firearms in estate administration: legal issues, executor liability,...

Firearms in Estate Administration: Legal Issues,

Executor Liability, Transferring Title I and II Guns,

PenaltiesUnderstanding Gun Legal Designations, In-State and Out-of-State Transfers, Use of Gun Trusts

Today’s faculty features:

1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific

The audio portion of the conference may be accessed via the telephone or by using your computer's

speakers. Please refer to the instructions emailed to registrants for additional information. If you

have any questions, please contact Customer Service at 1-800-926-7926 ext. 1.

TUESDAY, AUGUST 20, 2019

Presenting a live 90-minute webinar with interactive Q&A

Matthew J. Bergstrom, Managing Attorney, Arsenal Attorneys, Fairfax, Va.

Cynthia M. (Cindy) Clark, JD, CFP, Attorney, Law Offices of Cynthia M. Clark, Sarasota, Fla.

John Pierce, Attorney, The Law Office of John Pierce, Bristol, Va.

Tips for Optimal Quality

Sound Quality

If you are listening via your computer speakers, please note that the quality

of your sound will vary depending on the speed and quality of your internet

connection.

If the sound quality is not satisfactory, you may listen via the phone: dial

1-866-871-8924 and enter your PIN when prompted. Otherwise, please

send us a chat or e-mail [email protected] immediately so we can address

the problem.

If you dialed in and have any difficulties during the call, press *0 for assistance.

Viewing Quality

To maximize your screen, press the F11 key on your keyboard. To exit full screen,

press the F11 key again.

FOR LIVE EVENT ONLY

Continuing Education Credits

In order for us to process your continuing education credit, you must confirm your

participation in this webinar by completing and submitting the Attendance

Affirmation/Evaluation after the webinar.

A link to the Attendance Affirmation/Evaluation will be in the thank you email

that you will receive immediately following the program.

For additional information about continuing education, call us at 1-800-926-7926

ext. 2.

FOR LIVE EVENT ONLY

Program Materials

If you have not printed the conference materials for this program, please

complete the following steps:

• Click on the ^ symbol next to “Conference Materials” in the middle of the left-

hand column on your screen.

• Click on the tab labeled “Handouts” that appears, and there you will see a

PDF of the slides for today's program.

• Double click on the PDF and a separate page will open.

• Print the slides by clicking on the printer icon.

FOR LIVE EVENT ONLY

Firearms in Estate

Administration: Legal

Issues, Executor Liability,

Transferring Title I and II Guns, Penalties

Understanding Gun Legal

Designations, In-State and

Out-of-State Transfers, Use of Gun Trusts

6

Faculty

Cynthia M. Clark

Attorney at Law, Law Offices of Cynthia M. Clark,

Sarasota, Florida

Matthew J. Bergstrom

Attorney at Law, Arsenal Attorneys, Fairfax, Virginia

John Pierce

Attorney at Law, Law Office of John Pierce, Esq.

7

Cynthia M. ClarkAttorney at Law, Law Offices of Cynthia M. Clark

Cindy provides estate and disability planning, as well as probate and trust administration services, to Florida residents. She’s passionate about helping individuals dispose of their property as they choose – not as the government chooses.

Cindy is a gun enthusiast and collector, and a staunch supporter of the Second Amendment. She’s an active participant in the Sarasota-Manatee gun community and frequently speaks about gun law at local gun shops and other events. She has written several gun law articles and has organized two pro-Second Amendment rallies. She has also presented gun trust CLE for the members of the ABA, WealthCounsel, and the Southwest Florida Paralegal Association.

The vast majority of her clients own at least one gun, and gun trusts are a substantial part of her business.

8

Part I: Firearm

Classification,

Ownership, and

Transfer Rules

9

Why is this topic important?

Estimated 300,000,000 guns owned privately in the U.S. by about 60,000,000 people.*

1 in 10 gun owners owns 10+ guns; collectively accounting for over 40% of all guns.*

States have been relaxing laws regarding short-barreled rifles and shotguns, and silencers are now widely legal for hunting. In 2009, the ATF processed just 296,127 applications for these types of firearms; in 2018 it processed 1,422,353. Applications peaked in 2016 at 2,538, 397.

More women are buying more guns. According to Pew Research Center, in 2017 an estimated 1 in 5 women owned at least one gun. More than 3 in 5 men own at least one gun.

Concealed carry is on the rise. In FL, as of July 2019, there were 2,019,321 concealed carry license holders (about 12% of the adult population of FL); 27% are female.

Machine guns are seen as a valuable investment. There are a limited number available legally so the prices for well-kept machine guns keep rising.

*2015 National Firearms Survey

10

•Federal and State Gun Laws

•Title I vs. Title II Firearms

• Intrastate and Interstate

Transfers

11

Federal and State Gun

Laws

Historical Context

Federal Gun Laws

State Gun Laws

12

Historical Context

British Gun Laws

Colonial Gun Laws

U.S. Constitution

Pre-1900

13

Federal Gun Laws

1927 Mailing of Firearms Act

1934 National Firearms Act

1938 Federal Firearms Act

1968 Gun Control Act

1986 Firearm Owners’ Protection Act

14

1927 Mailing of Firearms

Act

Prohibits shipping of

concealable firearms

through the U.S. mail

Still in effect

Doesn’t apply to other carriers

(FedEx, UPS)

15


(NFA)

Enacted in response to violence that accompanied the Depression and Prohibition.

The federal govt’s first attempt to regulate and control firearms.

Didn’t actually ban any firearm; imposes a tax upon the making and/or transfer of certain firearms and created a national registration of NFA firearms.

16


(continued)

Regulates firearms and accessories considered especially dangerous: Fully automatic machine guns, silencers (suppressors), short-barreled rifles (SBRs) and shotguns (SBSs), and “any other weapons” (cane guns, wallet guns, etc.).

Governs the purchase, sale, transfer, ownership, use, and possession of these weapons.

Tried to ban all handguns, all semi-automatic rifles and shotguns, and create a national registration of all guns, but that failed.

17

1938 Federal Firearms Act

(FFA)

Required licenses and record-keeping for businesses engaged in interstate commerce of ordinary firearms.

Prohibited licensed dealers from selling firearms to persons convicted of a violent crime.

Replaced by the Gun Control Act of 1968

18

1968 Gun Control Act

(GCA)

Enacted in response to assassinations of the Kennedys and MLK.

Imposed stricter licensing and regulation on the entire firearms industry, established new categories of firearms offenses, and prohibited the sale of firearms and ammunition to felons and certain other prohibited persons.

Created two categories of firearms with different rules pertaining to each:

Title I - ”Ordinary” or non-NFA firearms

Title II – NFA firearms

19

Prohibited Persons

(18 U.S.C 922(d)) Precluded from directly possessing, buying, shipping, or transferring

any type of firearm:

Any person convicted of a crime punishable by imprisonment for more than one year;

Any fugitive from justice;

Any unlawful user of or any person addicted to a controlled substance;

Any person adjudicated by a court or govt. agency as having a mental defect, or who has been committed to a mental institution;

Any person who is illegally or unlawfully in the U.S.;

Any person discharged from the Armed Forces under dishonorable conditions;

Any person who has renounced his or her U.S. citizenship;

Any person subject to a restraining order; and

Any person who has been convicted of a crime of domestic violence.

20

1986 Firearm Owners’

Protection Act (FOPA) Enacted in response to rampant abuse of power by the

ATF and meant to clarify parts of the GCA 1968.

Provided a “safe harbor” for the interstate carrying of firearms in a vehicle. A person is entitled to transport a firearm from any place where he or she may lawfully possess and carry such firearm to any other place where he or she may lawfully possess and carry it, if the firearm is unloaded and locked out of reach.

Makes clear that people who make occasional sales and purchases to enhance their personal collection are not ”engaged in the business” and do not have to get an FFL.

Made it illegal for private citizens to buy or possess machine guns made after 1986.

21

State Gun Laws

Thousands of state and local laws that address firearms

Can be more restrictive if Congress hasn’t pre-empted (subject to Constitutional scrutiny)

Can have additional classes of prohibited persons

Concealed Carry vs. Open Carry

Nullification and Interposition

22

Title I and Title II Firearms

Title I (non-NFA)

Rifles, shotguns, and handguns

No national registration, may be state registration

Few federal laws regulating privatetransfers during life or at death; may be state laws

GCA 1968 regulates federal firearms licensees (FFLs) and transfers involving FFLs; states may impose additional regulations

23

Title I and Title II Firearms

Title II (NFA 1934)

GCA 1968 added “destructive devices” (mines, bombs, grenades) and expanded the definition of “machinegun” to includes parts of a machine gun **

National registration list is compiled and held by BATFE; classified as “tax information”

Unregistered NFA firearms are contraband and possession is a felony. They cannot be transferred and must be properly destroyed or turned over to law enforcement.

Registration can only be in an individual’s name or in the name of a trust or certain other entities. No joint ownership or beneficiary designation.

If registered in an individual’s name, the NFA firearm is subject to probate before it can be lawfully transferred.

Transfers – whether by FFLs or private parties – are highly regulated

Most transfers will incur a tax; exceptions for certain bequests to lawful heirs

24

Intrastate and Interstate

Transfers Intrastate transfers

Title I (non-NFA)

Federal (private): May privately sell/transfer ownership of a handgun to anyone over the age of 18 residing in same state, as long as he doesn’t know or have reasonable cause to believe the person is a prohibited person under federal law. May sell a long gun to anyone of any age.

Federal (FFL): An FFL cannot sell a long gun to anyone under the age of 18, and cannot sell a handgun to anyone under the age of 21. All transfers done through an FFL requires that the recipient show a DL, complete an ATF Form 4473, and pass a NICS instant criminal and incapacity background check.

State: may be more restrictive as to age, background checks, etc. Some states may mandate that all transfers go through an FFL.

The firearms can be transported by private car, subject to state laws.

Some common carriers may allow the intrastate shipment of handguns to a residence, but UPS and FedEx will only ship firearms (long or handguns) to an FFL.

A private seller may use an FFL to effect the transfer. The buyer can pick up the firearm at the FFL, or it can be shipped from one FFL to another FFL closer to the buyer. But the buyer must complete the ATF Form 4473 and pass the background check before the FFL will release the firearm.

25


Transfers

Intrastate transfers

Title II (NFA)

The seller and the buyer complete the appropriate ATF forms and either the seller or the buyer submits the forms, the buyer’s fingerprints and passport photos, a copy of the buyer’s gun trust (if applicable), and the $200 or $5 transfer tax to the ATF. A redacted copy of the ATF Forms are also sent to the buyer’s chief law enforcement officer for informational purposes. The buyer will have to pass the FBI background check before the ATF will approve the transfer. The approval process generally takes more than 6 months, and the paperwork (affixed with what looks like a $200 or $5 postage stamp) is returned to the seller. At that point, the firearm and the proof of transfer approval (a.k.a. tax stamp) may be physically transferred to the buyer.

The firearms can be transported to the recipient by private car, subject to state laws.

Intrastate mailing and shipping laws are the same as for non-NFA firearms. Short-barreled rifles and shotguns are treated like handguns by the USPS and cannot be mailed.

26


Transfers

Interstate transfers

Title I (non-NFA)

Federal: For transfers other than bequests, private transfers of all firearms are prohibited when the buyer and seller are residents of different states (even between family members). An FFL can sell a long gun to a non-resident who is physically in his shop, but cannot sell a handgun to that same non-resident. Online sales: FFLs can sell a gun to someone in another state, but the actual legal “transfer” is done through an FFL in the recipient’s state. Private online sales across state lines are prohibited; an FFL must handle the legal transfer.

Firearms shipped or mailed across state lines must be shipped or mailed to an out-of-state FFL, not directly to the recipient’s home.

Handguns cannot be mailed.

Exception: you can ship your own firearm to yourself in another state.

The firearms can be transported by private car to the out-of-state heir across state lines, subject to each state’s laws

the Firearms Owner’s Protection Act (FOPA) specifies a “safe harbor” for interstate transportation of firearms, but some states and cities ignore it and may prosecute anyway. Under FOPA, a person is entitled to transport a firearm from any place where he or she may lawfully possess and carry such firearm to any other place where he or she may lawfully possess and carry it, if the firearm is unloaded and locked out of reach.

27


Transfers

Interstate transfers

Title II (NFA)

The NFA firearm must be legal in the recipient’s state.

The seller and the buyer complete the appropriate ATF forms and either the seller or the buyer submits the forms, the buyer’s fingerprints and passport photos, a copy of the buyer’s gun trust (if applicable), and the $200 or $5 transfer tax to the ATF. A redacted copy of the ATF Forms are also sent to the buyer’s chief law enforcement officer for informational purposes. The buyer will have to pass the FBI background check before the ATF will approve the transfer. The approval process generally takes more than 6 months, and the paperwork (affixed with what looks like a $200 or $5 postage stamp) is returned to the seller. At that point, the firearm and the proof of transfer approval (a.k.a. tax stamp) may be physically transferred to the buyer.

The seller and/or buyer may also be subject to additional state laws (permits, registrations, etc.)

Mailing and shipping laws are the same as for non-NFA firearms (must be mailed/shipped to an out-of-state FFL). Short-barreled rifles and shotguns are treated like handguns by the USPS and cannot be mailed. Some common carriers won’t ship machine guns.

The firearms can be transported by private car to the out-of-state heir across state lines, subject to each state’s laws and FOPA.

28

Part II: Estate

Administration

of Firearms

29

Matthew J. Bergstrom,Managing Attorney, Arsenal Attorneys

Matthew Bergstrom leads Arsenal Attorneys, a

firearms law practice known for its ‘Arsenal Gun

Trust.’ From its main office in metro Washington, DC, the firm serves clients in nearly every state where NFA

firearms are permitted.

Matthew has taught firearms law for the American

Bar Association, the Federal Bar Association, the

NRA, and the Financial Planners Association. He has

been featured in the Wall Street Journal, Washington

Times, and on various TV networks and radio stations.

He currently lives with his wife, three kids, and three

dogs on a rice farm where he enjoys duck hunting.

30

Estate Administration of

Firearms

Learning Points

Understand the interplay between estate

administration and firearms law.

Identify steps in advising clients in the administration

of estates which include firearms.

Understand clients’ concerns about guns.

31

Introduction to Estate

Administration of Firearms

How do your clients view firearms in an estate?

Assets

Tools

Heirlooms

Heritage

Safety

Compliance

Privacy

Politics

Covetousness

32

Introduction, cont’d

Who are the players in an estate administration?

Personal Representative/Trustee

Heirs/Beneficiaries

Advisors

‘Friends’

What firearms-related concerns arise regarding

each of these players?

33

Step 1: Secure the

Firearms

Safety First

Is the client prepared to inspect and store the

firearms?

Compliance First, too!

Does the client need guidance on do’s and don’ts

of firearms laws and safety?

Asset Protection

Is there an inventory?

34

Step 1: Secure the

Firearms, cont’d

Duty of the Personal Representative: manage,

preserve, and care for the estate assets.

Must exercise the same degree of care, skill,

prudence, and diligence that a prudent person

familiar with such facts and acting on his or her own

behalf would exercise under similar circumstances.

What knowledge or assistance does the Personal

Representative require in handling firearms?

35

Step 1: Secure the

Firearms, cont’d

If the client lacks the knowledge or ability to

secure the firearms, an advisor is an obvious

consideration.

The personal representative of an estate is entitled

to seek assistance from advisors who can help with

the administration of the estate, including the

investment, management and sale of the assets.

But, may an advisor take possession of the estate’s

firearms?

Depends on the type of firearm and applicable state

and federal laws

36

Step 1: Secure the

Firearms, cont’d

Before involving anyone else with an estate’s

firearms, the personal representative should

address whether such persons raise concerns about:

Prohibited Persons

Interstate Transportation

Constructive Possession and Unlawful Transfers

Categorize the Firearms: Title I or Title II

37

Step 1: Secure the

Firearms, cont’d

The Special Case of Title II Firearms

Unlawful transfers

Constructive Possession

Interstate Movement

Prior to interstate transportation of an NFA firearm,

other than a silencer, the registered owner may be

required by 18 U.S.C. § 922(a)(4) to obtain permission

from ATF by submitting ATF E-Form 5320.20.

38

Step 2: Distributions

The Personal Representative must determine

whether a distributee has the legal right to possess

a firearm.

Beware of Prohibited Persons.

Beware of gun bans in a distributee’s jurisdiction.

39

Step 2: Distributions,

cont’d

Beware of Minors: 18 U.S.C. § 922(x) makes it

unlawful to sell, deliver or transfer a handgun, or

handgun ammunition, to a person less than 18. Punishable by up to 1 year imprisonment.

Federal law provides no minimum age for the

possession of long guns or long gun ammunition.

Several states impose stricter minimum age limits for

handgun and long gun possession

Under the National Firearms Act, a registered

owner of a Title II firearm must be at least 18.

40


cont’d

What if a distributee is ineligible to receive a

firearm?

Did the deceased want that firearm sold?

Did the deceased want the firearm given to

another person?

What if a distributee is eligible but unsuitable to

possess a firearm?

Ideally, an estate plan for firearms addresses such

contingencies and many others.

41


cont’d

Sale of an Estate’s Firearms

Valuations

Blue Book of Gun Values

Private Sale

FFL

Sale

Consignment

Auction

Background Check

Beware of self-dealing

42

Step 3: Firearms Transfers

to Distributees

Title 1 Firearms

Ordinarily, any interstate transfer of a firearm must

be handled by an FFL, but there is an exception for

distributions from an estate. Per 18 U.S. Code §

922(a)(3), the requirement to use an FFL for

interstate transfer does not apply to any person who

lawfully acquires a firearm by bequest or intestate

succession in a State other than his State of

residence. In these cases, a person may transport

an inherited firearm into his state of residence “if it is

lawful for such person to purchase or possess such

firearm in” his state of residence.

43


to Distributees, cont’d

The Special Case of Title II Firearms

Transferring NFA Firearms

ATF Form 5320.5 “Application for Tax Exempt Transfer and Registration of Firearm”

Estates, Trusts, and Other Transfers by Operation of Law. When a firearm is being transferred from an estate by bequest or intestate succession (see 27 CFR § 479.90a), or by other operation of law to a beneficiary or other authorized recipient, ATF Form 5 is used to effect the transfer. The executor, trustee, or other person appointed to dispose of property shall provide documentation of the legal status of the person entitled to receive property, and shall identify that person in item 2a. In the case of an estate, item 3e shall be completed to reflect the decedent's information. If the transfer is to someone other than to a person identified under operation of law, the transfer is subject to transfer tax and ATF Form 4 shall be used.

44



Title II Firearms, cont’d

For either a transfer using ATF Form 5320.4 or

5320.5, each responsible person must be identified using Form 5320.23.

Form 23 requires the transferee’s fingerprints and

photos.

Note: If a trust is the registered owner, and it

continues beyond the life of the settlor/grantor,

the existing registrations remain valid and no

transfer is needed; however, ATF Form 5320.20 would still apply to interstate transport of those

NFA firearms.

45



Be prepared to advise the client in transportation or shipment of firearms.

Firearm Owners’ Protection Act (FOPA) (18 U.S. Code 926A):

Unloaded in a locked container and beyond reach.

Travel must originate and end in states where the person can legally possess and transport the firearm.

No interim stops (exceptions for gas and bathrooms)

Guns may be checked as luggage on airlines

Guns may be mailed to oneself with certain restrictions.

For Title II firearms, remember ATF Form 5320.20.

46

Part III: Gun Trusts

47

John PierceAttorney at Law

John Pierce is a Virginia attorney whose practice is

focused upon the unique legal issues surrounding the

regulation of firearms. He is heavily involved in the development of gun trusts, specifically those that are

designed to hold items regulated under the National

Firearms Act (NFA).

He is the former Chair of the American Bar

Association Second Amendment Civil Rights

Litigation Subcommittee and is a frequent presenter

of firearms-related CLE classes.

John’s advocacy activities have been featured on

Nightline and The Daily Show with Jon Stewart.

48

Introduction: Benefits of a

Gun Trust

Avoidance of probate

Transfer to minors at an appropriate time

Detailed guidance to those unfamiliar with

firearms laws, especially the National Firearms Act

(NFA)

Greatly expanded usability

49

Drafting Considerations

Revocable or irrevocable?

Life, multi-generational, or perpetual?

Goals of the client?

50

Key Provisions

All gun trusts should include some

form of the following:

A clause that treats the settlor as deceased

should they become a prohibited possessor

under state or federal law

A clause that removes a trustee from power

immediately should they become a prohibited

possessor under state or federal law

51

Key Provisions

cont’d

A clause that treats a beneficiary as having

predeceased the settlor should they become a

prohibited possessor under state or federal law

A clause instructing the successor trustee on how

to proceed in the event of the settlor’s death

A clause instructing the trustee(s) that interstate

transport of certain NFA firearms may only take

place following the approval of a Form 20

52

Key Provisions

cont’d

A clause instructing the trustee(s) how

permanent relocation of NFA items should be

handled

A clause governing the validity of copies of

the trust

53

Understanding 41F

In 2013 the ATF proposed to modify the

regulations governing NFA applications for trusts,

corporations, and other non-individual legal

entities. This proposed regulatory rulemaking was

known as 41P. It was finalized on July 13, 2016 at

which time it went from a proposed rulemaking

to a final rule. Consequently, it is now known as

41F

54

Understanding 41F

cont’d

Prior to the promulgation of 41F, ATF regulations

required an individual applicant for registration of

an NFA item to comply with a number of

requirements that ‘legal-entity’ applicants were

exempt from. The most onerous of these was the

requirement that individual applicants get

‘approval’ from their local chief law-enforcement

officer (CLEO) before an application could be

submitted. This was known colloquially as the ‘CLEO

Sign-off.’

55

Understanding 41F

cont’d

In many jurisdictions, the CLEO would not sign the

form which acted as a complete and arbitrary

ban on the registration of NFA items.

That’s where an NFA trust (or other legal entity)

would enter the picture. Pre-41F, legal-entity

applicants did not need CLEO Sign-off. This

allowed applicants in those jurisdictions where

the CLEOs would not sign to avoid the de-facto

ban that individual applicants faced.

56

Understanding 41F

cont’d

41F eliminated the requirement that individual

applicants secure CLEO signoff and replaced it with

mere notification and then extended the

requirement to all ‘responsible persons’ of a legal

entity.

It also requires that all ‘responsible persons’ of the

legal entity submit a form 5320.23 along with

fingerprints, and photographs when the legal entity

submits an application to purchase or manufacture

an NFA item.

57

Understanding 41F

cont’d

Despite the fact that the CLEO signoff has been

eliminated as a concern, trusts remain the

preferred method of ownership for NFA items

since they provide significant usage and sharing

benefits during the Settlor’s life and guidance and

protection for the Successor Trustee upon the

Settlor’s passing.

58

What is a ‘Responsible

Person’?

As for what exactly is meant by the term

‘responsible person’, the ATF broadly defines it as

“any individual, including any grantor, trustee, [or]

beneficiary, … who possesses, directly or

indirectly, the power or authority under any trust

instrument … or under state law, to receive,

possess, ship, transport, deliver, transfer, or

otherwise dispose of a firearm for, or on behalf of,

the [trust].”

59

‘Responsible Person’ Issues

When laying out the powers and duties of those

on the trust, make sure that the powers of Joint or

Co-Trustees, Successor Trustees, and Beneficiaries

are each enumerated with the definition of

‘responsible person’ in mind.

There is currently a debate inside the ATF NFA

Branch regarding whether a beneficiary to whom

a trustee has the discretion to allow access is a

‘responsible person’.

60

Title 1 (Regular) Firearms in

the Trust

Most provisions in the trust are, of necessity, going

to be drafted to address the unique issues

involving NFA items. However, do not forget to

draft the trustee powers, duties, and requirements

in such a manner as to allow the trust to also

handle Title 1 firearms and accessories.

For example, a clause requiring that ALL items in

the trust have an approved tax stamp before

distribution would exclude Title 1 firearms.

61

NFA Terminology and

Acronyms SBR - A short barreled rifle

SBS - A short barreled shotgun

AOW - Any ‘concealable’ weapon other than a handgun

DD - Items considered ‘destructive devices’

CLEO - Chief law enforcement officer in a local jurisdiction

FORM 1 - ATF Form 5320.1 – application to manufacture an NFA item

FORM 3 - ATF Form 5320.3 – dealer transfer of an NFA item

FORM 4 - ATF Form 5320.4 – taxable transfer of an NFA item

FORM 5 - ATF Form 5320.5 – tax-free transfer of an NFA item

FORM 20 - ATF Form 5320.20 – interstate transportation of an NFA item

NFRTR - National Firearms Registration and Transfer Record

62

Thank You

Cynthia M. Clark

[email protected]

Matthew J. Bergstrom

[email protected]

John Pierce

[email protected]

63

firearms in estate administration: legal issues, executor liability,...

Documents