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HomeMy WebLinkAbout97-02678 ~ ~ Cj 1-. ~ u { .... " t ~ ~ =' ~ ~ ~ ~ ~ l ... ~ ..... . .. .::1 .. '-J , t', 0'- . C)' ';:> ~ '.:) .... "" 1-- .,t -, 1-' .. .' i (', , - UJ. . (), " To ct. ~i, c. " " . .u I i", LUlL . ii:j Et'~ L' , (: 1.0, "1:- C! .....; 1<. r- ~j 0 ~ U >- ..:I' 9;; tr. (; I~ w~.: r. ,- C1-'- ';~ frL J:i.:~ 0- ,..) ;~l: "- ~' ,j;:.i " <:n ,>- Ll .:') -' :-.... u.:;-; - .,- :;z F .....,'":; d'J :<: __'oJ a.. tL r- .'. 0 ::) a- u 2- ~IQ ~ ~ ~ ct: - ~ ~ \ ~ B' ., g ~ 1- ~ J" ~ <0 "l. ,.2'- '~ ~~ >. '" G c; .. <" .. ,.. r:: .,.) .. lUQ 1):'::; fr" -- , .,. , . ,,- "'~. .L L.. ~r. a. ": ~::! c" ~[.: ;'ti')' 1 '1 ~. ~ ,.... :l:'?:- rz::l!: t.:> " 'HI ',- =' ;.'1:.i... r- 0:: '-;": ,.. u. r- -'1 0 en () z < ~ o I:; ~ = ~ oll tii '" ... N !;;::8 - ... 0 K act~j iI < ;: 0 j~~o: ~z c= '" ~ .. Ul ::c . . i j; 0", ;:: - ~ ~ > .- ~ - ~ .- , w ~ 6 ~ E o w . ~ ; ~ . ;; . < :: >- -' Co '.~ C i~':': ~:~:5 lU';.; - , , . : ~~}: ' r.: \ .. ,,- to.. .k~:] (/ .'''- " f.... '.l~i") C~. I ';.:< " : " -~ , ,- <i;:-j ~ .L. e ,~W- j.., C:.: ..~ I " r- ".1 0 C., {,) ~ t;; C'J >- C C,: e:" .-'i 1-- .::; C' :'-:-,:~ 11J. . ( '\-- ~r.: -'.,'" It" w.. " ~ ,1..'r C,.J(", ,-. ~ /.'? Ci, 1 ',,-, Lll ~ -, ..... ,. -. ~ 1'- " !~J u... f.': c..; 1:!i...4. <.:; :.' l'_ r- (~ o. U -.. ..ll (: ;'.- --, .i~ ~~ ,. - . I L' -- >' (,~ ( , ~ . , , ".j Cr" , if) C.) , . t...: I- rj,lJ . C~ , .. I CO L.~ 1- .'"S Cj '"''' U . , , l,' I , , , , {'~ ) : .. , ! - I .. .. z < '" c .. '" ~ 0 t: .. ::E 0 a w 1: . ~<lll ~ ~ III '" < ~ ~ ~ = " < > lo. = . i - !:: 0<"- ~ ... . 31 ~ ;: 0 . w . . j tIl ! .: ~ 0 = ciz d L . ~ '" " 1= ft - . . " .. . ... < :c = . . MJ Mall, Carlisle, Cumberland County, Pennsylvania. 4. On May 28, 1995, at approximately 12:30 p.m., Plaintiff Lake entered Defendant Hills Department Store as a business invitee. 5. Throughout the day of May 28, 1995, it had been raining or drizzling. 6. As a result of the rainy day, the floor inside the door had accumulated an amount of water. 7. Plaintiff Lake entered Defendant Hills Department Store through a front door and as she entered and placed her foot on the floor she slipped as a result of the accumulation of water on the floor. Plaintiff Lake fell forward onto her outstretched palms and then on her right knee. The door then struck her in the back. D1IMAGES 8. As a direct and proximate result of falling on May 28, 1995, Plaintiff Lake suffered severe injuries, an aggravation to pre-existing conditions, that resulted in substantial medical care and treatment, which injuries, and aggravation to pre-existing conditions, complications, and treatment include but are not limited to, the following: a. Left chest contusion; b. Right knee contusion; c. Bilateral carpal tunnel syndrome; d. Right forearm pronator syndrome; e. Right knee lateral collateral ligament sprain; 4 f. Right knee patellar femoral syndrome; g. Right knee degenerative joint disease; h. Myofacial syndrome; i. Chronic back pain; j. Chronic pain syndrome; k. Permanent chronic pain in both upper extremities; 1. Extensive physical therapy with respect to bilateral carpal tunnel syndrome and right knee pain; m. Right carpal tunnel operative release; n. Right pronator syndrome operative release; and o. Revised left carpal tunnel surgery. 9. As a direct and proximate result of the injuries and complications thereof resulting from falling on May 28, ~995, (hereinafter the "injuries at issue in this case"), Plaintiff Lake has incurred medical expenses to date in excess of $27,000.00 and will continue to incur medical expenses for treatment and therapy in the future. ~O. As a direct and proximate result of the injuries at issue in this case, Plaintiff Lake has endured pain, suffering, and the loss of life's pleasures, and will continue to endure pain, suffering, and the loss of life's pleasures into the future. ~1. As a direct and proximate result of the injuries at issue in this case, Plaintiff Lake has and will continue to be limited in her normal daily activities. 12. As a direct and proximate result of the injuries at issue in this case, Plaintiff Lake has and will continue to suffer 5 impairment to her general health, strength and vitality. 13. As a direct and proximate result of the injuries at issue in this case, Plaintiff Lake has and will be obligated to receive and undergo medical attention and care, and she will incur various expenses for medical treatment and will be obligated to continue to expend such sums for an indefinite time in the future. 14. As a direct and proximate result of the injuries at issue in this case, Plaintiff Lake has and hereinafter may incur other expenses or losses for which she claims to the extent permitted by applicable law. LIABILITY 15. The injuries at issue in this case and the damages suffered by Plaintiff Lake as set forth herein, are the direct and proximate result of Defendant Hills Department Store being negligent, careless, and reckless by: a. Failing to maintain the entrance to the store where this incident took place in a reasonably safe condition with respect to the water that had accumulated thereon; b. Failing to properly remove the water that had accumulated in the entrance area to the store where this incident took place; c. Failing to correct the dangerous condition which it had created or permitted to exist; d. Failing to inspect the entrance area to the store where this incident took place to discover the dangerously wet 6 and slippery condition; e. Failing to provide adequate warning or notice for an individual entering the front door to the store of the wet slippery floor condition then existing; f. Failing to adequately warn or notify the Plaintiff of the dangerous condition in the entrance area to the store where this incident took place; g. Failing to correct a dangerous condition by providing carpeting or matting located in the entrance area to the store where this incident took place. 16. The dangerously wet and slippery condition of the entrance area to Defendant Hills Department Store existed long enough to be discovered by Defendant and its agents or employees and long enough to be remedied by Defendant through the exercise of reasonable care. 17. The wet and slippery condition of the entrance area to the store where this incident took place was such that Defendant Hills Department Store should have foreseen that someone could or would be injured as a result of this dangerous condition. 18. Employees and/or agents of Defendant Hills Department Store observed or should have observed the dangerously slippery condition of the entrance area to the store where this incident took place prior to Plaintiff Lake's fall and failed to warn of or correct the dangerous condition. 19. Defendant Hills Department Store, its agents and employees knew or should have known that the floor at the site of 7 this incident was slippery when wet. 20. The aforesaid accident was caused solely by the negligence, carelessness, and recklessness of Defendant Hills Department Store and/or its agents, as aforesaid, and was in no manner due to any act or failure to act on the part of Plaintiff Lake. 21. Plaintiff Lake acted reasonably at all time relevant to this accident. 22. Defendant Hills Department Store, its agents and employees knew or by the exercise of reasonable care would have discovered the wet floor condition at issue in this case, and should have realized that it involved an unreasonable risk of harm to persons such as Plaintiff Lake entering the premise. 23. Defendant Hills Department Store, its agents and employees should have expected that its business invitees would not discover or realize the danger described herein, or would fail to protect themselves against it. 24. Defendant Hills Department Store, its agents and employees failed to exercise reasonable care as set forth herein to protect Plaintiff Lake against the dangerous conditions described herein. WHEREFORE, Plaintiff Dorian Lake demands judgment against Defendant Hills Department Store in an amount in excess of the B asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. 4. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. 5. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. 6. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. 7. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. -2- ALLEGED DAMAGES 8. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. Defendant specifically denies each and every allegation set forth in paragraph 8 with relation to injuries, and the aggravation to pre-existing conditions, complications and treatment, the same being expressly denied, including, but not limited to, the allegations set forth in sub- paragraphs (a) through (0), and strict proof of each and every allegation contained within the paragraph is demanded at the time of trial. 9. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and -3- accordingly, the same are denied and strict proof thereof is demanded at time of trial. 10. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. 11. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. 12. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and -4- accordingly, the same are denied and strict proof thereof is demanded at time of trial. 13. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. 14. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. LIABILITY 15. Denied. The allegations of negligence, carelessness, and recklessness set forth in this paragraph, together with its sub-parts a through g are specifically denied, and strict proof thereof is demanded at the time of trial. By way of further -5- answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. To the contrary, at all relevant times to the material allegations set forth in Plaintiff's Complaint, Defendant acted with reasonable care under the circumstances. By way of further answer: a. Defendant specifically denies failing to maintain the entrance to the store where this incident took place in a reasonably safe condition with respect to the water that had accumulated thereon; b. Defendant specifically denies failing to properly remove the water that had accumulated in the entrance area to the store where this incident took place; c. Defendant specifically denies failing to correct the dangerous condition which it had created or permitted to exist; d. Defendant specifically denies failing to inspect the entrance area to the store where this incident took place to discover the dangerously wet and slippery condition; e. Defendant specifically denies failing to provide adequate warning or notice for an individual entering the front door to the store of the wet, slippery floor condition then existing; -6- f. Defendant specifically denies failing to adequately warn or notify the Plaintiff of dangerous condition in the entrance area of the store where this incident took place; g. Defendant specifically denies failing to correct a dangerous condition by providing carpeting or matting located in the entrance area to the store where this incident took place. 16. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. It is specifically denied that there existed any sort of dangerous, wet or slippery condition of the entrance area to Defendant Hills Department Store, and strict proof thereof is demanded at time of trial. 17. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. It is further specifically denied -7- that there existed any wet and/or slippery and/or dangerous condition of the entrance area to the store at any relevant time and strict proof thereof is demanded at the time of trial. 18. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. It is specifically denied that there existed a dangerous and/or slippery condition of the entrance area to the store at any relevant time, and strict proof thereof is demanded at time of trial. 19. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. Further, it is specifically denied that the floor at the site of the incident in question was slippery or wet at any relevant time, and strict proof thereof is demanded at time of trial. -8- 20. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. 21. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. By way of further answer, it is specifically denied that Plaintiff Lake acted reasonably at any time relevant to the events set forth in her complaint, and strict proof thereof is demanded at the time of trial. 22. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and -9- accordingly, the same are denied and strict proof thereof is demanded at time of trial. It is further specifically denied that the floor at issue in this case was wet at any relevant time, and strict proof thereof is demanded at the time of trial. 23. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. By way of further answer, it is specifically denied that there existed any danger in any portion of Defendant's store, including but not limited to the danger alleged in Plaintiff's Complaint, at any time relevant to Plaintiff's complaint. 24. Denied. Defendant lacks knowledge and/or information sufficient to form a belief as to the truth of the matter asserted, and therefore, this allegation is denied and strict proof thereof is demanded at the time of trial. By way of further answer, if it is determined that this paragraph sets forth conclusions of law, no responsive pleading is required, and accordingly, the same are denied and strict proof thereof is demanded at time of trial. By way of further answer, it is specifically denied that there existed any danger in any portion -10- of Defendant's store, including but not limited to the danger alleged in Plaintiff/s Complaint, at any time relevant to Plaintiff's complaint. WHEREFORE, Defendant Hills Department Store Company demands judgment in its favor and against Plaintiff, together with such other relief as this court shall deem appropriate. NEW MATTER DIRECTED TO PLAINTIFF 25. Defendant hereby incorporates by reference, as if set forth at length herein, its responses to Plaintiff's Complaint set forth in paragraphs 1 through 24 above. 26. Plaintiff was contributorily negligent. 27. Plaintiff assumed the risk for all of her activities on or about May 28, 1995. 28. Plaintiff's comparative negligence was a substantial factor in bringing about any injuries and/or damages alleged in her Complaint. 29. In the event that Plaintiff was injured and/or damaged as alleged, which allegations are specifically denied, said injuries and/or damages were caused by the actions and/or inactions of Plaintiff and/or others over whom Defendant had no control or right of control. 30. Plaintiff/s injuries and/or damages, the existence of which are specifically denied, pre-existed the incident giving -11- rise to this litigation and/or were caused by events prior or subsequent to the events alleged in Plaintiff's Complaint. 31. Plaintiff was not a business invitee on May 28, 1995 at the Hills Department Store located at the M.J. Mall in Carlisle, Cumberland County, Pennsylvania. 32. Plaintiff has failed to state a cause of action upon which relief can be granted. 33. Plaintiff's claims are barred by the applicable provisions of the Pennsylvania Workers' Compensation Statute. 34. Plaintiff knowingly and voluntarily assumed a risk of all injuries described in her Complaint and knowingly and voluntarily exposed herself to an open and obvious danger, if such danger is found to have existed. 35. Defendant owed Plaintiff no duty of care under the circumstances alleged in Plaintiff's Complaint. 36. Plaintiff's claims are barred by the applicable Statute of Limitations. 37. Plaintiff's negligence was the sole and proximate cause of the injuries and/or damages described by Plaintiff in her Complaint. 38. Defendant had neither actual nor constructive notice of any alleged defective condition existing upon its premises, any such defective condition being expressly denied. 39. Plaintiff's claims are barred and/or limited by the Pennsylvania Comparative Negligence Act. -12- 40. Plaintiff's claims are barred and/or limited by the doctrine of res judicata and/or collateral estoppel. 41. Plaintiff failed to mitigate her damages. 42. Defendant breached no duty of care owed to Plaintiff under the circumstances alleged by Plaintiff in her Complaint. 43. No act or omission on the part of Defendant or its representative was a substantial contributing factor in causing and/or contributing to the losses and/or damages described by Plaintiff in her Complaint, any and all such losses and/or damages being specifically denied. 44. Plaintiff had available to her alternative paths which she did not use. 45. No dangerous or defective condition averred to in Plaintiff's Complaint existed at all the times material to Plaintiff's Complaint. 46. In the alternative, if said dangerous or defective condition did exist, then Defendant had no notice nor cause to notice said defective or dangerous condition. 47. While this investigation is continuing, if it is determined that some intervening or superseding cause contributed to or caused Plaintiff's alleged accident, then Answering Defendant denies liability. 48. Plaintiff's accident as alleged in her Complaint did not occur. -13- ~ 0 ~ I~ ..:J "". .. e'</' CO') ::S'? .~ ( ;~ .~ ~ C,1~ 0 \tl ....ll) I'; I "1- <I. 'iJ~ l') c:l :{) L l.IJ F l&... ~ l:J ~ en u /ulr/lake/plead/relpon8e,nm 2.'." d.b business invitee in that she was entering the store as customer or potential customer of Defendant Hills. 32. Denied. The allegations in Paragraph 32 state legal conclusions to which no response is required. 33. Denied. The allegations in Paragraph 33 state legal conclusions to which no response is required. Further, it is specifically denied that the Workers' Compensation Statute has anything to do with this case, in that the Plaintiff, Dorian Lake, was not employed by Defendant and was not acting in the course of employment of anyone at the time that this incident occurred. 34. Denied. The allegations of Paragraph 34 state legal conclusions to which no response is required. To the extent the allegations in Paragraph 34 are deemed to be factual, they are denied pursuant to Pa.R.C.P. l029(e). 35. Denied. The allegations of Paragraph 35 state legal conclusions to which no response is required. It is specifically denied that Defendant Hills owed no duty of care to Plaintiff. Rather, as set forth in the Complaint, Defendant Hills owed a duty of care to Plaintiff. 36. The allegations of Paragraph conclusions to which no response is required. 36 state legal It is specifically 2 lu.r/llke/pleld/re.pon.e,nm 2.'." dab denied that the Plaintiff's claims are barred by the Statute of Limitations, in that Plaintiff timely filed a suit. 37. Denied. The allegations of Paragraph 37 state legal conclusions to which no response is required. To the extent the allegations in Paragraph 37 are deemed to be factual, they are denied pursuant to Pa.R.C.P. 1029(e). 38. Denied. The allegations of Paragraph 38 are denied pursuant to Pa.R.C.P. 1029(e). 39. Denied. The allegations of Paragraph 39 state legal conclusions to which no response is required. To the extent the allegations in Paragraph 34 are deemed to be factual, they are denied pursuant to Pa.R.C.P. 1029(e). 40. Denied. The allegations of Paragraph 40 state legal conclusions to which no response is required. To the extent the allegations in Paragraph 34 are deemed to be factual, they are denied pursuant to Pa.R.C.P. 1029(e). 41. Denied. The allegations of Paragraph 41 state legal conclusions to which no response is required. To the extent the allegations in Paragraph 34 are deemed to be factual, they are denied pursuant to Pa.R.C.P. 1029(e). 3 lu.r/l.ke/ph'.d/r..ponu,ntll 2."" d.b 42. Denied. The allegations of Paragraph 42 are denied pursuant to Pa.R.C.P. l029(e). 43. Denied. The allegations of Paragraph 43 state legal conclusions to which no response is required. To the extent the allegations in Paragraph 34 are deemed to be factual, they are denied pursuant to Pa.R.C.P. l029(e). 44. Denied. The allegations of Paragraph 44 are denied pursuant to Pa.R.C.P. l029(e). By way of further answer, Plaintiff avers that whether she had alternative paths in this case is not relevant. Plaintiff was using a public entrance to the Hills Store that was held open to the public as their entrance for use by customers and others using the Hills Store. Further, under conditions then and there existing, Plaintiff had no reason to consider an alternative path, not being aware of the dangerous conditions existing at the site of the incident at issue in this case. 45-46. Denied. The allegations of Paragraphs 45 and 46 are denied pursuant to Pa.R.C.P. l029(e). 47. Denied. The allegations of Paragraph 47 state legal conclusions to which no response is required. To the extent the allegations in Paragraph 34 are deemed to be factual, they are denied pursuant to Pa.R.C.P. l029(e). 4 ~ 0' '~ c.c, U'. l, ." ::; >-- ~ " \'_l~~ ~ :!, L")-. --. , \- t . . 1-- t_ I." CJ~' ,e) , 0 ,- ,,, .' \;.~ ..' :"7~ '. . r. .' \~j u- \.... ~ : ~ \- \. t" l.-~ ,t, (J.l :.J (J 0' U ~ CI >- N Z ,- r. --"J luR 15::': ~6 :c u:~ .-t '" c... ", ~t) ".:.. 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