HomeMy WebLinkAbout01-0812 FX
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RENEE MARIE DUNCAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 01- .8'1.1.
CIVIL TERM
RALPH EDWARD HARE,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed
against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In
particular, you may be evicted from your residence and lose other important rights.
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A hearing on this matter is scheduled on the J) day of February, 2001, at 'J ~ ~ /) J<IIl.,
in Courtroom No. ~_ on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse SqLare,
Carlisle, Pennsy.v;.rla.
You MUST obey the Order that is attached until it is modified or terminated by the court after notice
and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you
to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six
months in jail under 23 Pa. C. S. ~6114. Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code. Under federal law, 18 U.S.c. ~2265, this Order is enforceable
anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you
travel outside of the state and intentionally violate this Order, you may be subject to federal crimmal
proceedings under the Violence Against Women Act, 18 U.S.C. ~ 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer represent
you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or
cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If
you cannot find a lawyer, you may have to proceed without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, Pennsylvania 17013
Telephone Number: (717)249-3166
AMERICANS WITH DISABllJTIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
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Renee Marie Duncan,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYL VANIA
v.
: Civil Action - Law
.
: NO. 01- t)~
Ralph Edward Hare,
Defendant
: Protection From Abuse and
: Custody
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Ralph Edward Hare
Defendant's Date of Birth is: January 24, 1962
Defendant's Social Security Number is: 176-54-0652
Name(s) of All protected persons, including Plaintiff and minor children:
1. Renee Marie Duncan
AND NOW, on 9th Day of Febrnary, 2001 upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
Plaintiff's request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any
place where they might be found.
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2. Except for such contact with the minor child/ren as may be permitted under
paragraph 4 of this Order, Defendant is prohibited from having ANY CONTACT
with Plaintiff, or any other person protected under this Order, at any location,
including but not limited to any contact at Plaintiffs school, business, or place of
employment. Defendant is specifically ordered to stay away from the following
locations for the duration of this order.
Plaintiff's current residence located at 7 Plainview Road, Camp Hill,
Pennsylvania, and any future residence which she may establish.
3. Except for such contact with the minor child/ren as may be permitted under
paragraph 40f this Order, Defendant shall not contact Plaintiff, or any other
person protected under this Order, by telephone or by any other means, including
through thira persons.
4. Pending the outcome of the final hearing in this matter, Plaintiff is awarded
temporary custody of the following minor child/ren:
L Jerred Michael Hare
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
Supervised visitation.
Commnnication abont the child shall be limited to mail only.
The local law enforcement agency in the jurisdiction where the child/ren are
located shall ensure that the child/ren are placed in the care and control of the
Plaintiff in accordance with the terms of this Order.
5. The following additional reliefis granted:
Defendant is prohibited from having any contact with Plaintiff's relatives
and Plaintiff's child listed in this petition, except as the court may find
necessary with respect to snpervised visitation with the minor child.
6. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
Lower Allen Township Police Department
7. The sheriff, police or other law enforcement agencies are directed to serve the
Defendant with a copy of the Petition, any Order issued, and the Order for Hearing
without prepayment of costs. The Petitioner will inform the designated authority of
any addresses, other than the Defendant's residence, where Defendant can be
served. The Prothonotary is directed to file this Petition and Order without
prepayment of costs.
8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL AUGUST 9, 2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up
to six months in jail. 23 Pa.C.S. ~6114. Consent of the Plaintiff to Defendant's return
to the residence shall not invalidate this Order, which can only be changed or
modified through the filing of appropriate court papers for that purpose. 23 Pa. C.S.
~6113. Defendant is further notified that violation of this Order may subject him/her
to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the Violence Against Women Act, 18 D.S.C. ~~2261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintifi's
residence OR any location where a violation of this order occurs OR where the
defendant may be located. If defendant violates Paragraphs 1 through 4 of this Order,
defendant shall be arrested on the charge of Indirect Criminal Contempt. An arrest
for violation of this Order may be made without warrant, based solely on probable
cause, whether or not the violation is committed in the presence oflaw enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or
threatened to be used during the violation of this Order OR during prior incidents of
abuse. Weapons must forthwith be delivered to the Sheriff's office of the county
which issued this Order, which office shall maintain possession of the weapons until
further Order of this court, unless the weapon/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
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Distribution to:
Joan Carey, Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row, Carlisle, P A 17013
(717) 243-9400
Faxed & Mailed to PSP
Date
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PFAD Number: BJ1194217U
Renee Marie Duncan,
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
v.
;No.OI-f/~~ I~
Ralph Edward Hare,
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiffs name is:
Renee Marie Duncan
2. I, (the Plaintiff), am filing this Petition on behalf of:
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. Renee Marie Duncan
4. Plaintiffs Address is: 7 Plainview Road, Camp HilI, PA 17011
5. Defendant's Name is:
Ralph Edward Hare
6. Defendant is believed to live at the folJowing address:
Dauphin County Prison, Harrisburg, P A
7. Defendant's Social Security Number is:
176-54-0652
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8. Defendant's Date of Birth is:
January 24, 1962
9. Defendant is an adult.
10. The relationship between the Plaintiff and the Defendant is:
Parents of the same children
Persons who live or have lived like spouses
11. The defendant has been involved in a criminal court action.
12. The defendant is not currently on probation I parole
13. Plaintiff and Defendant are the parents of the following minor childlren:
a. Jerred Michael Hare
Age:6 wk.s
Child's address is: 7 Plainview Road, Camp Hill, PA 17011
14. Plaintiff is seeking an Order of child custody as part of this petition.
The following is a list of the children and where they have live for the past 5 years:
a. Jerred Michael Hare
For the past 5 years, this child has lived with:
Jared is only six weeks old and he has lived at 7 Plainview Rd. Camp
Hill, Pennsylvania, since birth. Plaintiff and maternal grandparents,
Richard and Sandra Duncan, also lived at 7 Plainview Road, Camp
Hill, Pennsylvania, with Jared.
15. The facts of the most recent incident of abuse are as follows:
On or about January 5, 2001, while Plaintiff was waiting for her mother to take her back
to her home, Defendant forcefully shoved Plaintiff causing her to stumble. When Plaintiff
went to pick up the baby which was in a baby carrier, Defendant grabbed the baby
carrier out of Plaintiffs hands and told her she could not take the baby home with her.
As Plaintiff walked out the door, Defendant grabbed Plaintiffs forehead and pushed her
into a wall causing swelling on the back of her head. When Plaintiffs mother arrived,
Defendant refused to put the baby into the car, and when Plaintiffs mother approached
the porch to try to get the baby, Defendant shoved her. When she said she would call the
police, Defendant put the baby in the car and they left the residence.
16. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor
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child/ren, (including any threats, injuries, or incidents of stalking) are as fo"llows: .
In or about August or September of 2000, when Plaintiff was pregnant, Defendant
blocked the door refusing to let her leave. Defendant grabbed and squeezed Plaintiff's
throat causing bruises. Plaintiff sought medical treatment for her injuries at Holy Spirit
Hospital.
17. The police department(s) or law enforcement agencies that should be provided with a copy of
the protection order are:
Lower Allen Township Police Department
18. There is an immediate and present danger of further abuse from the Defendant.
19. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER
A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD
DO THE FOLLOWING:
a. Restrain Defendant from abusing, threatening, harassing, or stalking
Plaintiff and/or minor child/ren in any place where Plaintiff may be found.
b. Award Plaintiff temporary custody of the minor child/ren and place the
following restrictions on contact between Defendant and child/ren:
Supervised visitation
Communication about the child shall be limited to mail only.
c. Prohibit Defendant from having any contact with Plaintiff and/or minor
child/ren, either in person, by telephone, or in writing, personally or through
third persons, including but not limited to any contact at Plaintiff's school,
business, or place of employment, except as the court may find necessary
with respect to partial custody and/or visitation with the minor child/ren.
d. Prohibit Defendant from having any contact with Plaintiff's relatives and
Plaintiff's children listed in this petition, except as the court may find
necessary with respect to partial custody and/or visitation with the minor
child/ren.
e. Order the following additional relief, not listed above:
The Cumberland County Sheriff's Department shall attempt to make
service at Plaintifrs request and without pre-payment of fees, but
service may be accomplished under any applicable Rule of Civil
Procedure.
This Order shall be docketed in the office of the Prothonotary and
forwarded to the Sheriff for service. The Prothonotary shall not send a
copy of this Order to Defendant by mail.
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This Order shall remain in effect until modified or terminated by.the
Court and can be exteuded beyoud its original expiration date if the
Court finds that Defendant has committed an act of abuse or has
engaged in a pattern or practice that indicates risk of harm to Plaintiff.
f. Grant such other relief as the court deems appropriate.
g. Order the police or other law enforcement agency to serve the Defendant
with a copy of this Petition, any Order issued, and the Order for Hearing.
The petitioner will inform the designated authority of any addresses, other
than the Defendant's residence, where Defendant can be served.
Date;
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Respectfully submitted,
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Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row, Carlisle, P A 17013
(717) 243-9400
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VERIFICATION
I verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S.g4904, relating
to unsworn falsification to authorities.
Dated: :;1/1/0 I
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Renee M. Duncan, Plaintiff
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02/09/01 FRI 15:18 FAX 717 240 6573
CUMB CO PROTHONOTARY
141001
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*** MULTI TN REPORT ***
*************$$**$*********
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2450
[ 03]9p2438026
[ 01]9p2405331
[ 04]92490779
LEGAL SERVICES
CENTRAL PROCESS
PSP
ERROR
,
OFFlCE OF 'mE PROI'HCN)1'ARY
CUMBERLAND COONT'l CXlUR'I1-IOOSE
ONE cnJR'rnOOSE SQuARE
CARLISLE. Pi\.. 17013-3387
(717) 240-6195
FAX (717) 240-6573
TO;
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Certl, PtOCe,S5.
Pi\. STATE POLICE
v rAT E L E COP I E R
FAX ~:
717-249-0779
FRCM;
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE:
IO~ ~. OF PAGES (lNCLUDING COVER SHEET)
'Ihis ~ is intH1':la:l o:lly fr:lr- tte l.Ige of tie irdiv.idtBl (][' 6"1tiq. ill miI:h is is a.l:lr: 0,1. cnl Ire'{
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RENEE MARIE DUNCAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-812 CIVIL TERM
RALPH EDWARD HARE,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
Plaintiff, Renee Marie Duncan, by and through her attorney, Joan Carey of Mid Penn Legal
Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the
grounds that:
1. A Temporary Protection From Abuse Order was issued by this Court on February 9,
2001, scheduling a hearing for February 15,2001, at 3:30 p.m.
2. The Cumberland County Sheriffs Department deputized the Dauphin County
Sheriffs Office and they served Defendant with a certified copy of the Temporary Protection From
Abuse Order and Petition for Protection From Abuse at the Dauphin County Prison, 501 Mall Road,
Harrisburg, Pennsylvania on Tuesday, February 13, 2000.
3. The parties agree that the hearing be rescheduled.
4. Plaintiff requests that the Temporary Protection From Abuse Orderremain in effect
for a period of eighteen months from the date it was entered or until further Order of Court,
whichever comes first.
WHEREFORE, Plaintiff requests that the Court grantthis Motion and reschedule this matter
for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of
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eighteen months from the date it was entered, through August 9, 2002, or until further Order of
Court, whichever comes first.
n Carey, Attorney fo
MIDPENN LEGAL S
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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RENEE MARIE DUNCAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 01-812 CIVIL TERM
RALPH EDWARD HARE,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
O~ FOR CONTINUANCE
AND NOW, this~ day of February, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on the 15th day of February, 2001, at 3 :30 p.m. by this
Court's Order of February 9,2000, is hereby rescheduled for hearing on the 19th day of March, 2001,
at 2:30 p.m. in Courtroom No.3 of the Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania.
The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen
months from the date it was entered, through August 9, 2002, or until further Order of Court,
whichever comes first.
By the Court,
Joan Carey, Attorney for Plaintiff
MIDPENN LEGAL SERVICES
Ralph Edward Hare
Dauphin County Prison
501 Mall Road
Harrisburg, PA 17101
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2001-00812 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DUNCAN RENEE MARIE
VS
HARE RALPH EDWARD
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
HARE RALPH EDWARD
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
County, pennsylvania, to
serve the within PROTECTION FROM ABUSE
On February 20th, 2001 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep. Dauphin Co
18.00
9.00
10.00
25.50
.00
62.50
02/20/2001
~~
R. Thomas Klin
Sheriff of Cumberland County
Sworn and subscribed to before me
this .<K" ~ day ofJ~,. - r
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@iiite of tq~ ~4~J:iff
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Ralph G. McAllister
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 171 0 I
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
DUNCAN RENEE MARIE
vs
Sheriff's Return
HARE RALPH EDWARD D36,641
No. 0402-T - -2001
OTHER COUNTY NO. 01-812
AND NOW: February 12, 2001 at 5:30PM served the within
PFA/CUSTODY/NOTICE OF HEARING & ORDER
HARE RALPH EDWARD D36,641
to HIM
of the original
upon
by personally handing
1 true attested copy (ies)
PFA/CUSTODY/NOTICE OF HEARING & ORDER
and making known
to him/her the contents thereof at DAUPHIN COUNTY PRISOND36,641
501 MALL ROAD
HARRISBURG, PA 17111-0000
NOTIFIED OF EXCLUSION FROM RESIDENCE & COMMUNICATION ABOUT THE CHILD.
Sworn and subscribed to
before me this 13TH day of FEBRUARY, 2001
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PROTHONOTARY
So Answers,
JR~
Sheriff of Dauphin County, Pa.
'Y7(U~
Sheriff's Costs: $0.00 PD 00/00/0000
RCPT NO
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RENEE MARIE DUNCAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANlA
v.
: NO. 01-812 CIVIL TERM
RALPH EDW ARDHARE,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
Plaintiff, Renee Marie Duncan, by and through her attorney, Joan Carey of MidPenn Legal
Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the
grounds that:
1. A Temporary Protection From Abuse Order was issued by this Court on February 9,
2001, scheduling a hearing for February 15,2001, at 3:30 p.m.
2. The Cumberland County Sheriffs Department deputized the Dauphin County
Sheriffs Office and they served Defendant with a certified copy of the Temporary Protection From
Abuse Order and Petition for Protection From Abuse at the Dauphin County Prison, 501 Mall Road,
Harrisburg, Pennsylvania on Tuesday, February 13,2000.
3. The parties agreed that the hearing be rescheduled. An Order for Continuance
was issued by this Court on February 13,2001, rescheduling the hearing for March 19,2001, at
2:30 p.m. in Courtroom No.3 of the Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania.
4. The parties agree that this hearing be generally continued while they negotiate an
agreement in this matter.
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5. Plaintiff requests that the Temporary Protection From Abuse Order remain in
effect for a period of eighteen months from the date it was entered or until further Order of Court,
whichever comes first.
WHEREFORE, Plaintiff requests that the Court grant this Motion and generally
continued this matter, and that the Temporary Protection From Abuse Order remain in effect for
a period of eighteen months from the date it was entered, through August 9, 2002, or until further
Order of Court, whichever comes first.
Respectfully submitted,
oan Carey, Attorney fo laintiff
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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RENEE MARIE DUNCAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 01-812 CIVIL TERM
RALPH EDWARD HARE,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
ORDE~OR CONTINUANCE
AND NOW, this ~day of March, 2001, upon consideration of the attached Motion
for Continuance, the matter scheduled for hearing on February 15, 2001, and rescheduled for March
19,2001, at 2:30 p.m., is hereby continued generally.
This Order is entered without prejudice to either party to request a hearing.
The Temporary Protection From Abuse Order of February 9, 2001, shall remain in effect for
a period of eighteen months from the date it was entered, through August 9, 2002, or until further
Order of Court, whichever comes first.
By the Court,
Joan Carey, Attorney for Plaintiff
MIDPENN LEGAL SERVICES
Ralph Edward Hare
917 Gibson Blvd.
Steelton, P A 17113
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