American Board of Psychiatry and Neurology in General Psychiatry (October, 1979) and Geriatric Psychiatry (April, 1991; Re-Certified, December, 2001, April, 2011, December 2022). He is licensed in California and Florida. Dr. Stein was the Director of Psychiatry at the Jewish Home of San Francisco from 2010-2020, and the Medical Director of their Geriatric Psychiatry Hospital. He has treated older individuals, typically people who have complex combination of psychiatric and medical problems. Dr. Stein has been a Member of the Task Force on Testamentary Capacity and Undue Influence, for the International PsychoGeriatric Association.

Dr. Stein is a Clinical Professor (Voluntary) in the Department of Psychiatry at the University of California, San Francisco, School of Medicine. He is a Distinguished Life Fellow of the American Psychiatric Association and a Distinguished Fellow of the American Association for Geriatric Psychiatry and a Life Member of the International PsychoGeriatric Association.

He is available to serve as an Expert Witness, do legal and forensic consultation, record review, and assessments concerning Psychiatric issues in Older Individuals. Dr. Stein offers his services to attorneys for both Plaintiff or Defense.

Consulting Specialties:

• Contested Wills and Trusts
• Testamentary Capacity, Undue Influence, Insane Delusions
• Geriatric Competence/Capacity
• Financial Elder Abuse
• Dementia and Delirium, Alzheimer’s Disease
• Geriatric Psychiatry Evaluation and Treatment, Psychiatric Medication, Psychotherapeutic Issues
• Depression and Anxiety Disorders
• Relationship Problems between the Elderly and their Adult Children
• Aging and Mental Disorders
• Geriatric Psychiatry issues concerning Hospitals, Nursing Homes, Independent and Assisted Living Facilities
• Medicare Psychiatric Services Coding and Documentation

View Dr. Stein's Expert Witness Profile.

Paul W. Burkett, JD, CPCU, CIC, ARM,CRM, ALCM, has been CEO of Snoaspen Insurance Group, Inc., since 1995. He has extensive experience:

• Providing Insurance Risk Management Consultant Services and Policy / Risk Management Program Audit Services to Commercial Clients and Agents/Brokers
• Providing Personal and Commercial Insurance Policy Coverage training for Agents, Brokers and Risk Managers

Mr. Burkett began his career as a Loss Control Representative for SAFECO Insurance Company after serving as an Officer in the United States Air Force. During his career with SAFECO, he served as a Loss Control Supervisor, Loss Control Manager, Commercial Sales Representative, Division Commercial Lines Underwriting Manager, and Regional Workers Compensation Manager.

From Safeco Insurance Company, Mr. Burkett worked for Frank B. Hall & Company as a Vice President in charge of Risk Management Services. From Frank B. Hall, Mr. Burkett assisted in establishing the Meadowbrook of Colorado office and focused on developing specialized group programs.

Paul Burkett delivers seminars as a National Instructor for Certified Insurance Counselor (CIC) Courses, National Instructor for Certified Insurance Service Representative (CISR) Courses and a Nevada Independent Insurance Agents Association Instructor for numerous Personal and Commercial Insurance coverage topics.

Areas of Expertise:

• Insurance Company Good and Bad Faith
• Agent / Broker Standard of Care
• Insurance Industry Customs and Practices
• Risk Management
• Business Contract Insurance Clause Analysis and Application
• Insurance Coverage Analysis
• Insurance Claims Disputes Analysis

View Paul Burkett's Expert Witness Profile.

Sasse Surgical Associates, PC is Northern Nevada’s premier provider of minimally invasive surgical solutions. Dr. Sasse is a nationally recognized expert in bariatric surgery, colorectal surgery, minimally invasive hernia and gallbladder surgery, and regenerative wound healing. 

Areas of Expertise:

Bariatric Surgery Gastric Sleeve Gastric Bypass Adjustable Band Gastric Balloon Bariatric Surgery Revision

Colorectal Surgery Gallbladder Surgery da Vinci Robotic Single Site Surgery Hernia Surgery Medically Supervised Weight Loss Regenerative Wound Care

Founder and Medical Director, Kent C. Sasse, MD, MPH, FACS, FASCRS, FASMBS, is certified by the American Board of Colon and Rectal Surgery, American Board of Surgery, and the American Society for Metabolic & Bariatric Surgery. 

Dr. Sasse performed the first laparoscopic colon resection procedure and the first laparoscopic gastric bypass procedure in northern Nevada more than 14 years ago. More recently, he is credited with performing the first daVinci Single Site gallbladder procedure in late 2013. 

With over 20 years of experience, Dr. Sasse is a sought after speaker and mentor to surgeons around the nation. He hosts cadaver courses on surgical topics including complex abdominal wall reconstruction at the University of Nevada School of Medicine, for visiting surgeons. He has also authored numerous peer-reviewed research articles, and some of his most recent papers discuss sleeve gastrectomy, laparoscopic rectopexy, gastric physiology, endoscopic techniques for gastric repairs, and minimally invasive hernia repair. He is an acclaimed award-winning author of five books www.SasseSurgical.com/books.

View Dr. Sasse's Expert Witness Profile.

Sanjay Adhia, MD, MRO, is triple-Board-Certified in Psychiatry, Brain Injury Medicine and Forensic Psychiatry. In addition to forensic/expert witness practice, Dr. Adhia has provided patient care in the Houston area. Currently, he is a neuropsychiatrist at Memorial Herman TIRR where he treats those with brain injury, stroke, and other neurological injuries. His forensic practice focuses on the psychiatric impact of personal injury, medical malpractice, drug and alcohol abuse, sexual abuse, competency, violence, and complicating mental illness, as well as psychiatric disability. 

Dr. Adhia is among one of the few Forensic Psychiatrists who is also Board-Certified in Brain Injury Medicine. Often, Traumatic Brain Injury (TBI) can be a major factor in litigation as it can result in psychiatric or neurocognitive impairments. He has expertise in psychopharmacology, the medicine of medication. 

In addition, Dr. Adhia works with Physicians for Human Rights to assess victims of kidnapping and false imprisonment, human trafficking, undue influence, physical and sexual abuse, rape, and fear of imminent death. In all populations, he assesses PTSD, Anxiety, Depressive Disorders, risk of suicide, and malingering. He is experienced in the treatment and impact of drug and alcohol abuse on decision-making. Dr. Adhia has also treated severe psychosis (Schizophrenia, hallucinations) and psychopathology. Dr. Adhia was formerly treating patients at a Maximum Security Prison and prison psychiatric hospital. He has treated Opioid Use Disorders. 

Dr. Adhia’s findings consider complicating factors, such as emotional distress worsened by other active physical and mental conditions. Other factors are pre-existing mental and physical illness, competency and capacity (e.g. dementia, Intellectual Disability.) As a physician, Dr. Adhia is uniquely qualified to review medical records and doctor reports. Institutional medicine, medical malpractice, and standard of care apply to both public and private facilities, including government, regulated correctional institutions, and psychiatric hospitals. Dr. Adhia is skilled in these med-legal issues. He conducts Independent Medical Examinations, review of records, and reports his med-legal findings and opinions. He is available to testify in civil, criminal, probate, Federal, Immigration, military, and administrative jurisdictions.