On September 27, 2018, the NJ State Assembly Scheduled a Vote on AR 181, a totally political Resolution that exemplified abortion extremism at its worst. Click below to see how your 2 State Assembly Members Voted. Please thank your State Assembly Members if they voted No. If they Voted yes, please express your disappointment and outrage and inform them that you will take their vote into consideration when they are up for re-election next November.
As we post this article, the U.S. Senate is deliberating over a repeal of Obamacare which will defund Planned Parenthood for one year. NJ’s two U.S. Senators Cory Booker and Robert Menendez shamefully support using our tax dollars to fund this disgraceful organization and appeared with Planned Parenthood militants at a protest just yesterday in Washington, D.C. to advocate on their behalf.
Here in NJ, we have state legislators who continue to criticize Governor Christie for ensuring that no taxpayer money goes to Planned Parenthood. In fact, we now have 5 Republican Assembly members who have vowed to defy the Governor’s actions and force NJ taxpayers to fund Planned Parenthood. View the article here
The entire NJ Legislature is up for election on November 7th. Please take note of how your State Senator and two Assembly members vote on this issue. We will post the vote tallies on this website. Any lawmaker who supports this organization also supports Planned Parenthood’s illegal activity and should be voted out of office.
Planned Parenthood Doctor Caught Breaking Ban on Partial-Birth Abortions: “Laws are Up to Interpretation”
NATIONAL STEVEN ERTELT JUL 27, 2017 | 9:28AM WASHINGTON, DC
A new video released by the organization that has caught numerous Planned Parenthood doctors selling the body pats of aborted babies has caught another Planned Parenthood abortion practitioner on video. This time the Planned Parenthood abotrionist is caught admitting to breaking the federal law that bans partial-birth abortions by falsifying records and pretending to use another abortion method.
Never-before-released undercover video shows Dr. Suzie Prabhakaran, the Vice President of Medical Affairs for Planned Parenthood of Southwest and Central Florida, graphically discussing Planned Parenthood’s late-term “dismemberment” and partial-birth abortion protocols in the context of fetal body part harvesting.
The new video comes as the U.S. Senate is debating provisions to terminate taxpayer subsidies to Planned Parenthood, the nation’s biggest abortion business.
At a Planned Parenthood conference evening reception, Center for Medical Policy investigators posing as buyers from a biotech company discuss partnering with Dr. Prabhakaran’s Planned Parenthood affiliate in order to harvest fetal organs and tissues from the 2nd-trimester abortions performed there. Prabhakaran advises that her affiliate is merging with the Orlando Planned Parenthood, which does abortions up to 23 weeks and has a high procedure volume, with eighteen abortions at 18-weeks and above scheduled for the next week.
Prabhakaran discusses how Planned Parenthood allows their abortion doctors to certify compliance with the federal Partial-Birth Abortion Ban, which prohibits abortions in which a fetus is extracted alive up to certain anatomical landmarks (18 U.S.C. 1531). According to Prabhakaran, Planned Parenthood abortion doctors can certify compliance with the law by using a feticide like digoxin to kill the fetus before the abortion, or they can simply “document” their “intent” to do a “dismemberment” abortion where the fetus is pulled apart with forceps rather than extracted intact.
“So some people train to just document that like, you know to comply with the Partial-Birth Abortion Ban, you basically have to say, ‘I intend to utilize dismemberment techniques for this procedure,’” explains Prabhakaran. “So every time you do a procedure, that’s how you document. So, like, there’s like a checkbox,” Prabhakaran states, “so it would be before the procedure, you do your evaluation, you write, ‘I intend to utilize dismemberment techniques for this procedure.’”
Prabhakaran indicates she never uses digoxin to kill the fetus before the abortion, and relies entirely on the “checkbox” to “document” her intent in the abortion to certify compliance with the federal law: “I’m not doing digoxin, and we’re just going to document and there’s never been a problem.”
Prabhakaran’s description of Planned Parenthood’s loose protocols for 2nd-trimester abortion procedures corroborates statements by Dr. Deborah Nucatola, Senior Director of Medical Services for Planned Parenthood Federation of America, in CMP’s first undercover video, that show a lax attitude toward the partial-birth abortion law:
“The Federal [Partial-Birth] Abortion Ban is a law, and laws are up to interpretation. So there are some people who interpret it as it’s intent. So if I say on Day 1 I do not intend to do this, what ultimately happens doesn’t matter.”
Nucatola states in the first video that Planned Parenthood abortion doctors can make changes to the abortion technique in order to bring the fetus out intact for body parts harvesting, regardless of any initial “intent” statement: “So if you do it starting from a breech [feet-first] presentation, there’s dilation that happens as the case goes on, and often, the last step, you can evacuate an intact calvarium [head] at the end.”
CMP project lead David Daleiden notes, “Planned Parenthood medical directors and abortion doctors feign compliance with the federal partial-birth abortion law on paper, knowing full well that ‘what ultimately happens doesn’t matter’ so long as no one is scrutinizing what they actually do to women and children in the operating room. And the fact that Planned Parenthood has a ‘dismemberment’ ‘checkbox’ on their abortion forms should tell the public and policymakers everything they need to know about this barbaric abortion business. The Department of Justice should open an immediate investigation into Planned Parenthood’s late-term abortion practices, and the U.S. Congress must stop forcing taxpayers to subsidize Planned Parenthood’s brutal abortion empire.”
Update: The Speaker of the Assembly has scheduled a Voting Session for Monday, July 31st. Please take the action suggested below immediately!
Override of A3492, 2017 supplemental funding bill failed
The attempt to Override of Governor Christie’s veto of A3492, a 2017 budget supplemental appropriation bill that would have provided $7.453M in taxpayer funds to Planned Parenthood failed on June 29th in the Assembly. As a result, the NJ Senate did not vote on the Override of A3492. Thank you to all who took action on our Alert! To see how your two Assembly members voted, click the hyperlink here: A3492 Ac1.pdf Override
Action Still Needed Today!
The Speaker of the Assembly has scheduled a Voting Session on Monday, July 31st.
It is very likely these bills will be on the board list. Please take Action Immediately!
Please email and call your legislators even if you have done so previously with the message below.
S3302/A4718 – Provides a supplemental appropriation of $7.453M to Planned Parenthood for “family planning services” for the 2018 Budget year.
S3248/A32 – Provides funding to Planned Parenthood for “family planning services’ through Medicaid for individuals with incomes up to 200% of the federal poverty level.
Please email and call your two State Assembly members. Please do both: call and email them. Please make sure you contact your Two Assembly members who represent you at the state level of government in Trenton. Please do this NOW even if you have contacted them previously on this subject.
Message for Two Assembly Members: Please Vote No on S3302/A4718 and S3248/A32. I don’t want my tax dollars used to fund Planned Parenthood. In 2011, one of their “family planning” affiliates in Perth Amboy, NJ was caught aiding and abetting sex traffickers of minors. An audit conducted by the Federal Govt in 2007 found that NJ Planned Parenthood family planning clinics were billing medicaid for services that did not qualify as family planning and the state (taxpayers) had to repay over $2M to the federal govt. for their fraudulent activity. Moreover, in 2011, the NJ Dept of Health inspected Planned Parenthood of Mercer County and Planned Parenthood in Shrewsbury and found multiple health and safety violations, including the reusing of vaginal ultrasounds. These are also “family planning” centers. This is not an organization that cares about women and we should not be funding them with our tax dollars. The Federally Qualified Health Centers are meeting the health care needs of NJ women. I am watching how you vote and will remember how you vote on this matter when I go to the polls on November, 7, 2017. I am watching how you vote and will remember how you vote on this matter when I go to the polls on November, 7, 2017.
Here is a link to find your two State Assembly members:
You can also call the Office of Legislative services: 1-800-792-8630 during regular business hours to obtain the names and contact info for your three legislators.
Also Contact these Legislators
I have also listed below the female Republican legislators who Planned Parenthood are targeting. Flood their offices with emails and phone calls asap and let them know we expect them to be consistent and continue to vote No on these bills as they all have done in the past and that we are watching!
View how your Senator voted on S3302, provides $7.453M for family planning services for 2018 budget year. HERE
View how your Senator voted on S3248,provides taxpayer funding to Planned Parenthood for “family planning services’ through Medicaid for individuals with incomes up to 200% of the federal poverty level. HERE
Safety concerns caused the organization to close the unit
ATLANTIC CITY — Planned Parenthood’s health center on Atlantic Avenue closed for good Friday, officials announced.
Triste Brooks, president and CEO of Planned Parenthood of Northern, Central and Southern New Jersey, said the organization ended its lease at 2922 Atlantic Ave. near South Morris Avenue because of safety concerns.
“Planned Parenthood’s top priority is the health and safety of our patients, and due to concerns about the safety of the rented facility that housed our health center, we came to the difficult decision to end our lease,” she wrote in a statement.
It was the only Planned Parenthood health center serving the southeastern part of the state. Its Stockton University location in Galloway Township exclusively serves the school.
Atlantic City patients may use Planned Parenthood’s Camden and Bellmawr sites in Camden County. All patient records are being transferred to the Camden facility in the transition.
Brooks said Planned Parenthood will look to add new health centers to the 25 locations it manages in the state.
Services for men and women include birth control, testing, treatment and vaccines for HIV and sexually transmitted infections, abortion services, cervical cancer screenings, breast exams (not mammograms) and testicular and prostate cancer screenings.
Most of Planned Parenthood’s clients are women, low-income populations and people with insufficient insurance, according to reports.
‘I Might . . . Pull Off a Leg or Two’ Center for Medical Progress video (via YouTube)
A shocking new undercover video exposes the grisly reality of ripping apart fetuses. Editor’s Note: This piece has been updated since its initial posting.
A shocking new video has just been released by the Center for Medical Progress, the undercover investigative group that in 2015 released videos showing that Planned Parenthood affiliates have profited from selling the body parts of aborted babies.
This latest video is a preview of footage that CMP investigators gathered at the 2014 and 2015 National Abortion Federation conventions, attended by hundreds of members of the abortion industry each year. (The NAF is a major trade group of North American abortion providers, and Planned Parenthood makes up about 50 percent of its members and leadership.) Here are some of the most horrifying remarks from the brand-new undercover footage. Attendees made some of these comments during official presentations, and others directly to undercover CMP investigators.
Dr. Lisa Harris, the medical director of Planned Parenthood of Michigan: Given that we actually see the fetus the same way, and given that we might actually both agree that there’s violence in here. . . . Let’s just give them all the violence, it’s a person, it’s killing, let’s just give them all that. Dr. Ann Schutt-Aine, the director of abortion services for Planned Parenthood Gulf Coast (which has been referred to local law-enforcement for criminal charges related to fetal-tissue trafficking): If I’m doing a procedure, and I’m seeing that I’m in fear that it’s about to come to the umbilicus [navel], I might ask for a second set of forceps to hold the body at the cervix and pull off a leg or two, so it’s not PBA [partial-birth abortion].
Dr. Stacy De-Lin, the director of abortion services for Planned Parenthood of New York City: But we certainly do intact D&Es [dilation and extraction, otherwise known as partial-birth abortion, a method that is illegal under federal law].
Dr. Uta Landy, the founder of the Consortium of Abortion Providers (CAPS), Planned Parenthood Federation of America (PPFA): An eyeball just fell down into my lap, and that is gross! [laughter from the crowd]
Talcott Camp, the deputy director of the ACLU’s Reproductive Health Freedom Project: I’m like — Oh my God! I get it! When the skull is broken, that’s really sharp! I get it! I understand why people are talking about getting that skull out, that calvarium.
Dr. Susan Robinson, an abortion provider at Planned Parenthood Mar Monte: The fetus is a tough little object, and taking it apart, I mean, taking it apart on Day One is very difficult. . . . You go in there, and you go, “Am I getting the uterus or the fetus? Oh, good, fetus. [Robinson makes a stabbing sound effect] What have I got? Nothing. Let’s try again.
Below are some comments from the footage that provide further evidence of Planned Parenthood’s involvement in illegally profiting from fetal-tissue trafficking, as well as altering abortion procedures to collect intact organs, which is also illegal under federal law.
Dr. Leslie Drummond, an abortion provider at Planned Parenthood Mar Monte (a PPFA affiliate that contracted with a biotech firm to be paid per fetal organ provided): I get a lot of oohs and ahhs from StemExpress [biotech firm]. You know, they’re wanting livers. . . . Last week I was in Sacramento, and she said, “I need four intact limbs.” And I said, you want what?
Dr. Deborah Nucatola, the senior director of medical services for PPFA: You know, sometimes she’ll tell me she wants brain, and we’ll, you know, leave the calvarium in till last, and then try to basically take it, or actually, you know, catch everything and keep it separate from the rest of the tissue so it doesn’t get lost.
StemExpress procurement manager: There’s a lot of clinics that we work with that, I mean, it helps them out significantly.
Deb VanDerhei, the national director of CAPS for PPFA: But the truth is that some might want to do it to increase their revenues. And we can’t stop them. Dr. Stacy De-Lin, the director of abortion services for Planned Parenthood of NYC: But I think a financial incentive from you guys [CMP investigators posing as tissue buyers] is going to be like . . . the people who we have to get this approved from will be very happy about it.
Dr. Paul Blumenthal, the former medical director for PP of Maryland: I know Planned Parenthood sells a lot of stuff [fetal organs] to people.
Both the NAF and Planned Parenthood sought and obtained a preliminary injunction against the Center for Medical Progress to prevent the release of these undercover videos. That civil suit is currently on appeal. But California’s attorney general took matters into his own hands in late March, charging CMP investigators David Daleiden and Sandra Merritt with 14 felony counts of illegally recording “confidential communications.” The state refuses to name the 14 accusers in the criminal case, even though Daleiden and Merritt have themselves been charged publicly.
The gruesome footage from this latest video leaves no doubt as to why NAF and Planned Parenthood want to silence CMP’s investigators. “Every video recording for which the attorney general is charging David was obviously and unquestionably made in a public place where it could not possibly be considered ‘confidential,’” says Brent Ferreira, one of Daleiden’s defense attorneys.
The gruesome footage from this latest video leaves no doubt as to why NAF and Planned Parenthood want to silence CMP’s investigators. Those in the abortion industry know they’re taking human life. They just don’t care. Updated May 26, 10:40 a.m.: A California judge ordered the CMP’s defense attorneys to remove the video footage from YouTube and from their website.
More information is available here. — Alexandra DeSanctis is a William F. Buckley Fellow in Political Journalism at the National Review Institute.
Read more at: http://www.nationalreview.com/article/447939/undercover-video-center-medical-progress-exposes-gruesome-abortion-practices
An ultrasound is one of the first encounters a mother has with her baby. She can see her child's heart beat, and monitor her baby's development and health — but Planned Parenthood uses ultrasounds for a very different reason…
There is substantial medical evidence that babies in the womb feel pain at a very early stage of gestation. Thanks to advances in medicine, babies as young as 20 weeks post-fertilization can survive and thrive with appropriate care and treatment. Experts in the field of Maternal-Fetal medicine routinely administer pain medication as standard medical practice because they recognize these babies as patients. There have been many instances of babies who survived abortions who were left to die or killed by abortionists. We have to look no further than the Gosnellcase in Pennsylvania.
The Pain Capable Unborn Child Protection Act will protect babies in the womb at 20 weeks and older who are capable of feeling pain and ensure that babies born alive during an abortion will be given the same proper life saving medical care given to premature infants. Babies in the womb experienceexcruciating pain during an abortion. A recent video from a former abortion provider, Dr. Anthony Levatino, explains how these abortions are done in thisvideo (Warning: viewing content may be disturbing for some.)
Take Action Now!
We are happy to report that A3452/S2026, the NJ Pain Capable Unborn Child Protection Act has been introduced in the NJ Legislature. We thank the sponsors of this bill for recognizing the horrific practices of the abortion industry, who callously and with depraved indifference to human life, brutally and routinely end the lives of innocent babies in the womb and endanger the lives of women. This bill is modeled after H.R. 36, the Federal bill by the same name. Passing this legislation is part of the 2020 Project, a collaborative effort by pro-life groups in NJ to protect pain capable babies. For more information on this initiative, please visit www.babiesinthewombfeelpain.com
Please go to the www.njrtl.org Legislation page and Take Action hereon this legislation. It’s time we protect babies in the womb capable of feeling pain.
What do medical experts say about whether babies in the womb feel pain?
“We are obligated to protect the undefensible,” stated Dr. Colleen A. Malloy, who teaches in the Neonatology division at Northwestern University’s Feinberg School of Medicine. Testifying before the United States Senate Judiciary Committee on Tuesday, March 15, 2016, Dr. Malloy said that advances in technology show the “viability” of human life at an earlier age than previously believed.
A child definitely feels pain at 20 weeks, testified Dr. Malloy, and it is certainly “viable.” Because of technological advancements “we have pushed back the gestational age” of when an unborn child “can be resuscitated and resuscitated successfully,” she said.
These children “are moving, reacting, and developing right before our eyes in the neonatal intensive care unit,” she said.
A June 2009 study of over 300,000 babies by the American Medical Association found that, among children aged 20 to 24 weeks post-conception, they had a steadily higher chance of survival with each passing week, ranging from 10 percent at the beginning to 85 percent at the end.
“Given these survival numbers, the NICU commonly cares for infants born in this gestational age range. We can easily witness their humanity, as well as their experiences with pain,” she testified.
The standard of care for NICUs requires attention to and treatment of neonatal pain,” she said. “There is no reason to believe that a born infant will feel pain any differently than that same infant if he or she were still in utero.”
“I could never imagine subjecting my tiny patients to a horrific procedure such as those that involve limb detachment or cardiac injection.”
Dr. Kathi Aultman, a retired gynecologist, said she had performed both first and second trimester abortions, had an abortion herself, and has a cousin who is an abortion survivor.
After performing second-trimester abortions, she recounted how she had to examine the remains of the unborn child and found “perfectly-formed organs.” While she worked in the neonatal intensive care unit by day and in an abortion clinic by night, her conscience began to be troubled by the fact that she was intent on saving babies in the NICU who were the same age as those being aborted in the clinic.
Attorney general says banned doctor still running Englewood abortion clinic
BY MARY JO LAYTON AND RICHARD NEWMAN
STAFF WRITERS |
An abortion doctor who lost his license in New Jersey and has been banned from practicing in other states is illegally exerting control over women’s clinics in Englewood and several other locations, the state attorney general has charged.
Additionally, the facility known as Englewood Women’s Services — one of 14 in a chain of clinics that extends to Maryland and Virginia — filed for bankruptcy protection from creditors this week after a federal judge in Maryland three weeks ago awarded $6.5 million to a former patient in a malpractice case.
Dr. Steven C. Brigham, who lost his New Jersey license in November 2014 after illegally performing abortions in Maryland, has been plagued by controversy throughout a career in which he estimated he performed 40,000 abortions — including late-term procedures — even though he never completed a residency in obstetrics or gynecology.
The website for the chain known as American Women’s Services promises low fees, immediate appointments and “private expert care with over 35 years experience.”
After New Jersey revoked Brigham’s license, the state ordered him to divest of all financial interest in the chain of clinics. The physician purported to sign over interests to another doctor who performed abortions at the clinic and then became a medical director after the state suspended Brigham’s license, the state alleges.
“We are arguing that the transfer of ownership was a sham and that through the management services agreement, Brigham is still exerting control over the practice that ought to be exercised by an owner,” said Paul Loriquet, a spokesman for the Attorney General’s Office.
There is no evidence or indication that Brigham “is engaging in any clinical practice,” Loriquet said.
The bankruptcy filing, which seeks Chapter 11 protection, lists “Dr. Steven C. Brighman” of Voorhees as an owner of the company. The Englewood clinic on Grand Avenue is behind $51,847 on rent, and an eviction is pending, according to court documents. Total assets and liabilities are estimated in the filing at no more than $50,000 each.
On Wednesday, the Englewood clinic’s landlord won a default judgment because no one appeared in court to represent the clinic, a court official said.
Hackensack lawyer Donald T. Bonomo, who is representing the Englewood clinic in bankruptcy court in Newark, said that it “will continue to operate” as it reorganizes. He declined to comment on the status of Brigham’s medical license or on clinic managers’ identities or credentials. As the bankruptcy attorney, he is not involved in those matters, he said.
A woman who answered the phone at the Englewood clinic this week identified herself as Skylar Hamilton, a “communications assistant,” and said Brigham was not available.
Joseph M. Gorrell, an attorney representing Brigham before the state Board of Medical Examiners, said Wednesday the physician has appealed the revocation, and oral arguments have not yet been scheduled. Brigham remains on the revoked physician list and owes the state more than $500,000 in fines and other costs, Loriquet said.
Began in South Jersey
Brigham, long accused of botched abortions in more than two dozen years of practice, lost his New Jersey license after questionable practices in Maryland.
He began the abortion process in a South Jersey clinic, then directed women — or had his staff drive them — to a clinic he owned in Maryland where the surgical part of the procedure would be performed. However, he was not licensed to conduct surgeries after the first trimester. In advanced cases, they have to be performed in hospitals and he doesn’t have admitting privileges or special qualifications, like residency training, which is required under New Jersey state law, officials said.
One patient from South Carolina claimed in a 2015 lawsuit against Brigham and others that in 2012 she underwent a failed non-surgical abortion at an American Women’s Services-affiliated clinic in Frederick, Md., resulting in the birth of a child more than 10 weeks premature, with hearing loss, developmental delays, heart defects and other problems.
On Aug. 5, Judge J. Frederick Motz granted the woman a $6.5 million judgment against Brigham and the other defendants.
The recent investigation into the control of the 14 clinics is tied to a complaint New Jersey filed against a physician affiliated with Brigham — Vikram H. Kaji — an 80-year-old board certified obstetrician and gynecologist, who has served as medical director at all clinic locations.
In addition to Englewood, clinics are located in: Elizabeth, Hamilton, Phillipsburg, Galloway, Toms River, Voorhees and Woodbridge in New Jersey. In Maryland, clinics are located in Baltimore, Cheverly, Frederick and Silver Spring.
In Virginia, there’s a clinic in Virginia Beach and Fairfax, but state regulators suspended the license of the Fairfax facility in April after finding a number of problems including unsanitary equipment, expired medication and failure to follow proper care protocols – 52 pages in all.
“The license remains suspended,” said Maribeth Brewster, a spokeswoman for Virginia regulators.
Kaji began working for Brigham as an independent contractor to perform abortions in 1996. In 2010, Kaji took over as medical director at all clinic locations when Brigham’s license was temporarily suspended and he was prohibited from serving in the job, according to the complaint the state filed against Kaji in June 2015.
The board received a stock certificate in March 2015 that purported to show Brigham transferred complete ownership to Kaji as a condition of Brigham’s losing his license. The two physicians also sent a transfer of ownership notice for three of the locations — Elizabeth, Englewood and Hamilton — to the state Department of Health, which registers the facilities, according to state documents.
In May 2015, Kaji testified under oath before a board panel and denied being the owner, according to the state complaint.
Kaji said Brigham continued to fulfill the obligations as owner in all clinic locations in New Jersey and beyond, state documents show. Kaji “expressly testified that ‘there is no other person around, [Brigham’s] the only one who runs the show,’” according to the complaint.
In fact, Kaji during testimony said of the ownership transfer: “It was just a technical paper transaction so the business could go on.”
Kaji “aided and abetted the unlicensed practice of medicine in allowing Brigham to maintain ownership of AWS, a professional service corporation, an activity for which a medical license is required,” the state complaint alleges.
Gorrell, who is also representing Kaji, declined to comment pending a hearing scheduled for Sept. 12 and 13 on the move to suspend Kaji’s license.
‘Cut enough corners’
Brigham has been the subject of many disciplinary hearings in New Jersey and elsewhere over the last two decades. Brigham left Pennsylvania in 1992, agreeing never to practice in the state again, according to a series of stories The Record published in 1994 on a three-state inquiry into the physician.
The agreement was reached after a confidential investigation by the Pennsylvania medical board, but authorities at the time refused to divulge further information. New York and New Jersey had investigated the physician on allegations of malpractice.
In November 1994, New York revoked the physician’s license after two women undergoing late-term abortions were injured, one of whom suffered a perforated uterus and one who bled for hours before being taken to an emergency room. New Jersey was undertaking its own efforts to revoke Brigham’s license, in some instance, citing the same cases, The Record found in 1994.
The attorney general pressed the state board at the time to revoke Brigham’s license, but the board chose to allow hearings to continue.
Two decades later, the New Jersey board revoked Brigham’s license after he practiced medicine in Maryland without a license. The order cited a New Jersey administrative law judge’s findings: After reviewing Brigham’s extensive track record of disciplinary actions in New Jersey, New York, Pennsylvania and Florida, the judge noted that “Dr. Brigham has finally cut enough corners.”
An attorney representing Brigham said there were 23 times that another doctor performed the surgery, not Brigham himself. He argued that he had a “consultive relationship” that allowed him to practice in Maryland.