Please see our Privacy Policy. /MediaBox [0.0 0.0 612.0 792.0] This case is both a potential collective action under federal law and a potential class action under Pennsylvania state law. The deadline for individuals to join the lawsuit is May 6, 2022. … He knows whos around him. We invite you to contact us and welcome your calls, letters and electronic Camp Lejeune residents now have the opportunity to claim compensation for harm suffered from contaminated water. endobj /Cour 8 0 R /Contents [51 0 R 52 0 R 53 0 R] However, you do not need to have records of your work hours to make a claim. 2135 0 obj<>stream Please see our Privacy Policy. /Rotate 0 endobj >> /Font << endobj /Metadata 3 0 R The state lawyers noted in a court filing last week that AmeriHealth oversees Medicaid benefits for all six initial plaintiffs in the Disability Rights Iowa lawsuit. Please see our Privacy Policy. >> /ProcSet [/PDF /Text /ImageC /ImageI] /Resources << From locally-focused health insurance plans to national-scale programs that assist those who need it the most, we exceed our customers' expectations through innovative health insurance and wellness solutions. /CropBox [0.0 0.0 612.0 792.0] filed a lawsuit against Defendant for violating the overtime . /AcroForm 2 0 R Today, AmeriHealth Caritas filed papers seeking to "remove" this lawsuit from the Philadelphia Court of Common Pleas to the United States District Court in Philadelphia, PA. 24 0 obj /PDFDocEncoding 7 0 R In the Complaint, the Plaintiff alleges that AmeriHealth Caritas misclassified her and other Clinical Care Reviewers as exempt employees, denying them overtime compensation. The workers allege that AmeriHealth Caritas violated Pennsylvania and federal law by failing to pay them full overtime premium compensation for hours worked over 40 per week. /brokenbar 168 /dieresis /copyright /ordfeminine 172 /logicalnot /.notdef /registered /macron …Its a difference in want vs. need.. The company's mission is to help those most in need get care, stay well, and build healthy communities. The Judge overseeing this case is JAN E. DUBOIS. AmeriHealth Caritas Servs., CIVIL ACTION NO. /Font << Read our Newswire Disclaimer. /Annots [] >> We will seek any records the company has of your hours worked. 10 0 obj /Tabs /S Law360 provides the intelligence you need to remain an expert and beat the competition. /Rotate 0 /CropBox [0.0 0.0 612.0 792.0] Enter your details below and select your area(s) of interest to receive Law360 Employment Authority daily newsletters and section features. Class Action Settlement Recap Enhancements to Claim Payment Policy, Processing and Payment Disclosure, and an Appeals Process for Class Action Settlement Providers The following enhancements are effective for providers who agreed to the terms of the court-approved class action settlement ("Settlement Providers"), for Gregg v. AmeriHealth et al, /TT1 40 0 R /Kids [13 0 R 14 0 R 15 0 R 16 0 R 17 0 R 18 0 R 19 0 R 20 0 R] >> For help enrolling, you can call Healthy Louisiana at 1-855-229-6848 (TTY 711). Daily and real-time news and case alerts on organizations, industries, and customized search queries. /Resources << We will ask the third-party administrator to re-mail the materials to you. /Rotate 0 More than 300clinical care review workers for AmeriHealth Caritas Services LLC secured approval from afederal judge Tuesday to finalize their $4.25 million settlement resolving a collective action alleging they were denied overtime wages after being improperly classified as overtime-exempt. /Resources << << However, Plaintiff and . /OCGs [4 0 R] /Font << x+ | Please download the PDF to view it: Download PDF. Regardless of which managed care company is in place, the director of the Iowa Department of Human Services is ultimately responsible for ensuring that Iowans have the Medicaid services they need and receive notice and an opportunity for a fair hearing when their services are denied or cut.. << As indicated, the company alleges, among other things, that CHC Service Coordinators are "exempt" from the federal and state overtime laws. /GS0 85 0 R Law360 may contact you in your professional capacity with information about our other products, services and events that we believe may be of interest.Youll be able to update your communication preferences via the unsubscribe link provided within our communications.We take your privacy seriously. Lawyers for the group later changed the suit. AMERIHEALTH CARITAS . endobj The lawsuit is being spearheaded by the advocacy group Disability Rights Iowa, which has asked a federal judge to declare the suit a class-action case on behalf of about 15,000 Iowans with . /Font << >> /ProcSet [/PDF /Text] << 17 0 obj Copies of the removal papers are available below. /F1 38 0 R Fisher, 62, said she needs extensive in-home assistance, because she cant eat, bathe or go to the bathroom by herself. /TT1 40 0 R /DA (/Helv 0 Tf 0 g ) The lawsuit against Iowa was filed last year by Disability Rights Iowa, a federally supported advocacy group that seeks to protect the rights of people with disabilities. . AmeriHealth Caritas denies that it violated any laws. 2023, Portfolio Media, Inc. | About | Contact Us | Legal Jobs | Advertise with Law360 | Careers at Law360 | Terms | Privacy Policy | Cookie Settings | Help | Site Map, BRISTOW, ON BEHALF OF HERSELF AND OTHERS SIMILARLY SITUATED v. AMERIHEALTH CARITAS. The Disability Rights Iowa lawsuit was originally filed against Reynolds and Charles Palmer, who was then director of the Iowa Department of Human Services. /C2_0 50 0 R LEXIS 10631, at *8 (W.D. action as a class action claim under Federal Rule of Civil Procedure 23. >> /ProcSet [/PDF /Text] HRmo0X*TU$:m4JMS4)sg' K[; /MediaBox [0 0 612 792] Please ensure you do not destroy any documents or data you have that relate in any way to your work for AmeriHealth. /Adieresis /Aring /AE /Ccedilla /Egrave /Eacute /Ecircumflex /Edieresis /Igrave /Iacute Nj_JxR"0 ~ "6?W|iiVpsSGR2 W_ R@OgBQK8>HhP/W/wb'_> HFtJ.#kx:0;Q~rA(Pkasq6H y^P kik(,mt"#qr]' >> /Type /Page Subscribe to Justia's Free Newsletters featuring summaries of federal and state court opinions. Try our Advanced Search for more refined results, Searching cases in Amerihealth Caritas /Encoding << /ExtGState << The judge also heard testimony from Beth Wargo of West Des Moines, whose boyfriend, Neil Siegel, is one of the six plaintiffs in the lawsuit. EZt*mTf1T*h? In Travel Pay Row. /ADBE_FillSignInfo << /Type /Font /Contents [76 0 R 77 0 R 78 0 R] /TT0 39 0 R 2:14-cv-00656 District Judge CYNTHIA M. RUFE, presiding. Read full Disclaimer. /Type /Font 23 0 obj We are proud of the work we did in Iowa and the accomplishments of our associates," Brett said. /Rotate 0 Arthur J. Tarnow, Senior United States District Judge. /Type /Page /C2_0 50 0 R /TT1 40 0 R >> /Type /Page /TT0 39 0 R Email (NOTE: Free email domains not supported). 22 0 obj /F1 38 0 R This is ClassAction.org's current list of open lawsuits and investigations. /Rotate 0 Today, AmeriHealth Caritas filed its Answer to the Amended Complaint. Kim Reynolds, say the shift is saving the state millions of dollars while leading to more efficient care for the approximately 600,000 poor or disabled Iowans who use the Medicaid program. Law360 may contact you in your professional capacity with information about our other products, services and events that we believe may be of interest.Youll be able to update your communication preferences via the unsubscribe link provided within our communications.We take your privacy seriously. They are to be shifted to UnitedHealthcare or Amerigroup at the end of this month. . . Cause of Action: 29 U.S.C. 8 0 obj 9?TBP+074zt72*CnFIs:!,bE2|Hu@Mn!W' Tv+. If AmeriHealth did not keep accurate time records, most courts will permit you to make a good faith estimate of your work hours. endobj /MediaBox [0.0 0.0 612.0 792.0] /Subtype /Type1 No, you will not have to pay us anything out of your own pocket. /ProcSet [/PDF /Text] Siegel, 54, suffered a brain injury when a car hit him as he bicycled in 2013. >> >> This case was filed in U.S. District Courts, Pennsylvania Eastern District. New to ClassAction.org? Mother says Iowas privatized Medicaid is unsafe for her son. ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS' MOTION TO SUMMARY JUDGMENT [43] Arthur J. Tarnow, Senior United States District Judge. 30 0 obj /Parent 12 0 R This form will be filed with the Court. /TT2 41 0 R }95e, \fwWr+Aj* -=k /TT3 72 0 R /C2_0 50 0 R /Annots [] I took a free trial but didn't get a verification email. 19 0 obj AmeriHealth Caritas service coordinators accuse the company of violating the state's minimum wage law by failing to pay overtime in a proposed class action filed in Pennsylvania state court. NLRB Chose Precedent For 'Predestined Result,' NRTW Says, Colo. Farms Drop Challenge To State's Labor Rights Law, NLRB Atty Says Tweets Over Race Bias Are Protected Activity, Movie Producers Illegally Fired Strikers, NLRB Judge Says, SEIU Affiliate Can't Escape Kaiser's Sympathy Strike Claims, TV Cos. /Tabs /S /Type /Metadata >> >> Hes happier. /Length 10 /ColorSpace << Learn more below about how our CARE IS about you. 18 0 obj >> >> /Type /Page /Contents [79 0 R 80 0 R 81 0 R] LUMA v. AMERIHEALTH CARITAS Federal Civil Lawsuit Pennsylvania Eastern District Court, Case No. 14 0 obj This docket was last retrieved on October 14, 2020. They said they would respond in court by Nov. 15. Last Friday, April 15, 2022, our office sent court-approved notice of the lawsuit to all eligible individuals who have not already joined. /ModDate (D:20211202101246-05'00') To complete and submit the form electronically, clickhere. Our mission is to help people get care, stay well, and build healthy communities. Iowas shift to privatized Medicaid is making changes that could leave Matteson without a safe option for staying in his home. /BaseFont /Helvetica >> /Tabs /S /Parent 12 0 R Medicaid pays for in-home aides. )Z9h/c The lawsuit seeks to recover unpaid overtime wages for CHC Service Coordinators employed in Pennsylvania by AmeriHealth Caritas. Over the past month the Court has issued two noteworthy Orders in this case: one lays out how the parties will deal with certain discovery issues ("Order - Representative Discovery"), and the other is a schedule for this case ("Order - Scheduling"). We are handling this case on a contingency basis. /Tabs /S /Contents [63 0 R 64 0 R 65 0 R] Despite the sharp criticism and concerns voiced publicly by lawmakers in both parties, DHS Director Jerry Foxhoven has given the agency and the private companies' overseeingMedicaid high marks. /MediaBox [0.0 0.0 612.0 792.0] /TT3 46 0 R 27 0 obj /ProcSet [/PDF /Text] /Resources << The lawsuit was filed in June on behalf of six Iowans with disabilities, who argue that the states shift to private management of Medicaid led to illegal cuts to their in-home care services. /Tabs /S /C2_0 50 0 R >> HYK0)13&iz,,B\_ A 9~O:jH,Z!W. >> /Font << /TT1 41 0 R endobj /acircumflex /atilde /adieresis /aring /ae /ccedilla /egrave /eacute /ecircumflex /edieresis /ZaDb 10 0 R Contacting us does not create an attorney-client relationship. More than 300 clinical care review workers for AmeriHealth Caritas Services LLC secured approval from a federal judge Tuesday to finalize their $4.25 million settlement resolving a collective. /Contents [73 0 R 74 0 R 75 0 R] /MediaBox [0.0 0.0 612.0 792.0] /Producer <6954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> << /Fm0 42 0 R /CropBox [0.0 0.0 612.0 792.0] /MediaBox [0.0 0.0 612.0 792.0] We have decided that we are not going to challenge AmeriHealth Caritas' removal of this lawsuit to the United States District Court. /Rotate 0 - Torres v. Brandsafway Indus. Try our Advanced Search for more refined results. << AMERIHEALTH CARITAS Labor: Fair Standards Stay ahead of the curve In the legal profession, information is the key to success. /Icircumflex /Idieresis /Eth /Ntilde /Ograve /Oacute /Ocircumflex /Otilde /Odieresis /multiply He knows where he is.. The information you obtain at this site is not, nor is it intended to be, legal advice. 28 0 obj /Resources << The list is updated frequently, so check . /Tabs /S PLEASE NOTE: A verification email will be sent to your address before you can access your trial. << SERVICES, LLC, Defendant. The Notice Form describes the lawsuit, while the Consent Form must be completed and returned by any individuals who wish to join the lawsuit. You may be eligible to make a claim under federal law if you worked over forty (40) hours per week for AmeriHealth within the past three years as a Clinical Care Reviewer, Concurrent Review Nurse, Prior Authorization Nurse, or in a similar position, and you were paid a salary. endobj Already a subscriber? /ON [4 0 R] In other words, the company alleges that its non-payment of overtime wages is legally correct and that it has not violated federal or state wage laws. 2:14-cv-00656 in the Pennsylvania Eastern District Court. /Fm5 101 0 R /TT2 41 0 R /Rotate 0 /Parent 12 0 R /Tabs /S << /CS0 [/Indexed /DeviceRGB 59 90 0 R] Pa. Jan. 20, 2023). Marty Matteson, a 39-year-old Webster City man with Down syndrome, was one of the six plaintiffs in the case. Hes better, she said. /XObject << /C2_0 50 0 R /dotlessi /lslash /oe /scaron /zcaron 160 /Euro 164 /currency 166 /Name /Helv /DR << The plaintiffs say without those services, they could be forced to move into nursing homes, violating their constitutional rights. AmeriHealth spokesman Joshua Brett said the focus of the lawsuit was the overall Iowa program and noted ithad not named AmeriHealth as a party. stream >> /RBGroups [] endobj stream As /CropBox [0.0 0.0 612.0 792.0] >> The lawsuit alleges that the plaintiff and others working as Clinical Care Reviewers are misclassified as exempt from overtime requirements under the Fair Labor Standards Act. /odieresis /divide /oslash /ugrave /uacute /ucircumflex /udieresis /yacute /thorn /ydieresis] << /Fm3 99 0 R >> 21 0 obj All significant new filings across U.S. federal district courts, updated hourly on business days. Kim Reynolds said while mistakes have been made in implementing the new management systems,she doesnt believe the state should resume management of the program. /Type /Page Federal District Judge Rebecca Goodgame Ebinger on Friday issued a ruling that concurred with the states argument that there is no evidence in the record that the issues complained of by the plaintiffs relate to other managed care organizations.. Filing 1 COMPLAINT against AmeriHealth Caritas Services, LLC ( Filing fee $ 400 receipt number 0313-14545013. AmeriHealth Caritas Louisiana has collaborated with the March of Dimes to offer Dismantling Bias in Maternal and Infant Healthcare provider training, and this training can now be accessed through the eLearning Module. @V0iSpy]O@?sD1=gHNr>Y? Hes safe. /F1 38 0 R That left Amerigroup and UnitedHealthcare to manage claims for the 600,000 Iowans in the program. Today, the Federal Judge entered a stipulated Order "conditionally certifying" this lawsuit as a "collective action." >> endobj /Font << /Annots [] /Parent 11 0 R I highly recommend contacting them to discuss your case., Order- Representative Discovery - 6/14/22. /Contents [87 0 R 88 0 R 89 0 R] /TT1 40 0 R /Count 8 No. /F1 38 0 R 20 0 obj /TT1 41 0 R To: AmeriHealth Caritas Louisiana Providers Date: October 11, 2021 Subject: Pending Lawsuit: A.A. et al. The lawsuit against Iowa was filed last year, Your California Privacy Rights/Privacy Policy. Won't Rethink Ruling Backing NC Farm Labor Law, NLRB Says Event Co. Must Assign Work To Teamsters, Replacement Steelworkers Win Class Cert. /Type /Page /Length 492 endobj >> >> Access this case on the Pennsylvania Eastern District Court's Electronic Court Filings (ECF) System. /Contents [69 0 R 70 0 R 71 0 R] /Type /Page /igrave /iacute /icircumflex /idieresis /eth /ntilde /ograve /oacute /ocircumflex /otilde /Count 7 You have to know whats happening with clients, competitors, practice areas, and industries. AmeriHealth Caritas Serving the Greater Philadelphia Area and Beyond This collective action lawsuit is going forward in the District Court for the Eastern District of Pennsylvania. He moaned,grunted and cried out as Wargo recounted the cuts AmeriHealth had ordered in the amount of in-home care it would finance under Iowas Medicaid program. /CropBox [0.0 0.0 612.0 792.0] /Filter /FlateDecode /Helv 9 0 R Multiple bills have been introduced in this years legislative session to change some of the ways Medicaid is managed, some that call for the state to again manage the program. 17-3697, see flags on bad law, and search Casetext's comprehensive legal database All State & Fed. << March of Dimes Awareness to Action: Dismantling Bias in Maternal and Infant Health Care How to Access Your eLearning Module. 30m |I+.^Hzi7wTRk vMpiF^GX#h`B ^1` stream /TT1 40 0 R The attorney generals office, which represents Foxhoven, has asked the judge to dismiss the suit. AmeriHealth Caritas is a subsidiary and/or an affiliate of AmeriHealth, Inc., a Pennsylvania corporation with . /Tabs /S No tags have been applied so far. AmeriHealth Caritas service coordinators accuse the company of violating the state's minimum wage law by failing to pay overtime in a proposed class action filed in Pennsylvania state court. )p>:\?QdAD%iB-`6DA\(( v. Dr. Courtney N. Phillips There is a class action lawsuit pending against LDH in federal court at the Middle District of Louisiana bearing the caption A.A. et al. >> >> /quotesingle 96 /grave 128 /bullet /dagger /daggerdbl /ellipsis /emdash /endash But AmeriHealth ordered her daily in-home aide hours cut to two hours, she testified. Use the links below to access additional information about this case on the US Court's PACER system. /BaseFont /Courier AmeriHealth Caritas Louisiana does that every day. to us until such time as an attorney-client relationship has been established. Have significant experience in similar matters under the [Pennsylvania Minimum Wage Act]. According to the Complaint, Clinical Care Reviewers do not satisfy any of the overtime exemptions under federal or state law. /F1 38 0 R >> /Resources << /TT0 39 0 R Learn more about our offerings, and . /TT0 39 0 R /MediaBox [0.0 0.0 612.0 792.0] Defendants. /Parent 11 0 R endstream Full-text searches on all patent complaints in federal courts. /ProcSet [/PDF /Text] /C2_0 92 0 R R. Steven Whalen, U.S. Magistrate Judge. 25 0 obj /Parent 11 0 R The departure of a controversial Medicaid management company should block a federal lawsuit against Iowas human-services director, state lawyers say. /F1 38 0 R << /TT2 41 0 R /TT0 39 0 R /Font << To join others in making a claim for overtime compensation under federal law, you must complete aPlaintiff Consent form. >> /Length 442 Though the plaintiff and similarly situated employees regularly work more than 40 hours per week, according to the complaint, they allegedly do not receive any time-and-a-half overtime wages for the hours they work above 40. /CropBox [0.0 0.0 612.0 792.0] /Parent 11 0 R Click here to login, Enter your details below and select your area(s) of interest to stay ahead of the curve and receive Law360's daily newsletters, Email (NOTE: Free email domains not supported). If you have records relating to your work with AmeriHealth, please keep them until we ask you for them. SRt@)&Y As she testified, Siegel sat in his wheelchair in the back of the courtroom, being comforted by supporters. This means we will only be paid if the lawsuit is successful in obtaining relief either through a settlement or an award, and that payment will only come out of that settlement or award. >> /MediaBox [0.0 0.0 612.0 792.0] Currently, we are working on a plan for completing "discovery," which is the phase of litigation where the parties exchange information and documents. ClassAction.org is a group of online professionals (designers, developers and writers) with years of experience in the legal industry. /MediaBox [0.0 0.0 612.0 792.0] Law360 takes your privacy seriously. /Font << /Type /Catalog >> Cox testified that she was paid $19.45 per hour, and spent much of her time at the home handling general chores, including cleaning, doing laundry and making meals for both Siegel and Wargo. Significant legal events involving law firms, companies, industries, and government agencies. But lawyers from the Iowa attorney generals office contend the ground crumbled from beneath the lawsuit last week, when the management firm AmeriHealth Caritas announced it would withdraw from Iowas Medicaid program because of a contract dispute. /ExtGState << I took a free trial but didn't get a verification email. If you suffer retaliation, you may have additional claims. /Resources << This is a pending lawsuit. >> 7 0 obj Do I Have a Qualifying Federal Law Claim? %PDF-1.6 /Tabs /S /Type /Pages A copy of the Answer is available below. x. /ProcSet [/PDF /Text] /TT2 41 0 R Direct access to case information and documents. >> << A more recent docket listing In the legal profession, information is the key to success. /TT0 39 0 R /Font << /Type /Page See below for more details on this process. You may be eligible to make a claim under state law if you worked over forty (40) hours per week for AmeriHealth as a Clinical Care Reviewer, Concurrent Review Nurse, Prior Authorization Nurse, or in a similar position, in Pennsylvania and you were paid a salary. /Fm0 96 0 R endstream /Length 3057 /Font << Disability Rights Iowa officials on Friday said its group is evaluating its next steps. /Annots [] 5 0 obj /F1 38 0 R >> /CropBox [0.0 0.0 612.0 792.0] AmeriHealth has more than 200,000 Iowa clients, including the bulk of Iowa Medicaid members who have serious disabilities. /Type /Page But Roxanne Conlin, a lawyer for the disabled plaintiffs, asked the judge to let the suit against the state move forward as a class action. /Subtype /Type1 ORDER THAT THE ABOVE ACTION IS DISMISSED WITH . /D << 16 0 obj E-MAILED To: COUNSEL on 9/9/2020 (bw, ), DEMAND for Trial by Jury by Tara L. Webb-Jones. /Tabs /S /Type /OCG >> Attorneys are either actively filing these cases or investigating to determine whether lawsuits can be filed. /Tabs /S There is no evidence in the record that the issues complained of by the plaintiffs relate to other managed care organizations, the state lawyers wrote. /Type /Pages /Parent 11 0 R >> Providers may also submit claims via the AmeriHealth Caritas NaviNet Provider Portal. 6 0 obj /Count 15 /Annots [] on behalf of six Iowans with disabilities, AmeriHealth Caritas announced it would withdraw, Your California Privacy Rights/Privacy Policy. AMERIHEALTH CARITAS SERVICES, LLC et al Case Summary On 08/26/2020 LOCKE filed a Civil Right - Employment Disability Discrimination lawsuit against AMERIHEALTH CARITAS SERVICES, LLC. Password (at least 8 characters required). We are very pleased to report that, as of today, 138 current and former CHC Service Coordinators have joined this lawsuit by returning "Consent Forms." /ordmasculine 188 /onequarter /onehalf /threequarters 192 /Agrave /Aacute /Acircumflex /Atilde /F1 38 0 R >> Kraemer called to the stand Rebecca Cox, who worked as an aide for Siegel. >> >> /TT0 39 0 R /Name (Adobe Fill & Sign) /C2_0 86 0 R /C2_0 50 0 R Hes now managed by UnitedHealthcare. /Rotate 0 /ProcSet [/PDF /Text] Court File No. 2 0 obj >g+Y(RhxSa.SM1ZjLLKkIS=Y!q8dL's%w$@/TE. endobj >> /CropBox [0.0 0.0 612.0 792.0] Before commenting, please review our comment policy. Disability Rights lawyers declined comment Monday on the states contention that AmeriHealths departure from the state should lead to dismissal of their lawsuit. endobj /CropBox [0 0 612 792] >> AmeriHealth last year reducedMattesons daily payments for care by 37 percent, from $274 to $173. << This is a collective and class action brought byindividual and representative Plaintiff Ann Wood ("Plaintiff"), on behalf of herself and ll others similarly situated,a to recover . /MediaBox [0.0 0.0 612.0 792.0] /ProcSet [/PDF /Text] /TT2 41 0 R endobj One of them was Melinda Fisher of Cedar Rapids, who has a severe form of multiple sclerosis. /Subtype /XML A `` collective action. intelligence you need to remain an expert and beat the competition ) &... And case alerts on organizations, industries, and customized search queries O?... Obj this docket was last retrieved on October 14, 2020 612.0 792.0 filed! Updated frequently, so check? TBP+074zt72 * CnFIs:!, bE2|Hu @ Mn W'... 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