Showing posts with label Will. Show all posts
Showing posts with label Will. Show all posts

Friday, May 9, 2025

Dangers of Incomplete and Last-Minute Estate Planning: A Mississippi Case Study


Estate planning is often delayed until the last possible moment, frequently done on an ad hoc basis- addressing issues as they arise without developing a comprehensive plan. A recent Mississippi case illustrates how such delays can leave seniors vulnerable to manipulation and undue influence, potentially unraveling their true intentions for their legacy. Havoc often ensues in the vacuum created by last-minute or incomplete planning. This article explores a real-life example of a will  invalidated due to the undue influence of a testator’s son, and how individuals and  families can protect themselves from similar risks.

The Case: A Will Invalidated Due to Undue Influence

In the case, In re the Matter of the Estate of Autry, the Mississippi Supreme Court affirmed a ruling setting aside several deeds and invalidating a decedent's will due to lack of authentication, lack of  capacity, and undue influence.  The case is an object lesson regarding the benefits of  comprehensive estate planning.

Effie Mae Autry  and her husband made a will within 2014, but he predeceased her.  She had three sons, two of whom also predeceased her, leaving five grandchildren (three from one sone, two from the other). Effie's 2014 will, stipulated that, if her husband predeceased her, 143 acres of real property would be divided equally:  one-third to her surviving son, Steve; one-third to her grandchildren from one deceased son; and one-third to her grandchildren from the other deceased son. Effie also provided for a $1,000 bequest to her church and specific bequests to Steve and each grandchild.

In early 2019, Marcus, one of Effie’s grandchildren, filed a petition for conservatorship after Effie’s bank notified him that Steve and his wife had accompanied Effie to the bank and tried to remove Marcus’s name from her accounts or close the accounts. Steve lacked a power of attorney to act on Effie’s behalf. Marcus later withdrew the petition because the conservatorship confused and upset Effie. Notably, Marcus' name was on Effie's accounts, suggesting that Effie had not executed a power of attorney; otherwise, Marcus would not have needed to file for conservatorship.  This indicates that Effie and her husband relied solely on wills for estate planning.

Later in 2019, Steve called the family’s longtime attorney who had drafted Effie’s 2014 will, to discuss drafting a new will and deeds. After meeting with Effie and Steve, the attorney refused to prepare new documents, citing a significant decline in Effie’s mental capacity and concerns about Steve's potential undue influence. The attorney even warned other attorneys about the situation.

Undeterred, Steve then engaged another attorney to draft a new will and deeds for Effie. Steve drove Effie to this new attorney's office, where the attorney, unaware of the prior attorney's refusal or 2014 will, discussed a new will with Effie. The attorney testified that Effie appeared competent and clear about her intentions. Several days later, Steve drove Effie, Effie’s "caregiver," and the caregiver’s sister to the attorney's office to execute the new will and deeds. Effie signed a will leaving all of her assets to Steve, providing for the grandchildren only if Steve predeceased her and omitting the church bequest. The caregiver’s sister and the attorney's secretary signed as witnesses but failed to include their addresses in a required affidavit. Effie also executed several warranty deeds conveying all real property to Steve, retaining a life estate for herself.

After Effie’s death in 2021, Marcus contested the validity of the 2019 will and the deeds. The court ruled that the will and deeds were invalid because: (1) improper authentication by the witnesses, (2) Effie lack pf testamentary capacity, and (3) Steve undue influence. The Mississippi Supreme Court affirmed the ruling. The case highlights the risks associated with last-minute estate planning and the vulnerabilities seniors face without a comprehensive plan.

What Happens Next?

The case isn't over.  It now proceeds back to the probate court.  The next step is likely to admit the 2014 will, if that will is signed and authenticated properly. However, even a will drafted by an attorney and executed in an attorney's office, as the 2019 will was, can invalidated for technical errors or contested on other grounds.  If no valid will is admitted, he estate will be  administered as intestate. 

In Mississippi, intestate distribution (Miss. Code § 91-1-3 (2024)) mirrors Effie’s 2014 will: one-third to Steve, one-third to the grandchildren of one deceased son (split equally), and one-third to the grandchildren of the other deceased son (split equally). However, certainty is elusive. The grandchildren could argue that Steve’s share be withheld due to his wrongdoing, or Steve might contest Marcus’s share, citing the conservatorship attempt. Other tort claims, such as fraud or breach of fiduciary duty, could arise, though Mississippi does not recognize the tort of intentional interference with an inheritance

Additionally, Medicaid estate recovery could complicate matters if Effie qualified for long-term care after transferring assets, now invalidated. While unlikely, this highlights an overlooked risk: Effie’s family likely did not anticipate the full consequences of their reactive decisions. Discord is common even in well-planned estates, but incomplete planning exacerbates conflict.


A Word On Motivations

In my practice, I focus solely on my client's motivations, assuming the worst from others in order protect the client.  Courts evaluate actions based on legality, not intent.  However, considering motivations can illuminate the consequences of poor planning.

It’s tempting to view Steve as selfishly attempting to seize the estate. Yet, the court noted intriguing details: Steve was married but had no children, and the 2019 will, upon Steve’s death, distributed assets to most grandchildren, excluding Marcus and his sister (possibly due to the conservatorship). The will did not benefit Steve’s wife, suggesting alignment with Effie’s broader intentions. Effie’s severe dementia and need for around-the-clock care, partly provided by the caregiver whose sister witnessed the will, further complicate the narrative.

The deeds, retaining a life estate, likely represented a hasty Medicaid planning attempt to protect assets from nursing home costs. Marcus’s dismissal of the conservatorship may reflect a shared family goal to avoid asset loss, as a finding of incompetency would have invalidated transfers. These dynamics underscore how complicated last-minute planning can be, and how a comprehensive estate plan could have prevented conflict and better served the family.


The Weaknesses of Incomplete and Last-Minute Planning

Last-minute estate planning often occurs when seniors are vulnerable— due to illness, cognitive decline, or emotional distress, making them susceptible to manipulation. In Autry, Steve exploited his mother’s weakened condition to influence the will. Rushed decisions, especially without proper legal guidance, often fail to reflect the testator’s true intentions. Courts scrutinize last-minute changes, particularly those deviating from prior plans or disproportionately benefiting one person.

Vulnerabilities Seniors Face Without a Comprehensive Plan

Without a comprehensive estate plan, seniors are exposed to several risks, including, but not limited to:

Lack of Legal Protections: Without powers of attorney or trusts, no trusted individual is authorized to act if the senior becomes incapacitated.

Increased Risk of Manipulation: Seniors without a plan are more likely to be targeted by those seeking to exploit their assets, as there are fewer legal safeguards in place.

Family Conflict: Ambiguous or incomplete estate plans can lead to disputes among family members, causing emotional and financial turmoil.

In Autry, the absence of a robust plan not only made it made it easier for the son to exert influence, but it allowed conflict that could only be resolved by the court.  

How a Complete Estate Plan Would Have Prevented
 and Resolved the Autrey Case

A revocable living trust offers transparency and protection. Unlike a will, which remains private until probate, a trust’s existence is evident in deeds, bank accounts, insurance policies, and other assets. This visibility deters manipulation, as third parties (e.g., new attorneys) are aware of the existing plan. In Autry, a trust would have prevented Steve from engaging an unaware attorney to draft a new will, and the 2019 will’s invalidity due to authentication errors would have been irrelevant.
 
In the Autrey case, one person exploited the limitations of a will, to obtain legal counsel to make a new will, that counsel being wholly unaware of the prior estate plan, such as it was.  The son might argue today that the grandchildren also exploited the weaknesses of the will by so easily contesting the second will, which was legally invalid even though it was drafted by an attorney, executed in the attorney's office, and a staff member of that attorney served as a witness.  The court did not need to find undue influence because the will was invalid as executed!  The reason I suspect the court considered and resolved the undue influence claim is to solve the problem of technical invalidity- a will can be invalid as a will for technical reasons, but evidence a clear intention to replace a former will.  That circumstance  results in no will, increasing the cost and complexity of the administration.  Your trust protects you from such exploitation.

Powers of attorney, which accompany every revocable trust, help protect you from conservatorship and guardianship by making them unnecessary, and if drafted properly, protect the trust assets from guardian control.  They even disincentivize third-party guardians (those appointed by a court that are not your family) by limiting what a guardian can manage of your entire estate.  Finally, in states that are required to give preference to agents nominated under a power of attorney when appointing a guardian, they help in getting your most  trusted family or advisors  appointed. 

Ad hoc solutions, like adding Marcus to Effie’s accounts, create uncertainty and risk. Banks rarely document the context of such changes (e.g., whether the account holder was advised or accompanied). Adding a co-owner can inadvertently make the account vulnerable to the co-owner’s creditors, a risk banks may not explain, as they are not legal advisors. Seniors often first learn the consequence of adding a child to an account when they are advised of a garnishment against a child as creditors seek to  remove assets from their account. 
      
If Medicaid planning motivated the deeds, a trust would have been superior. Modern Medicaid rules in many states, including Mississippi, scrutinize life estates, potentially valuing them as assets. A trust not only allows, but encourages crisis Medicaid planning without relying on the grantor’s competence, enabling an agent or trustee to create an irrevocable planning trust that preserves the original distribution plan. This would have avoided the need for questionable transfers and protected Effie’s estate.

Keep in mind that the real world result of the Autrey case is that Steve may ultimately receive nothing.  If he was acting in what he thought was the best interest of his mother and family, this result is tragic.  Comprehensive estate planning might have prevented such a result. 

An Actionable Plan to Protect Your Legacy

To prevent a situation like this from becoming your family’s reality, it’s essential to take proactive steps well before any health crises or vulnerabilities arise. Here’s an actionable list to help safeguard your estate and ensure your wishes are honored:

Create a Trust: A trust allows you to manage your assets during your lifetime and ensures they are distributed according to your wishes after your death. It can also provide protection against undue influence by clearly outlining your intentions in a legally binding document. It can assist in aging in place, reduce the risk of guardianship, and protect assets from third-party guardians.  Additionally, a trust can help avoid probate, reducing the likelihood of costly public disputes.

Establish General Durable Powers of Attorney (GDPOA): A GDPOA allows you to appoint trusted individuals to make financial and medical decisions on your behalf if you become incapacitated. This prevents someone from stepping in and taking control without your consent. Be sure to choose someone you trust implicitly, as this role carries significant responsibility.

Nominate a Guardian: Nominate someone in advance, usually in your GDPOA. This ensures that if a guardian is required, it’s more likely to be someone you’ve chosen, not someone appointed by the court who may not have your best interests at heart.

Incorporate Aging in Place Planning: Aging in place planning involves making arrangements for your care and living situation as you age, ensuring you can stay in your home or a suitable environment. This can include modifications to your home, arrangements for in-home care, or plans for assisted living if needed.

Include Guardianship Protections in Your Trust: Your trust should include provisions that prevent a guardian from easily accessing or altering the trust assets. This adds an extra layer of protection, ensuring that even if a guardian is appointed, your estate remains secure and distributed according to your wishes.

These steps should be taken well in advance, while you are still of sound mind and not under any undue influence. Waiting until the last minute can leave you vulnerable to manipulation, as seen in the Autry case.

The Emotional and Financial Toll of Undue Influence

Cases like this don’t just result in legal battles—they can tear families apart. The emotional toll of fighting over a loved one’s estate, combined with the financial costs of litigation, can be devastating. By taking proactive steps now, you can help protect your family from this kind of heartbreak and ensure your legacy is preserved as you intended.

Conclusion: Don’t Wait—Plan Today

The Autry case serves as a powerful reminder of the dangers of last-minute estate planning and the vulnerabilities seniors face without a comprehensive plan. By creating a trust, establishing powers of attorney, nominating a guardian, and incorporating aging in place and guardianship protections, you can safeguard your estate and ensure your wishes are honored.

If you haven’t already, now is the time to take action. Consult with an experienced elder law attorney to create a plan that protects you and your loved ones from the risks of undue influence and ensures your legacy is secure.




Monday, April 14, 2025

Revised Uniform Fiduciary Access to Digital Assets Act in Ohio


The Revised Uniform Fiduciary Access to Digital Assets Act (RUFADAA) is a legal framework developed by the Uniform Law Commission (ULC) to govern fiduciary access to digital assets, addressing the growing need to manage electronic records after a person’s death or incapacity. Ohio adopted RUFADAA in 2017 (Ohio Rev. Code § 2137.01 et seq.), aligning with 45 other states by 2023 to provide a consistent approach to digital estate planning. Below, I’ll outline the specifics of RUFADAA, focusing on its application in Ohio, its key provisions, and critical considerations. 

Key Provisions of RUFADAA in Ohio

Definition of Digital Assets: RUFADAA defines a “digital asset” as an electronic record in which an individual has a right or interest, excluding underlying assets or liabilities unless they are electronic records themselves (Ohio Rev. Code § 2137.01(I)). This definition includes:
  • Electronic Items with Monetary Value: Cryptocurrencies, domain names, online banking accounts.
  • Electronic Communications: Emails, social media messages, text messages.
  • Sentimental or Intellectual Property: Digital photos, videos, blogs.
This definition ensures fiduciaries can manage a wide range of digital assets but distinguishes them from the underlying value (e.g., funds in a bank account are not digital assets, but the electronic record of the account is).

Fiduciary Authority: RUFADAA applies to fiduciaries such as executors, trustees, agents under a power of attorney, and court-appointed guardians. Ohio Rev. Code § 2137.14. In Ohio, fiduciaries:
  • have the right to access digital assets if the user (the account holder) had a right or interest in them, provided they are not restricted by a terms-of-service agreement (TOSA).
  • are treated as authorized users under computer fraud and abuse laws, protecting them from legal liability when accessing assets within their scope of duties.
Hierarchy of Access Instructions: RUFADAA establishes a three-tier priority system for determining fiduciary access: 
  • Online Tools: If the user designated access through an online tool (e.g., Google’s Inactive Account Manager or Facebook’s Legacy Contact), this takes precedence. For example, a user can specify a trusted contact to access their account after a period of inactivity or opt for permanent deletion.
  • Legal Documents: If no online tool is used, the user’s will, trust, power of attorney, or other record governs access. For instance, a GDPOA can explicitly grant an agent authority to manage digital assets.
  • Terms-of-Service Agreements (TOSA): If neither an online tool nor legal document provides direction, the custodian’s TOSA dictates access. Many TOSAs (e.g., Verizon, Yahoo) state that accounts are non-transferable and terminate upon death, potentially limiting fiduciary access.

Custodian Compliance and Protections: Custodians (e.g., Google, Facebook) are the entities that store or provide digital assets. RUFADAA outlines their obligations and protections:
  • Compliance Timeline: Custodians must comply with a fiduciary’s request within 60 days of receiving required documentation, such as a certified copy of the fiduciary’s authority (e.g., letter of appointment, trust certification) and account identifiers (e.g., username).  Ohio Rev. Code § 2137.07.
  • Court Orders: Custodians can request a court order verifying the account belongs to the user, ensuring sufficient consent for disclosure, especially for electronic communications, which are protected under federal privacy laws like the Stored Communications Act, 18 U.S.C. § 2701 et seq.
  • Limited Access: Custodians may limit disclosure to what is “reasonably necessary” for estate administration, charge fees, or refuse burdensome requests. They cannot provide access to deleted assets or joint accounts.
  • Immunity: Custodians are immune from liability for good-faith compliance with fiduciary requests, protecting them from legal risks.
  • Privacy and Electronic Communications:  RUFADAA balances fiduciary access with privacy.  Fiduciaries can access the “content of electronic communications” (e.g., email content, private messages) only if the user explicitly consented in a will, trust, or power of attorney. Without consent, fiduciaries may access metadata (e.g., email logs) but not the content, protecting the user’s privacy while allowing estate administration to proceed.
  • Fiduciary Duties: RUFADAA applies the same legal duties to digital assets as to tangible property, including the duty of care, loyalty, and confidentiality.  Ohio Rev. Code § 2137.14. Fiduciaries cannot exceed the user’s access rights, ensuring they do not misuse their authority.
Application Challenges in Ohio 

Ohio’s adoption of RUFADAA in 2017 ensures that fiduciaries have a legal pathway to manage digital assets, but practical challenges remain.
  • Documentation Requirements: Fiduciaries must provide custodians with specific documents (e.g., a certified copy of their appointment, account identifiers), which can be cumbersome, especially for multiple accounts.
  • Court Involvement: If custodians resist disclosure, fiduciaries may need to seek a court order, adding time and expense to the estate administration process process.
  • TOSA Conflicts: Ohio law prioritizes user directions over TOSAs, but many custodians’ agreements (e.g., Verizon’s) terminate accounts upon death, potentially conflicting with user intent unless explicitly overridden in a legal document.
Critical Examination

While RUFADAA provides a much-needed framework, it has limitations:
  • Privacy vs. Access Tension: The requirement for explicit consent to access electronic communications protects user privacy but can hinder fiduciaries, especially if the user did not plan ahead. This balance may overly favor custodians, who can limit access to “reasonably necessary” information, potentially leaving sentimental assets (e.g., family photos) inaccessible.  Planning ahead, and planning capably is encouraged, but in those situations where a user does neither, or simply plans incapably or incompletely, family members will suffer.   
  • Practical Barriers: The process of obtaining access—requiring documentation, court orders, and custodian compliance—can be a “headache” and an "entry barrier" for fiduciaries. This complexity may discourage fiduciaries from pursuing access, especially for less valuable assets.
  • Incumbency Gaps: Incumbency gaps refer to the periods or situations in estate planning or trust administration where there is a lack of an active, legally recognized fiduciary (such as a trustee, executor, or agent under a power of attorney) to manage the estate, trust, or digital assets of a person who is incapacitated or deceased. These gaps can occur due to delays, resignations, deaths, or failures to appoint a successor fiduciary, leading to potential mismanagement, legal complications, or inability to access critical assets, including digital ones like email accounts or online financial platforms.
    • Incapacity Without a Successor: In states like California, RUFADAA initially did not apply to incapacitated individuals, though Ohio’s version covers both death and incapacity. Ohio Rev. Code § 2137.03. This ensures broader applicability but highlights inconsistencies across states, as not all jurisdictions have adopted uniform provisions. Even with Ohio's broader scope, incumbency gaps remain. If a person becomes incapacitated and their agent under a General Durable Power of Attorney (GDPOA) resigns, passes away, or is otherwise unable to act, and no successor agent was named, there may be no one with legal authority to manage the person’s digital assets (e.g., accessing Gmail, paying bills online), or if the agent was the only one with access to a password manager like LastPass, an incumbency gap could prevent timely access to critical accounts.
    • Death Without a Successor Trustee/Executor: Upon a person’s death, if the named executor or trustee is unavailable (e.g., predeceased, declines to serve, or is incapacitated) and no successor is appointed, there may be a delay in appointing a new fiduciary through the courts. During this gap, digital assets like Smart Home and IoT Accounts (e.g., Ring, Amazon Alexa) might go unmanaged, potentially compromising home security or functionality for aging-in-place individuals.
    • Legal and Administrative Delays: Incumbency gaps often arise from the time it takes to probate a will, appoint a new trustee, or obtain court approval for a successor fiduciary. During this period, digital assets may remain inaccessible, especially if platforms like Google require a court order for access , exacerbating the issue for heirs or fiduciaries. 
  • Custodian Discretion: Custodians’ ability to charge fees, limit access, or require court orders gives them significant control, potentially undermining user intent. This reflects a bias toward protecting tech companies rather than prioritizing fiduciary needs or user wishes.
Importance of a Plan Including a Digital Assets Inventory

RUFADAA’s hierarchy of access instructions supports the necessity of a tech-savvy estate plan specifying explicitly fiduciary access in a will, trust, or GDPOA to override TOSAs, and the use of a Digital Assets Inventory.  The user should:
  • Appoint and Empower Fiduciaries:  Ensure your GDPOA, will, and trust name multiple successor agents, executors, and/or trustees to step in if the primary fiduciary is unavailable, and explicitly confer broad and specific authority to manage all aspects of digital assets and accounts.  
  • Leverage Online Tools: Use platform-specific tools like Google’s Inactive Account Manager to designate trusted contacts, reducing reliance on fiduciaries during gaps, and minimizing disputes regarding fiduciary's' authority and role.
  • Use Digital Asset Inventory Tools: Document access instructions in a Digital Assets Inventory Worksheet and store it securely (e.g., in LegalVault®) so any fiduciary can access it.  Identify, by completing the inventory, for each digital  asset or account an intention regarding  access and control by a fiduciary, and sign each page of the inventory.
  • Regular Updates: Review and update your estate plan and inventory periodically to ensure named fiduciaries are still willing and able to serve, minimizing the risk of gaps, and track your decisions and updates on your Inventory.
  • Deploy a Trust: Time is a factor when dealing with digital assets.  Successor agents appointed by a GDPOA can be stood up quickly while you are alive.  Upon your death, the choice is between at trustee that you nominate prior to your death or a court appointed fiduciary, such as a general or special executor, administrator, or commissioner.  Although it is possible that these may be nominated, qualified, appointed, and empowered "quickly," the normal course of events in a court process is anything but "quick."  In most cases, a successor trustee of a trust, if available and willing to serve, is able to be empowered to serve within a week of receiving a death certificate.  A court-appointed fiduciary is "quickly"  empowered within 30-90 days, though exceptions are possible.    
  • Secure Storage:  Store access instructions securely (e.g., via LegalVault®) to facilitate fiduciary action.
Conclusion

RUFADAA in Ohio provides a structured legal framework for fiduciary access to digital assets, defining digital assets broadly, establishing a priority system for access, and balancing privacy with estate administration needs. However, its implementation can be complex, with custodians holding significant discretion and fiduciaries facing procedural hurdles. For estate planning, RUFADAA underscores the need for explicit authority in legal documents and proactive planning to ensure fiduciaries can manage digital assets effectively. Clients should be aware of both the legal pathway RUFADAA provides and its practical limitations, ensuring their estate plans are robust enough to navigate these challenges.

Sunday, October 13, 2024

Violence as a Consequence of an Estate Plan- Can Planning/Drafting Help? A Simple Provision in a Deceased Mother's Will Sparks a Son's Shotgun Rampage Causing the Death of Four

You can press play on the video, but if you would rather watch the video in a separate tab/window (recommended) click the link below:

In this video I discuss violence, threats of violence, and retaliation as a consequence of estate planning choices, and whether planning and drafting can avoid or protect a family from such a tragic consequence.

Trigger warning: the subject matter considers heartbreaking examples of violence including death. This video reports a recent tragedy in which a simple provision in a deceased mother's will sparked a son's shotgun rampage, causing the death of four, and discusses estate planning and administration considerations to prevent similar violence and harm.

The case example discussed is from a report in the Daily Mail, "Simple request in Long Island woman's will sparked her son's devastating shotgun rampage on siblings." (last retrieved 10/10/2024). The Daily Mail article was brought to my attention by Professor Gerry W. Beyer's article, similarly titled.

The video discusses, among others, the following considerations and strategies in an effort to reduce or eliminate the threat of tragic outcomes:
  • Drafting Considerations;
  • Considerations Regarding Communications with Family;
  • Securing Documents;
  • Physical Security;
  • Identifying/Reporting Threats/Troubling Behaviors, Mental Illness & Grief;
  • Logistics of the After-death Family Meeting including Timing and Location.
The video highlights the importance of worst-case scenario planning, and keeping a continuing relationship with a trusted advisor with whom such topics can be discussed and considered openly and thoroughly.

Additional Resources:


Tuesday, February 16, 2021

Larry King's 2019 "Hand-written" Will Omits Wife and Splits His $50M Estate Among His Children

Celebrity estates create interest in estate planning, and are often object lessons in either poor or exceptional estate planning. The estate of late broadcasting legend Larry King, is no exception. 

King died of sepsis on January 23rd at the age of 87. King reportedly left behind a hand-written Will "advising for an even split of his fortune to his five children in the event of his death." Larry King was reportedly worth around $50 million at the time of his death. 

The Will was reportedly written on October 17, 2019, coming just two months after he filed for divorce. His seventh wife (whom he intended on divorcing), Shawn Southwick, was entirely omitted from the handwritten Will. 

The document reads, "[t]his is my Last Will & Testament. It should replace all previous writings." The Will stated that King wanted "100 percent of his funds to be divided equally among my children Andy, Chaia, Larry Jr., Chance, and Cannon." King's son Andy passed away of a heart attack in July 2020 and his daughter Chaia, died in August after being diagnosed with lung cancer. 

There was no clear reporting whether the Will was admitted to probate, and of course, at this early date, whether King's wife (intended ex-wife) will contest the Will or exercise what may be her spousal rights under state law.  

Source: Tracy Wright, "Larry King left a 'hand-written will' in 2019 seeking equal split of his $50M fortune to his five children... and leaves out ex-wife Shawn," Daily Mail (U.K.), February 11, 2021. 

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