AFSCME Local 2401 Files Complaint Against the District Government Challenging District’s “Realignment” and Reduction in Force on Constititional, State Law and Other Grounds

The following is Civil Action-09-cv-1804 before Judge Henry H. Kennedy. This is a cut and paste version of the original word   document.

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

American Federation of State, County,

And Municipal Employees Local 2401


Plaintiff

v.

District of Columbia


Defendant.

AMENDED COMPLAINT

COMES NOW PLAINTIFF, American Federation of State, Municipal and County Employees (“AFSCME Local 2401) on behalf of its members, by and through undersigned counsel, and respectfully files this Complaint for damages as well as injunctive and declaratory relief.  Plaintiff’s claims are based upon an illegal, discriminatory reduction in force and termination of said Union Members in violation of their due process rights, their rights to be free from unlawful discrimination under the 5th amendment of the United States Constitution and in violation of applicable District of Columbia law.

JURISDICTION AND VENUE

  1. Jurisdiction of the Court is invoked pursuant to 28 U.S.C. §1331 in that this action arises under the Constitution of these United States; 28 U.S.C. §1343 in that this action is brought to redress deprivations of rights, privileges and immunities secured by the United States Constitution; under 28 U.S.C. §1343(a)(4), in that it seeks to secure equitable relief under an Act of Congress, specifically 42 U.S.C. §§1981 and 1983, which provide causes of action for the protection of civil rights; under §301(a) of the Labor Management Relations Act of 1947, 61 Stat. 156, 29 U.S.C. s 185(a) in that causes of action requiring interpretation of the collective bargaining agreement may be brought in federal court; under 28 U.S.C. §2201(a) in that one purpose of this action is to secure permanent injunctive relief.
  2. Venue is proper under 28 U.S.C. §1391(b) in that, during the time of the incidents complained of herein, Plaintiff AFSCME Local 2401 and Defendant were situated in or resided within the District of Columbia; under the 5th Amendment to the United States Constitution, and because all of the claims asserted by Plaintiff arose within the jurisdiction of the District of Columbia.

PARTIES

  1. Plaintiff AFSCME, Local 2401 (“Local”) is the duly recognized labor organization designated to represent employees in the Department of Health Care Finance (“DHCF”) in the District of Columbia for the purposes of collective bargaining, as set forth in the Master Agreement between AFSCME, District Council 20, AFL-CIO and the Government of the District of Columbia, effective through Fiscal Year 2010 (“CBA”).  All Union Members enjoy a contractual relationship either as employees of the District and/or as third party beneficiaries of their collective bargaining agreement (“CBA”).
  2. Defendant District of Columbia (“District”) is a municipality that controls and operates DHCF.  DHCF “transitioned” out of the Department of Health (“DOH”) and was created on October 1, 2008, as an “entity that would improve health outcomes by providing access to comprehensive, cost-effective, and quality healthcare services for the residents of the District of Columbia.”  The immediate RIF is made pursuant to a purported “realignment.” [1]
  3. Plaintiff has standing to bring this suit and hereby seek to enjoin Defendant from completing adverse and unlawful actions under the pretext of a “realignment.”
  4. Plaintiff can show that a concrete, particularized injury in fact has occurred and that the injury is not conjectural or hypothetical, but actual.
  5. Plaintiff can show that the injury suffered is directly related to the District’s illegal and unconstitutional acts.
  6. Plaintiff can show that the injury suffered is directly related to the Defendant’s conduct, which violated relevant laws and regulations of the District of Columbia.
  7. Plaintiff’s members are not bound by the grievance-arbitration provisions set forth in Article 22 of the CBA because the prescribed administrative remedy is plainly inadequate.  The timelines for the grievance process extend far beyond the September 30, 2009 termination date imposed by Defendant.  Exhaustion through these processes would so unreasonably delay the protection of Union members’ rights so as to create a serious risk of irreparable injury.
  8. Plaintiff’s members are not bound by the grievance-arbitration provisions set forth in Article 22 because the Office of Employee Appeals cannot provide an adequate remedy commensurate with the claims of unconstitutional behavior and violations of U.S.C. 42 §§ 1981 and 1983 set forth in this complaint.  Article 22, § 10 of the CBA states that “Matters not within the jurisdiction of the department/agency will not be processed as a grievance under this Article unless the matter is specifically included in another provision of this Agreement or the Compensation Agreement.”

FACTS COMMON TO ALL COUNTS

  1. The allegations set forth in paragraphs 1-10 are incorporated by reference as if fully set forth herein.
  2. Of approximately 78 Union members affected by the RIF, approximately 68 are African-American and nine (9) are Caucasian.  These 68 employees are members of a protected class for purpose of the Plaintiff’s claim of discrimination.
  3. Upon information and belief, Defendant developed a plan to “realign” the Agency, which included abolishing jobs, redefining jobs, creating new  positions, reducing the total number of positions, rehiring and otherwise filing supposed vacancies in the newly realigned agency.  Said realignment in effect constitutes an unauthorized and illegal reorganization.   According to D.C. law, a Realignment is an action which affects the internal structure and/or functions of an agency, but which does not constitute a “Reorganization.” (Emphasis added).  A Reorganization is an action which results in the transfer of, consolidation of, abolition of, or authorization with respect to functions and hierarchy, between or among agencies, and which affects the structure or structures thereof; which reorganization is subject to adoption by legislative action, including consideration of the District of Columbia Council in accordance with the Governmental Reorganization Act of 1981.
  4. Further, the so called “realignment” and corresponding RIF excluded approximately 13-15 newly hired Caucasian employees from the RIF process and thus from being required to reapply for employment. Approximately, 40% of these individuals are under age 40.  Approximately 90% of the terminated Union members are over age 40.
  5. The purported realignment plan has never been provided to, nor discussed with, Plaintiff Union in specific detail.  Rather, there were informal communications with the Union in which DCFS officials stated that only 7-13 persons would experience a reduction in force.
  6. On or about August 18, 2009, Natasha Campbell, Chief, Labor Relations contacted Sabrina Brown, President of AFSMCE 2401, and informed her that due to an upcoming “reorganization”, approximately thirteen (13) employees would be subjected to a planned reduction in force (RIF), with the possible termination of more employees if they could not qualify for the new positions created as a result of the reorganization.
  7. On August 27, 2009, Local 2401 sent a request for information consisting of ten (10) questions to Defendant’s Office of Labor Relations & Collective Bargaining.
  8. Four (4) days later, by letter dated August 31, 2009, Defendant issued RIF notices to approximately seventy-eight (78) employees (Plaintiff’s Union Members). Sixty-eight (68) of these employees were African-American.  The letter “[Served] as official notice of at least thirty (30) calendar days that you will be separated from District government service effective September 30, 2009.” (emphasis in the original).
  9. Pursuant to the termination of employment, Union members will lose all benefits including health benefits and coverage within 31 days following September 30, 2009.  Said benefits in some cases cover other family members.
  10. Loss medical benefits will cause significant health risks to these members and their families in view of their declining and poor health.  Certain members have diabetes, heart disease, high blood pressures, cancers and other serious illnesses.
  11. On September 11, 2009, Defendant responded to Plaintiff’s request for information. According to Defendant: “The agency eliminated 11 positions as a result of the FY 2009/2010 budget pressures.  [DHCF] saved $458,033 in local funds and $524,984 in federal funds as a result…The total savings of $983,017 represents 0.0474% of the agency’s overall budget.”[2] DHCF saved less than one-half of 1% by eliminating a number of FTEs.  Hence, the reorganization and associated RIF was admittedly not necessitated by budget considerations.
  12. That the “realignment” and associated RIF is not budget-driven is further evidenced by DHCF’s proposed FY 2010 budget which represents a 13.1% increase over the FY 2009 budget.
  13. Based upon information and belief, Defendant’s purported “realignment”   circumvented applicable procedural scrutiny, constituted a framework pretext for an illegal RIF and the wrongful taking of Union members’ jobs.
  14. Through the purported realignment, DHCF effectively converted existing jobs to new jobs with new job descriptions.  In most cases, however, the fundamental job duties were not changed.
  15. Numerous “Public Health Analysts” positions were abolished.  The Public Health Analyst in the existing Office of Program Integrity, Medical Assistance Administration (MAA), is responsible for policy development and preventing and detecting fraud.  The employee assists with the selection, planning, review and evaluation of health care payment records reflecting medical service providers provided by Medical Assistance program providers; conducts onsite audits of provider medical service records; compiles, evaluates and documents results of audits and prepares final audit records with appropriate remedial actions with federal and MAA policies, rules and regulations and the District State Medicaid Plan.
  16. As part of its purported “realignment”, Defendant abolished this MAA position in one instance and created the position of “Utilization Review Specialist” which required one year of specialized experience.  The so called “new” job similarly implements and evaluates health care utilization review, utilization control activities intended to ensure proper payment procedures and to detect abuse, conducts and reviews audits of independent providers to identify incorrect utilization and billing practices, conducts utilization review of Medicaid claims data, and prepares audit criteria and performs audit activities.
  1. There is no meaningful difference between these two positions. In most instances, the new jobs and job descriptions that Defendant created substantially include work functions described in the job description of abolished positions.  See Attachment.
  2. Examples of the same deceptive new job creation practice described in paragraphs 23-25 are evident throughout Defendant’s purported “realignment” and new position postings and descriptions.
  3. Defendant also created certain new jobs in a manner that rendered terminated Union Plaintiffs unqualified to compete for these jobs.
  4. According to D.C. Personal Manual, Section 1106.4:  “When the D.C. Office of Personnel finds that a position, group, or class of positions is not placed in the proper class and grade, in conformance with published standards, or that a position, group, or class of positions for which there are no published standards is not placed in the class and grade consistent with published standards, it shall, after consultation with appropriate officials of the agency concerned, place the position, group or class or positions in the appropriate class, grade and shall certify this action to the agency.
  5. Defendant, apparently with the participation of its Office of Human Resources, created illusory new jobs by changing job titles and modifying job descriptions but not in actuality abolishing the jobs.  Its ultimate end was the elimination of Plaintiff Union members’ jobs.
  6. To the extent that the “new” jobs executed the same functions as the old jobs, the realignment is a pretext for converting terminated Union members’ jobs under the guise of a realignment.
  7. Absent objective desk audits prior to the realignment and the involvement of the Office of Personnel, consistent with published standards, there was no practical and necessary justification for DHCF to develop new positions and job descriptions, particularly since Defendant expected to fill these new positions with persons other than existing employees.
  8. As a result of Defendant’s newly developed and revised job descriptions, many well-educated, highly experienced senior employees will be barred from applying for the new jobs and/or terminated, despite that the stated responsibilities in the new jobs mirror those in the old jobs.
  9. Upon information and belief, several new position descriptions were also reclassified at a higher pay grade, which further precluded Plaintiff’s Union Members from applying for the new jobs.
  10. Upon information and belief, the realignment created a group of “untouchable” new similarly-situated Caucasian employees hired within the one (1) year immediately preceding the Reduction in Force (“RIF”).  Of these employees, approximately 13-15 are similarly situated to the affected Union members.  Despite applicable laws governing RIFs, these similarly situated Caucasian employees were illegally exempted from the reduction in force.
  11. Exemption of said Caucasian employees from the RIF means that 13-15 Union members have higher preferences and seniority than these individuals and should thus be treated more favorably.  Further, because the affected Union pool is predominantly African-American, the different treatment will dilute African-Americans’ chances of being rehired.
  12. At least one affected Union member (non-African American) has complained about disability discrimination and believes that he may have been targeted as a result of said complaints.  That complainant fears that he will be excluded from the rehiring process in retaliation for his complaints.
  13. At all times referenced herein, Defendant’s efforts to implement the reduction in force were governed by the District of Columbia Personnel Regulations as set forth in Chapter 24, Part 1.  These regulations required that all employees assigned a RIF-date based on points awarded for residential, seniority and veteran preferences and placed on a retention list. Had the Caucasian untouchables been made subject to the RIF, most if not all of them, would have loss their jobs prior to the affected Plaintiff Union members.
  14. Upon information, and belief, Defendant’s actions also eliminated a critical unit in DHCF, which is subject to a court order still in effect issued by Judge Gladys Kessler dated November 14, 2004 in Oscar Salazar v. District of Columbia, Civil Action 93-452.    The Early Screening, Diagnosis and Treatment program (EPSDT) of D.C.’s Department of Health Medical Assistance (MAA) is administered by DCHF, formerly the Medical Assistance Administration in the Office of the Deputy Director, the office of Managed Care and the Office of Children and Families.
  15. According to Judge Kessler, this program, the well-child program of health checks, anticipatory guidance, diagnosis and treatment is one of the major programs under Title XIX of the Social Security Act of 1936 (as amended). In the MAA, all departments enjoyed a responsibility for EPSDT whether direct or indirect.   The Office then with the primary responsibility for EPSDT is the Office of Children and Families.   Defendant has failed to explain to the Union and to the public, nonetheless the court, how it will comply with the existing court order given its abolishment of the unit assigned to compliance therewith.
  16. Defendant’s purported realignment constitutes a pretext for its illegal termination and reduction in force of affected Union members.
  17. Moreover, said realignment is in effect an unauthorized reorganization, which requires appropriate consideration and approval by the District of Columbia City Council.
  18. Defendant’s action were calculated, deliberate, ill-willed and malicious, and designed to intentionally cause the loss of seventy eight union jobs, knowing that mostly African-Americans would lose their jobs and newly hired Caucasians would keep their new jobs.
  19. Defendant acted under color of law at all time referenced herein.

COUNT 1

Violation of 42 USC §1983

PROCEDURAL DUE PROCESS

(AFSCME AND UNION MEMBERS)

  1. Paragraphs 1 through 45 are reincorporated by reference as if fully set forth herein.
  2. Defendant’s so-called realignment is a pretext.  On one hand it abolished longstanding government jobs in order to enhance efficiency. On the other hand, it recreated the same jobs to give to other than the terminated employees.   It is akin to calling a plumber a pipe fitter and instead of fixing pipes and stopping leaks, describes his job as pipe connecting and controlling unregulated water flow.
  3. The District’s action’s here were terribly deceitful and disingenuous, not attributed to budget reasons, and brutally insensitive to its employee’s rights.  Most glaring is that the District gave more protection and credit to new employees with less than one year of public service than it did to employees with 20-30 years of public service.
  4. Defendant excluded newly hired employees from the termination process and thus diluted the rights of all affected Union members in the RIF process.
  5. The District’s favorable advantage to the excluded group negatively affected Union members, including but not limited to the fact that its favoritism resulted in inaccurate and improper competitive areas, competitive levels, and retention register and tenure groups (which should have included all employees). See District of Columbia Personnel Regulations Chapter 24, Part 1, sections 2412 – 2420.
  6. Plaintiff Union Members enjoy a property interest in continued employment, subject to an appropriate process for the removal and elimination of said jobs. The only way that Defendant could have abolished Union members’ jobs was through a RIF. Hence, it created a purported “realignment” to justify that end.  Defendant’s illegal termination of AFSCME employees violated their procedural and substantive due process rights.
  7. As a direct and proximate result of Defendant’s actions in violation of 42 U.S.C. §1983, Union members were harmed and continue to suffer harm due to a violation of their Fifth Amendment due process rights.  Plaintiff’s members suffered and continue to suffer mental anguish, humiliation, embarrassment, loss of compensation, loss of essential benefits, risks of loss of homes and residences, and other harm which amounts to imminent, actual and irreparable harm.

WHEREFORE, Plaintiff respectfully requests that this court 1) compensate its members for the violation of their rights in amount in excess of $5,000,000, to be more particularly determined at trial; (2) declare the District’s actions described herein to be a violation of the District’s Reduction in Force Regulations and constitutional due process rights; (3) immediately enjoin and restrain the District from implementing its September 30, 2009 Reduction in Force; (4) require the District to pay appropriate attorneys fees; and (5) render any other relief that this court deems appropriate.

COUNT II

Violation of 42 USC §1981 AND the Fifth

Amendment OF THE u.s. cONSTITUTION

(AFSCME AND UNION MEMBERS)

  1. Paragraphs 1 through 52 are reincorporated by reference as if fully set forth herein.
  2. Plaintiff Union members enjoy the benefit of duly accepted employment with Defendant by virtue of an offer and acceptance of terms of employment and further as third party beneficiaries of the Union’s collective bargaining agreement.
  3. Plaintiff’s members are entitled to enjoy the benefits of the contract with Defendant, and the property right based therein, without impairment of that enjoyment based upon racially motivated reasons.
  4. In developing a racially biased pretextual “realignment” plan, Defendant acted pursuant to a formally adopted policy executed by the Mayor and the head of DHCF to “realign” and/or reorganized DHCF.  It thus eliminated the jobs of African-American Union members while preserving and protecting the jobs of similarly situated Caucasians.
  5. Defendant District particularly denied Plaintiff’s members the enjoyment of their benefit in the contract through discriminatory treatment when the Executive Branch deliberately acted under the pretext of a so called realignment to terminate these members on impermissible discriminatory bases.
  6. In so doing, Defendant, through its officials, violated and will continue to violate Plaintiff’s Union Members’ rights to equal protection of the law.
  7. As a direct and proximate result of the District’s unauthorized and improper actions and taking, Plaintiff’s members suffered imminent and actual harm including, but not limited to, violation of their equal protection rights and right to contract without racially motivated impairment, all which constitute irreparable harm to affected employees.

WHEREFORE, Plaintiff respectfully requests that this court 1) compensate its members for the violation of their rights in amount in excess of $5,000,000, to be more particularly determined at trial; (2) declare the District’s actions described herein to be a violation of the District’s Reduction in Force Regulations, Plaintiff’s members’ equal protection rights and their right to contract without racially biased impairment of their right to make and enforce a contract and to enjoy the benefit thereof; (3) immediately enjoin and restrain the District from implementing its September 30, 2009 Reduction in Force; (4) require the District to pay appropriate attorneys fees; and (5) render any other relief that this court deems appropriate.

COUNT III

Violation of 42 USC §1983 DISPARATE TREATMENT

(AFSCME AND UNION MEMBERS)

  1. Paragraphs 1 through 59 are reincorporated by reference as if fully set forth herein.
  2. Defendant acted in violation of the 5th Amendment of the U.S. Constitution when the Mayor and agency head formally adopted and executed certain policies and customs designed to “realign” the Agency.
  3. Certain officials within the District government, through their deliberate actions subjected the Union’s African-American membership to disparate treatment in several respects including but not limited to its devaluing their skills, experience and competencies in filing purportedly new Agency positions, while valuing similarly situated, new white employees’ skills, knowledge and experience, and excluding the latter group from the RIF.
  4. Plaintiff’s Union Members are members of a protected group, African Americans, who, as qualified and incumbent employees, were vested with property interests in their employment.
  5. Plaintiff’s Union Members were subject to Defendant’s RIF policies and were terminated effective September 30, 2009 by virtue of this realignment and subsequent reduction-in-force while a group of approximately 13-15 similarly-situated Caucasian employees were not subject to Defendant’s RIF polices and were not terminated.
  6. Based on the disparate treatment described herein, the District through its decision makers engaged in illegal discrimination in such a way as to selectively terminate approximately 68 African-American employees.
  7. Said discrimination is further realized in the reclassification of jobs and grade levels that effectively disqualified incumbent African-American employees from consideration for the new positions.
  8. As a direct and proximate result of Defendant’s actions, Plaintiff’s members were harmed and continue to suffer harm. Plaintiff’s members suffered and continue to suffer mental anguish, humiliation, embarrassment, loss of compensation, loss of essential benefits, risks of loss of homes and residences, and other harm which amounts to imminent, actual and irreparable harm.

WHEREFORE, Plaintiff respectfully requests that this court (1) compensate its members for the violation of their rights in amount in excess of $5,000,000, to be more particularly determined at trial; (2) declare the District’s actions described herein to be a violation of the District’s Reduction in Force Regulations; (3) immediately enjoin and restrain the District from implementing its September 30, 2009 Reduction in Force; (4) require the District to pay appropriate attorneys fees; and (5) render any other relief that this court deems appropriate.

COUNT IV

Violation of DISTRICT’s PERSONNEL REGULATIONS

ILLEGAL ReORGANIZATION AND/OR ILLEGAL REductions in force

(AFSCME AND UNION MEMBERS)

  1. Paragraphs 1 through 67 are reincorporated by reference as if fully set forth herein.
  2. Defendant violated District of Columbia law when it strategically and deliberately abolished 78 Union jobs without any legal authority.  Said purported realignment was nothing more than a pretext to justify a reduction in force.
  3. In most cases when there is a reduction in force, there is a corresponding decrease in the number of positions as evidenced by the Agency’s budget for the successive fiscal year.
  4. Defendant also violated RIF regulations when it excluded newly hired employees (“untouchables”) from the RIF process thereby failing to properly compile the requisite competitive Levels, retention register and retention standings, and intentionally ignoring affected Union members’ length of service, performance ratings, veterans’ preference and residency preferences for Plaintiffs as incumbent employees within DHCF.  See District of Columbia Personnel Regulations Chapter 24, Part 1, sections 2412 – 2420.
  5. To the extent that the RIF is valid, all non-management employees should have been included in the RIF and treated similarly. There was no basis upon which to give preferential treatment to newly hired employees.
  6. The similarly situated, recently hired employees with far less experience were not included in the competitive groupings, not included on the retention register, and not terminated.
  7. The District’s purported realignment is nothing more than an illusion intentionally designed to eliminate Union jobs through an illegal reduction in force.
  8. As a direct and proximate result of Defendant’s actions, Plaintiff’s members   were harmed and continue to suffer harm including, but not limited to, mental anguish, humiliation, embarrassment, loss of compensation, loss of essential benefits, risks of loss of homes and residences, and other harm which amounts to imminent, actual and irreparable harm.

WHEREFORE, Plaintiff respectfully requests that this court 1) compensate its members for the violation of their rights in amount in excess of $5,000,000, to be more particularly determined at trial; (2) declare the District’s actions described herein to be a violation of the District’s Reduction in Force Regulations; (3) immediately enjoin and restrain the District from implementing its September 30, 2009 Reduction in Force; (4) require the District to pay appropriate attorneys fees; and (5) render any other relief that this court deems appropriate.

COUNT V

Wrongful Termination in Violation of Public Policy

  1. Paragraphs 1 through 75 are reincorporated by reference as if fully set forth herein.
  2. In the District of Columbia, wrongful termination in violation of a clear
    public policy is an exception to the traditional at-will employment doctrine.
  3. Defendant’s action contravenes existing federal and state law and the clear mandate of public policy.  In addition to the above cited state law, federal law prohibits Defendant from dispossessing employees of their rights in a vested property interest, namely their employment, in a manner that is racially biased, arbitrary, capricious, void of due process and equal protection.
  4. As a direct and proximate result of said breach, Plaintiff’s members suffered imminent and actual harm, including but not limited to the loss of member jobs.

WHEREFORE, Plaintiff respectfully requests that this court 1) compensate its members for the violation of their rights in amount in excess of $5,000,000, to be more particularly determined at trial; (2) declare the District’s actions described herein to be a violation of the District’s Reduction in Force Regulations; (3) immediately enjoin Defendant District Government and Mayor Fenty from effectuating DCHF RIF notices and the August 31, 2009 Reduction in Force effective September 30, 2009 and further refrain from any official decision that discriminate against Plaintiff’s members on the basis of their race; (4) require the District to pay appropriate attorneys fees; and (5) render any other relief that this court deems appropriate.

Respectfully submitted,

__________________

Donald M. Temple #408749

1229 15th Street, NW

Washington, DC 20005

Tel: (202) 628-1101

Fax: (202) 628-1149

dtemplelaw@gmail.com

Attorney for Plaintiffs

JURY TRIAL DEMANDED


[1] Letter dated August 31, 2009 from Julie Hudman, Director, DHCF to DHCF employees subject to the RIF.

[2] Letter dated September 11, 2009 from Nina McIntosh, Esq., Special Assistant, Office of Labor Relations & Collective Bargaining to Sabrina Brown, President, AFSCME Local 2401 re “DHCF Responses to Request for Information.”

  1. January 27, 2011 at 12:27 am | #1

    Question? What rights does a District of Columbia Bargaining Unit Employee have as for violations of Priority Placement, especially if it concers violtions of his veterans preference in both a promotion and later reduction in force. EEOC does not have jurisdiction and the Merit Systems Protection Board does not have jurisdiction as well. It is not an appealable subject under the provisions of OEA and not an ULP under PERB. All I could find is one must go directly to the US District Court? IS THIS CORRECT OR ARE THERE OTHER AVENUES. I am a recently rifed District employee and attempting to find the right answer. that is all I want. Thanks Earnest Durant former with the Department of Corrections and a 10 point disabled veteran.

  1. September 29, 2009 at 2:41 pm | #1

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