April 17, 2014

Parents May Restrict Court's Review of Adult Child Support Order

market-movements-2-1388612-m.jpgUnder California law, support orders may be modified or terminated at any time, as the court deems necessary. The law further defines "support order" as including a child, family or spousal support order. These provisions apply to cases filed in family courts in San Diego and throughout the state. And court decisions interpreting the statutory language, in relation to the underlying facts and circumstances of a case, can impact the way future family court cases are decided. Families facing child support disputes are encouraged to contact an experienced family law attorney who is fully knowledgeable of the local and recent court decisions affecting a party's right to child support.

It is important to understand the complexity of child support laws and how they apply to adult versus minor children. While California law specifies that a parent's child support obligation typically extends until a child reaches the age of 19 or completes the 12th grade, parents may agree to provide additional support. The question then arises, does a court have the authority to modify such an agreed upon extension of support for an adult child?

In a case of first impression in California, the court of appeals was asked to decide whether, under the state family code, parents may contractually limit the court's jurisdiction to modify an adult child support order that was made under the parents' marital settlement agreement. Here, the court looked at the interplay of two applicable family code statutes: section 3651 and section 3587. Section 3651 provides a court the authority to modify or terminate a support order - subject to section 3587, which gives a court the authority to approve a stipulated agreement by the parents to pay for the support of an adult child.

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April 10, 2014

In Custody Dispute, Court Temporarily Prevents Child from Traveling Outside the Country

three-globes-1372599-m (2).jpgWhen a court issues a child custody order, there's a good chance that it will be modified before the children reach adulthood. Parents may consider renegotiating the arrangement every couple of years or so. Changes may occur in the family's life that will precipitate the need to modify the custody arrangement, such as a new job or home or changes in the children's interests and activities. California law requires a judge to approve any alterations to a final custody order. If you have questions about modifying a court ordered custody arrangement, it is critical that you contact a San Diego family law attorney who is experienced in handling such matters in the local courts.

In a recent case, a California court modified a custody order, and in doing so, refused to allow a child to travel with the father out of the country. In this complicated matter, the parents were married in 2005, their only son was born in 2006, and they divorced in 2008. At that time, the parents were awarded joint legal custody of the child. The mother alleged that in 2010, the father halted contact with their son when he moved out of the country to Australia. It seems that the father and son had little communication with one another for two years. In December 2012, the father told the mother that he was coming back to San Diego and hoped to resume his 40 percent share of physical custody of the child.

Believing that this would be detrimental to the child, the mother filed a request for order (or "RFO"), asking for sole legal and sole physical custody of their son. Despite the fact that Family Court Services did not forbid the boy from visiting his father in Australia, the trial court issued a modified custody order, removing the possibility of the child going to Australia until at least June 2014 when a hearing could be held to reconsider the issue. The court granted the father two visits in San Diego for two weeks each, in addition to other visitation privileges. The father appealed the modification order contesting his inability to take the child out of the country, as well as other issues not discussed here.

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April 3, 2014

California Court Denies Wife's Request for Attorney's Fees in Divorce Proceedings

law-education-series-3-68918-m.jpgThe overwhelming sentiment is that parties to divorce proceedings should be represented by counsel, especially when there are children involved. There are many intricate legal details and requirements that must be followed throughout the entire process. For example, the California Family Code governs many issues that arise during the dissolution of a marriage. And the law certainly serves to protect the interests of parties to a divorce proceeding. If you are considering divorce, it is important to consult with an experienced San Diego family law attorney as early in the process as possible.

Because legal representation is particularly helpful to "level the playing field" in a divorce proceeding, state law provides that courts must make sure that each party has access to an attorney. Specifically, Section 2030 of the California Family Code provides in relevant part that in a dissolution of marriage proceeding, as well as any proceeding following the entry of a related judgment, the court shall ensure that both parties have access to an attorney. According to the statute, this includes access early in the proceedings, to preserve each party's rights by ordering, if necessary based on the income and needs assessments, one party to pay to the other party, an amount that is reasonably necessary for attorney's fees as well as other costs associated with maintaining or defending the proceeding.

In a recent case, the wife sought "need-based" attorney's fees (among other relief) in a divorce trial that lasted four days. The trial court refused to award the relief she requested, finding that the evidence did not support such a ruling. The court found that there had not been a disparity in access to funds to retain counsel and that neither party was in a position to pay the attorney's fees and costs of the other party. The wife appealed this ruling, arguing, 1) that her husband's testimony lacked credibility and, 2) that he made frivolous motions and forced her to compel his mandatory disclosures.

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March 27, 2014

California Court of Appeals Affirms Denial of Spousal Support

colorful-symbols-2-949759-m.jpgSpouses who seek to divorce are often faced with many emotional and practical decisions. Breaking up a family can be a very trying time for everyone involved. But there are issues that must be addressed, including financial matters that will likely affect the family's lifestyle going forward. For example, in California, courts have the discretion whether to order one party to pay for the support of the other, i.e., spousal support, for a certain period of time after the divorce. But keep in mind that spousal support is not mandatory. If you are considering a divorce, it is critical that you contact an experienced family law attorney from the San Diego area who can help to protect your financial interests in the outcome of the proceedings.

In a recent case, the court of appeals agreed with the trial court in its refusal to award spousal support to the wife. Here, the parties were married in 2005, had one child in 2007, and subsequently separated in 2011. The husband graduated from high school and works at a country club as a "starter." His earnings total between $3,000 and $3,200 per month, plus an annual bonus during the holidays. The wife has an Associate's degree in accounting. While she worked as an accountant at the same country club, she had to leave her position due to a significant illness that left her hospitalized and in a coma for a time.

During her hospitalization and then after she was released, the wife took high doses of narcotic painkillers. Just before the couple separated, the wife attacked the husband in a domestic violence incident. The court issued a two-year restraining order against the wife. At the divorce trial, the court awarded the husband sole physical custody of the child and denied the wife's request for spousal support. She appealed.

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March 20, 2014

California Court Reviews Standard for Renewing a Domestic Violence Prevention Restraining Order

law-badge-1164850-m.jpgDomestic violence is a very serious matter. Whether you have been the victim of domestic violence or accused of the crime, there are many important issues to address. The first, as far as a victim is concerned, is one's future safety and protection from harm. There are various remedies available under California law for victims and those who have been accused. In order to determine your rights and the laws applicable to your case, it is critical that you contact an experienced family law attorney who is fully familiar with the legal procedures in and around the San Diego area.

In a recent court of appeals case, the ex-wife sought a renewal of a domestic violence restraining order that had expired. The trial court refused to grant the renewal, citing applicable law - and concluding that the facts of the case did not support such renewal. The court of appeals reversed, pointing to the lower court's erroneous legal conclusions. Here, the couple divorced in May 2010 after seven years of marriage. During the divorce proceedings, the wife filed a request for a domestic violence prevention restraining order against her soon-to-be ex-husband. In support of the request, she described a history of verbal and physical abuse by her husband. She alleged that on various occasions, he slapped her, shoved her to the ground and attempted to choke her. In 2009, the court issued the protection order for a term of three years.

In July 2012, the ex-wife sought to renew the order, claiming that she still feared her ex-husband due to the abuse during the marriage. She further described various instances where he violated the original restraining order. The trial court denied the request, concluding that it did not meet the legal standard of "a reasonable apprehension of future physical abuse." The court pointed out that not only did the abuse occur a long time ago, but also it was of a nature that would not - alone - support renewal of the order. Significantly, the court concluded that because nothing happened in three years, there was no "reasonable apprehension." The ex-wife appealed.

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March 13, 2014

California Man Who Hid Assets in Divorce Gets 17-Year Sentence

handcuff-449966-m.jpgDivorce has the potential to bring out the worst in people. There are many significant issues to resolve before the parties can go their separate ways, such as child custody and support, division of property and spousal support. When the soon-to-be ex-spouses cannot see eye to eye on these all-important matters, disputes can arise and the negotiations can become more and more contentious. In an effort to minimize the animosity between the spouses and to move the process along efficiently and smoothly, it is important to consult with an experienced family law attorney from the San Diego area.

One of the most important issues to resolve is the division of marital property. In order to do that, parties must be able to find and identify marital property, subject to division. Fortunately, state law provides some guidance in this area. California is a "community property" state, which means that a marriage renders two people -- one legal "community." In effect, property that the couple acquires during marriage is "community property." In some cases, deceptive spouses attempt to conceal or hide joint assets in an effort to avoid division of the assets in divorce. Another tactic is to file a fraudulent bankruptcy petition.

In a recent case reported in the U-T San Diego, a man was sentenced to 17 years for his efforts to conceal millions of dollars in assets in divorce and bankruptcy. According to the news reports, the man told his wife that he would file for bankruptcy so that she would get "nothing, including child support." The couple split up in 1999. Between 1999 and 2005, the man reportedly concealed millions of dollars in assets by placing them in other people's names. In 2005, he filed for bankruptcy protection. In 2008, a California court of appeal ruled on the divorce case and said in the ruling that it was the husband's "unstated but apparent view that if he can conceal his finances long enough he will not have to support his children."

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March 6, 2014

California Courts and Legislature Address Abduction of Child by Custodial Parent or Guardian

911-776459-m.jpgIn most child custody disputes, parents are trying to determine the most suitable parenting plan for their family. Issues such as physical and legal custody are the most common matters to be resolved. In some cases, one parent may be dissatisfied with the ultimate arrangement approved by the court. And unfortunately, parents who are wholly unhappy with their share of parenting responsibilities have on occasion resorted to drastic measures, such as abducting their children in contravention of the custody order. In order to prepare an arrangement that is in the best interests of your children, it is critical that you contact a local San Diego family law attorney as early in the proceedings as possible.

The child abduction statistics in this country are staggering. According to the US Department of Justice, 800,000 children are reported missing every year in the United States, while an estimated 200,000 are taken or abducted by a family member. One of the most helpful tools in finding abducted children within a quick time frame has been the "Amber Alert" system. Despite the effectiveness of the system, there was a question as to its applicability to abduction by a child's parent or guardian. To address this ambiguity, the California legislature drafted a bill to amend the state Amber Alert law. The law now authorizes activation of the Emergency Alert System even if the abductor is the child's custodial parent or guardian where the child is in imminent danger of serious bodily injury or death.

In a recent court of appeals case, a mother who took her children in contravention of the current custody order was found guilty of two counts of child abduction in violation of the California state penal code. Here, the parties had twins in 1999 and divorced in 2007. At the time of the divorce, the original settlement agreement afforded the parents a right of first option to care for the children while the other parent was away dealing with an emergency. Many years and multiple custody orders later, the court awarded the dad primary physical custody of the twins in 2008.

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February 27, 2014

Quasi-Judicial Immunity Protects Actions by Family Court Child Custody Evaluator

u-s--supreme-court-2-1038828-m.jpgChild custody cases usually present many challenging issues that have the potential to impact the entire family for years to come. Ideally, parents will agree to a parenting plan that satisfies the wishes of both parties. But many cases involve parents with vastly different outlooks on what is in the best interests of their children going forward after a divorce. When there is no agreement between the spouses, a judge in California may decide to appoint a child custody evaluator to conduct a custody evaluation and recommend a parenting plan. And while a parent is entitled to ask for an evaluation, the request may not necessarily be granted. It is also possible that parents will be expected to pay for an evaluation. Parties facing child custody disputes are encouraged to contact an experienced San Diego family law attorney who can help to navigate the process with competence and knowledge of the local laws and procedures.

According to the California court's website, a child custody evaluation involves an investigation and analysis by an expert of the health, safety, welfare, and best interests of children. In a recent court case, the parents were involved in a lengthy and bitter child custody proceeding concerning their two young children. Here, the court ordered the parties to retain the services of a child custody evaluator who would evaluate the circumstances and provide a custody recommendation to the court. Apparently, during the proceedings, the court granted the evaluator the authority to issue interim custody orders pending the court's ultimate review.

The mother brought this action against the custody evaluator alleging negligence, breach of contract and intentional infliction of emotional distress. Among other things, she claimed that the evaluator issued an interim order that restricted access to her children. The evaluator responded by asserting that the acts complained of were quasi-judicial in nature and therefore protected by the common law privilege. The mother argued that the evaluator had no jurisdiction to render an interim custody order and thus, the act was not entitled to immunity.

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February 20, 2014

Challenge to Modification of Custody Order is "Moot" Once Child Turned Eighteen

children-crossing-1319861-m.jpgWhen people think about child custody disputes, most often the concepts of legal and physical custody come to mind. While these issues are a large part of many family law disputes, parties and their attorneys must also address various jurisdictional related matters. This means that the court must have proper jurisdiction to hear a case before it may render any orders affecting the parties. In California, the Uniform Child Custody Jurisdiction and Enforcement Act (the "UCCJEA") governs questions regarding a court's jurisdiction of a child custody matter. Many of these issues are complicated and require strict attention to detail. Failure to adhere to legal requirements could result in unexpected and unwelcome consequences. To avoid this, parties facing a child custody dispute are encouraged to contact a local San Diego family law attorney with experience handling such matters.

In a recent custody case, the mother sought to modify the custody arrangement concerning her 17-year-old daughter. Since 2006, the teenager had been living with her father, who had opposed the change of custody. Although the parties did not come to an agreement while attempting to mediate a custody plan, the mediator met with the parties and received voice messages from the child's therapist detailing her on-going treatment. After conducting the evaluation, the mediator recommended that the daughter change her residence (at the end of the school year) from the father's home in Oakland to the mother's in Santa Cruz.

Three days prior to the hearing on the matter, the court notified the parties of the mediator's recommendation. The father raised a few objections, namely that they only learned of the recommendation three days before the hearing, and that the mediator never actually spoke to the child's therapist, but relied on the information in the voice messages. The court postponed the hearing a few weeks but still adopted the mediator's unchanged recommendation and modified the custody order. The father appealed the decision. The court then asked the father to prepare a brief addressing the issue of whether the appeal is "moot."

The court of appeals pointed out that an appeal is moot when an event occurs which makes it impossible for the court to grant relief to the appellant. Under the UCCJEA, the courts in California have jurisdiction over child custody matters. The statute defines "child" as a person who has not yet reached 18 years of age. This means that when a child turns 18, the court relinquishes jurisdiction. The court concluded that when the parties' daughter -- who is the subject of the lower court's custody order - reached her 18th birthday, the issue on appeal became moot.

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February 13, 2014

California Court of Appeals Sets Forth General Law Regarding Division of Marital Property

mortgage-and-money-6-966070-m.jpgCalifornia is a community property state. This means that marital property -- items acquired during the marriage -- will typically be divided equally upon divorce. A significant part of most divorce proceedings is identifying (and then valuing) marital property. But there are many complicated factors to take into account, such as whether one spouse or another separately holds the title to any of the property accrued during the marriage. To protect and maximize your rights in a divorce proceeding, it is essential that you contact an experienced family law attorney who is well versed in the local laws and the San Diego court rules and procedures.

In a recent California court case, the wife appealed from a judgment in her marital dissolution action. She argued that the trial court erred by identifying certain property as belonging solely and separately to her husband, including real estate as well as rights and benefits in a pension plan. The couple's first marriage together lasted from 1974 to 1986 when they divorced. They chose to remarry in 1990 but later separated in 2007, and are now going through their second divorce. At various points throughout these proceedings, the parties were represented by counsel, but as of the date of trial, both spouses were representing themselves.

Before, and during their marriage, the parties acquired various real properties in California, Nevada and Mississippi. At some point after the separation, the court approved the parties' stipulation that they each would retain temporary possession of certain personal property that they would not sell or otherwise dispose of until the court issued an order. The trial lasted two days and each spouse presented various items of evidence. The court ultimately handed down several findings, identifying certain real properties as belonging separately and solely to each of the spouses, respectively. The court also awarded each party the furniture and furnishings currently in his or her possession.

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February 6, 2014

California Family Code Governs Jurisdiction for Child Custody Proceedings

california-flag-497343-m.jpgLegal proceedings that involve the welfare of children can be some of the most trying and stressful matters for all affected parties. Child custody disputes, in particular, require special attention to the best interests of the children. There are numerous legal issues that will need to be addressed every step of the way, many of which would never occur to parents, such as determinations related to "jurisdiction" of the matter. Because the outcome of a child custody case can significantly impact a family's future in terms of parenting arrangements, it is critical that an experienced family law attorney handle the matter with care and competence. If you are facing a child custody dispute of any kind, you are encouraged to contact a local San Diego attorney as early as possible in the proceedings.

A recent case exemplifies the need to pay attention to every detail of a child custody matter. Here, a California court of appeals concluded that the juvenile court lacked subject matter jurisdiction over a custody dispute, where there was evidence that the child lived in San Diego for less than six months, and prior to that, lived in Mexico. According to the facts of the case, the child was born in San Diego in 2005, but lived in Mexico with his parents and attended school there. In January 2013, the mother brought the child to San Diego.

Two months later, the San Diego County Health and Human Services Agency (the "Agency") received a report indicating that the paternal grandfather had abused the child in Mexico. In response, the mother presented the Agency with letters from the Mexican government to show that there was a services assessment for the child. Further, a Mexican official confirmed that there was an active case against the grandfather. In April 2013, the Agency filed a dependency action for the child, arguing that both parents were currently in jail and unable to arrange for the child's care. He was placed in a foster home.

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January 30, 2014

Appeal of Child Custody and Support Order Must Include Complete Record of the Hearing

justice-srb-2-1040137-m (1).jpgMany litigants choose to represent themselves in court proceedings, and not hire an attorney. While most lawyers would advise against this, some people continue to conduct their cases "pro se" - without the assistance of counsel. It has been suggested in a recent article, however, that parties involved in family law cases, where the fate of a child is involved, would best be served by hiring an attorney. To take this point one step further, parents contesting child custody and support cases are encouraged not only to hire a family law attorney to protect their rights, but also to consult with an experienced practitioner with full knowledge of the local San Diego court procedures and requirements.

In a recent case, the California court of appeals denied the father's appeal of the lower court's order, pointing out that appellant failed to provide a compete record of the three-day hearing, and did not identify any legal error on the appellate record. The father was not represented by counsel and appeared in "propria persona" or for oneself (aka: pro se). Here, the couple married in 1991, had two daughters in 1998 and 2000. In 2004, the wife filed for divorce and the marriage was dissolved in December 2006. The court awarded the parents joint legal custody, and the mom received primary physical custody with an allocated time-sharing arrangement. The father was ordered to pay $2,000 per month in child support. There were other provisions in the support order identifying the sharing of certain additional expenses.

In 2009, the couple agreed to temporarily grant the mother sole legal custody, allowing the father to have limited supervised visits due to his pornography addiction (for which he agreed to seek treatment). In 2010, the couple entered into another stipulation acknowledging the father's progress in treatment and restoring the joint legal custody but affording the mother the authority to make all of the decisions concerning the children's health, education, activities and overall well being. The stated goal under the second stipulation was to eventually fully reinstate the original December 2006 order and judgment.

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January 23, 2014

Appellate Review of Child Custody Order Must Be Filed in a Timely Manner

calendar-840874-m.jpgCalifornia law governs many aspects of family court proceedings. Divorcing spouses are expected to follow the various rules of procedure applicable to their case, including matters relating to child custody and visitation. Failing to adhere to important time constraints can significantly impact the outcome of your case, and consequently, your family's future. In a recent California case, the father failed to timely appeal two separate child custody orders and was ultimately precluded from contesting certain dissatisfactory court rulings. For this reason and for many other critical needs, parties who are dealing with child custody and visitation matters are strongly encouraged to seek the advice of a local San Diego family law attorney.

In the case mentioned above, in February 2008, the court ordered the mother sole legal and physical custody of the couple's two daughters, ages one and three. The order also permitted the mother to move with the children from California to Michigan, where her parents lived. According to a court evaluator's report, the mother was more likely to promote a positive relationship between the non-custodial parent and the children, than the father would be if he were awarded primary custody. The father was entitled to monthly visitation and the mother would be required to bring the children to California each summer. The February 2008 order was a final judgment in the custody dispute. The father failed to appeal the order.

In November 2008, the father attempted to modify the custody and visitation order, but to no avail. The court entered an order on February 7, 2011, denying the modification request, finding that there had been no significant change in circumstances requiring such a change. The court noted that there was no evidence supporting the father's claims that the children were subjected to (or at risk of) sexual abuse by the grandfather. The court also refused to find "parental alienation" concerning father's allegations that the mother: 1) failed to accommodate his travel delays and 2) failed to encourage the girls to speak with him on the telephone.

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January 16, 2014

A Voluntary Declaration of Paternity Does Not Guarantee Presumed Father Status

paper-family-ii-832858-m.jpgIn some family court cases, there may be a question related to the identity of a child's father. Under California law, a determination of paternity or "parentage" is a significant factor in a child's life. Identifying a child's legal parents has the potential to seriously impact many financial and emotional issues. In fact, before a court will render orders concerning child support, custody and/or visitation, the parties involved must establish paternity. With such important items to be resolved, it is critical that parties reach out to an experienced family law attorney to help sort through their rights. Parents with questions concerning child custody, support or visitation are encouraged to contact a attorney with in-depth and comprehensive knowledge of the local laws and procedures in the San Diego court system.

In a recent California court of appeals case, In re Jovanni B., two men claimed to be the child's father. The first is John B., who was living with the mother when the child was born, and who also signed a voluntary declaration of paternity. The other is Brian H., who submitted to court ordered DNA testing that ultimately revealed that he was in fact the child's biological father. Upon receiving the DNA test results, the juvenile court not only dismissed John from the proceedings, but offered "reunification" services to Brian.

At the beginning of this case, the Los Angeles County Department of Children and Family Services (the "DCFS") asserted jurisdiction over Jovanni under the state Welfare and Institutions Code, based on evidence that the mother and John engaged in violent behavior in Jovanni's presence. During the DCFS proceedings, the mother identified John as the child's father and he signed the voluntary family maintenance plan as such. During sessions with a state social worker, the mother indicated that Brian, and not John, was Jovanni's biological father.

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January 9, 2014

California Court of Appeals Affirms Decision Ordering Wife to Reimburse Husband's Spousal Support Payments

mortgage-and-money-2-963935-m.jpgDuring separation or divorce, spousal support is the payment that a court orders one spouse to pay to the other, on a monthly basis, for general support. Determining the amount of spousal support is a complicated process, and one that is not governed by any specific legal guidelines. The amount awarded fluctuates from case to case. Parties are encouraged to consult with an experienced San Diego family law attorney, someone who has detailed knowledge of the local laws and practices. Doing so will help to ensure that your right to receive a suitable amount of support is met (or to protect you from paying an unreasonable amount of spousal support).

Many surprising disputes have arisen over the right to receive spousal support in family law cases throughout California. In a recent court of appeals case, a husband sought to terminate his spousal support payments to his wife based on evidence that she remarried. The wife opposed the motion, arguing that she never actually remarried, but rather, merely procured a marriage license in Arizona without "consummating" the marriage. The parties later obtained an annulment, which she claimed was not the same as a divorce.

Here, the parties were married in 1985 and had two children who are both adults. The wife filed for divorce in 2000 and the judgment of dissolution was entered in 2001. After being awarded a temporary monthly support of $1,423, the wife was later awarded $2,400 in spousal support for five years beginning July 2002. At that point, the husband was also ordered to pay wife's attorney's fees of $25,000. Five years later, in October 2007, the wife sought a modification of spousal support - to permanent support, claiming that she had several medical conditions that prevented her from obtaining full-time employment. In June 2008, the court reinstated the $2,400 monthly payment, and the following year the award became permanent. The court ordered the husband to pay additional attorney's fees of $10,000.

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