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Posts from the ‘Child Support, Custody and Access’ Category

Parental Alienation and Custody Switches: Fostering Relationships is Key

Parental Alienation and Custody Switches: Fostering Relationships is Key

In a prior Blog, we discussed a case called Pryce v. Pryce where the court ruled the mother had alienated their children from the father, who originally had only access to them.  In response, the court ordered that custody should be switched from the mother to the father; this ensured children’s best interests would be served by maximizing their relationships with both parents.

This kind of court-ordered custody switch is not particularly common, but a finding of parental alienation is somewhat more so.  Perhaps this is understandable, since so many separations and divorces between parents are acrimonious, and often result in custody battles and acrimony.

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There is no bright line that a custodial parent must overstep, to be found to have alienated the other one to the extent that a custody switch is warranted.  It all depends on the facts and the circumstances.

But among the specific behaviour that courts hone in on, is an unwillingness of the custodial parent to put the children’s best interests at heart, and to “do the right thing” when it comes to fostering a good relationship with the other parent.

In Attia v. Garanna, for example, the court also took custody away from the mother and gave it to the father instead, emphasizing that the mother had made attempts to minimize the father’s role in their children’s lives.  Indeed, the court found she had done her “utmost” to restrict his access to them.  In contrast, the court found the father was “ready, willing and able” to share his parental role with the mother in a significant way.  This included abiding by court orders.

Likewise, in Rogerson v. Tessaro the Court of Appeal confirmed a lower-court ruling that custody of the children should also be switched from the mother the father.  While the mother insisted that she was supportive of the children’s relationship with their father, in reality she had actively thwarted it and made “diligent efforts” to exclude the father from their lives.  For example, she made a unilateral decision to move elsewhere, away from the father’s convenient access. In justifying the custody switch, the Court observed that the father would be more likely to support the children’s relationship with their mother, while the converse was not true.  The mother was unable to consider the children’s best interests; even though they were more closely bonded with her, the custody switch to the father would ensure that they would enjoy maximum contact with both parents.

For the full text of the decisions, see:

Pryce v. Pryce, 2019 ONSC 3558 (CanLII)

Attia v. Garanna, 2010 ONSC 2033 (CanLII)

Rogerson v. Tessaro, 2006 CanLII 15126 (ON CA)

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

The Laws Around the Non-Consummation of a Marriage: Which Jurisdiction’s Laws Govern

The Laws Around the Non-Consummation of a Marriage: Which Jurisdiction’s Laws Govern

In a case called Sahibalzubaidi v. Bahjat, the wife asked the Ontario court to annul her marriage to the husband on the basis that they had never consummated it.   The civil wedding ceremony took place in Malaysia and was duly registered there, but immediately afterwards she returned to her home in Canada to await her new husband’s arrival, under the immigration sponsorship process.

The non-consummation was on account of the wife’s strongly-held religious belief that the Malaysian ceremony represented only the civil portion of an Islamic marriage ceremony.  As a devout Muslim, she believed that she was prohibited from consummating the marriage until the couple had taken two further steps, namely: 1) receiving a religious blessing, and 2) participating in a public marriage feast.

Those two added steps never took place, because soon after the husband arrived in Canada the wife and her family concluded he was abusive. The wife stated she would never have married him if she had known of his true character beforehand. (Which was a factor that the court considered in another part of this judgement on the annulment issue, which we discussed in an earlier blog here).

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The question for the court was whether the wife’s annulment application to the Ontario court should be granted.  The court held that it should.

The ceremony took place in Malaysia, but the wife’s pre-marital domicile was Ontario. The laws of Ontario therefore governed the issue of how the non-consummation of the marriage affected the wife’s ability to get an annulment.  Those laws recognized that an annulment could be granted on the basis that the marriage was never consummated due to the wife’s strongly-held religious beliefs as to the need for a religious blessing and the public marriage feast to make the marriage valid.

(This was distinct from annulling the marriage because those added steps had not taken place;  the court found there was insufficient evidence on how or whether the legal validity of the marriage was impaired by the failure to perform all three components of the Islamic ceremony).

For the full text of the decision, see:

Sahibalzubaidi v. Bahjat, 2011 ONSC 4075 (CanLII)

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

Did Husband’s Poor Character Justify Marriage Annulment Based on Fraud?

Did Husband’s Poor Character Justify Marriage Annulment Based on Fraud? 

In a case called Sahibalzubaidi v. Bahjat, the court grappled with whether to annul the marriage between a woman and a man based on an unusual ground, namely “fraud”.   The woman claimed that in order to induce her to marry him, the man and committed fraud against her and her father, by misrepresenting that he had good character when he did not.

The man and woman were merely passing acquaintances while attending the University of Malaysia at the same time.  As a devout Muslim, she could not date or have an in-depth conversation with him in that environment.   However, when she returned to Canada to join her family, they continued to exchange emails and over time this led a discussion of marriage.  To her, “the most important thing in a potential husband was and is that he be honest, kind, moral and upright character and share my religious values which involve respecting me as his wife”, as she later told the court.

The man proposed to the woman by e-mail.  She accepted – subject to her father giving his consent, especially since she was his only daughter.  The father interviewed the man and his parents, and they gave him their assurances that the man possessed the character and qualities of a suitable husband for the woman.

The father approved the marriage, which took place in the customary manner involving both a civil ritual and a religious one. During that ceremony, the man promised to keep the woman safe, respect her, and take care of all aspects of her life.   He also directly promised the woman’s father that he would keep her safe and respect her.   The imam, who performed the marriage ceremony, told the man that if he tried to hurt the woman, she would have the right to make the marriage fasid, which means to have it annulled.

The court described the woman’s evidence as to what happened soon after:

[The woman] deposes that upon his arrival in Canada, [the man’s] true character emerged and had she known this she would have never agreed to marry him. [The man] breached his promise to keep her safe and respect her. … [T]he woman states:

He began to assault her, once even dragging her onto the front lawn of her parents’ house where everyone could see, which was a particularly debasing and humiliating act against someone of the [woman’s] cultural and religious background. The [man] threatened her and had her call his parents in Iraq to ascertain that, indeed, he had shot his father and broken his mother’s arm. The [woman] confirmed these facts with members of the [man’s] family, other than his mother and his father. He also implied that should she ever disobey him, a similar fate would await the [woman]. He would repeat the same complaint or instruction to her, not simply ad nauseum, but literally a hundred times a day in a succession. He refuses to recognize that he has any kind of personality disorder and will not under any circumstances obtain professional help in order to deal with it.

In light of these developments, the woman asserted that both the man and his parents deceived her and her father.  She asked the court to concluded that these facts were tantamount to fraud, which could form the basis  for annulling the marriage entirely.

The court noted that fraud does not usually vitiate a marriage, unless it induces an “operative” mistake,  for example one relating to a party’s identity, or a mistake in understanding that the ceremony that is taking place is a legal marriage.

The mistaken identity factor that could justify an annulment might arise if, for example, party A is induced to marry B, believing that she is marrying C.  Here, there was no such deception as to the man’s identity per se; the misrepresentations as to his character or personality traits did not fall within the traditional category of fraud.

The court accordingly rejected the woman’s annulment argument on this ground (although it did agree annul the marriage on one of the other grounds she raised, namely non-consummation, and failure to comply with certain religious requirements).

For the full text of the decision, see:

Sahibalzubaidi v. Bahjat, 2011 ONSC 4075 (CanLII)

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at Russellalexander.com

Challenging a Domestic Contract – Are its Terms Still Valid Pending Trial?

Challenging a Domestic Contract – Are its Terms Still Valid Pending Trial?

As readers of my Blog will know, “domestic contracts” (which include separation agreements and marriage contracts) are essentially signed, written legal contracts that embody the negotiated agreement between spouses in the event of their separation or divorce.  Among other things, they typically include provisions relating to how much post-split spousal support is to be paid, and by whom.

A well-drafted domestic contract will withstand a court’s scrutiny, and its terms may even be incorporated into an eventual divorce order made by the court.  But not all domestic contracts pass this test – one or both spouses may decide to challenge the validity of the agreement they negotiated, and may go to court for a temporary ruling on whether its provisions should be enforced pending a fuller trial, when all their issues relating to the separation or divorce can be finally addressed.

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These kinds of contract-challenge scenarios give rise to two interesting legal questions:

Question 1:  Do the support-related provisions of a domestic contract remain effective pending a court’s later determination of whether they are legally valid?

Yes.  In a case called Balsmeier v. Balsmeier, the court stated that there is a legal presumption that the marriage contract executed between a couple is valid.  So if one of them asks the court to set it aside, and requests interim support until the rest of their issues can be determined later at trial, then the court should normally order that support in keeping with what the parties agreed to in the contract.  In other words, the court should be reluctant to order interim relief that contradicts what the parties themselves agreed to in the signed contract.

Question 2:  Can a couple add a provision to domestic contract that effectively ousts a court’s authority to change or set aside other provisions that relate to support?

No. If a domestic contract includes a provision for support, or a waiver of a right to support, then the court can freely set it aside and make its own support determination – even though the contract itself contains an express provision trying to preclude the court’s power to do so under the Family Law Act (FLA). There are three situations in which a court can do this:

  • Where the provision for support, or the waiver of the support right, results in unconscionable circumstances,
  • The support provision is in favour of a dependent who qualifies for an allowance for support out of public money, or the waiver is by or on behalf of this kind of dependant, or
  • There is default in the payment of support under the contract at the time the application is made.

In an upcoming Blog, we will take a look at how this power can be wielded by a court, and applied practically in the face of rather onerous domestic provisions that are being challenged at an interim stage pending trial.

For the full text of the decision, see:

Balsmeier v. Balsmeier, 2014 ONSC 5305(CanLII)

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

 

Gambling, Drinking and Affairs – How do Ontario Divorce Courts Treat Spouses for their Misdeeds?

Gambling, Drinking and Affairs – How do Ontario Divorce Courts Treat Spouses for their Misdeeds?

A case called Malandra v. Malandra, where the court found that – for the purposes of deciding whether their Net Family Property (NFP) should be unequally divided – the husband should not be held solely accountable for certain bad business investments.

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This question of whether the NFP should be divided unequally comes up often: among other things courts must consider whether one of the spouses behaved in a manner that makes an even split unfair. Here are some of the categories of spousal misdeed that can come under the court’s scrutiny:

Learn more:

Property Division 101: Introduction to Sharing Family Property in Ontario Divorce

“Property” or “Income”? Appeal Court Rules on Structured Settlement Annuities

Is Husband’s Payment of 230 Gold Coins Under Islamic Marriage Contract Excluded from Wife’s Property?

  1. Reckless Investing

In a case called Lamantia v. Solarino, 2010 ONSC 2927, the question was whether the husband should be held accountable for deceit and various financial misconduct designed to hide his reckless investments in the stock market. He had forged the wife’s signature, and had borrowed from credit cards for which she became liable without her knowledge. He also took active steps to keep the wife from learning the true state of their financial affairs; for example, he made sure their bank statements were sent to another address. Furthermore, he continued to play the stock market even though the wife had asked him to stop. Those bad investments led to significant capital losses for the couple.

In finding that the NPF should not be equally divided, the court found that the husband had engaged in a pattern of deceit and engaged in conduct that made it unconscionable for the NFP to be divided equally.

Learn more:

Should Support-Paying Ex-Husband Be Saddled with Ex-Wife’s Financial Irresponsibility?

When Can You Vary a “Final” Spousal Support Order on an Interim Basis?

 My Spouse Has Bad Credit – What’s My Exposure?

  1. Spending to Feed an Addiction

In a second case, Dillon v. Dillon, 2010 ONSC 5858, the husband was a severe alcoholic, who incurred debts to feed his alcohol addictions. He lost many jobs over the years, and took pains to hide the dire family financial circumstances from the wife, who was completely unaware.

Given that their financial circumstances were spurred by the husband’s need to incur debt to feed his addiction, the court found this was a situation completely out of the wife’s control. Because of his reckless behaviour, she had effectively contributed significantly more than the husband toward amassing their family assets which formed the NFP – for example a cottage worth $260,000, and RRSPs funds amounting to $150,000. She had also paid over $50,000 towards the husband’s debts in order to keep things afloat for the benefit of their children.

By concealing the extent and timing of his “financial perdition” (as the court called it), the husband deprived the wife of an opportunity to prevent his destructive behaviour, or to prepare herself for retirement. The court found that the husband had “taken advantage of the [wife’s] selfless act of placing herself in a position of vulnerability in the best interests of her children.” An unequal division of NFP was ordered.

Learn more:

82 Year-Old Gambling Husband Loses Almost Everything – Should the Wife Get What’s Left?

Leaving lost wages? Court may order an unequal division property.

Should Alcoholic, Unemployed Father Be Forgiven $40,000 in Support Arrears?

  1. Spending Money on an Affair Partner

Finally, in a case called Hutchings v. Hutchings (2001), 2001 CanLII 28130 (ON SC), 20 R.F.L. (5th) 83 (Ont. S.C.J.), the husband was engaged in an extra-marital affair, and used family money in to order to travel with his mistress to Europe and Quebec. The wife was suspicious, and accused the husband of spending money on not just this but other affairs as well; however she was never able to prove the allegations. In this case, the court also ordered that the husband

had engaged in reckless and intentional depletion of the NFP and that there should be an unequal division.

Learn more:

Wife’s Accusations About Husband’s Infidelities “A Waste of Time”

Can a “Misbehaving“ Spouse Lose Out on Support?

If Husband Was Unfaithful, Should Wife Get Bigger Share of Equalization?

 

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

Dad’s Poverty Claim Foiled by Instagram Pics

fuji camera lens vintage

Dad’s Poverty Claim Foiled by Instagram Pics

The father had been ordered to pay child support in 2009, but never did. Over the course of the following decade, the child support arrears had accumulated to the point where he owed the mother more than $145,000 in respect of their two children.

It was only in 2018 that the matter came back before the courts, when the father asked the court to rule that he had met the tests for reducing the arrears, and for eliminating the going-forward support obligations. By law, this included the court looking at whether there had been a change of circumstances that occurred since the original child support order was made.

The father claimed that he’d had to move out of province to look for work in 2010, and that his income had dropped significantly from the almost $73,000 on which his child support levels had been calculated. In fact, he said he’d earned just over $11,000 in that year, and ended up living on the streets and panhandling for money. He said he also became an alcoholic, and sobered up only in 2012 when he met his former fiancée. However, he claimed that he and the fiancée were no longer in a relationship.

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The court relied on Instagram to both prove – and then disprove – various parts of the father’s story.
First, it accepted the claim that the father met his fiancée in 2012, because Instagram photos were filed with the court showing them together. But other Instagram photos proved to the court that the father was lying when he said the relationship had since ended, and that he was currently living alone in poverty in a basement apartment. The court said:

[The father] says that he is separated from [his fiancée], and that they are co-parenting their child, Nina, who lives with [the fiancée]. [The father] claims to live in relative poverty in a basement apartment costing him $400 per month. …
However, the Instagram photographs filed by [the mother] demonstrates a completely different lifestyle. They disclose a number of trips to Columbia, the most recent of which may have been as late as 2019, as well as trips to Portugal and to France. There are numerous smiling images of [the father and his fiancée] enjoying visits to exotic locations. There was a post from [the fiancée’s] mother which congratulates [the father] for acquiring a residence in Columbia. [The father] flew his daughter, Vanessa, to Columbia for a holiday in 2017. …
[The father] claims … to have paid these trips through points earned by buying gas for company vehicles which he drove when he was working. Outside of the fact that he needed about 300,000 points to go on the trips that [the mother] was able to find out about, that statement does not ring true. [The father] must be driving a lot to earn points to buy flights to Portugal for himself and his daughter, Nina (60,000 points). Yet he claims to effectively be working part-time because of his own health issues, which would mean that he would not be driving very much at all …

This evidence contradicted the father’s claims that he was earning $16 per hour and had an annual income of $17,000 per year; his stated income and lifestyle were simply at odds. The court surmised that it was more likely that he was being paid under-the-table by the fiancée, who owned her own business. When giving evidence they were both vague about the company he worked for and the details of his alleged employment.

Dad Wrests Custody from Mom After She Alienates the Kids from Him

Dad Wrests Custody from Mom After She Alienates the Kids from Him

The parents married in 2007, and had two daughters. In 2016 they separated very acrimoniously, and the court ordered the children to live primarily with the mother pending a later determination of their fuller issues. The father as given generous access on a set schedule.

At that later hearing, the mother asked for joint custody but with the added stipulation that the children would live with their father only on a limited basis, pursuant to a set schedule. In a somewhat unusual move, the father asked the court to change the status quo so that he had sole custody, with an equal timesharing agreement during various set days.

According to the father, the basis for this request was that the mother had used the time since their separation to intentionally alienate the children from him, and to relegate him to a small role in their lives and upbringing.

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The court heard that even during the marriage the father had tried to be actively involved with the children, but that the mother had made all the decisions about their care. In the court’s words, she “attempted to dominate all aspects of the children’s lives and attempted to reduce the [father] to a spectator regarding his own daughters”. This changed only when it suited the mother’s needs, and in the father’s view it only got worse after they split up.

For instance, he claimed that since separation she blocked him from having overnight access, even though he lived with his parents in a five-bedroom home that the family had occupied during the marriage. She suddenly and unilaterally terminated his right to pick up the children from school. She refused to allow him summer access, forced him to go to court three times over that issue – and then did not even show up for one of the court hearings.

The father also accused the mother of thwarting the children’s everyday interactions with him. Since separation, he still encouraged the children to call their mother during every one of his access weekends; conversely, he had received only two calls in the entire time they were with her. The children were also encouraged to keep secrets from the father, and were coached not to eat meals with him on those limited days during the week when he had access. The mother also did not inform the father of any medical, dental or counselling appointments, even though she had been ordered by the court to do so. Finally – and tellingly in the court’s view – she also insisted that the father’s weekend access be interrupted so that she could take the eldest child to piano lessons on Saturday mornings, and to her church on Sunday mornings.

The court found this collectively indicative of the mother’s “selfishness and lack of appreciation of the role that the [father] plays in his own daughters’ lives.”
The court added that both parents clearly loved the children, and both had the requisite parenting skills. But while the father’s overall conduct was geared towards the children’s best interests, the mother’s conduct was not. Joint custody was not appropriate, since the mother had not been willing to cooperate and make joint decisions. As the court explained:

The [mother] does not value and recognize the [father’s] crucial role in the lives of the two children. The [mother] is self-centred and only considers her best interests and not those of her children. Rather than embrace the [father’s] involvement in the children’s lives, the [mother] has attempted to minimize and restrict his involvement in major decisions affecting the girls and in a parenting scheme that is in the girl’s best interests.

The court accordingly ordered that it would be in the children’s best interests that there be shared physical access to the children, but that the father should have sole custody. Although the father was required to consult with the mother prior to making any final decisions, in the event of a dispute, he was granted the right to make the final decision. Otherwise, the children would reside equally with both parents on a stipulated, strict schedule.

For the full text of the decision, see:
Pryce v. Pryce, 2019 ONSC 3558 

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at RussellAlexander.com

Joint Custody? Parallel Custody? What’s the Difference? And When Can They Work?

Joint Custody? Parallel Custody? What’s the Difference? And When Can They Work?

The concepts of “joint custody” and “parallel custody” sound similar – and can feature nuances that can be confusing even to Family Lawyers and practitioners, let alone to the separated and divorced parents who are trying to navigate the effective care and custody of the children they have together.

The recent decision in Lall-Persaud v. Persaud afforded the Ontario court a chance to clearly articulate the basic elements of these two child custody formats.  This is the first of our two-part Blog on this case, and it covers the court’s stated thoughts on the “joint custody” model as one of the available paradigms.

The background facts were these:  The couple – Vanessa and Devendra — first met in 2004.  When they learned in 2014 that Vanessa was pregnant, they got legally married in a Hindu wedding ceremony performed at the home of Devendra’s parents.  They began living together in the matrimonial home – which was also owned by Devendra’s parents – only about a week after the child was born, due to renovations being made.

The court summed up the problem that quickly developed between the newlywed parents:

The parties had great difficulties adjusting to their new life. Both parties accused each other of not being a good partner.

Vanessa objected to her in-laws’ over-involvement in their lives.  She complained that Devendra did not treat her in a loving manner, was bullying, disrespectful and both physically and emotionally abusive.  She said he was not doing enough around the house, and was spending too much time working as a Disc Jockey.

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Conversely, Devendra felt underappreciated by his new wife, and felt she as not doing enough around the house while home with their child.  He claimed that far from being verbally or physically abusive, he said she was the one who liked to start arguments and be aggressive towards him.

This culminated in a fight just in late 2015, where the police were called but no charges were laid.  Vanessa moved out with their child to her parents’, for what she said was a few days;  however she never returned with the child to live in the matrimonial home with Devendra.

Since separation, Vanessa had been the primary caregiver of their child, but Devendra was actively involved.  The parents asked the court to determine the issue of custody, and what specific form it should take.

The court began by reflecting on the concept of “joint custody”.  Since it requires the parents to make joint decisions regarding their child, it is “an exceptional remedy that would be granted in circumstances where the parties demonstrated cooperation and consent” – including good communication. The court summarized some of the prevailing considerations:

For example, is there a history of day-to-day decisions made between the parties, or are there concerns that will one party will make unilateral decisions or involve the child unnecessarily in the disputes between the parties? There must be a measure of communication and cooperation for a joint custody order to work, although a standard of perfection is not required.

In considering whether joint custody is appropriate, it is not enough to hope that communication will improve once the litigation is completed. A party may also not act unreasonably by impeding access and marginalizing the other parent, only to then claim sole custody on the basis of lack of cooperation and communication.

In the case of Vanessa and Devendra, both parents seemed to accept that this would never work for them, since neither of them were asking the court for a straightforward joint custody order.  The court agreed that a custody model requiring them to decide parenting issues together would be simply unworkable in light of their existing level of conflict.

Instead, the court closely considered Devendra’s request, which was for joint custody with a “parallel-parenting” regime — where the parents would try to make decisions together, but where each of them has final decision-making in connection with specific issues.

More on that in next week’s Blog, when we will revisit the Vanessa and Devendra’s case while highlighting the court’s rules on when parallel parenting should and should not be ordered.

For the full text of the decision, see:

Lall-Persaud v. Persaud, 2019 ONSC 3587

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

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