Brown motion (New York) · Go Syfert
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Brown motion in New York

28 New York opinions name it 9 courts 1848–2026 3 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Russo v. Sabella Bus Co.green
nyappdiv · 2000 · cited in 3 New York opinions naming this issue, 2016–2016
2 sentences

2016Brown submitted evidence establishing as a matter of law that his efforts to warn approaching motorists of his disabled van were reasonable (cf. Axelrod v Krupinski, 302 NY 367, 369-370 [1951]; see generally Russo v Sabella Bus Co., 275 AD2d 660, 660-661 [2000]), and the deposition testimony of a witness that she observed his van without its hazard lights flashing more than two hours after the accident did not raise a triable issue of fact.

2016Brown submitted evidence establishing as a matter of law that his efforts to warn approaching motorists of his disabled van were reasonable (cf. Axelrod v Krupinski, 302 NY 367, 369-370 [1951]; see generally Russo v Sabella Bus Co., 275 AD2d 660, 660-661 [2000]), and the deposition testimony of a witness that she observed his van without its hazard lights flashing more than two hours after the accident did not raise a triable issue of fact.

33
Axelrod v. Krupinskigreen
ny · 1951 · cited in 3 New York opinions naming this issue, 2016–2016
2 sentences

2016Brown submitted evidence establishing as a matter of law that his efforts to warn approaching motorists of his disabled van were reasonable (cf. Axelrod v Krupinski, 302 NY 367, 369-370 [1951]; see generally Russo v Sabella Bus Co., 275 AD2d 660, 660-661 [2000]), and the deposition testimony of a witness that she observed his van without its hazard lights flashing more than two hours after the accident did not raise a triable issue of fact.

2016Brown submitted evidence establishing as a matter of law that his efforts to warn approaching motorists of his disabled van were reasonable (cf. Axelrod v Krupinski, 302 NY 367, 369-370 [1951]; see generally Russo v Sabella Bus Co., 275 AD2d 660, 660-661 [2000]), and the deposition testimony of a witness that she observed his van without its hazard lights flashing more than two hours after the accident did not raise a triable issue of fact.

23
People v. Backusgreen
ny · 2009 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014Furthermore, the plaintiff failed to state a cause of action against the defendant Trinity Presbyterian Church to recover damages for negligent supervision (see Doe v Roman Catholic Diocese of Rochester, 12 NY3d 764, 765-766 [2009]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d at 841 ; Spielman v Carrino, 77 AD3d 816, 818 [2010]).

2014Furthermore, the plaintiff failed to state a cause of action against the defendant Trinity Presbyterian Church to recover damages for negligent supervision (see Doe v Roman Catholic Diocese of Rochester, 12 NY3d 764, 765-766 [2009]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d at 841 ; Spielman v Carrino, 77 AD3d 816, 818 [2010]).

22
Spielman v. Carrinogreen
nyappdiv · 2010 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014Furthermore, the plaintiff failed to state a cause of action against the defendant Trinity Presbyterian Church to recover damages for negligent supervision (see Doe v Roman Catholic Diocese of Rochester, 12 NY3d 764, 765-766 [2009]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d at 841 ; Spielman v Carrino, 77 AD3d 816, 818 [2010]).

2014Furthermore, the plaintiff failed to state a cause of action against the defendant Trinity Presbyterian Church to recover damages for negligent supervision (see Doe v Roman Catholic Diocese of Rochester, 12 NY3d 764, 765-766 [2009]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d at 841 ; Spielman v Carrino, 77 AD3d 816, 818 [2010]).

22
Rodrigues-Lytwyn v. Roman Catholic Diocese of Brooklyngreen
nyappdiv · 2010 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

22
Coopersmith v. Goldgreen
nyappdiv · 1991 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

22
Marmelstein v. Kehillat New Hempsteadgreen
ny · 2008 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

22
Langford v. Roman Catholic Diocesegreen
nyappdiv · 2000 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

22
People v. Freycinetgreen
ny · 2008 · cited in 1 New York opinions naming this issue, 2017–2017
1 sentence

2017Concerning the fourth Pealer/Brown factor, because the DNA profile of Male Donor A was developed at a time when no suspect had been identified, the report names neither defendant nor any other suspect, and it does not accuse defendant by directly linking him to the crime ( see People v Freycinet , 11 NY3d at 42 [report not testimonial where it "did not directly link defendant to the crime"]).

11
115-41 St. Albans Holding Corp. v. Estate of Harrisongreen
nyappdiv · 2010 · cited in 1 New York opinions naming this issue, 2015–2015
1 sentence

2015Albans Holding Corp. v Estate of Harrison, 71 AD3d 653, 653-654 [2010]; Staples v Jeff Hunt Devs., Inc., 56 AD3d 459 [2008]; Counsel Abstract, Inc. Defined Benefit Pension Plan v Jerome Auto Ctr., Inc., 23 AD3d 274 [2005]; State St.

11
Donnelly v. Feitgreen
nyappdiv · 1993 · cited in 1 New York opinions naming this issue, 2005–2005
1 sentence

2005Although the motion court opined that plaintiffs’ allegation as to actual intent to defraud was conclusory, such intent “is ordinarily a question of fact which cannot be resolved on a motion for summary judgment” (Grumman Aerospace Corp. v Rice, 199 AD2d 365, 366 [1993]), or, in this case, a motion to dismiss.

11
SNS Bank v. Citibankgreen
nyappdiv · 2004 · cited in 1 New York opinions naming this issue, 2005–2005
1 sentence

2005The motion court correctly determined that plaintiffs failed to state claims on the theory of fraudulent concealment, since the parties, as mere debtor and creditor, had no fiduciary relationship and no resultant affirmative duty to disclose (SNS Bank v Citibank, 7 AD3d 352, 355-356 [2004]), and on the theory of fraudulent conveyance pursuant to Debtor and Creditor Law § 273, which requires allegations that the debtor be rendered insolvent.

11
Wilson v. City of New Yorkgreen
nyappdiv · 1997 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Although several courts have previously denied motions to unseal where the petitioner has failed to obtain such a waiver, and is neither a party protected by the privilege of CPL § 160.50 nor is one of the parties to which the statutory exceptions apply ( see , e.g. , Wilson v. City of New York , 240 A.D.2d 266, 267 [1st Dept. 1997]; Heine , supra ), this factor alone does not end further evaluation of Mr. Brown's motion.

11
People v. Chan Lingreen
nyappdiv · 1997 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004It has been held that an action should be discontinued with prejudice where a “plaintiff’s request for a discontinuance without prejudice was an apparent attempt to evade the consequences of an adverse order on defendant’s pending motion for summary judgment and preserve its ability to commence a Federal action” (see, NBN Broadcasting v Sheridan Broadcasting Networks, 240 AD2d 319, 319 [1997]).

11
Hynes v. Karassikgreen
ny · 1979 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Our Court of Appeals has recognized that courts have an "inherent power" beyond the provisions of CPL § 160.50 to grant relief to release sealed records when the interests of justice so mandate and this power "grows out of that measure of discretionary authority courts enjoy with respect to their own records insofar as they pertain to the business of the court and when essential to the proper administration of justice." Matter of Hynes v. Karassik , 47 N.Y.2d 659, 664 (1979).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (31)

CaseCitedYears
People v. Brown green
ny · 2002
2 sentences

2024Thus, while it was appropriate to impeach the Rivera defendant with the attorney's affidavit, he was not precluded from presenting his inconsistent testimony. ( People v Brown , 98 NY2d at 232 n 2.) With respect to the Brown defendant in People v Brown , the Court held that he was bound by his attorney's prior inconsistent statement made at a Sandoval hearing, which could be used to impeach him: The facts in Brown fall comfortably within the Rivera holding.

2024Thus, while it was appropriate to impeach the Rivera defendant with the attorney's affidavit, he was not precluded from presenting his inconsistent testimony. ( People v Brown , 98 NY2d at 232 n 2.) With respect to the Brown defendant in People v Brown , the Court held that he was bound by his attorney's prior inconsistent statement made at a Sandoval hearing, which could be used to impeach him: The facts in Brown fall comfortably within the Rivera holding.

22024–2024
Williams v. Beemiller, Inc. green
nyappdiv · 2012
2 sentences

2019Slip Op. 34303[U] , 2011 WL 13286044 [Sup. Ct., Erie County 2011] ) but the Appellate Division reversed, holding in relevant part that plaintiffs made a ***528 sufficient showing of personal jurisdiction to warrant further disclosure ( 100 A.D.3d 143 , 952 N.Y.S.2d 333 [4th Dept. 2012] ).

2019Supreme Court, among other things, initially granted Brown’s motion to dismiss the action ( 2011 NY Slip Op 34303 [U] [Sup Ct, Erie County 2011]) but the Appellate Division reversed, holding in relevant part that plaintiffs made a sufficient showing of personal jurisdiction to warrant further disclosure ( 100 AD3d 143 [4th Dept 2012]).

22019–2019
Dupree v. Giugliano green
nyappdiv · 2011
2 sentences

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

2014Brown, Hindsight Biblical Counseling, and Hindsight Ministries, Inc. (hereinafter collectively the Brown defendants), to recover damages for negligence and professional malpractice, based upon allegations regarding the Brown defendants having provided the plaintiff with biblical counseling (see Langford v Roman Catholic Diocese of Brooklyn, 271 AD2d 494, 495-496 [2000]; cf. Marmelstein v Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, 11 NY3d 15, 21-22 [2008]; Rodrigues-Lytwyn v Roman Catholic Diocese of Brooklyn, 79 AD3d 840, 841 [2010]; cf. also Dupree v Giugliano, 87 AD3d 97

22014–2014
In re the Arbitration between Matarasso & Continental Casualty Co. green
ny · 1982
1 sentence

2026Co.] , 56 NY2d at 267 ; Matter of Progressive Ins.

12026–2026
Crawford v. Washington green
scotus · 2004
2 sentences

2016The DNA profiles, if testimonial, require the appearance of the witnesses who prepared them and this the majority is unprepared to say (see US Const 6th Amend; Crawford, 541 US at 68-69 ).

2016The DNA profiles, if testimonial, require the appearance of the witnesses who prepared them and this the majority is unprepared to say (see US Const 6th Amend; Crawford, 541 US at 68-69 ).

12016–2016
Williams v. Illinois red
scotus · 2012
1 sentence

2016While purporting to apply our primary purpose test, the majority in fact opts for the reasoning set forth in the Williams dissent: informed by that analysis, the majority reaches the same result — at least one analyst must testify (see Williams, 567 US at — n 4, 132 S Ct at 2273 n 4 [Kagan, J., dissenting]).

12016–2016
Counsel Abstract, Inc. Defined Benefit Pension Plan v. Jerome Auto Center, Inc. green
nyappdiv · 2005
1 sentence

2015Albans Holding Corp. v Estate of Harrison, 71 AD3d 653, 653-654 [2010]; Staples v Jeff Hunt Devs., Inc., 56 AD3d 459 [2008]; Counsel Abstract, Inc. Defined Benefit Pension Plan v Jerome Auto Ctr., Inc., 23 AD3d 274 [2005]; State St.

12015–2015
Bullcoming v. New Mexico green
scotus · 2011
2 sentences

2013Applying the Brown test, the court in People v DiBari ( 26 Misc 3d 1220[A] , 2010 NY Slip Op 50191[U] , *4-5 [2010]) held that “calibration and simulator solution certificates of breath test instruments” are “qualitatively dissimilar from the report at issue in Melendez-Diaz” and thus “are non-testimonial.” But, the debate continued, requiring yet another effort at clarification by the US Supreme Court in 2011 in Bullcoming (564 US —, 131 S Ct 2705 ).

2013Applying the Brown test, the court in People v DiBari ( 26 Misc 3d 1220[A] , 2010 NY Slip Op 50191[U] , *4-5 [2010]) held that “calibration and simulator solution certificates of breath test instruments” are “qualitatively dissimilar from the report at issue in Melendez-Diaz” and thus “are non-testimonial.” But, the debate continued, requiring yet another effort at clarification by the US Supreme Court in 2011 in Bullcoming (564 US —, 131 S Ct 2705 ).

12013–2013
Pascual v. Kingsley Realty Holdings, Ltd. green
nyappdiv · 2004
1 sentence

2005Also proper was the partial denial of Brown’s motion for summary judgment, since the conflicting affidavits of the parties’ respective engineering experts raised triable issues (see Pascual v Kingsley Realty Holdings, Ltd., 8 AD3d 26 [2004]) as to whether Brown may be held accountable for plaintiffs’ accident on a defective design and/or failure to warn theory.

12005–2005
County of Nassau v. Heine neutral
nyappdiv · 1981
1 sentence

2004Although several courts have previously denied motions to unseal where the petitioner has failed to obtain such a waiver, and is neither a party protected by the privilege of CPL § 160.50 nor is one of the parties to which the statutory exceptions apply ( see , e.g. , Wilson v. City of New York , 240 A.D.2d 266, 267 [1st Dept. 1997]; Heine , supra ), this factor alone does not end further evaluation of Mr. Brown's motion.

12004–2004
Connolly v. Rogers green
nyappdiv · 1993
1 sentence

1998As to the denial of Brown’s motion for summary judgment, it is clear that a duty was imposed upon it to provide a safe place for its patrons to board and exit its vehicle (see, Miller v Fernan, 73 NY2d 844 ; Connolly v Rogers, 195 AD2d 649 ).

11998–1998
Zuckerman v. City of New York green
ny · 1980
1 sentence

1998With only speculation proffered as to how Brown may have breached its duty, Brown’s motion for summary judgment should have been granted (see, Zuckerman v City of New York, supra).

11998–1998
Miller v. Fernan green
ny · 1988
1 sentence

1998As to the denial of Brown’s motion for summary judgment, it is clear that a duty was imposed upon it to provide a safe place for its patrons to board and exit its vehicle (see, Miller v Fernan, 73 NY2d 844 ; Connolly v Rogers, 195 AD2d 649 ).

11998–1998
Era Steel Construction Corp. v. Egan green
nyappdiv · 1988
1 sentence

1995Corp. v Egan, 145 AD2d 795, 798-799 ), we find that the testimony adduced undercuts Brown’s claim of control.

11995–1995
In re Christopher W. neutral
nyappdiv · 1990
11992–1992
Zinker v. Zinker green
nyappdiv · 1992
1 sentence

1992Defendant’s submissions were insufficient to demonstrate entitlement to that relief (see, Zinker v Zinker, 185 AD2d 698 ; Unifirst Corp. v Gaslin, 166 AD2d 930 ).

11992–1992
Brown v. Illinois green
scotus · 1975
11988–1988
United States v. Crews green
scotus · 1980
11988–1988
People v. Conyers green
ny · 1986
11988–1988
Thompson v. State green
ga · 1981
11988–1988
Brown v. Micheletti green
nyappdiv · 1983
11987–1987
Two Associates v. Brown neutral
nysupct · 1986
11987–1987
Myoung Goo Lee v. Moley neutral
nyappdiv · 1983
11985–1985
Filippo v. White green
nyappdiv · 1984
11985–1985
Friends of Animals, Inc. v. Associated Fur Manufacturers, Inc. green
ny · 1979
11985–1985
People v. Hetherington green
ny · 1970
11979–1979
People v. Townsend green
ny · 1973
11979–1979
People v. Bevilacqua green
ny · 1978
11979–1979
People v. Hobson green
ny · 1976
11979–1979
Withrow v. Larkin green
scotus · 1975
11978–1978
Gilman v. Lowell neutral
· 1832
11848–1848

Where else courts name it

TX 122 (1901–2026) CA 102 (1967–2026) FL 65 (1975–2023) GA 62 (1975–2026) PA 58 (1974–2026) OH 56 (1974–2026) MS 47 (1985–2026) OR 45 (1971–2025) IL 40 (1968–2026) WA 31 (1936–2025) IN 31 (1979–2021) NY 28 (1848–2026) MI 28 (1988–2023) KS 28 (1991–2026) MO 27 (1912–2022) NE 23 (1983–2024) AL 23 (1918–2024) LA 22 (1952–2023) CO 21 (1980–2026) AZ 21 (2004–2026) TN 20 (1960–2026) MD 20 (1960–2021) DC 19 (1981–2025) IA 19 (1976–2024) MN 18 (1974–2025) ID 17 (1987–2026) VA 16 (1990–2022) WI 14 (1987–2023) DE 13 (1970–2025) SC 13 (1990–2026) UT 12 (1941–2025) NJ 12 (1990–2018) NC 10 (1961–2026) WY 10 (1987–2021) ME 9 (1979–2016) NV 9 (1990–2017) CT 9 (1982–2026) MA 8 (1982–2007) AK 8 (1984–2023) MT 8 (1996–2022) NM 6 (1986–2020) AR 6 (1976–2022) KY 6 (1984–2026) RI 6 (1976–2011) SD 6 (1992–2019) OK 6 (1935–2021) ND 4 (1991–2009) HI 4 (2009–2025) WV 3 (1979–1996) VT 2 (2008–2018) VI 2 (2008–2011)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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