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Home My WebLink About00-07730 . TW4lll'~ . JACOB MILLER, APPELLANT V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, APPELLEE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7730 CIVIL TERM ORDER OF COURT ~ AND NOW, this day of November, 2000, a hearing on the within appeal from the suspension of driving privileges shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania, at 1 :30 p.m., Monday, February 12, 2001. This appeal shall act as a supersedeas for the action by the Department. :saa VdYc leWf-S q I <-{ - 331-5 <f'5CJ I'''' ,'~,~ , I ~' . .-\ B th .c J, .y e ourt,. / , / ~~ 1/ -$'-00 1<Ks '~'=~I' " ~ " ~ ---',-.,.- ii,",;'--',-<.--- . II 4 ,t ,'d"",,~_ "-,: " .,,' '0 ;"<,_~".-,~~__., '-" ,,~ " , "",~_~,,~_"_, ,,~,_ _". ,~ _,-,",YO .,,;,-....I~;,;., hiju "-L"',,jl~;'_ '--= " - >",- r"_ '",,~__, _,-.~ - ,~-,- ,. ---";",J_'. ~81_ *-- ~ ~-- ~~lIiIti.J ,...""",r...~'~ll!iilIiIil ~ '. . "'lMliIill1 r:-:l.E:fJ--OfF/CE 0,' ""-'('~'T'JC;!'!07ARY ClONOV~7 PN 4:23 CUMBEI'1u,,"'VO COUNTY PENNSYLVANIA -~ ". =- , 'H""O "-, ., '. Peters, Lindsay, Lewis and Hatheway Don Lewis, Esq. 311 Walnut Street Meadville, Pennsylvania 16335 (814) 337-5443 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION--LAW JACOB MILLER, Appellant vs. A.D. No. 2000-'713D CiuJ I~ COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, Appellee PETITION TO APPEAL DRIVERS LICENSE SUSPENSION AND TO GRANT STAY OF EXECUTION OF DRIVING PRIVILEGES AND NOW, this 9th day of October, 2000, comes the Appellant, Jacob Miller, by and through his Attorney, Don Lewis, Esq., of the law offices of Peters, Lindsay, Lewis & Hatheway, and moves this Honorable Court and the Commonwealth of Pennsylvania, Department of Transportation to take notice that he is appealing his suspension of his drivers license imposed by this Court on 9/12/2000. The Appellant further requests for this Honorable Court to grant a stay of execution of his driving privileges and not suspend his driving privileges until this matter is ultimately resolved, and, in support hereof represents as follows: 1. The Defendant was arrested on or about September 6, 2000 for Driving Under Alcohol Related Suspension. 2. At the time of the summary trial, the Defendant plead guilty. 3. The Court ordered that the Defendant's Notice of Appeal must be filed within thirty (30) days from September 12, 2000. The Defendant filed his Notice of Appeal on October 5, 2000 via U.S. Certified Mail - Return Receipt Requested. 4. Since the Defendant is appealing his case, he is requesting for this Court to grant to him a stay of execution of his driving privileges until the Court issues its decision in this matter. ,- ,. ~,"" - , '~~I' .. '. ,. -~, -"{'" ...,..,~ "'- ~--", - ',~ , " -~, ~" ", .. " WHEREFORE, for the above reasons, the Defendant respectfully requests for this Honorable Court to grant a Stay of Execution of his driving privileges until the Court issues its decision in this case. Respectfully Submitted, PETERS, LINDSAY, LEWIS & HATHEWAY By: , Esq. for Appellant ",","-, T "-.- "- -"; ~'_~_'-" -'00-)"0'- ~,--:__"Ioo- --~ ,,~,' -~,'I ~ fo ,.- COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Harrisburg, PA 17123 SEPTEMBER 14, 2000 JACOB N MILLER 951.2 CARMEN RD 002519283713386 001 09/07/2000 20983892 12/21/1963 HARTSTOWN PA 16131 LICENSE IN BUREAU Dear Motorist: As a result of your conviction on 09/06/2000 of violat- ing section 1571 of the Vehicle Code VIOLS CONCERNING LI- CENSES on 09/06/2000, 3 points have been assigned to your record. Section 1544 of the Vehicle Code requires the Department to extend any existing suspension/revocation at the rate of five days for each additional point. Therefore, an addi- tional sanction of 15 DAVCS) is imposed. The effective date of suspension is 11/04/2000, 12:01 a.m. The above mentioned sanction is in addition to any pre- viously issued sanctionCs). APPEAL Vou have the right to appeal this action to the Court of Common Pleas CCivil Division) within 3D days of the mail date of this letter, SEPTEMBER 14, 2000. If yOU file an appeal in the County Court, the Court will give yOU a time- stamped certified copy of the appeal. Send this time- stamped certified copy of the appeal by certified mail to: PENNSYLVANIA DEPARTMENT OF TRANSPORTATION OFFICE OF CHIEF COUNSEL THIRD FLOOR; RIVERFRONT OFFICE CENTER HARRISBURG, PA. 17104-2516 -\., - , , , ---I ~~ ; I"F ',.< ,.. . . ~ 002519283713386 SEND FEE/LICENSE/DL-16LC/TO: Department of Transportation Bureau of Driver Licensing P.O. Box 68693 Harrisburg, PA 17106-8693 ,~ - ,~, "" . o.~, I' ~ Sincerely, ~~,~ Rebecca L. Bickley, Director Bureau of Driver Licensing INFORMATION (7:00 IN STATE OUT-OF-STATE TDD IN STATE TOO OUT-OF-STATE --, AM TO 9:00 PM) 1-800-932-4600 717-391-6.190 1-800-228-0676 717-391-6191 " ; '. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: SEPTEMBER 20, 2000 JACOB N MILLER 9562 CARMEN RD WID I 002579283873090 001 PROCESSING DATE 09/13/2000 DRIVER LICENSE I 20983892 DATE OF BIRTH 12/21/1963 HARTSTOWN PA 16131 LICENSE IN BUREAU Dear MR. MILLER: This is an Official Notice of the Suspension of your Driving Privilege as authorized by Section 1543 of the Pennsylvania Vehicle Code. As a result of your 09/12/2000 conviction of violating Section 1543B of the Vehicle Code DRVNG UNDR ALCHOL REL SUS on 09/06/2000: . Your driving privilege is SUSPENDED for a period of 1 YEARCS) effective 11/19/2000 at 12:01 a.m. This suspension is in addition to any other suspensions al- ready on your record. PROVIDING PROOF OF INSURANCE Within the last 30 days of your suspension, we will send you a letter aSking that you provide proof of insurance at that time. This letter will list acceptable documents and what will be needed if you do not own a vehicle registered in Pennsylvania. Important: Please make sure that PennDOT is notified if you move from your current address. You may notify PennDOT of your address change by calling any of the phone numbers listed at the end of this letter. ~.J .".."...,,1 I -._~,--- -"- , '. 002579283873090 APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date of th-is letter, SEPTEMBER 20, 2000. If you file an appeal in the County Court, the Court will give yOU a time- stamped certified copy of the appeal. Send this time- stamped certified copy of the appeal by certified mail to: PENNSYLVANIA DEPARTMENT OF TRANSPORTATION OFFICE OF CHIEF COUNSEL THIRD FLOOR, RIVERFRONT OFFICE CENTER HARRISBURG, PA. 17104-2516 Remember, this is an OFFICIAL NOTICE OF SUSPENSION. Sincerely, ~~\~ Rebecca L. Bickley, Director Bureau of Driver Licensing SEND FEE/LICENSE/DL-16LC/TO: Department of Transportation Bureau of Driver Licensing P.O. Box 68693 Harrisburg, PA 17106-8693 INFORMATION (7:00 IN STATE OUT-OF-STATE TOO IN STATE TOO OUT-OF-STATE AM TO 9:00 PM) 1-800-932-4600 717-391-6190 1-800-228-0676 717-391-6191 -.., ...., VERIFICATION I, Jacob Miller, Appellant in this case, do hereby verify that the facts and averments contained in my petition to Appeal Driver's License Suspension and to Grant Stay of Execution of Driving Privileges are true and correct to the best of my knowledge, information and belief. I make this verification knowing that false statements contained in my petition will subject me to the penalties of 18 Pa.C.S.A. Sec. 4904 of the Pennsylvania Crimes Code relating to unsworn false statements to authorities. By: Date: October 6, 2000 . ~ : <, ", " ,~I ~'." '-~ ,- , , '-~- ,"--- [/< ,". CERTIFICATE OF SERVICE I, Don Lewis, Esq., Attorney for the Appellant, Jacob Miller, do hereby certify that I served a true and correct copy of the Appellant's Petition to Appeal Drivers License Suspension and to Grant Stay of Execution of Driving Privileges upon the following and in the following manner on October 9, 2000: Commonwealth of Pennsylvania Department of Transportation Office of the Chief Counsel Room 103 Transportation and Safety Building Harrisburg, PA 17120 and Commonwealth of Pennsylvania Department of Transportation Att: william Kuhar, Esq. State Office Building 300 Liberty Avenue Pittsburgh, PA 15222 By: PETERS, LINDSAY, LEWIS & HATHEWAY . Date: October 9, 2000 '. ,- -"~"I = - , ~ ~ ~ I, .. ... -,- ,^-.-~-"-'-~. ~~-'- ~ ~ ~~~~.o , M. D ':) ~ v C (J g I ' ~(\tJ~ (-i- ~ '^ __,,,,, _", '__~~'='~ 'a<<.,''''f,''''.<c,'_'^,',_.,''''' c,L " . _.1!. 'A" - -. -- , -'~" ,. . ~~'o' ~_H"h () c: ;;;:: 'V ,"'P rn r:: Z_..., :z:rM ,~~> v.."z__ ~6 ~O >~ ~ ~~~~~~~, -~,"~~,"r!'~"o, o a o n --4 W (:J 'Yl t\;:l;;~ ~3t:; 1_~_) (~) -c'''Tl "-'-n 1::;P5 ~:~'fn 9 ."" ~ -0 ''..:? :..n "M . '~f 9 ,P',IJJ'JE"" ""~'!"~ JACOB MILLER, APPELLANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, APPELLEE 00-7730 CIVIL TERM ORDER OF COURT AND NOW, this 2/l-t. day of November, 2000, it appearing from the record that the within appeal of Jacob Miller filed on October 31,2000, (1) from a notice of suspension of operating privilege for 15 days for a violation of Section 1571 of the Vehicle Code, that was mailed by the Department of Transportation on September 14, 2000, and (2) from the notice of suspension of operating privilege for one year for a violation of Section 1543(b) of the Vehicle Code, that was mailed by the Department of Transportation on September 20, 2000, was filed more than thirty (30) days from the date of both notices of suspension, and no petition to appeal nunc pro tunc was filed, IT 15 ORDERED that the last paragraph of the scheduling order of November 6, 2000, which states that "This appeal shall act as a supersedeas for the action by the Department," 15 VACATED. Edgar B. Bayley, J. LopUD 11\' II - J, <j{ -or; RK.g George Kabusk, Esquire For the Department of Transportation Jacob Miller 9562 Carmen Road Hartstown, PA 16131 :saa -~f'! . .- -..,.~ - - I ." " '-, '-~-', '" ~~ ~~lM!"t1J.Xiliaj;f<dj;HIii,~'44,%li,..r,;",\"';,;j;f,{I"';~'t;j,fj,;,i,,"-~_'"'"''_:;''''''',l'~~liI~ni.l'i!.i-' '" -. Il -~. " <.~~ j ;.:> c'~ '"S~~ 'S~:.:~'B- ,-~::0 '0 f,~. _~~ _~:~~:.: {\, ,- /~;j~~ ,""';:::;: , 'r-./~ :--.. ~}('/./ ,,0;:;: " (j , -- ^ '''''~'''Il!'~~-'' . !II ~mi;~~ ' , IIfilMIit I II ii 11 i . ~ \ COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION OFFICE OF CHIEF COUNSEL VEIDCLE & TRAFFIC LAW DIVISION RIVERFRONT OFFICE CENTER-THIRD FLOOR 1101 SOUTH FRONT STREET HARRISBURG, PENNSYL VANIA 17104-2516 TELEPHONE: (717) 787-2830 FAX: (717) 705-1122 November 14, 2000 Honorable Edgar B. Bayley, Judge Court of Common Pleas, Cumberland County Cumberland County Courthouse 1 Courthouse Square Carlisle,PA 17013-3387 Re: Jacob Miller v. Cornrnw. ofPa., DOT, BDL, 2000-7730 Civil, License Suspension Appeal Dear Judge Bayley: The above mentioned licensee filed a license suspension appeal from a notice dated September 14, 2000, sent by the Department of Transportation informing the licensee that as a result the licensee's conviction on September 6, 2000 of a violation of Section 1571 of the Vehicle Code, Violations Concerning Licenses, on September 6, 2000, the petitioner's operating privilege was being suspended for an additional period of 15 days effective November 4,2000. Additionally, the above mentioned licensee filed a license suspension appeal from a notice dated September 20, 2000, sent by the Department of Transportation informing the licensee that as a result of the licensee's conviction on September 12, 2000 of a violation of Section l543B of the Vehicle Code, Driving Under Alcohol Related Suspension, on September 6, 2000 the petitioner's operating privilege was suspended for a period of one year effective November 19, 2000. The two suspensions were filed in one appeal on October 31, 2000. This Honorable Court issued an Order dated November 6th of2000. That Order reads: AND NOW, this 6th day of November, 2000, a hearing on the within appeal from the suspension of driving privileges shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 1 :30 p.m., Monday, February 12, 2001. This appeal shall act as a supersedeas for the action by the Department. :I"f";'~_",,,," , I ....., , In this case, the appeal was not filed within 30 days of the mailing date of the Department's Notices of Suspension. The notice of suspension dated September 14, 2000 was required to be filed by October 16, 2000 and the notice of suspension dated September 20, 2000 was required to be filed by October 20, 2000. The appeal in this matter was not filed until October 31, 2000. The appeal is untimelv. An appeal of a license suspension must be filed within 30 days of the mailing date of the Department's Notice of Suspension. See 75 Pa. C.S. ~ 1550 and 42 Pa. C.S. ~~ 5571, 5572; Bye v. Departmellt of Transportation, Bureau of Driver Licensing, 147 Pa. Commw. 205, 607 A.2d 325 (1992). Failure to file the appeal within the thirty-day appeal period deprives the court of jurisdiction to entertain the merits of the case. See Departmellt of Transportation, Bureau of Motor Vehicles v. Shemer, 157 Pa. Commw. 380, 629 A.2d 1063 (1993), appeal denied, 536 Pa. 635,637 A.2d 294 (1993), (appeal quashed when filed one day after the expiration of the 30 day appeal period.). An appeal nunc pro tunc may only be allowed when there is proof of extraordinary circumstances involving fraud or breakdown of administrative or judicial system which causes the late filing. Maxion v. Department of Transportation, Bureau of Driver Licensing, 728 A.2d 442 (pa. Cmwlth. 1999); Kulick v. Department of Transportation, Bureau of Driver Licensing, 666 A.2d 1148 (pa Cmwlth. 1995), appeal denied, 544 Pa. 616, 674 A.2d 1077 (1996); Department of Transportation, Bureau of Traffic Safety v. Rick, 75 Pa. Commw. 514, 462 A.2d 902 (1983). The petitioner did not file a nunc pro tunc appeal nor allege grounds for granting an appeal nunc pro tunc. I respectfully request that based upon the appeal being filed untimely the Order of November 6,2000 in regard to the issuance of the supersedeas be vacated. Sincerely, /i~wc George H. Kabusk Assistant Counsel cc: Don Lewis, Esquire, Peter, Lindsay, Lewis & Hatheway, 311 Walnut Street, Meadville, Pennsylvania 16335. Francis P. Bach, Assistant Counsel in Charge, Vehicle and Traffic Law Division "]f" '-, ~-I Generally, the filing of a timely Petition for Appeal acts as an automatic supersedeas in most license suspension and revocation appeals. Section 1550 of the Vehicle Code states, in part: !~'-'"~' 1550. Judicial review (a) General rule. Any person who has been denied a driver's license, whose driver's license has been canceled or whose operating privilege has been recalled, suspended, revoked or disqualified by the department shall have the right to appeal to the court vested with jurisdiction of such appeals by or pursuant to Title 42 (relating to judiciary and judicial procedure). The appellant shall serve a copy of the petition for appeal, together with a copy of the notice of the action from which the appeal has been taken, upon the department's legal office. (b) Supersedeas. (I) (i) Except as provided in subparagraphs (ii) and (iii), filing and service of a petition for appeal from a suspension or revocation shall operate as a supersedeas until final determination of the matter by the court vested with the jurisdiction of such appeals. (ii) The filing and service of a petition for appeal from a denial, recall, suspension or cancellation of a driver's license under section 1503 (relating to persons ineligible for licensing; license issuance to minors; junior driver's license), 1504 (relating to classes of licenses), 1509 (relating to qualifications for school bus driver endorsement), 1514 (relating to expiration and renewal of drivers' licenses), 1519 (relating to determination of incompetency) or 1572 (relating to cancellation of driver's license) shall not act as a supersedeas unless ordered by the court after a hearing attended by the petitioner. (iii) Further review by another court shall not operate as a supersedeas unless a court of competent jurisdiction determines otherwise. (2) In the case of a disqualification of the commercial operating privilege, the driver may petition to the court of common pleas of his county of residence, which court may grant a supersedeas ex parte upon a showing of reasonable likelihood of successful prosecution of the appeal 75 Pa. C.S. 9 1550. --I '. .. Don Lewis, Esquire 311 Walnut Street Meadville, PA 16335 814/337-5443 NOV16~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW JACOB MILLER, ,. Appellant A.D. No. 2000 - l'l30 vs. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, Appellee ORDER AND NOW, this ttt day of November, 2000, upon presentation and consideration of the foregoing Motion to withdraw as Counsel, said Motion: ,.Cj C\~. cc: Department of Transportation Don Lewis, Esq. Jacob N. Miller R 1, Box 25 Hartstown, PA 16131 t.~ 11-/7-00 RK5 J. iii""""""""'- ;,.--;,.,J.:.::'iiO_''"''',"'''_:....;,;e''~' __"~',." ,.~;r'-"'~'~~iIli_a: '.' ':.';"ci.:" J '~.";" c'" ,-.,""~-.' '~~-"_e""'> '.' ., r._"_" ,', '.C', .~ -- 'r:TAF:Y 00 W)'} 17 PH 3: 20 CUivlBEFi}\;\D COUNTY PENNSYLVANIA . II , ~"'--' .y. -, ~ ~"'" .'.." -,' , , Don Lewis, Esquire 311 Walnut Street Meadville, PA 16335 814/337-5443 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW JACOB MILLER, Appellant A.D. No. 2000 - 7730 vs. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, Appellee MOTION TO WITHDRAW AS COUNSEL AND NOW, this 14th day of November, 2000, comes the Appellant, Jacob N. Miller, by and through his Attorney, Don Lewis, Esquire, and in support of the within Motion represents as follows: 1. The Appellant Notice of Appeal was filed on October 9, 2000. A License Suspension Appeal Hearing on this matter is scheduled for February 21, 2001. 2. Defense Counsel received notice of the License Suspension Appeal Hearing by phone call from Judge Bailey's Chambers on November 9, 2000. 3. Defense Counsel is unable to contact the Defendant by phone due to the current number being disconnected. Also, the defendant was notified of the hearing date on this matter by U.S. First Class Mail on November 9, 2000 and has not contacted defense counsel. 4. November business A copy of this Motion was 13, 2000 by FedEx Express, afternoon) . sent to the Defendant on Standard Overnight Mail (next _H.w,_ __ -0"1 C' _,.<,." . . 'p ,~ , . WHEREFORE, for the foregoing reasons, counsel for the appellant requests this Court's permission to withdraw as counsel. Re~s:p.ectf lly ! \, ! /- . ~ L!-~ Don ewis submitted, -. ,.~, '_ ,., - '~:7-1 >, '<~ ,-_ ~,~-","',~'" -., __,n . _ ~ -.- 'I _ ,~ . . ' CERTIFICATE OF SERVICE I certify that a copy of the foregoing Motion to Withdraw as Counsel was served on the Department of Transportation on November 14, 2000, by U.S. First Class M ~, ~, ',~-' ~ ~" "I'~:" ~, ., . ,-~,~ 1- "~ , " " -"~ ,,;,, '--''<<' ,_. "_^" 0_.' ...... ""~ 0 ~ -,,~"I' " ~1114~ R_ ,<,' .--~ ~-"';",~.:~ ,,' :,--lU-L ,e ~""",_."",~",_ ,,'~ ^' H_ p ".,~ <~ -ofr, mr"':\ z-:;:.-' zc:. cn.):; ::<,~ ~'-) Y'li Zl.....~' y'-' c;t -;; -- C) C,J' -'r'" C~ r'!2:~. .i;:~' II ~ ::-1 i~~~ ;~t~ ist\\ .., 2 ~ P" --1\. - - C;: N ...1 '0 ,,~ ~ ',e./f'''' JACOB MillER, APPELLANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, APPEllEE : 00-7730 CIVil TERM ORDER OF COURT AND NOW, this ~day of February, 2001, upon agreement of both parties, the license suspension hearing scheduled this date is continued. The hearing is rescheduled to Monday, March 19, 2001, at 2:30 p.m., in Courtroom Number 2, Cumberland County Courthouse, Carlisle. George Kabusk, Esquire For the Department of Transportation Jacob Miller R. 1, Box 25 Hartstown, PA 16131 :saa ~ ff. 0' tGt O~\'J~ ~"!. "~-"','->% .--~. .",' I'~ ""'"""""~- iiliIlIIliIiui ~-.--"-~Ji:ltilil,~,.;t"~i;g;UJa~"E';I~"i,,,,,,p;tl:-';lO~~II!M!' ~-~~ =~- (\\ I.,,' .<t'\ \\" C~. \) \:>'t'\ '. . ,. \. ,.,1 " . , ' d'di~\i '.':' U.) ( 'l\~!\\.~C:Y'!;;\;J ~~I'M\ ,J I'cl'\\'\') !11 Lt -, ~ - ~.~~~- ~.~. ~'~~i-~ -'.1 i "' -~ JACOB MILLER, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, Appellee 00-7730 CIVIL TERM ORDER OF COURT AND NOW, this 19th day of March, 2001, upon the request of the Department of Transportation, the within case is remanded to the Department for further action. By the Court George Kabusk, Esquire For the Department of Transportation Jacob Miller 9562 Carmen Road Hartstown, PA 16131 / 3,6 \ L~ oy~ ~\~ Sheriff prs ',w>_>_ -0 l. ^_, ~ "c~" = ~ "'-~~~jj;jjilW.I\lal~Ii::~bh"~h1;g;'~'Kh",,.!!;!te<:~~"lni.:l. 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