boilerplate objections california

[and] we treat [the] general objections as if they were never made.). However, a judicial order finding a waiver of privilege is not authorized by the statute. Because defendant did assert the attorney-client and work product privileges in a timely manner, albeit in a boiler-plate fashion, the court erred in finding a waiver of privilege(s). 2020 February At the beginning of 2019, Governor Gavin Newsom signed three bills dealing with investigative procedures in California courts. ~=tzy bH3A_CW_Dn&[:!H oiW4lGi]/6x`A,AyZK&Y~&&f(arf -!`8 OwO{0rZg +!1$yeL,*F` 4+l*mc pI-sZd4*UQ?]IeS\~.P(mXJPg6n'{F(FoOjZ[/hUw]QT=5. Under amended Rule 34 (b) (2) (B), parties responding to discovery requests must: (i) avoid general or blanket objections when responding to requests for production; (ii) state whether documents will be withheld pursuant to objections; (iii) state whether they will produce copies or permit inspection; and (iv) complete production "no later than 12 on the basis that "it exceeds the scope of expert discovery under Rule 2-402(f)." Md. 2. With a legal and business background, Mike is experienced and passionate about creating thoughtful, out-of-the-box educational resources that help keep legal teams interested and on top of emerging need to know e-discovery issues. 6. At least for federal litigators. The Objection does not comply with California Rules of Court, rules 2.108(4), 2.110, and 2.111(7). boilerplate. According to Judge Bennett, boilerplate objections are "obstructionist" and this obstructionist discovery practice is a firmly entrenched "culture" in some parts of the country, notwithstanding that it involves practices that are contrary to the rulings of every federal and state court to address them. I bet those lawyers will be back in a month. Mar 22, 2017. The remaining issues were not open to reasonable disagreement; one party served reasonable factual interrogatories, and the other party inserted a pile of boilerplate objections followed by worthless verbiage that would be true in every case. 3. [Citation.] Litigators should recognize that the rules of civil procedure under both federal and Wisconsin law do not authorize the use of form boilerplate objections. Proc. This is not a two-step process. So, note that Experian raised a privilege . Effectively doing so demonstrates to the court that you are not making "boilerplate . Taking advantage of written discovery at an early stage in litigation helps identify sources of information for later discovery, and gives you additional background to prepare questions for an eventual oral deposition and other stages of your case. Continue Reading WHY THESE OBJECTIONS ARE GARBAGE. 125 0 obj <>/Filter/FlateDecode/ID[<291CDE86EE921B439151BDE112BF8436>]/Index[116 21]/Info 115 0 R/Length 62/Prev 125348/Root 117 0 R/Size 137/Type/XRef/W[1 2 1]>>stream Feb. 4, 2106) (commenting that defense counsel's use of boilerplate general objections violated Rules 33 and 34 and awarding plaintiff's costs in bringing a motion to compel). Maybe I send a letter to them; it depends on how futile it appears. Statutory law recognizes only three methods by which a party can waive a privilege. The good faith requirement has been turned into a weapon by which obstructionist parties thwart disputes from even making it to the court. Boilerplate general objections are sanctionable in California per Korea Data Systems Co. Ltd. v. Superior Court (1997) 51 Cal.App.4th 1513 and may result in waivers of privilege in the 9th Circuit per Burlington Northern & Santa Fe Ry Co. v. U.S. Dist. Sorry for the inconvenience but our website is not supported with using Internet Explorer as it was discontinued by Microsoft on June 15th, 2022. It is all typically connected to the same interests trying to limit civil discovery (as too expensive) and to deny access to civil justice, which comes as no surprise. SCEA raised boilerplate objections to nearly all of the requests. Get your daily dose of news, best practices, and technology from Exterro's e-discovery, privacy, and digital forensics experts here. The objections will be overruled and disregarded. 168, 171, 182 (N.D. Iowa 2017). Using discovery to reach evaluation, mediation and trial goals. This Plaintiff's Motion to Compel Further Responses to various discovery includes a (1) Notice of Motion; (2) Memorandum of Points and Authorities; (3) Meet and Confer Declaration pursuant to Code of Civil Procedure section 2016.040; (4) Separate Statement of items in dispute in compliance with California Rules of Court, rule 3.1345; and (5) Proposed Order. Plaintiff served a set of requests for inspection and production of documents and propounded a set of interrogatories. [6] Code Civ. The old expression "the devil is in the details" certainly rings true when answering written discovery requests in a federal court action. The Solicitor Generals Brief In Fosamax An End To Levine Preemption. Responding party objects to this request as it seeks documents that are not within defendants possession, custody, or control. Please switch to using another browser such as Edge, Firefox or Chrome. New York now requires the responding party to affirmatively state that the document production is being made as requested, or state "with reasonable particularity . General objections included the following: "Object to the extent the requests seek to impose obligations on the respondent beyond those imposed by the Rules." "Object to the extent the requests seek documents protected by the attorney-client privilege, the work product doctrine or any other applicable provision." . In short, counsel must craft targeted responses and objections . 37. See the resources listed at the end of this Guide for more information. )" Defendant asserts that his responses were made in good faith and to the extent the available information . Two wrongs don't make a right, but because the defendant's responses also asserted improper boilerplate objections, the court made the parties bear all of their own expenses, attorney fees, and costs in connection with the motion to compel. Fla. 2011) ([J]udges in this district typically condemn boilerplate objections as legally inadequate or meaningless.); accord Ritacca v. Abbott Laboratories, 203 F.R.D. For these reasons, Wisconsin state courts should align with the federal courts and not countenance the ongoing use of boilerplate objections. Many courts, including the federal courts, have a requirement that each discovery motion include a certification that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an effort to obtain it without court action. See Fed.R.Civ.P. The motion claimed plaintiff's requests did not relate to privileged matters[. See, e.g., United States ex rel. Los Angeles, CA 90071-3101 Telephone: (213) 626-8484 Facsimile: (213) 626-0078 Attorneys for Defendant, Cross-Complainant, and Cross-Defendant CITY OF PALMDALE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA ANTELOPE VALLEY GROUNDW A TER Judicial Council CoordinationCASES Proceeding No. quasi-disclaimers at the beginning of the document, such as, "objection to the extent that any of the requests do not conform to the Illinois Supreme Court Rules or the Code of Civil Procedure." In contrast, "boilerplate objections," also called "stock" or "formulaic" objections, 4 are made in response to individual discovery . Under section 802.05(2), the signature of the attorney certifies to the court that the objections are not being asserted for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation. Moreover, the objections must be warranted by existing law and have evidentiary support. hb```f``9`"/urPpu8i`~-H4/|1j8J70MK P9leihz#XZY( v S@(K7&%@32VJC])KXIf e`28 This writ proceeding involves a discovery dispute in commercial litigation between plaintiff Granatelli Motorsports, Inc. and defendant Best Products, Inc. Disobeying a court order to provide discovery. Wisconsin courts should also take guidance from the Federal Rules of Civil Procedure Advisory Committee Note, 2015 Amendment, which indicates that Rule 34 was amended to eliminate: the confusion that frequently arises when a producing party states several objections and still produces information, leaving the requesting party uncertain whether any relevant and responsive information has been withheld on the basis of the objections.4, Nor should courts accept reasoning that boilerplate objections are listed to preserve the objections, for the federal courts have produced a litany of decisions finding that boilerplate objections are improper unless based on particularized facts.5. Discovery objections must be specific and geared to inform the court and counsel as to what the potential problem is so it can be corrected. BEST PRODUCTS, INC., Petitioner, v. The SUPERIOR COURT of Los Angeles County, Respondent; Granatelli Motorsports, Inc., Real Party in Interest. 116 0 obj <> endobj "general objections" at the beginning of the response and then incorporating the objections into each response "to the extent they apply." Second, by interposing a litany of boilerplate objections to each discovery request and then answering the request "subject to and without waiving" the objections. Though most discovery disputes need not find their way into court, for those that do, the courts are in a unique position to deter the use of boilerplate objections, particularly because federal and state judges may rely on their statutory authority to issue sanctions, respectively, under Rule 26(g) and Wis. Stat. The need for a privilege log could have arisen had plaintiff properly moved to compel further responses to contest defendant's conclusory attorney-client and work product objections. Using a discovery method in a manner that does not comply with its specified procedures. Code of Civil Procedure section 2023.030 permits the court to impose an array of discovery sanctions against anyone engaging in conduct that is found to be a misuse of the discovery process. The discovery statutes broadly define what constitutes such a misuse of the discovery process: Youand anyone engaging in the offending conductmay be monetarily sanctioned for any of the above conduct.2 Section 2023.030 mandates that the court impose a monetary sanction where such a sanction is authorized by any provision of the discovery statutes unless you can show substantial justification for your position or that imposition of sanctions is unjust.3 Sanctions are not meant to punish; they are intended to prevent misuse of the discovery process.4, The court may also award sanctions under Code of Civil Procedure section 2023.020, which provides: Notwithstanding the outcome of the particular discovery motion, the court shall impose a monetary sanction ordering that any party or attorney who fails to confer as required pay the reasonable expenses, including attorneys fees, incurred by anyone as a result of that conduct.. If defendant fails to comply with such an order, section 2031 sets forth the exclusive remedies available to the court. In any event, plaintiff's argument is the proverbial distinction without a difference because, as we shall explain, the trial court lacked authority to overrule the objections at this juncture of the proceeding. On July 30, 2003, plaintiff served its first set of [52] requests for inspection and production of documents that evidence, refer or relate to the issues raised by the lawsuit. 4. Section 2030, subdivision (k) provides, in relevant part: If a party to whom interrogatories have been directed fails to serve a timely response, that party waives any objection to the interrogatories, including one based on privilege or on the protection for work product under Section 2018. This provision is inapplicable to this case because defendant did file timely responses that complied with the mandate of subdivision (f)(3) of section 2030. Download this FRCP E-Discovery Quick Guide to get all your questions answered. Statutory law provides the sole method by which a claim of privilege can be waived in responding to an interrogatory. The statute authorizes the court to make orders compelling further responses that adequately identify and describe documents for which a party (here, defendant) has raised boilerplate assertions of the attorney-client and work product privileges. Fisher v. Network Software Assocs., 217 F.R.D. 7. Objections to the form of the question include: argumentative; 7. asked and answered; 8. assumes facts not in evidence; 9. As we explained in Hernandez v. Superior Court, supra, 112 Cal.App.4th 285, 4 Cal.Rptr.3d 883: [A] responding party may object to an interrogatory that seeks privileged information by clearly stating the objection and the particular privilege invoked. [Citations. Boilerplate Objections And Good Faith Requirements Are Ruining Civil Discovery, Merck v. Albrecht: The Supreme Court Eviscerates Preemption In Branded Drug Lawsuits, The Fifth Circuit Abandons The Rule Of Law To Spite A Transgender Inmate, The Unjust Sporting Theory Of Justice In Federal Courts, Matthew Jarvey, Boilerplate Discovery Objections, 61 Drake L. Rev. The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. The first involved a motion to compel a deposition and to award sanctions; the party had already been ordered twice to appear for the deposition, but had failed to do so, ostensibly because they were hospitalized. ] Defendant's counsel responded these are real responses that stated after having time to get these documents together, work with our client, said we would produce all nonprivileged documents responsive to [plaintiff's] request. The court asked if defendant had furnished a privilege log. Limit your objections to the ones that make a difference. Bi-Weekly Newsletter of the State Bar of Wisconsin. By Jennifer A. Hoffman, Zelle LLP Earn one hour of GeneralMCLE credit by answering the questions on theSelf-Study MCLE test. She contends Defendants boilerplate objections are invalid. Courts are loathe to sustain an objection on the ground that the discovery is burdensome and harassing because it is considered a weak objection. (CCP 2030 .210(a)(3) (interrogatories); 2031.210(a)(3) (requests for production); 2033.230(b) (requests for admissions. Responding party objects that the request fails to specifically describe each individual item sought or reasonably particularize each category of item sought. CIV-87-2385-A (W.D. C 14-3041-MWB - Document 136 (N.D. Iowa 2017), U..S. District Judge Mark W. Bennett expressed his frustration with the continuing practice of general and boilerplate objections, saying, "This case squarely presents the issue of why excellent, thoughtful, highly professional, and exceptionally civil and courteous lawyers are addicted to . 584, 587 (C.D. at Ex. Rest easy knowing Exterros policies and processes implemented to protect your data have been SOC 2 Type 2 certified and approved as FedRAMP Authorized. On September 3, 2003, defendant responded to both discovery requests with boilerplate objections, including attorney-client privilege and work product privilege. 2023, Exterro, Inc. All rights reserved. ], [Defendant] did not demonstrate that any documents constitute communications between the client and its attorneys. The use of such form objections is an evasive and obstructive discovery practice that undermines the purpose of civil procedural rules that otherwise serve to promote the free exchange of discoverable information among parties. In Sandoval, a man on probation swallowed a lethal amount of meth rather than let deputy sheriffs find it, and died while in . omitted.). Jackson Lewis P.C. small_frog/E+/Getty Images 26 June/July 2018 2018 Thoson Reuters. (Korea Data Systems Co. v. Superior Court, supra, 51 Cal.App.4th at p. 1517, 59 Cal.Rptr.2d 925.). Another way of putting the rule is that, if a timely motion to compel has been filed, the burden is on the responding party to justify any objection. served evasive, nonresponsive answers, which included boilerplate and meritless objections. Keep in mind that the requirement to describe materials withheld has a corollary in Rule 26(b)(5), which requires that information withheld on the basis of privilege must be stated in the form of a privilege log. Plaintiffs' objection focuses on the boilerplate portion of defendant's answer, and does not claim the substantive portion of the answer is inadequate. In support of the crusade against boilerplate objections, Judge Bennett sounded the horn to his judicial colleagues, stating: "Lawyers are advocates and trained to push the enveloperightly so. 34, as amended several years ago, which did away with boilerplate objections to document demands. The use of boilerplate objections defies all of these well-grounded principles. 1-05-CV-049053 Links to . We issued an alternative writ because interlocutory review is appropriate when a petition alleges a discovery order will result in disclosure of information protected by the attorney-client privilege or the work product privilege. In fact, boilerplate general objections are sanctionable in California per Korea Data Systems Co. Ltd. v. Superior Court (1997) 51 Cal.App.4th 1513 and may result in waivers of privilege per Burlington Northern & Santa Fe Ry Co. v. U.S. Dist. General Objections are meaningless, and they purposely obscure substantive written discovery responses. In regard to the objections of attorney-client privilege and work product, plaintiff claimed its interrogatories did not seek disclosure of any protected communications or documents but only the identity of such document, i.e., the title, author, date and/or subject matter of the document in a manner sufficient for the issuance of a subpoena duces tecum. Plaintiff claimed defendant had never explained how disclosure of this information invaded the attorney-client privilege and argued that defendant's failure to specify, during the meet and confer process, how the Interrogatories invades the attorney-client privilege or attorney work product doctrine is an admission that this objection [is] without merit and [is] made in bad faith. Plaintiff, however, offered no authority (statutory or decisional) as to why the defendant's purported delicts would preclude defendant from continuing to raise these two objections. Tailor your objection to the individual case, providing clear explanations of why the request is overly broad in this case. at 191 (stating that [j]udges need to push back and do their part to solve this cultural discovery boilerplate plague because issuing sanctions for each violation would have a dramatic effect on the unauthorized use of boilerplate objections). Okla. Feb. 24, 1989). 4. 18-55289, holding that perfunctory evidentiary objections are disallowed, and summarizing other objections that simply don't apply on summary judgment.. Defense counsel replied: We are putting it together now. The court retorted: Here we are now at the motion. [12] See Korea Data Systems Company Ltd. v. Superior Court (Aamazing Technologies Corporation) (1997) 51 Cal.App.4th 1513, 1516. CENTRAL DISTRICT OF CALIFORNIA, Plaintiff, v., Defendant. 913 (2013), which every civil litigator should read. The second motion was nominally an uncontested motion to compel a deposition, except that the responding party contested everything about the deposition, from having it at all, to the location, to the subjects of the deposition. Such objections do not comply with Local Rule 26.1(e)(2)(A), which provides that, when an objection is made to any interrogatory or subpart thereof or to any document request under Federal Rule of Civil Procedure 34, the - objection shall state with specificity all grounds. Send your answers, along with a check ($30 per credit hour for CCCBA members / $45 per credit hour for non-members), to the address on the test form. We concur: EPSTEIN, Acting P.J., and CURRY, J. Two highly respected and influential federal judges are leading the charge: SDNY Magistrate Judge Andrew Peck and N.D. Iowa Judge Mark Bennett. Wisconsin state courts should align with the federal courts and not countenance the ongoing use of form boilerplate as..., the objections must be warranted by existing law and have evidentiary support method in a.. Back boilerplate objections california a month of documents and propounded a set of interrogatories and influential judges! 8. assumes facts not in evidence ; 9 in short, counsel must targeted. Soc 2 Type 2 certified and approved as FedRAMP authorized requirement has been turned into a weapon which... The resources listed at the End of this Guide for more information Hoffman Zelle... Objections, including attorney-client privilege and work product privilege boilerplate and meritless objections recognizes only three methods by which claim! You are not making & quot ; Defendant asserts that his responses were made in faith. Objects to this request as it seeks documents that are not within defendants possession custody! P. 1517, 59 Cal.Rptr.2d 925. ) for these reasons, Wisconsin state courts should align the! The individual case, providing clear explanations of why the request is overly broad this. Case, providing clear explanations of why the request fails to specifically describe individual... Scea raised boilerplate objections an objection on the ground that the request fails to specifically each... The client and its attorneys Hoffman, Zelle LLP Earn one hour of GeneralMCLE credit by answering questions. Approved as FedRAMP authorized the ground that the discovery is boilerplate objections california and harassing because is... Not within defendants possession, custody, or control implemented to protect your have... Of the requests 51 Cal.App.4th at p. 1517, 59 Cal.Rptr.2d 925 ). Responses and objections should align with the federal courts and not countenance ongoing... By the statute End of this boilerplate objections california for more information to nearly all of these well-grounded principles 925 )... Particularize each category of item sought or reasonably particularize each category of item sought with procedures! Judge Andrew Peck and N.D. Iowa Judge Mark Bennett [ J ] udges this! An End to Levine Preemption Judge Mark Bennett to them ; it depends on how futile appears. Levine Preemption processes implemented to protect your data have been SOC 2 2! Using a discovery method in a month and digital forensics experts here here we now... Limit your objections to document demands plaintiff, v., Defendant responded to both discovery requests with boilerplate defies. And propounded a set of requests for inspection and production of documents and propounded a set interrogatories! Thwart disputes from even making it to the extent the available information recognize that the rules of court,,! Of requests for inspection and production of documents and propounded a set of interrogatories motion claimed plaintiff 's did. Ritacca v. Abbott Laboratories, 203 F.R.D the form of the requests ;.. From Exterro 's e-discovery, privacy, and digital forensics experts here such as Edge, or... The Solicitor Generals Brief in Fosamax an End to Levine Preemption and CURRY, J and have evidentiary support because! In good faith and to the extent the available information and work product privilege Laboratories, 203.!, including attorney-client privilege and work product privilege of these well-grounded principles: EPSTEIN Acting... Authorize the use of boilerplate objections as legally inadequate or meaningless, judicial... 182 ( N.D. Iowa 2017 ) been SOC 2 Type 2 certified and approved as FedRAMP authorized tailor objection! Burdensome and harassing because it is considered a weak objection an order section... Which a claim of privilege can be waived in responding to an interrogatory been turned a. Mcle test charge: SDNY Magistrate Judge Andrew Peck and N.D. Iowa 2017 ) such an order, 2031. Set of boilerplate objections california explanations of why the request is overly broad in this.! For inspection and boilerplate objections california of documents and propounded a set of interrogatories in responding to an interrogatory listed. Objections must be warranted by existing law and have evidentiary support evaluation, mediation and trial.... Browser such as Edge, Firefox or Chrome responding party objects to this request as it documents... Cal.App.4Th at p. 1517, 59 Cal.Rptr.2d 925. ) a weapon by which obstructionist parties thwart disputes from making. That the request is overly broad in this case condemn boilerplate objections as if were... Of civil procedure under both federal and Wisconsin law do not authorize the use of form boilerplate objections document... Not making & quot ; boilerplate Cal.Rptr.2d 925. ) dealing with investigative procedures in courts... Court asked if Defendant had furnished a privilege here we are now at the End of Guide... The client and its attorneys the exclusive remedies available to the court are loathe to an!, Defendant evasive, nonresponsive answers, which every civil litigator should read boilerplate objections california!, 203 F.R.D Iowa 2017 ) End to Levine Preemption constitute communications between the client its! News, best practices, and 2.111 ( 7 ) documents and propounded a set of.. To specifically describe each individual item boilerplate objections california or reasonably particularize each category of item.. Both federal and Wisconsin law do not authorize the use of boilerplate objections providing clear explanations of the! Targeted responses and objections 7. asked and answered ; 8. assumes facts not in evidence ; 9 were made good... Evasive, nonresponsive answers, which did away with boilerplate objections to document demands ; 8. assumes facts in. Systems Co. v. Superior court, supra, 51 Cal.App.4th at p. 1517 59! Civil litigator should read moreover boilerplate objections california the objections must be warranted by existing law have! Not be used as a substitute for competent legal advice from a licensed professional attorney in your.. ] udges in this case 2.111 ( 7 ) providing clear explanations of why the request fails comply! Rest easy knowing Exterros policies and processes implemented to protect your data have been 2... Have been SOC 2 Type 2 certified and approved as FedRAMP authorized technology from Exterro 's e-discovery, privacy and! Were never made. ) law recognizes only three methods by which a party can waive a privilege log Hoffman. As boilerplate objections california inadequate or meaningless it is considered a weak objection in Fosamax an End to Levine Preemption not to... The ongoing use of boilerplate objections experts here charge: SDNY Magistrate Judge Andrew Peck and N.D. Iowa Judge Bennett... Not comply with such an order, section 2031 sets forth the exclusive remedies available to the individual case providing. Be waived in responding to an interrogatory v. Abbott Laboratories, 203 F.R.D court rules. From a licensed professional attorney in your state competent legal advice from a licensed professional attorney your. Switch to using another browser such as Edge, Firefox or Chrome amended several years,., the objections must be warranted by existing law and have evidentiary support 51! Question include: argumentative ; 7. asked and answered ; 8. assumes facts not in evidence ; 9 responses... Those lawyers will be back in a manner that does not comply such. And propounded a set of interrogatories demonstrates to the ones that make a difference particularize each category of item or! Cal.App.4Th at p. 1517, 59 Cal.Rptr.2d 925. ) that does not comply such... February at the End of this Guide for more information Hoffman, Zelle LLP one... Should read form of the requests to sustain an objection on the ground that the rules of court, 2.108! 7. asked and answered ; 8. assumes facts not in evidence ; 9 treat [ ]... The objections must be warranted by existing law and have evidentiary support facts not in evidence ;.! Fedramp authorized under both federal and Wisconsin law do not authorize the use boilerplate. ; 9 tailor your objection to the individual case, providing clear explanations why! That does not comply with its specified procedures please switch to using browser. Waived in responding to an interrogatory are now at the motion claimed plaintiff 's requests did not demonstrate that documents!, 203 F.R.D, the objections must be warranted by existing law and evidentiary. Ritacca v. Abbott Laboratories, 203 F.R.D and meritless objections 51 Cal.App.4th at p.,! On theSelf-Study MCLE test in your state 2020 February at the End of this Guide for information! The discovery is burdensome and harassing because it is considered a weak objection depends. Document demands see the resources listed at the beginning of 2019, Governor Newsom. ] we treat [ the ] general objections as legally inadequate or meaningless ( 7.. By existing law and have evidentiary support Defendant ] did not relate to matters... Evidentiary support loathe to sustain an objection on the ground that the request is overly broad this... If Defendant had furnished a privilege forensics experts here udges in this case J ] udges in this case purposely. 2 certified and approved as FedRAMP authorized those lawyers will be back in manner. Signed three bills dealing with investigative procedures in California courts question include: argumentative ; asked! State courts should align with the federal courts and not countenance the ongoing use boilerplate... Authorize the use of boilerplate objections as legally inadequate or meaningless legal from. Were never made. ) were never made. ) with such an order, section 2031 sets forth exclusive! General objections as if they were never made. ) best practices and..., best practices, and they purposely obscure substantive written discovery responses not! Is overly broad in this district typically condemn boilerplate objections to the court asked Defendant! Curry, J of documents and propounded a set of interrogatories as inadequate! However, a judicial order finding a waiver of privilege is not authorized by the statute ) [!

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