Putting in the fix for Riverbirch and the landfill's diverse ownership. Slabbed examines the Parish's suit against Waste Management

Our readers make Slabbed the good read and this post is no different as it comes courtesy of reader tips and reader assisted research. As much as I’d like to take all the credit for our Jefferson Parish coverage I can’t though I greatly appreciate the highly complimentary comments on our coverage that were left on the last Rich Rainey story on the landfill for the Times Picayune (which now appear to have been deleted), that we profiled here. Before we get to the lawsuit lets first address an insightful comment made by our friend from the jungle Curious George on the process, specifically the CPA firm hired to analyze the River Birch contract:

However, it is the subjective analyzer who can give false numbers to an honest CPA which will result in misleading conclusions and intentional fraud.

George nailed it because in an Agreed Upon Procedures Engagement only the assertions specified by management will be examined by the CPA. Thus how the question is asked is an important determinate of the answer. For example let’s pretend River Birch’s tipping fees was actually a dollar a ton cheaper than Waste Management instead of the other way around. If the question is “Does the River Birch contract contain cost savings over Waste Management?” The obvious answer is yes. Also suppose the landfill in St Bernard was $5/ton cheaper but was never considered by the Parish Council, is River Birch really the best deal? The answer is no but the question wasn’t whether the Parish’s taxpayers got the best deal. In short folks, the devil is in the details with the CPA review.

In this installment of As the Landfill Turns we’ll take a look at the Parish’s lawsuit against Waste Management, the purpose of which is to clear Waste Management out of the way so Butch Ward and company at River Birch could belly up to the taxpayer trough. The suit also helps us add data elements to the mathematical word problem we began to solve in my last landfill post so let’s again circle back to Paul Rioux’s Times Picayune story on the subject circa June 2009 to begin:

River Birch will be paid a tipping fee of $21.50 per cubic yard for household garbage from unincorporated areas of the parish and Jean Lafitte.

That’s a dollar more than the parish currently pays Waste Management to operate the parish dump, but the parish’s overhead costs to maintain and continually expand the dump are more than enough to offset the difference, Wilkinson said.

The data element that is missing from the equation is the number of tons subject to the tipping fee so we can figure Wilkinson’s “savings” on overhead. I found this in the Parish’s lawsuit against Waste Management:

….enforcing the law and contract provision limiting the maximum annual tipping fee payable by the Parish to 240,000 tons times the tipping fee.

The suit goes on to detail an alleged Waste Management overcharge saying it is at least $3,000,000 and counting which translates to another 145,000 tons plus of household waste. The tonnage does not lie and alleged overcharge relates only to not getting council approval for the extra trash that was collected. As such we’re up to 385,000 tons of trash at a dollar more per ton or $385,000 per year in overhead charges Wilkinson says he could save Parish taxpayers. Does it really cost that much to oversee the landfill contract, especially considering other costs such as woody waste disposal are not factored in?

Aside from the alleged overcharges the Parish’s suit has several pages detailing how Waste Management did not pick up trash after Katrina which I thought was funny considering Aaron Broussard’s bone headed decision to abandon the pumping stations is what caused the Jefferson Parish’s east bank flooding. I also found it slightly amusing the Traveler’s is also being sued as it must be Waste Management’s insurer.

Wlikinson and company however we not amused when Waste Management asked for an extension to file their reply around 2 weeks after the suit was served on them. I think it is clear the gang intended to play hardball with Waste Management, at least until Wilkinson and Whitmer’s double-dealing with Lagniappe Insurance came to light.

As with everything in Jefferson Parish it is the players that give color to the doings and this lawsuit is no different.  The outside law firm used by the Parish is Gaudry, Ranson, Higgins & Gremillion which is Fritz Windhorst’s old law firm. Our readers no doubt remember Fritz as a long time Jefferson Parish politico whose son Steve is now a judge in the Louisiana 24th Judicial District. Mr Theriot’s lawsuit against the blogosphere was assigned to Steve Windhorst and our readers were split whether that constituted judicial shopping.

Finally there is the docket itself which is also interesting.  When an employee of a law firm leaves the firm there are generally going to be cases that are in various stages of litigation that must have counsel changed midstream.  This is accomplished via a routine Motion to Withdraw Counsel. As of last Friday the Parish was still being represented in this matter by disgraced former Parish Attorney Tom Wilkinson. Peggy Barton is evidently too busy filing frivolous lawsuits against bloggers to be concerned with such trivialities but then again we’ve had more than one source tell us Wilkinson has left the Parish Attorneys office in name only.

In any event it not only appears the Parish’s residents are being screwed on the River Birch deal they are also paying to make it stick.

I’ve embedded the original complaint on Scribd for those so interested.

[scribd id=33041395 key=key-2avtdz2fk5naxep5i9po mode=list]


16 thoughts on “Putting in the fix for Riverbirch and the landfill's diverse ownership. Slabbed examines the Parish's suit against Waste Management”

  1. A review of the record reveals that this case came to a screaching halt shortly after Parish Attorney Wilkinson resigned in infamy. And one of the contentions is that Waste Management breached the contract by failing to pick up garbage in the months after Katrina….are you serious? Force majeure as a defense leaps to mind. Great post, sop.

  2. “It’s not a question of not wanting to do business with Waste Management
    anymore. We were presented with a proposal…”

    That is a quoted answer by Wilkinson in his interview with Val Bracy when she asked him why did the Parish decide it didn’t want to do business with Waste Management anymore. One might interpolate: River Birch is a deal you can’t refuse.

    Whitmer, in referring to the prospect of recommending to the Council the need for a PRR relating to garbage, is quoted as saying:

    “…for lack of a better word, we’re going on a fishing expedition
    and seeing what we can catch…”

    To which Heebe, upon hearing the signal from Whtimer, states:

    ‘…this is just the kind of opening we’ve been waiting for…’

    I can only imagine them fishing together in Nova Scotia…

    A conspiracy is generally defined as an agreement between two or more persons to engage jointly in an unlawful or criminal act, or an act that is innocent in itself but becomes when done by the combination of actors. A conspiracy is a crime separate from the criminal act for which it is developed. A conspiracy is an inchoate, or preparatory crime.

    The above quoted response by Wilkinson is ‘the tell’ that the River Birch monopoly conspiracy hatched post- Katrina, 2005, under the direction of Whitmer and Wilkinson, and aided by Roberts and Lagasse’s Barry Bordelon on behalf of the principals of River Birch is still proceeding with the supervision of Theriot. To put it bluntly, that’s the substantive reason Roberts championed the illegal appointment of Theriot. And now we have this suspect facade of transparency, a ‘much ado about nothing’ review of a contract with River Birch that is itself fraudulently illegal. It’s ironic that we should probably thank Wilkinson, Fos and Gandolfi for their gross negligence and incompetence in scoring in favor of River Birch in furtherance of this monopoly conspiracy by their conduct, which is being attempted be covered up by this spurious consultant review of what ? Not River Birch but Waste Management? This sounds very similar to Theriot’s and the Council’s course of action in the Vandenweghe Whistlblowing matter; paying high priced professionals to protect them and their interests. What does it matter if you attack an innocent person or breach a legitimate contract, they’re not paying for.

    Having written time and time again about the various scenarios that have evolved to become Sop’s aptly coined drama, “As the Landfill Turns”, I am always learning bits and pieces that add up exponentially as it relates to this monopoly conspiracy.

    Val Bracy hammered Wilkinson about the Parish’s potential legal exercise of the Appropriations clause of it’s contract (Part XIV) with WM and identified in the Parish’s petition, allegation 13. He repeatedly said that over the years (2005 thru 2009) that using the Appropriations clause to cancel WM’s contract had been discussed with Council members and top level Administration people.

    Val Bracy also hammered Wilkinson about his representation ( we now know to be a lie) that the contract was for a total of $160,000,000 for 25 years, when in fact it would hover around $500,000,000 with variable annual CPI imputs calculated in. He says he forgot to consider that component when praising the savings the contract with River Birch would ensure to the benefit of the Parish. Well in his defense Wilkinson answered honestly when answering Val’s question about having any accountants involved, the buffoon answers NO.

    But the real jewel to this contract is the added stipulation that the Parish padlock it’s landfill for the 25 years River Birch is to operate under the terms of this ludicrous scenario… MONOPOLY…MONOPOLY…MONOPOLY… Get it Mr. Letten !

    And I suggest that the terms of this contract relating to the Appropriations clause was and is the perfect tool to carry out the monopoly conspiracy: that the contract is contigent upon the appropriation of funds by the Parish Council and if the Council fails to appropriate the monies the agreement shall terminate without liability to the Parish. In fact on two occassions the Council upon recomendation by Whitmer attempted to do just that. However it seems that Whitmer withdrew the matter from the agenda in late October 2009. It was only a few days later we learn of the Lagniappe deals and the Federal investigation that had only just begun. What a coincidence ! This is the potential danger when you have a rogue government with conditions that can be abused. What due process ? That’s only for Whitmer.

    The fact that the illigitimate Parish President Theriot appointed Barton as Parish Attorney is a disgrace and an insult to the citizens and taxpayers of Jefferson Parish, and both should RESIGN NOW !

    Prison n’est pas suffisant, nous devons ramener la guillotine pour bande de salauds.


  3. A tell tale sign in this whole process is that the proposal that produced the River Birch contract was initially supposed to be for the collection and recycling of yard waste. It was intended to have an environmental benefit and assist the Parish in preserving landfill space for future generations. Other commenters here and on NOLA have stated that at some point, the proposal was hijacked and it morphed into a

  4. OOOOOOOOOOOOOOOOOOOOOwweeeeeeeeeeeeeee Whitmergate, I do believe you may very well have revealed the “JP River Birch Big Bang Theory” and the general genesis date of the suspected conspiracy with Whitmer, Wilkinson and others at that very council meeting where you have apparently quoted the actual words from the mouths of the possible suspected co-conspirators themselves!!!!!! Even though the council meetings are not held at times when more good government citizens can attend, the video recording of them make it easy to go back in time, review council meeting videos and put the pieces of the conspiracy theory together; especially knowing now the names of some of the suspected co-conspirators.Hmmmmm,I’m curious if the FBI has reviewed some of the JP council meeting videos in the same time frame when this suspected conspiracy was being first conceived and created. Its like trying to research the “Big Bang” theory of the universe with the Hubble telescope looking back in light years of time and it takes a lot of fine-tuned expert research. Lets hope this is the reason for the delay in indictments from Mr.Letten. Seems like there is still the loud sounds of squealling pigs and a strong smell of chicken soup in the air, but the oil spill odor seems to be attracting much of the medias’ attention away. I’m anxious to hear what SupaSleuth may have to add to this discussion. Its nana’ break time. OOOOOOOOOOOOOOOOOOOwweeeeeeeeeeeeeeeee

  5. This from the 2/9/00 TP:

    “””All told, the parish contracted out more than $6.8 million in legal work during the past three years, even though it has its own staff of 15 full-time and 15 part-time attorneys. Lead parish attorney Tom Wilkinson said parish lawyers handle property matters, contracts, administrative law and legal research for federal programs. Outside attorneys sometimes are hired for expertise in a specific area that parish attorneys do not have, he said.

    The Connick firm began handling civil liability lawsuits in 1988, after Yenni and his staff decided they needed more control over the host of liability lawsuits the parish faces each year. The parish’s insurance company had been picking the lawyers to defend the parish, but Yenni negotiated a change to allow the parish president to choose attorneys from a list of firms approved by the insurance company. Yenni hired Connick’s firm and a New Orleans firm.

    Coulon replaced the New Orleans law firm with two other Jefferson Parish firms when he took office four years ago, saying he wanted to keep the work within Jefferson Parish.

    Now the insurance work is split among the Connick firm, the Windhorst firm and Ansardi , Maxwell & Power of Kenner, which includes Rep. Glenn Ansardi , D-Kenner. Ansardi , Maxwell & Power has been paid about $262,000 for parish work in the past three years. Each firm charges an hourly rate of $95 for the insurance work, a price far below rates charged to other entities, officials said.

    “We charge Kenner $125 an hour and even that is probably considered a good (low) rate,” said Michael Power, one of the owners in the Ansardi firm.

    Coulon said he chose firms to do insurance work based on a list of qualified firms provided by Traveler’s Insurance Co.

    “Certainly those firms are friends, but at the same time, I think they possess expertise in the areas they represent,” Coulon said.

    The Parish Council chooses firms for non-insurance work, ***often at the suggestion of the parish attorney.

    A parish committee works closely with the firms to decide how and whether to proceed with a case, Coulon said. “”””””

    So let me see if I have this straight:

    JP has sued its insurer Travelers along with its former waste company.

    The judge is former counsel for JP and Travelers (as JP’s insurer) – and his firm still works for JP (and Travelers?)????

    The JP counsel is the law firm of a JP state senator /father of a fellow judge.

    The men who chose the judge and the counsel to work for them are the same guys who sought to replace the defendant waste manager with a company he was doing insurance work for (at the expense of another defendant, Travelers, or no?)?

    And Ansardi referred curator cases to Broussard who partly made the decision on the case before the judge.

    And this doesn’t get mentioned in a recusal motion, why???

    This is the JP court system:

    The Judge worked for the Parish and the actual parties and persons involved and the Parish sues you.

    And the judge cannot be or won’t be recused.

    Ballgame’s over before you step in the court room.

  6. OOOOOOOOOOOOOOOwweeeeeeeeeeeeeeee Telemachus, you have exposed enough conflict of interests with Judge Ansardi in the presently pending 24th JDC adjudication of the JP Waste Management landfill contract to either start ” Wrinkled Robe II” by the FBI or attract the interests of the Louisiana Discliplinary Board and/or the Louisiana Judiciary Commission; the latter commission probably more than the former Board.I hope the FBI has read your comments and some citizen files a complaint to the Louisiana Judiciary Commission ASAP. Its nana’ supper time—OOOOOOOOOOOOOOOwweeeeeeeeeeeeeee

  7. This incestuous and incorrigible cesspool of political lawyers and judges in and of Jefferson Parish are what can best be described as evil personified. Their profligate conduct, coupled and in collusion with the abhorrent actions of JP Council and subterfuge of the illegitimate Parish President, is abominable. Tom Wilkinson is the poster child for this greed driven entitlement class. Peggy Barton is Wilkinson in persona and conduct, as is the other members of his posse of Fos, Giangrosso, Gandolfi, Tomba, Gruntz, Donelon, and Nass, to name a few. Then there are the “outside ” political contributor contract lawyers that were favored by Wilkinson and the Council to receive huge amounts of monies as fees, thereby enabling Wilkinson to play the tit for tat contribution game all over again on their behalf.

    It is a list of the usual suspects such as was alluded to by Telemachus, and includes the likes of Chehardy, Sherman; Burglass & Tankersly: Landry and Swarr; Halpern and Martin; Adams and Reese; Becknell and Tomeny; Blue, Williams; Breazeale, Sache & Wilson (Peter Butler, Jr.); Colvin Law Firm; Courcelle and Burkhalter; Phelps, Dunbar; and of course our DA’s Firm, Connick and Connick just to name a few. These lawyers seem to be a never ending source of money for these politicians; well of course, it’s those schmucks, the taxpayers’ money.

    One of the favorites is the law firm of Gaudry, Ranson, Higgins and Gremillion. Micheal Peytavin of the Gaudry firm was hired to negotiate the contract with River Birch. From January 2009 thru December 2009 the parish was billed the sum of $100,000 dollars for this contract “negotiation”. However I not certain whom Peytavin was negotiating with or for whom. Now that Theriot is continuing to press for the River Birch contract to be somehow washed clean, I suspect Peytavin will be billing in his sleep.

    Qu’est-ce qu’un putain de situation…ces gens sont programme pour le viol de notre tresoerie avec un abandonUSA v Mai…pdf

  8. Here’s an oldie but a goodie from the TP:

    7/23/98: “Jefferson Parish Council actions on Wednesday : … Authorized the Jefferson Parish attorney to negotiate with lawyers Daniel A. Ranson and Michael D. Peytavin of the firm of Windhorst, Gaudry, Ranson, Higgins & Gremillion for assistance in defending a suit by the New Orleans Publishing Group against council Chairman Aaron Broussard in connection with the awarding of the parish’s legal journal contract.”

    From the 7/24/98 TP:

    >>>By law, the parish is required to select a legal journal annually to publish legal advertisements, which inform the public of parish business. This includes proposed laws and requests for bids or proposals.

    The naming of the parish legal journal was complicated this year by litigation between The Times-Picayune Publishing Corp., publisher of The Times-Picayune, and New Orleans Publishing Group, publisher of New Orleans CityBusiness.

    The two companies have been in litigation for two years over the rights to publish legal ads in Jefferson Parish and whether CityBusiness qualifies as an official journal.

    In June, the council voted 6-1 to name the New Orleans Publishing Group its legal journal , with ****** only Councilman T.J. “Butch” Ward dissenting. The company was the low bidder at $1.89 per column inch, and the council’s decision was based on a recommendation by Parish Attorney Tom Wilkinson that there was “no legal impediment” to using CityBusiness.

    A contract was negotiated and sent to the council in early July. ****** However, Wilkinson subsequently reversed himself, suggesting that the council go with The Times-Picayune Publishing Corp., the second-lowest bidder at $2.25 a column inch. The council then voted to defer the CityBusiness contract until Aug. 5 and advertise monthly with The Times-Picayune.

    The council also asked Wilkinson to investigate whether the parish had used a bidding process, which requires awarding the contract to the low bidder, or a request for proposals process, which is more open to negotiation.

    On Wednesday, the council ***** voted unanimously to rescind the naming of New Orleans Publishing Group as the official legal journal and also to rescind the monthly contract with The Times-Picayune. The new, yearlong contract with The Times-Picayune begins retroactively July 1 and ends June 30, 1999. **** It is worth about $75,000 annually.

    ***** Peter Butler Sr., attorney for *****The Times-Picayune, said Wednesday’s action should have no impact on the litigation between the two companies. “I do think it reflects that there’s a serious issue as to whether CityBusiness is a qualified newspaper,” he said.

    Council members said that a letter from the secretary of state’s office was the primary motivator. The letter says Louisiana laws call for a publisher to be named “for a term of one year.”

    In addition, Wilkinson said the legal journal was chosen through a request for proposals, meaning the low bidder need not win. “Very clearly, parish ordinances and state law defines the publication of legal notices as a professional service, which is not subject to public bid laws,” Wilkinson said.

    Ward said the council was “correcting a flaw.”

    Meanwhile, the parish geared up to defend itself against a lawsuit filed in July by New Orleans Publishing Group, asking the courts to require the parish to execute the contract with CityBusiness.

    The request for a writ, which originally named only council Chairman Aaron Broussard, has been amended to include all seven council members, Wilkinson said. It is scheduled for a hearing July 31 in Jefferson Parish’s 24th Judicial District, Wilkinson said.

    The council voted unanimously to let Wilkinson negotiate with the law firm of Windhorst, Gaudry, Ranson, Higgins & Gremillion for help with the case, spending a maximum of $20,000.<<<

  9. Has anyone looked at a prior incident re: Ward, Heebe and River Birch, and the tussle with GNOL [greater new orleans landfill] from 1995?

    4/1/95 TP

    “”””” An attorney for the Greater New Orleans Landfill has filed a state ethics complaint against Jefferson Parish Councilman T.J. “Butch” Ward, saying Ward’s criticism of the project is designed to help a competing landfill proposed by his brother.

    Ward has criticized GNOL’s attempts to get state permission to accept an additional 7 million cubic yards of garbage, a move that could allow the landfill to remain open through 1999.

    He said Friday the complaint is an attempt to silence his questions on an issue critical to parish residents. “They’re just trying to put me on the run, but that’s not going to happen.”

    In his letter to the Commission on Ethics for Elected Officials, Stephen T. Dwyer, secretary-treasurer of landfill operator GNOL Inc., said Ward’s support of council resolutions asking questions about the extension request could possibly put him in violation of state and parish ethics laws.

    “He has consistently lobbied other members of the Jefferson Parish Council to the detriment of Greater New Orleans Landfill Inc. and in aid of River Birch Landfill Inc.,” the letter said. River Birch Inc., whose principals are Ward’s brother Jim and Jim Ward’s stepson, Fred Heebe, is trying to build a landfill next to GNOL.

    “His brother clearly has a financial interest in what happens with GNOL,” Dwyer said Friday.”””””

    1/2/96 TP:

    “””””””””””Dubbed “Landfill Alley” by nearby residents, the western edge of Jefferson Parish along U.S. 90 has become a collision point of political haggling, big-money private development and evolving state and federal environmental regulations.

    The parish-owned Jefferson Parish Landfill, the Greater New Orleans Landfill and the proposed River Birch Landfill are tangled in concurrent lawsuits, the outcome of which could determine how much Jefferson Parish residents pay to have their garbage collected.

    Meanwhile, the new Jefferson Parish Council is faced with tough choices about what to do with its landfill.

    Complying with strict new federal and state environmental laws that take effect in August would double the parish’s operating costs, said Deano Bonano, director of citizens services.

    He said there are two ways to cover the increased costs:

    Double monthly garbage collection fees. ….

    By contrast, Muniz favors increasing the parish’s presence in the landfill business.

    “We should expropriate or buy the River Birch land,” Muniz said, referring to a piece of property located between GNOL and the Jefferson Parish Landfill. “This way, we would have more room to put garbage in the future.”

    River Birch , which its owners also want to develop into a landfill, has become the wild card in the landfill debate.

    The company, which is proposing a landfill that would meet all the new environmental rules, won a court order in May that says the parish should grant an operating permit denied by the council. The parish is appealing.”””””

    2/24/95 TP:

    “””””””” The Greater New Orleans Landfill does not need Jefferson Parish’s approval to operate, even though developers who want to build a new landfill next door needed that permission, according to the parish attorney.

    Parish Councilman T.J. “Butch” Ward asked Parish Attorney Anthony Messina on Feb. 13 to shut down GNOL because it did not have the special use permit the parish required River Birch landfill developers to seek.

    GNOL, which has been operating under an agreement that requires it to close by today, is seeking an extension of the agreement. The owners say they haven’t been able to make enough money to close the site.

    A decision on the extension was expected Thursday, but Department of Environmental Quality spokeswoman Jennifer Armand said department Secretary Bill Kucharski was out of the office yesterday.

    Ward’s brother Jim is a partner in River Birch Inc., which is suing the parish over its refusal to grant the permit.

    “All we’re asking for is a level playing field,” Butch Ward said Thursday when asked about the letter.

    However, Messina’s opinion said GNOL was grandfathered into the parish zoning code because the Parish Council signed a contract with a company to dispose of parish garbage at the site in 1970.

    The property owners, Marsh Investment Inc., did not give up the right to operate the landfill after the state closed it down between 1985 and 1992 for environmental violations because the closure was involuntary, Messina wrote.

    Messina’s opinion further states that River Birch needs a special use permit from the council because its site was never used as a landfill.

    Messina declined to discuss the opinion, saying he was giving legal advice to his client, Ward.

    Ward, in a letter responding to the opinion, said parish law did not require intent for a property to lose its “non-conforming use,” rights.

    “There is no question that whatever right was given to this property to operate as a landfill expired in 1986 as a result of its cessation as a landfill for a period of one year.” “”””””””

    Etc., lots of stuff there.

    This goes way back apparently, Ward interfering with the Council; I guess Ward’s theory at some point became he was never going to let a measley Parish Attorney get in his way again.

  10. And most recently what happened to his wife, Jocelynn. Seems the Wards have a long memory. And like to send ‘messages’ to anyone who might be thinking about getting in their way.

  11. Telemachus…kudos …your compendious dissemination of all things River Birch (timeline, players, place and politics) is a must read for all who concern themselves with the drama, the ongoing monopoly conspiracy, “As the Landfill Turns”(cSop)

    A troglodyte like Butch Ward does not use such words as “cessation” or “non-conforming use”, he can hardly speak English less have such a vocabulary of word usage. I suspect a lawyer like Peter Butler, Jr. wrote the response letters to Messina.

    However I can assure you that he is the author of this quoted travesty to further stymie the orderly legal protocol: “All we’re asking for is a level playing field…” A euphemism for goodbye Messina , hello Wilkinson, come on down !

    Butch Ward…qu’est-ce qu’um trou du cul sans vergogne

  12. OOOOOOOOOOOOwweeeeeeeeeee Telemachus, you are the “King of the Landfill Jungle” !!!! I didn’t know that where my nana’ peels went(i.e the dump) was the business of the ultra rich.Like they say, “one monkey’s garbage is another man’s treasure”. I was waiting for SupaSleuth’s input and meanwhile you have blown us away with your exposure of the conflicts of interest of Judge Ansardi in the landfill lawsuit and now exposed the chronicity of the Wards and Heebes to muscle their way into developing a monopoly of the JP garbage business—–Sounds more and more every day like RICO dealings with River Birch. OOOOOOOOOOOOOOOOOOOOOOowweeeeeeeeeeeeee

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