Image Source for the Cash Roses: TheHandmadeCharm on Etsy.com
Link to printable PDF of this report:
Link to printable PDF of this report:https://drive.google.com/file/d/1evmu5KP26VfGUiwIc0a0pjVTR7BUEIYv/view?usp=sharing
Contents, and Summary of Findings:
1. The Roof Repair Fundraiser - On May 1, 2018, Jackson Right to Life (JRTL), a 501 (c)(4) non-profit announced a “desperate need” to their donors for $16,000 for roof repairs on the building that they lease. That solicitation occurred one week after JRTL’s largest annual fundraiser dinner and auction (April 24, 2018), and two months after they had an in-person consultation with a contractor for the repairs (March 3, 2018).
2. The Landlord Beneficiary, Jerry Potts - Gerald (Jerry) Potts is the private landlord of the building leased by JRTL. His spouse, Kathleen (Kathy) Potts is JRTL’s Executive Director and Principal Officer. Unless the lease says otherwise, then Jerry Potts would be responsible for major building repairs, not the non-profit’s donors.
3. The Organizers and Promotors from Walberg’s Campaign - US Congress member, Tim Walberg’s principle campaign office is in the same building as JRTL. Walberg’s campaign staffers, Peter Baergen and Billie Fox Dawson helped create and promote the roof repair fundraiser online, and were publicly thanked for that by JRTL.
4. The “generous gift” from Barker Weber - On May 23, 2018, JRTL publicly thanked Timothy Walz and Daniel Weaver, executives at Barker Weber Insurance Agency, Inc. for “their generous gift”, which completed the roof fundraiser. Two weeks later, Kathy Potts started working as an agent for Barker Weber.
1) The Roof Repair Fundraiser:
At 6:23 AM, May 1, 2020, Jackson Right to Life posted to Facebook, a “DESPERATE need” solicitation for funds for roof repairs on the building that they lease. Later that morning, the post was shared by Tim Golding, co-owner of Covenant Construction Group, who had consulted with JRTL on those repairs two months earlier. Later, an expanded formal email was sent out to JRTL’s supporters, signed by the Executive Director, Kathy Potts, with a link to the crowd-funding webpage on the Anedot platform [Exhibit Below].
Email from Potts to JRTL donors soliciting $16,000 for roof, linked to the crowdfunding site
The tone of desperation in JRTL’s solicitations was undermined by two facts:
1) Two Months earlier, on March 3, 2018, the Covenant Construction Group posted on Facebook that they were already starting work on the roof of the Jackson Right to Life building. The contractor mentioned that the weather had finally cleared up enough to start doing that work. So that means that the contractor had already been communicating with Jackson Right to Life about that work for several weeks, at least [exhibit below].
Contractor post shows JRTL worked on the issue two months before ‘urgent’ fund solicitation.
1) Exactly one week earlier, on April 24, 2018, Jackson Right to Life hosted their annual Focus on Life, fundraising dinner, and silent auction. It is their largest annual fundraiser. So it is odd that they would be so desperate with another fundraiser immediately on the heels of their largest annual fundraiser. Walberg’s campaign purchased two tickets to JRTL’s fundraising dinner on April 9, the same day as his own campaign’s birthday fundraiser [exhibit below].
JRTL’s annual fundraiser was one week before their roof solicitation
Based on the contractor’s post, we know that Jackson Right to Life had already been working on their roof for months, so I suspect that it was discussed at some point during their April 24 Focus on Life fundraiser event too. Jackson Right to Life usually posts photos and videos of their annual fundraisers, but they did not post any photos from their 2018 event.
The key point: Jackson Right to Life’s “desperate” solicitation to their donors neglected to mention that the non-profit did not own that building. So, the donors to Jackson Right to Life should not have been burdened with those repair costs. Usually, the building’s landlord must pay for major repairs like that, unless there was a highly unusual stipulation in their lease that put that burden on the non-profit. The building’s landlord is Gerald (Jerry) Potts. Tim Walberg’s campaign pays rent to Jerry Potts for space in the same building. Kathy Potts, the Executive Director and Principal Officer of Jackson Right to Life since 2004, is the spouse of Jerry Potts.
I asked Phillip Berkemeier, Treasurer, of Jackson Right to Life if he, and the other Board Members approved using donor funds on the roof repairs. I also asked Berkemeier if the donor funds were disbursed to the roof contractor, to Jerry Potts, or to someone else. I have not received a reply at the time of this report [see list of questions in Appendix]
2) Jerry Potts – The Landlord Beneficiary:
Jerry Potts at Grand Rapids Right to Life fundraiser, where Ben Carson delivered the keynote
The building owned by Gerald (Jerry) Potts houses both Jackson Right to Life and Tim Walberg’s principle campaign office. It is located approximately 1,000 feet from the front door of Tim Walberg’s government office and also Jerry Potts’ accounting office [exhibit below].
Jackson County Parcel Viewer shows JRTL building owned by Gerald R Potts [with my markups]
Jerry Potts is a professionally licensed accountant in Michigan [exhibit below]. From 2008-2017, Gerald Potts’ accounting business was listed among the corporate sponsors on Jackson Right to Life’s website. In 2018, JRTL removed the list of all of their corporate sponsors from their website [see Archive.org, for web captures over time].
Gerald Potts is a Public Accountant, Professionally Licensed in Michigan
On November 3, 2008, Walberg paid his last rent check to Potts (until June 2010). The next day Walberg lost the election [exhibit below].
Walberg’s campaign paid rent to Gerald Potts the day before the 2008 general election
Jerry Potts is not a distant, disinterested landlord with regard to the activities of Jackson Right to Life, or of Tim Walberg’s campaign. He regularly attends Right to Life events throughout the state [exhibit page 5], and shortly after receiving Walberg’s last rent check in 2008, Jerry Potts wrote a letter to the Jackson Citizen Patriot newspaper, expressing gratitude and praise to Walberg’s spouse and to his campaign staffers by name, who he had gotten to know well over that time [exhibit below].
In that letter, Jerry Potts praised the political position that Walberg took, opposing the 2008 Wall Street banks bail out (H.R. 1424). Potts said, “He rightly knew those responsible should clean up the mess, not taxpayers.” Very well, if Jerry Potts believed that taxpayers were not responsible for cleaning up the mess of Wall Street Bankers, then likewise, donors to his spouse’s nonprofit should not be responsible for cleaning up his mess as a landlord.
Jerry Potts wrote this letter after receiving Walberg campaign’s last rent payment in 2008
3) The Organizers and Promotors from Walberg’s Campaign:
There are no delineations between Walberg’s Campaign and Jackson Right to Life’s activities. Walberg’s campaign office stays operational with salaried staff all year-round. Walberg’s campaign signs are always visible from outside of the Jackson Right to Life building, either on the front lawn, displayed from the front windows, or affixed to the front door. In the months leading up to elections every year, the front lawn of Jackson Right to Life pops with an array of pickets for other right-wing candidates [exhibit below].
Campaign signs displayed outside Jackson Right to Life from 2008 to 2020.
The interior of the building is no less overtly political as the outside. There is not one direction for a person to turn their eye - above door entryways, across windows and every wall – without seeing Walberg campaign signs. Yet, Kathy Potts described the building as a, “safe and secure shelter”, and “This is where we meet worried mothers with unborn children and others seeking assistance with pro-life needs.”That description evoked a soothing place of refuge, but that is not at all what we see of the building’s decor. Also the term “shelter” comes with specific, necessary responsibilities for non-profits, which JRTL is not equipped for.
Photos from inside the Jackson Right to Life nonprofit building from 2008 to 2020
Jackson Right to Life’s roof fund solicitation on May 1, 2018, 6:23 am, linked to a crowd-funding webpage, hosted by Anedot, an exclusively Republican campaign fundraising vendor. At 6:41 am, the same day, Grassroots Jackson reposted that solicitation. Then, at 8:32 am, that same day, JRTL posted a reply, thanking Peter Baergen and Billie Fox Dawson [exhibit below].
Initial solicitation for roof funds on May 1, 2018, thanking Peter Baergen and Billie Fox Dawson
Staffer Spotlight: Peter Baergen
In 2013, when Peter Baergen was 16 years old, MLive news wrote an article about his creation of a viral Twitter campaign hashtag, #ScheduleIt, to pressure Michigan state legislators to vote on an anti-abortion insurance bill before the end of that legislative year.
Link to article: https://www.mlive.com/politics/2013/12/scheduleit_right_to_life_of_mi.html
Throughout his teen years, Peter Baergen was involved in a lot of JRTL’s Jackson Students for Life events. That teen group was created by Kathy Potts for political purposes. Potts described that she formed it out of her concern with the 2008 election outcome, because as Potts said, “We needed something to counter that,”. Quote from mlive article: https://www.mlive.com/news/jackson/2010/12/group_of_area_high_school_and.html
Jackson Students for Life operates and fundraises as an assumed name for Jackson Right to Life [per Michigan LARA filings]. In 2014, Peter Baergen joined other volunteer children at the Jackson Right to Life building to canvass the city on behalf of Tim Walberg’s and Mike Shirkey’s political campaigns [attached image]
Baergen campaigned with other children for Walberg & Shirkey from the JRTL building
In 2015, at 18 years old, Peter Baergen was hired as the Campaign Manager for Bill Jors for Mayor of the City of Jackson, and again gathered volunteer children to run canvassing operations from the Jackson Right to Life building [attached image].
Peter Baergen, Campaign Manager for Bill Jors, with child canvassers at JRTL building
In 2016, at 19 years old, Peter Baergen was hired as Walberg’s Deputy Campaign Manager, and that same year performed in a Walberg TV advertisement as a vocational trainee, led by Walberg through a tooling facility, for the message favoring job training over college education [image below].
Peter Baergen, deputy campaign manager, acted as a vocational trainee in Walberg TV ad
Link to Walberg’s campaign TV ad: https://www.youtube.com/watch?v=Qwl1BXAH2eI
Peter Baergen founded and co-owned the campaign business, Wilberforce Strategies, and both Baergen and his co-owner publicly opposed the election of Donald Trump on social media. In 2019, Baergen quit politics to work full time on disaster relief evangelism with Franklin Graham’s charity, Samaritan’s Purse.
Staffer Spotlight: Billie Fox Dawson
In January 2018, Billie Fox Dawson founded the business, In to Amen Tactics, to produce graphics, messaging, and digital outreach for non-profits and political campaigns. On March 15, 2018, Tim Walberg’s official government Twitter account tested a new constituent engagement gimmick, telling Twitter users to submit questions about the Tax Cuts & Jobs Act using the hashtag #AskTim. On Twitter, the most engaged person in that activity, by far, was Billie Fox Dawson. She tweeted three friendly questions to Walberg (at 3:43pm, 3:44pm, & 4:02pm), and shortly thereafter, Chris Dawson tweeted a question (at 4:15pm), who had only Tweeted twice before in the previous two years, and never again since. Chris Dawson’s Tweet to Walberg received a single “like”, from Billie Dawson [image below].
Chris Dawson’s #AskTim tweet, liked by Billie Fox Dawson
During the #AskTim activity, Billie Fox Dawson tweeted defensive replies to constituents who criticized Walberg. On March 16, Walberg Tweeted only two video responses in the entire #AskTim activity. One of them was to Dawson’s question [Exhibit below], and the second one was to another constituent’s more challenging question. One month after that #AskTim activity, on April 17, 2018, Walberg’s campaign made its first payment to Billie Fox Dawson for “Advertising – internet”. It is a violation of House ethics for a Congress member to use campaign funds to pay for services related to government work, or visa-versa. Again, that #AskTim activity was on Walberg’s government Twitter account. Walberg has never done another #AskTim.
Dawson participated in this #AskTim gimmick one month prior to first payment from campaign
On March 29, 2018, Billie Fox Dawson was quoted in an MLive news article on behalf of the group, “Grassroots Jackson” regarding a petition to push Michigan’s DNR to allow a large Christian cross structure to stay in place at a state park in Grass Lake. Grassroots Jackson was founded in December, 2016 as nothing more than a PO Box. The group then started Facebook page on May 5, 2017 mostly to just repost local conservative links and news stories. The “about” section on the Facebook page said that they were “Paid for with regulated funds”, and that they were, “not authorized by any candidate or candidate committee”. There is no filing in Michigan’s LARA system, nor any Campaign filings related to Grassroots Jackson, nor any public information identifying the leadership behind the group. On May 1, 2018, JRTL’s roof fundraiser solicitation was reposted by Grassroots Jackson 18-minutes after it was initially posted by Jackson Right to Life.
On June 15, 2018, Billie Fox Dawson received her first salary payment from Walberg’s campaign, and the very next day, Jackson Right to Life thanked Dawson for creating new graphic designs for the organization’s Facebook profile and cover pictures [exhibit below].
JRTL posted this the day after Dawson’s first salary payment from Walberg’s campaign
Billie Fox Dawson continues to do both government and campaign political work. In 2018, Dawson created ads and ran social media for Sarah Lightner’s campaign. On January 7, 2019 Dawson was hired by Walberg’s district government office as “Constituent Relations Spec”, while simultaneously remaining a year-round salaried employee on Walberg’s campaign.
Most recently, from June through October 2020, Billie Fox Dawson’s did marketing and social media work for Craig Pappin for District Judge’s campaign. In July 2020, Jackson Right to Life began to display large Craig Pappin campaign signs in front of their building. Craig Pappin’s campaign signs are modeled exactly off of Walberg’s campaign signs, just with different colors [exhibit on page 9].
Baergen and Dawson’s Work Together
The paths of Peter Baergen and Billie Fox Dawson had crossed a few times before they formally joined together on the campaign committee for Teri Aiuto, Republican for State Representative. Their work for the Aiuto Campaign coincided with the kickoff of JRTL’s roof fundraiser. On April 29, 2018, Baergen’s company, Wilberforce Strategies was paid by Aiuto’s campaign for “In House Design and Website”. The fundraising platform used on Aiuto’s website was Anedot, the same fundraising platform used for the JRTL roof. On May 1, the day that the roof fundraiser kicked off, Dawson’s company, In to Amen Tactics was paid by Aiuto’s campaign for, “in house graphic design-social media” [exhibit below].
Baergen and Dawson worked on Teri Aiuto’s campaign at same time as JRTL’s roof fundraiser
Baergen and Dawson’s professional skills for design, social media, and fundraising, used in Teri Aiuto’s campaign, were all applicable simultaneously in the creation of Jackson Right to Life’s roof fundraiser.
Neither Peter Baergen, nor Billie Fox Dawson stood to personally benefit, nor did they appear to receive any financial compensation for the work that they did on JRTL’s roof fundraiser. They both appear to be very idealistic and trusting of the people that they have worked for, and there is no reason to suspect that they knew of any potential wrongdoing on the part of the leadership of Jackson Right to Life with regard to the roof fundraiser.
4) The “Generous Gift” from Barker Weber:
From 2008 to 2017, Jackson Right to Life listed their corporate sponsors on their website, which included Kathy Potts’ employer at the time, Anderson Insurance Agency Inc. In 2018, the list of corporate sponsors was removed, and not put back [see Archive.org]. The removal seems to have coincided with Kathy Potts departure from that employer.
JRTL announced the completion of their roof fundraiser on May 22, 2018 (10:21 pm), on Facebook. That night, (12:16 am), Timothy Walz, an executive at Barker Weber Insurance Agency, Inc., posted a comment of congratulations. The next day, May 23, 2018 (7:56 pm), JRTL responded, thanking Daniel Weaver (President of Barker Weber) and Walz by name for completing the fundraiser with a, “generous gift”. JRTL also linked to the Barker Weber website in their comment [exhibit below].
Just before Kathy Potts started work at Barker Weber, they topped off her roof fundraiser
About two weeks later, Kathy Potts began working for Barker Weber Insurance Agency.
Kathy Potts began working for Barker Weber right after they donated to JRTL’s roof fundraiser
I asked Walz and Weaver if their donation to the roof fundraiser was a corporate tax-deduction [see questions in Appendix]. The flyer for the Focus on Life fundraiser dinner [exhibit page 4], said that Corporate reservations to the fundraiser “may be tax-deductible”. So, if Barker Weber’s donation was tax deductible, then essentially our taxes went to the personal enrichment of Jerry Potts, and to a new roof for Walberg’s campaign headquarters.
Were Any Laws Broken
· All legal analysis was decidedly outside the scope of this report. I am an amateur researcher, blogging about things I observed on public platforms. I am not a lawyer.
· Kathy Potts and Jerry Potts had the most knowledge and control over the scope of the roof fundraiser, and also personally benefitted financially from those non-profit funds. Jerry Potts benefitted from having the non-profit donors pay for repairs on his private property.
· Tim Walberg indirectly benefitted from his longtime relationship with Kathy Potts and Jerry Potts. He got a new roof for his campaign headquarters. Walberg had some knowledge and responsibility over the activities of his staffers. There were several opportunities for him to intervene. Jackson Right to Life would have coordinated that construction work with him as a fellow tenant, during the 2018 general election period.
· The donors to Jackson Right to Life were misled about the “desperate” need for the roof funds, and the description of the building as a, “shelter” for “worried mothers”, which it is not. The donors were not informed that their money would enrich the building’s landlord, and cover his neglect of repairs on his private property.
Areas for Further Inquiry
· Jackson Right to Life has never filed a full IRS Form 990, which would publicly disclose their total annual receipts, disbursements, and holdings. Instead, each year they file a short 990-N (e-Postcard), in which they claim that their gross annual receipts are less than $50,000. Frankly, I do not believe that. In 2018, JRTL would easily have received more than $50,000 from three activities: 1) the roof fundraiser; 2) the Jackson Students for Life trip to the March for Life in Washington, DC; and 3) the Focus on Life benefit dinner and silent auction. There should be a public audit of JRTL’s books.
November 2, 2020
APPENDIX: Questions for Fundraiser Participants
On the morning of November 2, 2020, I sent the following messages, and questions to the individuals involved in Jackson Right to Life’s 2018 roof fundraiser. As stated in the letter, I will honor any and all wishes for anonymity in their responses, or as permitted, I will include their responses in a follow-up report.
Subject: Questions About Jackson Right to Life’s Roof Fundraiser in 2018
Good Morning [name of fundraiser participant],
My name is Steven Meyer, and I have drafted a report for my blog about the fundraiser from 2018, for the new roof on the Jackson Right to Life building. I became interested in that event while researching our Congressman, Tim Walberg. I am seeking to include your comments, and any records or information that you have on that subject in my report, or in a follow-up report on my blog, www.TakeCareTim.com. I will honor your preferences, with respect to any information that you provide. Based on your preferences, I will either credit you by name, or anonymously, or keep your responses entirely on background. To date, the information that I have gathered for this report has been entirely through public sources. I intend to publish my initial report this week.
These are my questions for you [per addressee below]:
Kathy Potts (Executive Director, Principle Officer, former President of JRTL, 2004 - present)
[Note: emailed to Potts’ public JRTL email and the organization’s “info” email address]
1) Did Jackson Right to Life’s board of directors approve the decision to solicit donors for the roof repair fundraiser? Did Jackson Right to Life’s Treasurer, Phillip Berkemeier sign off on paying out those roof repair costs using donor funds?
2) Was there any discussions with the other tenants, or the landlord, Gerald Potts, about who was responsible for paying for the roof repairs? Does Jackson Right to Life’s lease designate the non-profit as responsible for major structural repairs? Was the landlord aware of the plans to hold a special non-profit fundraiser for those repairs on his privately owned building?
3) Did Jackson Right to Life’s donors contribute more than the $16,000 that you solicited for the new roof? What was the total gross for the roof fundraiser?
4) How much money did Timothy Walz and Daniel Weaver contribute in the roof fundraiser? Was their contribution designated as an official corporate donation from Barker Weber? Was their contribution designated as tax-deductible? Did you discuss the roof fundraiser with them during your hiring process at Barker Weber?
5) Was the contractor’s final invoice for the roof repairs higher or lower than the gross total from the fundraiser? What was the total cost of the contractor’s work?
6) Were the roof repairs discussed during the 2018 Focus on Life event, the week before the roof fundraiser kicked off? What was the gross total raised at Jackson’s 2018 Focus on Life event from donations, dinner tickets, and the auction?
7) How much in annual gross receipts did Jackson Right to Life raise in 2018? Are the itemized financial records for Jackson Right to Life available for the public to look at? Can you show me where to find those?
8) Did you solicit help, or provide direction on the fundraiser to the staff of the Walberg for Congress campaign?
Gerald Potts (Landlord of JRTL / Walberg for Congress building, 2006-2008, 2010-present)
[Note: emailed to Potts’ public accounting office email address]
1) As the building landlord, when did you become aware about the roof repair fundraiser that Jackson Right to Life conducted for your property?
2) Don’t you, as the building’s landlord, have the responsibility for major repairs like that? Did the tenants of the building ever discuss the need for the new roof with you? Why should Jackson Right to Life’s donors take on the financial burden of those repairs?
3) Does the lease agreement place the burden of major repairs for the building on Jackson Right to Life? Is the lease agreement for Jackson Right to Life available for the public to see? Could you provide a copy of that for me?
4) What was the total gross for Jackson Right to Life’s roof fundraiser?
5) As the landlord, were you ever involved in discussions with Tim Golding of the Covenant Construction Group, or with any other potential contractors for the roof repairs? What was the difference in amount between the money raised for the roof repairs and the final invoice for the roof repairs? Which contractor did the roof repairs for the Jackson Right to Life building?
6) Does Jackson Right to Life pay rent to you? Have you ever been the recipient of any other funds from Jackson Right to Life?
Phillip Berkemeier (Director/Treasurer of Jackson Right to Life, 2009 – 2011, 2015 - present)
[Note: emailed to Bekemeier’s public law office email address]
1) As treasurer, when did you become aware of the plans for Jackson Right to Life to conduct a fundraiser for the building’s roof repairs?
2) Did you and the other Jackson Right to Life board members approve the decision to solicit donors for the roof repair funds?
3) As treasurer, did you sign off on paying out those donor funds for the roof repairs? Who did Jackson Right to Life pay those funds to: the contractor, the landlord, or someone else?
4) How much in donor funds were paid out for the roof repairs?
5) Was the Jackson Right to Life building’s landlord, Gerald Potts involved in the discussion with the tenants of the building, or the non-profit board members, about who was responsible for paying for major repairs on the building?
6) Did the building’s landlord agree that the nonprofit donors were the responsible party to pay for major repairs on his property?
7) Are the financial records for Jackson Right to Life available for the public to look at? As treasurer, can you show me where to find those?
8) Are Jackson Right to Life’s monetary holdings kept in more than one account? Does the board need to approve any and all of Jackson Right to Life’s financial disbursements?
Tim Walberg (principal campaign office inside JRTL building 2006-2008, & 2010-present)
[Note: submitted message through the Contact portal on Walberg for Congress Website]
1) Were you involved in the discussions or the planning with your fellow tenants, for the major roof repairs that occurred on your campaign office’s building in 2018?
2) Did you ever discuss the need for major repairs with your building’s landlord, Gerald Potts?
3) When did you become aware that your co-tenant, Jackson Right to Life would conduct a fundraiser for those roof repairs?
4) Were you aware that your paid campaign staffers were involved in the organizing and promotion of Jackson Right to Life’s roof fundraiser? Did you or your campaign leadership direct their involvement in that?
5) Why did your landlord not pay for those major roof repairs?
Timothy Walz and Daniel Weaver (Executives at Barker Weber Insurance Agency, Inc.)
[Note: emailed to their two public insurance company email addresses]
1) When did you become aware of the roof fundraiser at Jackson Right to Life?
2) Was your contribution to the fundraiser made on behalf of Barker Weber, or on behalf of yourselves as an individuals?
3) How much money did you, or Barker Weber contribute to that fundraiser?
4) Was your contribution to the Jackson Right to Life roof fundraiser tax deductible?
5) Was your contribution made before or after the decision to hire the Executive Director of Jackson Right to Life at Barker Weber? Was the roof fundraiser discussed at all during that hiring process?
Peter Baergen (Walberg campaign staffer, 2016, 2018)
[Note: attempted, but unable to find public contact info for Peter Baergen for this report]
Billie Fox Dawson (Walberg campaign staffer & government staffer, 2018 – present)
[Note: emailed to Dawson’s In To Amen Tactics address, & received delivery error. Unable to find alternate public contact info for Dawson to send these questions.]
1) What was your involvement in the roof fundraiser conducted by Jackson Right to Life in May 2018? When did you first become aware of the plans for that fundraiser? Did leadership at Jackson Right to Life or the Walberg campaign direct your involvement in the roof fundraiser?
2) Were you aware of any individuals who stood to personally profit from Jackson Right to Life’s roof fundraiser?
3) Was anyone else from the Walberg for Congress campaign involved in the roof fundraiser with Jackson Right to Life?
4) Does Jackson Right to Life and the Walberg for Congress campaign collaborate or share resources on a regular basis?
Sincerely, Steven Meyer [attached my contact info]
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