The
international non-governmental organization Human Rights Watch (HRW) has been accused by
critics of being influenced by United States
government policy, in particular in relation to reporting on Latin America;
ignoring anti-Semitism in Europe or being anti-Semitic;
biases in relation to the Arab–Israeli conflict; and unfair and
biased reporting of human rights issues in Eritrea
and Ethiopia.
Accusations in relation to the Arab–Israeli conflict include claims that HRW is
biased against Israel
and that requesting or accepting donations from Saudi Arabian
citizens causes it to be biased; it has also been accused of unbalanced
reporting against Hezbollah in Lebanon and against Palestinian militant groups.
HRW
has publicly responded to criticisms relating to its reporting on Latin America
and in the context of the Arab–Israeli conflict.
Poor
research and inaccuracy
The
Rupert
Murdoch owner of The Times, accuses HRW of a lack of sufficient
expertise to report on warfare because the organization has never hired any
former members of any military or any person with expertise in warfare with the
sole exception of Marc Garlasco. The Times accuses HRW of
overriding its own researcher who wished to rescind a factually inaccurate
report accusing Israel of responsibility for the Gaza beach explosion (2006).
HRW
has been accused of bias in gathering evidence because it is said to be
"credulous of civilian witnesses in places like Gaza and Afghanistan"
but "sceptical of anyone in a uniform." Robert Bernstein, founder of HRW, now accuses
the organization of poor research methods, for relying on "witnesses whose
stories cannot be verified and who may testify for political advantage or
because they fear retaliation from their own rulers."
According to The Times, HRW "does
not always practice the transparency, tolerance and accountability it urges on
others."
The
pro-Israel research institute NGO Monitor has accused HRW of "faulty
methodology", "misrepresenting international law", and
"promoting the BDS agenda". In
addition, in 2012, New Europe wrote that HRW "allegedly
erased references in its reports to its previous cooperation with the Gaddafi
regime, including organisation's MENA Director Sarah Leah Whitson's role in
marketing Saif al-Islam Gaddafi as a reformer
Selection
bias
The Times
accuses HRW of "imbalance" since it ignores many human rights abusing
regimes while covering other zones of conflict "intensely", notably
Israel. It issued 5 lengthy reports
on Israel in one 14 month period, whereas in 20 years it has issued only 4
reports on the conflict in Kashmir, despite the fact that there have been
80,000 conflict-related deaths in Kashmir and the fact that "torture and
extrajudicial murder have taken place on a vast scale." It issued
no report on post-election violence and
repression in Iran. One source told The Times, "Iran is just not a bad guy
that they are interested in highlighting. Their hearts are not in it. Let’s
face it, the thing that really excites them is Israel.” The Times also accuses
HRW of failing to report on human rights abuses of Arabs when
"perpetrators are fellow Arabs."
Ideological
bias
HRW
founder Robert Bernstein now accuses HRW of allowing
repressive regimes to play a "moral equivalence game" by failing to
distinguish the evidence available from open and closed societies, and of
failing to recognize the "difference between wrongs committed in
self-defense and those perpetrated intentionally."
The
Times accuses HRW of filling its staff with former radical political activists
including Joe Stork
and Sarah Leah Whitson, writing,
"theoretically an organization like HRW would not select as its
researchers people who are so evidently on one side."
HRW
has been accused of being unwilling or unable to perceive threats posed by
radical Islam because their leftist ideology leads them to see criticism of
Hezbollah, Hamas, Al Qaeda and similar groups as "a dangerous distraction
from the real struggle." An example was the 2006 verbal attack on Peter
Tatchell, who was accused of racism, Islamophobia and colonialism by
HRW staff for criticizing Iranian execution of homosexuals
Fund-raising
policies
HRW
has been criticized for cooperating with the Saudi government by holding
fundraisers in that country, and for not releasing the names of its Saudi
donors.
On
7 September 2010, it was announced that George Soros
planned to donate 100 million US dollars to Human Rights Watch. Soros's
donation was criticized by Gerald
Steinberg, the founder of the pro-Israel research organization NGO Monitor
Accusations of bias for or
against particular nations
Allegations of bias concerning Latin America
Claims have been made regarding alleged HRW bias
with regards to Haiti, Venezuela and Honduras. Robert Naiman, policy director
of Just Foreign Policy, has claimed that HRW is "often heavily
influenced" by United States government policy.
Haiti
The 2004 Haiti rebellion was a coup d'etat that removed elected President Jean-Bertrand Aristide of Haiti either voluntarily (according to
US authorities) or involuntarily (according to Aristide and supporters) from
the Americas on a US plane accompanied by US
security personnel on 29 February 2004. Z Communications author Joe Emersberger claimed
that HRW had accurately reported on human rights violations in Haiti following
an earlier coup against Aristide, in 1991, but that it was inaccurate in
reporting the relative numbers of violent deaths before and after the 2004
coup. Emersberger estimated the
relative numbers of deaths as about 20–30 per year before the 2004 coup versus
1000 in the first month following the coup. He stated, "HRW's
reports were not only inexcusably sparse, but they legitimized the overthrow of
Aristide" and that HRW "knew that criminals were being incorporated
into the police; yet they were silent about this contributing factor to the
abuses that occurred under Aristide."
Venezuela
Human Rights Watch's work in Venezuela became the
subject of controversy in late 2008. In September 2008, Venezuela expelled two HRW staff accused
of "anti-state activities" Foreign Minister Nicolas Maduro said "These groups, dressed
up as human rights defenders, are financed by the United States. They are
aligned with a policy of attacking countries that are building new economic
models." On December 17, 2008 an open letter was sent to the HRW Board of
Directors in response to an HRW report, entitled, A Decade Under Chávez:
Political Intolerance and Lost Opportunities for Advancing Human Rights in
Venezuela. 118 scholars from
Argentina, Australia, Brazil, México, the United States, the U.K., Venezuela,
and other countries publicly criticized HRW for a perceived bias against the government of Venezuela. The open letter criticized the
report by stating that it "does not meet even the most minimal standards
of scholarship, impartiality, accuracy, or credibility." The letter also
criticized the lead author of the report, Jose Miguel Vivanco, for his "political agenda", and called on Mr. Vivanco
to discuss or debate his claims in "any public forum of his
choosing". Hugh O'Shaughnessy accused HRW of using false and misleading
information, and said the report was "put together with the sort of
know-nothing Washington bias..." Kenneth Roth, director of Human Rights Watch
responded, claiming the letter misrepresents "both the substance and the
source material of the report.". Tom Porteous, Human Rights Watch's London
director, replied saying that O'Shaughnessy "...not only fails to provide
any evidence for these allegations" but that "...more seriously he
misrepresents HRW's positions in his apparent determination to undermine our
well earned international reputation for accuracy and impartiality."
Honduras
On 21 August 2009, 93 academics
and authors from the UK, US, Canada, Australia, Mexico, Colombia and other
countries published an open letter in which they criticised HRW for HRW's
"absence of statements and reports" on human rights violations in Honduras after 8 July 2009, following the
coup d'état of
28 June 2009. The authors of the statement said that after 8 July, HRW had not
"raised the alarm over the extra-judicial killings, arbitrary detentions,
physical assaults, and attacks on the press - many of which have been
thoroughly documented - that have occurred in Honduras, in most cases by the
coup regime against the supporters of the democratic and constitutional
government of Manuel Zelaya." The authors requested HRW to make a strong
statement against the human rights violations and to conduct its own
investigation into them. The letter signers stated that the Obama
administration was supporting the de facto Roberto Micheletti government, by providing "aid money through
the Millennium Challenge Account and other sources" and by training
Honduran military students at the School of the Americas, and that the Obama
administration was ignoring Honduras' human rights situation.
Four days later, HRW published a summary of a
preliminary version of a major human rights report in Honduras by the Inter-American Court of Human Rights (IACHR) that had been released
by IACHR on 21 August. HRW referred to its earlier reports published up to 8
July, stating "Given the scope of alleged abuses, and the region's history
of bloody coups leading to massive violations, human rights advocates believed
the situation warranted the direct intervention of the region's most
authoritative human rights investigative body, the Inter-American Commission on
Human Rights." HRW did not state whether or not its summary of the IACHR
preliminary report constituted a response to the 93 academics' and authors'
appeal
Anti-Israel
or pro-Arab-League bias
Aryeh
Neier, a founder of Human Rights Watch says that it "is wrong to suggest
that open societies should be spared criticism for human rights abuses"
Neier also states that Robert L. Bernstein's contention that the difference
between "wrongs committed in self-defense and those committed
intentionally" is not made by the laws of war. And that It is also a
dangerous distinction. On such grounds, groups such as al-Qaeda in Iraq that
murdered tens of thousands of civilians after the American invasion of 2003
could claim excuses for their crimes.
Anatol
Sharansky, argued "here is an organization created by the goodwill of the
free world to fight violations of human rights, which has become a tool in the
hands of dictatorial regimes to fight against democracies," he said this
week. "It is time to call a spade a spade. The real activity of this
organization today is a far cry from what it was set up 30 years ago to do:
throw light in dark places where there is really no other way to find out what
is happening regarding human rights." Kenneth
Roth has responded that "Israel accounts for about 15 percent of our
published output on the region" and that "our war coverage in the
region has documented violations by all sides". Roth argued that
"by failing to hold those responsible to account, Israel increases anger
and resentment among the Palestinian population and in the wider Arab world, and
undercuts moderates who wish to pursue peace." Scott MacLeod of Time Magazine
commented that Israel's policies can't be shielded from a group like Human
Rights Watch.
HRW
has been accused of bias against the state of Israel of issuing one-sided and
hostile reports attacking Israel and of having an anti-Israel agenda by general
circulation newspapers, the Israeli government and supporters of Israel.
Political Science Professor and former consultant to the Israeli Ministry of
Foreign Affairs Gerald M. Steinberg of Bar Ilan University, head of NGO Monitor,
a pro-Israel NGO[44]
accused HRW of having "a strong anti-Israel bias from the beginning".
He claimed their reports were based primarily on "Palestinian eyewitness
testimony" — testimony that is "not accurate, objective or credible
but serves the political goal of indicting Israel". According to David Bernstein HRW is
"maniacally anti-Israel". Mark Regev (spokesman for Israeli PM Binyamin Netanyahu) has said that "We
discovered during the Gaza operation and the Second Lebanon War that these
organizations come in with a very strong agenda, and because they claim to have
some kind of halo around them, they receive a status that they don't deserve,"
in reference to HRW's and Amnesty International’s allegations of human rights
violations by Israeli forces during those conflicts.
There
have been a number of accusations that HRW has either ignored anti-Semitism,
or is anti-Semitic itself. Ana Palacio, former Foreign Minister
of Spain,
in a speech given to the Anti-Defamation League in 2005 said, “NGOs
like Human Rights Watch or Amnesty International pay little attention to
anti-Semitism.” It has also been suggested (by ADL) that criticism of Israel
may be motivated by anti-semitism. Abraham
Foxman writing in the New York Sun has said "not in an
"eye for an eye a tooth for a tooth" fashion which Mr. Roth cited and
is a classic anti-Semitic stereotype about Jews".
Sarah Leah Whitson, director of HRW's Middle
East and North Africa division, responding to the criticism said "in the
case of Israel, where our focus is primarily on the violations of international
law and humanitarian law in the occupied Palestinian territories, the fact that
government is a democracy is completely irrelevant because the rule in place in
the occupied territories is military rule, it is not a democracy". In July
2009, Larry Derfner writing in the Jerusalem Post in response to the criticism
of HRW accused Israel's Prime Minister's Office and NGO Monitor of
"smearing" human rights organizations. In August 2009, Iain Levine,
Program Director for HRW stated "If the Israeli government wants to
silence critics, it should fully investigate allegations of wrongdoing and take
action to end the abuses."
Kenneth Roth,
the executive director of Human Rights Watch, wrote an editorial in The
Jerusalem Post in August 2009 that the reports on recent Israeli human
rights violations had "given rise to an intense campaign by the Israeli
government and some of its uncritical supporters to smear the messengers and
change the subject." He went on to write that the "problem is not the
messenger carrying news of that misconduct, whether Judge Goldstone or the
human rights groups that have been the target of a disinformation campaign
launched by the Israeli government and some supporters. The problem is the
conduct of the Israeli military."
According
to The Times, "most" of the Middle East department staff of Human
Rights Watch "have activist backgrounds — it was typical that one newly
hired researcher came to HRW from the extremist anti-Israel publication
Electronic Intifada — unlikely to reassure anyone who thinks that human-rights
organisations should be non-partisan."
Garlasco incident
Marc Garlasco,
a senior investigator for HRW, has been criticized for being an avid collector
of Nazi memorabilia. Emma Daly confirmed in March 2010 that Garlasco resigned
from Human Rights Watch in February 2010, and offered no elaboration. “He has
written a book, about Nazi-era
medals. In one post he wrote: "That is so cool!
The leather SS
jacket makes my blood go cold it is so COOL!" Commenting on allegations
concerning Garlasco in the media, Israeli Prime Minister Binyamin Netanyahu's policy director said on
September 9, 2009 that Human Rights Watch's employment of "a man who
trades and collects Nazi memorabilia" as its senior military expert is a
"new low". HRW issued a rebuttal to the allegations which stated that
the "accusation is demonstrably false and fits into a campaign to deflect
attention from Human Rights Watch's rigorous and detailed reporting on
violations of international human rights and humanitarian law by the Israeli
government." noting that Garlasco, "has never held or expressed Nazi
or anti-Semitic views."
Helena Cobban,
a fellow Middle East analyst of the Human Rights Watch Middle East advisory
board, noted that Garlasco engaged with "people who clearly do seem to be Nazi sympathizers,"
something she called "extremely disturbing,"
HRW
replies that Garlasco "covered Iraq as a senior intelligence analyst at
the Pentagon" The Guardian reports that he served in this role for 7
years. In addition they write that he was chief of high-value targeting during
the Iraq war in 2003, was on the Operation Desert Fox (Iraq) Battle Damage
Assessment team in 1998, and led a Pentagon Battle Damage Assessment team to
Kosovo in 1999. He also participated in over 50 interrogations as a subject
matter expert.
In
a piece for The National, Alan Philps writes that "the Netanyahu
government and its supporters have set out to destroy the credibility of the UN
Human Rights Council and all non-governmental organisations (NGOs) working in
the human rights field." "The aim is clearly to delegitimise the
organisation at a time when its rights-based analysis coincides with the some
of the views of the US president Barack Obama," Philps continued.
In
a piece for the Christian Science Monitor, Robert Marquand notes that a
U.N. report "Jurist Richard Goldstone, head of South Africa’s Truth and
Reconciliation Commission, chief prosecutor for the Yugoslav war-crimes
tribunal" showed illegal white phosphorus use consistent with Garlasco's
first hand testimony which was provided to the Monitor. Marquand further wrote
that it wasn't okay "to use Garlasco to distract from or obfuscate
findings that war crimes and crimes against humanity may have taken place in
Gaza".
Criticism of fund raising in Saudi Arabia
Some
columnists have criticised Human Right Watch for requesting, encouraging or
accepting financial donations in Saudi Arabia, and have criticised HRW's
methods in which it requests, encourages or accepts these funds. According to
the critics, these methods include the descriptions of HRW's
"battles" and arguments with Israel and its supporters. Herb Keinon,
a columnist for the Jerusalem Post, and Jeffrey
Goldberg, a correspondent for the Atlantic (magazine) and former columnist for
the Jerusalem Post, claim this compromises HRW's integrity. In an email
exchange, Jeffrey Goldberg asked HRW director Kenneth Roth
if funds were raised to fight back against pro-Israel lobbying groups. Roth
responded, "The Saudis obviously are aware of the systematic attacks on us
by various reflexive defenders of Israel. Everyone is." During
fundraisers, he states that these complaints are common in
"discussions" and is not just exclusive to Saudi Arabia. Mark Regev
(spokesman for Israeli PM Binyamin Netanyahu) has said that "A human
rights organization raising money in Saudi Arabia is like a women's rights
group asking the Taliban for a donation," in response to HRW's fund
raising visit to Saudi Arabia.
David Bernstein of the George Mason University School of Law
writes, something's "wrong when a human rights organization goes to one of
the worst countries in the world for human rights to raise money to wage
lawfare against Israel." although IPS latter claimed he apologized for
suggesting that HRW didn't also discuss Saudi human rights abuses during the
meetings.
Human
Rights Watch says the allegations that HRW had "compromised its
neutrality" by meeting with Saudi donors were based on "misleading
assumptions and wrong facts". HRW notes that staffers made two
presentations in Saudi Arabia in May 2009 in private homes to people who were
interested in Human Rights Watch. Among an estimated 50 guests at a reception
in Riyadh, there were three with governmental affiliations, "the
spokesperson for the Ministry of Interior; the deputy head of the Human Rights
Commission, a governmental organization; and a member of the Shura Council,
a government-appointed consultative body." According to HRW, none of those
individuals were solicited for funds and HRW never accepts funds from
government officials in any country. HRW stated that there is no reason why
Saudi citizens cannot legitimately want to support human rights. Gerald
Steinberg, the executive director of NGO Monitor,
said that the HRW defense was an "absurd attempt to cast a distinction
between soliciting Saudi officials and prominent members of society who owe
their very position to the regime."
HRW
told IPS that the notion "that any money from
Saudi Arabia is tainted because it comes from a country with a totalitarian
ruling regime is a gross generalisation." adding "The ethnic
background of our donors is irrelevant to the work we do,...It's not relevant
to our work in Israel that many, many of our donors are Jewish. And it's not
relevant for the work that we do that we get money from Arab countries".
According
to HRW, its work in Saudi Arabia was discussed at the receptions, including
"coverage of women's rights, the juvenile death penalty, domestic workers,
and discrimination against religious minorities". HRW also claimed,
"No other human rights group has produced a more comprehensive, detailed,
and thorough body of work on Saudi Arabian human rights issues in recent years
than Human Rights Watch" (HRW Saudi
Arabia). Although the Gaza situation was covered, HRW claimed that
the coverage was justified as the Gaza war dominated worldwide headlines and is
a regional issue in Saudi Arabia. Criticism of HRW as anti-Israel was
juxtaposed against the accusations HRW faces in much of the Middle East that
HRW is soft on Israeli human rights violations.
In
2008, HRW issued five single-country reports and one multi-country report
criticizing the Saudi Arabian government and in August 2009, HRW issued a
report "Human Rights and Saudi Arabia's Counterterrorism Response:
Religious Counseling, Indefinite Detention, and Flawed Trials" criticizing
the Saudi Arabian government's counterterrorism program.
Allegations of anti-Israel bias
Ron Kampeas
in an analysis published by the Jewish Telegraphic Agency criticizes HRW
reports for "Reconstructions of the horrific death of civilians replete
with painstakingly gathered evidence are coupled with bewildering omissions of
context and blended into a package that assumes an inherent Israeli
immorality," and "efforts to turn criticism of individual officers
and soldiers into a wholesale indictment of Israel’s military establishment and
the decision to resort to military force." According to Kampeas, the HRW
reports on the 2009 fighting in Gaza "fail to assess evidence -- including
videos of Israeli forces holding their fire because of the presence of
civilians -- that Israel has provided to show that such incidents were the
exception to the rule; they fail to examine what measures Israel has taken to
prevent civilian deaths, which would be pertinent in examining any claim of war
crimes."
In
October 2009, Robert L. Bernstein, the founder of HRW,
criticized the organization's policy in the Middle East in a New York Times op-ed. Bernstein
questioned the fact that "with increasing frequency, [HRW] casts aside its
important distinction between open and closed societies... The region is
populated by authoritarian regimes with appalling human rights records. Yet in
recent years Human Rights Watch has written far more condemnations of Israel
for violations of international law than of any other country in the
region." Tom Porteus, director of the London branch of Human Rights Watch,
replied that the organization rejected Bernstein's "obvious double
standard. Any credible human rights organisation must apply the same human
rights standards to all countries." Jane Olson and Jonathan Fanton wrote
"we were saddened to see Robert L. Bernstein argue that Israel should be
judged by a different human rights standard than the rest of the world"
and "as long as open societies commit human rights abuses, Human Rights
Watch has a vital role to play in documenting those violations and advocating
to bring them to an end."[68]
Human Rights Watch noted that Bernstein brought his concerns to the Human
Rights Watch Board of Directors in April 2009 and also noted that the board
unanimously rejected his view that Human Rights Watch should report only on
closed societies, and expressed its full support for the organization's work.
In
April 2010, The New Republic published a very lengthy and
critical piece about HRW, discussing HRW's "giving disproportionate
attention to Israeli misdeeds." Specifically, "Robert James - a
businessman, World War II veteran, and member of the MENA [Middle East and
North Africa Desk of HRW] advisory committee who has been involved with HRW
almost since its inception -calls the group 'the greatest NGO since the Red
Cross,” but argues that it is chronically incapable of introspection. “Bob
[Bernstein, founder and former chair of HRW] is bringing this issue up on
Israel,” he says. “But Human Rights Watch has a more basic problem. ... They
cannot take criticism.'"
The New
Republic, referring to Bernstein's OpEd piece in the New York
Times, quotes Bernstein, saying, "Yet, as difficult as it was
to go public, Bernstein does not believe that Human Rights Watch left him with
much choice. 'They think they’ve heard me out,' he says. 'You see, they think
they’ve listened to me until they can’t listen anymore. Actually, they haven’t
listened at all.'"
In
November 2010, Bernstein gave the Shirley and Leonard Goldstein Lecture on
Human Rights at the University of Nebraska at Omaha. During this lecture, he
accused HRW of "fault[ing] Israel as the principal offender" in the Israel-Palestine conflict and suggested
that groups like HRW were responsible for polarization on university campuses.
In
December 2010, Jennifer Rubin, writing in her Washington
Post blog, described HRW as "an anti-Israel group masquerading
as one devoted to human rights".
In
January 2012, New Europe quoted an NGO Monitor
report which said that HRW gives "disproportionate attention" to
'Israel and the Occupied Territories' which received "more attention in
2011 than Tunisia, Saudi Arabia, or Iraq." The article also said that the
HRW reports continued to show "bias on Israel," and that "all
op-eds published on the Arab-Israeli conflict in major media focused on
allegations against Israel."
Anti-Arab-League
or pro-Israel bias
In
regard to reporting on the 2006 Israel-Lebanon conflict, Israel-based
journalist Jonathan Cook claimed that by making statements
regarding the intentions of Israel and Hezbollah
to target or to avoid targeting civilians that were not justified by the
available evidence, HRW "[seemed to distort] its findings to placate the
Israel lobby". Cook stated, 'HRW is accusing Hezbollah of committing
graver war crimes than Israel, even though it killed far fewer civilians both
numerically and proportionally, because its rockets are "less
accurate"'. A representative of HRW responded, defending the organisation's
objectivity. Cook countered that he did not criticise the empirical aspects of
HRW's research, only its interpretation of that research. HRW has also been
criticised for taking Israel's side in its condemnation of the Palestinian use
of human shields. Norman Finkelstein has criticised HRW for
"seeking to appease pro-Israel critics after taking the heat for its
report documenting Israeli war crimes in Lebanon?".
Ignoring
Islamic laws
A
prominent Saudi human rights activist has described the Human Rights Watch
report on the rights situation in Saudi Arabia as contradicting the truth in
some of its items and does not take into account in many cases the religious
background of the people of Saudi Arabia.
Human
Rights Watch responds to criticism
In
the wake of the Goldstone
report, HRW accused in 2009 Israel and its supporters of an
organized campaign of false allegations and misinformation aimed to discredit
the group over its findings over the Gaza War.
HRW ties the criticism to a statement by a senior official in the Israeli prime
minister's office in June 2009, pledging to "dedicate time and manpower to
combating" human rights organisations. HRW said it concluded the criticism
amounted to an organized effort since attacks from different sources appeared
to be co-ordinated. HRW said that similar language and arguments in criticism
implied that there had been prior coordination. Iain Levine of HRW said
"We are having to spend a lot of time repudiating the lies, the
falsehoods, the misinformation".
A
group of 10 Israeli rights groups has protested that the Israeli government has
been attempting to "instill fear and silence or alarm vital
organizations" that were engaging in free public discourse.
Allegations
of bias concerning Africa
HRW has also been accused of unfair and biased reporting of human rights issues in Eritrea and Ethiopia.
Eritrea
In
April 2009, HRW published a report that accused the Eritrean government of being responsible for
serious human rights violations. Sophia Tesfamariam, Director of the US
Foundation for the Horn of Africa refuted the allegations in the
report which she described as an "anti-Eritrea report" and stated
"HRW goes to great lengths to embellish the truth in its attempts to paint
a bleak picture of Eritrea and its government". She described it as “not
only short on facts and evidence, but also short on intellectual and
professional integrity”.
Ethiopia
The
Ethiopia government has also raised questions about HRW's methods. It
commissioned a report of its own that dismissed Human Rights Watch's
allegations of human rights abuses in the Ogaden as
hearsay and its methods as slapdash.
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