/Fields [] AmeriHealth Caritas is a multi-line health insurance company that provides managed care programs and related services. As /Annots [] /Fm0 96 0 R The goal of this section is to provide consumers with a comprehensive resource on class action and mass tort lawsuits. >> I would be forced to go into a nursing home, because I cant function on two hours a day, she said. /C2_0 50 0 R If you have records relating to your work with AmeriHealth, please keep them until we ask you for them. In Travel Pay Row. Iowa shifted its $4 billion Medicaid program to private management last year. Password (at least 8 characters required). But Roxanne Conlin, a lawyer for the disabled plaintiffs, asked the judge to let the suit against the state move forward as a class action. /TT0 39 0 R /Length 10 2Q0`caInp V#I*bv00Vb D 2E01v`eX\3d)x``A8l3FPAA You may be eligible to make a claim under state law if you worked over forty (40) hours per week for AmeriHealth as a Clinical Care Reviewer, Concurrent Review Nurse, Prior Authorization Nurse, or in a similar position, in Pennsylvania and you were paid a salary. /C2_1 93 0 R /F1 38 0 R /Resources << << The Plaintiff, a Clinical Care Reviewer, brings her claims on behalf of herself and other Clinical Care Reviewers (also known as Concurrent Review and Prior Authorization Nurses), who worked for AmeriHealth Caritas across the country. /Name (Adobe Fill & Sign) /CropBox [0.0 0.0 612.0 792.0] The six plaintiffs in the case all were clients of AmeriHealth Caritas, one of three companies initially hired by Iowa in April 2016 to take over management of the Iowa program, which costs $4.8 . Win Toss Of SAG-AFTRA's Royalties Suit For Now, NLRB Should Keep Ballots Impounded, Transport Co. Says, 4th Circ. Its sole named defendant is now Jerry Foxhoven, who succeeded Palmer as department director in June. Password (at least 8 characters required). /degree /plusminus /twosuperior /threesuperior /acute /mu 183 /periodcentered /cedilla /onesuperior /Annots [] /F1 38 0 R /MediaBox [0.0 0.0 612.0 792.0] /Rotate 0 Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. /Contents [66 0 R 67 0 R 68 0 R] /F1 38 0 R /F1 38 0 R /Type /Pages /Rotate 0 /Marked false /CropBox [0.0 0.0 612.0 792.0] >> 9?TBP+074zt72*CnFIs:!,bE2|Hu@Mn!W' Tv+. /ADBE_FillSignInfo << Email (NOTE: Free email domains not supported). Hes better, she said. - Torres v. Brandsafway Indus. Regardless of which managed care company is in place, the director of the Iowa Department of Human Services is ultimately responsible for ensuring that Iowans have the Medicaid services they need and receive notice and an opportunity for a fair hearing when their services are denied or cut.. Fisher, 62, said she needs extensive in-home assistance, because she cant eat, bathe or go to the bathroom by herself. /TT0 95 0 R 17-3697, see flags on bad law, and search Casetext's comprehensive legal database All State & Fed. In other words, the company alleges that its non-payment of overtime wages is legally correct and that it has not violated federal or state wage laws. % If you work for AmeriHealth and you believe you may be the victim of retaliation for joining this lawsuit,contact the case clerk, Madeline Orozco, at (612) 256-3297 or morozco@nka.com to determine whether they may be eligible to make a claim. Daily and real-time news and case alerts on organizations, industries, and customized search queries. 23 0 obj /TT1 40 0 R /Type /Font v. Dr. Courtney N. Phillips There is a class action lawsuit pending against LDH in federal court at the Middle District of Louisiana bearing the caption A.A. et al. 21 0 obj /CropBox [0.0 0.0 612.0 792.0] /Type /Page Class Action Settlement Recap Enhancements to Claim Payment Policy, Processing and Payment Disclosure, and an Appeals Process for Class Action Settlement Providers The following enhancements are effective for providers who agreed to the terms of the court-approved class action settlement ("Settlement Providers"), for Gregg v. AmeriHealth et al, AmeriHealth Caritas is a multi-line health insurance company that provides managed care programs and related services. /Version 100 The lawsuit alleges that the plaintiff and others working as Clinical Care Reviewers are misclassified as exempt from overtime requirements under the Fair Labor Standards Act. 27 0 obj /BaseFont /ZapfDingbats Doocy on Friday said the cuts have continued under UnitedHealthcare. /Tabs /S /Font << In the legal profession, information is the key to success. >> The plaintiffs want U.S. District Judge Rebecca Goodgame Ebinger to order Foxhoven to step in and change the way the managed-care companies handle services for Iowans with disabilities. This collective action lawsuit is going forward in the District Court for the Eastern District of Pennsylvania. /Pages 5 0 R 2023, Portfolio Media, Inc. | About | Contact Us | Legal Jobs | Advertise with Law360 | Careers at Law360 | Terms | Privacy Policy | Cookie Settings | Help | Site Map, AmeriHealth Workers' $4.3M FLSA Overtime Deal Gets OK'd. Court File No. /Type /Encoding /ProcSet [/PDF /Text] /Parent 12 0 R The lawsuit is being spearheaded by the advocacy group Disability Rights Iowa, which has asked a federal judge to declare the suita class-action case on behalf of about 15,000 Iowans with disabilities. |e H?'hQSrWS}NZ?V endstream >> AmeriHealth Caritas Services, LLC Et. /TT2 41 0 R >> << Al. Pa. Jan. 20, 2023). >> The lawsuit seeks to recover unpaid overtime wages for CHC Service Coordinators employed in Pennsylvania by AmeriHealth Caritas. More than 300clinical care review workers for AmeriHealth Caritas Services LLC secured approval from afederal judge Tuesday to finalize their $4.25 million settlement resolving a collective action alleging they were denied overtime wages after being improperly classified as overtime-exempt. 19 0 obj /Tabs /S /Count 8 They said they would respond in court by Nov. 15. /Name /ZaDb /Tabs /S Filing 1 COMPLAINT against AmeriHealth Caritas Services, LLC ( Filing fee $ 400 receipt number 0313-14545013. /igrave /iacute /icircumflex /idieresis /eth /ntilde /ograve /oacute /ocircumflex /otilde For help enrolling, you can call Healthy Louisiana at 1-855-229-6848 (TTY 711). More than 300 clinical care review workers for AmeriHealth Caritas Services LLC secured approval from a federal judge Tuesday to finalize their $4.25 million settlement resolving a collective. /ProcSet [/PDF /Text] /Encoding 7 0 R The Disability Rights Iowa lawsuit was originally filed against Reynolds and Charles Palmer, who was then director of the Iowa Department of Human Services. >> /Type /Catalog Though the plaintiff and similarly situated employees regularly work more than 40 hours per week, according to the complaint, they allegedly do not receive any time-and-a-half overtime wages for the hours they work above 40. /Font << >> /Resources << /Filter /FlateDecode Kim Reynolds said while mistakes have been made in implementing the new management systems,she doesnt believe the state should resume management of the program. << /Resources << To: AmeriHealth Caritas Louisiana Providers Date: October 11, 2021 Subject: Pending Lawsuit: A.A. et al. Doocy says voters this fall should take careful note of their representatives actions in the matter. >> endobj /Resources << /Name /Helv Full-text searches on all patent complaints in federal courts. Already a subscriber? Later in the hearing, Assistant Attorney General Gretchen Kraemer tried to cast doubt on Wargos contention that all the in-home services her boyfriend receives under Medicaid are crucial to his health. Try our Advanced Search for more refined results, Searching cases in Amerihealth Caritas Today, we started this lawsuit by filing a Complaint in the Philadelphia Court of Common Pleas. To learn more about this case, feel free to contact the case clerk, contact the case clerk, Madeline Orozco, at (612) 256-3297 or morozco@nka.com to determine whether they may be eligible to make a claim. /Font << /Font << endobj Have significant experience in similar matters under the [Pennsylvania Minimum Wage Act]. << The deadline for individuals to join the lawsuit is May 6, 2022. Although the process and terminology may differ slightly, the idea behind both a class and collective action is the same: it allows one or more people to sue on behalf of themselves and other similarly situated people who have similar claims. 5 0 obj /Oslash /Ugrave /Uacute /Ucircumflex /Udieresis /Yacute /Thorn /germandbls /agrave /aacute The lawsuit against Iowa was filed last year, Your California Privacy Rights/Privacy Policy. Today, AmeriHealth Caritas filed its Answer to the Amended Complaint. /Parent 12 0 R /XObject << /Type /Page /ProcSet [/PDF /Text] endobj We strongly disagree with the judges decision, said DRI Director Jane Hudson. >> We are very pleased to report that, as of today, 111 current and former CHC Service Coordinators have joined this lawsuit by returning "Consent Forms." /Annots [] << No tags have been applied so far. << You can learn more about the lawsuit below. Doocy also believes the in-home assistance provided to her son has saved taxpayer dollars, citing the overall and ongoing costs of long-term institutionalized care. Copies of the removal papers are available below. /MarkInfo << /Contents [82 0 R 83 0 R 84 0 R] xZl^ @o{%k << /Type /Font /Tabs /S 25 0 obj 11 0 obj /Rotate 0 /Fm4 100 0 R AmeriHealth Caritas service coordinators accuse the company of violating the state's minimum wage law by failing to pay overtime in a proposed class action filed in Pennsylvania state court. NLRB Chose Precedent For 'Predestined Result,' NRTW Says, Colo. Farms Drop Challenge To State's Labor Rights Law, NLRB Atty Says Tweets Over Race Bias Are Protected Activity, Movie Producers Illegally Fired Strikers, NLRB Judge Says, SEIU Affiliate Can't Escape Kaiser's Sympathy Strike Claims, TV Cos. /ModDate (D:20211202101246-05'00') PRELIMINARY STATEMENT 1. /C2_0 86 0 R Nj_JxR"0 ~ "6?W|iiVpsSGR2 W_ R@OgBQK8>HhP/W/wb'_> HFtJ.#kx:0;Q~rA(Pkasq6H y^P kik(,mt"#qr]' endobj endstream /Rotate 0 A copy of the Complaint is available below. /Tabs /S >> /Tabs /S endobj He has for years lived independently through a network of assistance that his mother, Marilyn Doocy, said has saved her son from being institutionalized. Today, the Federal Judge entered a stipulated Order "conditionally certifying" this lawsuit as a "collective action." . /F1 38 0 R /CropBox [0.0 0.0 612.0 792.0] >> endobj /ProcSet [/PDF /Text] advice regarding your individual situation. Significant legal events involving law firms, companies, industries, and government agencies. In the Complaint, the Plaintiff alleges that AmeriHealth Caritas misclassified her and other Clinical Care Reviewers as exempt employees, denying them overtime compensation. << The lawsuit against Iowa was filed last year by Disability Rights Iowa, a federally supported advocacy group that seeks to protect the rights of people with disabilities. >> /Helv 9 0 R R. Steven Whalen, U.S. Magistrate Judge. One of them was Melinda Fisher of Cedar Rapids, who has a severe form of multiple sclerosis. /Type /Page This means we will only be paid if the lawsuit is successful in obtaining relief either through a settlement or an award, and that payment will only come out of that settlement or award. endobj Already a subscriber? That's why we offer a variety of benefits, services, and tools that focus on the whole person. 22 0 obj Case 2:17-cv-03697-GJP Document 1 Filed 08/15/17 Page 3 of 14 PARTIES 11. New to ClassAction.org? The lawsuit is being spearheaded by the advocacy group Disability Rights Iowa, which has asked a federal judge to declare the suit a class-action case on behalf of about 15,000 Iowans with . /Type /Page 30 0 obj /Resources << << /Annots [] /Rotate 0 Read full Disclaimer. /Parent 12 0 R Eligible individuals have until May 31, 2022 to join the case. ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS' MOTION TO SUMMARY JUDGMENT [43] Arthur J. Tarnow, Senior United States District Judge. /Resources << Iowas shift to privatized Medicaid is making changes that could leave Matteson without a safe option for staying in his home. SRt@)&Y A more recent docket listing /TT1 40 0 R >> /Resources << She seeks to recover unpaid overtime compensation, liquidated (double) damages, and other statutorily-permitted relief for herself and others. /TT2 41 0 R endobj >> >> 24 0 obj You should consult an attorney for /F1 38 0 R Patti Murphy of Indianola speaks on behalf of her 39-year-old disabled daughter, Shannon, who survives on a ventilator. << /MediaBox [0.0 0.0 612.0 792.0] /TT3 72 0 R /Order [] >> Defendants. on behalf of six Iowans with disabilities, AmeriHealth Caritas announced it would withdraw, Your California Privacy Rights/Privacy Policy. /ProcSet [/PDF /Text] >> Claims may be keyed into the ConnectCenter within the AmeriHealth Caritas NaviNet provider portal using the 1500 and UB-04 online claim forms or submitted into the system by using the claim upload functionality. /Parent 11 0 R /Tabs /S /Producer <6954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> stream Enter your details below and select your area(s) of interest to receive Law360 Employment Authority daily newsletters and section features. 6 0 obj >> /Font << Reflects complaints, answers, motions, orders and trial notes entered from Jan. 1, 2011.Additional or older documents may be available in Pacer. This docket was last retrieved on October 14, 2020. /Font << Disability Rights claimed in a June 2017 lawsuit that levels of care for people with serious disabilities are being terminated, reduced or denied without legal justification, often violating constitutionally protected due process, through engaging in vague, subjective, arbitrary and secret criteria.. >> /C2_0 50 0 R /odieresis /divide /oslash /ugrave /uacute /ucircumflex /udieresis /yacute /thorn /ydieresis] << >> Near the end of the hearing, Assistant Attorney General Anagha Dixit summed up the states contention that its Medicaid program cant afford to finance every service people with disabilities could use at home. /TT2 41 0 R }95e, \fwWr+Aj* -=k /Parent 11 0 R /Parent 11 0 R /ColorSpace << Mother says Iowas privatized Medicaid is unsafe for her son. /Parent 12 0 R /Contents [73 0 R 74 0 R 75 0 R] /TT0 39 0 R Goodgame Ebinger recently presided over a daylong hearing on the suit that at times became emotional. Simplified Chinese (PDF) Spanish (PDF) Vietnamese (PDF) The member handbook on this website is the most up-to-date version. /Rotate 0 Access this case on the Pennsylvania Eastern District Court's Electronic Court Filings (ECF) System. /CropBox [0.0 0.0 612.0 792.0] filed a lawsuit against Defendant for violating the overtime . >> According to the Complaint, Clinical Care Reviewers do not satisfy any of the overtime exemptions under federal or state law. SERVICES, LLC, Defendant. COLLECTIVE ACTION . Marilyn Doocys son Marty Matteson has Down syndrome and lives in his own home with assistance paid for by Medicaid. /Rotate 0 As indicated, the company alleges, among other things, that CHC Service Coordinators are "exempt" from the federal and state overtime laws. /MediaBox [0.0 0.0 612.0 792.0] /Type /Page /TT1 40 0 R >> Use the links below to access additional information about this case on the US Court's PACER system. Do I Have a Qualifying Federal Law Claim? AmeriHealth Caritas Services, LLC is on the receiving end of a proposed class and collective action filed by a current employee who claims she does not receive proper overtime wages. ClassAction.org is a group of online professionals (designers, developers and writers) with years of experience in the legal industry. /ordmasculine 188 /onequarter /onehalf /threequarters 192 /Agrave /Aacute /Acircumflex /Atilde 201 : Jury Demanded By: Plaintiff: RSS Track this Docket Docket Report . /Type /Pages But lawyers from the Iowa attorney generals office contend the ground crumbled from beneath the lawsuit last week, when the management firm AmeriHealth Caritas announced it would withdraw from Iowas Medicaid program because of a contract dispute. Cause of Action: 29 U.S.C. stream /ProcSet [/PDF /Text] /C2_0 50 0 R /C2_0 50 0 R /Contents [63 0 R 64 0 R 65 0 R] AmeriHealth Caritas Louisiana does that every day. 20 0 obj Kim Reynolds, say the shift is saving the state millions of dollars while leading to more efficient care for the approximately 600,000 poor or disabled Iowans who use the Medicaid program. Im going to keep fighting.. /F1 38 0 R /TT0 39 0 R /Type /Page /Font << >> /ProcSet [/PDF /Text] >> endobj << /Parent 5 0 R As she testified, Siegel sat in his wheelchair in the back of the courtroom, being comforted by supporters. New cases and investigations, settlement deadlines, and news straight to your inbox. /TT0 39 0 R /ZaDb 10 0 R /Contents [76 0 R 77 0 R 78 0 R] >> /Font << Read our Newswire Disclaimer. /Kids [13 0 R 14 0 R 15 0 R 16 0 R 17 0 R 18 0 R 19 0 R 20 0 R] >> /quotesingle 96 /grave 128 /bullet /dagger /daggerdbl /ellipsis /emdash /endash 16 0 obj Skill and professionalism are just as important as the ability to connect on a personal level. She is more than a dollar sign, she is a person. To join others in making a claim for overtime compensation under federal law, you must complete aPlaintiff Consent form. >> endobj Learn more about our offerings, and . >> /TT0 39 0 R He moaned,grunted and cried out as Wargo recounted the cuts AmeriHealth had ordered in the amount of in-home care it would finance under Iowas Medicaid program. /Encoding 7 0 R /F1 38 0 R No. /TT0 39 0 R /TT1 41 0 R On March 24, 2022, the Court conditionally certified a Fair Labor Standards Act collective of clinical care reviewers who worked for AmeriHealth Caritas from three years prior to the filing of the Complaint to the present and who have not been paid overtime for work in excess of forty hours per week. This takes the place of all previous print or website versions of the handbook. There is no money currently available and there is no guarantee that you will receive money for participating in the lawsuit. /dotlessi /lslash /oe /scaron /zcaron 160 /Euro 164 /currency 166 /Rotate 0 Law360 may contact you in your professional capacity with information about our other products, services and events that we believe may be of interest.Youll be able to update your communication preferences via the unsubscribe link provided within our communications.We take your privacy seriously. Our attorneys are zealous advocates committed to fighting for the justice our clients deserve. /TT0 39 0 R endobj /BaseFont /Courier >> /Parent 12 0 R /TT0 39 0 R 9 0 obj If you know of any Clinical Care Reviewers, Concurrent Review Nurses, Prior Authorization Nurses, or others that worked in a similar position who may be interested in making a claim for unpaid overtime, please inform them that they should contact the case clerk, Madeline Orozco, at (612) 256-3297 or morozco@nka.com com to determine whether they may be eligible to make a claim. …Its a difference in want vs. need.. /C2_0 50 0 R /Tabs /S >> HRmo0X*TU$:m4JMS4)sg' K[; All significant new filings across U.S. federal district courts, updated hourly on business days. stream /ProcSet [/PDF /Text] 13 0 obj /Type /Metadata But AmeriHealth ordered her daily in-home aide hours cut to two hours, she testified. /TT2 40 0 R /ExtGState << It doesnt matter which company youve got, theyre all profit-motivated and acting the same, Doocy said. >> On November 30, 2021, an AmeriHealth Caritas Services, LLC (AmeriHealth) employee filed a lawsuit in the United States District Court for the Eastern District of Pennsylvania to recover unpaid overtime wages from her employer. /Contents [69 0 R 70 0 R 71 0 R] /GS0 85 0 R /TT1 40 0 R Today, we filed an Amended Complaint. Despite the sharp criticism and concerns voiced publicly by lawmakers in both parties, DHS Director Jerry Foxhoven has given the agency and the private companies' overseeingMedicaid high marks. /Contents [43 0 R 44 0 R 45 0 R] Lawyers for the group later changed the suit. On November 30, 2021, an AmeriHealth Caritas Services, LLC ("AmeriHealth") employee filed a lawsuit in the United States District Court for the Eastern District of Pennsylvania to recover unpaid overtime wages from her employer. /Rotate 0 See below for more details on this process. 12 0 obj AmeriHealth spokesman Joshua Brett said the focus of the lawsuit was the overall Iowa program and noted ithad not named AmeriHealth as a party. >> /Parent 11 0 R << Learn more below about how our CARE IS about you. endobj /Rotate 0 << There is no evidence in the record that the issues complained of by the plaintiffs relate to other managed care organizations, the state lawyers wrote. /F1 38 0 R endobj %PDF-1.5 % Password (at least 8 characters required). >> endobj If we can prove AmeriHealth willfully violated the law, the statute of limitations may be extended to three years. >> /TT1 40 0 R AmeriHealth has more than 200,000 Iowa clients, including the bulk of Iowa Medicaid members who have serious disabilities. /Name /Cour We have decided that we are not going to challenge AmeriHealth Caritas' removal of this lawsuit to the United States District Court. Because this lawsuit arises under both federal and state law, you may have a qualifying federal law claim, state law claim, or both federal and state law claims. … A showing that unconstitutional practices have taken place in the past is not enough. >> /quoteright /quotesinglbase /trademark /fi /fl /Lslash /OE /Scaron /Ydieresis /Zcaron Try our Advanced Search for more refined results. HYK0)13&iz,,B\_ A 9~O:jH,Z!W. The list is updated frequently, so check . Click here to login, 2023, Portfolio Media, Inc. | About Employment Authority | Contact Us | Advertise with Law360 | Terms | Privacy Policy | Cookie Settings. Earlier this month,the Register published an investigation showing hundreds of cases where Medicaid recipients have appealed what they say are illegal denials of care. >> /Resources << /Cour 8 0 R >> >> However, Plaintiff and . /Font << endobj /Contents [87 0 R 88 0 R 89 0 R] >> /Tabs /S /Contents [60 0 R 61 0 R 62 0 R] A lawsuit accusing Iowas privately run Medicaid program of illegally denying health assistance for thousands of Iowans with disabilities was dismissed Friday by a federal judge because the managed-care company in the suit ended its contract with the state. Siegel, 54, suffered a brain injury when a car hit him as he bicycled in 2013. The state lawyers noted in a court filing last week that AmeriHealth oversees Medicaid benefits for all six initial plaintiffs in the Disability Rights Iowa lawsuit. /Parent 12 0 R /C2_0 50 0 R /Filter /FlateDecode Our dedicated staff have unparalleled commitment to our clients as well, and together with our attorneys, they work tirelessly to advance employee and consumer rights. /AcroForm 2 0 R I took a free trial but didn't get a verification email. /Annots [] /T1_0 94 0 R You have to know whats happening with clients, competitors, practice areas, and industries. /TT2 41 0 R /MediaBox [0.0 0.0 612.0 792.0] /Length 492 That left Amerigroup and UnitedHealthcare to manage claims for the 600,000 Iowans in the program. The lawsuit was filed in June on behalf of six Iowans with disabilities, who argue that the states shift to private management of Medicaid led to illegal cuts to their in-home care services. /Annots [] 15 0 obj Camp Lejeune residents now have the opportunity to claim compensation for harm suffered from contaminated water. /TT3 46 0 R To complete and submit the form electronically, clickhere. It is against the law for an employer to retaliate against a person for joining a lawsuit to reclaim unpaid wages. endobj /Type /Page Contacting us does not create an attorney-client relationship. /TT1 40 0 R endobj endobj >> This case is both a potential collective action under federal law and a potential class action under Pennsylvania state law. The deadline for individuals to join the lawsuit is May 6, 2022. PLEASE NOTE: A verification email will be sent to your address before you can access your trial. /TT1 40 0 R A copy of the Amended Complaint is available below. AmeriHealth Caritas Servs., CIVIL ACTION NO. /TT1 46 0 R This case was filed in U.S. District Courts, Pennsylvania Eastern District. /Tabs /S AmeriHealth Caritas Services, LLC Filed: August 15, 2017 2:17-cv-03697-GJP Read Complaint AmeriHealth Caritas Services, LLC is on the receiving end of a proposed class and collective action filed by a current employee who claims she does not receive proper overtime wages. /MediaBox [0.0 0.0 612.0 792.0] The AmeriHealth Family of Companies offers a range of services for individuals and employers. The company's mission is to help those most in need get care, stay well, and build healthy communities. @V0iSpy]O@?sD1=gHNr>Y? PLEASE NOTE: A verification email will be sent to your address before you can access your trial. /C2_0 50 0 R >> /Encoding << /Type /OCG 4 0 obj The departure of a controversial Medicaid management company should block a federal lawsuit against Iowas human-services director, state lawyers say. 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