california discovery verification requirements

App. Plaintiff, POINTS AND AUTHORITIES IN SUPPORT 2023 California Rules of Court. You already receive all suggested Justia Opinion Summary Newsletters. Proc., 446, 2015.5) by Party CASE TITLE I, (Name), declare: am thein the above-entitled matter. (Ruiz v. Moss Brothers Auto Group (2014) 2014 WL 7335221.) provides specific remedies for evasive or incomplete discovery responses. 2022, Stimmel, Stimmel & Roeser, All rights reserved| Terms of Use | Site by Bay Design, Electronic Signatures and their Requirements in California-the latest case. of a party, unless the parties are absent from the county where the attorney has his Assuming plaintiff meant section 446, the applicability of section 446 to section 2033, as previously noted, was uncertain prior to 1986. A Motion to Compel Discovery Responses in California under CCP 2030.300 is a legal action taken when a party fails to serve timely responses to discovery requests, such as interrogatories or requests for production. P. 26(b)(1). App. ), [3a, 4] Section 473 is liberally construed because the law strongly favors trial and disposition on the merits. CGC-05-444887 . 3d 1095, 1099 [199 Cal. fn. These requirements are consistent across Facebook and Instagram. | Finally, Defendant's counsel explains it had not received the discovery requests and it searched its files, to no avail, after Plaintiff sent a meet and confer communication. Rptr. The parties acknowledge that they have reviewed and shall reference the Court's Checklist for Conference of Counsel Regarding ESI during any Rule 26 conference and when seeking to resolve discovery disputes about ESI during (See 6 Witkin, Cal. California's Compulsory Financial Responsibility Law 1656.2 VC; WIC 366.26; California Family Code Parental Alienation 3040; California ID Law; CCP 2033.250; Penal Code1185 Police Code; California Discovery Verification Requirements; PC 591.5; BP 25658 A; Government Code 12935; Civ Code 3480 Civil Code; PC 636; 24002 CVC; Child Name Change . Furthermore, an award of any such sanctions is in the Courts discretion. A party or other person is not required to use a digital signature on an electronically filed document. The language of Defendants verifications sufficiently complies with the requirements of Code of Civil Procedure Section 2030.250. h (d)If a law requires a signature, an electronic signature satisfies the law. The trial court agreed with plaintiffs that the defendants signature must be accorded legal effect under Civil Code section 1633.7. You are attesting that you mailED, mailED, mailED the document. Attorney for Plaintiff BY:VANESSA WU Attorney for Plaintiff Beavers peony eek Recently I was readingAaron Morris article Dont be that AttorneyTen Ways to Make Yourself Look Foolish, a humorousarticle that many of us lawyers always wanted to write about the outlandish positions attorneys take. Code, 1633.7(a), (d), 2030.250), an "electronic signature" is only attributable to a person if it was "the act of the person." (Civ. Although the court in Steele v. Totah, supra, found Chodos did not support the proposition that section 446 applies to requests for admissions, prior to Steele, an attorney reasonably could have interpreted Chodos to support such a proposition. App. 4 In fact, Chodos v. Superior Court (1963) 215 Cal. Even the authorities cited by plaintiff, in opposition to defendants' motion for relief, did not affirmatively establish that propounded parties are the only persons who can verify responses to request for admissions. (b) This section shall become operative on January 1, 1999, unless a statute that becomes effective on or . FN 4. 2031.280 (a). The requirements for electronic signatures that are compliant with the rule do not impair the power of the courts to resolve disputes about the validity of a signature. 6.1 was not verified under oath, which is a violation of Code of Civil Procedure section 2030.250, subdivision (a). 620.) Under CCP section 2030.250, "[t]he attorney for the responding party shall sign any responses that contain an objection." An honest mistake of law is a valid ground for relief where a problem is complex and debatable. You already receive all suggested Justia Opinion Summary Newsletters. county thereof, city, school district, district, public agency, or public corporation, 3d 227, 233 [184 Cal. The electronic filer must maintain the original, signed document and must make it available for inspection and copying as provided in (b)(2) of this rule and Code of Civil Procedure section 1010.6. 3d 333] [10] One seeking relief under section 473 must also attach to his moving papers his proposed responses to the request for admissions. Law Offices of Harris & Zide ELECTRONICALLY [Fn. A summary judgment is proper only if there is no triable issue of fact and, as a matter of law, the moving party is entitled to judgment. believes it to be true; and where a pleading is verified, it shall be by the affidavit App. App. Interrogatories;. 3d 227, 232 [211 Cal. This motion was successfully opposed by defendants' attorney on the grounds that the warning required by Code of Civil Procedure fn. 328-329.) . [9] While a mistake in law may warrant relief from default, there are certain procedural requirements that must be satisfied. Procedure, supra, Proceedings Without Trial, 25, 26, pp. (See 8 Witkin, supra, 150, p. 446 AND 2015.5) STATE OF CALIFORNIA, COUNTY OF ORANGE I have read the foregoing_____ _____and know its contents. The insured employee's failure to respond to discovery or to provide certifications regarding discovery responses that the defense attorney has submitted can result in sanctions. We noticed that you're using an AdBlocker. The court may impose a terminating sanction by one of the following orders: (1) An order striking out the pleadings or parts of the pleadings of any party engaging in the misuse of the discovery process. Rptr. The Civil Discovery Act ( 2016.010 et seq.) March 17, 1987. App. importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.". Proc., 2023.030. A party may not seek discovery from any source before the parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B), or when authorized by these rules, by stipulation, or by court order. 1445 Huntington Drive, Suite 300 We therefore conclude that the 473 motion should have been granted and the motion for summary judgment denied. Every court document you send to opposing counsel should have an UNSIGNED!! Sarkis S. Karayan, State Bar #316926 Sav. App. VS. GENARO R VAVURIS ET AL, POINTS AND AUTHORITIES ISO MOTION FOR JUDEMENT TO DEEM REQUESTS FOR ADMISS, JHPDE FINANCE 1, LLC VS. HA T JOHNSON ET AL. Accessing Verdicts requires a change to your plan. The California Discovery Act is unequivocal regarding a party's burden to make a reasonable and good faith effort to obtain the information and documents sought in Plaintiff's discovery requests, and to furnish complete and responsive discovery responses. Using discovery to reach evaluation, mediation and trial goals. [1] In reviewing a summary judgment, the appellate court is limited to the facts shown in the affidavits and those admitted and uncontested in the pleadings. (A & S Air Conditioning v. John J. Moore Co. (1960) 184 Cal. The section permits the party to 'deny only a part or a qualification of a matter of which an admission is requested.' Verification Form. Yes, I get how it works in the real world and why 90 percent of attorneys do it wrong. must each be complied with before an electronic signature can be accorded legal effect, and (2) one of those indispensable elements specified by the UETA is that all parties to the transaction agree to conduct the transaction by electronic means (Civ. But that is not proper service. (Subd (a) adopted effective January 1, 2019. 1 For the reasons that follow, we shall reverse with directions. However, since there was uncertainty in the law regarding who may verify responses to request for admissions, we find that defendants' attorney did adequately comply with the attachment requirement. Rule 2.257 amended effective January 1, 2020; adopted as rule 2057 effective January 1, 2003; previously amended and renumbered effective January 1, 2007; previously amended effective January 1, 2008, July 1, 2016, January 1, 2018, and January 1, 2019. If you sign the proof of service before you mail the document, you are perjuring yourself. 1986) Discovery and Production of Evidence, Request for Admissions, 1553, pp. However, that section dealt only with interrogatories and provided in part that "[a]nswers to interrogatories are not within the purview of CCP Section 446 and may not be verified by counsel when the client is out of the county." Pantzalas v. Sup. school district, district, public agency, or public corporation, in his or her official hb```NaB `."Ig&*R^b") HI/`n`i l 8Ma`x|Hs1*e.]"]l-Yg@@lFpw10J~b0 >0Q This power stems from the sections themselves and is not dependent upon the general authority of a trial court to relieve a person from default pursuant to section 473. You will lose the information in your envelope, UNITED EDUCATION INSTITUTE VS RYAN & DANIELS LLC, GARCIA V. ORANGE COUNTY TRANSPORTATION AUTHORITY, KIMBALL SKEET WILSON VS. AC AND S, INC. AMERICAN ASBESTOS, MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO COMPEL FURTHER RESPO, ADAM O'NEILL ET AL VS. PIERRE BERTERRETCHE ET AL, SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPE, MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO DEEM REQUEST , PALISADES COLLECTION,L.L.C. Rptr. Rptr. Flint C. Zide, State Bar #160369 (See United States v. Taylor (W.D.La. App. 416, 695 P.2d 713].) The demand must be served on all other parties but need not be filed with the court. Under section 446, the verification may be by the party's attorney or any other person when (1) the parties are absent from the county where the attorney has his office; (2) the parties are from some cause unable to verify; or (3) the facts are within the knowledge of the attorney or other person. (id, at p. 322; italics added.) Cheong & Denove and Mary M. Bennett for Defendants and Appellants. Better yet, here is the official proof of service by the Judicial Council, with instructions on how to serve someone, specifically stating in item 3b that the proof of service sent to the other side must be unsigned. When I was a research attorney for Alameda County Superior Court, myjudge drilled into me to always check the proof of service to make sure that it wassigned and service on all parties had properly been made. 647 0 obj <>stream However, CCP section 2030.290 does not require substantial compliance with CCP section 2030.250 as a prerequisite to granting relief from waiver. App. will be included in the production."] 2 "A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and . You can explore additional available newsletters here. First, the Court determined that the trial courts record failed to disclose that all parties (i.e., litigants) to the action had executed the settlement agreement, rendering the purported settlement agreement unenforceable under Code of Civil Procedure section 664.6, pursuant to established case law, such as Levy v. Superior Court (1995) 10 Cal.4th 578, 584, 586; and Harris v. Rudin, Richman & Appel (1999) 74 Cal.App.4th 299, 305. ), on which section 2033 is based, federal courts have allowed verifications by persons other than the party to whom the request was directed. Rptr. Rptr. Civ. When a corporation is a party, the verification may be made by any officer thereof. RMR RD ee a a When the pleading is verified by the attorney, or any other person except one of [6b] In the instant case, defendants' attorney verified responses on behalf of two defendants who were unable to sign since they were out of the county where defendants' attorney has his office. [7] Where there are several parties, verification by one is sufficient. (C) At any time after the electronic version of the document is filed, the court may order the filing party or other person to produce the original signed document in court for inspection and copying by the court. local rules - central district of california 6/1/2020 chapter i - i . Operative July 1, 2005, by Sec. Ambiguity In Contracts-What Do The Courts Do? [6d] In the instant case, defendants' attorney did attach responses to his motion for relief under section 473. 340].) KFC 1020 .D44 Electronic Access: On the Law Library's computers, using . However, the 30-day period may be extended for 5 days, under section 1013a, where service of the deemed admitted notice is by mail. Copied to clipboard TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. But in reviewing the record, the Court found no substantial evidence in the record to support the trial courts judgment. G CHECK APPLICABLE PARAGRAPHS G I am a party to this action. will be able to access it on trellis. To the contrary, the authorities cited do not even address the issue of who is required to verify responses. fn. Investment Partners, Ltd. v. Fair (2014) 232 Cal.App.4th 974, (First District Court of Appeal) by unanimous verdict: (1) the requirements of the Uniform Electronic Transactions Act (UETA), Civil Code section 1633.1 et seq. ;qQZX3nhBnqAE|\\|HX*`+dm \*DQ$yH',!0Qe-ip63|3fCMXU2mtfj_#8fz5t 8~WmV +Fb.,VQU71ZB 5Tm;=rVHr;XnmCV3unhzx]#b3aqfXm`u53?``G`;jK* 5uO]ddw d]M}.Ao{IRU`wU{p;pAg1! Format of discovery motions (a) Separate statement required . The separate statement must include-for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested-the following: (1) The text of the request, interrogatory, question, or inspection demand; (2) The text of each response, answer, or objection, and any further responses or answers; (3) A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute; (4) If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it; (5) If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and. (14 Grossman & Van Alstyne, Cal. glendale dmv driving test route selects academy at bishop kearney tuition california discovery verification form; 29. There is no proportionality requirement in state discovery. He can answer stating that he has been 'informed and believes' either the truth or falsity of the request and may verify his response in the traditional form of verification of such allegations." CIVIL DISCOVERY ACT [2016.010 - 2036.050] . Faesimile: (415) 673-6030 Clerk of the Court VS48 5Qe~ zhFMjT4M(QM4!M4q&> .O=j. I am informed and believe and on that ground allege that the matters stated in the foregoing document are true. that the same is true of his own knowledge, except as to the matters which are therein 9 I declare under the penalty of perjury under the laws of the United States that th 1 o foregoing is true and correct. A: Yes. Contact us. have read the foregoing(pleading, e.g., complaint) and know the contents thereof. Here, Plaintiff challenges the electronic signatures on verifications served 09/06/2019, 10/31/2019, and 12/16/2019. 807].). Find helpful legal articles & summaries on key areas of the law! Standing Order on Discovery Disputes, the Federal Rules of Civil Procedure, and the Local Rules of this Court. CCP 2016.060 : b) Hearing deadlines: Count backward from the hearing date, excluding the date of the hearing. Once the notice is served, the party upon whom the notice is served shall not have the right to apply for relief under the provisions of Section 473 unless a motion requesting relief is served and filed within 30 days after service of the notice.". 639 0 obj <>/Filter/FlateDecode/ID[<41B89BCA2A2F3B4081B12DF4C2F80C87><7CBAD2FCBBF43C4CB5FE4D4C8C7BD53D>]/Index[626 22]/Info 625 0 R/Length 72/Prev 72497/Root 627 0 R/Size 648/Type/XRef/W[1 2 1]>>stream Wheres the Authority to Award Sanctions? Why You Need to Bring that Motion To Compel Further Responses to Interrogatories, Its a New Year and there are New Discovery Laws. verification. An electronic signature is an electronic sound, symbol, or process attached to or logically associated with an electronic record and executed or adopted by a person with the intent to sign a document or record created, generated, sent, communicated, received, or stored by electronic means. The response need merely be signed by the responding party or his attorney. when new changes related to "" are available. COUNTY OF SAN FRANCISCO, SAN FRANCISCO COURTHOUSE 12.01-80. Rptr. On this page you will find frequently asked questions and answers for Civil law related matters. COUNTY OF SAN FRANCISCO, SAN FRANCISCO COURTHOUSE Defendants claim that the trial court abused its discretion in denying their motion for relief from default in responding to the request for admissions. The imposition of an evidence sanction is not one of the remedies. agency, or public corporation, in his or her official capacity, is defendant. 551.) thereof, city, school district, district, public agency, or public corporation, or Attached to the motion and supplemental declarations were properly verified responses of all defendants to the second set of request for admissions. Requirements for signatures on documents (a) Electronic signature An electronic signature is an electronic sound, symbol, or process attached to or logically associated with an electronic record and executed or adopted by a person with the intent to sign a document or record created, generated, sent, communicated, received, or stored by electronic means. 617, 7 Cal. A motion concerning interrogatories, inspection demands, or admission requests must identify the interrogatories, demands, or requests by set and number. In. After Rule 26 Meeting. Neither section, however, makes any mention of any specific form of verification to be employed. h204S0P004W01Ww/+QL)()!vvp0FPp)3bR@bQ*P! A(& ?&O App. When a document to be filed electronically provides for a signature under penalty of perjury of any person, the document is deemed to have been signed by that person if filed electronically provided that either of the following conditions is satisfied: (1) The declarant has signed the document using an electronic signature and declares under penalty of perjury under the laws of the state of California that the information submitted is true and correct. or public corporation, in his or her official capacity is defendant, its or his or Defendants' attorney filed his motion for relief on November 27, 1984, which was within the extended 35-day period. Stay up-to-date with how the law affects your life. (2) When a document to be filed electronically, such as a stipulation, requires the signatures of opposing parties or persons other than the filer not under penalty of perjury, the following procedures apply: (A) The opposing party or other person has signed a printed form of the document before, or on the same day as, the date of filing. Furthermore, an award of any such sanctions is in the Courts discretion. Corp. (1976) 55 Cal. Defendants appeal from a summary judgment that was primarily based upon matters deemed admitted arising from an improper response to plaintiff's request for admissions. ROBERT BROCHTRUP, Plaintiff and Respondent, v. INTEP et al., Defendants and Appellants. Parties often fail to do so, however, and choose instead to serve discovery that is inconsistent with the requirements of California's Civil Discovery Act (the "CDA"), Cal. 44-45.). A new change to California's Civil Discovery Act has all of the trappings of a burdensome and costly requirement for employer defendants litigating in California state court. The matters stated in the foregoing document are true of my own knowledge, except as to those In the instant case, the trial court's determination that there was no triable issue of fact was based primarily on matters deemed admitted against defendants because of their failure to properly respond to the second set of requests for admissions of plaintiff. local civil rules PALISADES COLLECTION, LLC, Case No. Endnote. Or, I dont know, how about if we just check the Code of Civil Procedure that sets forth the rules for service. Ct. (2003) 112 CA4th 285. While such an agreement can be proven by the context and conduct of the parties under Civil Code section 1633.5, subdivision (b), there would seem to be no guaranteed method of establishing that requirement absent a clear and unequivocal provision in the document itself which provides that the parties intend to use and rely upon electronic signatures. Appellate Court Decision-No Binding Agreement: Reasoning: Consistent with established case law, the Court of Appeal reviewed the trial courts findings under the substantial evidence standard of review, resolving all evidentiary conflicts and drawing all reasonable inferences in support of the trial courts finding of an enforceable settlement, consistent with the policy favoring settlements. 3d 679, 682 [222 Cal. Key Lesson: As the law now stands in California, electronic signatures will not be accorded legal effect, unless all the parties have agreed to conduct the transaction electronically. (2) When a court has allowed the moving party to submit-in place of a separate statement-a concise outline of the discovery request and each response in dispute. 2131 Lombard Street Superfor Court of Caiffornia, chapter i . In all cases of a verification of a pleading, the affidavit of the party shall state It states that, if a document is not signed under penalty of perjury then it is considered signed when eFiled. This . https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-446/, Read this complete California Code, Code of Civil Procedure - CCP 446 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', SCOTUS to Decide Constitutionality of Consumer Financial Protection Bureau. california discovery verification form california discovery verification form. (Weitz v. Yankosky (1966) 63 Cal. Effective January 1, 2005. Binding Contracts and Legal Actions Predicated on Breach of Contract, Getting the Deal That Hurts You - The Conflict Between the Lawyer and the Sales Department in Commercial Contracts, Mutuality of Obligation-A Contractual Requirement-Sort Of. (D) Notwithstanding (A)-(C), local child support agencies may maintain original, signed pleadings by way of an electronic copy in the statewide automated child support system and must maintain them only for the period of time stated in Government Code section 68152(a). The secretary prepares and signs the proof of service, makes copies, and then puts the original in the attorney service basket, mails a copy to opposing counsel, and keeps one copy for the file. Plaintiff, POINTS AND AUTHORITIES IN SUPPORT Deputy Clerk 582.) Following the entry of judgment, the trial court denied the plaintiffs motion for attorney fees, finding that no agreement existed between the parties, providing for such recovery in litigation. After finally being notified by their attorney in May 1985, that no further representation would be taken, defendants substituted present attorneys on June 28, 1985. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or the information linked to on the state site. v. Long (1959) 175 Cal. South Pasadena, CA 91030 Pecan: Sate ae Ca erpia: When Do I Have to Bring a Motion to Compel Written Discovery? 1016; Van Horne v. Hines (D.D.C. Under the FDCPA, when a debt collector first contacts you on a debt, it is required by law to notify you of your right to dispute the debt and require "validation" or "verification.". An order denying a motion to vacate a default may be reviewed on appeal from a judgment. endstream endobj 627 0 obj <. But that is not proper service. Clerk of the Court (Opinion by Thompson, J., with Lillie, P. J., and Johnson, J., concurring.). true and correct. (Ibid; also see 3 DeMeo & DeMeo, Cal. After the deemed admitted notice is served, the nonresponsive party has 30 days to make a motion for relief from default under section 473. (1) If a document does not require a signature under penalty of perjury, the document is deemed signed by person who filed it electronically. requirements. LAW OFFICES OF JAMES COY DRISCOLL FILED Your recipients will receive an email with this envelope shortly and or public corporation, or any officer of the state, or of any county thereof, city, 583].) When referred to either a Local Rule or California Rules of Court, click on the buttons below to access either: Local Rule. Each party is to bear his own costs on appeal. There, the court noted the failure of the Legislature in amending section 2033 to expressly deal with the requirement of section 473 that the party seeking relief submit a copy of the proposed pleading. Non-Party Discovery In California Non-party discovery is an effective tool when used properly. 303], the only case prior to 1986 to specifically deal with the verification issue, supports the view that an attorney verification may suffice. Finally, plaintiff cited former section 251B of the Discovery Policy Manual of the Los Angeles Superior Court as part of his opposition to the defendants' motion for relief from default in failing to properly respond to the request for admissions. 3d 327] Ramirez had been given a power of attorney by the remaining defendants to sign court documents. Civ. Code 2016.010-2036.050. [6c] Thus, we can safely say that at the time defendants' motion for relief was heard and decided, the law on who may verify responses under section 2033 was unsettled. The two words are used interchangeably, and the requirement is quite simple in general: First, the debt collector must notify you of the right to dispute . FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. 1985) Attack on Judgment in Trial Court, 180, p. (Code Civ. 2030.250(b), 2031.250(b), 2033.240(b). The defendant who received the e-mail responded several times, indicating his agreement to the settlement terms. Please wait a moment while we load this page. The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. (626)799-8444 02/07/2019 |BANK OF AMERICA, N. __._ Case No. Brumfield, Lorna H. ), Additionally, in considering rule 36 of the Federal Rules of Civil Procedure (28 U.S.C. fn. Specifically, the Court held absent any evidence establishing the fundamental requirement of Civil Code section 1633.5, subdivision (b)that is, an agreement of the parties to conduct the transaction by electronic means. of the complaint might subject the party to a criminal prosecution, or, unless a county Robert D. Coviello for Plaintiff and Respondent. Flint C. Zide, State Bar #160369 After being notified by plaintiff's attorney on October 24, 1984, that the verifications were improper and that the requests for admissions were thereby deemed admitted, defendants' attorney on November 27, 1984, filed a motion for relief from default under section 473. We have notified your account executive who will contact you shortly. endstream endobj 2322 0 obj <>stream 2 section 2033 had not been appropriately placed with the request for admissions. (b)A contract may not be denied legal effect or enforceability solely because an electronic record was used in its formation. Rule 3.1345. HiTech Auto Collision Painting Servs., Inc., E029854, 2001 WL 1239716 (Cal. (Ibid) However, the court further held that since the issue was of first impression, a party could reasonably have failed to anticipate this construction of the statutes and should not be penalized for failure to submit responses in that case. becomes effective on or before this date extends or deletes the repeal date of Section 446, as amended by Assembly Bill 3594 of the 1993-94 Regular Session.

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