Video the caption or insert info in post production

Discussion in 'Professional Video Production' started by LMOC, May 6, 2005.

  1. LMOC

    LMOC Guest

    Been a CLVS for 3 years, our normal procedure is like everyone else
    reading the caption on record. We add the info in post production on
    MPEGs and DVD's only. I would like to start getting this info on my VHS
    in real time at the beginning of the tape. Our state rules state that
    you are to video the caption as you are reading the info.

    My question, how do you get a smooth transition to the deponent after
    you have been focused on the caption? (i have purchased standing
    clipboards to attach the caption)

    Do you pause the video and & then tilt up to the deponent then start
    again or do you tilt up to the deponent without pausing. The 2nd option
    will give a bad transition. The first option stops the video and is
    really going off the record.

    I would like some feedback on your procedure.
    LMOC, May 6, 2005
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  2. I think I'm following this. You are a certified legal video specialist
    shooting depositions, and there is some boilerplate mumbo-jumbo that
    must be recited at the beginning, and you are now required to have a
    physical printed poster or something of this appear at the beginning of
    the tape, at the location, yes? We'll say for the sake of argument
    that you'll stipulate to that;-)

    With cameras that have an auto-focus feature, I would just zoom out
    from the poster, let the auto-focus re-lock on the deponent, then let
    the focus control go back to manual. This way, the camera does a "rack
    focus" for you. other choices might include making a CG crawl and
    supering it live on location, that adds a lot of gear and work. Some
    camcorders have a memory for these crawls and can super them on
    command. I don't know how long the text is, so i can;t be more
    nobody special, May 6, 2005
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  3. LMOC

    marks542004 Guest

    Depending on your setup I would put the caption board close to the
    camera and below direct sight line to the people seated at table.

    Focus on the card and zoom back to a wide view of the room and then go
    to closeup.

    Otherwise just allow a sloppy transition and clean it up in postwork.
    (If you are allowed to postwork this type of material.)
    marks542004, May 6, 2005
  4. LMOC

    Steve Guidry Guest

    I'm a CCV.

    What state are you in ? I've done work for jurisdictions in Texas,
    Mississippi, and California, and I've not run into that requirement yet.

    Unless Federal Rule 30 has been recently revised, this is not necessary.
    And, as I understand it, if you produce your depos observing all aspects of
    Rule 30, then all courts in the country must accept them.

    Paul, what's the scoop on this ?

    Steve Guidry, May 6, 2005
  5. LMOC

    PTravel Guest

    Steve, I don't know what the state court rules are for all jurisdictions,
    and they may very well vary. There's no caption requirement that I'm aware
    of in federal court, unless this has changed in the last couple of years
    (always possible). Actually, I just looked it up -- here are the pertinent

    FRCP 30(b)(2):

    The party taking the deposition shall state in the notice the method by
    which the testimony shall be recorded. Unless the court orders otherwise,
    it may be recorded by sound, sound-and-visual, or stenographic means, and
    the party taking the deposition shall bear the cost of the recording.

    FRCP 30(b)(4):

    Unless otherwise agreed by the parties, a deposition shall be conducted
    before an officer appointed or designated under Rule 28 and shall being with
    a statement on the record by the officer . . . If the deposition is recorded
    other than stenographically, the officer shall repeat items (A) through (c)
    at the beginning of each unit of recorded tape or other recording medium.
    The appearance or demeanor of deponents or attorneys shall not be distorted
    through camera or sound-recording techniques.

    The rules state that a deposition be conducted before, "an officer
    authorized to administer oaths by the laws of the United States." FRCP 28.

    Under the federal rules, this means a few things.

    1. The court reporter is always "an officer authorized to administer oaths
    by the laws of the United States." This means that a videographer who is
    taping a deposition recorded by a court reporter does not need certification
    of any kind.

    2. The federal rules have no requirement regarding showing the caption on
    the tape. They require only that the caption information be "repeated" on
    the tape. I construe that as meaning "read" though, I suppose, a shot of
    the caption page would serve the same purpose (though it would not contain
    the appearances which also must be "repeated" on the tape). Interestingly
    enough, at all of the video depositions I've taken (and I've taken
    hundreds), the videographer, rather than the court reporter, would read the
    caption information. This is, evidently, precluded by the rules unless, for
    some reason, the videographer is the designated court officer for the
    deposition. This would be rather odd, as there can only be one officer at a
    depo (the officer acts as judge-surrogate), and it would certainly call into
    question the validity of the written transcript.

    3. Pursuant to Erie doctrine, state procedural rules usually apply to
    federal litigation. If a state has _additional_ rules vis-a-vis video
    depositions, they would apply to a deposition taken under Rule 30. For
    example, under California _state_ law, a deposition notice must indicate
    whether real time computer transcription will be used. This would apply to
    a Rule 30 deposition notice in a federal action for a deposition taken in
    California, even if the action is venued somewhere else.

    See . . . ask a lawyer a simple question and get a 20 page dissertation. ;)
    PTravel, May 7, 2005
  6. LMOC

    LMOC Guest

    Thanks for everyones input, I am in SC. What brought this up, I was
    recently in a depo with an attorney who was the president of the SC bar
    last year and he was very straight forward about our SC rule 30. As he
    read it, it states that the videographer record while announcing all
    the specifics of a depo. Believe me, I always read the rule as you guys
    do. To me "recording" the caption and the officers is reading it or
    videoing it. Take your pick.

    My wife(who is a state reporter) and I discussed it and I think that
    the solution to this is, we will read and video the caption in without
    announcing on the record, pause the camera, focus on the deponent, un
    pause the camera and announce the date and time and then announce on
    the record. I am good friends with her judge as well; I might get his
    opinion of the rule.
    One of the NCRA CLVS officials was surprised about this rule as well
    and did not have a solution.

    Also from what I have gathered, you should only follow Federal Rules
    when your state doesnt have any rules to follow.

    LMOC, May 7, 2005
  7. LMOC

    PTRAVEL Guest

    You follow the federal rules when you're doing a deposition for a federal
    court matter. For a federal court matter, if your state has rules which
    supplement the federal rules, you follow them as well. If it has rules
    which contradict the federal rules, you do not.

    For state court matters, the federal rules should be irrelevant, unless, for
    some reason, the state has incorporated them in the state's rules.
    PTRAVEL, May 7, 2005
  8. LMOC

    LMOC Guest

    I had always thought that if it was a Federal case you are to follow
    Fed. rule, But from what I am reading, we are to follow the state rule
    Well I am wondering how to follow state rules and Federal at the same
    time as stated in this last reply. I dont think there are supplements,
    I think you follow one of the two.
    One rule that is specific to SC is to never move the camera off of the
    witness unless agreed upon by both parties. Just because it is a
    Federal case doesnt mean that we disreaguard this rule. Basically if we
    are in SC, we follow SC rule. This is what we learned in CLVS. I will
    follow up on this. Our attorney in SC has got us wondering.
    LMOC, May 7, 2005
  9. LMOC

    PTRAVEL Guest

    No, that's not right. Erie Doctrine (named after a U.S. Supreme Court case
    by that name) provides, essentially, that federal substantive law will
    preempt state substantive, but federal procedure law will not preempt state
    procedural law. You need to follow both, as long as state law doesn't
    conflict with federal law. This is a question that can only be answered by
    an attorney.

    I can't give you legal advice -- you're not my client. However, the federal
    and state laws aren't in conflict. Federal law wants the caption
    information "read" into the video record. You can do that AND still include
    whatever SC law wants.
    Nope. You follow both.
    Good rule. I wish it was universal.
    I didn't say that you did. You need to read what I wrote very carefully.
    If you're certified by a credentialing organization, ask them. If you can't
    ask them, ask an attorney.

    I would be more than a little ticked off (to say the least) if a
    videographer produced an inadmissible record of a deposition that I took.
    I don't believe they told you that.
    Which is what you need to do.
    PTRAVEL, May 7, 2005
  10. LMOC

    Steve Guidry Guest


    Under #2 below, I think you're saying that if the videographer does the
    "read-on" (style of the case, and the appearances), the authenticity of the
    transcript could be called into question. Please elaborate a bit . . . how
    would that argument play out ?

    Also, - - and i know you're not my attorney, so your response wouldn't be
    advice - - I've had quite a bit of resistance from attorneys when I ask them
    to identify themselves for the video record - - and that's only for the
    first tape. i don't usually do this on subsequent volumes, because of this
    sometimes extreme resistance, even resistance by the attorney hiring me.

    The view around here in East Texas seems to be that the video is just an
    add-on, and not really important. The attorneys seem to hold that they'll
    just let the court reporter handle the appearances, and argue the tape's
    authenticity to the judge if it ever comes up. It seems a screwy way to
    handle the client's important business, but I'm caught in a situation where
    I know more than the attorneys about this narrow slice of the situation, and
    they aren't letting me serve them well. And if I try to do so, then they
    just call someone else who will give them what they want with no backtalk.
    I had one ask me "Where did you go to law school?", and then follow up with
    "don't tell me the law here. I'm the attorney."

    I don't work for that guy anymore, but I'm kinda at a loss for how to
    proceed on these other less extreme cases. In any other situation, I'd
    insist on a 'ground rules" conversation with the client, but I rarely get to
    talk with the attorney before we meet at the deposition - - it's all
    scheduled by his office manager.

    Can you shed any light (not advice) on this for me and other members of the
    group who may be dealing with similar situations ?

    Steve Guidry, May 24, 2005
  11. LMOC

    PTravel Guest

    I can only speak to the federal rules. The require, merely, that the
    caption information appear on the tape. They don't specify who puts them
    there. For every video deposition I've done, the videographer reads the
    caption information. Appearances are entered by the attorneys themselves,
    though I suspect that's merely to ensure that names are pronounced right and
    microphones are working.
    By "identify themselves," do you mean state their names at the beginning of
    the tape? I can't imagine why they'd resist that, as it's certainly common
    at the video depositions that I've done.
    I've never re-identified myself for subsequent volumes of a tape unless the
    deposition was adjourned and resumed at a different date.
    Heh. I'm tempted to make a Texas joke, but I'll refrain. ;)

    Video isn't an add-on. It can be a substitute for a written transcript
    though, in practice, it is rarely used that way. I've seen lawyers take a
    casual attitude towards the video record. However, I've also seen lawyers
    take casual attitudes towards other aspects of legal practice. It's simply
    bad lawyering, pure and simple.

    Well that's kind of silly. The tape would be admissible as evidence,
    regardless of the legal formalities -- it need only be authenticated as any
    other piece of physical evidence, e.g. someone needs to testify, "This tape
    accurate depicts that which it purports to portray." Without the
    formalities, however, it could not be used in lieu of a transcript.
    Somewhere on is an article I wrote (actually a re-print of a very
    long reply to an inquiry in one of the forums there) that talks about
    depositions. One of the points that I made was that, bottom line, it's the
    attorney's a$$ that's on the line, and that makes the attorney the Grand
    Poobah of the deposition. When I take depositions, I expect the
    videographer to do it my way. As an example, I like to sit directly across
    from a witness so that I can look them in the eye, and I prefer the camera
    to be somewhere over my left shoulder. I once had a videographer get in to
    an arguement with me about camera placement -- he wanted me to the side of
    the camera, with the witness directly in front of it. It was a very short
    argument -- I fired him on the spot.

    If a video record is screwed up and rendered inadmissible or unusable due
    the actions of the attorney, it is the attorney, and not the videographer,
    that will take the blame. In your example, if the attorney doesn't want to
    enter an appearance on the video record, that's probably sufficient to
    invalidate it as the official record of the deposition under the federal
    rules. If that happens, it's the attorney who refused to enter an
    appearance who will risk liability (assuming he doesn't try to blame it on
    the videographer -- always document these things).

    All you can do is inform the attorney of how you'd like to do it. If he
    wants to do it another way, it's his neck (and his client's money).

    Right. I usually chat with videographers before a depo because (1) I'm a
    video freak and like to talk shop, and (2) there are a couple of things that
    I do that the videographer needs to know about.
    All I can say is this: the lawyer is the boss -- he's in the role of
    producer/director/star and gets to call the shots, even if he screws things
    up. If you don't like working for a particular lawyer, you did the right
    thing: you stopped accepting his engagements.

    Note that all this changes if the videographer is the deposition office,
    i.e. there is no court reporter and the video record is the only record.
    Then, as an officer of the court, you have to ensure that everything is done
    in compliance with the law.
    PTravel, May 25, 2005
  12. I gotta jump in for a moment.
    I have only done two depositions. Both in the last 12 months. And both in
    Northern California. (I live in Seattle)
    Both were doozies. One was shot a couple days every two weeks over a course
    of a couple months and the other was the same drill, but took eight months
    to complete. ( I must have had 30 shooting days between the two)
    Every day, as we initially rolled tape, the soundman (we had six mikes in
    place) would read into the record a statement identifying the case. (Paul
    knows what it's called)
    The court reporter also typed a written record of the statement the soundman
    The court reporter then asked that all parties present AND on the speaker
    phone (there were up to twenty five lawyers in the room and logged into a
    conference call, on both sides participating) to identify themselves. We
    did this EVERY morning.
    Knowing that this dep would probably change venues a time or two, it was
    decided by the law firm that we would light the witness and place him in
    front a background canvas that we would always bring with us. That way it
    all looked the same on camera.
    In San Francisco, over the course of eight months, we used several different
    hotel conference rooms. So, for consistency we used a simple gray backdrop,
    lit by a dedo with a break-up pattern.
    The witness (there was only one) was lit by a back light and a soft box for
    the key / fill.
    The camera didn't move, except for basic composition purposes if the witness
    leaned left or right to hear what the lawyers were asking.
    The camera NEVER ZOOMED in. NEVER.
    I did zoom out slightly if the witness leaned forward to read or examine
    However, once the focal length changed to wider, it didn't move back in
    until after we stopped to change tape or when we were wrapped for the day.
    We used a lot of mics.
    One for the witness. One each for the two lead lawyers. One for the speaker
    phone. One for the audience (all the other lawyers in the conference room.)
    And one as a slate mic for the soundguy.
    As Paul also mentioned, the lawyer (or law firm) paying for it all was the
    boss. His way, or the highway. (sometime though, the highway is quite nice)
    Fortunately, we were working for a pretty savvy and well established law
    firm and they know how to comply with the law. I guess that's the key.

    Bill F.
    Bill Farnsworth, May 25, 2005
  13. LMOC

    PTravel Guest

    The record is open when the videographer (or soundman) reads the case
    caption. The court reporter's transcript covers the entire open record, so
    she (or he) will transcribe the videographer's caption, as well as the
    attorneys' identifications.

    She did that for her own convenience, and it's typical if there are a lot of
    people present (and, particularly, if people are present on the telephone).
    The record has to reflect who is there. If you've ever seen a written
    transcript of a deposition, you'll see things like, "Attorney X joined the
    preceding" when someone comes into the room.
    Interesting. My personal preference is that lights never be used though, of
    course, there's no procedural rule either way.
    I like those backgrounds. Most of the videographers I work with bring these
    springy things that coil up into a little disk, but when unpacked spring
    open into a 4 x 6 background.
    Exactly. And it also means that the trier of fact won't be distracted (or,
    worse, biased) by the shooting environment ("Look at all those diplomas on
    the wall -- who is he trying to impress?")
    I prefer the camera to not move at all. Witnesses shift around, and it's
    one of the subconscious factors that a trier of fact uses to evaluate
    credibility. If a witness winds up slumping down in his chair as the
    deposition proceeds, I want the trier of fact to see that, and don't want
    the videographer to re-frame.

    The only exception to this is when I'm doing a depo that involves physical
    evidence. As I'm an intellectual property litigator, I tend to do a lot of
    these. I'll show a witness a thing and ask, "Please identify the transverse
    actuator mounting on the accused pump." I'll tell the videographer ahead of
    time that, when I ask things like that, to make sure that whatever the
    witness is showing is clearly visible. I'll even say, on the record, "Mr.
    Videographer, would you please zoom in on the pump so that we may see what
    Mr. Witness is indicating." Once the witness has finished, I'll say, "Mr.
    Videographer, we can resume," and I'll watch the monitor and wait until the
    shot is re-framed before proceeding.

    Never say never. ;) See above.
    When I take video depos, I want everyone miked. This means, at least, lapel
    mikes for the questioning attorneys, the defending attorney and the witness.
    I also want anyone else in the room recorded if they speak -- many of the
    videographers I work with use PZM mikes for this purpose.

    Anything that winds up on the written record should also be heard on the
    video record.
    Yup. The only time I ever had trouble at a video deposition was when
    opposing counsel decided that he wanted his own video recorded, and wanted
    an employee of his client to video the deposition with a consumer camcorder.
    There were so many things wrong with that, I don't know even know where to
    PTravel, May 25, 2005
  14. Oops! My bad.
    Actually, it was the lead attorney representing the law firm that was paying
    for the deposition that asked everyone present in the room and on the
    conference call to identify themselves. (plaintiff reps first then defence)

    Bill F
    Bill Farnsworth, May 25, 2005
  15. LMOC

    PTravel Guest


    It makes sense. The rules generally limit those present to parties (or, if
    a party is a corporation, officers of parties), witnesses, attorneys and
    support staff. I'll always question why someone I don't know is there and,
    if they say, "Oh, he's a vice president" (as was once told to me by a
    mafioso type about the large enforcer standing behind the witness chair),
    I'll make sure it appears on the record.

    I've covered a couple of depositions in some mass tort cases for other
    lawyers in my firm. These are huge, multi-party actions involving dozens of
    plaintiffs and defendants. I did note that things were an awful lot more
    casual at these depositions than at the ones I'm used to attending.
    PTravel, May 26, 2005
  16. LMOC

    Steve Guidry Guest

    She did that for her own convenience, and it's typical if there are a lot
    Usually, around here, all the attorneys just pass the court reporter a card,
    and that atkes care of that. I'm guessing that this is the most common way
    of handling this . . . ?
    I carry a black one, and a light blue one, so I can always give some
    contrast between the deponent and the background.
    I did a depo once - - before I got the backgrounds - - where the pictures on
    the wall were of Civil War "rebel battle heroics". This was pretty
    interesting when you know that : 1) It was in Mississippi, and 2) It was
    a case with racial overtones. This is when I decided to get the
    It's pretty common around here for opposing attorneys to refuse to wear a
    mic. They don't want to be troubled with going off the record every time
    they want to confer with their client. Our trade group - - the American
    Guild of Court Videographers - - recommends that we NEVER agree to pot down
    a mic, and instead insist that they go off the record. In practice, I
    usually just give the opposing attorney an SM-57 on a short stand, so he can
    push it away and confer. That seems to satisfy everyone.

    On another audio note - - I always record "split-track" audio : deposing
    atty and ambient go on the left channel, and opposing atty and deponent go
    on the right channel. This really is for the benefit of the court reporter,
    since as a courtesy, I always give him/her the split-track audio cassette I
    make along with the video. That way s/he can listen to just one side if
    both sides talk at the same time. Court reporters love this, because my
    recording is always better than teh little microcassette they make.
    video record.

    Paul - - Let's suppose that my mic happened to catch a whispered atty/client
    concerence while on the record. The court reporter didn't hear it live, but
    discovered it when reviewing the cassette I give her. Would she be likely
    to include it, and would it be admissable ?

    It's pretty common for attorneys around here to have a paralegal or other
    staffer record depos with consumer gear, using the on-camera mic. I get a
    fair amount of price-resistance because that's what they're comparing me
    with. By contrast, I get almost NO price resistance from out-of-town
    lawyers, and absolutely none from lawyers whose deops come to us through
    referral services.

    Steve Guidry, Jul 14, 2005
  17. LMOC

    PTravel Guest

    At non-video depositions, yes. In fact, court reporters will, frequently,
    have a special form for the lawyers to fill out that calls for name, firm,
    etc., and whether your want a printed depo transcript, miniscript, ASCII
    disk, etc. I just hand them a card with the form.

    That's interesting. Under the federal rules of evidence, as well as most
    states with which I'm familiar, the presence of those pictures could be
    grounds for, at minimum, an instruction to the jury and, in a worst case
    scenario, exclusion of the depo video. Some lawyer was sloppy in allowing
    the deposition to proceed. That's one of the reasons I always get up and
    look at the monitor from time to time, whether I've hired the videographer
    or he's working for the other side. Neutral backgrounds solve all these
    problems neatly.
    Wow! That means opposing counsel's objections won't be heard when the video
    is played -- I argue that's a waiver of objections. ;)

    As for conferring with clients during the deposition, though it's done a
    lot, it's actually prohibited under the federal rules. I once closed the
    record on a deposition when opposing counsel insisted on taking a break to
    confer with his client while a question was pending. I told him he could
    have a break as soon as his client answered the question. He said, "I have
    to go to the bathroom. Are you telling me I can't go to the bathroom?" I
    said, "Of course you can go to the bathroom -- just as soon as your client
    answers the pending question." He wouldn't let his client answer, so I
    closed the record and told the videographer and court reporter that we were
    done for the day. Whenever I start a deposition, I always have a chat with
    the court reporter and videographer before I begin, and tell them that, if I
    say we're closing the record, I'm not bluffing -- I mean it, and they should
    do so, rather than asking, "are you sure?" or waiting to see if we resolve
    the dispute. When opposing counsel saw the court reporter and videographer
    packing up and knew that I would put his conduct in front of the magistrate
    judge, he instantly changed his tune and let his client answer my question.
    That's absolutely the correct way to do it. The only way to go off the
    record is by stipulation. I've been at depositions where either I or
    opposing counsel refused to stipulate to going off the record. I also took
    a deposition in Hong Kong once, where opposing counsel and his clients kept
    making snide remarks about my client under their breath. Unfortunately, I
    was working with a local videographer who didn't mike everyone or use PZMs,
    so the video record didn't pick it up. If it had, I would have ended the
    deposition, brought a sanctions motion back in the US, and would have
    gotten, at minimum, an all-expense paid trip back to Hong Kong courtesy of
    opposing counsel.
    I know enough about mikes to know that a good condensor mike can pick up
    sounds at a surprising distance. When I go off the record and want to talk
    to my client, I take him out of the room -- you can never be too careful.
    That's interesting, and makes a lot of sense. Anything that results in a
    more accurate record is a Very Good Thing, as far as I'm concerned.
    It depends on the court reporter, as well as the circumstances. Lots of
    court reporters automatically edit out comments inadvertently made on the
    record. However, some of them will record everything, and I've seen records
    with wonderfully embarrassing things in them. With respect to the recording
    itself, it would be admissible, though I'd imagine any attorney who got
    caught this way would bring a motion to exclude it as an inadvertent breach
    of attorney/client privilege.

    I was once taking a deposition (also in Hong Kong, though a different case)
    that involved copyright and trademark infringement of a toy talking parrot.
    The parrot had a voice-activated digital recorder -- if you said something,
    it would automatically repeat it back twice at a higher pitch while flapping
    its wings. The depo took place in the showroom of one of the parties, and
    there were about a dozen of these parrots on display. At one point, the
    deposition got a little heated and one of the lawyers shouted, "OBJECTION!"
    He was loud enough to trigger the parrots, and they all started flapping,
    while shouting, "OBJECTION" in a high voice. It cracked us all up, but we
    were all wondering what the court reporter would put in the record. I told
    her (on the record) she shouldn't include the parrots' comments unless they
    were sworn in. ;)

    Wow! I don't see how the "home made" video could possibly be admissible,
    since it's clearly open to attack on the grounds of bias. Even if that was
    not an issue, who wants to use a grainy, shaky, poorly lit video with lousy
    sound? That's not economy, that's malpractice, as far as I'm concerned.
    PTravel, Jul 14, 2005
  18. LOL! :))
    That's one of the funniest, clean, lawyer stories I've heard in a long time.
    Does posting it here in Usenet make it public domain, or do you retain the
    rights to your written record of it? :)
    Richard Crowley, Jul 14, 2005
  19. LMOC

    PTravel Guest

    I'll have to assert my copyright. ;)

    That case was my first big IP matter, and involved a variety of bizarre and
    strange occurrences, including death threats to witnesses, involvement of
    the Army of the Peoples' Republic of China, the Communist party, and a whole
    bunch of Texans. However, the chief strange occurrence resulted in my
    meeting my now-wife on a blind-date in China. One of these days, I'll have
    to write a book. In the mean time, feel free to tell the story. ;)

    To bring this thread back on topic, I celebrated the ultimate conclusion of
    the parrot lawsuit by making a video titled, "La Morte D'un Perrot" (Death
    of a Parrot), a black-and-white, pseudo-cinema verite short in which we
    executed (by firing squad) one of the parrots in the desert. I shot the
    video with the camcorder I bought for my wedding, and that's what started my
    long obsession with amateur video.
    PTravel, Jul 14, 2005
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