The Lion's Roar

Tom Kline, the famed Philadelphia lawyer who has battled giant corporations and powerful public institutions for multi-million-dollar verdicts through four decades of courtroom wars, still sees the face of an adversary who tormented him in the 1960s.

He was a fraternity member, but he was meaner than the others — scaring the pledges with his reputation for paddling during initiation rites.

“I decided that I would grin and bear it, until I was hit very hard multiple times by one brother,” said Kline, reflecting on his days at Albright College in Reading, Pennsylvania.

“I tried to avoid medical treatment, but when I had swelling and welts, as well as other symptoms, I ended up in the infirmary,” he said, adding that he soon quit Alpha Phi Omega. “I thought many times over many years that I could’ve ended up a paraplegic.”

Kline’s not one to dwell on personal tragedies, and he downplayed the incident in a recent interview, calling it “inconsequential.”

But in many ways, Kline’s personal trauma is not inconsequential to scores of fraternity men who have been subjected to far worse physical and mental torture over the past year.

And it’s certainly not inconsequential to Jim and Evelyn Piazza, who have hired Kline and become nationally recognized anti-hazing advocates after losing their son to an alcohol-fueled pledge ceremony at Penn State’s Beta Theta Pi house in February 2017.

Fraternity brothers waited 12 hours to call for medical help after 19-year-old sophomore Timothy Piazza tumbled “hair-first” down a basement staircase. In the interim, Piazza continued to fall drunkenly into the front door, iron railings and hardwood flooring, all the while suffering from a fractured skull and lacerated spleen.

“Jim Piazza wanted to know if I was all in,” Kline said. “I told him I was.”

The 70-year-old Kline has taken on some of the biggest Pennsylvania cases during the past decade – the Piazza tragedy, the horrors inflicted by Jerry Sandusky in another Penn State scandal, and the Amtrak derailment in Philadelphia in 2015, in which eight people died.

He is the namesake of the Drexel University Thomas R. Kline School of Law in Philadelphia, thanks to his $50 million gift. In Pittsburgh, there is the Thomas R. Kline Center for Judicial Education at Duquesne University, his alma mater, to which he gave $7.5 million.

To Dan Ryan, a prominent medical negligence defense attorney in Philadelphia, Kline is “the consummate advocate.”

“I know that when I’m dealing with him, I’m dealing with someone who is totally honest and scrupulously ethical,” Ryan said. “He is as fine an adversary as anyone I’ve seen in my career.”

To the Piazzas, Kline is more than their lawyer. He is their crusader, poised to take on Penn State and revamp what Kline calls the “public health hazard” of Greek life.

American colleges and universities across the country are grappling with rampant fraternity hazing violations. Since September, pledges have died at fraternity functions at Louisiana State, Florida State and Texas State.

Kline first faced off against Pennsylvania’s flagship university when he represented “Victim 5” in the earlier Sandusky scandal. The former Penn State assistant football coach, convicted of sexually abusing 10 boys, was sentenced to 30 to 60 years in prison. Three top administrators, including the university president, were also convicted of child endangerment for failing to report Sandusky to authorities. Speculation as to what revered head coach Joe Paterno knew continues to divide the university community six years after his death.

Kline said as he negotiated to secure the first settlement, he saw firsthand the inner workings of Penn State – the “internecine factions that exist on the Board of Trustees.” In 2013, Kline called himself a “constructive adversary,” seeking to hold the university accountable for faulty reporting protocols.

Five years later, with the Piazza case, Kline is embroiled in yet another monumental Penn State shakeup. But he said he’s not interested in destroying a university that seeks to educate nearly 100,000 students. As a lifetime Pennsylvanian, he said, “I’ve always had an interest ultimately in seeing Penn State succeed and not be defeated.”

“Finding fault does not equate with dragging a person or an institution down,” Kline said.

***

In June, four months after Timothy Piazza died, the Penn State Board of Trustees voted to strip fraternities and sororities of their self-regulating power, turning over disciplinary action to university administrators.

Kline said he was less than impressed.

As Kline saw it, the Greek-life reforms – encompassing more stringent underage drinking and impromptu spot checks of fraternity houses – were “aspirational, not concrete.”  He and the Piazzas have been pushing for stronger anti-hazing legislation at the state level.

Kline said he forges strong “affinities,” even close friendships, with many of his clients. He and the Piazzas have wept together, he said, as evidence continues to surface from the night of Feb. 2, 2017.

“He just has a presence about him – his stature, his confidence,” Evelyn Piazza said. “I just felt like he was going to protect us and protect Tim.”

When the Piazzas were searching for an attorney, every recommendation circled back to Kline, who became involved in the Timothy J. Piazza Memorial Foundation and attended a charity dinner to learn about their son.

“I just felt like he was sent to us for a reason,” Jim Piazza said. “He has been tremendous.”

Kline is at their disposal 24 hours a day, seven days a week, the Piazzas said.

“With the Piazza case, when you have this callous and outrageous behavior and system that is so clearly broken, that’s something that invigorates Tom,” said Dominic Guerrini, a partner at Kline & Specter. “The cases are like the fire, and he is the moth being drawn to the fire.”

Jim and Evelyn Piazza have until Feb. 4, 2019, two years after their son’s death, to file a civil lawsuit.

Kline said he is already envisioning his opening statement: “This senseless, needless tragedy would not have occurred but for the collective institutional and individual failures about which you are about to hear.”

***

Before becoming a storied plaintiff’s attorney with homes in Philadelphia, in New York City and at the Jersey shore, Kline grew up in the coal-mining town of Hazleton, Pennsylvania.

As a 10-year-old, he would often accompany his father to work at the Rival Dress Co., a nondescript brown brick building that still blends into a neighborhood reminiscent of the 1950s. A few miles away, along the main drag, now sit big-box retailers, chain restaurants and a Penn State branch campus.

Isadore Kline managed 100 women who made dresses and pantsuits for the likes of JCPenney department stores – not, his son noted, Saks Fifth Avenue.

Tom Kline would carry bundles of garments and buttons from machine to machine. He knew early on toiling away in a factory wasn’t his destiny. His parents, products of the post-World War II era, were firm believers in the American dream and wanted better lives for their children.

Yet, this childhood, interspersed with hardship, solidified Kline’s future of helping the downtrodden.

“When I was 15, my sister was in a … car accident, in which her best friend was killed. So, I was exposed to that,” Kline said. “I saw people injured in the factory. I was exposed to that.”

His mother, Jeanne, was a breast-cancer survivor. His neighbor died from inhaling toxic fumes at the beryllium plant where he worked. His boss at a stock brokerage house was a paraplegic from a gunshot wound in the Korean War.

These were the kinds of people Kline would come to represent as he rose through the ranks beginning in 1980 as a fledging lawyer for the legendary Philadelphia plaintiffs’ attorney, Jim Beasley. In 1995, he joined with Shanin Specter, son of longtime U.S. Sen. Arlen Specter, to open Kline & Specter in Philadelphia.

“I had seen a lot as a young man,” Kline said. “I saw the people who were innocent and bad things happened to them. I think that made an impact on me.”

It grounded him – small-town life and a close-knit family, he said.

“He’s obviously done very well for himself, but he’s not somebody who needs to go to the fanciest restaurants or do the fanciest things,” said Jordan Merson, Kline’s son-in-law and a lawyer in New York.

After graduating with a degree in political science from Albright, Kline began working as a sixth-grade teacher in Freeland, Pennsylvania, not far from his hometown. Simultaneously, he worked on a full graduate course load in American history at Lehigh University and wrote the first draft of a Ph.D. dissertation, tracing population trends among immigrant groups in Scranton, Pennsylvania, between 1840 and 1910.

“I could have gone on to law school, but I decided I want to teach for a while — not a lifetime,” he said. “I always had the view I wanted to be a lawyer.”

In 1971, Kline bumped into Paula Wolf at the Hazleton Jewish Community Center, where he and his mother were attending a performance of black Israeli folk dancers.

Paula, a Boston University student, was in white go-go boots, probably made of pleather, Kline recalled. He asked her out on a date, and they saw “Brewster McCloud,” an eccentric film about a boy living in the Houston Astrodome who tries to fashion himself a mechanical set of wings.

“I remember I read the review ahead of time, and I sounded smart enough for her to want to go on a second date,” Kline said. “She was tiny and cute and pretty.”

On the weekends, he would take a commuter plane to Boston to visit her at college. After graduation, Paula was hired to teach fifth grade in the same school district as Kline, and they were engaged and married in 1972. Once he hit his five-year teaching mark, they jointly decided it was time to launch Kline’s law studies at Duquesne University.

“I’ve always been attracted by the ability to do good and make change,” Kline said. “In a coarse and bitter and destructive world, it is still the fiber that holds the world together. At the core is the goodness of man.”

They crossed the state to Pittsburgh. Paula, continuing to teach, was the sole breadwinner. Kline worked hard in law school and received the distinguished student award for serving as editor of Duquesne’s law magazine.

One paper in particular, written for an “arcane” class on municipal corporations, helped to guide Kline’s future. Already familiar with collective bargaining between teachers and school districts, he dived into Pennsylvania’s Act 195, the source of controversy for an impending case in the state Supreme Court.

A classmate put in a good word, and Kline landed a clerkship with Justice Thomas Pomeroy – a “primo thing,” he said. It was a calling card, beckoning Kline to the prestigious law firms in Philadelphia and Pittsburgh.

But instead, Kline and Paula returned in 1979 to their roots in Pottsville, in the anthracite region for just under a year.

“Paula believed, rightfully so, that we had done all of this and ended up in a small town working for a small firm,” Kline said. So, she gave him an ultimatum, the only one in their 32-year marriage: “If you stay, you’re staying alone.”

“I think she said it more in jest than in earnest, but she said it nevertheless,” Kline said, an amused smile splayed on his face. With Paula’s warning in mind, Kline penned several lines to Beasley, introducing himself and inquiring about a job.

“Paula encouraged me to think big, and I thought big,” Kline said. “I packed myself up to work for the greatest trial lawyer of his era. The rest is history.”

Kline embarked on this next chapter of life as a new father – Hilary was just 9 months old. Their son Zac wouldn’t arrive for almost another five years.

Paula died in 2004 from breast cancer, the disease that had claimed his mother and maternal grandmother years earlier. Not long after, Kline bought an apartment in New York City to be closer to his children and grandchildren – Parker, Cole and Dylan.

He also took to traveling the world with Zac, who is a playwright and has a law degree. The self-proclaimed music “junkies” were in constant pursuit of Bob Dylan and Leonard Cohen concerts. Along the way, there were unexpected cultural excursions – like ending up in a “grimy standing-room venue” in Melbourne, Australia, to catch one of Dylan’s opening bands, The Frames.

“We traveled to Montreal when Leonard Cohen began his comeback tour in 2008 and stood outside the concert hall in the middle of the day,” Zac said. “My dad in his black suit and me in my jeans and blazer. That was a special intergenerational bond.”

***

In February 2001, graduate assistant Mike McQueary told head coach Paterno he had witnessed Sandusky rape a boy in the locker-room showers. It was the same place Sandusky had exploited boys for years – either unbeknownst or, as some suggest, overlooked by other football coaches and university administrators.

The dynamic should have changed, but “nothing was done about it,” Kline said.

Kline’s client, Victim 5, was assaulted six months later in August – after McQueary’s meeting with Paterno. He was the first to settle. All told in 2013, Penn State would pay nearly $60 million in civil settlements to 26 victims.

“Tom Kline was the voice for the victims in the Jerry Sandusky-Penn State horror,” said Bob Mongeluzzi, another celebrated attorney in Philadelphia. “He consistently and courageously stood up for them when they couldn’t speak for themselves.”

The settlement for Victim 5 was a “benchmark decision” for the rest of the litigation, Kline said, and it was also a landmark in the lawyer’s own career.

He was now entrenched in university politics. An outsider without “allegiances,” Kline said he saw the Penn State Board of Trustees as “factionalized,” with some members prioritizing social and athletic success over academics.

Under Penn State’s current president, Eric Barron, Kline said: “There is a more direct responsiveness, I believe, but there appears to me to be the same power centers and competing power centers. Therein lies the main problem with Penn State.”

Kline is now an insider too, at least where conversations between Jim Piazza and Barron are concerned on the fraternity question.

“It is my very much insider’s sense that, for good reason, the Piazzas are not satisfied with the pace of the progress – not only at Penn State, but in America generally,” Kline said.

University spokesperson Lisa Powers declined to comment on Kline’s role litigating against Penn State.

***

Before there was a boy called Victim 5, there was 4-year-old Shareif Hall. His foot had been amputated while riding an escalator at the Cecil B. Moore subway station in Philadelphia in 1996, mutilating both his body and quality of life.

Kline went on the offensive against the Southeastern Pennsylvania Transportation Authority (SEPTA), revealing mechanical failures compounded by employee negligence. In the courtroom in 1999, Kline held up the remnants of Shareif’s battered hiking boot. One day during the trial, he even encouraged his young client to remove his prosthesis and show the jurors a fleshy, brown stump of an ankle.

The tactics forced many to weep – or, at the very least, sympathize with Kline.

He has a knack for coming across as fundamentally human to juries, colleagues said.

“He’s not trying to be superior to them,” Mongeluzzi said. “He likes to be on this journey with them.”

Kline, the former sixth-grade teacher, brought along charts, printed with blank spaces that he invited jurors to fill in with hefty dollar figures as they calculated a litany of damages: disfigurement, pain and suffering, embarrassment, humiliation and loss of life’s pleasures.

“I rarely say this … and I have never told a jury, but I am going to tell you: Err on the side of giving him everything,” Kline said, according to the court transcript.

The jury returned a $51 million verdict, and the parties would ultimately settle for $7.4 million

The case led SEPTA to replace the escalator and implement additional safety measures.

“It was probably the most important case that was tried in the development of our firm,” Specter said. “That verdict and the social change it produced vaulted our firm onto the front pages of the newspapers for a long time.”

Other cases stand out to Kline, such as product-liability lawsuits he waged against manufacturers of prescription painkillers and anti-psychotic drugs.

There are also the cases he has lost — or the ones in which the verdicts fell far short of expectations. This past June, he secured $2.1 million for a woman who had been injured by what Kline referred to as a “barbaric” transvaginal mesh product. Kline said the verdict was a huge disappointment. He was after punishing Johnson & Johnson and a subsidiary “until it hurt.” This jury, he said, “just wasn’t going to do it, and it kind of baffled me.”

And then there is the litigation after the deadly Amtrak 188 derailment in Philadelphia in 2015. Kline chaired the Plaintiffs’ Management Committee, helping to consolidate 159 claims of wrongful death and personal injury. U.S. District Judge Legrome Davis, in a memorandum dated July 2017, commended Kline and colleagues for their “exceptional” leadership and “their labors, vision and spirit of acting in the best interest of the passengers.”

***

In the courtroom, Kline is known for his charisma, an emotional flair that comes from latching onto every last technical and human element of the case. He’ll don a designer black suit, discreetly combing back his long gray hair.

Amid the evidence boxes bursting with medical records and legal documents, a special mountain of papers gets towed along to every trial that is reserved expressly for Kline. Each sheet of white copy paper has a single sentence scrawled on it in black Sharpie ink.

“One of his idiosyncrasies is that when he gives a speech, he does it on many, many pages,” Kline & Specter partner Guerrini said. “His hallmark is one thought per page.”

In preparation for a trial, Kline will sit at the dining room table in his Philadelphia home, writing draft after draft. Only he can decipher the notes, but it’s a “terrific system that he knows well,” his son Zac said.

Kline will test the versions on associates and family members alike. He aims for a closing argument infused with the right blend of solemnity and compassion.

Sometimes, Brittney Schoenbeck, 31, his girlfriend and a graduate of the Thomas R. Kline School of Law, will coach him. “That’s really impactful,” she’ll say. Or, “Hit something more.”

***

One day in the Lancaster County Courthouse last October, Kline stood only inches away from the railing separating him and the jury box. He was delivering an opening statement in a trial for a 22-year-old woman who he said was “locked into” her body after a teenage pregnancy and childbirth gone catastrophically awry.

“She is paralyzed. She can’t move. She can barely talk, although enough for her to communicate yes or no. She can’t take care of any of her bodily functions, nothing,” Kline told the jury.

It was the type of medical malpractice suit, Kline said later in the day, that is emblematic of his firm – a core case like the Piazza litigation, holding other people accountable and trying to achieve a remedy.

As always, Kline’s notes rested on a music stand. He doesn’t like to use a solid wooden lectern because it creates too much distance, too much of a division between himself and the members of the jury.

“In a courtroom, Tom can be more arts than science,” Specter said.

Kline paced to his right, his arm swinging like a conductor, as he pieced together a convoluted tale of doctors who visited Analisa Ramos at Lancaster General Hospital. As he recounted the allegedly overlooked symptoms of preeclampsia, his voice rose in anger and then abruptly dropped to a whisper.

“I’m not looking at my notes right now,” Kline said, too immersed in the moment to be constrained by a script and the exact blood-pressure measures.

Yet, he made no immediate move to return to the music stand. Kline was confident that he was right – or close enough.

This is his system, too: cutting through legal or medical jargon to pierce the jury’s moral compass. Kline tells them that while he is a Philadelphia lawyer, he comes from humble beginnings – that he’s a “proud graduate of Albright College,” a private liberal arts school of 2,300 students just 35 miles from the very courthouse where they were gathered.

***

Kline took control of the Ramos case only three weeks ahead of time, and he let his colleagues handle the five years’ worth of day-to-day operations – collecting the interrogatories, taking the depositions. Still, he knew all of its intricacies.

“Tom amazes you because he’s so busy and has so many things going on at once,” said Kila Baldwin, a partner at Kline & Specter. “With a naïve eye, you’d think he wouldn’t be ready. He’ll grasp a concept in a very short time. He will not quit until he fully understands something.”

Among big-time lawyers, Kline is “one of the best of the best,” said Joseph Power Jr., a leading personal-injury attorney based in Chicago. They sit together on the board of directors for The Inner Circle of Advocates, comprised of 100 premier plaintiff lawyers across the country.

“He’s doesn’t just talk the talk – he walks the walk,” said Power, who now is president of the organization, a post once held by Kline. “His results speak for themselves. He’s not a bragger. He’s just Tom Kline: good person, great trial lawyer.”

Part of the reason for Kline’s success, colleagues said, is his stamina. He’ll camp out at his 1525 Locust St. office for as long as it takes to devise a long-term “global strategy” that will take his opponents by surprise.

“This is not a job. It’s a part of his life,” said Patrick Fitzgerald, an attorney at the firm.

It’s Kline being present in “all capital letters,” as Zac Kline likes to say. There is an “all in-ness” to what his father does.

Glued to his iPhone, Kline will chip away at emails late into the night – and then he’ll be back online by the early-morning hours.

“It doesn’t seem to bother him to constantly be busy,” said Merson, his daughter.

He’s not one to take breaks either, not even for meals. Instead, the 6-foot-3-inch, 195-pound lawyer is a snacker, popping the occasional Necco wafer into his mouth in court and swishing it down with a Dr Pepper. At home, he has an entire drawer littered with black licorice and other candies – and a refrigerator shelf containing small bowls of his freshly made icing.

***

At this point in Kline’s career, practicing law isn’t about making money. Associates said Kline does it for the public good, and he’s eager to tackle the most complex cases.

There’s a satisfaction, Kline said, that comes from receiving a thank-you note from a client years after a case has settled.

In 2016, he received the Philadelphia Trial Lawyers Association’s Justice Michael A. Musmanno Award, a testament to Kline’s “high integrity, scholarship, imagination, courage and concern for human rights.”

He has appeared alongside U.S. Supreme Court Chief Justice John Roberts on the “Lawdragon Legends” list, reserved for those featured in the legal media company’s “elite annual guide” 10 times. He has been named the No. 1 attorney in Pennsylvania by “Super Lawyers” for the last 14 years.

His high-profile cases have catapulted him into the national news media at a dizzying pace. Kline’s stance is that “if we do not have a public platform to express our view, we cannot shape public opinion.”

He added: “I don’t believe a lawyer should want to be on TV because he or she wants to see herself on TV. I believe it should be because there is a purpose or a message.”

Five-year-old Cole Merson delights in watching “famous Grandpa Tom” on live broadcasts, and he and his older sister, Parker, 7, are starting to catch on to Kline’s profession. They don’t know the grisly details of Piazza’s hazing death, but Kline managed to explain it to them in the simplest of possible terms.

“He’ll say it was a bunch of boys who were mean to this other boy,” said Hilary Merson, a preschool teacher, “and they just weren’t being nice.”

The Piazza case dominated Kline’s summer last year, as the lengthy preliminary hearings for 16 fraternity brothers dragged on in Bellefonte, Pennsylvania, not far from Penn State’s University Park campus. As Jim and Evelyn Piazza came face-to-face with the defendants, eight of whom were initially charged with involuntary manslaughter, Kline was by their side.

Sometimes, he sat erect, shielding the Piazzas from onlookers. At other moments, he was slouched forward, craning to listen to arguments between the district attorney and the defense lawyers.

“Thank God, Tom and his partner are there with us,” said Jim Piazza, who was often agitated by the proceedings. “They guide us through what’s happening and, frankly, they protect me from myself. They’re just incredible.”

Kline would swiftly escort the Piazzas outside the courtroom when the shocking fraternity-house surveillance video was queued up. It revealed the “gauntlet” ritual, which led to their son’s consumption of 18 alcoholic drinks in 82 minutes, and the aftermath of his fall down the fraternity house’s basement steps.

A new round of preliminary hearings on the case is scheduled for late March.

***

Last August, during the initial pretrial phase, Kline trekked back and forth to his vacation house on Long Beach Island, New Jersey. It’s there that he unwinds and reconnects with the “bedrock” of his life: family.

“I don’t claim to be perfect, but I believe that it is exquisitely important for lawyers and all professionals to strike a balance in their lives,” Kline said. “If you don’t know what’s important to you, you’ve really lost your way. I’ve always been blessed by love that has surrounded me.”

At the beach in Loveladies, wearing his Jawbone fitness tracker, Kline walks his daily 10,000 steps along the ocean. He “spends every bit of time” that he can with the family and bakes Challah bread with his grandchildren ahead of Shabbat dinner.

The family isn’t religious, Merson said, but the Jewish holidays are always a cause for celebration. In keeping with his late wife’s tradition, Kline will decorate the house with stuffed animal frogs during Passover, evoking the Ten Plagues inflicted on Egypt while the Israelites were enslaved there.

“We just always make sure we are together,” Merson said.

Beyond his devotion to family and music, Kline stays on top of the Philadelphia sports scene.

He’s often spotted behind home plate at a Phillies game, or, he’ll be found courtside at a 76ers game, right next to the away team. Those are the very seats that led him to Schoenbeck, who had been given one of Kline’s season tickets by a friend. When she sent a thank-you email, the two hit it off virtually before finally meeting in person in January 2011.

“I went to that other game, and we’ve been together ever since,” Schoenbeck said.

***

The consensus both at home and at Kline & Specter?

Kline will never retire.

“I get up every morning with the same vigor, with the same resolve, with the same motivation that I did literally 40 years ago,” Kline said. “I’m not tired by any stretch of the imagination.”

The classroom, which launched Kline’s career, still holds a certain appeal. The idea of teaching did cross his mind, he said, as he toured the newly constructed Thomas R. Kline Institute of Trial Advocacy at Drexel.

Kline has transformed Drexel through his $50 million donation, but his continued presence is an “awesome gift” in its own right, said Daniel Filler, the dean of the law school.

“He is incredibly generous with his time,” Filler said. “His heart is genuinely in this place, and I really appreciate that — it makes a difference.”

Kline is often invited to speak at the university or lead continuing legal education classes. “I might someday want to teach a full course,” he said, “but that’s not high on the agenda.”

In addition to the Piazza case, Kline is currently involved in sexual-abuse litigation dealing with the Archdiocese of Philadelphia.

A “notorious pedophile priest,” as Kline phrased it, molested a young boy between 1998 and 2001. The now-deceased victim, Sean McIlmail, stayed silent for years, before succumbing to depression and a drug overdose.

Kline, who represents the parents, will try the case in federal court early next year. Much as he did in the Sandusky litigation, Kline aims to hold the archdiocese accountable for endangering children and repeatedly covering up incidents.

His docket also contains a case against the Philadelphia School District stemming from the abduction and assault of a kindergarten student in 2013. The mother, lost in a media frenzy and legal labyrinth, had come to Kline for guidance.

“What struck me most was the brutality of the crime, the level of recklessness in handing over a kindergarten child to a stranger, and the need to help a child and family,” Kline said.

This is exactly the type of case that is most important to Kline.

He could protect the victim of “predatory behavior,” an area of increasing interest for him, and he could prevent future harm. It is an emotional case, just like Beta Theta Pi.

“The stakes have always been high,” Kline said. “I want to continue to do this for as long as I can, for as high a level as I can.”

~ 03.01.2018

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