Professional Documents
Culture Documents
Plaintiff, No.
v.
COMPLAINT
AND NOW, comes Plaintiff Jane Doe, by and through counsel Robert A.
Bracken, Esquire and Bracken Law Firm, LLC and files the following Complaint and
avers as follows:
Pennsylvania. As Plaintiff was a 17-year old student in the Chambersburg Area School
District when she was a victim of institutional sexual assault and corruption of minors,
she has been identified as Jane Doe; however, Defendants know her identity. Plaintiff
employed by CASD. Claims are being asserted against Dr. Dusman individually and in
employed by CASD. Claims are being asserted against Dr. Padasak individually and in
employed by CASD. Claims are being asserted against Ms. Barnhardt individually and in
five-year prison sentence. At the time of the events set forth herein, Hand was a soccer
coach employed by CASD. Claims are being asserted against Mr. Hand individually and
7. Defendants John Does 1-5, are adult individuals that were administrators
are being asserted against John Does 1-5 individually and in their official capacities.
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9. The Court has jurisdiction over these claims pursuant to 28 U.S.C. § 1331
and § 1343. The Court has supplemental jurisdiction over Plaintiff’s state law claims
substantial part of the events giving rise to this Complaint occurred in Franklin County,
Pennsylvania.
FACTUAL ALLEGATIONS
CASD Soccer Coach Grooms and Preys Upon Plaintiff Jane Doe
11. Since approximately 2011, Jeffrey Hand acted in a soccer coach capacity
at CASD. Mr. Hand also acted as a soccer coach for the Chambersburg Youth Soccer
12. Mr. Hand was also a licensed therapist during the time of his employment
with CASD.
13. Jane Doe was a 17-year-old Chambersburg Area High School student and
14. Mr. Hand had known Jane Doe since she was about 10 years old, as he
16. When Jane Doe was 16 and following the permanent exit of her father
from Jane Doe’s home after her parents’ divorce, Mr. Hand began grooming Jane Doe.
The grooming that began in Jane Doe’s junior year of high school continued through part
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17. Initially, Mr. Hand’s overtures appeared innocuous. For example, Mr.
Hand invited Jane Doe to help him with junior high school soccer tryouts, which Jane
Doe did. Similarly, Mr. Hand volunteered to drive and did drive Jane Doe to soccer
18. Over time, Mr. Hand’s grooming became more targeted to Jane Doe.
19. Mr. Hand invited Jane Doe to his apartment to provide her with a book he
purchased for her and Jane Doe did visit his apartment for this reason.
20. Mr. Hand invited Jane Doe to go hiking and did go hiking with Jane Doe.
21. Mr. Hand invited Jane Doe to go out to dinner following soccer games and
22. Mr. Hand invited Jane Doe to his apartment to play Uno and watch
23. Mr. Hand invited Jane Doe to his apartment to assist her with her college
24. Mr. Hand often “counseled” Jane Doe regarding personal matters such as
25. Eventually, Mr. Hand succeeded with his grooming and began engaging in
26. The first sexual encounter occurred in September 2016 at Mr. Hand’s
parents’ home after Mr. Hand plied Jane Doe with alcohol; Mr. Hand’s parents were not
present.
27. A few days after the encounter, Jane Doe was injured playing soccer for
CASD.
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28. Mr. Hand fondled Jane Doe by intentionally grabbing her buttocks while
29. Thereafter, Mr. Hand continued to engage in sexual acts with the student,
31. The last sexual encounter between Mr. Hand and Jane Doe occurred on or
institutional sexual assault and felony corruption of minors resulting from his wrongful
conduct with Jane Doe and received a one to five-year prison sentence, followed by five
years of probation.
34. As part of his sentence, Mr. Hand must also undergo sex offender
treatment and is not allowed to contact Jane Doe or have unsupervised contact with
35. Upon information and belief, sometime during his employment with
CASD, and prior to 2016, Mr. Hand was accused of assaulting another CASD student.
36. Upon information and belief, as a result of this accusation, Hand was
temporarily suspended while CASD investigated. He was also suspended from CYSA
37. Thus, upon information and belief, one or more of John Does 1-5, had
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38. Yet, upon information and belief, CASD, through one or more of John
Does 1-5, chose not to involve the Pennsylvania State Police but rather handled the
investigation internally.
Mr. Hand was reinstated by one or more of John Does 1-5 and permitted to continue
41. Upon information and belief, a complaint was made by a female CASD
high school junior varsity soccer coach to either the Head Coach for CASD soccer or the
CASD Athletic Director (or both) about her witnessing Mr. Hand telling the junior
varsity players to lift up their shirts during practice. It appears that no permanent (or any
for that matter) corrective action was taken. The complainant subsequently resigned her
position as junior varsity soccer coach with CASD when nothing was done about her
complaint.
42. In approximately 2016 Mr. Hand was retained by CASD as the junior
43. Upon information and belief, CASD, through one or more of John Does 1-
5, failed to adequately consider Mr. Hand’s troubling background when making the
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45. Head Coach Franchi stated that he saw the need to counsel Mr. Hand
regarding his “disturbing” behavior with female CASD soccer players which he
described as Mr. Hand being “too handsy”. Notwithstanding, it appears that no report of
Mr. Hand’s “disturbing” behavior was made to anyone outside of CASD. Further, it
appears that the CASD took no permanent disciplinary measures (or any) as a result of
such “disturbing” behavior. CASD permitted Mr. Hand to continue as the CASD junior
46. CASD’s decisions, through John Does 1-5 regarding the hiring and
him with minor, female soccer players - including those listed above - jeopardized the
47. As a result, Mr. Hand was put in a position that allowed him to target and
groom Jane Doe – ultimately, engaging in sexual relations with her, while plying her
alcohol.
48. The failures by CASD, through one or more of John Does 1-5, including
the failure to adequately screen Mr. Hand’s background prior to hiring/retaining him; the
failure to report “disturbing” behavior brought to their attention to the proper authorities
as required by applicable law; and the failure to adequately investigate and discipline
49. This reckless indifference allowed Mr. Hand to continue preying upon
Jane Doe.
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50. Teachers, coaches and school administrators owe a duty of care to their
students, which includes (i) a requirement that they promptly and adequately report any
mandated by law; (ii) a requirement that they properly screen teachers, coaches and
school administrators at the time of hiring; (iii) a requirement that they adequately
administrators regarding a student; and (iv) a requirement that they invoke appropriate
involving a student.
51. Notwithstanding, CASD, through one or more of John Does 1-5 made the
affirmative decision not to report such concerns – including allegations that could have
constituted crimes. Further CASD, through one or more of John Does 1-5 failed to
adequate hiring screen when hiring Mr. Hand and failed to take adequate (or any)
52. The conduct of CASD and CASD’s failures to properly act, through one
or more of John Does 1-5, emboldened Mr. Hand and left his female students vulnerable
53. On December 14, 2016, Jane Doe was suddenly pulled into a meeting with
administrators included Principal Cathy Dusman, Assistant Principals Jaime Vinglass and
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54. Jane Doe was told that the meeting was the result of a report being made
to CASD about the inappropriate relationship involving Mr. Hand and Jane Doe.
55. The date that CASD received this report is presently unknown.
56. At some point after the meeting was in progress, Jane Doe’s mother was
57. Throughout that meeting, Jane Doe was humiliated, verbally attacked and
58. The attacks and accusations included those of Dr. Dusman – who berated
Jane Doe, shook her head in disgust at Jane Doe, demanded Jane Doe’s phone and
passcode, searched her private text messages and insisted that Jane Doe answer her
questions. Dr. Dusman even called Jane Doe a “liar” in the meeting.
59. More shocking was that the meeting turned into an interrogation of Jane
Doe’s sexual activity. This included Ms. Vinglass asking Jane Doe’s mother (in the
presence of Jane Doe) whether she was “sexually active” - stating that she had “heard”
60. Based upon Ms. Vinglass’ accusation, it appears that rumors were
circulating regarding Jane Doe being “sexually active” – which upon information and
belief, was directly associated with Mr. Hand’s sexual assaults of Jane Doe.
61. Upon information and belief, these rumors made their way to senior
administrators at CASD, yet it appears that no action was taken until a “formal report”
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62. The conduct of the CASD senior administrators in the meeting was so
deplorable that Jane Doe’s mother had to remind them multiple times that Jane Doe was
the victim.
63. During the meeting, Jane Doe tried to cooperate with the demands of the
senior administrators after she was assured that everything discussed would be kept
applicable law. Jane Doe’s mother later learned directly from Superintendent Joseph
Padasak that he had instructed Dr. Dusman “not to touch” the situation and to
immediately contact the police, but that Dr. Dusman disregarded his specific instructions.
Notwithstanding his receipt of the report, Dr. Padasak did not himself contact the police,
did not attend the meeting on December 14, 2016 and did not follow up to ensure that his
the end of the meeting, Jane Doe was in shock and hysterical. Jane Doe’s condition was
so uncharacteristically fragile that her mother took her from the meeting to the
66. Jane Doe’s mother also arranged for a licensed therapist to talk with Jane
Doe following her release from the hospital, as she was so alarmed and very concerned
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Jane Doe is Bullied by a Teacher and Students After CASD Breaches its
Promise of Confidentiality and Fails to take Corrective Action
meeting with the CASD faculty and informed them all of the report – including Jane
Doe’s identify.
68. Thereafter, teacher Katherine Barnhart (who at one time had a romantic
relationship with Mr. Hand) started discussing these events – including Jane Doe
69. Ms. Barnhart’s conduct was outrageous and calculated to cause Jane Doe
enormous embarrassment, humiliation and severe emotional distress; Ms. Barnhart was
successful.
70. Indeed, Ms. Barnhart encouraged bullying and harassment of Jane Doe,
which included and led to Jane Doe being called, among other things, a “whore,” “slut,”
“disgusting,” “gross,” “f*cked up,” and stating that she should be “in jail” rather than Mr.
Hand.
71. Ms. Barnhart’s bullying and harassing behavior began soon after the
December 14, 2017 meeting and continued throughout the remainder of the school year.
72. In particular, Ms. Barnhart encouraged one particular student, who hung
out with Ms. Barnhart outside of school, interacted with Ms. Barnhart on social media
and through text messages and was essentially Ms. Barnhart’s sidekick, to bully Jane
Doe.
73. In fact, this student apologized to Jane Doe after her high school
graduation and admitted that she acted the way she did and did not apologize earlier
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74. The bullying included students keying Jane Doe’s car and shooting it with
paintballs.
75. The bullying and harassment Jane Doe experienced were on the basis of
sex and related to the sexual assaults that Mr. Hand had committed.
76. This harassment caused Jane Doe severe and on-going emotional distress
and often led Jane Doe to a sympathetic teacher’s classroom to talk about the bullying
77. The bullying contributed to Jane Doe’s need for medical care and
78. Jane Doe pleaded with to Dr. Dusman herself to take action to stop the
79. Jane Doe’s mother pleaded with both Dr. Dusman and Dr. Padasak in
writing about Ms. Barnhart’s behavior, yet her concerns were intentionally ignored.
80. During the holiday break, Jane Doe’s mother contacted Dr. Padasak and
requested a “re-entry plan” for Jane Doe’s returned to school in January. She expressed
her concern about how cruel people can be and wanted a safe emotional and physical
environment for Jane Doe. Despite Dr. Padasak’s promise that action would be taken to
ensure her safe return nothing at all was done and the harassment and bullying behavior
continued after Jane Doe returned to school in January. This includes Ms. Barnhart’s
continuing to spread rumors and engaging in gossip regarding Jane Doe and Mr. Hand.
emotional distress and physical symptoms from the sexual assaults and from CASD’s
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82. Accordingly, instead of experiencing the joy of her high school senior
year, Jane Doe experienced regular and severe harassment, bullying and humiliation.
Jane Doe often skipped classes to get away from the harassment, bullying and
humiliation and went through medical treatment and counseling to try and cope.
83. Jane Doe continues to experience physical and emotional issues and
85. All named Defendants were state actors at all times relevant to the claims
in this Complaint.
87. Jane Doe had a liberty interest in her bodily integrity and her reputational
88. Further, a student’s right to be free from sexual assault is a clearly defined
Constitutional right, as is a student’s right to equal protection and to be free from sex-
based harassment.
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89. Yet, these Defendants violated Jane Doe’s due process and equal
90. Mr. Hand by committing institutional sexual assault and engaging in the
corruption of a minor violated Jane Doe’s Fourteenth Amendment Rights, including but
not limited to her due process rights, including her right to bodily integrity.
91. Ms. Barnhart by her own actions and by encouraging students to bully and harass
Jane Doe on the basis of her sex violated Jane Doe’s rights to equal protection and to be
free from sex-based harassment and violated Jane Doe’s due process rights, including her
92. Defendants CASD, Dr. Dusman, Dr. Padasak and John Doe’s 1-5 violated
93. Defendants CASD, Dr. Dusman, Dr. Padasak, Ms. Barnhart, Mr. Hand
and John Doe’s 1-5 violated Jane Doe’s Fourteenth Amendment Rights under a state-
94. John Does 1-5, Dr. Padasak and Dr. Dusman possessed policymaking
95. Furthermore, the failures of CASD, Dr. Dusman, Dr. Padasak and John
Does 1-5 to adequately implement effective policies, train its teachers, staff, agents and
administrators regarding those policies and/or enforce those policies reflects a deliberate
particularly given the recurring situations involving Mr. Hand and Ms. Barnhart that
presented an obvious potential for continuing Constitutional violations (which did, in fact
occur).
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96. Upon information and belief, CASD, Dr. Padasak, Dr. Dusman and John
Does 1-5 failed to have effective polices, customs and practices in place and/or
adequately educate or train its teachers, administrators and staff and ensure their
97. The failure to enact, train and/or enforce policies in these regards amounts
Dusman, Dr. Padasak and John Does 1-5, as they knew that employees of the district
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inappropriate sex-based harassment and that a failure to properly handle such matters
99. Further, the Chambersburg Area School District, Dr. Padasak, Dr. Dusman
and John Does 1-5 acted with deliberate indifference to the plight of Jane Doe, which
100. These failures, as well as the customs, policies and habits enacted and
followed by the Chambersburg Area School District, Dr. Padasak, Dr. Dusman and John
Dr. Dusman and all other defendants and Dr. Dusman with respect to Ms. Barnhart and
all other defendants, had knowledge of and acquiesced, condoned, permitted and/or failed
to end Mr. Hand’s and Ms. Barnhart’s on-going violations of Jane Doe’s rights, as
102. CASD is also liable for its failure to adequately screen Mr. Hand prior to
103. Adequate scrutiny of Mr. Hand’s background should have led CASD or
any reasonable administrator to conclude that Mr. Hand should not be coaching minor,
104. Moreover, CASD is liable for its failure to adequately discipline Mr. Hand
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105. The failure to adequately discipline Mr. Hand emboldened him to engage
107. The harm suffered by Jane Doe, being subjected to sexual assault, was
foreseeable, particularly given that there had been reports to CASD and John Does 1-5
regarding Mr. Hand engaging in inappropriate sexual behavior involving other students
108. Furthermore, upon information and belief, there had been reports and
rumors regarding Mr. Hand’s illicit sexual conduct with Jane Doe for months, yet CASD,
Dr. Dusman, Dr. Padasak and John Does 1-5 refused to timely involve the police
department.
109. Moreover, Jane Doe and her mother repeatedly reported Ms. Barnhart’s
111. Next, Mr. Hand, a state actor, acted with a degree of culpability that
minor.
112. Ms. Barnhart, a state actor, acted with a degree of culpability that shocks
the conscience by engaging in and encouraging other students to engage in the sex-based
113. Additionally, Dr. Dusman, a state actor, acted with a degree of culpability
that shocks the conscience by engaging in bullying, harassment and humiliation of Jane
Doe during the December 14, 2019 meeting, intentionally choosing not to immediately
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involve the police despite Dr. Padasak’s instruction to do so, subsequently betraying the
confidentiality promised to Jane Doe by revealing her identity to others within the school
114. Dr. Padasak, a state actor, acted with a degree of culpability that shocks
the conscience by intentionally choosing not to involve the police, intentionally choosing
not to properly supervise or monitor CASD’s handling of the reported sexual assault and
115. Furthermore, the conduct of John Does 1-5 in intentionally choosing to not
thoroughly investigate the prior allegations of Mr. Hand or to timely enlist the police or
116. Finally, the state actors, Mr. Hand, Dr. Dusman, Ms. Barnhart and John
Does 1-5, affirmatively used their authority in ways to create a danger and/or rendered
Jane Doe more vulnerable to danger than if they had never acted.
117. Indeed, students have a clearly established right not to be sexually abused
by their teachers or sexually harassed and bullied by students and teachers, and that
supervising school officials clearly violate students’ rights, as they did here, if their
118. These affirmative acts (or failures to act) were gross abuses of authority
119. Jane Doe has suffered physical and emotional harm and monetary loss and
is entitled to and seeks all available damages recoverable against CASD, Dr. Dusman,
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Dr. Padasak, Ms. Barnhart, Mr. Hand and John Does 1-5, including but not limited to the
following:
g. Past, present and future physical and mental pain, suffering and
inconvenience with respect to the above injuries;
120. Additionally, the conduct of Dr. Dusman, Dr. Padasak, Ms. Barnhart, Mr.
Hand and John Does 1-5 (who have all been named in their individual capacity as well)
reckless or callous indifference to the federally protected rights of others, including Jane
Doe.
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WHEREFORE, Plaintiff demands judgment jointly and severally for all available
121. Plaintiff incorporates Paragraphs 1 through 120 as if fully set forth herein.
122. There is an implied private right of action for monetary damages under
123. Jane Doe was subjected to sexual harassment in violation of Title IX.
Mr. Hand was convicted of the corruption of a minor and institutional sexual assault of
Jane Doe.
offensive and outrageous harassment, bullying and humiliation on the basis of her sex at
the hands of Ms. Barnhart and various students who were encouraged to do so by Ms.
Barnhart.
offensive that it severely limited Jane Doe’s ability to participate in or benefit from the
educational program - thus effectively denying her equal access to educational resources
and opportunities.
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127. As discussed herein at length, CASD had actual notice of the on-going
sexual harassment and intentionally failed to act when it had a clear duty to act to protect
128. One or more of John Does 1-5 were aware of Mr. Hand’s prior history of
130. Moreover, upon information and belief, one or more of John Does 1-5
were aware of, at the very least, rumors of Mr. Hand’s inappropriate relationship with
132. John Does 1-5 were appropriate persons that possessed the authority to
complaints.
133. Upon information and belief, Dr. Padasak and Dr. Dusman, the principal,
were aware of the sex harassment Jane Doe was experiencing, which was being
134. Dr. Padasak and Dr. Dusman possessed authority to supervise and
other corrective action, yet they intentionally failed to take any action to end Ms.
Barnhart’s conduct.
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135. The response to the harassment by the CASD, through Dr. Padasak, Dr.
Dusman and one or more of John Does 1-5, however, amounted to deliberate
indifference.
circumstances.
137. Further, their responses caused Jane Doe to be more vulnerable to the
continued harassment.
138. Jane Doe has suffered physical and emotional harm and monetary loss and
is entitled to and seeks all available damages recoverable against CASD, including but
g. Past, present and future physical and mental pain, suffering and
inconvenience with respect to the above injuries;
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amount in sufficient to compensate Plaintiff, together with interest, costs, attorney’s fees
139. Plaintiff incorporates Paragraphs 1 through 138 as if fully set forth herein.
140. Jane Doe participated in protected activity when she told Dr. Dusman and
others during the December 14, 2016 meeting that Mr. Hand had engaged in sexual
141. Jane Doe’s statements and identity became known broadly to the CASD
faculty, including its school board, administration, teachers and staff due to the
143. Jane Doe was humiliated during the December 14, 2016 meeting and after
she was identified by Dr. Dusman to the CASD faculty in intentional violation of the
promised confidentiality.
144. CASD teacher Ms. Barnhart humiliated, harassed and bullied Jane Doe by
engaging in gossip sessions and encouraging others to harass, humiliate and bully Jane
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reasonable person from engaging in protected activity such as opposing or reporting the
sexual harassment to which Jane Doe had been and was being subjected.
146. And, despite CASD’s principal Dr. Dusman and CASD Superintendent
Dr. Padasak having direct knowledge of Ms. Barnhart’s retaliatory conduct and on-going
harassment and bullying, nothing was done by either of them to stop it.
147. Jane Doe’s reporting of her sexual assault by. Hand and the gross
mishandling of the reported incident by CASD was the catalyst for Ms. Barnhart’s
wretched conduct and the on-going bullying and harassment of Jane Doe by Jane Doe’s
peers.
148. Accordingly, Jane Doe has suffered physical and emotional harm and
monetary loss and is entitled to and seeks all available damages recoverable against
g. Past, present and future physical and mental pain, suffering and
inconvenience with respect to the above injuries;
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WHEREFORE, Plaintiff demands judgment jointly and severally for all available
149. Plaintiff incorporates Paragraphs 1 through 148 as if fully set forth herein.
150. As described in detail throughout the complaint, Ms. Barnhardt and Mr.
Hand engaged in extreme and outrageous conduct that intentionally and/or recklessly
151. Jane Doe has suffered physical and emotional harm and is entitled to and
seeks all available damages recoverable against Ms. Barnhardt and Mr. Hand, including
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g. Past, present and future physical and mental pain, suffering and
inconvenience with respect to the above injuries;
152. Additionally, the conduct of Ms. Barnhardt and Mr. Hand warrants the
and outrageous and involved reckless or callous indifference to the rights of Jane Doe.
amount sufficient to compensate Plaintiff, together with interest, costs, attorney’s fees
Plaintiff v. Hand
153. Plaintiff incorporates Paragraphs 1 through 152 as if fully set forth herein.
154. As set forth in detail throughout this complaint, Mr. Hand engaged in the
illegal sexual intercourse and contact with Jane Doe when she was a 17-year-old high
school student.
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156. Mr. Hand’s conduct was unlawful, incapable of being consented to and
157. As a result of Mr. Hand’s illegal conduct, Jane Doe sustained physical,
158. Jane Doe has suffered physical and emotional harm and monetary loss and
is entitled to and seeks all available damages recoverable against Mr. Hand, including but
g. Past, present and future physical and mental pain, suffering and
inconvenience with respect to the above injuries;
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159. Further, Mr. Hand’s conduct was reckless, outrageous, willful, wanton,
amount sufficient to compensate Plaintiff, together with interest, costs, attorney’s fees
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