Terry Green, et al vs Creditor Iustus Et Remedium

Filing 25

STIPULATED PROTECTIVE ORDER, signed by Magistrate Judge Jennifer L. Thurston on 3/17/2014. (Hall, S)

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1 2 3 4 5 6 7 Tara Muren, Esq.SBN 260154 Deanna Fraser, Esq. SBN 270362 Mark Bennett, Esq. SBN 113731 CREDITOR IUSTUS ET REMEDIUM, LLP 8665 Gibbs Drive, Ste 150, San Diego, CA 92123 Mailing: PO Box 23189, San Diego, CA 92193-3189 Tel: (858) 496-8909 Fax: (858) 496-5977 Attorney for Defendant CREDITOR IUSTUS ET REMEDIUM, LLP d/b/a CIR, LAW OFFICES, LLP 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 12 TERRY GREEN and CHARLES WITCHER, 13 Plaintiffs, 14 vs. 15 16 17 CREDITOR IUSTUS ET REMEDIUM, LLP d/b/a CIR, LAW OFFICES, LLP, 18 Defendant. ) CASE NO.: 1:13-cv-01414-LJO-JLT ) ) ) ) STIPULATED PROTECTIVE ORDER ) ) ) ) ) ) ) ) ) ) 19 20 21 1. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production of 22 confidential, proprietary, or private information for which special protection from public 23 24 disclosure and from use for any purpose other than prosecuting this litigation may be warranted. 25 Accordingly, the parties hereby stipulate to and petition the court to enter the following 26 Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket 27 protections on all disclosures or responses to discovery and that the protection it affords from 28 1 STIPULATED PROTECTIVE ORDER 1 public disclosure and use extends only to the limited information or items that are entitled to 2 confidential treatment under the applicable legal principles. The parties further acknowledge, as 3 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file 4 confidential information under seal; Local Rule 141 sets forth the procedures that must be 5 followed and the standards that will be applied when a party seeks permission from the court to 6 7 file material under seal. 8 2. DEFINITIONS 9 2.1 Challenging Party: a Party or Non-Party that challenges the designation of 10 information or items under this Order. 11 12 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is 13 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule 14 of Civil Procedure 26(c). 15 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as 16 well as their support staff). 17 18 19 20 21 2.4 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, 22 testimony, transcripts, and tangible things), that are produced or generated in disclosures or 23 24 25 26 27 responses to discovery in this matter. 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action. 28 2 STIPULATED PROTECTIVE ORDER 2.7 1 2 Counsel does not include Outside Counsel of Record or any other outside counsel. 3 4 House Counsel: attorneys who are employees of a party to this action. House 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 5 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this 6 7 action but are retained to represent or advise a party to this action and have appeared in this 8 action on behalf of that party or are affiliated with a law firm which has appeared on behalf of 9 that party. 10 2.10 Party: any party to this action, including all of its officers, directors, employees, 11 12 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 2.11 13 14 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 15 2.12 Professional Vendors: persons or entities that provide litigation support services 16 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and 17 18 19 organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors. 20 21 2.13 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 22 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 23 24 Producing Party. 25 /// 26 /// 27 /// 28 3 STIPULATED PROTECTIVE ORDER 3. 1 The protections conferred by this Stipulation and Order cover not only Protected Material 2 3 4 SCOPE (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 5 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 6 7 However, the protections conferred by this Stipulation and Order do not cover the following 8 information: (a) any information that is in the public domain at the time of disclosure to a 9 Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as 10 a result of publication not involving a violation of this Order, including becoming part of the 11 12 public record through trial or otherwise; and (b) any information known to the Receiving Party 13 prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who 14 obtained the information lawfully and under no obligation of confidentiality to the Designating 15 Party. Any use of Protected Material at trial shall be governed by a separate agreement or order. 16 4. DURATION 17 Even after final disposition of this litigation, the confidentiality obligations imposed by 18 19 this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court 20 order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all 21 claims and defenses in this action, with or without prejudice; and (2) final judgment herein after 22 the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this 23 24 action, including the time limits for filing any motions or applications for extension of time 25 pursuant to applicable law. 26 /// 27 /// 28 4 STIPULATED PROTECTIVE ORDER 5. 2 3 4 DESIGNATING PROTECTED MATERIAL 5.1 1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-Party that designates information or items for protection under this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. 5 The Designating Party must designate for protection only those parts of material, documents, 6 7 items, or oral or written communications that qualify – so that other portions of the material, 8 documents, items, or communications for which protection is not warranted are not swept 9 unjustifiably within the ambit of this Order. 10 Mass, indiscriminate, or routinized designations are prohibited. Designations that are 11 12 shown to be clearly unjustified or that have been made for an improper purpose (e.g., to 13 unnecessarily encumber or retard the case development process or to impose unnecessary 14 expenses and burdens on other parties) expose the Designating Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it designated for 16 protection do not qualify for protection, that Designating Party must promptly notify all other 17 18 Parties that it is withdrawing the mistaken designation. 5.2 19 20 21 Manner and Timing of Designations. Except as otherwise provided in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 22 designated before the material is disclosed or produced. 23 24 Designation in conformity with this Order requires: 25 /// 26 /// 27 /// 28 5 STIPULATED PROTECTIVE ORDER 1 (a) for information in documentary form (e.g., paper or electronic documents, but 2 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing 3 Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only 4 a portion or portions of the material on a page qualifies for protection, the Producing Party also 5 must clearly identify the protected portion(s) (e.g., by making appropriate markings in the 6 7 8 9 10 margins). A Party or Non-Party that makes original documents or materials available for inspection need not designate them for protection until after the inspecting Party has indicated which material it would like copied and produced. During the inspection and before the designation, all 11 12 of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the 13 inspecting Party has identified the documents it wants copied and produced, the Producing Party 14 must determine which documents, or portions thereof, qualify for protection under this Order. 15 16 Then, before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page that contains Protected Material. If only a portion or 17 18 19 20 21 portions of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). (b) for testimony given in deposition or in other pretrial or trial proceedings, that the Designating Party identify on the record, before the close of the deposition, hearing, or other 22 proceeding, all protected testimony. 23 24 (c) for information produced in some form other than documentary and for any other 25 tangible items, that the Producing Party affix in a prominent place on the exterior of the 26 container or containers in which the information or item is stored the legend 27 28 6 STIPULATED PROTECTIVE ORDER 1 2 3 4 “CONFIDENTIAL.” If only a portion or portions of the information or item warrant protection, the Producing Party, to the extent practicable, shall identify the protected portion(s). 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate qualified information or items does not, standing alone, waive the Designating Party’s 5 right to secure protection under this Order for such material. Upon timely correction of a 6 7 8 9 10 designation, the Receiving Party must make reasonable efforts to assure that the material is treated in accordance with the provisions of this Order. 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 11 12 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 13 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic 14 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to 15 challenge a confidentiality designation by electing not to mount a challenge promptly after the 16 original designation is disclosed. 17 18 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 19 process by providing written notice of each designation it is challenging and describing the basis 20 for each challenge. To avoid ambiguity as to whether a challenge has been made, the written 21 notice must recite that the challenge to confidentiality is being made in accordance with this 22 specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in 23 24 good faith and must begin the process by conferring directly (in voice to voice dialogue; other 25 forms of communication are not sufficient) within 14 days of the date of service of notice. In 26 conferring, the Challenging Party must explain the basis for its belief that the confidentiality 27 designation was not proper and must give the Designating Party an opportunity to review the 28 7 STIPULATED PROTECTIVE ORDER 1 designated material, to reconsider the circumstances, and, if no change in designation is offered, 2 to explain the basis for the chosen designation. A Challenging Party may proceed to the next 3 stage of the challenge process only if it has engaged in this meet and confer process first or 4 establishes that the Designating Party is unwilling to participate in the meet and confer process in 5 a timely manner. 6 7 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 8 intervention, the Designating Party shall file and serve a motion to retain confidentiality under 9 Local Rules of this Court 7 within 21 days of the initial notice of challenge or within 14 days of 10 the parties agreeing that the meet and confer process will not resolve their dispute, whichever is 11 12 earlier. Each such motion must be accompanied by a competent declaration affirming that the 13 movant has complied with the meet and confer requirements imposed in the preceding 14 paragraph. Failure by the Designating Party to make such a motion including the required 15 declaration within 21 days (or 14 days, if applicable) shall automatically waive the 16 confidentiality designation for each challenged designation. In addition, the Challenging Party 17 18 may file a motion challenging a confidentiality designation at any time if there is good cause for 19 doing so, including a challenge to the designation of a deposition transcript or any portions 20 thereof. Any motion brought pursuant to this provision must be accompanied by a competent 21 declaration affirming that the movant has complied with the meet and confer requirements 22 imposed by the preceding paragraph. 23 24 The burden of persuasion in any such challenge proceeding shall be on the Designating 25 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 26 unnecessary expenses and burdens on other parties) may expose the Challenging Party to 27 sanctions. Unless the Designating Party has waived the confidentiality designation by failing to 28 8 STIPULATED PROTECTIVE ORDER 1 file a motion to retain confidentiality as described above, all parties shall continue to afford the 2 material in question the level of protection to which it is entitled under the Producing Party’s 3 designation until the court rules on the challenge. 4 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed 5 6 7 or produced by another Party or by a Non-Party in connection with this case only for 8 prosecuting, defending, or attempting to settle this litigation. Such Protected Material may be 9 disclosed only to the categories of persons and under the conditions described in this Order. 10 When the litigation has been terminated, a Receiving Party must comply with the provisions of 11 12 section 13 below (FINAL DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at a location and 14 in a secure manner that ensures that access is limited to the persons authorized under this Order. 15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 16 ordered by the court or permitted in writing by the Designating Party, a Receiving Party may 17 18 19 disclose any information or item designated “CONFIDENTIAL” only to: (a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees 20 of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information 21 for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that 22 is attached hereto as Exhibit A; 23 24 (b) the officers, directors, and employees (including House Counsel) of the Receiving 25 Party to whom disclosure is reasonably necessary for this litigation and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 28 9 STIPULATED PROTECTIVE ORDER 1 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 2 reasonably necessary for this litigation and who have signed the “Acknowledgment and 3 Agreement to Be Bound” (Exhibit A); 4 (d) the court and its personnel; 5 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, and 6 7 8 9 10 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 11 12 A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of 13 transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be 14 separately bound by the court reporter and may not be disclosed to anyone except as permitted 15 under this Stipulated Protective Order; 16 (g) the author or recipient of a document containing the information or a custodian or 17 18 other person who otherwise possessed or knew the information; 19 (h) the Parties; and 20 (i) the jury. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 22 OTHER LITIGATION 23 24 If a Party is served with a subpoena or a court order issued in other litigation that compels 25 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that 26 Party must: 27 28 10 STIPULATED PROTECTIVE ORDER (a) promptly notify in writing the Designating Party. Such notification shall include a 1 2 copy of the subpoena or court order; 3 4 (b) promptly notify in writing the party who caused the subpoena or order to issue in the other litigation that some or all of the material covered by the subpoena or order is subject to this 5 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 6 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 7 8 Designating Party whose Protected Material may be affected. 9 10 If the Designating Party timely seeks a protective order, the Party served with the subpoena or court order shall not produce any information designated in this action as 11 12 “CONFIDENTIAL” before a determination by the court from which the subpoena or order 13 issued, unless the Party has obtained the Designating Party’s permission. The Designating Party 14 shall bear the burden and expense of seeking protection in that court of its confidential material – 15 and nothing in these provisions should be construed as authorizing or encouraging a Receiving 16 Party in this action to disobey a lawful directive from another court. 17 9. 18 IN THIS LITIGATION 19 20 21 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED (a) The terms of this Order are applicable to information produced by a Non-Party in this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 22 connection with this litigation is protected by the remedies and relief provided by this Order. 23 24 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking 25 additional protections. 26 /// 27 /// 28 11 STIPULATED PROTECTIVE ORDER 1 (b) In the event that a Party is required, by a valid discovery request, to produce a Non- 2 Party’s confidential information in its possession, and the Party is subject to an agreement with 3 the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 4 (1) promptly notify in writing the Requesting Party and the Non-Party that some 5 or all of the information requested is subject to a confidentiality agreement with a Non-Party; 6 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 7 8 Order in this litigation, the relevant discovery request(s), and a reasonably specific description of 9 the information requested; and 10 (3) make the information requested available for inspection by the Non-Party. 11 12 (c) If the Non-Party fails to object or seek a protective order from this court within 14 13 days of receiving the notice and accompanying information, the Receiving Party may produce 14 the Non-Party’s confidential information responsive to the discovery request. If the Non-Party 15 timely seeks a protective order, the Receiving Party shall not produce any information in its 16 possession or control that is subject to the confidentiality agreement with the Non-Party before a 17 18 19 20 21 determination by the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of seeking protection in this court of its Protected Material. 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 22 Material to any person or in any circumstance not authorized under this Stipulated Protective 23 24 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the 25 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 26 Protected Material, (c) inform the person or persons to whom unauthorized disclosures were 27 28 12 STIPULATED PROTECTIVE ORDER 1 2 made of all the terms of this Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A. 3 11. 4 INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain inadvertently 6 7 produced material is subject to a claim of privilege or other protection, the obligations of the 8 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This 9 provision is not intended to modify whatever procedure may be established in an e-discovery 10 order that provides for production without prior privilege review. Pursuant to Federal Rule of 11 12 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a 13 communication or information covered by the attorney-client privilege or work product 14 protection, the parties may incorporate their agreement in the stipulated protective order 15 submitted to the court. 16 12. MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to 17 18 19 seek its modification by the court in the future. 20 21 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order no Party waives any right it otherwise would have to object to disclosing or producing any 22 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, 23 24 no Party waives any right to object on any ground to use in evidence of any of the material 25 covered by this Protective Order. 26 /// 27 /// 28 13 STIPULATED PROTECTIVE ORDER 12.3 1 Filing Protected Material. Without written permission from the Designating Party 2 or a court order secured after appropriate notice to all interested persons, a Party may not file in 3 the public record in this action any Protected Material. A Party that seeks to file under seal any 4 Protected Material must comply with Local Rule 141. Protected Material may only be filed 5 under seal pursuant to a court order authorizing the sealing of the specific Protected Material at 6 7 issue. Pursuant to Local Rule 141(d), a sealing order will issue only upon a request establishing 8 that the Protected Material at issue is privileged, protectable as a trade secret, or otherwise 9 entitled to protection under the law. If a Receiving Party's request to file Protected Material 10 under seal pursuant to Local Rule 141 is denied by the court, then the Receiving Party may file 11 12 13 14 15 the information in the public record pursuant to local rules unless otherwise instructed by the court. 13. FINAL DISPOSITION Within 60 days after the final disposition of this action, as defined in paragraph 4, each 16 Receiving Party must return all Protected Material to the Producing Party or destroy such 17 18 material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, 19 compilations, summaries, and any other format reproducing or capturing any of the Protected 20 Material. Whether the Protected Material is returned or destroyed, the Receiving Party must 21 submit a written certification to the Producing Party (and, if not the same person or entity, to the 22 Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all 23 24 the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has 25 not retained any copies, abstracts, compilations, summaries or any other format reproducing or 26 capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to 27 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 28 14 STIPULATED PROTECTIVE ORDER 1 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work 2 product, and consultant and expert work product, even if such materials contain Protected 3 Material. Any such archival copies that contain or constitute Protected Material remain subject to 4 this Protective Order as set forth in Section 4 (DURATION). 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 GOLDEN & CARDONA, LOYA 8 9 DATED: __March 14, 2014___________ 10 11 ___s/ Jeremy Golden________________________ Jeremy S. Golden, Esq. Attorneys for Plaintiffs TERRY GREEN and CHARLES WITCHER 12 13 CIR, LAW OFFICES 14 15 DATED: __March 14, 2014___________ 16 17 18 ___s/ Tara Muren__________________________ Tara Muren, Esq. Attorneys for Defendant CREDITOR IUSTUS ET REMEDIUM, LLP d/b/a CIR, LAW OFFICES, LLP 19 IT IS SO ORDERED. 20 21 Dated: March 17, 2014 /s/ Jennifer L. Thurston UNITED STATES MAGISTRATE JUDGE 22 23 24 25 26 27 28 15 STIPULATED PROTECTIVE ORDER 1 2 3 4 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND I, _____________________________ [print or type full name], of ____________________________________________________________ [print or type full 5 address], declare under penalty of perjury that I have read in its entirety and understand the 6 7 Stipulated Protective Order that was issued by the United States District Court for the Eastern 8 District of California on [date] in the case of Terry Green and Charles Witcher v. Creditor Iustus 9 Et Remedium, LLP d/b/a CIR, Law Offices, LLP, Case No.1:13-cv-01414-LJO-JLT. I agree to 10 comply with and to be bound by all the terms of this Stipulated Protective Order and I 11 12 understand and acknowledge that failure to so comply could expose me to sanctions and 13 punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner 14 any information or item that is subject to this Stipulated Protective Order to any person or entity 15 except in strict compliance with the provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court for the 17 18 19 20 21 Northern District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after termination of this action. I hereby appoint __________________________ [print or type full name] of _______________________________________ [print or type full address and telephone 22 number] as my California agent for service of process in connection with this action or any 23 24 25 proceedings related to enforcement of this Stipulated Protective Order. Date: ______________________________________ City and State where sworn and signed: _________________________________ 26 27 Printed name: _______________________________ 28 Signature: __________________________________ 16 STIPULATED PROTECTIVE ORDER

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