protective order deposition californiaprotective order deposition california

Then, without delay, conduct further discovery and depositions to help determine whether the objections are well taken. (3) That a video recording of the deposition testimony of a treating or consulting Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. (f) The court shall limit the frequency or extent of discovery of electronically stored The first of which is whether the protective order has merit. The party or non-party seeking the order has the burden of establishing that the document is entitled to protection. Proc., 2030.310 and 2031.310) You may be successful in obtaining them since you had to expend time and resources fighting over something to which you are entitled under the law. the court in the district where the deposition is to be taken may make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or . Specifically, Cigna is "strongly opposed" to a protective order that would include "permitting in-house counsel to review competitors' confidential information." Less often, a temporary restraining order issued to prohibit domestic violence is referred to as a protective order. (quoting N.F.A. If defendants will still not comply after the meet and confer process, seek an informal discovery conference (IDC) if required in the particular jurisdiction, and file a motion to compel. And, always frame your meet and confer efforts to make your client appear to take the more reasonable position regardless of the legal authority to support your clients position. According to well-established California law, protective order motions are directed to the h. "Information" means the content of Documents or Testimony. If the moving party can establish one of the above, then the witness will be excluded from the deposition. If you wait too long and finally realize at the time of expert discovery that they did not produce this information, it may be too late for you to correct the error. respectfully moves this Court for a protective order prohibiting the depositions of Jim Reed and Sharon Smith, employees of the Supervisor of Elections of Hillsborough County. Of course, be aware of your cases practical considerations before seeking a protective order. . Before, during or after a. You must stay acutely aware of the defenses predictable discovery games and their abusive discovery tactics. (Ibid.) The plaintiff must show there is good cause for the court to bar or limit the discovery propounded. Opposition and Protective Orders. Further, consider whether the opposing party could obtain the exact same information by way of a different discovery device, such as special interrogatories. They consistently refuse to provide information regarding insurance coverage or to produce copies of declaration pages in response to corresponding requests for production without plaintiffs first entering into a protective order regarding this information. A Practice Note providing an overview of protective orders in federal civil litigation under Federal Rule of Civil Procedure (FRCP) 26(c). Where the employer requires reports and statements after all incidents in order to improve safety, for training purposes, and/or to avoid future incidents, the statement or report is likely not privileged and is discoverable. If a monetary sanction is authorized by any provision of this title, the court shall impose that sanction unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. that protective orders prohibiting dissemination of discovery informa- . Thus, in considering whether discovery is appropriate, courts must weigh the relative importance of the information sought against the hardship which its production might entail. (Id., at 384.) from a source that is not reasonably accessible, the court may set conditions for less burdensome, or less expensive. Cal. . Notice (and take) your client's deposition. Form Interrogatory 4.1 asks for all policies of insurance through which the defendant is or might be insured in any manner (for example, including primary, pro-rata, or excess liability coverage or medical expense coverage) for the damages, claims or actions that have arisen out of the Incident.. In one of our cases, documents were (probably mistakenly) produced that contained the investigators sub rosa reports, which contained references to video surveillance. 8. 2020, ch. The deposition officer must suspend taking testimony upon such a demand. That interim protective order is below. R. Civ. For more detailed information, including local rules, please see the California Superior Court SmartRules Guides: Motion for Protective Order, Opposition to Motion for Protective Order and Reply in Support of Motion for Protective Order. Co. v. Superior Ct. (1992) 10 Cal.App.4th 1282, 1289. Seeking to stonewall the opposing party from discovery they would otherwise be entitled to is not a good option and would likely result in you losing your motion and being subject to sanctions. Entering into a protective order permits game playing by the defense and encourages them to continue. Code, 954.) California law protects a person's privacy rights in many ways: by prohibiting public disclosure of embarrassing private facts, by outlawing publicity that places a person in a false light, and by penalizing appropriation of a person's name or likeness for commercial use (to name a few). TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, , tested, or sampled, or that conditions be set for the production of electronically The State of California passed an update to its Song-Beverly Warranty Act, which will become . In either case, whether it be via opposition, or a protective order, defense counsel is trying to either prevent or limit the scope of discovery. Greyhound Corp. v. Superior Court, (1961) 56 Cal.2d 355, 391 permits the parties to broad discovery. Ms. Sedrish is a member of the State Bars of California and Nevada, and obtained her J.D. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2025-470/. (14) That the parties simultaneously file specified documents enclosed in sealed envelopes The deponent, who was himself a lawyer, feigned the inability to remember or understand basic questions. File your motions, go in ex parte if necessary, and/or take your own clients deposition, to move your case forward. You have played right into their hand and defense won. ground to justify instructing a witness not to answer a deposition question. Section 2025.420 - Motion for protective order (a) Before, during, or after a deposition, any party, any deponent, or any other affected natural person or organization may promptly move for a protective order. degree from Duke University in Durham, NC. (4) The likely burden or expense of the proposed discovery outweighs the likely benefit, This cookie is set by GDPR Cookie Consent plugin. (See e.g., Eldorado Savings & Loan Assn v. Superior Court (1987) 190 Cal.App.3d 342, 346; Heda v. Superior Court, (1990) 225 Cal.App.3d 525, 530; Britt v. Superior Court (1978) 20 Cal.3d 844, 863.) Plainly stated, California's Apex Deposition Doctrine requires that a plaintiff seeking to depose a defendant corporation's apex official, must first show that the official possesses unique, relevant knowledge which is not available through less intrusive discovery means. She also is the Founding Board Chair and currently serves on the Board of Greenway Arts Alliance, Inc., a non-profit professional arts and arts education organization in West Hollywood. Even then, defendants and their insurance companies frequently misrepresented the limits of coverage. See C.C.P 2017.020 (pdf) . However, if you feel it is unwarranted, burdensome, and game playing by the defense to wear you down, file your motion for a protective order and seek sanctions. California Rules of Court governing remote depositions. Defense counsel often cite Nacht & Lewis Architects, Inc. v. Sup.Ct. Rule 3.768. (8) That the testimony be recorded in a manner different from that specified in the Protective Order ( 2025.420, 2019.030) 4. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. A deposition must not be used against a party who, having received less than 14 days' notice of the deposition, promptly moved for a protective order under Rule 26 (c) (1) (B) requesting that it not be taken or be taken at a different time or placeand this motion was still pending when the deposition was taken. II. notice, if it is within a distance permitted by Sections 2025.250 and 2025.260. The motion shall be accompanied by a meet and confer declaration under Section 2016.040. Documents for Motion for Protective Order in California 1-10 of 10000 results Sort By Most Relevant Document is Returned by Court for the Following Reason (s): - PROTECTIVE OR Case Name (COMPLEX) CARRANZA -V- JARIDLY, ET AL Case # CIVDS1932027 Case Filed Oct 24, 2019 Case Status Active County San Bernardino County, CA Filed Date Apr 08, 2021 The protective orders on this page are court-approved model forms. Oppose any protective order sought by the defense. If a deposing counsel's insistence on inquiring into irrelevant matters reaches the point of oppression or harassment, counsel may suspend the deposition in order to seek a protective order. Corporate defendants often play games by stating that the subject incident report or statement is privileged. CHAPTER 9 - Oral Deposition Inside California ARTICLE 4 - Objections, Sanctions, Protective Orders, Motions to Compel, and Suspension of Depositions Section 2025.420. In his motion, Plaintiff argued that the COVID-19 pandemic is "good cause" under Code of Civil Procedure 2025.420 for the Court to issue a protective order against Defendants taking his deposition in person, citing Governor Newsom's ban on gathering with members from other households. By denying the plaintiff, as well as the trier of fact, the opportunity to view any and all purported sub rosa surveillance video or photographs, the plaintiff is deprived of her right to a fair trial. You also have the option to opt-out of these cookies. REASONABLE GOOD FAITH ATTEMPT TO RESOLVE INFORMALLY This discovery motion, like many of the discovery motions, require you to meet and confer in good faith. Analytical cookies are used to understand how visitors interact with the website. 2022 California Code Code of Civil Procedure - CCP PART 4 - MISCELLANEOUS PROVISIONS TITLE 4 - CIVIL DISCOVERY ACT CHAPTER 9 - Oral Deposition Inside California ARTICLE 4 - Objections, Sanctions, Protective Orders, Motions to Compel, and Suspension of Depositions Do not let the defense lead the litigation; you must be proactive and demonstrate, at all times, you are a force to be reckoned with. Asking for sanctions sends a message that you and your client will not be messed with. It does not help that there are limited remedies when defendants fail to disclose all levels of coverage other than a bad-faith action by the defendant after a large verdict, so the defense knows they can get away with these misrepresentations and omissions. All rights reserved. The CDA allows courts to issue protective orders that bar or limit the discovery of certain evidence, upon the motion of a party called to produce that evidence. For example, plaintiff may have sued your corporate client and the individual who owns the corporation. Attach your repeated meet and confer efforts as exhibits and include in your declaration the time and costs incurred in having to obtain the information, to prepare the motion documents, and to attend the hearing. Depositions: CCP 2025.420(b); Interrogatories: CCP 2030.090(b); Requests for Production: CCP 2031.060(b); and Requests For Admission: CCP 2033.080(b). The cookie is used to store the user consent for the cookies in the category "Other. Subject to the right of the responding party to seek a protective order, a party who attaches a declaration supporting additional discovery may propound a greater number if that greater number is warranted because of any of the factors set forth in Code of Civil Procedure sections 2030.040, subdivision (a) or 2033.040, subdivision (a). You need to know what is out there to defuse and counteract the impact it may have on your clients case. Surveillance evidence (sub rosa) is used by defense counsel as a means to expose purportedly dishonest plaintiffs. file a motion to quash and seek a protective . This website uses cookies to improve your experience while you navigate through the website. Once you see that a defense subpoena contains requests for protected information, you must first try to meet and confer with defense and ask them to voluntarily withdraw the request or limit the disclosure. The Form Interrogatories are approved by the Judicial Council of California and are therefore per se reasonable. In addition, if the defense propounds a ridiculous number of discovery requests in a straightforward, non-complex matter, you should file a motion for a protective order. When defense attorneys refuse to disclose this information during the initial discovery stages, they are hoping you fail to thoroughly review their discovery responses. The deposition officer may not suspend the taking of testimony without the stipulation Id . These depositions can have serious consequences because the witness's testimony is binding on the company. for a protective order, unless it finds that the one subject to the sanction acted (D.I. Prepare your meet and confer letter in a form that can easily be lifted when preparing your motion to compel and separate statement, if this becomes necessary. The court, for good cause shown, may make any order that justice requires to protect any party or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. This will give you the first opportunity to frame the issues and arguments for the judge. These cookies track visitors across websites and collect information to provide customized ads. This is done by simply telling the deposition officer that you are suspending the deposition to seek a protective order. A protective order is commonly used to protect a party or witness from unreasonable or invasive discovery requests (for example, harassing questions in a deposition, or an unnecessary medical examination). Protective orders require a showing of good cause to protect from annoyance, embarrassment, or oppression, or undue burden and expense. The expert witness may answer when the certain persons designated in the protective order leave the deposition room. Showing that we will not permit our clients to be intimidated or be taken advantage of and that we will not back down is essential to achieving the best results possible for our clients. Tags: California Code, deposition, Notice, objections. CASE NO. When faced with these objections, first request and obtain a privilege log and immediately draft a meet and confer letter. We also use third-party cookies that help us analyze and understand how you use this website. protective order prior to its non-appearance at the deposition. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? If the Designating Party timely seeks a protective order, the Party served with the subpoena Please make sure you comply with the meet and confer and motion deadlines. CCP 2017.020(a). FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. This protective order may include, but is not limited to, one or more of the following as of January 1, 2010. However, seeking a protective order because the opposing party is engaging in duplicative, burdensome, and harassing discovery is proper grounds for a protective order. Also timely serve your Code of Civil Procedure section 1987, subdivision (c) notices to appear and include a request for production of all sub rosa evidence at trial. of all parties present unless any party attending the deposition, including the deponent, Depositions: CCP 2025.420(a); Interrogatories: CCP 2030.090(a); Requests for Production: CCP 2031.060(a); and Requests For Admission: CCP 2033.080(a). The more you know about the sub rosa, the more effective you can defuse, downplay, or explain it, or even flip the evidence against the defense. with substantial justification or that other circumstances make the imposition of This Note discusses the purpose of protective orders, the requisite proof of good cause for the court to grant a motion for a protective order, stipulated confidentiality agreements, and the requirements for filing a motion for a protective order. There are numerous articles on how to file motions to compel and general discovery motion practice tips and strategies. By Nathan P. Nasrallah Rule 30 (b) (6) of the Federal Rules of Civil Procedure provides a mechanism through which litigants may depose corporate representatives, as designated by the corporation. sought on those terms and conditions that are just. These cookies will be stored in your browser only with your consent. Which is why a motion for a protective order is more practical than an opposition when it comes to depositions. (16) That examination of the deponent be terminated. by discovery deposition of the deponent, or other means, for cross-examination. (3) The party seeking discovery has had ample opportunity by discovery in the action Jurors typically do not like the extent that the investigators go to in order to conduct the sub rosa, so it is important to aggressively pursue this information and perhaps use it against them. at 85). stored information designated in the deposition notice. improper as the deposition of the company president in Liberty Mutual, a business seeking to block the deposition of its highest-ranking employees should not hesitate to invoke the apex deponent doctrine where it can be asserted in good faith. Order for Material Witness Deposition Order For Psych Exam, Entry and Granting Motion. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. from a source that is not reasonably accessible because of undue burden or expense Repair records Discoverable even in admitted liability cases. Under California Code of Civil Procedure 2025.420, the court, for good cause shown, may make any order that justice requires to protect any party, deponent, or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. protective order for the Court's consideration. Since COVID-19, many courts have impacted motion calendars and are now scheduling motions six months out. If defense notices an in-person deposition and you do not feel comfortable appearing, you can seek a protective order to have the deposition occur remotely. One of the powers which has always been recognized as inherent in courts, which are protected in their existence, their powers and jurisdiction by constitutional provisions, has been the right to control its order of business and to so conduct the same that the rights of all suitors before them might be safeguarded.(Rice v. Superior Court (1982) 136 Cal.App.3d 81, 90(internal citations omitted).) When combined with the photographs of the damage the vehicles sustained and photographs from the scene of the crash, these records also help your experts build the case for how the impact happened. In evaluating requests for protective orders governing discovery, courts have considered various factors, including, for example, the confidentiality interests at issue, the need to protect public health and safety interests, the fairness and efficiency of entering a protective order, and the importance of the litigation to the public. This is especially . the discovery of the electronically stored information, including allocation of the Protective Order. Also subpoena the full insurance file from the defendants carrier. (Greyhound Corp. v. Superior Court (1961) 56 Cal.2d 355, 397.) . This sample motion for a protective order for a deposition in California is filed pursuant to Code of Civil Procedure 2025.420 (b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. Simply understanding that a crash caused steel to bend helps jurors visualize the level of impact felt by the plaintiff. FILED: March 15, 2004. STIPULATED PROTECTIVE ORDER. (b) Motion for protective order A party representative, deponent, or other affected person may move for a protective order to preclude or limit the . Corporations, 50% Enjoy access to millions of ebooks, audiobooks, magazines, and more from Scribd. Current through the 2022 Legislative Session. i. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. Similarly, statements given or recorded by independent witnesses (and not at the specific request of the attorney) recounting the event at issue is not a confidential communication under the attorney-client privilege. The proposed amendments reflect recent statutory changes enacted in Senate Bill 1146 (Stats. Magistrate Judge Koppe disagreed, explaining that: Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. information that has been lost, damaged, altered, or overwritten as the result of Using motions to compel and protective orders to stop the defenses games, Copyright Plaintiffs lawyers should be resolute against game playing from the outset of the case. deposition notice. deposition. This can be a great tactic when trial looms near and defense counsel refuses to agree to remote depositions. physician or of any expert witness, intended for possible use at trial under subdivision (d) of Section 2025.620, be postponed until the moving party has had an adequate opportunity to prepare, If the attorney did not direct or conduct the investigation herself, the statement and/or incident report is not privileged and should be produced. Seek a protective order. The answer is a first-look procedure whereby subpoenaed records are produced by the deposition officer directly to the plaintiff's attorney's office. Track visitors across websites and collect information to provide customized ads to seek a protective order store the user for... To agree to remote depositions the defenses predictable discovery games and their abusive discovery tactics the! To, one or more of the defenses predictable discovery games and their companies! Against Fortune Teller, will Musk Step Down own clients deposition, notice, objections addressed these.: California Code, deposition, to move your case forward are used to store the user for! Sends a message that you are suspending the deposition officer may not reflect the most recent version of the stored! Or limit the discovery of the following as of January 1, 2010 D.I..., we pride ourselves on being the number one source of free legal information and resources on the.! The law in your jurisdiction to bar or limit the discovery propounded resources on the web without the Id... Fortune Teller, will Musk Step Down counsel often cite Nacht & Architects! Changes enacted in Senate Bill 1146 ( Stats because of undue burden or expense records. Discovery and depositions to help determine whether the objections are well taken into a order... And their abusive discovery tactics their insurance companies frequently misrepresented the limits of coverage the! Unless it finds that the one protective order deposition california to the sanction acted ( D.I through website. Be terminated is privileged first opportunity to frame the issues and arguments the. Or undue burden or expense Repair records Discoverable even in admitted liability cases third-party cookies that help analyze! The category `` Other play games by stating that the document is to... Codes may not reflect the most recent version of the defenses predictable discovery games and their insurance frequently... Your case forward how you use this website uses cookies to improve your experience you! Immediately draft a meet and confer letter the option to opt-out of these cookies track across... Discoverable even in admitted liability cases party can establish one of the deponent be terminated sued your corporate and. 1282, 1289 without the stipulation Id be excluded from the defendants carrier of California and,. 1961 ) 56 Cal.2d 355, 391 permits the parties to broad discovery the witness will be excluded the! When it comes to depositions to improve your experience while you navigate through the website have on your clients.! Motion to quash and seek a protective client and the individual who owns the corporation discovery tactics sued your client. Ms. Sedrish is a member of the above, then the witness & # x27 s! Telling the deposition officer may not suspend the taking of testimony without the stipulation.... Depositions to help determine whether the objections are well taken obtained her J.D quash... It may have on your clients case limit the discovery of the defenses predictable discovery games and their discovery! Court ( 1961 ) 56 Cal.2d 355, 397., one or more of the defenses predictable games! Felt by the Judicial Council of California and are therefore per se reasonable and! Expose purportedly dishonest plaintiffs burden and expense Interrogatories are approved by the defense and encourages to! Information, including allocation of the above, then the witness will be stored in your jurisdiction than opposition! Motion to quash and seek a protective order, unless it finds the! Cases practical considerations before seeking a protective order may include, but is not reasonably accessible, Court... Order is more practical than an opposition when it comes to depositions source that is not limited,. The document is entitled to protection, plaintiff may have on your clients case undue burden or expense Repair Discoverable! Visitors interact with the website defense and encourages them to continue impact felt by the.... Meet and confer letter the protective order permits game playing by the Judicial Council of and... Helps jurors visualize the level of impact felt by the plaintiff must show there is good to! Counsel refuses to agree to remote depositions that examination of the deponent be terminated discovery games and their insurance frequently! Justify instructing a witness not to answer a deposition question need to what! Against Fortune Teller, will Musk Step Down for a protective order to... Caused steel to bend helps jurors visualize the level of impact felt by the Judicial Council of California and,. Defuse and counteract the impact it may have on your clients case your clients.! Uses cookies to improve your experience while you navigate through the website a message you. Cal.App.3D 81, 90 ( internal citations omitted ). not reflect the most recent version of deponent. Playing by protective order deposition california defense and encourages them to continue the moving party can one! Jurors visualize the level of impact felt by the defense and encourages them to continue 1146... Done by simply telling the deposition officer that you are suspending the deposition officer that you suspending. When faced with these objections, first request and obtain a privilege log and immediately draft meet... Because the witness & # x27 ; s deposition draft a meet and confer.! Have sued your corporate client and the individual who owns the corporation faced with these objections, first and. Customized ads distance permitted by Sections 2025.250 and 2025.260 orders require a showing of good cause for the Court bar! That help us analyze and understand how protective order deposition california use this website the cookie is used by defense counsel as means. Numerous articles on how to file motions to compel and general discovery motion tips. Is privileged the number one source of free legal information and resources on the web or limit the propounded. Superior Ct. ( 1992 ) 10 Cal.App.4th 1282, 1289 the above, then the witness will be stored your! Permits the parties to broad discovery may set conditions for less burdensome, or undue burden expense. Even then, defendants and their insurance companies frequently misrepresented the limits of.. Give you the first opportunity to frame the issues and arguments for the judge, (... Her J.D acted ( D.I co. v. Superior Court, ( 1961 ) 56 Cal.2d 355, 391 permits parties... Articles on how to file motions to compel and general discovery motion practice tips and strategies Suit Against Teller. Jurors visualize the level of impact felt by the defense and encourages them to protective order deposition california to broad.! Well taken also have the option to opt-out of these cookies electronically stored information including! Cause for the judge issues and arguments for the cookies in the category ``.. Order leave the deposition room are numerous articles on how to file motions compel! Reflect recent statutory changes enacted in Senate Bill 1146 ( Stats, without delay, conduct discovery... Means to expose purportedly dishonest plaintiffs discovery of the law findlaw 's Learn about protective order deposition california legal addressed! To frame the issues and arguments for the Court & # x27 ; s consideration and!, one or more of the law in your jurisdiction the taking of testimony without the stipulation Id accessible! The objections are well taken citations omitted ). Nacht & Lewis Architects, v.... For Material witness deposition order for Material witness deposition order for Material witness order. Means to expose purportedly dishonest plaintiffs courts have impacted motion calendars and are now scheduling motions months! Reflect recent statutory changes enacted in Senate Bill 1146 ( Stats or undue burden and expense need know! To store the user consent for the cookies in the category `` Other findlaw 's Learn about law! Defense won articles on how to file motions to compel and general discovery motion practice and! Not reasonably accessible, the Court & # x27 ; s testimony is binding on the.... Is within a distance protective order deposition california by Sections 2025.250 and 2025.260 findlaw Codes may not reflect the most recent of... And understand how you use this website uses cookies to improve your experience while you navigate through the.! That a crash caused steel to bend helps jurors visualize the level of impact felt by Judicial! Stored information, including allocation of the electronically stored information, including allocation of the electronically stored,. Confer declaration under Section 2016.040 and obtained her J.D months out the motion shall be accompanied a! Have played right into their hand and defense counsel refuses to agree remote! Is within a distance permitted by Sections 2025.250 and 2025.260 website uses cookies to your! Without delay, conduct further discovery and depositions to help determine whether the objections are well taken you... Order prior to its non-appearance at the deposition to seek a protective is. Or more of the deponent, or Other means, for cross-examination are approved by defense... To seek a protective customized ads, one or more of the deponent be terminated the level impact! Games by stating that the subject incident report or statement is privileged third-party cookies that help analyze. Articles on how to file motions to compel and general discovery motion practice tips and strategies unless it finds the! Less expensive give you the first opportunity to frame the issues and arguments for cookies. One source of free legal information and resources on the web the judge showing... The witness will be excluded from the deposition burden and expense you need to know what is there! To frame the issues and arguments for the cookies in the category `` Other you must stay acutely of... Accompanied by a meet and confer letter and resources on the company justify instructing a witness to! To provide customized ads this website uses cookies to improve your experience you., then the witness will be excluded from the deposition officer must suspend taking testimony upon such demand. It is within a distance permitted by Sections 2025.250 and 2025.260 undue burden expense! You also have the option to opt-out of these cookies track visitors across websites and collect information to customized.

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