In a published opinion filed October 21, 2024, the Second District Court of Appeal (Div. 7) reversed a judgment entered after the trial court granted without leave a real party developer’s motion for judgment on the pleadings, based on statute of limitations grounds, in a writ of mandate action alleging CEQA and Planning and Zoning Law causes of action and challenging the permit and vesting tentative map approvals for a residential subdivision project. Santa Clarita Organization for Planning the Environment et al v. County of Los Angeles (Williams Homes, Inc., Real Party in Interest) (2024) ___ Cal.App.5th ___. The Court held that judgment on the pleadings was improper as to the CEQA claim because Government Code section 66499.37, the Subdivision Map Act’s (SMA) statute of limitations requiring filing and service of summons within 90 days in subdivision-related actions, could not completely dispose of that cause of action. The Court reasoned this was so because most of the claims alleged in that cause of action were “procedural violations” and other claims “unique to CEQA” that could not have been brought under the SMA. The Second District’s opinion is poorly reasoned and concerning because it appears to diverge from the statute’s plain language, as well as from prior caselaw construing it to have an extremely broad application to any subdivision-related action, and to read into it a new and significant limitation on its reach, essentially making it applicable only to actions attacking a subdivision decision based on legal theories that are or could be brought under the SMA.
The Project and the Trial Court Litigation
Respondent County of Los Angeles (County) approved a conditional use permit, oak tree permit, and vesting tentative tract map (VTM) for real party developer’s (Williams) residential subdivision project in an unincorporated area of the Santa Clarita Valley. The project was to subdivide 94.38 acres of undeveloped land into 45 lots for 37 single-family homes, six public facilities, and two open space areas. County approved the project’s permits and VTM based on a mitigated negative declaration (MND) adopted pursuant to CEQA, and it conditioned the approvals (including the VTM) on compliance with the resulting “Mitigation Program.”
Petitioners’ (SCOPE) writ petition challenging the project approvals asserted two causes of action, one under CEQA and the other (later abandoned) under the Planning and Zoning law. SCOPE’s CEQA cause of action challenged the MND’s legal adequacy and alleged an EIR was required. It alleged a number of different legal theories under CEQA, including: County’s failure to provide adequate notice of its intent to adopt the MND; failure to provide the MND to the State Clearinghouse’s CEQAnet database; failure to recirculate the MND after discovery of a mountain lion on the site; failure to consult with the Santa Monica Mountains Conservancy; failure to disclose, analyze, and mitigate numerous significant environmental impacts (relating to fire hazards, mountain lions, rare and threatened plant species, wildlife habitat connectivity, hydrology and water supply, open space and trails, air quality, transportation, GHG emissions, and noise); and adoption of inadequate, vague, and improperly deferred mitigation measures.
SCOPE failed to serve a summons within 90 days of County’s decision approving the project ostensibly because it did not believe it needed to do so in an administrative mandamus action.
About 10 months after the action was filed, and after SCOPE had filed its opening brief on the merits, Williams moved for judgment on the pleadings on the ground that the action was time-barred due to SCOPE’s failure to comply with Government Code section 66499.37’s 90-day service-of-summons requirement. The trial court (per the Hon. Mitchell L. Beckloff) granted that motion without leave to amend, and SCOPE appealed.
The Court of Appeal’s Opinion
Although the Court of Appeal’s 29-page Slip Opinion did not get around to setting it forth in full it until page 15, it is most helpful to an understanding of the issues presented in the case to begin by considering the plain language of the SMA’s statute of limitations. That statute is codified at Government Code Section 66499.37, which states in relevant part:
Any action or proceeding to attack, review, set aside, void, or annul the decision of an advisory agency, appeal board, or legislative body concerning a subdivision, or of [sic] any of the proceedings, acts, or determinations taken, done, or made prior to the decision, or to determine the reasonableness, legality, or validity of any condition attached thereto, including, but not limited to, the approval of a tentative map or final map, shall not be maintained by any person unless the action or proceeding is commenced and service of summons effected within 90 days after the date of the decision. Thereafter all persons are barred from any action or proceeding or any defense of invalidity or unreasonableness of the decision or of the proceedings, acts, or determinations. …”
(Gov. Code, § 66499.37.)
The statute’s component elements, as relevant to this case, are that it: (1) applies to “any action or proceeding” brought to “attack,… set aside, void, or annul” an agency’s “decision…concerning a subdivision,… including, but, not limited to, the approval of a tentative map;” (2) provides that an action or proceeding that is subject to it “shall not be maintained by any person unless [it] is commenced and service of summons effected within 90 days after the date of the [challenged] decision;” and (3) provides that absent compliance “all persons are barred from any action or proceeding or any defense of invalidity… of the decision or of the proceedings, acts, or determinations [made prior to it].” Notably, the statute does not contain any language restricting the scope of its phrase “any action or proceeding” by limiting it to only actions or proceedings alleging certain legal theories.
The case’s undisputed facts include: (1) SCOPE’s CEQA cause of action attacked and sought to set aside and void, inter alia, County’s approval of the VTM (as well as its CEQA determinations preceding that decision) based on numerous legal theories of alleged CEQA violations; (2) SCOPE did not serve a summons within 90 days of the County’s challenged subdivision decision, i.e., County’s decision approving the VTM; and (3) the trial court ruled that SCOPE was conclusively barred from maintaining its CEQA action.
The trial judge’s decision was correct based on the plain language of the statute, and was also supported by longstanding case law. (See, e.g., Presenting Jamul v. Board of Supervisors (1991) 231 Cal.App.3d 665, 671 [“broad language the Legislature employed within section 66499.37 was specifically designed to include any challenge, regardless whether procedural or substantive in character, to any subdivision-related decision of either a legislative or advisory entity, or of any of the necessary precedent proceedings, acts or determinations pursued before the making of the challenged decision”].) Nonetheless, the Second District Court of Appeal’s Division 7 saw things differently and reversed. The Court of Appeal concluded that a “portion” of the CEQA cause of action – in fact, most of it – was not barred, and should have survived the motion for judgment on the pleadings, because it asserted “procedural violations unique to CEQA” that could not be “brought under” the SMA. This decision is more than a bit odd because, as shown above, nothing in the plain language of the statute states, or even implies, any limitation on the actions and proceedings to which it applies based on the legal theories they assert.
So how did the Court of Appeal reach its conclusion? Well, its statutory analysis started out on the wrong foot and only went further off track from there. The Opinion gave lip service to the well-established principles of statutory interpretation that a court must “first consider the words of the statute[], as statutory language is generally the most reliable indicator of legislation’s intended purpose” and will only look to “extrinsic sources” such as “legislative history” when the statutory language is ambiguous. (Slip Opn., at p. 11.) But the Opinion’s analysis did not actually follow these principles. Instead, after (finally) reciting the statutory language, with no analysis of its “plain language” meaning (either in general or as applied to the case before it), and without identifying any ambiguity in it (Slip Opn., at p. 15), the Opinion immediately veered off into an alleged examination of its legislative history, which it concludes (despite the statute’s contrary plain language) “reflects the Legislature’s intent that section 66499.37 apply to actions brought under the SMA (which in turn, applies to subdivisions).” (See, Slip Opn., at 15-17, emph. added.) This bit of judicial legerdemain rewrites the statute by adding something not found in its actual language. The broadly phrased statutory language “any action or proceeding” attacking a “decision … concerning a subdivision” is thereby transmogrified into “any action or proceeding brought under the SMA” attacking a “decision … concerning a subdivision.” That’s quite a difference.
One might suppose that the Court would have adduced powerful and conclusive evidence of legislative intent to support its significant departure from the statute’s plain meaning, but that supposition would be wrong. The Opinion gleans its legislative “intent” solely from a Senate Committee on Local Government analysis and a Legislative Counsel’s Digest memo, neither of which analyzed any of the statute’s operative language, and both of which concerned only a 1980 amendment whose sole object was numerically shortening the limitations period from 180 to 90 days. These documents described the statute, but only in passing, as applying to actions “brought under” or “under” the SMA. (Slip Opn., at p. 17.) No other analysis of legislative intent regarding the statute’s relevant substantive language is provided.
The Opinion also mentions, but ignores the import of, subsequent and far more relevant 2007 legislation that further clarified the statute’s broad reach by adding, following its description of covered actions challenging a “decision… concerning a subdivision,” etc., the language “including, but not limited to, the approval of a tentative map or final map.” (Slip Opn., at p. 16, citing Stats. 2007, ch. 612,, § 9, p. 5358.) That added language only makes sense if construed to provide non-exclusive examples of the types of “decision[s] … concerning a subdivision” that fall within the statute’s meaning and reach; it has no other function that I can discern. The 2007 amendment, which was described as a clarification of the statute, made pellucid that any action challenging a tentative or final map approval – like the CEQA action challenging the VTM at issue here – is within the statute and subject to its requirements.
After missing the import of the 2007 amendment, the Opinion proceeds to discuss some of the relevant case law. It first cites the Supreme Court’s decision in Hensler v. City of Glendale (1994) 8 Cal.4th 1, 23, which held an inverse condemnation action (alleging an ordinance enacted by a city under the SMA effected a regulatory taking) was barred by section 66499.37 due to the plaintiff’s failure to challenge the ordinance within 90 days of its enactment or application. The Opinion quotes Hensler’s language stating that “section 66499.37 applies by its terms to any action involving a controversy over or arising out of the [SMA]” to support the assertion that “the Legislature’s focus in section 66499.37 was on challenges to decisions made under the SMA[.]” (Slip Opn., at p. 18.) That assertion is unremarkable: section 66499.37 does focus on actions challenging decisions made under the SMA, including, but not limited to, actions challenging decisions to approve a tentative map – i.e., actions just like SCOPE’s CEQA cause of action. Indeed, as pointed out above, that is the clear import of the “clarifying” 2007 statutory amendment; so it is difficult to fathom how Hensler provides any support for the Opinion’s conclusion that SCOPE’s CEQA claim falls outside the statute’s reach.
The Opinion then discusses Friends of Riverside’s Hills v. City of Riverside (2008) 168 Cal.App.4th 743 (Friends) and Legacy Group v. City of Wasco (2003) 106 Cal.App.4th 1305 (Legacy Group) and describes these decisions as “expand[ing] on the holding of Hensler in concluding that section 66499.37 applies to a claim if it overlaps with an SMA claim or could have been brought under the SMA.” This, however, is another bit of judicial legerdemain because, as will soon become clear from the Opinion’s ensuing analysis, the Court actually reads these cases not to “expand on,” but, rather, to limit Hensler’s holding, and in doing so it reads the “if” in the foregoing quote to mean “only if.” Again, that’s quite a difference.
Friends involved an action asserting one CEQA cause of action and three other causes of action (that happened to allege SMA and municipal code violations) challenging a city’s approval of three tract maps without requiring the applicant to comply with all conditions of approval and mitigation measures contained in a specific plan. The Friends Court held the trial court did not err in dismissing the entire petition – including the CEQA cause of action – as barred by failure to comply with section 66499.37’s 90-day service-of-summons requirement. It rejected the argument that that requirement did not apply to CEQA claims because such claims are governed by different procedures, and observed “there is ample case law holding that the 90-day requirement applies to all types of actions seeking review of a legislative or advisory body’s subdivision-related decisions under the SMA, regardless of the legal basis.” (Friends, 168 Cal.App.4th at 750-751, emph. added [citing Jamul and Hensler].) It held there was no irreconcilable conflict between CEQA’s and the SMA’s statutory limitations or service provisions that would exempt CEQA actions generally from section 66499.37’s requirements (id. at 751-754), and then held that because the CEQA claim was an action “concerning a subdivision” within the meaning of the statute it was barred. (Id. at 754-756.)
The Friends court cited to Legacy Group, probably because it was a then-recent case involving the same statute that was also cited by both parties in the case before it. Legacy Group refused to extend the SMA’s statute of limitations beyond actions challenging subdivision-related decisions to apply to a breach of contract action based on a statutory development agreement. A breach of contract is obviously not a decision concerning a subdivision. By “contrast” to the breach of contract cause of action in Legacy Group, the Friends court concluded that the CEQA cause of action in the case before it was subject to the SMA statute of limitations’ 90-day service of summons requirement “because it both overlapped with the SMA causes of action and could have been (and was) brought under the SMA.” (Id. at 754-756.)
Friends could have readily distinguished Legacy Group as involving a breach of contract claim based on a contractual obligation arising from a contract made under an entirely different statutory scheme – a claim typically governed by a substantially longer (4-year) limitations period than claims arising out of the SMA (or CEQA, for that matter) – rather than a challenge to a subdivision-related decision. Friends is interesting here for the issues it did not address or decide. For example, Friends noted, but did not directly address or decide the City’s and Real Party’s argument to it “that the CEQA claim directly challenges the City’s approval of the Project, and thus clearly “concern[s] a subdivision” under section 66499.37.” (Id. at 754-755.) That argument, standing alone, should have been dispositive in favor of the affirmance in Friends, particularly in light of the statute’s 2007 amendment adding the language clarifying that “decision[s] … concerning a subdivision” encompassed decisions “including, but not limited to, the approval of a tentative map or final map[.]” But the 2008 Friends decision did not address the argument, and even deleted (by an ellipsis) the language added by the 2007 amendment when it quoted the statute. (Id. at 748-749.)
Whether Friends’ omission was an oversight, or an intentional omission of the extant statutory language out of concern that objections might have been raised to its retrospective application to bar an otherwise timely claim filed before the amendment became effective, is not known. What is apparent is that although Friends based its holding on ostensibly narrower grounds, it would have reached the same result had it simply applied the plain statutory language of section 66499.37 as it had then recently been amended. In other words, it would have been compelled to conclude that a cause of action directly attacking a tentative map approval – on any legal theory – falls within the statute. Full stop.
Legacy Group’s treatment of a breach of contract claim arising out of a statutory development agreement, and not challenging any map approval, as falling outside the statute’s broad reach was undoubtedly correct, but its reasoning as to why that was so in the case before it was also entirely irrelevant to any analysis of a CEQA claim asserted as a vehicle to directly attack and void an actual subdivision map approval. One of Legacy’s clear concerns was to not allow the “relabeling” (through creative pleading) of claims that could have been brought under the SMA as “breach of contract” claims solely in order to avoid the SMA’s shorter statute of limitations; Legacy’s aim was not to limit the legal theories of actions clearly subject to the SMA’s statute of limitations to only SMA-based legal theories. And, in any event, it must be kept in mind that Legacy was decided several years before the Legislature amended the statute to make it even clearer that it encompassed, inter alia, any actions directly attacking an agency’s decision approving a subdivision map.
The developer and County in the instant case clearly made what should have been – and which was in the trial court – the dispositive argument in their favor. The Opinion notes that “they contend, the CEQA cause of action is subject to section 66499.37 because it challenges the County’s approval of the vesting tentative tract map [made] under the SMA.” (Slip Opn., at p. 21, emph. added; see id. at pp. 21-22 [also noting their arguments under Presenting Jamul’s language emphasizing the statute’s broad reach].) But the argument fell on deaf ears – the Opinion simply dismisses it and narrowly reads Presenting Jamul’s holding as “not mean[ing] section 66499.37 applies to any subdivision-related decision[,]” but only “any subdivision-related decision involving a controversy under the SMA regardless of the label placed on that decision.” (Slip Opn., at p. 22, last emph. added.) Lost entirely in the Opinion’s strained effort to reframe the past precedents to support its result is that the statute’s plain language as it currently reads – which, absent an identified ambiguity, should be the starting and ending point of the analysis – makes abundantly clear that it applies to “any action” attacking a “decision… concerning a subdivision,” which the statute expressly references as including (but not being limited to) “the approval of a tentative map or a final map[.]”
It is difficult to see how the Court of Appeal could have missed all this. Judge Beckloff clearly did not. It is also difficult to see how the Legislature could have made it any clearer that section 66499.37 encompasses any and all actions that directly attack and seek to void a subdivision map approval decision, regardless of the legal theory asserted. Indeed, an analogous 90-day statute of limitations applicable to land use writ actions challenging decisions made pursuant to the Planning and Zoning Law, which has operative language very similar to that of the SMA’s statute of limitations, has long been interpreted to broadly apply to any actions attacking the specified decisions regardless of the legal theory asserted. (See Gov. Code, § 65009(c)(1); Travis v. County of Santa Cruz (2004) 33 Cal.4th 757, 767-768 [“Section 65009, subdivision (c)(1)(E), in setting a time limit for actions challenging permit conditions, does not purport to restrict the legal theories or claims that may be made in such an action, and we see no justification for reading such a substantive limitation into the clear procedural language of the statute”; further noting § 65009(e) provides that, following its limitations period, “all persons are barred from any further action or proceeding”].) Statutes that are in pari materia should be construed together; yet the Opinion essentially ignores Government Code section 65009, failing to apprehend and summarily dismissing its relevance in a footnote (Slip Opn., at pp. 23-24, fn. 8), and not discussing the Supreme Court’s highly instructive decision in Travis at all.
The Opinion’s Specific Holdings
The Court of Appeal’s Opinion makes the following holdings and statements of law (set forth as bullet points below followed by my own comments):
- “[T]o the extent SCOPE’s CEQA cause of action asserts a claim that arises from or involves a controversy under the SMA or challenges the reasonableness, legality, or validity of a condition of approval under the SMA of the vesting tentative tract map for the Project section 66499.37 applies.” (Slip Opn., at p. 23.)
Comment: While this is a correct statement as far as it goes, the statute goes further and actually applies to SCOPE’s entire CEQA claim.
- “As the Friends and Legacy Group courts elaborated, a CEQA claim is also barred if it overlaps with a claim for violation of the SMA or could have been brought under the SMA.” (Ibid.)
Comment: Again, this is a correct statement as far as it goes, but as shown above such are not the only types of CEQA claim to which the broadly worded statute applies.
- The five “procedural CEQA violations” alleged by SCOPE (discussed above) (1) “are unique to CEQA and could not have been brought under the SMA” and (2) are thus not barred by SCOPE’s failure to comply with Section 66499.37’s service-of-summons requirement. (Slip Opn., at p. 24.)
Comment: The first statement is probably correct, but the second is wrong; the statute bars claims based on any legal theory that directly attack a subdivision approval by seeking to set it aside.
- SCOPE’s allegations that the MND failed to adequately analyze and disclose numerous environmental impacts (discussed in detail above) and that an EIR is required due to substantial evidence that these impacts may be significant similarly “assert CEQA claims that do not arise from the SMA or involve any controversy under the SMA” and are therefore not barred. (Slip Opn., at pp. 24-25.)
Comment: This statement is partly correct, but here it should be noted that the opinion fails to acknowledge or discuss the potential effect on its conclusions of the SMA’s statutory provision addressing environmental findings justifying disapproval of a tentative map. One of these findings is “[t]hat the design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and unavoidably injure fish or wildlife or their habitat.” (Gov. Code., § 66474(e).) An agency making that finding, or any one of six (6) others listed under section 66474, is required to deny approval of the map.
- In rejecting the developer’s and County’s contentions that “section 66499.37 governs the entire CEQA cause of action because the Board’s approval of the [VTM] was “inextricably linked” to the Project’s CEQA review and mitigation measures[,]” the Opinion states “[a]lthough these findings were made with respect to the [VTM], they were made by the Board to comply with CEQA, not the SMA.” (Slip Opn., at p. 25.) It then concludes the entire CEQA claim was not barred, reasoning: “The fact that the County’s approval had to comply with CEQA does not transform a cause of action for violation of CEQA into a claim that arises under the SMA or overlaps with a CEQA claim. Likewise, SCOPE’s claims that the County failed to adequately analyze and disclose the Project’s environmental impacts in the MND arise under CEQA, not the SMA, and SCOPE could not have brought those claims under the SMA.” (Id., at p. 26.)
Comment: All of this reasoning is irrelevant to whether an action or cause of action attacking a map approval decision and seeking to void it is subject to the statute.
- Thus, the Court held “most” of SCOPE’s CEQA claims were not barred despite its failure to comply with section 66499.37; the sole exception was “claims within the CEQA cause of action challenging the adequacy of the mitigation measures in the Mitigation Program” which it held “fall within the scope of section 66499.37 because they challenge conditions of the County’s approval of the [VTM] under the SMA.” (Id. at p. 26.)
Comment: Here, the Court’s Opinion further rewrites the statute’s plain language, stating: “Section 66499.37 applies to any action “to determine the reasonableness, legality, or validity of any conditions attached [to an approval of a subdivision], including, but not limited to, the approval of a tentative map or final map.”” (Slip Opn., at p. 27 [bracketed language added by Court].) By omitting the first and most critical portion of the statute’s lengthy first sentence describing its application to “[a]ny action… to attack… the decision… concerning a subdivision, or any of the proceedings, acts, or determinations taken, done, or made prior to the decision” the Court glosses over its primary focus on a subdivision-related decision and focuses solely on a subordinate clause of the sentence dealing with a subset of such actions challenging conditions attached to an approval. By adding language not contained in the statute – i.e., replacing “thereto” with “to an approval of a subdivision” – the Court subtly attempts to shift the meaning of the key phrase “including, but not limited to, the approval of a tentative map or final map” from providing nonexclusive examples of the types of subdivision-related “decisions” that “actions” within the statute “attack” and attempt to “set aside,” to examples of approvals to which challenged conditions may be attached. The Court further misquotes the statute by cutting off the end of its first sentence with a premature period and omitting its final portion beginning with “shall not be maintained….” All of this editing and rewriting of the statute appears to be result-oriented: not only does it ignore the statute’s broad language encompassing an agency’s findings and determinations made “prior to” a subdivision-related decision (which on its face would appear to broadly cover any required CEQA findings and determinations), but it focuses attention solely on and unduly emphasizes a subordinate clause dealing with one type of action that is a mere subset at all covered actions – i.e., an action challenging only conditions attached to an approval under the SMA – while obscuring that the statute also (and, indeed, primarily) applies to actions attacking the decisions granting the SMA approvals themselves, i.e., “the approval of a tentative map or final map,” as clarified by the 2007 amendment.
Conclusion and Implications
Given Government Code § 66499.37’s plain language and patent objective – to achieve certainty and finality for an agency’s subdivision-related decisions in the shortest timeframe possible consistent with due process – as well as the decisions interpreting and applying both it and the analogous statute of limitations of section 65009(c)(1), the Opinion’s interpretation of the SMA’s statute of limitations not to apply to most of the CEQA claim at issue here appears quite untenable.
Interestingly, the penultimate paragraph of the part of the Court’s Opinion preceding its “Disposition” states:
“SCOPE argues it should have been granted leave to remove the allegations that are barred under section 66499.37, including its request that approval of the [VTM] be set aside. Williams and the County urge us to affirm the trial court’s grant of Williams’s motion for judgment on the pleadings. Neither side has it quite right.”
(Slip Opn., at p. 28, emph. added.) Contrary to the Court’s conclusion, it seems to me that both sides had it right with respect to their above contentions. Because SCOPE’s CEQA cause of action sought to set aside County’s decision approving the VTM, it was plainly an action falling within the scope of the SMA’s statute of limitations as set forth in Government Code § 66499.37, and it was therefore barred by SCOPE’s failure to comply with that statute; as SCOPE apparently recognized, its only hope to preserve it was to amend it, if possible, to seek relief other than voiding the VTM. Since the pleadings had presumably long been joined and settled, and SCOPE had already filed its opening brief on the merits when the trial court considered, and granted without leave, Williams’ motion for judgment on the pleadings, it is apparent that the trial court “got it right,” too. As far as I can see, Judge Beckloff did not err on the law in granting the motion, and there is no indication that refusing leave to amend at that late stage was an abuse of his discretion since the entire CEQA claim was legally nonviable (and SCOPE had abandoned its only other cause of action).
In sum, it appears that the Court of Appeal “got it wrong” in this case, by performing an improper and result-oriented statutory interpretation “analysis” and effectively re-writing the SMA’s broad and clear statute of limitations – all solely in service of saving a large portion of the non-complying plaintiffs’ CEQA claim. If this case stands and is followed by other courts, the negative implications are profound. Because virtually every CEQA action will be able to allege procedural and substantive allegations that are “unique to CEQA” and do not “arise from” the SMA – apart from serving as legal theories and a vehicle to attack and void a tentative or parcel map approval – and that cannot be “brought under” the SMA, the Court’s Opinion renders the statute’s 90-day service-of-summons requirement a “dead letter” when it comes to CEQA actions. Under the Court’s decision, CEQA plaintiffs will now be able to ignore the statute with impunity, and with no adverse consequences.
Perhaps the Court of Appeal intended this result. Maybe it disagrees with the wisdom of the statute’s service-of-summons requirement, or views it as bad public policy or a trap for the unwary plaintiff. But such judgments are within the province of the Legislature, not the courts, and it is the Legislature’s prerogative to rewrite the statute if it is to be rewritten. It will certainly be interesting to see where this decision leads.
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