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Wow... Your posts history shows you are a genius with words... The same words... Over and over and over...
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Write on!
Right on!!
RedHawk!!!
$$$$$$$trong!!!!
NICE DD DOG!!! REDHAWK FORWARD!!! THE JUDGE FORWARD ON!!
DEADHAWK
Klug has been keeping many secrets from SNDD investors... There are 9 lawsuits in Louisiana against RedHawk and Klug.
Klug and RedHawk have been in trouble for many years even before he stopped filing. Klug was promising collateral to some. then selling off that same "collateral" to others and diverting the money somewhere without paying those he put the colateral up for.
https://drive.google.com/file/d/1-eIyCrD8K2Qn7kXbVRGvQu0_m4OmfEL-/view
Judgment in that case for 100,000.00 plus attorney's fees, interest, and 2,500,000 shares that they likely never got a chance to sell because Klug allowed the SEC to revoke the stock.
https://drive.google.com/file/d/1-el-BNoN_WE1Sf_RtcEcKBcIQqnOrb4N/view
The latest was filed in May with 13 plaintiffs and totals near 300,000.00 bucks... More collateral sold off. Klug has likely sold off everything as I have said before. Nothing left. There will be no filings and no Form 10... Ever.
https://drive.google.com/file/d/1-a5ARjVhNIXrrBAH7qvK8vdeE3MFYqSF/view
Judgment against RedHawk for $645,222.26, plus default interest at the rate of 24%
https://drive.google.com/file/d/100M_2nbp9gUtCOF44HhRiHamw4Q_P58N/view
Check this out... These guys sold 1,117,000.00 bucks of SNDD stock for Klug to private investors and Klug failed to pay them their 2% commission. Then failed to pay interest on a note and sold off pledged collateral to someone else with zero benefit to them.
https://drive.google.com/file/d/1-rl6mpFZuK1YAItaJHRnrC9yYPYB9FPO/view
I don't remember seeing anything in the financials about a lawsuit filed against Redhawk for patent infringement with the needle incinerator thing. Redhawk won a favorable Judgment, but Klug didn't disclose this suit to investors. Thats more Fraud....
https://drive.google.com/file/d/1-xjPlbpHsuqH62f8b4NvaPKEckw-CKvW/view
Another 50,000.00 bucks worth and Klug's same MO...
https://drive.google.com/file/d/1-rb2h4yIa_OOudTgWar_IvV34CpU6y4Q/view
Writ for garnishment to seize all property sufficient to satisfy Judgment...
https://drive.google.com/file/d/1-tDVELI-o0ozFq6rSLV-t0myz93zcDnD/view
Lets not forget about this!!
Another breach of contract lawsuit. Klug/RedHawk the defendant. Klug failed to notify investors of this lawsuit as well. Its was a purchase and sale of future receivables agreement. I also don't recall seeing that deal in any filings as well. Pretty good deal for the financier... and really bad for SNDD investors.
If you are referring to the N95 thing.... Since many Redhawk "investors" don't know how to use or what it is for, or both, the "reply" button. The Judge may make a decision on the motion for reconsideration motion for Judgment Debtor Exam and motion for Protective Order. N95 could also respond to this response from Redhawk.
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No shit... I am asking where are your links?
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ii TABLE OF CONTENTS EXHIBITS...
ii TABLE OF AUTHORITIES iv, v, vi I)
FACTUAL BACKGROUND
2 II) LAW AND ANALYSIS
3 A) ALL N95 SHIELD, LLC MEMBERS HAVE RELEVANTKNOWLEDGE REGARDING THE COMPANY AND THE REDHAWKTRANSACTION, AND THEREFORE SHOULD BE REQUIRED TOPARTICIPATE IN THE JUDGMENT DEBTOR EXAMINATIONS
3 1) Holcombe, Miller, and Reiss were members of the LLC at all times pertinent hereto
3 2) Holcombe and Reiss should be required to undergo a Judgment Debtor Examination as members of N95 Shield, LLC
4 3) While Miller was Redhawk’s main point of contact with N95 Shield,LLC, there is evidence that Holcombe and Riess have knowledge ofN95 Shield, LLC transactions
8 B) N95 SHIELD, LLC’s, MEMBERS ARE PERSONALLY LIABLE TOREDHAWK FOR THE MAY 28, 2024, JUDGMENT, THEREFORE, THEPERSONAL FINANCES OF EACH MEMBER ARE RELEVANT
10 1) The determination of N95 Shield members’ personal liability is properly made under Arizona Law
11 2) Under Arizona Law, the Alter Ego Theory applies to the determination of whether the members of N95 Shield, LLC could be found to be personally liable
11 a) N95 Shield, LLC was undercapitalized when formed
12 b) The actions of N95 Shield, LLC and its members illustrate fraudulent behavior
13 i) All Transactions funded by third parties
14 ii) N95 Shield failed to comply with the required winding-up procedures, in accordance with Arizona law; therefore, committing the crime of perjury
15 iii) N95 Shield, LLC purposefully defaulted on the Mask Transaction
18 Case 6:23-cv-01021-DCJ-CBW Document 60 Filed 09/24/24 Page 2 of 31 Page ID #: 1066
iii c) Under Arizona law, without the Judgment Debt Examinations of all Members and N95 Shield, LLC, Plaintiff will be unlawfully left without Remedy
18 3) Under Arizona Law, the members of N95 Shield, LLC are personally liable for the debts of N95 Shield, LLC .
19 4) Under Louisiana law, the members of N95 Shield, LLC are personally liable for the debts of N95 Shield, LLC
20 C) REDHAWK OBJECTS TO DEFENDANTS’ AFFIDAVIT OF MATTHEW MILLER
D_DOG
September 23, 2024
Via ECF
The Honorable Victor Marrero
United States Courthouse
500 Pearl Street
New York, NY 10007-1312
Re: DarkPulse, Inc., et al. v. Crown Bridge Partners, LLC, et al., No. 1:22-cv-08163-VM
Proposed Case Management Plan, Submitted Pursuant to September 16 Order
Dear Judge Marrero:
We write on behalf of DarkPulse, Inc., Decentral Life, Inc. (f/k/a Social Life Network, Inc.) and
RedHawk Holdings Corp. (together, “Plaintiffs”) in response to the Order, dated September 16,
2024, directing the parties to “confer and to propose an abbreviated case management plan for
jurisdictional discovery and related dispositive motion practice, in light of the decision by the
United States Court of Appeals remanding this case for further proceedings.” ECF 59 (the
“Order”). As detailed herein, the parties were unable to mutually agree on dates to propose in a
jointly submitted case management plan.
On Tuesday, September 17, 2024, Plaintiffs’ counsel contacted counsel for Crown Bridge Partners,
LLC, Soheil Ahdoot and Sepas Ahdoot (together, “Defendants”) via email to solicit dates and
times to meet and confer pursuant to the Order. Defendants’ counsel, instead, requested that
Plaintiffs’ counsel communicate their availability along with a draft case management plan.
On Wednesday, September 18, 2024, Plaintiffs’ counsel circulated a draft case management plan
(filed herewith as Exhibit A) and communicated they were generally available to meet and confer
during the remainder of the week. Defendants’ counsel responded by stating “I am in an arbitration
until Friday but will try to get you something by then.”
On Friday, September 20, 2024, Defendants’ counsel responded with a redline to Plaintiffs’ draft
case management plan (filed herewith as Exhibit B). Defendants’ redline of the case management
plan proposed an approximately 70% reduction to the deadlines proposed by Plaintiffs, who
promptly communicated why such a drastic reduction was unacceptable:
[W]e believe these deadlines are entirely unrealistic and prejudicial due to, inter
alia, the novel legal issues, numerous, fast approaching holidays and failure to
account for the normal course of discovery. Indeed, if the requests were served
today, responses and objections would not be received for another 30 days—
resulting in an abbreviated time (~70 days) to, inter alia, raise discovery
deficiencies, seek supplemental discovery and schedule and conduct depositions.
Your schedule fails to account for each of these anticipated issues, as demonstrated
by the fact that you suggest summary judgment motions be filed on or before
January 1, 2025.1
We, therefore, cannot agree to any portion of your proposed
scheduling.
September 20, 2024, email from Plaintiffs’ counsel to Defendants’ counsel. Defendants’ counsel,
in response, communicated that they were only willing to agree to one additional week to the dates
they proposed in their responsive edit. Given the impasse, Plaintiffs’ counsel believed that a meet
and confer would be unfruitful and waste further client resources. Defendants’ counsel,
subsequently, agreed to Plaintiffs’ submitting their proposed case management plan to the Court
along with a disclosure of the parties’ aforementioned positions.
Plaintiffs respectfully request that the Court enter its proposed case management plan, filed
herewith as Exhibit A. As explained to Defendants’ counsel, the jurisdictional issues in this case
are novel, as demonstrated by the fact that an appeal was necessary to address this aspect of
Plaintiffs’ case. It is, therefore, highly improper and prejudicial to Plaintiffs’ claims that
discovery—consisting of initial and supplemental requests for documents, requests for admission
and interrogatories, in addition to depositions of potentially six different parties—and dispositive
motion practice all be completed during the 4-month period2
that Defendants are proposing,
despite the numerous, fast-approaching religious and federal holidays (e.g., Yom Kippur, Diwali,
Thanksgiving, Christmas, Hanukkah and New Years) and discovery disputes that will likely arise.
The dates proposed by Plaintiff are more reasonable in that they avoid scheduling conflicts with
the foregoing holidays, attempt to resolve unnecessary future requests to the Court to modify and
extend the case management plan and, most importantly, seek to provide a maximum allowed time
frame; indeed, nothing prohibits either party from moving for summary judgment before the
July 25, 2025, deadline proposed by Plaintiffs.
Plaintiffs respectfully request that the Court enter the proposed case management plan filed
herewith as Exhibit A. Plaintiffs are available for a status conference on this matter should further
discussion be necessary.
1
In response to this email, Defendants circulated a revised edit with one change: that dispositive
motions be submitted on or before January 31, 2025. See Exhibit B. No changes were made to
the other proposed case deadlines.
2 Plaintiffs note that whatever period ordered by the Court is immediately shortened by at least
1 month due to the fact that—presuming no extensions are requested and provided—discovery
responses will be due 30 days from the date the requests are served. This, however, fails to
additional delays that could arise from discovery disputes.
Case 1:22-cv-08163-VM-SDA Document 60 Filed 09/23/24 Page 2 of 3
DarkPulse, Inc., et al. v. Crown Bridge Partners, LLC, et al.,
No. 1:22-cv-08163-VM
September 23, 2024
Page 2 of 2
Plaintiffs thank the Court for its time and attention to this matter.
Respectfully submitted,
/s/ Eric J. Benzenberg
Eric J. Benzenberg, Esq.
Mark R. Basile, Esq.
THE BASILE LAW FIRM P.C.
390 N. Broadway, Suite 140
Jericho, NY 11753
Tel.: (516) 455-1500
Email: eric@thebasilelawfirm.com
mark@thebasilelawfirm.com
Counsel for Plaintiffs DarkPulse, Inc.,
D_DOG
THATS SOME NICE DD!!!
Now does the judge make a ruling from this or does the defendant get 6 months to file something else?? 6 months is just a made up number. Hoping it’s more like 7 days
And so, where are the links to the docs?
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THANKS DOG!!!
Tuesday, September 24, 2024
60 respm Memorandum in Opposition to Motion Tue 09/24 3:19 PM
MEMORANDUM in Opposition re56 MOTION for Reconsideration re54 Order on Motion for Judgment Debtor Exam MOTION for Protective Order filed by Redhawk Medical Products & Services L L C.(aty,Hargett, Jacob)
Att: 1 Exhibit A,
Att: 2 Exhibit B,
Att: 3 Exhibit B1,
Att: 4 Exhibit B2
D_DOG
I checked out the tickers listed in "The Basile Law Firm P.C. - Recent Court Wins" list to see where they are now since the "wins" .
8 tickers are no longer found on OTCMarkets - Gone
3 are now Expert Market and in the trip zero's
5 are flat or worst, many with very large A/S and O/S share structure, most in the trip zero's
NONE of these "wins" made any positive changes to the bottom line of these companies. They just carried on being a bad investment.
Even if they win this it will likely only provide some debt relief and maybe a relatively small monetary damages award. Klug will not share this with his victims.
The ones making out with these suits are the attorneys.
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THANK YOU FOR POSTING NICE DD
REDHAWK MOVING FORWARD IMO!!’ REDHAWK FORWARD ON
He works for Klug, not you.
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Obviously Eric Benzenberg is at the front of the line lol wait for it!
The clock is ticking now!! Tic tok tic tok! $$$$ no where to run now! lol
Eric Benzenberg
Super Lawyers
https://profiles.superlawyers.com › ... › Jericho
Eric Benzenberg is one of the top rated Securities & Corporate Finance attorneys in Jericho, NY. He has met the stringent Super Lawyers selection criteria.
Eric Benzenberg - The Basile Law Firm P.C.
LinkedIn · Eric Benzenberg
600+ followers
Roslyn, New York, United States · The Basile Law Firm P.C.
Eric Benzenberg, The Basile Law Firm PC, New York Law School, About, Admitted to practice in the State of New York, United States District Court.
This guy is a killer!! never looses a case!!
THANK YOU D DOG!!!
Monday, September 23, 2024
60 misc Letter Mon 09/23 4:28 PM
LETTER addressed to Judge Victor Marrero from Eric Benzenberg dated September 23, 2024 re: ECF 59. Document filed by DarkPulse, Inc., Redhawk Holdings Corp., Social Life Network, Inc...(Benzenberg, Eric)
Att: 1 Exhibit Plaintiffs' Proposed CMP,
Att: 2 Exhibit Defendants' Redline Proposed CMP
Monday, September 16, 2024
59 1 pgs order Order Mon 09/16 4:50 PM
ORDER The parties in this matter are hereby directed to confer and to propose an abbreviated case management plan for jurisdictional discovery and related dispositive motion practice, in light of the decision by the United States Court of Appeals remanding this case for further proceedings. (See Dkt. No. 58.) The proposed abbreviated case management plan shall be filed no later than seven days from the date of this Order. SO ORDERED. (Signed by Judge Victor Marrero on 9/16/2024) (jca)
D_DOG
Yeah, right !!!
Lol... That makes perfect sense coming from a Redhawk defender.
Hilarious...
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IMO I DIDNT. IT IS A POST NOT A REPLY. THANKS
I thought you said you wouldn't respond to them quite a while ago but you keep on responding.
IMO CALL MR KLUG HE WILL ANSWER WE WILL SEE WHAT THE COURTS SAY IMO
Thank you...
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SONY WILL ONLY RESPOND TO THE LONGS FOR NOW ON. THANKS LONGS.
KNIFE GREAT DD KEEP UP THE GREAT WORK YOUR THE BEST ON THE DD
Klug can say anything he wants in a phone call... Klug can just deny he ever said it. Hearsay...
Let's get Klug to post to this board what he has been telling folks...
How about it Klug???
We can start with "are the financials audited and ready to file with a form 10???" Or was that a lie, or did you never really say that???
We all will be waiting for an answer...
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IMO I DARE YOU TO CALL HIM I CAN GIVE YOU THE PHONE NUMBER GOOD BYE
Will he put it in writing and make it public????
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IMO MR KLUG WILL ANSWER YOUR CALL AND TALK TO YOU ! HE IS WAITING ON YOUR CALL TO TO DISCUSS ANYTHING WITH YOU
Who are you screaming at?
Use the public reply button.
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IMO MR KLUG STILL WAITING ON YOUR PHONE CALL
I am fairly certain that would be a TOS violation on my part if I answered that, however those that sent me such encouraging words which I will always appreciate are free to do whatever
We are all in this together.
We all have something in common and that common bond is pieces of paper that are worthless in a revoked Untradable stock
Technically speaking, they aren’t pieces of paper they were before revocation, electronic entries however they’re just as worthless as a roll of toilet paper
Well thank you and all those other Redhawk shareholders that suggested I should apply for a MOD position. I am still learning the rules and look forward to making updated changes to the intro page that I woefully outdated.
Thanks for the endorsement
Redhawk = we’ve been had
Congrats on your new position here 👏
The previous "filings" Klug did post to EDGAR were also incomplete. misleading, and fraudulent.
Klug is not what he may appear to be... Klug is a lying con man...
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He hid the books by going delinquent, then private.
IF SOMEONE MET OR THEY KNOW MR KLUG THEY HAVE NO PROBLEM CALLING HIM IMO
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About RedHawk Holdings Corp.
RedHawk Holdings Corp., formerly Independence Energy Corp., is a diversified holding company which, through its subsidiaries, is engaged in the sales and distribution of medical devices, sales of branded generic pharmaceutical drugs, commercial real estate investment and leasing, sales of point of entry full-body security systems, and specialized financial services. Through its medical products business unit, the Company sells the Sharps and Needle Destruction Device (SANDD™), WoundClot Surgical - Advanced Bleeding Control, and the Carotid Artery Digital Non-Contact Thermometer. Through our United Kingdom based subsidiary, we manufacture and market branded generic pharmaceuticals. RedHawk Energy holds the exclusive U.S. manufacturing and distribution rights for the Centri Controlled Entry System, a unique, closed cabinet, nominal dose transmission full-body x-ray scanner. For more information, please visit: http://www.redhawkholdingscorp.com
May 11, 2022
Redhawks Year to Year Growth, 2020 to 2022
For the fiscal year ending June 30, 2022 and the fiscal years ended June 30, 2021 and 2020, a summary of our net revenues under contract on a disaggregated basis:
2020 = $1,134,192 2021 = $1,992,952 2022 = $951,519,231
https://www.sec.gov/Archives/edgar/data/1353406/000175392622000688/g083009_ex99-1.htm
May 16, 2022
Redhawk is working with a leading US healthcare provider/pharmacy to have our SANND Pro Needle Destruction Devices in all of their locations nationwide.
They are also working on an agreement to sell our SANDD mini units as well.
https://www.sec.gov/ix?doc=/Archives/edgar/data/1353406/000175392622000715/g083015_8k.htm
Redhawk Medical is a branch of Redhawk Holdings:
ABOUT REDHAWK MEDICAL
https://redhawkmedicalproducts.com/pages/about-redhawk-medical
Who We Are
Redhawk Medical Products and Services is a wholly owned subsidiary of RedHawk Holdings Corp. a diversified company which, through its partially and wholly owned subsidiaries, is engaged in medical device sales, pharmaceuticals, and medical equipment lease & sales.
Capabilities
In addition to the distribution of an industry changing line of medical devices, RedHawk Medical Products and Services is capable of distributing products to aid in a return to work and safe reopening of our nation’s schools, restaurants, hospitality brands, law enforcement and first responder agencies and healthcare providers.
We’re committed to manufacturing and distributing quality products that will make a positive contribution in our communities.
Sharps and Needle Destruction Device SANDD, FDA approved, proprietary line of devices that provide a safer, more economical and environmentally friendly method of disposing of used needles.
UV C light sanitization products developed to maintain safe and clean environments, air space and surfaces.
High quality Personal Protective Equipment sourced from reputable manufacturing partners
Personal Protective masks, gloves and face shields that meet NIOSH specifications and/or FDA guidelines.
Customized PPE packages for Law Enforcement and First Responders
Safe Sanitized Classroom bundles for School Systems
Safe Sanitized Patron packages and Guest Room packages for Restaurants and Hospitality applications
Safe Resident package for Assisted Living and Nursing Home residents
Our Core Principles: RedHawk Medical Products and Services develops, introduces and distributes equipment that serves a greater purpose by offering safe, more economical and environmentally friendly products to our customer base. RHMP&S unconditionally guarantees its products.
Owners: RedHawk Medical Products and Services is a wholly owned subsidiary of RedHawk Holdings Corp. (OTC: SNDD)
National Spokesperson: Dr. Drew Pinsky
Redhawk Medical carries Numerous medical products which are wholesaled and retailed:
https://redhawkmedicalproducts.com/
Redhawk Medical also holds the Intellectual Property Rights to the SANDD line of Needle Destruction devices. Through its medical products business unit, the Company sells the Sharps and Needle Destruction Device (SANDD™)
https://nomoresharps.com/
The SANDD Mini:
The SANDD Pro:
More information on the SANDD line of products can be found here:
https://nomoresharps.com/
https://twitter.com/destroyneedles
https://www.facebook.com/destroyneedles/
https://www.linkedin.com/company/destroyneedles/
https://www.instagram.com/destroyneedles/
The SANDD line featuring Dr. Drew has had commercials on the following networks:
CMT, Ovation, CNN, Fox News, INSP, Discovery Life Channel:
https://ispot.tv/a/nfyA
https://www.youtube.com/watch?v=z1e1GnI06n4
Actor Derek Theler Joins SNDD as a spokesman
Some Police Departments are currently using the SANDD First Responder.
There are many aspects to Redhawk Holdings which also include:
-EcoGen Europe
https://ecogen-europe.co.uk/
-RedHawk energies
https://www.redhawkholdingscorp.com/redhawk-energy-corp/
http://www.redhawkenergycorp.com/
-RedHawk Land and Hospitality
https://www.redhawkholdingscorp.com/redhawk-land-hospitality/
The team that has been created here has vast medical experience. They have been strategically selected and have years of experience in the medical supply chain with hospital and law enforcement connections.
Who We are:
Darcy Klug - CEO:
https://www.expertconnectionpr.com/darcy-klug/
Philanthropy:
https://www.lsufoundation.org/s/1585/17/interior.aspx?sid=1585&gid=1&pgid=880
Interview with Darcy Klug:
https://healthprofessionalradio.com.au/sandd-mini-sharps-and-needle-destruction-device/
Board of directors member Joseph Mohr:
https://finance.yahoo.com/news/redhawk-announces-appointment-supply-chain-170000139.html
https://www.accesswire.com/559414/RedHawk-Announces-Appointment-of-Supply-Chain-Veteran-to-the-Board-of-Directors
Here is his Linkedin showing all his experience:
https://www.linkedin.com/in/joe-mohr-1bbb7015
Board of directors member Charles D'Agostino:
https://ih.advfn.com/stock-market/USOTC/redhawk-holdings-corp-SNDD/stock-news/81319066/charles-f-dagostino-joins-redhawk-board
https://www.accesswire.com/569664/Charles-F-Dagostino-Joins-RedHawk-Board
https://www.linkedin.com/in/charles-d-agostino-349a613
Board of directors member Gerald C. Guzzino
https://ih.advfn.com/stock-market/USOTC/redhawk-pk-SNDD/stock-news/80726865/redhawk-announces-appointment-of-senior-medical-de
https://www.accesswire.com/559537/RedHawk-Announces-Appointment-of-Senior-Medical-Device-Sales-Executive-to-Board
https://www.linkedin.com/in/gerald-guzzino-32601a80/
Redhawk hired Sheriff Bud Torres to lead the first responder marketing unit:
https://www.prnewswire.com/news-releases/sheriff-bud-torres-iii-to-lead-redhawks-first-responder-marketing-unit-301037487.html
https://ih.advfn.com/stock-market/USOTC/redhawk-pk-SNDD/stock-news/82195158/sheriff-bud-torres-iii-to-lead-redhawks-first-resp
https://www.linkedin.com/in/bud-torres-0a6116a0/
For information about the current share structure please follow this link:
https://www.otcmarkets.com/stock/SNDD/security
===================================================================================================================
OVER YEAR+ DELINQUENT FINANCIALS !!
SHAREHOLDERS IN THE DARK ABOUT SNDD's FINANCIAL SITUATION.
LAST FILING AS OF Period End 3-31-2021
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