# Legal Question: Impossible to Conduct "Affirmative Defense" (Dzhokhar Tsarnaev) **URL:** \ **Category:** Factual Questions\ **Created:** [May 20, 2013, 5:37pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846 "2013-05-20T17:37:32Z")\ **Posts on this page:** 20\ **Page:** 2
**Author:** ![deltasigma](https://avatars.discourse-cdn.com/v4/letter/d/e5b9ba/32.png) [@deltasigma](https://boards.straightdope.com/u/deltasigma)\ **Post date:** [May 21, 2013, 11:05pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/21 "2013-05-21T23:05:37Z")
Since cross examination serves multiple purposes such as impeaching credibility and finding inconsistencies in the opposing party’s theory of the case, certainly failing to challenge witnesses would in most cases represent an important lost opportunity since it could contribute to reducing the weight given to certain evidence by the trier of fact. I think the only point being made by moi and others is that the trier is also capable of weighing evidence and applying the applicable standard without your assistance as opposing counsel. ---
**Author:** ![magnusblitz](https://avatars.discourse-cdn.com/v4/letter/m/b4bc9f/32.png) [@magnusblitz](https://boards.straightdope.com/u/magnusblitz)\ **Post date:** [May 21, 2013, 11:30pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/22 "2013-05-21T23:30:46Z")
**Labdad** and **lawbuff** touched on this, but - “affirmative defense” is a legal term referring to something _the defense_ has the burden of proving that forces innocence. The burden of proof is usually on the prosecution, but for certain defenses - such as self-defense, duress, and insanity - the burden of proving the defense is on the defense. Example: Defendant is charged with battery (hitting another person). Prosecution bears the burden of proof to show beyond a reasonable doubt that the defendant hit another person. If the prosecution doesn’t put on evidence, they don’t meet their case. But let’s say they present a witness who takes the stand and says “John Doe punched me in the face, yadda yadda.” It’s believable. If the defense wants to claim self-defense, they can’t just say “self-defense!”, they need to put on their own witnesses/evidence and the jury needs to believe it before they can make a finding of not guilty due to self-defense. ---
**Author:** ![Cliffy](https://avatars.discourse-cdn.com/v4/letter/c/59ef9b/32.png) [@Cliffy](https://boards.straightdope.com/u/Cliffy)\ **Post date:** [May 22, 2013, 2:19am UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/23 "2013-05-22T02:19:55Z")
Getting back, if we may, to **ralph** ’s original question, from which the thread has somewhat digressed, Tsarnaev’s factual guilt is absolutely up for debate. The pictures might not be him. The confession might have been coerced, the product of a morphine-addled mind, or the statement of a punk kid who wanted to look like a big man for all his anti-american buddies. (I don’t suggest any of this is the case, but the government is the one who has to prove it isn’t.) The O.J. Simpson trial is illustrative. I think any half-honest examination of the facts surrounding the case make Simpson’s (factual) guilt plain. But the State had, basically, two pieces of evidence: DNA and testimony of the investigating detective. The defense showed that the DNA was not properly handled and the investigating detective hated black folk – or at least, that these were reasonable conclusions – and so the jury acquitted. There’s more concrete evidence against Tsarnaev, of course, but the point is that during cross examination, the defense may very well evoke evidence that what we think we know about Tsarnaev’s guilt is based on a foundation that’s not nearly as solid as it seems now, when the only side of the story is the one drafted by the pulic information office of the Boston P.D. –Cliffy ---
**Author:** ![Melbourne](https://avatars.discourse-cdn.com/v4/letter/m/b5e925/32.png) [@Melbourne](https://boards.straightdope.com/u/Melbourne)\ **Post date:** [May 22, 2013, 5:12am UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/24 "2013-05-22T05:12:10Z")
> [@deltasigma](#): > > fund this from the NY penal code. > Quote: > The following is a list of the minimum required crime elements for Burglary: > • Person knowingly enters or remains unlawfully and > • Building and > • Intent to commit crime therein. c’mon. In my limited experience, that last point is almost never ‘proven’ in an ordinary non-lawyer sense by anything presented in court. They find a young man inside a closed and locked building at night, and that is taken as proof of an intent to commit a crime. If he wants to try to claim he was not intent on committing a crime, the requirment for proof falls on him. And, of course, nothing he says in self defense is admissable evidence, so he needs some other kind of evidence. I admit that this seems to be in conflict with the clear statement of the law above, but the fact is that in all my time observing lower courts, I never saw any attempt to independently prove intent for anything, nor did the judge require it. ---
**Author:** ![deltasigma](https://avatars.discourse-cdn.com/v4/letter/d/e5b9ba/32.png) [@deltasigma](https://boards.straightdope.com/u/deltasigma)\ **Post date:** [May 22, 2013, 5:34am UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/25 "2013-05-22T05:34:27Z")
I defer to your experience on the practicalities. I was mainly a word monkey doing research and writing briefs. I did read a lot of transcripts but those were almost exclusively for appellate briefs so your focus is a bit different. ---
**Author:** ![Quercus](https://avatars.discourse-cdn.com/v4/letter/q/7ab992/32.png) [@Quercus](https://boards.straightdope.com/u/Quercus)\ **Post date:** [May 22, 2013, 1:45pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/26 "2013-05-22T13:45:20Z")
> [@Melbourne](#): > > c’mon. In my limited experience, that last point is almost never ‘proven’ in an ordinary non-lawyer sense by anything presented in court. > > They find a young man inside a closed and locked building at night, and that is taken as proof of an intent to commit a crime. If he wants to try to claim he was not intent on committing a crime, the requirment for proof falls on him. And, of course, nothing he says in self defense is admissable evidence, so he needs some other kind of evidence. IANAL, but work with them, and I think the defendant’s statements are (generally) very much admissible. The finder of fact might or might not find his statements particularly believable, and might think they’re weak or even worthless evidence to use for reaching a conclusion about guilt, but they’re certainly admissible evidence. I don’t dispute your overall point about lack of intent being, in actual practice, something the defense has to actively raise, and even give some evidence for, however. ---
**Author:** ![Really\_Not\_All\_That\_Bright](https://avatars.discourse-cdn.com/v4/letter/r/e8c25b/32.png) [@Really\_Not\_All\_That\_Bright](https://boards.straightdope.com/u/Really_Not_All_That_Bright)\ **Post date:** [May 22, 2013, 1:52pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/27 "2013-05-22T13:52:30Z")
I’m a little curious about the admissibility comment too. In what sense are exculpatory statements not admissible, assuming there are no hearsay problems? ---
**Author:** ![deltasigma](https://avatars.discourse-cdn.com/v4/letter/d/e5b9ba/32.png) [@deltasigma](https://boards.straightdope.com/u/deltasigma)\ **Post date:** [May 22, 2013, 2:02pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/28 "2013-05-22T14:02:59Z")
I guess I stopped reading once it seemed like the issue was a matter of trial experience because in the US at least, that part about the defendant’s testimony not being admissible wouldn’t be true to the best of my knowledge. But give me a rule of evidence to look up and I have the 2012 annotated rules for NJ which are pretty much the same as the federal I think. ---
**Author:** ![Loach](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/loach/32/350_2.png) [@Loach](https://boards.straightdope.com/u/Loach)\ **Post date:** [May 22, 2013, 2:13pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/29 "2013-05-22T14:13:56Z")
> [@magnusblitz](#): > > **Labdad** and **lawbuff** touched on this, but - “affirmative defense” is a legal term referring to something _the defense_ has the burden of proving that forces innocence. The burden of proof is usually on the prosecution, but for certain defenses - such as self-defense, duress, and insanity - the burden of proving the defense is on the defense. > > Example: Defendant is charged with battery (hitting another person). Prosecution bears the burden of proof to show beyond a reasonable doubt that the defendant hit another person. If the prosecution doesn’t put on evidence, they don’t meet their case. But let’s say they present a witness who takes the stand and says “John Doe punched me in the face, yadda yadda.” It’s believable. If the defense wants to claim self-defense, they can’t just say “self-defense!”, they need to put on their own witnesses/evidence and the jury needs to believe it before they can make a finding of not guilty due to self-defense. That is exactly right. > [@Cliffy](#): > > Getting back, if we may, to **ralph** ’s original question, from which the thread has somewhat digressed, Tsarnaev’s factual guilt is absolutely up for debate. The pictures might not be him. The confession might have been coerced, the product of a morphine-addled mind, or the statement of a punk kid who wanted to look like a big man for all his anti-american buddies. (I don’t suggest any of this is the case, but the government is the one who has to prove it isn’t.) > > The O.J. Simpson trial is illustrative. I think any half-honest examination of the facts surrounding the case make Simpson’s (factual) guilt plain. But the State had, basically, two pieces of evidence: DNA and testimony of the investigating detective. The defense showed that the DNA was not properly handled and the investigating detective hated black folk – or at least, that these were reasonable conclusions – and so the jury acquitted. There’s more concrete evidence against Tsarnaev, of course, but the point is that during cross examination, the defense may very well evoke evidence that what we think we know about Tsarnaev’s guilt is based on a foundation that’s not nearly as solid as it seems now, when the only side of the story is the one drafted by the pulic information office of the Boston P.D. > > –Cliffy I do think that is the actual question. Not if he can use an affirmative defense. He can’t unless he tries to plead insanity. It certainly wasn’t self-defense. The question is about if he can have an effective defense. That is completely unknown at this time. We think we know what the evidence is but we really don’t know what they have and what will be admissible. ---
**Author:** ![lawbuff](https://avatars.discourse-cdn.com/v4/letter/l/13edae/32.png) [@lawbuff](https://boards.straightdope.com/u/lawbuff)\ **Post date:** [May 22, 2013, 3:48pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/30 "2013-05-22T15:48:22Z")
> [@deltasigma](#): > > Where exactly are you getting this from? A summary judgment motion is to dispose of a case when there is [no dispute of any material fact.](http://legal-dictionary.thefreedictionary.com/Summary+Judgment) And as to the specific standard, you are simply wrong. Quoting a dictionary link is not “specific” in nature, at least here. This is a quote from a case. …In considering a summary judgment motion, a court accepts as **true** the nonmovant’s evidence and draws “justifiable inferences . . . in [her] favor.” Estate of Parsons v. Palestinian Auth., 651 F.3d 118, 123 (D.C. Cir. 2011)… Very similar, if not exact, to a Motion to dismiss for failure to state a claim upon which relief can be granted; …A motion to dismiss pursuant to Rule 12(b)(6) may be granted only if, accepting all well-pleaded allegations in the complaint as\*\* true\*\*, and viewing them in the light most favorable to plaintiff, plaintiff is not entitled to relief.” In re Burlington Coat Factory Sec. Litig., 114 F.3d 1410, 1420 (3d Cir. 1997) (citing Bartholomew v. Fischl, 782 F.2d 1148, 1152 (3d Cir. 1986)… The court considers the facts as TRUE, there is just no COA stated. Notallthatbright, at post 15, and I are correct. > [@](#): > > At the summary judgment level, it is presumed that everything the non-moving party asserts is true. ---
**Author:** ![Bricker](https://avatars.discourse-cdn.com/v4/letter/b/977dab/32.png) [@Bricker](https://boards.straightdope.com/u/Bricker)\ **Post date:** [May 22, 2013, 4:38pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/31 "2013-05-22T16:38:27Z")
omitted ---
**Author:** ![deltasigma](https://avatars.discourse-cdn.com/v4/letter/d/e5b9ba/32.png) [@deltasigma](https://boards.straightdope.com/u/deltasigma)\ **Post date:** [May 22, 2013, 5:05pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/32 "2013-05-22T17:05:07Z")
> [@lawbuff](#): > > Quoting a dictionary link is not “specific” in nature, at least here. This is a quote from a case. > > …In considering a summary judgment motion, a court accepts as > **true** the nonmovant’s evidence and draws “justifiable inferences > . . . in [her] favor.” Estate of Parsons v. Palestinian Auth., > 651 F.3d 118, 123 (D.C. Cir. 2011)… > > Very similar, if not exact, to a Motion to dismiss for failure to state a claim upon which relief can be granted; > > …A motion to dismiss pursuant to Rule 12(b)(6) may be granted only if, > accepting all well-pleaded allegations in the complaint as\*\* true\*\*, and viewing them in the light most favorable to plaintiff, plaintiff is not entitled to relief.” In re Burlington Coat Factory Sec. Litig., 114 F.3d 1410, 1420 (3d Cir. 1997) (citing Bartholomew v. Fischl, 782 F.2d 1148, 1152 (3d Cir. 1986)… > > The court considers the facts as TRUE, there is just no COA stated. > > Notallthatbright, at post 15, and I are correct. You’re just being tedious now. Not a single link that can be verified I see. IOW, nice try grasshopper. ---
**Author:** ![deltasigma](https://avatars.discourse-cdn.com/v4/letter/d/e5b9ba/32.png) [@deltasigma](https://boards.straightdope.com/u/deltasigma)\ **Post date:** [May 22, 2013, 5:21pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/33 "2013-05-22T17:21:50Z")
What lawbuff has attempted to do, whether in bad faith or simply out of ignorance I cannot judge, is to conflate the rendering of an issue not in dispute with the standard by which such rendering is made. This is laid out very clearly in [NJ Court Rule 4:46-2](http://www.judiciary.state.nj.us/rules/r4-46.htm) > [@](#): > > [ul] > [li] **(b) Requirements in Opposition to Motion.** A party opposing the motion shall file a responding statement either admitting or disputing each of the facts in the movant’s statement. Subject to R. 4:46-5(a), all material facts in the movant’s statement which are sufficiently supported will be deemed admitted for purposes of the motion only, unless specifically disputed by citation conforming to the requirements of paragraph (a) demonstrating the existence of a genuine issue as to the fact. An opposing party may also include in the responding statement additional facts that the party contends are material and as to which there exists a genuine issue. Each such fact shall be stated in separately numbered paragraphs together with citations to the motion record.[/li][li] **(c) Proceedings and Standards on Motions.** The judgment or order sought shall be rendered forthwith if the pleadings, depositions, answers to interrogatories and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact challenged and that the moving party is entitled to a judgment or order as a matter of law. An issue of fact is genuine only if, considering the burden of persuasion at trial, the evidence submitted by the parties on the motion, together with all legitimate inferences therefrom favoring the non-moving party, would require submission of the issue to the trier of fact. The court shall find the facts and state its conclusions in accordance with R. 1:7-4. A summary judgment or order, interlocutory in character, may be rendered on any issue in the action (including the issue of liability) although there is a genuine factual dispute as to any other issue (including any issue as to the amount of damages). Subject to the provisions of R. 4:42-2 (judgment upon multiple claims), a summary judgment final in character may be rendered in respect of any portion of the damages claimed.[/li][/ul] ---
**Author:** ![Really\_Not\_All\_That\_Bright](https://avatars.discourse-cdn.com/v4/letter/r/e8c25b/32.png) [@Really\_Not\_All\_That\_Bright](https://boards.straightdope.com/u/Really_Not_All_That_Bright)\ **Post date:** [May 22, 2013, 5:53pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/34 "2013-05-22T17:53:11Z")
> [@deltasigma](#): > > You’re just being tedious now. Not a single link that can be verified I see. IOW, nice try grasshopper. “Not a single link that can be verified”? Aren’t you a lawyer? He gave you the reporter citations. Beyond that, if you don’t know what rule 12(b)(6) is, you’re apparently _not_ a lawyer. ---
**Author:** ![deltasigma](https://avatars.discourse-cdn.com/v4/letter/d/e5b9ba/32.png) [@deltasigma](https://boards.straightdope.com/u/deltasigma)\ **Post date:** [May 22, 2013, 6:13pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/35 "2013-05-22T18:13:49Z")
> [@Really\_Not\_All\_That\_Bright](#): > > “Not a single link that can be verified”? Aren’t you a lawyer? He gave you the reporter citations. Beyond that, if you don’t know what rule 12(b)(6) is, you’re apparently _not_ a lawyer. Aren’t you cute. In the real world, real lawyers don’t use the fed. rules of civil procedure unless in fed. ct. they use their own state’s court rules, [to wit:](http://www.judiciary.state.nj.us/rules/r4-6.htm) > [@](#): > > **4:6-2. How Presented** > > Every defense, legal or equitable, in law or fact, to a claim for relief in any complaint, counterclaim, cross-claim, or third-party complaint shall be asserted in the answer thereto, except that the following defenses, unless otherwise provided by R. 4:6-3, may at the option of the pleader be made by motion, with briefs: (a) lack of jurisdiction over the subject matter, (b) lack of jurisdiction over the person, (c) insufficiency of process, (d) insufficiency of service of process, (e) failure to state a claim upon which relief can be granted, (f) failure to join a party without whom the action cannot proceed, as provided by R. 4:28-1. If a motion is made raising any of these defenses, it shall be made before pleading if a further pleading is to be made. No defense or objection is waived by being joined with one or more other defenses in an answer or motion. Special appearances are superseded. If, on a motion to dismiss based on the defense numbered (e), matters outside the pleading are presented to and not excluded by the court, the motion shall be treated as one for summary judgment and disposed of as provided by R. 4:46, and all parties shall be given reasonable opportunity to present all material pertinent to such a motion. ---
**Author:** ![Really\_Not\_All\_That\_Bright](https://avatars.discourse-cdn.com/v4/letter/r/e8c25b/32.png) [@Really\_Not\_All\_That\_Bright](https://boards.straightdope.com/u/Really_Not_All_That_Bright)\ **Post date:** [May 22, 2013, 6:35pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/36 "2013-05-22T18:35:11Z")
Right. And New Jersey law is relevant to this discussion… how, exactly? ---
**Author:** ![deltasigma](https://avatars.discourse-cdn.com/v4/letter/d/e5b9ba/32.png) [@deltasigma](https://boards.straightdope.com/u/deltasigma)\ **Post date:** [May 22, 2013, 6:40pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/37 "2013-05-22T18:40:54Z")
> [@Really\_Not\_All\_That\_Bright](#): > > Right. And New Jersey law is relevant to this discussion… how, exactly? Really? 12-b-6 = 4:6-2(e) That really wasn’t obvious I take it. BTW, THAT is what you should be questioning in terms of relevance. Would you like me to explain why or do you want to try that on your own? ---
**Author:** ![lawbuff](https://avatars.discourse-cdn.com/v4/letter/l/13edae/32.png) [@lawbuff](https://boards.straightdope.com/u/lawbuff)\ **Post date:** [May 23, 2013, 2:56pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/38 "2013-05-23T14:56:30Z")
> [@deltasigma](#): > > What lawbuff has attempted to do, whether in bad faith or simply out of ignorance I cannot judge, is to conflate the rendering of an issue not in dispute with the standard by which such rendering is made. This is laid out very clearly in [NJ Court Rule 4:46-2](http://www.judiciary.state.nj.us/rules/r4-46.htm) Out of ignorance? C’mon dude! Since you quote NJ law here is a case link and a quote from it, that should ice it, if not, I have no further comment. IV A Analytically, tying the test for summary judgment determinations to the question of what reasonable conclusions a rational jury can draw from the evidence is similar to an involuntary dismissal under Rule 4:37-2(b). We recognized as much in Dairy Stores, supra, 104 N.J. at 156, 516 A.2d 220. The standard for determining a motion for an involuntary dismissal under Rule 4:37-2(b) is the same as the standard for determining motions under Rule 4:40-1, and Rule 4:40-2. The motion must be denied “if the evidence, together with the legitimate inferences therefrom, could sustain a judgment in plaintiff’s favor.” R. 4:37-2(b); see S. Pressler, Current N.J. Court Rules, R. 4:40-2 comment (1991). In each case, “the court must accept as **true** all the evidence which supports the position of the party defending against the motion and must accord him [or her] the benefit of all legitimate inferences which can be deduced therefrom, and if reasonable minds could differ, the motion must be denied.” S. Pressler, supra, R. 4:40-2 comment (1991); see Dolson v. Anastasia, [55 N.J. 2, 5-6, 258 A.2d 706 (1969).] > **[BRILL v. GUARDIAN LIFE IN | 142 N.J... | 142nj520176 | Leagle.com](https://www.leagle.com/decision/1995662142nj520176.xml)** > > The opinion of the Court was delivered by COLEMAN J. This appeal involves a claim of negligence against a life insurance broker and...142nj520176 ---
**Author:** ![deltasigma](https://avatars.discourse-cdn.com/v4/letter/d/e5b9ba/32.png) [@deltasigma](https://boards.straightdope.com/u/deltasigma)\ **Post date:** [May 23, 2013, 3:07pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/39 "2013-05-23T15:07:51Z")
Are you actually following this thread? Here’s part of your post > [@lawbuff](#): > > "the court must accept as **true** all the evidence which supports the position of the party defending against the motion and must accord him [or her] the benefit of **all legitimate inferences which can be deduced therefrom** , And this is what I said in post 17 > [@deltasigma](#): > > It’s not assumed to be true. You are only given **the benefit all reasonable inferences.** There is a difference. Do you see any similarities? ---
**Author:** ![Bricker](https://avatars.discourse-cdn.com/v4/letter/b/977dab/32.png) [@Bricker](https://boards.straightdope.com/u/Bricker)\ **Post date:** [May 23, 2013, 3:14pm UTC](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846/40 "2013-05-23T15:14:49Z")
> [@deltasigma](#): > > Do you see any similarities? I see a difference: > [@lawbuff](#): > > the court must accept as true all the evidence which supports the position of the party defending against the motion … > [@deltasigma](#): > > It’s not assumed to be true. Lawbuff’s correct. To the extent that you’re saying the court must only accept reasonable inference and NOT assume the truth of well-pleaded allegations, you’re wrong, **deltasigma**. [Previous page](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846.md?page=1) [Next page](https://boards.straightdope.com/t/legal-question-impossible-to-conduct-affirmative-defense-dzhokhar-tsarnaev/658846.md?page=3)