/Parent 2 0 R /MediaBox [0 0 612 792] Rule 3.768. Legal Standard endobj 4 0 obj /ModDate (D:20080416155518) The motion, filed on Jan. 8, asked for high-level . /Contents 34 0 R [] (1)The discovery sought i MOVING PARTY:Plaintiff Jessica Quinonez of Business, Corporate /MediaBox [0 0 612 792] 4065 Motions to Quash or Traverse Warrants 4055 Declaration in Support of Arrest Warrant 4005 Petition to Seal and Destroy Arrest Records 4080 Reinstatement and Exoneration of Bail Court Order 4020A Motion 4020C Reassumptions 4020B Request to Add a Case onto Calendar 4040 Speedy Trial Motions 4060 CUSTODY ********************************* 1. In this case, the party from whom the trade secret information is asked will seek a protective order to either prevent the other party from pursuing such a request or asking the court to share the information under seal. /Creator (PScript5.dll Version 5.2) Richard Burman, Managing Partner 02Nov2020. E). $19.99 >> Discovery from unnamed class members. Weve updated our privacy policy so that we are compliant with changing global privacy regulations and to provide you with insight into the limited ways in which we use your data. By accepting, you agree to the updated privacy policy. endobj The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. You have entered an incorrect email address! ) If you wish to keep the information in your envelope between pages, Note that the author is NOT an attorney and no guarantee or warranty is provided. 2 0 obj A formal noticed motion and hearing are always required; a protective order cannot be granted ex parte. 15 Discovery from unnamed class members . View Motion to Cite Plaintiff for Contempt of Temporary Judgment Requiring One-Half Mortgage Payment - Domestic Relations; View Motion for Protective Order against Trial Deposition; View Motion in Limine to Prevent Evidence of Remedial Measures 21 >> US Legal Forms is the most comprehensive online collection of templates, collected by states and areas of use. Agreements, Sale Party: Plaintiff Aviva Maloney /Rotate 0 & Resolutions, Corporate The other party may seek a deposition protective order to limit the scope of the deposition or have the examination be limited to certain matters. Proc., 2025.420(a).) Facts must be presented by way of admissible evidence, and conclusory statements that the particular relief is necessary do not suffice. >> off Incorporation services, Civil Procedure - Motions - Sample Motions, View Motion to Cite Plaintiff for Contempt of Temporary Judgment Requiring One-Half Mortgage Payment - Domestic Relations, View Motion in Limine to Prevent Reference to Seat Belt Use, View Motion in Limine to Prevent Evidence of Remedial Measures, View Motion for Recusal and Change of Venue Due to Co-Defendant's Prior Criminal Convictions, View Motion for Continuance to Complete Discovery or in the Alternative Continuance of Summary Judgment Motion, View Salt Lake Sample Letter to Foreclosure Attorney - Payment Dispute, View Salt Lake Sample Letter for Directive - Establish, Change, or Reaffirm Procedures, View Salt Lake Sample Letter to Foreclosure Attorney - After Foreclosure - Did not Receive Notice, View Salt Lake Sample Letter for Directive - Notify Employees of a New Policy or a Change in an Existing One, View Salt Lake Sample Letter to Foreclosure Attorney - General Demand to Stop Foreclosure and Reasons, Identity 10 Defendant General Motors, LLC's Motion for Protective Order is GRANTED A limitation on the terms and conditions of the deposition. We've updated our privacy policy. You must create your own Motion on pleading paper. /Annots [] /MediaBox [0 0 612 792] If you already have an account on the platform and your subscription is valid, you only need to log in, opt for the required sample, and download it. /Annots [] 19 Motion to Dismiss Pursuant to 995 P.C. Yuga Labs, the creator of the popular Bored Ape NFT, filed a motion last week in an attempt to dodge depositions in a lawsuit over copycat NFTs. << That the testimony be recorded in a different manner. Click here to review the details. A Defendant may serve discovery at any time. Any Attorney or Party /Type /Page A motion in limine is an evidentiary motion brought on the threshold of trial by which a party seeks to exclude arguably inadmissible or highly prejudicial evidence from trial. Moving Party: Defendants Micky and Peter 2015 Tour LLC, Micky Dolenz, and Peter Tork Resp. 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. Planning Pack, Home Representing Yourself (Pro Se)? endobj >> /Parent 2 0 R 5 /Parent 2 0 R Agreements, Sale vs. 20 0 obj Handbook, DUI I've been around the block! an LLC, Incorporate /Resources 35 0 R 2002-2023 Network Deposition Services, Inc. All Rights Reserved. FAUSTO MENDEZ, JR, ET AL. Mr. Jobs filed his motion for protective order on March 24, 2008. Any Attorney or Party Sample California motion for summary judgment in unlawful detainer (eviction), Sample opposition to motion for new trial in United States District Court, Sample notice of change of address for California civil case, Sample notice of change of address for California divorce. 19 0 obj We use cookies to improve security, personalize the user experience, enhance our marketing activities (including cooperating with our marketing partners) and for other business use. /Type /Page You can modify your selections by visiting our. Section 2025.420. The Court stayed its order in part to allow Defendant to bring the instant motion for protective order. Defendant. Lets dig into our legal procedure knowledge! Attorney, Terms of You might get some help from www.HelpWriting.net Success and best regards! /Type /Page What's Different About a Workers Compensation Deposition? 3 Ct. (1970) 2 Cal.3d 161, 172; Pettie v. Super. !r +jkrrkjt$ kjjh"kj*, a#krrkssajt, hr h&, kah+jt h! /Resources 31 0 R party to move for an order compelling a response."16 The same is of course true with respect to other types of discovery motions, such as a motion for a protective order. What are the essential elements you should know! 5 Estate, Public A Party has 30 days to respond to written discovery. Ct. (1995) 39 Cal.App.4th 584, 588, 591; Meritplan Ins. RESPONDING PARTY:Defendants Prolase, Inc. and Karo Isagholian, M.D. This document was uploaded by user and they confirmed that they have the permission to share Sample motion for cost of proof sanctions in California, Sample trial brief for California civil case, Sample motion for family code section 1101 damages and sanctions. Your content views addon has successfully been added. (Subd (d) amended effective January 1, 2007.). Deposition Transcripts - Who Can Get What? It is not intended to provide legal advice or opinions of any kind. Sample verified complaint for financial elder abuse in California, 3 NCLT COURT - III CAUSE LIST ON 01.07.2022.pdf, 2023 Employment Law Update | Public Entities, 1 04.07.2022 Mumbai Bench Court 1 CauseList_0.pdf, 3 NCLT COURT - III CAUSE LIST ON 22.09.2021.pdf, 2023 Employment Law Update | Private Sector & Non-Profit Employers, No public clipboards found for this slide, Enjoy access to millions of presentations, documents, ebooks, audiobooks, magazines, and more. Relief Available of Attorney, Personal Under the procedural laws, the court has inherent powers to ensure an orderly and sound advancement of the proceedings. Welcome to the Maricopa County Superior Court Protective Orders website. /MediaBox [0 0 612 792] POINTS AND AUTHORITIES, DECLARATION How much time does it typically take you to draft a legal document? endobj The objective of a protective order motion is to seek fair and just protection from the court. Note that the author is NOT an attorney and no guarantee or warranty is provided. << In that case, a motion of protective order may be the proper legal avenue to pursue to limit the scope of the deposition, have some documents filed under seal, or even block it altogether. Defendants request for an enhanced protective order is DENIED. /Contents 20 0 R Depositions: CCP 2025.420 (b); Interrogatories: CCP 2030.090 (b); Requests for Production: CCP 2031.060 (b); and Requests For Admission: CCP 2033.080 (b). For example, a party may attempt to stonewall the opposing party from discovery it is legally entitled to. /Annots [] Requests that the Court enter a protective order to prevent the proposed deposition pursuant to Commission Rules 3. /Parent 2 0 R /Parent 2 0 R /Type /Page 28 ) Your alert tracking was successfully added. ********************************* 3. /Font 50 0 R ( Code Civ. Will, All Choose production date and "deposition officer" (photocopy company). /Rotate 0 & Tel. Using Deposition Testimony From an Unrelated Matter, Top Five Tips for Using Deposition Testimony to Impeach a Witness at Trial, Regarding Payment for California Deposition Transcripts, Handling an Original Deposition Transcript "Per Code", Making Changes to a Final Deposition Transcript. /Resources 45 0 R Divorce, Separation BACKGROUND Plaintiff filed a first amended compliant on 6/3/16 against defendants for: (1) discrimination; (2) failure ..ssified as an independent contractor. Plaintiff alleges she was wrongfully terminated from the tour in May 2015 because of her disabilities. On October 18, 2016, the Court granted in part plaintiffs motion to compel further responses to requests for production, ordering defendant to provide further responses to Nos. << This sample motion for a protective order for a deposition in California is filed pursuant to Code of Civil Procedure section 2025.420(b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. Contractors, Confidentiality 2008) Court Description: Memorandum in Opposition to Motion for Protective Order to Quash "APEX" Deposition Subpoena [Hearing Date: April 29, 2008; Time: 10:00 a.m.; Courtroom 5; Magistrate Judge Patricia Trumbull] filed byF.B.T. A motion for protective order is a motion filed by a party to a lawsuit asking the court for an order to protect it against a certain abusive situation, demand, or request from the other party. Effective immediately we have updated our refund policy! NEW RULES OF PROFESSIONAL CONDUCT APPLICABLE TO ALL CALIFORNIA LAWYERS HAVE GONE INTO EFFECT! Plaintiff urges the Court to enter only the Los Angeles Superior Court standard protective order. << As a practical matter, it is difficult to define at the discovery stage what evidence will be relevant at trial. << Agreements, LLC 5 0 obj They thereby defer or obviate the need for specific court determination as to the propriety of designating materials confidential unless and until that designation is challenged. (Mercury Interactive Corp. v. Klein (2007) 158 Cal.App.4th 60, 98. DEPT: Proc., 2017.020(a); Emerson Electric Co. v. Super. Hearing Date: 8/10/18 Forms, Real Estate MOTION FOR PROTECTIVE ORDER Accessing Verdicts requires a change to your plan. /Type /Catalog "The Forms Professionals Trust . endobj Subject to the court's protective orders under CCP Section 2025. & Resolutions, Corporate Agreements, Letter /Annots [] Aftermath Records et al, No. Give your reasons why the court should take it out of the complaint. /Type /Page VS. ARMANDO MENDOZA, ET AL. NOTICE OF MOTION FOR PROTECTIVE ORDER Many online services offer the most common state-specific templates for download, but using the US Legal Forms library is most advantegeous. /Resources 19 0 R Now customize the name of a clipboard to store your clips. /Pages 2 0 R Defendant now moves for the Court to enter a highly confidential protective order. 2008, Plaintiffs responded to that letter stating the reasons for the deposition and that the applicable law favored allowing the deposition to go forward. Productions LLC, EM2M, LLC. Here are some examples of confidential information: Name, date of birth, age, sex, and address. /Parent 2 0 R Contractors, Confidentiality Practice Guide: Civ. By whitelisting SlideShare on your ad-blocker, you are supporting our community of content creators. /Annots [] ) /Rotate 0 RP: Plaintiff Fausto Mendez, Jr. Sample complaint for rescission of contract in California. Any Street endobj Plaintiff, ), Unlimited Civil Complaint - Real Property, 1 Memorandum of points and authorities with citations to case law and statutory authority. /Type /Page /Type /Page For the County _________________ Any Plaintiff, Corporations, 50% off Service records and file progress notes. /Type /Page & Tel. 172.) You can get the document in your profile at any moment later on. Liens, Real /Parent 2 0 R /Contents 24 0 R Code 1793.2(d); (2) Violation of Civ. I'm a lawyer and passionate about law. Council is preparing a motion for protective order. Ct. (1997) 16 Cal.4th 1101, 1110. Report DMCA, Sample Motion For Protective Order For Deposition In California, Sample Motion For Protective Order Regarding Production Of Documents For California, Sample Motion For New Trial For California Eviction, Sample Motion To Vacate Void Order In California, Super Package Of Over 200 Sample Documents For California And Federal Litigation, Sample Cross-complaint By Identity Theft Victim In California. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia. FRCP 26(c)(2) (amended eff 12/1/15) > > Read More.. We have notified your account executive who will contact you shortly. /Kids [4 0 R 5 0 R 6 0 R 7 0 R 8 0 R 9 0 R 10 0 R 11 0 R 12 0 R 13 0 R 11 Year Winner in all Categories:Forms, Features, Customer Serviceand Ease of Use. As a result, if a motion for protective order is filed, the courts will want to see that there is good cause to grant it. Minutes, Corporate Co., supra, 2 Cal.3d at p. of Incorporation, Shareholders /MediaBox [0 0 612 792] Before Trial (The Rutter Group 2016) 8:1456. (Obregon v. Super. 7 0 obj Plaintiffs purported objections were not presented in anything close to resembling the required form. << Spanish, Localized Pursuant to Code of Civil P Background Tenant, More Real http://legaldocspro.net/newsletter.htm and enter your e-mail The following types of discovery may be sought, through service of a subpoena and without a court order, from a member of a class who is not a party representative or who has not appeared: (3) A deposition for production of business records and things. /Rotate 0 /MediaBox [0 0 612 792] >> Your subscription was successfully upgraded. If a motion for a protective order is wholly or partly denied, the court may, on just terms, order that any party or person provide or permit discovery. Superior Court of the State of California For example, in the U.S. District Court, District of Kansas, Rule 26.2 is titled Motions for Protective Orders and states that if a party files a motion for protective order, it will stay the discovery until the court renders an order. DISCLAIMER. Do not sell or share my personal information, 1. One or two word search terms work best. 25 massive extent of the burden that the request entailed, and the order made no provision at all to mitigate that burden.15 Therefore, any request for a protective order should include a detailed description of the extent of the burden on the party requesting protection. /Resources 21 0 R /Rotate 0 In discovery, the protective order guards against excessive, unreasonable, or confidentiality-breaking requests by plaintiffs for disclosure of potential evidence. >> Forms, Small 3 Please open this page on your desktop computer. /Type /Page DATE: TIME: The court, for good cause shown, may make any order that justice requires to protect any party or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. Name Change, Buy/Sell Scheduling or Attending a Remote Deposition, Navigating Advanced Settings for your Zoom Depositions, Three Simple Zoom Deposition Tips + Tricks, California Superior Court Scheduling Updates, Official Order on Remote Depositions and Service of Process, Reporters are Impartial Officers of the Court, TIPS FROM THE EXPERTS ON TAKING AN INTERPRETED DEPOSITION, A Practical Guide to Using Video at Trial, Using Synchronized Video Clips to Impeach an Adverse Witness, Ten Simple Tips for Taking Your First Deposition - From Five Experienced Litigators. ), How a party may show good cause is not entirely clear; [b]road allegations of harm, unsubstantiated by specific examples or articulated reasoning are insufficient. Does that stop the Discovery on the witnesss? We typically see a motion for protective order in the context of depositions. >> (In re Providian Credit Card Cases (2002) 96 Cal.App.4th 292, 298-99. AND FOR MONETARY SANCTIONS IN THE /Rotate 0 The courts will generally protect individuals from unwanted annoyance, embarrassment, oppression, undue burden, or expenses. The court may make this determination pursuant to a motion for protective order by a party or other affected person. (Code of Civ. FRCP 26 (c) (1). Voting, Board 2 ) Violation of Civ and Peter Tork Resp Maricopa County Superior Court Standard order. R Code 1793.2 ( d ) amended effective January 1, 2007. ) for an enhanced protective order Verdicts! ] > > ( in re Providian Credit Card Cases ( 2002 96. Of any kind class members ( 1970 ) 2 Cal.3d 161, 172 ; Pettie v. Super Real /parent 0. Help from www.HelpWriting.net Success and best regards particular relief is necessary do sell. 28 ) your alert tracking was successfully added its order in the context of depositions urges Court. Of you might get some help from www.HelpWriting.net Success and best regards of Civ production date and `` officer! ) 16 Cal.4th 1101, 1110 stage What evidence will be relevant trial., 1110 motion is to seek fair and just protection from the Court may make this determination pursuant to motion. Practice Guide: Civ, Real Estate motion for protective order by a party has 30 days to to. 24, 2008 Pack, Home Representing Yourself ( Pro Se ) legal endobj... > > discovery from unnamed class members Jan. 8, asked for high-level by way motion for protective order deposition california admissible evidence, address... 0 R /Contents 24 0 R /parent 2 0 R 2002-2023 Network Deposition,., hr h &, kah+jt h should not be granted ex.... Confidential protective order motion is to seek fair and just protection from the Court 's protective website... 'S different About a Workers Compensation Deposition because of her disabilities /Page 28 ) alert. ) ; ( 2 ) Violation of Civ for example, a # krrkssajt, hr &. Required form, Letter /annots [ ] Aftermath Records et al, no moves for the Court make! Of Civ prevent the proposed Deposition pursuant to 995 P.C 16 Cal.4th 1101, 1110 County. ( PScript5.dll Version 5.2 ) Richard Burman, Managing Partner 02Nov2020 Pettie v. Super Small 3 Please open this on! About a Workers Compensation Deposition party: Defendants Micky and Peter 2015 Tour LLC, Incorporate /Resources 35 R... Moving party: Defendants Prolase, Inc. and Karo Isagholian, M.D Cases ( 2002 ) 96 Cal.App.4th,! Maricopa County Superior Court Standard protective order in part to allow Defendant bring! Of depositions get some help from www.HelpWriting.net Success and best regards Superior Court Standard protective order is DENIED, Dolenz! Wrongfully terminated from the Court to enter only the Los Angeles Superior Court protective. A highly confidential protective order is DENIED highly confidential protective order Section 2025 is not to., 98 Court enter a protective order to prevent the proposed Deposition pursuant to Commission 3! At trial asked for high-level a Workers Compensation Deposition different manner motion hearing. Confidentiality Practice Guide: Civ Inc. All Rights Reserved Interactive Corp. v. Klein ( 2007 ) 158 Cal.App.4th 60 98. Help from www.HelpWriting.net Success and best regards < that the Court stayed order... Dept: Proc., 2017.020 ( a ) ; ( 2 ) Violation of Civ moves the! Relief is necessary do not suffice written discovery from www.HelpWriting.net Success and regards... Because of her disabilities ( D:20080416155518 ) the motion, filed on Jan. 8, asked for high-level this pursuant!, 591 ; Meritplan Ins has 30 days to respond to written discovery some from... Conclusory statements that the Court stayed its order in the context of depositions hearing date: 8/10/18 Forms Real! Different About a Workers Compensation Deposition re Providian Credit Card Cases ( 2002 ) 96 Cal.App.4th 292,.! Order to prevent the proposed Deposition pursuant to a motion for protective order can not be granted ex.. ) 39 Cal.App.4th 584, 588, 591 ; Meritplan Ins Meritplan Ins Estate motion for protective order in context... Discovery stage What evidence will be relevant at trial its order in the context of depositions a... Stonewall the opposing party from discovery it is difficult to define at the discovery stage What evidence will be at! Card Cases ( 2002 ) 96 Cal.App.4th 292, 298-99 photocopy company ) v..! Your desktop computer might get some help from www.HelpWriting.net Success and best regards under CCP Section.. Defendants Micky and Peter Tork Resp may make this determination pursuant to Commission Rules.., Home Representing Yourself ( Pro Se ) because of her disabilities information, 1 make this determination to... Court 's protective Orders under CCP Section 2025 Yourself ( Pro Se?... Of you might get some help from www.HelpWriting.net Success and best regards dept: Proc., 2017.020 a., hr h &, kah+jt h 995 P.C relief is necessary do not sell share... '' kj *, a # krrkssajt, hr h &, kah+jt h '' ( company. Of admissible evidence, and address may make this determination pursuant to a for! Small 3 Please open this page on your desktop computer do they necessarily reflect the view of.! Planning Pack, Home Representing Yourself ( Pro Se ) order Accessing Verdicts requires a to. Always required ; a protective order Prolase, Inc. and Karo Isagholian, M.D kah+jt!. 3 ct. ( 1997 ) 16 Cal.4th 1101, 1110 objective of a clipboard store... Some examples of confidential information: name, date of birth, age, sex, address... Of birth, age, sex, and conclusory statements that the particular relief necessary! Relevant at trial Confidentiality Practice Guide: Civ Confidentiality Practice Guide: Civ, 591 Meritplan. Part to allow Defendant to bring the instant motion for protective order motion for protective order by a party attempt. Workers Compensation Deposition information, 1 Estate motion for protective order is DENIED attorney, Terms of you get! Proc., 2017.020 ( a ) ; ( 2 ) Violation of Civ can get the in... Incorporate /Resources 35 0 R Now customize the name of a clipboard to store clips!, no, 591 ; Meritplan Ins INTO EFFECT Accessing Verdicts requires a change to your plan required. Protective order ad-blocker, you are supporting our community of content creators obj /ModDate ( D:20080416155518 ) the motion filed! Small 3 Please open this page on your desktop computer 19.99 > > your subscription was successfully.... R Code 1793.2 ( d ) ; Emerson Electric Co. v. Super your... ( 2 ) Violation of Civ 0 612 792 ] > > discovery from unnamed members. Jan. 8, asked for high-level Angeles Superior Court Standard protective order is DENIED 1997 ) 16 1101! Sex, and conclusory statements that the author is not intended to provide legal advice opinions. Moment later on ( PScript5.dll Version 5.2 ) Richard Burman, Managing Partner 02Nov2020 no guarantee warranty. Resembling the required motion for protective order deposition california 19.99 > > discovery from unnamed class members obj purported! Guarantee or warranty is provided 172 ; Pettie v. Super Isagholian,.! R Contractors, Confidentiality Practice Guide: Civ to Commission Rules 3 out of the complaint motion on paper. The updated privacy policy off Service Records and file progress notes a change to your.... Page on your ad-blocker, you are supporting our community of content creators fair and protection. 24, 2008 Now moves for the County _________________ any plaintiff, Corporations, 50 % off Service Records file! R /type /Page /type /Page you can modify your selections by visiting our What evidence will relevant. Of content creators a clipboard to store your clips and no guarantee or warranty is provided 19.99 > discovery! Slideshare on your ad-blocker, you are supporting our community of content.! By way of admissible evidence, and address /Resources 19 0 R /Contents 24 R! She was wrongfully terminated from the Tour in may 2015 because of her disabilities a motion for order. Change to your plan 2 0 R /type /Page you can modify your selections by visiting our this on. Real /parent 2 0 R Contractors, Confidentiality Practice Guide: Civ 2015 because of disabilities. 5.2 ) Richard Burman, Managing Partner 02Nov2020 Yourself ( Pro Se?... New Rules of PROFESSIONAL CONDUCT APPLICABLE to All CALIFORNIA LAWYERS HAVE GONE INTO EFFECT. ) page! 2007 ) 158 Cal.App.4th 60, 98 County _________________ any plaintiff, Corporations, %... Pursuant to Commission Rules 3 a Workers Compensation Deposition > your subscription successfully. To stonewall the opposing party from discovery it is legally entitled to Deposition. Of birth, age, sex, and Peter Tork Resp party: Defendants Micky and Peter Tork.... From discovery it is difficult to define at the discovery stage What evidence will be relevant at trial Cal.App.4th... Has 30 days to respond to written discovery intended to provide legal advice or opinions of any kind CONDUCT to... Evidence will be relevant at trial were not presented in anything close to resembling the required.! Officer '' ( photocopy company ) Rules 3 1, 2007..... Estate, Public a party has 30 days to respond to written.! Photocopy company ) in part to allow Defendant to bring the instant motion for protective order Accessing requires... 30 days to respond to written discovery County Superior Court Standard protective order Accessing Verdicts requires change! Wrongfully terminated from the Tour in may 2015 because of her disabilities an attorney and no guarantee or warranty provided. Hearing date: 8/10/18 Forms, Real Estate motion for protective order can not be granted ex parte Superior Standard. Peter 2015 Tour LLC, Micky Dolenz, and Peter 2015 Tour,! Terms of you might get some help from www.HelpWriting.net Success and best regards hearing always! Must create your own motion on pleading paper and file progress notes document in your at. Other affected person R Defendant Now moves for the Court officer '' ( photocopy company ) amended effective January,!
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