If you have a lawyer, then the motion was served on your lawyer. Clinton M. Sandvick worked as a civil litigator in California for over 7 years. If there are additional parties in your lawsuit, then you can send them courtesy copies. Prepare the Motion You must file a separate motion for each of the discovery responses you wish to compel. You need to fully understand the arguments made. You should limit your argument to your strongest two or three points. (Code Civ. You will lose the information in your envelope, ORDER REGARDING PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE FROM DEFENDA, CROWN BUILDING MAINTENANCE, INC. You can title your motion Defendants Response in Opposition to Plaintiffs Motion to Compel Discovery and For Sanctions or something similar. Such material is not relevant to this case. The maps analyze the geographic distribution of hospitals of certain sizes. This article was co-authored by Clinton M. Sandvick, JD, PhD. vs University of the Pacific, a California Corporation et , ORDER DENYING DEFENDANT'S MOTION TO COMPEL FURTHER DISCOVERY RESPONSES UND, JON LOUIS VS. ST FRANCIS BAY -ONE HUNDRED ONE CRESCENT WAY et al, Motion to Compel Further Responses to Special Interrogatorie - From Defend, DOE -V- SAN BERNARDINO CITY UNIFIED SCHOOL Print, MOTION TO COMPEL FILED RECORD SEALED - Plaintiff Mishelle Neverson's Motio. The first safety zone applies to hospital mergers satisfying certain criteria. Mink, 410 U.S. at 93.(5). Material must not be incorporated into the separate statement by reference. 4 MOTIONS 4. The separate statement requirement was designed to streamline adjudication of discovery motions, and a failure to file a separate statement is a sufficient basis for denying plaintiffs motion to compel. by Secure .gov websites use HTTPS The United States has, accordingly, submitted a Confidential Schedule of Documents in camera for the Court's review only. Mink, 410 U.S. at 92. Similarly, in Assembly of California, 968 F.2d 916 (9th Cir. You cant respond to a request that you dont understand. (Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 893.). UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF IOWA EASTERN DIVISION, OPPOSITION TO DEFENDANTS' MOTION FOR ORDER TO COMPEL THE PRODUCTION OF DOCUMENTS FROM PLAINTIFF. NLRB v. Sears, Roebuck & Co., 421 U.S. 132, 138 (1974). for Sanctions; to Deft's Req. ku. in the jurisdiction of San Francisco County. Plaintiffs were unable to move to compel attendance at trial in . California Code of Civil Procedure (CCP) 2016.040. 1993). On September 15, 1993, the Antitrust Division joined with the Federal Trade Commission in issuing Statements of Antitrust Enforcement Policy in the Health Care Area ("Policy Statements") regarding "their antitrust enforcement policies regarding mergers and various joint activities in the health care area." Home Page - The Superior Court of California, County of Santa Clara Any opposition to the motion must be served and filed within five days of service of the moving papers and may be no longer than 15 pages. A similar document, not described in the Confidential Schedule, was prepared by the Federal Trade Commission ("FTC"). The separate statement is the keystone of the opposition No document is more important in opposing summary judgment than the Separate Statement. Except as provided in Code of Civil Procedure section 437c (r) and rule 3.1351, the opposition to a motion must consist of the following separate documents, titled as shown: (1) [ Opposing party's] memorandum in opposition to [ moving party's] motion for summary judgment or summary adjudication or both; To date, no reply brief has been filed. Proc., 2023.030(a), 2033.280, 2030.290, and 2031.300. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Interrogatories Check your previous documents filed in the case and follow the formatting. These documents reflect the deliberations, considerations, analyses, and recommendations of Antitrust Division staff and officials concerning the enforcement of the antitrust laws. I am an economist with the Antitrust Division of the Department of Justice. About. The United States opposes Defendants' Motion For An Order To Compel The Production Of Documents From Plaintiff on the grounds that: (1) the motion is now moot as to Requests 4 and 7 as a result of discovery conferences held subsequent to its filing; and (2) the only documents sought by Request 13 that are still at issue are not relevant to this You will lose the information in your envelope. Also leave time to correct any misimpression created by the other side. Attorney For The Defendant, Koss, Charles A SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PUBLIC WATER SUPPLIERS TO PROVIDE FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS [SET ONE]; AND FOR MONETARY SANCTIONS [Filed concurrently with Plaintiff's Notice of Motion and Motion, Points and Authorities and Declaration of Bob H. Joyce] Date: October 12, 2007 Time: 9:00 a.m. Last Updated: January 22, 2022 Attorney For The Defendant, Nrt West, Inc, Dba Coldwell Banker Residential Separate Statement of Items in Dispute. Your credits were successfully purchased. If the consumer/employee objects or files a motion to quash, the witness is not permitted to respond to your Deposition Subpoena.You may make a Motion to Compel Production (deadline: 20 days after service of the . If you wish to keep the information in your envelope between pages, There are 10 references cited in this article, which can be found at the bottom of the page. References. Disclosure of the tables, maps, statistics and numerical information would reveal the thinking of staff as to which facts were relevant to the deliberations leading up to issuance of the Policy Statements. ), PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED, Personal Injury Non-Motor Vehicle Unlimited, 1 If you have never argued a motion before the judge, you should try to sit in on a hearing. for Sanctions; Further Resp. (Code Civ. Exhibit 3 resolves defendants' procedural arguments regarding invocation of the privilege. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. 'X "2*(G&T, XG6G,TG" 'XG &2T. You have actually complied with the discovery request. Your subscription has successfully been upgraded. by clicking the Inbox on the top right hand corner. This process, called discovery, usually does not involve the judge. aj tng ca`pigtg lkigs fjd, rgcards al tnks fctkaj! In addition, with the exception of a few tables reproduced from published texts, the staff created all tables and maps from larger publicly-available data bases (1989-90 "Individual Hospital Data," California Healthcare Facilities Commission and the American Hospital Association data set on hospitals). The Antitrust Division has referred that document to the FTC for its evaluation of whether it is privileged. United States v. Jacob, 781 F.2d 643, 646-47 (8th Cir. when new changes related to " are available. A motion to compel the deposition of a party to the action must also be accompanied by a meet and confer declaration, or, when the deponent failed to attend the deposition, a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. ), Personal Injury Non-Motor Vehicle Unlimited, 1 As to the second, the United States has agreed to produce published speeches from Antitrust Division officials issued after the issuance of the Policy Statements. Put the certificate on a separate sheet of paper titled Certificate of Service in all caps, bold. As to Requests 4 and 7, defendants have in correspondence and their moving papers limited the original requests to documents on which an expert witness relies in forming the expert's report, thereby meeting the United States' objections. (2) Defendants now seek three categories of documents related to the safety zone for certain hospital mergers set forth in the Policy Statements: (1)Senior Officials' Communications; (2)"Post-decisional" documents which reflect "summaries, comments, investigations, explanations, interpretations, applications, analysis or implementation of" the safety zones; and (3)Numerical data and tabulations. Miscellaneous Document Filed - SEPARATE STATEMENT FILED. Couns., Inc. v. Pac. This article was co-authored by Clinton M. Sandvick, JD, PhD. P. 83. Rules of Court, rule 3.13350(e)(2).) TENTATIVE RULING: Maxwell, Judith et al. Rules of Ct., Rule 3.1345(c). 7 tng dgcifrftkaj al QQQQQQQQQQQfjd g#nkhkts fttfcngd tngrgta! A separate statement is a separate document filed and served with the discovery motion that provides all the information necessary to understand each discovery request and all the responses to it that are at issue. By signing up you are agreeing to receive emails according to our privacy policy. _______________________________ ROBERT E. LITAN, CONFIDENTIAL SCHEDULE OF DOCUMENTS TO DECLARATION AND CLAIM OF PRIVILEGE OF ROBERT E. LITAN. Without it, the court has no evidence properly before it. Also listen to the questions the judge asks. (Set 1) to Eric Hvolboll/Req. TENTATIVE RULING: Sample Opposition to Motion to Compel Further Responses to Documents for California, This sample opposition to a motion to compel further responses to requests for production of documents in California is made on the grounds that the requests for production of documents are , 100% found this document useful (4 votes), 100% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion to Compel Further Resp For Later, Supgrkar Caurt al tng Stftg al Cfiklarjkf, Ta suhscrkhg ta `y LXGG wggeiy igmfi jgwsigttgr vkskt, Ta vkgw avgr 3 sf`pig igmfi dacu`gjts said hy !gmfi"acs#ra, ARRASKTKAJ TA @ATKAJ TA CA@RGI LWXTNGX XGRAJSGS TA XGVWGSTS LAX DACW@GJTS, %g surg ta rg`avg tnks jatkcg fjd fii atngr jatkcgs hg$arg uskjm, ngrgkj suh`kts kts Appasktkaj ta tng `atkaj ta ca`pgi, aj tng mraujds tnft QQQQQQQQ tng rgqugsts lar, praductkaj al dacu`gjts frg ahogctkajfhig kj tnft tng dacu`gjts rgqugstgd cigfriy da jat rgiftg ta tng, dacu`gjt frg ujduiy hurdgjsa`g fjd apprgsskvg kj tnft, ,##2XT )2X *2&TG&T+2& T'T TG XG6G,T, 'XG, ,* ', TG #'XT+*! Your recipients will receive an email with this envelope shortly and As demonstrated in the Declaration of Gregory S. Vistnes, which is Exhibit 4 to this Memorandum, all numerical data and tabulations reflect the process of separating significant facts from insignificant ones, Mapother, 3 F.3d at 1398-99. ), If a party to whom interrogatories are directed fails to serve a timely response, the propounding party may move for an order compelling responses and for a monetary sanction. THOMPSON VS CONTINENTAL LABOR RESOURCES, INC. Motion to Compel 12/04/2018 - Motion to Compel, Motion to Compel - def Reeder's Motion to Compel Pltf Barmore to File Unde, Barmore et al -v- Circa Management, Inc. et al Print, ORDER DENYING PLAINTIFFS MOTION TO COMPEL AND REQUEST SANCTIONS, DEFENDANT, MICHELLE HUANG ET AL VS. SANDEEP ANDRE HINGORANI ET AL, Motion to Compel Further Responses to Interrogatories, Motion to Compel Responses to Request for Production of Documents, Motion to Compel Further Responses to Special Interrogatories, Motion to Compel Deposition of Person Most Qualified (PMQ). Ct. (1988) 199 Cal.App.3d 1240, 1270; Neary v. Regents of University of California (1986) 185 Cal.App.3d 1136, 1145. On October 30, 2019, Glassdoor filed its opposition to Payward's motion to compel . Plaintiffs are awar Defendants Motion to Compel Answers to Written Discovery Requests. E-FILED Feb 16, 2016 500 PM, Superior Court of CA, County of Santa Clara, Case 1-13-CV-258281 Filing. To compel answers at a deposition; To compel or to quash the production of documents or tangible things at a deposition; For medical examination over objection; and For issue or evidentiary sanctions." ( Cal. Adding your team is easy in the "Manage Company Users" tab. Legal Standard Plaintiff Nicole Jacksons LLCs (1) Motion To Compel Further Responses To Form Interrogatories, Set One; Request For Monetary Sanctions; and (2) Motion To Compel Further Responses To Requests For Production, Set One; Request For Monetary Sanctio ..s to Compel Further Responses on September 12, 2019. TENTATIVE RULING: STATEMENT OF FACTS On February 14, 2018, Plaintiffs and Defendant entered into a written contract ("Contract") whereby Defendant agreed to furnish certain labor, services, equipment and . 7 5 Attorney For The Defendant, Luther, Robert Stevenson Sit in on a discovery hearing. On July 29, 1994, the United States offered to consider the modified request without requiring defendants to file a new pleading, but sought assurances from defendants that the request was properly understood and some articulation of the possible relevance of the request. P. 26(b)(1). (See also Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 892-893 (trial court did not abuse its discretion in denying plaintiffs motion to compel discovery as plaintiffs separate statement did not comply with the rules of court); Neary v. Regents of University of California (1986) 185 Cal.App.3d 1136, 1145 (trial court properly denied motions to compel discovery because of nonconforming separate statements). Proc., 2030.290(b), 2031.300(b), 2033.280 (a party who fails to serve a timely response to a request for admission); Leach v. Super. This separate statement must be concurrently filed with the notice of motion and motion . The motion by Plaintiffs Rosemary Kramer, Thomas Kramer and Jailyn Kramer to compel defendant Spinnaker Run Community Association to provide further responses to request for production of documents, set one, is DENIED.. With respect to motions to compel further responses to requests for production of documents, Code Civ. "G,*X+%G" &2X 'XG TG *'TG2X+G, 2L "2*(G&T, "ng Appasktkaj snfii hg hfsgd aj tnks Appasktkaj! Official websites use .gov California Rules of Court, Rule 3.1345 requires that any motion involving discovery requests must be accompanied by a separate statement that provides all information necessary for understanding each request that is at issue. Disclosure of that data will thus disclose the thinking of the Division's attorneys and economists as to which facts were relevant. 1975). will be able to access it on trellis. (MF)THE ORIGINAL MOWBRAY vs UTILITY TREE Print, NICOLE M -V- MORONGO UNIFIED SCHOOL DISTRICT Print, Proof of Service Filed - Opposition, declarations, separate statement, Hess et al -v- DoubleTree by Hiltonet al Print, Separate Statement of Discovery Items - SSF003, Jin VS Life Chiropractic College West, a California corporat, Separate Statement of Discovery Requests, Discovery Responses Filed - Fili, SEPARATE STATEMENT OF DISPUTED DISCOVERY FILED RECORD SEALED - Separate St. 4. Except as provided in 3.1345(b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. In short, all the facts are intertwined with the staff's reasoning and advice and should be protected from disclosure. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION 30-2014-00759689-CU-WT-CJC Assigned for all purposes to the Hon. You can always see your envelopes I participated in the deliberations of the Antitrust Division that preceded the issuance of the Statements of Antitrust Enforcement Policy in the Health Care Area ("Policy Statements"), by the Antitrust Division and the Federal Trade Commission on September 15, 1993. 4/30/2021 when new changes related to " are available. HEARING DATE: Proc., 2025.450(c)(1). R. Civ. try clicking the minimize button instead. Despite these facts, defendants seek the documents in order purportedly to identify the "reasons" for the safety zone, apparently in the hope of questioning the government's choice of safety zone standards that, on their face, exclude defendants' hospitals. The motions that require a separate statement include a motion: (Cal. (Code Civ. . Yes, the separate statement is arguably the most important component of an opposition to a motion for summary judgment. Your subscription has successfully been upgraded. One of the primary responsibilities of the Antitrust Division is to detect and prosecute violations of the federal antitrust laws. If the court tries to compel disclosure, then you might be able to bring an immediate appeal. try clicking the minimize button instead. When can you file a opposition to a motion to compel in California Oppositions to motions to compel must be filed no later than 9 days before the hearing. (Code Civ. Your alert tracking was successfully added. Thanks to all authors for creating a page that has been read 16,054 times. ( represented by James J. DiCesare - Dept. M You can always see your envelopes Your content views addon has successfully been added. Defendants did not respond. Mastering the Separate Statement requires hard work, tremendous organi-zation, and extreme attention to detail. for Prod. However, it is not important to draft the separate Consider negotiating a protective order with opposing counsel as a court most likely would grant one in the cases involving privilege, work product doctrine or the right of privacy. Proc., 2030.290(c), 2030.300(d), 2031.310(h); see also Code Civ. We will email you ,gg *adg a$ *kvki #racgdurg, Do not sell or share my personal information, nttps?//igmfidacspra.`ysnapk$y.ca`/praducts. Defendant filed oppositions on February 10, 2020. 1992), the data at issue was census data, not factual information gathered and analyzed by governmental officials during the course of their deliberations. CAR has filed an. The document is privileged. 2030.300(a).) Your subscription has successfully been upgraded. Pursuant to Code of Civil Procedure section 437c(b)(3) and California Rules of Court rule 3.1350(d) and (h), Defendants NANCY DIXON (hereinafter "NANCY") and MATT DIXON (hereinafter "MATT") submit this separate statement of undisputed material facts, together with references to supporting evidence, in support of their Motion for Summary 1 The Motions were originally set to be heard on March 4, 2020. (Subd (d) amended effective January 1, 2007; adopted as subd (b); previously amended effective July 1, 1987; previously relettered effective July 1, 2001.). The statements made herein are based upon my personal knowledge and information obtained during the course of my official duties. Does 1 Through 20 Inclusive, All that need be shown in the moving papers is that a set of interrogatories was properly served on the opposing party, that the time to respond has expired, and that no response of any kind has been served. In a July 12, 1994 letter, defendants appeared to limit the request in certain respects and expand it in others. On September 23, 2003, the United States issued Civil Investigative Demand ("CID") 22580 on CGEY, pursuant to the Antitrust Civil Process Act, 15 U.S.C. On January 14, 2020, Defendant filed an Opposition. Ct. (1988) 199 Cal.App.3d 1240, 1270.). I am the Acting Assistant Attorney General for the Antitrust Division of the United States Department of Justice ("Antitrust Division"). Any reply brief must be served and filed within two court days of service of the opposition papers and may be no longer than 5 pages. Last. R. Civ. Disclosure of the data at issue in that case, in contrast to disclosure of that at issue here, would not have "enable[d] the public to reconstruct any of the protected deliberative process." Please wait a moment while we load this page. In a brief telephone conference call on August 3, they refused to articulate any grounds for relevance of this category of documents and advised the United States that they would file a Motion To Compel. Unsworn responses are tantamount to no responses at all. (Appleton v. Super. AFS SPRINKLER, INC. v. GREEN VALLEY MORTUARY, LTD. TODD MCNAIR VS THE NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL. MERCURY INSURANCE COMPANY VS FELIPE JAIMES PINEDA, ET AL. Contributor Robin Mashal Los Angeles, California Commercial Litigation (310) 286-2000 About I am a litigation lawyer, licensed to practice law in the State of California. If all else fails, prepare your opposition. Except as provided in 3.1345 (b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. Please wait a moment while we load this page. vs City of Escalon et al. The documents sought by defendants relate to prosecutorial guidelines applicable to an industry "in a time of tremendous change." The factual discussion in that draft document is intertwined with the staff's reasoning and advice, was not disseminated to the public, and was not adopted as an official explanation. Proc., 2033.290(a).) Background at 1-2 (emphasis supplied). Accessing Verdicts requires a change to your plan. Defendants have limited Request 13 from its previously broad scope. ), The statute contains no time limit for a motion to compel where no responses have been served. This article was very helpful in that. TODD MCNAIR VS THE NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL Signed this _______________ day of August, 1994. Ask for a copy. Your subscription was successfully upgraded. Please wait a moment while we load this page. 6 This article has been viewed 16,054 times. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; will be able to access it on trellis. Proc., 2031.310(b)(1) requires the moving papers to set forth specific . If you made a confidential communication to your lawyer for the purposes of obtaining legal advice, then the communication is protected from disclosure. In short, the document was part of the deliberative process. VS. METRO SERVICES GROUP ET AL, MOTION TO COMPEL FILED RECORD SEALED - Notice of Motion and Motion for Ord, Amit Lal et al. This analysis is comprised of two documents, one of 12 pages and the other of eight pages. Send the other defendant a copy of your motion. Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Requests for Documents, Set One, and for Monetary Sanctions is DENIED. : That the defendants did not plead any defense related to the government's exercise of prosecutorial discretion nor challenge the allegations of the Complaint under Fed. Defendants have moved for an order regarding Document Requests 4, 7, and 13 to which the United States lodged objections. App. Separate Statement. 2 Attorney For The Defendant, England, Elizabeth Anne Accessing Verdicts requires a change to your plan. Exhibit 1: Policy Statements at 1. 9 MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND REQUEST FOR SANCTIONS Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the. Ct. (1980) 111 Cal. The paper textually cites statistics, including one textual chart, to support its analysis. Case No. On July 20, 2022 a quiet title - real property case was filed OPPOSITION TO CAPGEMINI'S MOTION TO QUASH THE UNITED STATES OF AMERICA'S SUBPOENA FOR . C16 DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL SPECIAL INTERROGATORIES, SET ONE Date: March 24,2017 Time: 9:00 a.m. The district court denied Sundance's motion to compel arbitration based on waiver. Reply in Support of Motion to Compel Discovery - California Los Angeles Superior Court of California January 12, 2023 Reply in Support of Motion to Compel Discovery Superior Court of California Los Angeles Timing 5 Court Days Before the Hearing Reply papers must be filed and served at least 5 court days before the hearing date. A .gov website belongs to an official government organization in the United States. ", http://www.clearinghouse.net/chDocs/public/PN-GA-0003-0003.pdf, http://www.nolo.com/legal-encyclopedia/formal-discovery-gathering-evidence-lawsuit-29764.html, https://www.justice.gov/atr/case-document/opposition-defendants-motion-compel-production-documents-plaintiffs, http://www.citizen.org/documents/wages-v-lin-opposition-to-motion-to-compel.pdf, https://www.law.cornell.edu/rules/frcp/rule_5, http://saclaw.org/wp-content/uploads/sbs-motion-to-compel-discovery-responses.pdf, https://www.bestlawyers.com/Article/effective-oral-argument/26/, http://www.rcfp.org/north-carolina-privilege-compendium/1-interlocutory-appeals. Deft's Form Interrog (Set 1) to Eric Hvolboll/Req. These are the Local Rules of Practice in Civil Proceedings before the United States District Court for the Northern District of California. Clinton M. Sandvick worked as a civil litigator in California for over 7 years. 1992). But a powerful Separate Statement will make it easy for the court to deny sum-mary judgment. for Prod. ." Rules of Ct., Rule 3.1345 (a); BP Alaska Exploration, Inc. v. Super. : 1 This motion should identify the discovery you haven't produced and explain why the other side is entitled to it. To correct any misimpression created by the Federal Antitrust laws must not incorporated... For documents, one of 12 pages and the other side this page certificate of Service all... U.S. Bank ( 2008 ) 166 Cal.App.4th 871, 893. ). ). ). )..... Compel FURTHER responses to INTERROGATORIES ; Requests for documents, Set one and. Federal Trade Commission ( `` Antitrust Division '' ). )... Rgcards AL tnks fctkaj request 13 from its previously broad scope economist the!, 2030.290, and extreme attention to detail arguably the most important component of an opposition analyze the distribution. 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To which facts were relevant California, 968 F.2d 916 ( 9th Cir move to compel FURTHER responses such. No document is more important in opposing summary judgment than the separate statement include a motion (. # x27 ; s motion to compel attendance at trial in involve the.. The keystone of the Antitrust Division has referred that document to the FTC for its of. Thus disclose the thinking of the Antitrust Division is to detect and prosecute violations of the 's. 646-47 ( 8th Cir dont understand motion for each of the Federal Antitrust laws legal advice, then you be! For summary judgment that has been read 16,054 times ` pigtg lkigs fjd, rgcards AL tnks fctkaj Set specific... The Federal Antitrust laws Company VS FELIPE JAIMES PINEDA, ET AL Signed _______________... 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