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Case CaptionCase No.Topics and IssuesAuthorCitation / CountyDecidedPostedWebCite
State v. Wheeler 1-25-09Aggravated Robbery; R.C. 2911.01(A)(3). Defendant-appellant's conviction for aggravated robbery was supported by sufficient evidence.MillerAllen 12/15/2025 12/15/2025 2025-Ohio-5572
State v. Johnson 1-25-04Self-Defense; Defense of Another; R.C. 2901.05(B)(1); R.C. 2901.05(B)(2); R.C. 2901.09(B). The jury did not clearly lose its way and create a manifest miscarriage of justice in resolving conflicts in the evidence by concluding Johnson's actions were not in self-defense or in defense of another. The trial court did not commit plain error in failing to give an unrequested jury instruction on a presumption of self-defense. The trial court did not commit plain error in failing to give an unrequested jury instruction on aggravated assault as an inferior-degree offense to felonious assault.MillerAllen 12/15/2025 12/15/2025 2025-Ohio-5571
In re E.A. 3-25-02Notice; Legal Custody Hearing; Right to Counsel; Waiver. Mother-appellant had proper notice of the scope of the hearing and, thus, her due process rights were not violated. The trial court did not err by not appointing counsel for father-appellant where his actions indicated that he waived his right to counsel.MillerCrawford 12/15/2025 12/15/2025 2025-Ohio-5573
Adams v. Adams 14-24-41Calculation of Child Support; Imputing Potential Income for Parent Who is Voluntarily Unemployed; Award of Spousal Support; Abuse of Discretion. The trial court did not abuse its discretion by determining that the defendant-appellant is voluntarily unemployed and imputing potential income for him. The trial court found that the defendant-appellant left his employment eight months after the plaintiff-appellee filed a complaint for divorce, and that the defendant-appellant had an ongoing responsibility to support the plaintiff-appellee and their child. The trial court did abuse its discretion by ordering the defendant-appellant to pay spousal support. The record shows that the magistrate carefully considered each of the factors listed in R.C. 3105.18(C)(1) in fashioning the award of spousal support. The judgment of the trial court is affirmed.ZimmermanUnion 12/15/2025 12/15/2025 2025-Ohio-5574
State v. Kelly 8-25-06Consecutive Sentences. Trial court did not err in imposing consecutive sentences when the required findings were made and the record supported those findings.WillamowskiLogan 12/8/2025 12/8/2025 2025-Ohio-5461
State v. Compton 1-25-17Manifest Weight of the Evidence; Felonious Assault. The defendant-appellant’s felonious assault conviction for drug possession is not against the manifest weight of the evidence.ZimmermanAllen 12/8/2025 12/8/2025 2025-Ohio-5459
State v. Taylor 5-25-04"Knowing" possession of drugs; Sufficiency of the evidence; Manifest weight of the evidence; Ineffective assistance of counsel; Failure to file a motion to suppress. The judgment of conviction and sentence is affirmed.WaldickHancock 12/8/2025 12/8/2025 2025-Ohio-5460
State v. Giles 14-25-16Felony sentencing; R.C. 2953.08(G)(2). The trial court’s imposition of maximum, consecutive sentences is not contrary to law because the trial court did not improperly consider “other acts” evidence—namely, letters from alleged former victims about uncharged conduct and the facts of the dismissed rape charges—when imposing the defendant-appellant’s sentence.ZimmermanUnion 12/8/2025 12/8/2025 2025-Ohio-5465
State v. Stackhouse 13-25-06Manifest Weight of the Evidence; Drug Possession; Constructive Possession; Admission and Exclusion of Evidence; Motion in Limine; Third-Party Guilt; Consecutive Sentences; R.C. 2929.14(C)(4)(c). The defendant-appellant’s convictions for drug possession are not against the manifest weight of the evidence where his constructive possession of the drugs was supported by their discovery in plain view, his on-scene admission of ownership, and his statement about recent cocaine use. The trial court did not abuse its discretion by excluding evidence of a third party’s prior criminal conviction because it was too remote and failed to sufficiently connect her to the crimes at issue. The trial court's imposition of consecutive sentences is supported by the record, as the defendant-appellant’s lengthy criminal history and the seriousness of the offenses demonstrate that the sentences are necessary to protect the public.ZimmermanSeneca 12/8/2025 12/8/2025 2025-Ohio-5464
Versa-Pak, Ltd. v. Sispack Corp. 10-25-10Civ.R. 4.1; Service by certified mail; Rebuttable presumption of valid service. The trial court did not err in overruling the defendant's motion to vacate the default judgment entered against it, on the basis of the defendant's claim that it had not been validly served with the complaint.WaldickMercer 12/8/2025 12/8/2025 2025-Ohio-5462
State v. Baker 11-25-02Possession of marihuana; Definition of marihuana; Definition of hemp; R.C. 3719.01(M); R.C. 928.01(C); Weighing of marihuana; Admissibility of expert testimony; Failure to preserve sample of drugs used for testing; Trial court's decision on sending exhibits into the jury room; Evidence proving "knowing" possession; Motion for a new trial on basis of juror misconduct. The judgment of conviction and sentence is affirmed.WaldickPaulding 12/8/2025 12/8/2025 2025-Ohio-5463
Randall E. v. Courtney B. 7-25-04Legal Custody; Manifest Weight. Award of legal custody to grandparents was supported by the evidence.WaldickHenry 12/1/2025 12/1/2025 2025-Ohio-5376
Dinh v. Goble 14-25-19Divorce; Spousal Support; Best Interests; Plain Error. Trial court did not abuse its discretion in divorce proceeding.WaldickUnion 12/1/2025 12/1/2025 2025-Ohio-5375
State v. Havron 5-25-17Tolling of a Community-Control Sentence for Absconding; R.C. 2929.15(A)(1). More than eight years after the trial court issued a bench warrant alleging that the defendant-appellant had failed to comply with the conditions of her supervision, the defendant-appellant filed a motion to lift the bench warrant. Without any legal analysis, the trial court denied the defendant-appellant’s motion. Since the trial court never made a determination that the defendant-appellant had absconded, the defendant-appellant’s five-year term of community control was never tolled such that the trial court lacked authority to take further action because the original term of community control had long since expired. The judgment of the trial court is reversed.ZimmermanHancock 12/1/2025 12/1/2025 2025-Ohio-5373
State v. Frericks 10-25-08Right to Counsel; Ineffective Assistance of Counsel; Consecutive Sentence; R.C. 2929.14(C)(4). Defendant-appellant’s right to counsel was not violated because the hearing at issue was not a critical stage of the criminal proceedings. Defendant-appellant failed to demonstrate that he received ineffective assistance of counsel. The trial court’s decision to run the sentences for each conviction consecutively was not contrary to law.MillerMercer 12/1/2025 12/1/2025 2025-Ohio-5374
State v. Greene 14-25-05Void Sentencing Doctrine; Voidable Judgment; Res Judicata. Defendant-appellant's appeal, arguing that the trial court erred when it imposed a previously-ordered suspended prison sentence because the previously-ordered sentence was contrary to law, was barred by res judicata.MillerUnion 11/24/2025 11/24/2025 2025-Ohio-5279
State v. Butler 14-25-18Offenses Committed Prior to March 22, 2019; R.C. 2929.14(A)(1)(b); Sentence is Clearly and Convincingly Contrary to Law; R.C. 2953.08(G)(2). The defendant-appellant’s sentence is clearly and convincingly contrary to law since the trial court imposed an indefinite prison term for a first-degree-felony offense committed prior to the enactment of the Reagan Tokes Law. The judgment of the trial court is reversed and the matter remanded for resentencing.ZimmermanUnion 11/17/2025 11/17/2025 2025-Ohio-5176
State v. Clark 8-25-04Intervention in Lieu of Conviction; R.C. 2951.041(F); Plain Error. For Plain error to apply, the trial court must have deviated from a legal rule; the error must have been an obvious defect in the proceeding; and the error must have affected a substantial right. R.C. 2951.041(F) governs the process of addressing an offender's failure to comply with the terms or conditions of his or her ILC. If an offender fails to comply with the terms or conditions of his or her intervention in lieu of conviction, the trial court may continue the period of the ILC, continue the ILC with additional terms or conditions, or may enter a finding of guilt and impose a sanction.WillamowskiLogan 11/17/2025 11/17/2025 2025-Ohio-5173
State v. Miller 2-25-05R.C. 2929.11; R.C. 2929.12; Appeal of maximum consecutive sentences. Appellate court lacks jurisdiction to review application of R.C. 2929.11 and 2929.12. Appellate court must affirm if 2929.11 and 2929.12 are considered and the sentence is within the statutory range.WillamowskiAuglaize 11/17/2025 11/17/2025 2025-Ohio-5170
In re S.D. 6-25-05Due Process; Permanent-Custody Hearing. The trial court did not err by proceeding with the permanent-custody hearing in the absence of mother-appellant.MillerHardin 11/17/2025 11/17/2025 2025-Ohio-5172
Stone v. Humphress 5-25-06Contempt. Trial court erred by finding that appellee was not in contempt of court given the trial court's prior final decisions that were not appealed.WaldickHancock 11/17/2025 11/17/2025 2025-Ohio-5171
State v. Bonifas 15-25-02Sufficiency of Evidence; Manifest Weight; Aggravated Menacing. Defendant-appellant’s conviction for aggravated menacing is supported by sufficient evidence and is not against the manifest weight of the evidence.MillerVan Wert 11/17/2025 11/17/2025 2025-Ohio-5177
State v. Loy 13-25-09Manifest Weight of the Evidence; Motion to Sever; Consecutive Sentences. The convictions were supported by credible evidence and does not indicate that the jury lost its way creating a manifest injustice. As such, the convictions were not against the manifest weight of the evidence. The trial court's decision not to sever the charges was not in error when no prejudice was alleged. Trial court made the required findings to impose consecutive sentences and the evidence supported the findings.WillamowskiSeneca 11/17/2025 11/17/2025 2025-Ohio-5175
Piacentino v. Heinz 9-24-51R.C. 2505.02(B)(4). Final appealable order; Preliminary Injunction. The trial court's judgment entry denying defendant-appellant's petition for a preliminary injunction is not a final, appealable order.MillerMarion 11/17/2025 11/17/2025 2025-Ohio-5174
State v. Averesch 12-24-05Motion to Suppress; Identified Citizen Informant; Reasonable Articulable Suspicion; Forfeiture; Excessive Fines. Motions to suppress present mixed questions of law and fact. When a dispatcher's information comes from an informant, courts must examine the tip to examine its weight and reliability. Informants fall into three general categories: (1) anonymous informants; (2) known informants; and (3) identified citizen informants. Information from an identified citizen informant is generally considered to be more reliable. The forfeiture of a vehicle pursuant to R.C. 4511.19(G)(1)(c)(v) is a fine used to punish an offender. To determine whether an in personam forfeiture under this provision is excessive, courts are to examine whether the forfeiture is grossly disproportional to the gravity of the offense.WillamowskiPutnam 11/10/2025 11/10/2025 2025-Ohio-5106
State v. Hesseling 1-24-34Major Drug Offender Specification; R.C. 2929.14(B)(11); Drug Trafficking; Drug Possession; Constructive Possession; Ineffective Assistance of Counsel; Accomplice Jury Instruction; R.C. 2923.03(D). The trial court did not err in imposing a prison term for each of the major drug offender specifications. Defendant-appellant's convictions were supported by sufficient evidence and were not against the manifest weight of the evidence. Defendant-appellant was not denied effective assistance of counsel due to his trial counsel failing to file a motion to suppress and failing to object to certain alleged hearsay statements. The trial court did not commit plain error in failing to provide a cautionary instruction pursuant to R.C. 2923.03(D) concerning accomplice testimony.MillerAllen 11/10/2025 11/10/2025 2025-Ohio-5102
Bigler v. Haynes 9-25-10Appellate Rules of Procedure; Record; Appellate Review; Transcript. Appellate review is strictly limited to the matters contained in the record. The appellant has the burden of demonstrating that the trial court erred on appeal. App.R. 16 requires that the appellant provide arguments to substantiate the assignments of error raised on appeal.WillamowskiMarion 11/10/2025 11/10/2025 2025-Ohio-5105
State v. Bolen 6-25-12Allied Offenses; Consecutive Sentences; Crim.R. 11 Colloquy; Guilty Plea. In order to impose consecutive sentences, the trial court must make the findings required by R.C. 2929.14(C)(4). Allied offenses of similar import are to merge at sentencing. Merger is not required where offenses are dissimilar in import; were committed separately; or committed with separate animus. In examining a Crim.R. 11 colloquy to determine if a plea was knowingly, voluntarily, and intelligently entered, a reviewing court examines whether (1) the trial court has complied with the relevant provisions of the rule; (2) whether any failure to fully comply with the rule requires a demonstration of prejudice to vacate the plea; (3) whether the defendant has demonstrated prejudice where required for a failure to comply with Crim.R. 11.WillamowskiHardin 11/10/2025 11/10/2025 2025-Ohio-5104
State v. Horton 1-24-62Motion to Suppress; Consent to Search; Ineffective Assistance of Counsel; Custodial Interrogation. The trial court did not err in denying defendant-appellant's motion to suppress the drugs found during the search of his home because his consent to the search was freely and voluntarily given. Trial counsel was not ineffective in failing to timely file a motion to suppress on Miranda grounds because defendant-appellant did not show such a motion had a reasonable probability of success. Defendant-appellant's drug possession conviction was not against the manifest weight of the evidence.MillerAllen 11/10/2025 11/10/2025 2025-Ohio-5103
State v. Shipley 14-25-02Sufficiency of the Evidence; Manifest Weight of the Evidence; Robbery; R.C. 2911.02(A)(3); Theft; R.C. 2913.02(A)(1); Force; Prosecutorial Misconduct; Witness Vouching; Commenting on Decision Not to Testify; Misstatement of Law. The defendant-appellant’s robbery conviction is based on sufficient evidence and is not against the manifest weight of the evidence. The defendant-appellant was not deprived of a fair trial due to prosecutorial misconduct.ZimmermanUnion 11/3/2025 11/3/2025 2025-Ohio-5001
In re R.P. 1-25-05Restitution; R.C. 2152.20; Receiving Stolen Property; 2913.51(A). The trial court did not abuse its discretion in determining the amount of restitution suffered by the victim as a direct and proximate result of appellant's delinquent act.MillerAllen 11/3/2025 11/3/2025 2025-Ohio-4997
In re Adoption of T.M.Z. 13-25-07CONTESTED ADOPTION; R.C. 3107.01(A); NO CONTACT WITH MINOR; JUSTIFIABLE CAUSE; MANIFEST WEIGHT OF THE EVIDENCE; R.C. 3107.161(B); BEST-INTEREST DETERMINATION; ABUSE OF DISCRETION; ADMISSION OF EVIDENCE; R.C. 3107.031; HOME STUDY. The record does not contain credible evidence that the biological mother intentionally concealed the minor child’s whereabouts. Therefore, the trial court’s determination that the biological father-appellant was without justifiable cause for his failure to have contact with the child during the one-year period immediately preceding the filing of the adoption petition is not against the manifest weight of the evidence. The record reflects that the trial court considered the factors set forth in R.C. 3107.161(B) in making its best-interest determination. Thus, the trial court did not abuse its discretion in granting the petitioner-stepfather’s adoption petition. The trial court appointed an assessor to conduct a home study of the petitioner-stepfather’s home. The purpose of a home study is to ascertain whether a person seeking to adopt a minor is suitable to adopt. The trial court did not abuse its discretion by admitting the assessor’s report filed in compliance with R.C. 3107.031.ZimmermanSeneca 11/3/2025 11/3/2025 2025-Ohio-5000
State ex rel. Pelmear v. Henry Cty. Land Reutilization Corp. 7-25-05Open Meetings Act; R.C. 121.22; Discovery; Civ.R. 26(B); Civ.R. 34; Discovery Sanction; Admission of Evidence; Injunctive Relief; Burden of Proving an Open Meetings Act Violation. The trial court did not abuse its discretion by denying the relator-appellant’s objection to the respondents-appellees’ reliance on its exhibits or by admitting the respondents-appellees’ exhibits at trial because the relator-appellant failed to use the proper procedural tools under Civ.R. 34 to obtain the documents. Because the relator-appellant failed to satisfy his burden of proving that the respondents-appellees violated Ohio’s Open Meetings Act under R.C. 121.22(F), the trial court did not abuse its discretion by denying the relator-appellant’s requested injunctive relief.ZimmermanHenry 11/3/2025 11/3/2025 2025-Ohio-4998
In re G.N. 10-24-09 & 10-24-10Permanent Custody; Best Interest; Manifest Weight of the Evidence; In Camera Interview; Evidence; Hearsay; Kinship. The trial court’s decision granting the Agency permanent custody was supported by clear and convincing evidence. The trial court did not abuse its discretion by denying Mother-appellant’s motion for an in-camera interview. Mother-appellant and Father-appellant’s arguments relating to the shelter-care hearing and adjudication hearings were not timely.MillerMercer 11/3/2025 11/3/2025 2025-Ohio-4999
State v. Gingerich 14-25-10Misdemeanor Sentencing; R.C. 4511.21; R.C. 2929.22; R.C. 2929.24. The trial court sentenced the defendant-appellant to 60 days in jail with 30 days suspended on a third-degree misdemeanor. Absent an affirmative showing that the trial court failed to consider the applicable statutory factors, this court will presume that the trial court considered the criteria set forth in R.C. 2929.22 when imposing a misdemeanor sentence.ZimmermanUnion 10/27/2025 10/27/2025 2025-Ohio-4908
State v. Clay 8-25-01Review of consecutive sentences; R.C. 2929.14(C)(4); Misstatement of name of crime by trial judge at sentencing. The judgment of sentence is affirmed.WaldickLogan 10/27/2025 10/27/2025 2025-Ohio-4905
Hoover v. Pfeifer 16-25-06Easements; Civ.R. 15(B); Motions to Amend Pleadings to Conform to the Evidence; Standing; Summary Judgment; Declaratory Judgment. The trial court did not err in granting summary judgment, declaratory judgment, and a permanent injunction in favor of the plaintiffs-appellees.WaldickWyandot 10/27/2025 10/27/2025 2025-Ohio-4909
State v. Clapsaddle 6-24-17Rape; Gross Sexual Imposition; Evid.R. 404(B); Other Acts Evidence; Ineffective Assistance of Counsel; Rebuttal Testimony. The conviction for gross sexual imposition was supported by sufficient evidence. The conviction for rape was supported by sufficient evidence and was not against the manifest weight of the evidence. The trial court did not commit plain error in allowing other-acts evidence to be introduced by the State. Defendant-appellant did not show that his trial counsel rendered ineffective assistance. The trial court did not err by allowing the State to offer rebuttal testimony after the Defense rested its case.MillerHardin 10/27/2025 10/27/2025 2025-Ohio-4904
Horne v. Adena Pointe Homeowners Assn., Inc. 14-25-03Summary Judgment; Declaratory Judgment; Business Judgment Rule; R.C. 5312.16. The trial court erred by granting summary judgment in favor of the plaintiffs-appellees, as the plaintiffs-appellees failed to carry their burden of proving that the homeowners’ association’s restrictions were unreasonable as a matter of law. However, because genuine issues of material fact remain on the undeveloped record, the defendants-appellants were also not entitled to summary judgment.ZimmermanUnion 10/27/2025 10/27/2025 2025-Ohio-4916
State v. Downton 1-25-32Violating a Protection Order; R.C. 2919.27(A)(2); Manifest Weight of the Evidence. The defendant-appellant’s violating a protection order conviction is not against the manifest weight of the evidence because the weight of the evidence presented at trial reflected that she did not immediately depart the public place when she accidentally encountered the victim as required by the protection order.ZimmermanAllen 10/27/2025 10/27/2025 2025-Ohio-4903
State v. Paul 10-25-07Crim.R. 43(A); Defendant's presence in courtroom; Waiver of right to be present; Harmless error; Plain error; R.C. 2929.13(D); Presumption for prison not overcome; Court-appointed counsel costs; R.C. 2941.51; Civil assessment. The judgment of conviction and sentence entered against the defendant-appellant is affirmed.WaldickMercer 10/27/2025 10/27/2025 2025-Ohio-4907
State v. Hobson 1-24-58Operating a Vehicle Under the Influence of Alcohol ("OVI"); Probable cause to arrest for OVI; Sufficiency of evidence and manifest weight of the evidence relating to impairment while driving. The judgment of conviction and sentence is affirmed.WaldickAllen 10/27/2025 10/27/2025 2025-Ohio-4901
State v. Greenawalt 9-24-40Self-Defense; Jury Instruction; Separation of Witnesses; Prior Inconsistent Statements; Cumulative Error. To raise the affirmative defense of self-defense at trial, the defendant must produce evidence that tends to support the conclusion that his or her use of force was justified. To warrant a jury instruction on self-defense, the defendant must produce evidence that (1) he or she was not at fault in creating the situation that led to the affray; (2) he or she had a bona fide belief that the use of force was the only way to escape an imminent threat of death or great bodily harm; (3) he or she did not violate any applicable duty to retreat. A separation order is issued to prevent witnesses from hearing the testimony of others and tailoring their statements accordingly. Issues relating to the separation of witnesses are entrusted to the discretion of the trial court. If a witness admits to making a prior inconsistent statement, a trial court does not abuse its discretion in excluding extrinsic evidence of that prior inconsistent statement.WillamowskiMarion 10/27/2025 10/27/2025 2025-Ohio-4906
State v. Jones 1-25-07Self-Defense; Recklessness; Manifest Weight; Sufficient Evidence; Nondeadly Force. Recklessness is defined as disregarding, with heedless indifference to the consequences, a substantial and unjustifiable risk that the person's conduct is likely to cause. If the defendant produces sufficient evidence to create an issue as to each of the elements of the affirmative defense of self-defense, the State has the burden of disproving at least one of the elements of self-defense beyond a reasonable doubt. If the defendant was at fault in creating the affray, he or she cannot claim self-defense.WillamowskiAllen 10/27/2025 10/27/2025 2025-Ohio-4902
State v. Kittle 2-25-02 & 2-25-03Felony Sentencing; R.C. 2929.11; R.C. 2929.12. Defendant-appellant's prison sentence is not clearly and convincingly contrary to law.MillerAuglaize 10/20/2025 10/20/2025 2025-Ohio-4793
In re P.S. 6-25-03 & 6-25-04Permanent Custody; Reasonable Efforts; Sunset Date. Trial court's determination to grant permanent custody to children's services agency was not against the weight of the evidence. In addition, trial court did not err by determining agency engaged in reasonable efforts to support reunification.WaldickHardin 10/14/2025 10/14/2025 2025-Ohio-4726
State v. Murphy 10-25-05Pretrial Delay; Constitutional Right to a Speedy Trial; Withdrawal of Guilty Plea; Criminal Rule 43; and Effectiveness of Counsel. The trial court did not violate Criminal Rule 43 when it required the defendant to appear remotely when no objection was made and no prejudice to the defendant is shown. Trial court did not err in denying the motion to withdraw the guilty plea when it weighed the factors for granting it and determined that they fell against granting the motion. Constitutional right to a speedy trial was waived by defendant and was fully considered by the trial court. Counsel was not ineffective for failing to raise the speedy trial issue when it was considered and denied by the trial court.WillamowskiMercer 10/14/2025 10/14/2025 2025-Ohio-4713
In re K.S. 11-25-06Delinquency; Sufficiency; Manifest Weight. Juvenile adjudications were supported by the evidence and were not against the weight of the evidence.WaldickPaulding 10/14/2025 10/14/2025 2025-Ohio-4715
Williams v. D&J House Doctors, L.L.C. 13-25-08Summary Judgment; "As Is" Clause; Fraud; Bad Faith Claim. An "as is" clause in a purchase agreement for fraud will not bar a claim of positive fraud against the seller of the property. Unlike a claim for negligence, a buyer must prove that the seller had some knowledge of the defect in question where an "as is" clause is contained in the purchase agreement. R.C. 5302.30 directs sellers to complete a residential property disclosure form. However, this document is not a warranty. Thus, the purchaser has a duty to inspect the premises and is charged with knowledge of the conditions that a reasonable inspection would uncover.WillamowskiSeneca 10/14/2025 10/14/2025 2025-Ohio-4716
In re K.B. 11-25-05Manifest Weight of the Evidence; Breaking and Entering; Vandalism; Identity; Evidence Admissibility; Authentication; Evid.R. 901. The child-appellant’s breaking and entering and vandalism adjudications were not against the manifest weight of the evidence. The trial court did not abuse its discretion by admitting photographs into evidence because the State properly authenticated the photographs by presenting testimony from a witness with personal knowledge of the scene.ZimmermanPaulding 10/14/2025 10/14/2025 2025-Ohio-4714
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