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Directive:
UNEMPLOYMENT INSURANCE PROGRAM LETTER NO.23-08

Subject:
Supplemental Appropriation Act, 2008, Title IV— Emergency Unemployment Compensation

Purpose:
To provide states with instructions for implementing and operating the Emergency Unemployment Compensation, 2008 (EUC08) program, including fiscal and reporting instructions.

To:
STATE WORKFORCE AGENCIES

From:
DOUGLAS F. SMALL
Deputy Assistant Secretary
Date: July 07, 2008
Expiration Date: July 07, 2009

1. Attachment A - Implementing and Operating Instructions for EUC08
2. Attachment B - General Provisions for Administering EUC08
3. Attachment C - Title IV - Emergency Unemployment Compensation

What could possibly go wrong?

Background 1: The Code of Federal Regulations...according to Wikipedia
Wikipedia Code of Federal Regulations


"The Code of Federal Regulations (CFR) is the codification of the general and permanent rules and regulations (sometimes called administrative law) published in the Federal Register by the executive departments and agencies of the federal government of the United States."

"Every regulation in the CFR must have an "enabling statute," or statutory authority. The United States Code (U.S. Code) precedes the CFR and contains statutes enacted by Congress. The CFR contains regulations, which spell out in further detail how the executive branch will interpret the law.[1] The two documents represent different stages in the legislative process. The U.S. Code is a codification of legislation, while the CFR serves as administrative law. Administrative law exists because the Congress often grants broad authority to executive branch agencies to interpret the statutes in the U.S.Code (and in uncodified statutes) which the agencies are entrusted with enforcing. Congress may be too busy, congested, or gridlocked to micromanage the jurisdiction of those agencies by writing statutes that cover every possible detail, or Congress may determine that the technical specialists at the agency are best equipped to develop detailed applications of statutes to particular fact patterns as they arise."
"Under the Administrative Procedure Act, the agencies are permitted to promulgate detailed rules and regulations through a public "rulemaking" process where the public is allowed to comment, known as public information. After a period of time, the rules and regulations are usually published in the Federal Register."
" Effect of administrative law
The rules are treated by the courts as being as legally binding as statutory law, provided the regulations are a reasonable interpretation of the underlying statutes. This "reasonable interpretation" test or Chevron doctrine was articulated by the U.S. Supreme Court in a unanimous decision (six voting, three recused) involving a challenge to new Clean Air Act regulations promulgated by the Reagan administration in 1981. See Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. (467 U.S. 837 (1984).)"
Background 2: Department of Labor Compliance Pages
Code of Federal Regulations (CFR) Pertaining to the Department of Labor
Title 20 — Employees' Benefits
Chapter V — Employment and Training Administration, Department of Labor
Part 615—Extended Benefits in the Federal-State Unemployment Compensation Program

Emergency Unemployment Compensation Program Pre-Errors:
Attachment A - Implementing and Operating Instructions for EUC08

When you become eligible for EUC08 payments, you are known as an "exhasutee" (Page A-3 Eligibility for EUC08 1. (a)-(b)(1)).

Question for the class:

What do you do when the claimant for EUC08 establishes a valid new benefit year? Doing so would mean they have gone back to work for some period of time and earned enough wages to qualify for a new regular compensation state unemployment claim. So now what happens with the EUC08 claim and any remaining balance?

(2)  Exhaustees cease to be exhaustees when they can establish a valid new benefit year; therefore, at each quarter change, the state must check to see if an individual meets the state’s requirements  to establish a new benefit year. If the individual can establish a new benefit  year, s/he would no longer qualify for the EUC08 claim. In these cases, the claimant should be advised that s/he no longer qualifies for the EUC08 claim and that s/he can file a regular UI claim.

Once the claimant qualifies for a new claim, the payments on the EUC08 claim must end, even if the Weekly Benefit Amount (WBA) for the new claim is lower than what the claimant  was receiving on the EUC08 claim.
Note.  The requirement to check eligibility for regular compensation at each quarterly change was not explicitly stated in the guidance implementing the Temporary Extended Unemployment Compensation Act of 2002.  However, the Department has determined that it  is a method of administration necessary for assuring that individuals have in fact exhausted regular compensation as required by the Act. "
- Page A-3 and A-4 Determining Exhasutees 1. (b)(2))

This section of the EUC08 Implementing and Operating Instructions is an interpretation of the following from the Code of Federal Regulations:

§ 615.5  Definition of “exhaustee

(2) An individual who becomes an exhaustee as defined above shall cease to be an exhaustee commencing with the first week that the individual becomes eligible for regular compensation under any State law or 5 U.S.C. chapter 85, or has any right to unemployment compensation as provided in paragraph (a)(1)(v) of this section, or has received or is seeking unemployment compensation as provided in paragraph (a)(1)(vi) of this section. The individual's Extended Benefit Account shall be terminated upon the occurrence of any such week, and the individual shall have no further right to any balance in that Extended Benefit Account.
Emergency Unemployment Compensation Program Post-Errors:
UNEMPLOYMENT INSURANCE PROGRAM LETTER NO.23-08, Change 1
1. Emergency Unemployment Compensation, 2008 – Questions and Answers

Attachment to UIPL No. 23-08, Change 1
Emergency Unemployment Compensation, 2008
Questions and Answers

D. Monetary Eligibility (page 5-6)
7.   Question:  May an individual have more than one EUC08 claim?
Answer:   Yes.  An individual may establish a claim for EUC08, qualify for a new UC benefit year, exhaust that benefit year, exhaust the first EUC08 claim and subsequently qualify for a second EUC08 claim based on the new (most recent) benefit year.

Example:
An individual is determined eligible for EUC08 based on a UC benefit year that ended on May 12, 2007.  S/he receives 10 weeks of EUC08 prior to the calendar quarter change, at which point s/he qualifies for a new UC benefit year.  Because the individual qualifies for regular UC, EUC08 payments must stop.
The individual exhausts benefits based on his/her new UC benefit year; therefore, s/he is again an exhaustee for EUC08 purposes.  S/he may collect the remaining entitlement on his/her existing (first) EUC08 claim and after exhausting these benefits s/he may file a new (second) EUC08 claim based on the new (most recent) UC benefit year.  The new/most recent benefit year is the applicable benefit year for a second EUC08 claim, if the initial claim for that second claim is for a week of unemployment ending on or before March 31, 2009.

Summary:

The Q&A section above, regarding "Monetary Eligibility/Multiple EUC Claims", does not comply with Program Letter 23-08 Attachment A, Operating Instructions, 1. (b)(2). The EUC08 payments "must end" is what it says. There is no listed provision in the Implementing and Operating Instructions anywhere that gives permission to start up this EUC08 claim again. There is no regulation nor statute to back this up. They would have used the phrasing "payments must stop" in that case. Then they would have explained in detail how the claim would be re-opened, and also how to keep track of the second EUC claim that would be "deferred" until the claimant could exhaust the older balance first. The don't...

The Q&A section above does not comply with the federal administrative law, found in the Code of Federal Regulations shown earlier, found at Title 20 Chapter V part 615.5(2), "Definition of Exhaustee". This specifically states, in the exact circumstances described by the Q&A above, that, "The individual's Extended Benefit Account shall be terminated upon the occurrence of any such week, and the individual shall have no further right to any balance in that Extended Benefit Account".

The Q&A was a mistake. People do make them all the time. In this case the "policy experts" at the Department of Labor Employment & Training Administration, did make what appears to be a 100% correct interpretation with UIPL 23-08 Attachment A. But, when they came to the Change 1 Q&A section, they made a historic very contradictory and non-compliant policy error which they have yet to explain.

This has caused a great deal of waste, harm, denial and fraud. I was a victim of this mistake...just like millions of other struggling workers and families have been. I was one of the very few that fought through an appeal and prevailed against this mistake. I tried to act as whistle blower, pointing out the contradictions between the DOL ETA EUC08 guideline Q&A section vs the CFR. I filed a complaint with my state employment agency (EDD). I filed a precedent request with the state UI appeal board (CUIAB). I presented public concerns and evidence to many state and federal agencies. I filed a recovery fraud complaint (RATB-2011-DOL-9DF2506-0). I was in contact with other victims who had lost their appeals. Millions of people seem to have been affected for over the last four years.

This is what I got instead:

The rest of the Story on DK...
Read me First:
Mr. President there is a serious problem with the EUC08 program

Part One:
If Regulations are Broken in the Forest, and "Nobody" Sees and Hears them get broken...

Part Two:
ARRA Fraud in the Emergency Unemployment Insurance Program

Part Three:

Mr. President, I hear FOIA calling...

Part Four:
a Recovery Fraud Complaint Ignored...

While I was trying to request oversight, and while the state and federal agencies were working together during the 2/7-2/17 actions described in the "rest of the story" above, I also discovered, via my earlier FOIA request, that the DOL ETA was questioning the source of their implementation themselves even after they squashed my precedent decision :
From: Simonetta, Suzanne-Schwartz - ETA
Email March 30, 2012 11:57AM
To: Johnston, Robert - ETA, Castillo, Betty - ETA, Wagner, Robert - ETA
Cc: Gay Gilbert - ETA
Subject: Facebook Questions

"Below is a question about paying EUC with respect to multiple benefit years.
(I note that there are some inaccuracies in the premises and citations in the incoming email.)

As I recall, ETLS made the call that entitlement to EUC with respect to a prior benefit BY doesn't end when there is entitlement to EUC with respect to a subsequent benefit year.

Do any of you have an email or a Q and A that provides the rationale for this position?"

This communication is referring to an email I sent to Treci Johnson - OPA on Friday March 30, 2012 at 9:43AM. At this time I was unaware of what had happened 2/7-2/14 and was still requesting oversight post DOL OIG 2/17/12 refusal to investigate. I had pointed out the specific CFR regulations that seem to have been violated by the DOL ETA Q&A mistakes in this email and via Facebook.

They never responded. The DOL ETA seems to have violated the Freedom of Information Act since then, with regards to my follow up attempts to find out what specific response documents exists to this email. Someone must have responded right? It does not appear that the DOL wants me to learn or discover any more from FOIA nor the Privacy Act. I think I surprised them with it the first round. It is looking like we will have to sue them over this to get the documents. If they were correct, then they could just respond right? ETLS must have something to say about it.

The DOL ETA/EDD/CUIAB could not overturn my appeal case during the 2/7-2/17/12 actions that squashed my precedent decision from Case No A0-265448. They still refused to talk to me openly, but some within the DOL ETA, like Suzanne Simonetta, were questioning what legal basis the "Multiple EUC Claims policy" had and where did it come from. I wonder what the response was?

Through this communication it has been partially revealed that the Division of Employment and Training Legal Services (ETLS), "made the call", but there seems to be no regulatory statute to back it up does there? They must have one. They cannot just make up policy as they like. Remember that the feds tried to have EDD and the CUIAB in California overturn my case (2/7-2/14). If they were legally correct and justified, why did they not even try to take it to Superior Court using a writ of mandate to overturn this standing decision? If the decision, had in fact, violated federal law, then why not put it before an "impartial" judge?

The Department of Labor Office of Inspector General on 2/17/12 refused to investigate the evidence that exposed these mistakes. They did not try to refute the evidence in any way either. They made pretty weak excuses and tried to classify this as a "state determination matter" that they had no authority to be involve in. But we now know from FOIA that this is utter BS. They were all working together to decide "what vehicle" the "response" to me should be prior to Feb 2012 (DOL ETA, DOL OIG, EDD, CUIAB, White House?).

The DOL ETA was actively engaged on 2/7/12 with a "state determination mater", making threats about it, and making demands to overturn my CUIAB case (A0-265448 10/20/11). They said that the decision violated federal law...law that they did not cite...instead they offered up the same Q&A errors my appeal case, evidence and complaints have refuted: The UIPL 4-10 Q&A version of the same "Multiple EUC Claim" mistake shown above from UIPL 23-08 Change 1.
UIPL 4-10 Section D. Page 3+4 Multiple EUC Claims

Why also has the Recovery Accountability and Transparency Board, since March 2012 gone out of their way to respond as little as possible or not at all? They haven't done anything other than forward the complaints and evidence to all the "accused parties" and allowed them to dictate how to run the investigation against themselves. Even the FOIA revelations won't budge a response out of them.

I have repeatedly challenged the Department of Labor to provide the compliance information to justify their "Multiple EUC claims" mistake. They are dead silent, except for talking to their own legal counsel I bet. EDD lost a major appeal in California that backs up what I am saying. None of them could overturn the decision since then. My payments for EUC08 continue, but apparently California is paying for it and not the feds (see 2/7/12 DOL ETA letter). They won't respond either way. I have contacted Suzanne above and the ETLS wing of the DOL. I have asked them directly to refute me. Show me the legal basis for that Q&A...pretty please?

THERE HAS BEEN NO ANSWER NOR REPLY.

If they were right don't you think they could have easily provided the information and would have done so a very long time ago? I am after all sending them copies of all my media and public disclosure...right before the general election. In addition to the standing FOIA requests with the DOL OIG, DOL ETA and RATB, I have a current new one aimed at the the White House, who was informed by the DOL ETA on 10/18 and 10/21/11 about CUIAB Case No A0-265448 (WH663175/WH9262011-61). I am asking them what they know and how they have been involved, if at all. Wouldn't you think they would step right up and tell everyone that I am wrong and here are the specific regulations that back them up?

If not, then what exactly are they doing and what do they plan to do next about all of this?

Wed Sep 12, 2012 at 10:39 PM PT: Petitioning The President of the United States:
The Obama Administration is robbing the Unemployed out of ARRA Funds

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Comment Preferences

  •  Spam number 6 (1+ / 0-)
    Recommended by:
    Lost and Found

    "Mitt Romney looks like the CEO who fires you, then goes to the Country Club and laughs about it with his friends." ~ Thomas Roberts MSNBC

    by second gen on Sat Aug 18, 2012 at 01:36:58 PM PDT

    •  baseless reply #.... (0+ / 0-)

      You have a heap of refuting to do.
      Back up your claims that this is spam.
      Prove it wrong.
      I look forward to your attempts.

      This sounds familiar....?

      Do you need to see the "birth certificate" in person? Hmm...it is a different story when the shoe is on the other foot isn't it?

  •  I haven't been HRing your diaries but this is (1+ / 0-)
    Recommended by:
    Lost and Found

    ridiculous. Stop spamming.

    •  baseless accusations #... (0+ / 0-)

      How exactly is this spam?
      What am I selling?
      What is my commercial interest?
      Helping millions of unemployed and exposing government errors/cover-up gets me what exactly?

      I could be working on my own legal action...but I did manage to get my ARRA funds back and have kept them so far. Instead of trying to make a buck for myself, I have chosen to help the many unemployed who have contacted me and begged for help. I have those emails too if you want to ignore them and call them spam. I am sure the unemployed would appreciate your invaluable input since you seem to know so much about the subject.

      You know the unemployed are not hoarding those funds. That money goes directly back into the economy. You don't want that, if this error is exposed and causes a massive re-recovery surge of funds (lump sum back-payments no less)?

      Is asking the government to explain a serious implementation contradiction/error affecting $97,433,246,688 in ARRA funds not on "your agenda"? Do we not do that anymore in this country? You do know that neither regular unemployment nor the original state extended benefits work this way ("multiple EUC claims")?

      Would anyone prefer one of the many opposite party members from the Department of Labor to have given this information to the GOP, resulting in an "October Surprise" of epic proportions? This is why I am trying to shake the Obama Administration awake, or sway them from any course that would cause them to lose the election. I see the Department of Labor as the bad guy here. I hope the White House has minimal involvement.

      Those seeking election and re-election are talking a great deal about the unemployment rate, the recovery and the stimulus. EUC08 is right in the middle of all of those.

      You and Second Gen, are just looking like the loon-bat you are trying to make me out as...do your homework (your comments so far anyway).

      Refute me.
      Otherwise spam on for all to watch.

  •  Can you summarize in (1+ / 0-)
    Recommended by:
    Churchill

    maybe 3 to 4 sentences what you are complaining about?

    The banks have a stranglehold on the political process. Mike Whitney

    by dfarrah on Sat Aug 18, 2012 at 05:07:27 PM PDT

    •  there is no easy 140 character or less (0+ / 0-)

      summation for you. I have tried short. I have tried long. I would paint it red white and blue if that would get people's attention better. I am just the investigator...but I will continue to try.

      1. I was denied ARRA funds last year.

      2. I discovered evidence, in plain sight,  that shows the DOL EUC08 guidelines for these ARRA funds are non-compliant with federal regulations regarding "multiple EUC claims".

      3. Using this evidence I won funds back on Appeal in California with the CUIAB and had the incorrect error based determinations reversed.

      4. The appeal victory proves errors exists in EUC08 Implementation that violate 20 CFR 615.5(2), 20 CFR 612.2 (c)(2) and 20 CFR 615.2(h)(1)(2). The case still stands and payments still continue uninterrupted to this day.

      5. These implementation errors affect millions of claimants and billions of ARRA dollars nationwide.

      6. Much effort has been made to report this to our government via precedent request for the appeal, complaints to the involved agencies, requests for oversight, and via the recovery fraud complaint that was filed.

      7. The government would not respond, except to delay and cover up their trail.

      8. The government wants to refute this evidence and appeal victory but cannot. They tried and failed. The initial FOIA requests from the DOL OIG and the RATB show this clearly.

      9. In the course of ignoring my requests and trying to stop my case from becoming a precedent, they may have violated many rights, laws and regulations.

      10. FOIA and Privacy Act documents back this up and show many high level and high priority communications among agency heads and their  respective legal counsels over many months. This is the same time period I filed complaints and requested oversight, but got no response.

      11. I am still investigating and uncovering more. Multiple FOIA, Privacy Act and Presidential Records request are pending.

      Read through the links and the rest of my "story" no matter how painful it may be for you. Ask me questions. Test me. Fire away...

      •  It's just too much to wade through. (1+ / 0-)
        Recommended by:
        Churchill

        Okay, so you received the benefits that you were entitled to.  And the government is not going to try to recover any funds from you, is that correct?

        Now what exactly are you trying to do.  Ensure that other claimants get what is due to them?  Because it sounds like what you've done has already caused agency head to look into the matter, even if it is going at a snail's pace.

        The banks have a stranglehold on the political process. Mike Whitney

        by dfarrah on Sat Aug 18, 2012 at 05:45:37 PM PDT

        [ Parent ]

        •  So you won't read the material? (0+ / 0-)

          Okay then...I'm the new kid, so I will face the bullies. But good luck trying to get my lunch money...

          Yes. Guilty as charged with no due process. I am trying to get billions of dollars back for millions of struggling unemployed workers and families who are the victims of not only improper determinations and payments, but also faulty adjudication (all based on the errors in the UIPL Q&A sections).

          This money is not just for them. It goes right back into the economy. There is also an overpayment issue to deal with and the government had better be fair to those "lucky ones" they misinformed for more than four years.

          As for my ARRA funds, EDD and the CUIAB in California lost against me. They cannot recover the funds from me even though they would like to in order to support their incorrect implementation for these ARRA emergency designated funds. There is a small problem with the fact that the Feds REFUSE to pay me in support of CUIAB Case No A0-265448 (see below). Cali is paying me out of their state funds, to cover my federal EUC08 account, because of my appeal victory that they could not overturn.

          This is "the" definition of improper payments under the Improper Payment Act. If I won an EUC08 case against the feds faulty EUC08 implementation, then they have to pay me federal funds. But, my legal issues out of this take a back burner. Those denied emergency funds need them back before I even think about trying to spend years suing the feds for what they pulled on me (all administrative remedies are not quite at their final end for me...but close).

          The 2/7 an 2/14/12 letters I uncovered show that all agencies wanted overturn my case. They never took it to court despite saying that the decision was "contrary to federal law". The Feds cannot recover funds from me, despite trying to threaten California into do so, and are claiming that their UIPL guidelines ARE THE LAW (above the federal regulations). Read the letters and you will see the Feds demanded that no precedent be set whether they could overturn my case or not.

          This federal agency was caught messing in a state determination matter (a precedent decision that would directly affect their EUC08 implementation). They were caught making threats about state determinations, payments and adjudications. The even threatened millions of other claimants over my precedent request ("...end of the EUC08 program in California"). The DOL ETA states clearly on their webpages and elsewhere that they have no authority to do this:

          Benefit Denials
          "Please note that the Federal Government has no authority to intervene in individual claims for benefits."
          So at a very minimum, these actions from the 2/7/12 letter I discovered via FOIA, would be an "abuse of authority" by the Department of Labor Employment & Training Administration would they not? (getting involved in my CUIAB case in the way they have and threatening other claimants over it).
          Thank you FOIA. This is right from the mouth of Todd Yamamoto, DOL ETA Region 6 San Francisco on 2/7/12:

          "I am writing to request the state to take actions set forth below to remedy this problem."

          "Since the CUIAB's decision is inconsistent with this UIPL, the agreement requires the EDD to appeal the CUIAB's decision..."

          "If there is no reversal of this decision, then the EDD is not to use the CUIAB's decision as precedent in making future determinations of the eligibility for EUC08. Using this decision as precedent will result in the termination of the Agreement with the Secretary of Labor which will require the end of the EUC08 program in California. In addition, any EUC08 benefits incorrectly paid as the result of no reversal of the decision will result in disallowed costs under any audit."

          EDD Pam Harris and CUIAB Chair Robert Dresser (the judge in my appeal case), responded back to the DOL ETA on 2/14/12. They said:
          "2. The decision in Case No. A0-265448 will not be adopted by the CUIAB as a precedent.
          3. Any and all benefits paid in error to xxxxx pursuant to Case No. A0-265448 will be paid without the use of federal funds."

          "It is our understanding that with these assurances it will not be necessary to pursue further action in court to seek the overturn of Case No. A0-265448. Thank you for helping us achieve a satisfactory resolution to this matter."

          No review process for the precedent. No mention of 20 CFR 615 that won my appeal case in either letter. No reference to any US Law, Code, Statute nor regulation. The same UIPLs I proved had non-compliant errors, that were the basis for my appeal victory in the first place, where the only "federal law" mentioned by any party.

          But, when I requested oversight and an investigation from the DOL Office of Inspector General in this same time period, this is what I was told in an email on 2/17/12 by Eder Marcus:

          "The Office of Audit has reported it will not pursue your complaint.  The DOL-OIG does not typically initiate investigations or directly intervene in complaints related to the handling, processing and/or adjudication of unemployment claims or benefits determinations, such as those you have reported."
          I have the emails from FOIA/Privacy Act requests (lots of them). There is no investigation going at a snails pace. There is a cover up going on and it is moving very fast to subvert most of what I have tried to do ever since I won that appeal case.

          The emails I have clearly show communications labeled "high priority", sharing my evidence, complaints and public disclosure amongst the heads of the agencies and their respective legal counsel. I have only been allowed to see the "lower level" communications ( a violation of FOIA and the Privacy Act). I am appealing the earlier FOIAs to get the "upper management" side of these conversations (#688882 - Gay Gilbert, Hilda Solis, ETLS, Daniel Petrole among others). They are of course trying to stop me from doing that (White House FOIA #12-167/12-168 are still within the 20 day time limit).

          I know it is a great deal to swallow. Trust me I know better than anyone else. I invite you to read the material. There is something very wrong about how our government has been acting throughout this whole affair. They are violating FOIA, ignoring oversight under three federal laws (ARRA, Improper Payments and IG Act), while never refuting the evidence once. They don't even try to come up with an excuse. FOIA/Privacy Act documents show all the involved agencies sharing evidence and keeping each other up to date about my complaints, public concerns and media disclosure.

          Oh yea...and the EUC08 program has a major implementation error. The "Multiple EUC Claims" Q&As seem to have no basis in any factual law. This agency feels they are above those laws and that their faulty guidelines trump 20 CFR 615. They are wrong. Their own compliance material proves this.

          The DOL OIG is supposedly separate from the DOL ETA in investigations right? The Recovery Board should not be acting this way either, should they? Can anyone explain why the accused parties in an ARRA Fraud investigation are allowed to share evidence and dictate how the investigation against them is run? Is that how it is supposed to work? Would an ARRA "outside" contractor accused of Fraud/Improper Payments get such a luxury from the Feds?

          So. Is this spam? Or are we looking at a discovery of some serious abuses of authority by the Department of Labor? What about everything else? Have time to take a read now?

          Can I at least get my lunch money back?

  •  Okay, one more time. (1+ / 0-)
    Recommended by:
    Churchill

    What are you complaining about?

    Were you kicked out of  a program for which you should not have been kicked out of?

    Were you given payments that you shouldn't have received?

    What's the deal?

    The banks have a stranglehold on the political process. Mike Whitney

    by dfarrah on Sat Aug 18, 2012 at 05:10:10 PM PDT

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