Think about the hard questions that you would like to get answers to read to a jury. endstream endobj 71 0 obj <> endobj 3 0 obj <> endobj 1 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 5 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 8 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 11 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 14 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 17 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 20 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 23 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 26 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 29 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 32 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 35 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 38 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 41 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 44 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 47 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 50 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 53 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 56 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 59 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 62 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 65 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 68 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 264 0 obj <>stream Interrogatories to the defendant car owner - New Jersey Personal Injury 3. Make sure you are not objecting to form interrogatories approved by the court. 1. The term "or" shall mean "and" and vice-versa, as necessary to bring within the scope of the following interrogatories all information or documents that would be excluded absent this definition. These are sample written questions that you might receive in your divorce. e. in the case of an agreement, its date, the place where it occurred, the identity of all persons who were parties to the agreement, the identity of each person who has knowledge of the agreement and all other persons present when it was made, and the subject matter of the agreement. CERTIFICATE OF SERVICE. 99-005 (MMS) PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. "Shade guide" means any device used to match the color or shade of prefabricated artificial teeth to a patient's natural teeth for the specifications contained in a dentist's prescription for dentures or any other removable or fixed dental prosthetic device. The purpose of providing these to our colleagues is that we should all be trying to spend more time maximizing the value of our cases and less time reinventing the wheel. Interrogatories to Parties, N.J. Ct. R. 4:17 - Casetext They are battle tested and we think they are pretty good. Browse Workers Compensation forms and publications below. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. How to Answer Interrogatories in Workers Compensation Insurance defense counsel often refuses to answer discovery. HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 Pursuant to Tennessee Rule of Civil Procedure 26.02(5), if any 0000037811 00000 n The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun, and vice versa; and the past tense shall include the present tense where the clear meaning is not distorted. INTERROGATORIES SAIA MOTOR FREIGHT LINE, LLC Information If you contend that Plaintiff has sued the wrong party or that your name is incorrectly stated in this lawsuit, please explain the basis for your contention and identify the correct legal entity for the correct party in interest to this suit. {i;6#0O R(VnxTw&:f0L(Y#c{l'tD C]FqC eZ yvm?6=a/DFdrz3 }*S B4,;B@+D\M.F6``CnFwg8#k7"K3T$222LU4iY6@U@pTnb!]1?=g4spG0 `>X=bkKw#>LPb"; 519 0 obj << /Linearized 1 /O 522 /H [ 1427 424 ] /L 157345 /E 66972 /N 14 /T 146846 >> endobj xref 519 30 0000000016 00000 n Insurance Carrier Contact form (online): this form to designate a contact person must . No agreement, understanding, or stipulation by the Department of Justice or any of its representatives purporting to modify, limit, or otherwise vary these interrogatories shall be valid or binding on the Department of Justice unless confirmed or acknowledged in writing (or made of record in open court) by a duly authorized representative thereof. PDF Sample LT Interrogatories - Bardos, Esq Summary judgment may be granted where the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and the moving party is entitled to summary judgment as a matter of law. R. Civ. They are just looking for creative ways to circumvent answering discovery. %PDF-1.5 % 0000015309 00000 n Identify the person signing and attesting to the truthfulness of these Interrogatories, and, if a different individual, the custodian of any business records relating to the premises. 6/2014. 3643, Mark J. Botti William E. Berlin Michael S. Spector Michael D. Farber Health Care Task Force Antitrust Division Washington, D.C. 20004 U.S. Department of Justice 325 7th Street, N.W., Suite 400 Washington, D.C. 20530 (202) 307-0827, Interrogatory Motions, Memoranda, and Orders, This document is available in two formats: this web page (for browsing content) and. at fniemann@hnlawfirm.com or call him toll-free at (855) 376-5291. . If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. "Dealer" means any person that distributes any dental products of any other person or purchases or acquires any such product for the sole purpose of reselling such products to any other person, such as a dental laboratory, dentist, dental school or government entity. Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at 325 Seventh Street, N.W., Room 400, Washington, D.C. 20530, within 30 days of service of these Interrogatories. "Agreement" means a contract, arrangement, or understanding, formal or informal, oral or written, between two or more persons. Request for Records Inspection: this form must be completed and signed before the Division can release records. Rule 4:17-4. Hb```f`` It allows you time to be reasonable and time to file a motion to compel long before the discovery deadline. In most jurisdictions, parties may serve 30 written questions. Attorney Calendar E-mail Program application(fillable): this form initiates the transmission of "Attorney Calendar" scheduling notices via e-mail to designated e-mail address(es). Figure out how long you have to respond. 2. Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. 8/9/97 1. 0000001829 00000 n If an interrogatory has five related subparts, it will be counted as five interrogatories. (b) Uniform Interrogatories in Certain Actions. CN: 10160. : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. A Workers' Guide to Workers' Compensation in New Jersey (legal size paper), Guia Interpretativa para el Trabajador A la Ley de Compensacion al Trabajador en Nueva Jersey (legal size paper), Uninsured Employers Fund Pamphlet: provides the regulations associated with the Uninsured Employers Fund (legal size paper), Second Injury Fund - A Beneficiary's Guide: provides necessary information to recipients of second injury fund benefits. Interrogatory No. (c) In response to any interrogatory, you are permitted to provide copies of business Sample Interrogatories for Assault and Battery to Defendant 6. CN: 10153. They are to be answered by you fully, in writing, on oath, and within 30 days of their receipt, unless by agreement or Court order such time is extended: (a) These Interrogatories are continuing in character, so as to require you to file supplemental answers at . Unless you go over every answer - and even interrogate them just a little bit - there is a chance you are going to get it wrong. 3. 4!mU>]3Nn6~p ,5_Rn]`R.nQirvuA+`i&.8ZfS |cg2'~pY>+8u4>)n9wv|aS9)y>P4}/fd`0W2bUOg"~yf;+[?JZjbtt5qr'r4"|D>fYLZCCE+zX9/+3qyq#1$x,8U1UBV(hSwa3>"n.$2=b. 2. 2. As a result, we make a lot of diving impossible catches but miss too many fly balls. New Jersey Family Law: Interrogatories as a Discovery Tool in Divorce DEJON WELCOME, CIEMON MOUZON. 2013-04-26T13:58:46-05:00 Second Injury Fund Information Review Sheet(fillable), Judgment / Order Approving Settlement(fillable) (with Case Exhibit Listing), Generic Order (for Miscellaneous Decisions, Motions, etc.) Another favorite objection is that the plaintiff bears the burden, so no answer is required, an objection that is beyond silly. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. 4:46-2(c) > > Read More.. MOVING PAPERS Get a copy to your clients quickly. 0 The responding party must answer in writing and under oath. Pursuant to Fed. These questions are referred to as "Interrogatories". Use these sample interrogatories however you like. (Caption) 1. DOC Plaintiffs' First Set of Interrogatories to Defendant PDF Husband/Wife'S First Set of Interrogatories Propounded to Wife to Unless otherwise specified, these interrogatories are limited to the time period from January 1, 1995, to and including the date of service of these interrogatories. This form must be signed by both the subscriber and the firms Contact Person prior to submitting. "Person" means any natural person, corporation, company, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission, office or other business or legal entity, whether private or governmental. Don't object just because you don't want to answer the question and try to keep the objection as narrow as possible. 34:15-20, Decision of Dismissal (Second Injury Fund), Order for Total Disability with SS Offset (fillable), Order for Total Disability with SIF(fillable), Addendum to Order for Total Disability(fillable), ELECTRONIC CALENDARS, COURTS ON-LINE AND ELECTRONIC FILING FORMS. 8/22. A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30 Washington, DC 20005 . A-4540-16T4 JI SUNG KIM, Plaintiff-Appellant, v. PAUL P. KOBLISKA, Defendant-Respondent. L-3773-15. In a New Jersey Child Custody Case, What Kind Of Questions Will I Be Asked? COURTS on-line Subscriber Change Form(fillable): this form needs to be completed if an existing COURTS on-line subscriber has had a change to their name or e-mail address or if their e-filing access level request has changed. Superior Court of New Jersey, Law Division. Draft your answers. The interrogatories shall be so arranged that after each separate question shall appear a blank space reasonably calculated to enable the answering party to have the answer typed in. Limitation of Interrogatories. of the California Rules of Court, these interrogatories must not be used until the asking party has PDF Form C. Uniform Interrogatories to be Answered by Defendant in All Separately for 1990 and each subsequent year through 1996, describe in detail and quantify each separate cost or expense, and all fees and other income Dentsply collected from third parties, relating to training or educating dentists. Interrogatories and demands for production to slip and fall defendant New Jersey Interrogatories - Fill Online, Printable, Fillable, Blank The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. 0000007135 00000 n All rights reserved. Search for another form here. 7. previous. IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. endobj SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). 0000002401 00000 n #+wmoSd&Vx7H3"uk]v0 A"`>MB-u6`[dxd;X!CfD3w\BT!g#WQILYgUXTt!2VpPvYpogZzS1(J |J/-T%w5m 1l05Xgh}nH.t`(e@Q:gL^6pVIE)D- {5hMKdzo`-P2d+!Bc~ RTR+[c(GC7N6;4Vl[ 8. Subpoena to Produce Documents, Information, or Objections or to Permit Inspection of Premises (AO 88b) Category: Civil. First, serve an initial set as well as later "clean-up" set so long as the total number of questions does not exceed 30. 4. Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at 325 Seventh Street, N.W., Room 400 . <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> The user is on notice that neither the State of NJ site nor its operators review any of the services, information and/or content from anything that may be linked to the State of NJ site for any reason. Complaint for Divorce (with children) Complaint for Divorce (without children) Certification of Insurance (filed with Complaint and Answer) Confidential Litigant Information Sheet (filed with Complaint and Answer) Answer and Counterclaim. 0000003166 00000 n The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. 0000040914 00000 n We get so much advice as to what we should do. Workers' Compensation | Forms and Publications - Government of New Jersey Motion for Summary Judgment - New Jersey Essex Superior - SmartRules (b) residential cases involving six or more single-family homes or housing units. Package contains both the Designation of Contact form and Subscriber application form. SUPERIOR COURT OF NEW JERSEY. Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. R. Civ. Fillable PDF Williams v. Marziano :: 1963 :: New Jersey Superior Court, Appellate Decided February 14, 1963. endobj Subscriber Application only (fillable): this form needs to be completed if a law firm, insurance carrier or self-insured is interested in adding an additional subscriber to access COURTS on-line and the firm has already established a Contact Person with the Division. 8. 73 0 obj <> endobj 74 0 obj <> endobj 265 0 obj <>stream interrogatories, please note: (a) You are required to furnish all information available to you, your agents, employees and attorneys. The objections are, of course, drafted by the attorney. The last case I referred to them settled for $1.2 million. If you are unable to answer an interrogatory fully, submit as much information as is available, explain why your answer is incomplete, and identify or describe all other sources of more complete or accurate information. 5. More sample discovery List of Sample Objections Sometimes, it is hard to come up with the exact words of why you want to object or to match the feeling that the request is objectionable with the appropriate law. The phrase "describe in detail" as used in these interrogatories includes a request for a complete description and explanation of the facts, circumstances, analysis, opinion and other information relating to (as that phrase is defined below) the subject matter of a specific interrogatory. Your landlord must respond to these requests under oath; they are then admissible in court if you need them. 1: State your full name, current address and any and all other names which you have used or by which you have been known. Describe in detail and quantify your company's costs or expenses attributable to each dealer to whom you sell prefabricated artificial teeth, separately for each year, and separately for each such dealer, including but not limited to administrative, transactional or other costs or expenses relating to tooth returns or exchanges, drop-shipments, inventory management (including computer hardware or software provided to dealers by Dentsply), training, sales support, marketing, or advertising. An official website of the United States government. So asking an interrogatory with several questions does not help keep the number down. Answers to Uniform Interrogatories by Letter of Demand In a case deemed complex under rule 3.400 et seq. Service, Scope of Interrogatories, Rule 4:17-2. Pursuant to Fed. 1 0 obj Adobe Acrobat 8.13 Paper Capture Plug-in Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-016-7534, https://content.next.westlaw.com/practical-law/document/Ib7c96852c00111e8a5b3e3d9e23d7429/Interrogatories-NJ?viewType=FullText&transitionType=Default&contextData=(sc.Default). So if you can pin down what the arguments will be, you will be in a much better position to structure your case effectively. Employee's Claim Petition(can be used for Amended CP), Employee's Claim Petition Supplemental Page, Application for Review or Modification of Formal Award (can be used for Amended ReOpener), Dependency Claim Petition(can be used for Amended DCP), Dependency Claim Petition To Convert Voluntary Tender to Formal Judgment, Notice of Motion for Temporary and/or Medical Benefits(fillable), Standard petitioner's occupational interrogatory form, Second Injury Fund Verified Petition(fillable), Medical Provider Application for Payment or Reimbursement of Medical Payment, Uninsured Employer's Fund Information Packet, Respondent's Answer to Claim Petition (can be used for Amended Answer), Respondent's Answer to Application for Review & Modification of Formal Award (can be used for Amended Answer), Respondent's Answer to Dependency Claim Petition, Answering Statement for Motion for Medical and/or Temporary Benefits(fillable), Respondent's Answer to Medical Claim Petition, Standard respondent's occupational interrogatory form, Request for Adjournment / Ready Hold - page 1 (fillable). Response to Interrogatories - New Jersey Bergen Superior - SmartRules Form A (2) - Uniform Interrogatories to be Answered by Plaintiff in Product Liability Cases (Other Than Pharmaceutical and Toxic Tort Cases) Only: Superior Court Form B - Uniform Interrogatories to be Answered by Plaintiff: Property Damage to Motor Vehicle: Superior Court* Questions for Loss of Consortium Interrogatories You need to mold them to the facts. 11. 4 0 obj endstream endobj 31 0 obj <> endobj 32 0 obj <> endobj 33 0 obj <>stream The term also includes information stored in, or accessible through, computer or other information retrieval systems (including any computer archives or back-up systems), together with instructions and all other materials necessary to use or interpret such data compilations. Except as otherwise provided by R. 4:17-4(e), if a party who has furnished answers to interrogatories thereafter obtains information that renders such answers incomplete or inaccurate, amended answers shall be served not later than 20 days prior to the end of the discovery period, as fixed by the track assignment or subsequent order. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. % Resource Family Information Form. "Prefabricated artificial teeth" or "teeth" means any prefabricated (as opposed to dental laboratory or dentist constructed) product used in a denture or as an implant to replace one or more natural teeth. 16. The following Interrogatories are served upon you pursuant to Fed. COURTS on-line Internet Access Application(fillable): this application package needs to be completed if a law firm, insurance carrier or self-insured is interested in accessing COURTS on-line, the Division'son-line case management website. NEW JERSEY'S CIVIL COURT PROCEDURES UPDATED AS OF JANUARY 2011 NEW JERSEY INSTITUTE OF CONTINUING LEGAL EDUCATION One Constitution Square, New Brunswick, N.J. 08901-1520 (732) 249-5100 The New Jersey Institute for Continuing Legal Education Celebrating over 40 years of service to the bench and bar 10. Objections to Interrogatories, Rule 4:17-6. The term includes agreements; contracts; letters; telegrams; inter-office communications; memoranda; reports; records; instructions; specifications; notes; notebooks; scrapbooks; diaries; plans; drawings; sketches; blueprints; diagrams; photographs; photocopies; charts; graphs; descriptions; drafts, whether or not they resulted in a final document; minutes of meetings, conferences, and telephone or other conversations or communications; invoices; purchase orders; bills of lading; recordings; published or unpublished speeches or articles; publications; transcripts of telephone conversations; phone mail; electronic-mail; ledgers; financial statements; microfilm; microfiche; tape or disc recordings; and computer print-outs. responses to first set of interrogatories ELECTRONICALLY FILED - 2018 Mar 15 2:01 PM - GREENVILLE - COMMON PLEAS - CASE#2014CP2304432. In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. Have ever seen someone running away from their answers to discovery at trial? Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. 2. Plaintiffs' complaint was dismissed with prejudice for failure to provide complete answers to interrogatories and completely respond to a demand for production of documents by order . Think about the questions that box in the defendant (in one direction or the other). Forms | District of New Jersey | United States District Court While the Interrogatories you receive may not be exactly like these, they will be substantially similar. 22. Sample Interrogatories | Livinglies's Weblog Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. 12. Use [ edit] The first questions you'll encounter in interrogatories for a loss of consortium will be similar to the kinds of questions you can expect in any kind of injury case: your full name, address, social security number, and possibly your employment information. Pursuant to Tennessee Rule of Civil Procedure 26.05(2) these interrogatories are continuing in nature requiring supplementation with such additional information to which you will have access in the future. Number of Copies Served; Form of Interrogatories. "Exclusive arrangement with a dental laboratory or dentist" means any proposed or actual agreement, arrangement, policy, program, practice, term or condition of your company that: a. requires any dental laboratory or dentist to limit the use of, or refrain from using, the products of any other person; or. PDF SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-4540-16T4 v. Separately for 1997 and each subsequent year, describe in detail and quantify all fees and other income Dentsply collected from third parties relating to training or educating dealers' personnel', dental laboratories' personnel, and dentists, and to the extent possible, allocate the fees and other income between dealers, dental laboratories, and dentists. Secure .gov websites use HTTPS PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. These are used in conjunction with requests for admission. Answer each interrogatory fully. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. 2. CN: 10151. 0000040696 00000 n Sample Plaintiff's Answers to Defendant's Interrogatories. District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. 5. Report of Non-Compliance (online): this form may be used by any individual or organization to report allegations of failure on the part of an employer to maintain workers' compensation insurance coverage or obtaining authorization to self-insure. 0000001288 00000 n No matter what the objection, the key is to object quickly and press the defendant with a motion to compel if necessary. I also understand that Miller & Zois works with multiple law firms on these claims and that I may be contacted by an affiliated law firm working with Miller & Zois on these lawsuits. If you think you need an extension to answer, ask for it early. Accordingly, we suggest serving more than one set. Princeton, New Jersey 08542-0627 Tel. PDF [NAME AND ADDRESS OF PLAINTIFF S ATTORNEY] Attorneys for Plaintiff _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. 1. 33. Save the form onto your computer byhitting Save As. Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. <>>> DEJON WELCOME v. CABLEVISION :: 2009 :: New Jersey - Justia Law Bergen County Law Office. It is trite, but you have to digest each word. All questions must be answered unless the court otherwise orders or unless a claim of privilege or protective order is made in accordance with R. 4:17-1(b)(3). THiLfxS^i >T.^%ll_TuFe5c~~1jEWKRd19JY. 6. and Towson; Carroll County including Westminster; Frederick County including Frederick; Harford County including Abingdon, Bel Air, Belcamp, and Forest Hill; Montgomery County including Germantown and Rockville; Howard County including Ellicott City and Columbia, Washington, D.C. and Washington County including Hagerstown. Interrogatories are written sets of questions that both sides of the case can send to one another. A certification of the amendments shall be furnished promptly to any other party so requesting. Employer Notice of Workers' Compensation Insurance Coverage:this link will take you to the NJ Compensation Rating & Inspection Bureau's website. Any challenge to the certification of due diligence will be deemed waived unless brought by way of motion on notice filed and served within 20 days after service of the amendment. The form must be signed by the firm's Contact Person prior to submitting. Written responses from a defendant can help narrow down the issues in a case.
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