From East to West

Last month we touched on the different classification of Process Servers in Florida. From our far east state to our far west, this month, we are all about the Ins and Outs of serving process in Colorado. The state association for process servers in Colorado is called PSACO or Process Servers Association of Colorado. I applied for membership in 2020 and was accepted, thanks PSACO representatives, members, etc. My website proudly displays our membership logo, see below:

Fellow Accurate Serve® Team Member, Brennan Fogarty, is also a member of PSACO.  He is also the proud Owner of Accurate Serve® of Denver.

To know how to do something well, you need to know the basics.  Well, to be as basic as possible, CO rules of SOP are as follows:

• Can NEVER Drop Serve, 18 to sub serve.  To sub serve, must be a direct family member at least 18 years old.

So, you can call those the meat and potatoes of CO PS but we are making Shepherd’s Pie, so there is a lot more to it.  Luckily for us, PSACO has made a nice little cheat sheet to aide those in the legal field, see attached.

A quick note:

• CO requires an Affidavit of Service (AOS) w/ notary.  When Covid-19 became a widespread pandemic, CO courts started to allow Returns of Service (ROS) w/o notary

From FL to CO (and AL, MI, GA and TX too), we have you covered.  If you are a Denver Attorney (or paralegal) reach out to our Denver office please.  If you are located in one of these states, find your right point of contact with our organization.  Please visit our franchise website and use the cool tool, Find Location, feature.  It’s red and currently in the Pacific Ocean.

Warmest regards,
Beau Charlet
https://www.theaccurateservefranchise.com/

Happy New Year! Each January marks the beginning of a new year, a fresh start and new goals to achieve. This January also marks the beginning of our second office opening in TX. Accurate Serve® of Houston will work side by side with Accurate Serve® of Dallas to provide Houston Attorneys and Paralegals with a Professional Process Serving company that will handle local, statewide, nationwide and international service of process.

Our team is here to provide you with quick response time to all emails, including confirmation of new jobs. No matter the location of service we provide timely updates on all attempts as well as job completion notifications.

Communication remains the main priority for our team. Part of that communication is ensuring that our servers throughout the nation understand how to serve process in accordance to TX Statute. All servers, including our locals ones are provided with instructions on how to serve each job and completed service is only accepted by our office if the job is served in accordance with the instructions. This allows you to also provide us with special instructions such as serving someone at an alternate location (Work or family/friends house), contacting someone to set up service or sitting on a location for surveillance in order to get a job done. Any additional information or special instructions for service is appreciated and communicated with our servers to help complete service more efficiently for you.

As we move forward in this new year please reach out to our new offices in TX as we are looking forward to the opportunity to earn your business. We have our goals set high and look forward to having you and your team as a part of our Accurate Serve® Family. When you are ready to contact us for service please email us at – [email protected], we are also always available for phone calls. I look forward to hearing from you and earning your business.

Thank you,

Brandon Muscato
Need our help?
Call (346) 226-3111
or
Email [email protected]

As you can see in the CO cheat sheet, some papers can be sub served but some need to be personally served.  There are specific rules/laws for each state that need to be followed. We pride ourselves in our knowledge BUT if you need something special on a serve you send us, please let us know. This will only ensure accuracy of delivery.

December 2020 Job Count – 4,527
Average Number of Days from Receiving Paper to Paper Being Served* – 5.5

*This includes jobs that may be on hold or waiting for new info. There is no way to take those jobs out of the calculation. So, if a job is placed on hold for 2 weeks, that’s 14 days on that job which factors in to this average. So, we’re even better than what the eyes see, LOL. Some papers get served same day, some next day and some take multiple attempts/addresses to effect service. All we do all day and every day is serve papers. We’re good at it and we love what we do. Thank you for allowing us the opportunity to continue to serve your papers.

We have had questions on Motion & Order in Process Serving, so my article this month is an article re-pull from a few years ago. The below describes M&O for PS in FL in detail.

In Florida, you have 2 options when it comes to serving your civil process.  You can go with the Sheriff or a private process server. The Sheriff has a lot of responsibilities other than serving papers whereas here at Accurate Serve, all we do all day every day is serve papers.

Florida has 3 classifications for private process servers and they are detailed below:

1. Special Process Servers
2. Certified Process Servers
3. Process Server by Motion & Order

A Special Process Server is a Process Server who has been appointed by the Sheriff to serve non-enforceable civil process in that county. Basic requirements to become a special process server include: Permanent Resident of the State, 18 years of age, no mental/legal disabilities. You also have to take a class, pass a test, pay a fee, get a background check, stay in good-standing, re-certify annually and maintain your ID card. See 48.021 for more info.

A Certified Process Server is a Process Server who has been certified by the Chief Judge to serve non-enforceable civil process in that circuit. The qualifications needed mirror the ones listed for Special Process Server. The main difference is the certification goes through the courts not the Sheriff and you are certified to serve process in the whole circuit, not just one county. See 48.27, 48.29 and 48.31

And now for the last and most dreaded one, it’s Motion & Order Counties.  *There are 14 counties that are labeled Motion & Order. What this means is that the courts do not certify process servers in that county and the sheriff does not appoint process servers in that county. So, if we need to serve process in a Motion & Order county, then we need to be appointed on a case by case basis. Note, Subpoenas do not need a Motion & Order but Summonses do require one. We have templates at the ready for these counties which list our Servers’ names.  If a serve requires a M&O, we will let you know and send you our template to complete. It needs to be completed by the Attorney and e-filed to the case docket. You should also follow up with the Judge or JA to ensure the M&O gets executed quickly so we can begin our efforts.

Please note that M&O does not apply to serving foreign process in Florida.

*Alachua, Baker, Bradford, Calhoun, Clay, Flagler, Gilchrist, Holmes, Levy, Nassau, Putnam, Union, Volusia, Washington

Warmest regards,
Beau Charlet
https://www.theaccurateservefranchise.com/

Let me start by saying Merry Christmas and Happy Holidays to you and your loved ones. As we are wrapping up what has been an unprecedented 2020, I am excited to announce our growth and opening of Accurate Serve Dallas. Our Dallas office is ready to handle any process serving needs that you and your office may have. We will be providing service locally throughout Dallas County as well as Statewide and Nationwide Service.

Our office is focused on providing timely service while keeping you up to date on all attempts and information for each job. We are always available for phone calls but much of our communication will come via email. Once we update a job, whether it is an attempt or the job has been completed, you will receive an email with the details of that attempt or job completed information. Many of our servers take advantage of the technology that we have by using our app on their phone to provide job details. This helps us to provide you with quicker updates and images of attempts or service when needed.

All jobs filed within the state of TX will be served in accordance with TX Statutes and procedures of service. As Accurate Serve continues to grow throughout the nation, our team also continues to expand our knowledge of Statues and Procedures from state to state. Our objective is to be your one stop shop for a process serving company. I should also mention that we have successfully served internationally as well, throughout many parts of Canada, Europe, Asia and South America.

If you are in need of service or just have a question, please email us at [email protected]. We look forward to working with you, creating new relationships and successfully serving your office.

Thank you,

Brandon Muscato
Need our help?
Call (469) 518-9581
or
Email [email protected]

Routine service is within 4 business days. Rush Service is within 24 hours. Same Day Service is service that day. When sending your AS office docs for service, please let us know in the email (or website submission) what priority you require for service. Please note, if the court date is less than a week away, we will auto rush it BUT it helps if you draw our attention to the court date in your correspondence.

November 2020 Job Count – 4,374
Average Number of Days from Receiving Paper to Paper Being Served* – 4.7

*This includes jobs that may be on hold or waiting for new info.  There is no way to take those jobs out of the calculation.  So, if a job is placed on hold for 2 weeks, that’s 14 days on that job which factors in to this average. So, we’re even better than what the eyes see, LOL. Some papers get served same day, some next day and some take multiple attempts/addresses to effect service. All we do all day and every day is serve papers. We’re good at it and we love what we do. Thank you for allowing us the opportunity to continue to serve your papers.

New Office Openings in Texas!!

We are over the moon excited to announce the opening of not one but two new offices this month!!  Accurate Serve® of Dallas and Accurate Serve® of Houston are set to officially open over the next few weeks. By the time you read this email (unless it is post-Nov.), the websites for the new offices are not yet live. Some tweaks, you know I dotting and t crossing stuff, still needs to be done. But, our Servers are in place, our software is set up, emails and phones are live, so if you are an Attorney, Paralegal or Legal Assistant in Dallas or Houston, reach out to your Owner/Operator right now.

Dallas office:
Email: [email protected]
Contact Number:  469-518-9581

Houston office:
Email: [email protected]
Contact Number:  346-226-3111

Have you used our Find Location feature on our franchise website?  It is a great tool to use to determine which Accurate Serve® office is your point of contact for service of process.  

https://www.theaccurateservefranchise.com/

Warmest regards,
Beau Charlet

Hello I am James Pantell, the new owner and operator of Accurate Serve Atlanta. Beau recently accepted me into his team of professionals last August and since then I’ve had the opportunity to train and learn from multiple other partners. It’s been a great experience getting things going in a new city, and certainly plenty of new things to learn! I’ve always believed that success comes from our ability to adapt and grow so we are able to fit the needs of each situation we encounter. Here at Accurate Serve, I certainly have witnessed our ability to do just that!

Accurate Serve Atlanta started accepting business October 1st 2020 and has been growing each day since. I currently have servers set up to encompass the Atlanta area with servers in multiple counties (Fulton, Cobb, Gwinnett, Paulding, Dekalb, Douglas, Clayton, Forsyth, and multiple others in the Southern GA region). With these servers on hand, our competitive prices, and ability to facilitate service of process throughout the state, AS Atlanta is ready to serve your needs!

Please go to www.accurateserveatlanta.com to read more about myself and Accurate Serve. We accept requests for process as well as prepayment through our website to keep things easy for our clients. If you have any other questions feel free to email me at [email protected]

I look forward to hearing from you and stay safe out there,

– JP

James Pantell
Need our help?
Call (404) 924-4838

or
Email [email protected]

Never put a frozen turkey in a turkey fryer full of hot oil.

October 2020 Job Count – 5,186
Average Number of Days from Receiving Paper to Paper Being Served* – 4.1

*This includes jobs that may be on hold or waiting for new info.  There is no way to take those jobs out of the calculation.  So, if a job is placed on hold for 2 weeks, that’s 14 days on that job which factors in to this average. So, we’re even better than what the eyes see, LOL. Some papers get served same day, some next day and some take multiple attempts/addresses to effect service. All we do all day and every day is serve papers. We’re good at it and we love what we do. Thank you for allowing us the opportunity to continue to serve your papers.

Some Peachy News

2020 has been a crazy year for sure.  Well, here at Accurate Serve® it has been crazy busy, that’s for certain.  Well, we have some more great news to share with you. Officially open for business as of October 2, 2020, we welcome to the AS team, Accurate Serve® of Atlanta. My office (Tampa Bay area) has already sent multiple papers to Accurate Serve® of Atlanta and all of them were served quickly and accurately, you know the Accurate Serve® way!!

The man behind the email and on the phone is new team member, James Pantell, but you can call him JP for short.  On a lighter note, JP joins several other Accurate Serve® team members whose first names start with J, like Josh Wright, Josh Kes and Jared Williams. Adding to that, we have 3 team members whose names start with B, Beau Charlet, Brennan Fogarty and Brandon Muscato. I know, I’m way off track but it’s fun to read about funny things like that, don’t you agree?

So JP went through Accurate Serve® franchise training July – Sep of this year. He has Servers all over the State of Georgia ready to serve your papers. If you are an attorney in Atlanta or GA, reach out to JP, he is the Man and will get the job done!!

If you are a FL attorney (or Denver or Detroit), keep sending your work to your local Owner/Operator.  Just know the next time we serve one of your papers in GA, we have upgraded the level of service you will be provided.

Warmest regards,
Beau Charlet

Hello Accurate Serve Customers Clients Franchisees and welcome to October 2020.

Hello I am Erik Devlin, the new Owner and Operator of Accurate Serve of Detroit. Beau and I came into talks of making this idea come to fruition in June of 2020. Since then, I have been able to train with Brandon Muscato in Ft Myers, Beau Charlet in Lakeland, and Brennan Fogarty in Tallahassee. Working with multiple training centers for Accurate Serve has provided me the tools for success and has enabled me to come up with solutions for whatever situation may arise. I am excited to work with you all and grow with Accurate Serve.
Accurate Serve Detroit did a soft opening in September with a hard open October 1^st 2020. I will be covering the greater Detroit area including Wayne County and Oakland County. I have competitive prices in the market and servers on hand ready to serve your needs.  Keep us in mind if you need papers served over the river in Windsor, Canada or If you are a Canadian Law Firm looking for someone to serve Papers in Michigan.  This month I am looking to reach out to some of our past clients in Michigan to let them know we now have an office in Detroit and to let them know we are here to assist with all of their legal needs.

If you are interested in our services please go to accurateservedetroit.com and follow our tabs. We accept pre-payment for new customers and have a list of all the services we provide.  If you have any other questions feel free to email me at  [email protected].

I look forward to hearing from you and stay safe out there.

Erik Devlin
Need our help?
Call (313) 385-3703
or
Email [email protected]

All Colorado courts are currently accepting unsworn Affidavits, or Returns of Service, in lieu of notarized Affidavits in regards to service of process.

September 2020 Job Count – 5,045
Average Number of Days from Receiving Paper to Paper Being Served* – 4.48

*This includes jobs that may be on hold or waiting for new info.  There is no way to take those jobs out of the calculation.  So, if a job is placed on hold for 2 weeks, that’s 14 days on that job which factors in to this average. So, we’re even better than what the eyes see, LOL. Some papers get served same day, some next day and some take multiple attempts/addresses to effect service. All we do all day and every day is serve papers. We’re good at it and we love what we do. Thank you for allowing us the opportunity to continue to serve your papers.

Process Serving, Recent Legislature Changes & Technological Advancements

In June 2019, Florida House Bill 91 was signed, sealed and delivered. One of the major changes in this Bill was the fact that process servers could now electronically sign their Returns of Service. This was a HUGE development. Prior to the signing of this Bill, only the Sheriff was allowed to electronically sign Returns, not private process servers (PPS).

Once this Bill was signed into effect, our software programmer went to work and built a feature into our software program and App which allowed Accurate Serve Process Servers to update jobs and sign Returns using their Smartphones. They could serve a paper and within minutes be able to sign the Return of Service (ROS). This sure does beat the old way of doing things which would consist of printing the Return, waiting for Server to report to the office to sign Return, then scan it, save it and email it.

This new development/advancement has been great for us here at Accurate Serve as well as our Clients. The quicker we can serve the paper and provide the ROS, then the happier our Clients will be. Well, what about an Affidavit of Service (AOS)? A notary can’t notarize a document when an electronic signature has been used, right? Well in June 2019, that was true. Fast forward 6 months, different story.

As of January 1, 2020, current Florida notaries have had the opportunity to add remote online notary (RON) duties to their current commission. In order to be approved, the following criteria must be met:

• Complete a course
• Obtain Bond
• Obtain Errors & Omissions insurance
• Select a RON Service Provider
• Complete a form
• Pay a Fee to the State

There are very specific duties that a RON Service Provider must undertake. The technology they utilize must meet requirements set forth in Chapter 117, Florida Statutes as well as Chapter 1N-7.001, Florida Administrative Code. Some duties include:

• Facilitating 2-way video conferencing for online notary and Affiant (record video and store for 10 years)
• Attach digital signatures/notary’s stamp and signature of Server

Well, just like building electronic signatures into our software program, our programmer stepped up to the cleanup spot this time and hit a grand slam. Our software program, Paper Tracker, applied to be a RON Service Provider in the State of Florida.  After that, the RON process was built into our software and after months of testing, it is now live for use. We have successfully electronically signed and notarized over a dozen Affidavits in our Tampa Bay offices this past week and now we are making the feature live in all 38 Accurate Serve locations in Florida.

When changes happen, we adjust. When advancements need to made, we get to work.  Bust most importantly, we serve papers and we serve them quickly and accurately. We pride ourselves in service of process. We are experts in the field and are committed to the industry.

Just to let you know, we opened an office in Denver, CO in July 2020. We open an office in Detroit, MI in September 2020. And we open an office in Atlanta, GA in October 2020.

We’re always working, we’re always open, and we are always doing our best to ensure your papers are served in a timely fashion and according to State Statutes.

Warmest regards,
Beau Charlet

Accurate Serve of Denver is here to handle all your service of process needs.

We are here in downtown Denver ready to affect service on any subjects. Your firm would only need to send us an email with docs attached and we can get you a quote and get your job out for service!

We regularly affect service at the large corporate Registered Agents. CT Corporation is located here in Denver.

We can go to Littleton Co. and affect service on Corporation Service company as well!

What about service of process on the State of Colorado? We can direct our servers to affect process at any government entity in Denver or anywhere around the state!

That’s not all!! We have an extensive network nationwide! If you are looking for a process server in Colorado, or anywhere else just send us an email and we will be happy to take great care of you and your business.

– Your Accurate Serve Denver Team

Need our help?
Call (303) 501-7121
or
Email [email protected]

Life is getting back to normal, slowly.  Kids are back in school, whether it be at home, brick and mortar or a combo. Sports are back, I have been glued to the U.S. Open and can’t wait for football to start. Just want to say thanks to everyone who does their part to keep themselves safe as well as those they interact with in their respective bubbles.  We’ll all get through this together and we all must do our part.

August 2020 Job Count – 5,057
Average Number of Days from Receiving Paper to Paper Being Served* – 4.25

*This includes jobs that may be on hold or waiting for new info.  There is no way to take those jobs out of the calculation.  So, if a job is placed on hold for 2 weeks, that’s 14 days on that job which factors in to this average. So, we’re even better than what the eyes see, LOL. Some papers get served same day, some next day and some take multiple attempts/addresses to effect service. All we do all day and every day is serve papers. We’re good at it and we love what we do. Thank you for allowing us the opportunity to continue to serve your papers.

Lions, Tigers but Not Bears….Not Yet at Least

Accurate Serve® is over the moon excited to announce another office opening in yet another state!! Accurate Serve® of Detroit opens its doors THIS September!! Introducing new Team Member and Owner/Operator of the Detroit office, say hello to Erik Devlin. Erik has served in a different role with AS the past few years, no pun intended, because he is and has been an awesome process server the past few years!! Erik attended and graduated from Accurate Serve® corporate franchise training in August after working closely with and at multiple Accurate Serve® office locations in July and August.

After serving voluminous amounts of papers for the AS team, Erik saw the opportunity to own his own office and he seized it!!  Erik will be the 3rd process server working for Accurate Serve® who has taken the leap to become an owner of an Accurate Serve® office. The previous two Process Servers turned Owners, Brennan Fogarty and Brandon Muscato, have worked out well and we look forward to Erik growing within the organization too and becoming a solid team member for the Accurate Serve® family.

Warmest regards,
Beau Charlet

At Accurate Serve® Gainesville, we are always concerned about the health and safety of our clients, the people who we service, and our employees. This is even more important to us as we all work to navigate the “new normal” that exists during the middle of a global pandemic.

Accurate Serve® Gainesville continues to provide Contactless Service to our clients. All requests for service through AccurateServe® Gainesville may be completed via email, phone call, or US postal service. Our process servers wear PPE while delivering your important court documents, so that all parties can feel safe when they receive your information. Those served are not required to provide signatures; instead, our servers provide detailed descriptions when verifying service by using our process server app, so that procedures are touchless from start to finish. Accurate Serve® Gainesville will be here for you our clients, throughout the pandemic.

COVID numbers continue to fluctuate from county to county in our state, but scientists predict that they are expected to rise as students re-enter their classrooms and flu season approaches. Many K-12 learners in public, private and charter schools, as well as scholars at Santa Fe College and the University of Florida are returning to their respective campuses this fall, so we want to urge our clients, partners, and everyone in the Accurate Serve® family to stay safe. The influx of flu season is just around the corner, so please be sure to follow the CDC guidelines for safety and social distancing during this pandemic. Please stay safe!

– Your Accurate Serve Gainesville Team

Need our help?
Call (352) 553-2009

or
Email [email protected]

Kids are going back to school soon, if not already.  Please visit the CDC website and view the resources they have to ensure you, your child and all those they interact with remain safe as schools open back up.

https://www.cdc.gov/coronavirus/2019-ncov/community/schools-childcare/index.html

July 2020 Job Count – 4,819
Average Number of Days from Receiving Paper to Paper Being Served* – 4.2

*This includes jobs that may be on hold or waiting for new info.  There is no way to take those jobs out of the calculation.  So, if a job is placed on hold for 2 weeks, that’s 14 days on that job which factors in to this average. So, we’re even better than what the eyes see, LOL. Some papers get served same day, some next day and some take multiple attempts/addresses to effect service. All we do all day and every day is serve papers. We’re good at it and we love what we do. Thank you for allowing us the opportunity to continue to serve your papers.

From the East Coast to the West Coast, We Got You!

It’s official, Accurate Serve of Denver opened its doors to the public on July 6, 2020.  We are beyond excitement as our first true nationwide office is open for business.  Brennan Fogarty, current franchisee, it this market’s owner.  He partnered up with Monte Phillips, who will be the Office Manager & Head Process Server.  Well, you all know Brennan, but who’s Monte?

Monte is a childhood school friend of Founder, Beau Charlet.  Monte made the move to Denver in 2019.  Prior to that, he lived in the Miami, FL area.  Monte reached out to Beau about process serving and Accurate Serve while in Florida.  After he made the move to Colorado, he once again reached out and the two started talking about how to bring Accurate Serve to the west coast.  Beau brainstormed and spoke to his franchise team and then put Brennan and Monte in touch and then that’s when history was made.

Brennan has proven over the years how well he embodies the Accurate Serve mentality, which includes hard work, dedication to the profession and Accurate Serve Clients. In addition to Owner and Office Manager, the team at Accurate Serve Denver is here to answer your calls, emails, texts, FB Messages, etc. Reach out to us and we’ll be here to take care of your process serving needs.

The new website is: www.accurateservedenver.com

Please like their FB page:  https://m.facebook.com/Accurate-Serve-Denver-104329644680582

I will also request that you check out the updated franchise website: www.theaccurateservefranchise.com

Lastly, we are looking to explode all over the U.S.  Be on the lookout for new markets opening in: Detroit, Atlanta, Dallas, Washington D.C., Boston, Baltimore, Chicago, Las Vegas.

Warmest regards,
Beau Charlet

2020 has already been one for the books… literally lets close this thing and open 2021! Just kidding, as unpredictable as this year has been we are looking forward to the rise that will come from this pandemic. Everyday life has and will continue to change but when it comes to hiring Accurate Serve for your process serving needs you can rely on having the same easy process.

You have two, easy and great, options to send us new work. First, just email us the documents for service including everything that needs to be served to the subject(s). Our team will quickly confirm receipt of this email along with any special instructions or information you may provide. The second option is to use the send work tab at www.accurateserveportstlucie.com, or your local offices site. Here you have the ability to upload all of the documents electronically and type in the client, case, and servee details manually. Once uploaded our office is able to accept the job and can quickly process the documents for our server to begin attempts.

Our fees cover four attempts at service for one address. Making additional attempts or rerouting a job is never an issue, no matter where the reroute location is. Our team will keep you updated on all attempts and service details via email. Once completed returns/affidavits will be emailed to you, if requested we mail the originals.

In the midst of all the change, allow us to keep some normalcy in your life with quick, easy and efficient process serving on any cases, anywhere.

Fun fact on Sub Service according to Fl Statute. The statute below reads that you can leave documents at his or her place of abode to any person residing therein 15 or older in age. One of the meanings for Abode is an extended or temporary stay. People who may take extended vacations or are currently staying with family or friends can still be sub served at alternate locations as long as it is confirmed that this location is where they are sleeping/currently living or staying.

48.031 Service of process generally; service of witness subpoenas.—

(1)(a) Service of original process is made by delivering a copy of it to the person to be served with a copy of the complaint, petition, or other initial pleading or paper or by leaving the copies at his or her usual place of abode with any person residing therein who is 15 years of age or older and informing the person of their contents. Minors who are or have been married shall be served as provided in this section.

Abode: noun

a place in which a person resides; residence; dwelling; habitation; home.

an extended stay in a place; sojourn.

– Your Accurate Serve Port St. Lucie Team

Need our help?
Call 772-236-7214

or
Email [email protected]

June 2020 Job Count – 5,027
Average Number of Days from Receiving Paper to Paper Being Served* – 4.5

*This includes jobs that may be on hold or waiting for new info.  There is no way to take those jobs out of the calculation.  So, if a job is placed on hold for 2 weeks, that’s 14 days on that job which factors in to this average. So, we’re even better than what the eyes see, LOL. Some papers get served same day, some next day and some take multiple attempts/addresses to effect service. All we do all day and every day is serve papers. We’re good at it and we love what we do. Thank you for allowing us the opportunity to continue to serve your papers.